Document
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
___________________________
FORM SD
Specialized Disclosure Report
___________________________
VERA BRADLEY, INC.
(Exact name of registrant as specified in its charter)
___________________________
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Indiana | | 001-34918 | | 27-2935063 |
(State or Other Jurisdiction of Incorporation) | | (Commission File Number) | | (IRS Employer Identification No.) |
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12420 Stonebridge Road, Roanoke, Indiana | | 46783 |
(Address of Principal Executive Offices) | | (Zip Code) |
John Enwright, Chief Financial Officer (877) 708-8372
(Name and telephone number, including area code, of the person to contact in connection with this report)
___________________________
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
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Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
A copy of Vera Bradley, Inc.'s Conflict Minerals Report is filed as Exhibit 1.01 hereto. This Specialized Disclosure Form and the associated Conflict Minerals Report are posted in the “Corporate Information” section, under “Supply Chain,” of the Company’s website at www.verabradley.com.
Item 1.02 Exhibit
See Exhibit 1.01 to this specialized disclosure report, incorporated herein by reference.
Section 2 - Exhibits
Item 2.01 Exhibits
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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| | | | Vera Bradley, Inc. |
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Date: May 31, 2022 | | | By: | /s/ John Enwright |
| | | John Enwright Chief Financial Officer |
DocumentExhibit 1.01
Conflict Minerals Report of Vera Bradley, Inc.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934
This is the Conflict Minerals Report of Vera Bradley, Inc. for calendar year 2021 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). The terms “Company” and “Vera Bradley” refer to Vera Bradley, Inc. and its subsidiaries.
1.Introduction
Vera Bradley manufactures or contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”), such as handbags, accessories, and luggage and travel items. For the 2021 calendar year, the Company determined that certain of its products may have zippers, fasteners or other components and materials, which are necessary to the production or functionality of its products, that may contain 3TG. Therefore, Vera Bradley conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs that may be in its products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”). Based on its RCOI, Vera Bradley believes that its products contain 3TGs that may have originated in the Covered Countries and, therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (from here on referred to “Section 1502 of the Dodd-Frank Act” or “the Rule”), performed due diligence on the source and chain of custody of the 3TGs in question to determine whether its products are “DRC Conflict Free.” The Company designed its due diligence measures to conform, in all material respects, with the internationally recognized due diligence framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).
Vera Bradley is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, the Company has put into place a due diligence program to contribute towards upholding human rights and responsible practices across the supply chain.
2.Reasonable Country of Origin Inquiry
To determine whether necessary 3TGs in products originated in Covered Countries, Vera Bradley retained Assent Compliance (“Assent”), a third-party service provider, to assist in reviewing the supply chain and identifying risks. The Company provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager (“ACM”).
To collect data on the materials’ sources of origin within the supply chain, Vera Bradley utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.0 or higher to conduct a survey of all in-scope suppliers.
During the supplier survey, the Company contacted suppliers via the ACM, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.
Via the ACM and the Assent team, the Company requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency. Vera Bradley directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that these suppliers complete the CMRT and submit it to Assent.
The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT, which help to identify areas that require further classification or risk assessment, and are designed to facilitate an understanding of the due-diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, Vera Bradley tracks program gaps to account for future improvement opportunities. As of May 16, 2022, there were 12 invalid supplier submissions that could not be corrected.
As of May 16, 2022, there were 66 suppliers in scope of the conflict minerals program for the 2021 reporting year and 47 of such suppliers provided a completed CMRT. Vera Bradley’s total response rate for the 2021 reporting year was 71%. These metrics are summarized in the table below in order to assess progress from prior year:
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Year | Suppliers in Scope | % Responded |
RY 2020 | 57 | 79% |
RY 2021 | 66 | 71% |
Based on the findings through the RCOI process, the Company was able to determine the countries of origin for a large portion of the 3TGs in its products. As such, Vera Bradley continued to perform further due diligence on the source and chain of custody of the minerals in question.
3.Product Description
Vera Bradley contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”), such as handbags, accessories and luggage and travel items. The Company determined that certain of its products may have zippers, fasteners or other components and materials, which are necessary to the production or functionality of its products, that may contain 3TG. As these materials are necessary to Vera Bradley's products, the Company is dedicated to tracing the origin of these metals to safeguard that our sourcing practices do not support conflict or human rights abuses in the Democratic Republic of Congo (“DRC”) and adjoining countries.
4.Design of Due Diligence Measures
Vera Bradley designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to identify continuous improvement opportunities.
Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by the Company. However, through continued outreach and process validation, the Company believes its processes align with industry standards and market expectations for downstream companies’ due diligence.
5.Due Diligence Measures Performed
Internal Compliance Team
Vera Bradley established a cross-functional Compliance Team led by its Director of Global Quality & Compliance. The Compliance Team is responsible for implementing the conflict minerals compliance strategy and briefing senior management about the results of these due diligence efforts.
The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company will undertake with suppliers in regards to conflict minerals.
The Company leverages Assent’s Managed Services in order to work with dedicated program specialists
who support Vera Bradley’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.
Control Systems
The Company expects all suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to Vera Bradley are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. The Company relies on direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied, including sources of 3TGs that are supplied to them from lower-tier suppliers.
Vera Bradley’s Supplier Code of Conduct applies to all direct suppliers and outlines certain expected behaviors and practices. This code of conduct is based on industry and internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Supplier Code of Conduct is provided to all direct suppliers. If a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. The Supplier Code of Conduct is reviewed annually in an effort to ensure that it continues to align with industry best practices.
Supplier Engagement
Vera Bradley believes that it has a strong relationship with its Tier 1 direct suppliers. As an extremely important part of the supply chain, Vera Bradley has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access to a free platform to upload their CMRTs, help desk support and other multilingual resources. Vera Bradley’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.
The Company engages with suppliers directly to request a valid CMRT for the products that they supply to the Company and continues to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources.
The Company believes that the combination of the Supplier Code of Conduct and direct engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.
Grievance Mechanisms
The Company established grievance mechanisms whereby employees and suppliers can report violations of Vera Bradley’s policies, including conflict minerals. Suppliers and others outside of Vera Bradley may contact the Company, including to report grievances, via a dedicated email address that is published. In addition, employees may anonymously report suspected violations. Any violations are reported to corporate management.
Violations or grievances at the industry level can be reported to the Responsible Minerals Initiative (the “RMI”) directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
Maintain Records
The Company has adopted a policy to retain relevant documentation for a period of five years. Through Assent, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. The Company stores all of the information and findings from this process in an auditable database.
6.Identifying Risks in the Supply Chain
Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the company level. In those cases where a company-level CMRT (such as when a company declares there are no 3TGs in any of its products) is submitted, Vera Bradley is unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied to the Company.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners consolidated by the RMI in order to determine that the facilities met the recognized definition of a 3TG processing facility that was operational during the 2021 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). Vera Bradley does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed an RMAP audit are considered to be DRC-conflict free. In cases where the smelters due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
•Geographic proximity to the DRC and covered countries.
•Known mineral source country of origin.
•RMAP audit status.
•Credible evidence of unethical or conflict sourcing.
•Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to Vera Bradley. Additional escalation may in some cases be necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
7.Design and Implement a Strategy to Respond to Risks
Together with Assent, Vera Bradley developed processes to assess and respond to the risks identified in the supply chain. Vera Bradley has a risk management plan, through which the conflict minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and the Company’s expectations.
Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. The Company engages suppliers believed to be supplying 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.
In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, the Company will assess the feasibility of replacing that supplier. The results of the program and risk assessment are shared with the Compliance Team and the Vera Bradley leadership team to ensure transparency within the Company.
8.Identified Smelters or Refiners (“SORs”)
Based on survey responses received from Vera Bradley’s suppliers, Vera Bradley was not able to identify all SORs for all 3TG that may be used in its products. Vera Bradley has identified the SORs listed below that may have processed 3TG used in its products. SORs with a “Not Applicable” RMI Audit Status have not been verified to be legitimate SORs.
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Metal | Smelter Name | Country | RMI Audit Status |
Gold | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Conformant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant |
Gold | Argor-Heraeus S.A. | Switzerland | Conformant |
Gold | Asahi Pretec Corp. | Japan | Conformant |
Gold | Asaka Riken Co., Ltd. | Japan | Conformant |
Gold | Aurubis AG | Germany | Conformant |
Gold | Boliden AB | Sweden | Conformant |
Gold | C. Hafner GmbH + Co. KG | Germany | Conformant |
Gold | Chimet S.p.A. | Italy | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
Tin | Alpha | United States Of America | Conformant |
Gold | Dowa | Japan | Conformant |
Tin | Fenix Metals | Poland | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
Gold | Heimerle + Meule GmbH | Germany | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | China | Conformant |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant |
Gold | Istanbul Gold Refinery | Turkey | Conformant |
Tungsten | Japan New Metals Co., Ltd. | Japan | Conformant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Conformant |
Gold | Asahi Refining USA Inc. | United States Of America | Conformant |
Gold | Asahi Refining Canada Ltd. | Canada | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
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Metal | Smelter Name | Country | RMI Audit Status |
Gold | Kennecott Utah Copper LLC | United States Of America | Conformant |
Tin | China Tin Group Co., Ltd. | China | Conformant |
Gold | LS-NIKKO Copper Inc. | Korea, Republic Of | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | Japan | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | China | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | China | Conformant |
Gold | Metalor Technologies S.A. | Switzerland | Conformant |
Gold | Metalor USA Refining Corporation | United States Of America | Conformant |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Conformant |
Tin | Mineracao Taboca S.A. | Brazil | Conformant |
Tin | Minsur | Peru | Conformant |
Gold | Mitsubishi Materials Corporation | Japan | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant |
Gold | Nihon Material Co., Ltd. | Japan | Conformant |
Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) | Conformant |
Gold | PAMP S.A. | Switzerland | Conformant |
Tin | PT Mitra Stania Prima | Indonesia | Conformant |
Tin | PT Refined Bangka Tin | Indonesia | Conformant |
Tin | PT Timah Tbk Kundur | Indonesia | Conformant |
Tin | PT Timah Tbk Mentok | Indonesia | Conformant |
Gold | Royal Canadian Mint | Canada | Conformant |
Tin | Rui Da Hung | Taiwan, Province Of China | Conformant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant |
Tin | Soft Metais Ltda. | Brazil | Conformant |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
Tin | Thaisarco | Thailand | Conformant |
Gold | Tokuriki Honten Co., Ltd. | Japan | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant |
Gold | United Precious Metal Refining, Inc. | United States Of America | Conformant |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | China | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant |
Tin | Melt Metais e Ligas S.A. | Brazil | Not Enrolled |
Tin | Metallo Belgium N.V. | Belgium | Conformant |
Tin | Metallo Spain S.L.U. | Spain | Conformant |
Gold | Advanced Chemical Company | United States Of America | Conformant |
Tungsten | Kennametal Huntsville | United States Of America | Conformant |
Tungsten | Global Tungsten & Powders Corp. | United States Of America | Conformant |
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Metal | Smelter Name | Country | RMI Audit Status |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Conformant |
Tantalum | Telex Metals | United States Of America | Conformant |
Gold | Geib Refining Corporation | United States Of America | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | Germany | Conformant |
Tantalum | H.C. Starck Co., Ltd. | Thailand | Conformant |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Conformant |
Tantalum | H.C. Starck Ltd. | Japan | Conformant |
Tantalum | Global Advanced Metals Boyertown | United States Of America | Conformant |
Gold | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
Tin | Metallic Resources, Inc. | United States Of America | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant |
Tin | Mitsubishi Materials Corporation | Japan | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | China | Conformant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
Tungsten | A.L.M.T. Corp. | Japan | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
Gold | Cendres + Metaux S.A. | Switzerland | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant |
Gold | Chugai Mining | Japan | Conformant |
Gold | DSC (Do Sung Corporation) | Korea, Republic Of | Conformant |
Tin | Dowa | Japan | Conformant |
Gold | Eco-System Recycling Co., Ltd. East Plant | Japan | Conformant |
Tin | EM Vinto | Bolivia (Plurinational State Of) | Conformant |
Tantalum | F&X Electro-Materials Ltd. | China | Conformant |
Gold | OJSC Novosibirsk Refinery | Russian Federation | Non Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Conformant |
Gold | LT Metal Ltd. | Korea, Republic Of | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant |
Gold | Japan Mint | Japan | Conformant |
Gold | Jiangxi Copper Co., Ltd. | China | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | China | Conformant |
Gold | JSC Uralelectromed | Russian Federation | Non Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | China | Non Conformant |
Gold | Kazzinc | Kazakhstan | Conformant |
Tungsten | Kennametal Fallon | United States Of America | Conformant |
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Metal | Smelter Name | Country | RMI Audit Status |
Gold | Kojima Chemicals Co., Ltd. | Japan | Conformant |
Tantalum | LSM Brasil S.A. | Brazil | Conformant |
Gold | Materion | United States Of America | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | India | Conformant |
Tantalum | Mineracao Taboca S.A. | Brazil | Conformant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
Tantalum | NPM Silmet AS | Estonia | Conformant |
Gold | Moscow Special Alloys Processing Plant | Russian Federation | Non Conformant |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Non Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Non Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant |
Tin | PT Artha Cipta Langgeng | Indonesia | Conformant |
Tin | PT Babel Surya Alam Lestari | Indonesia | Conformant |
Tin | PT Prima Timah Utama | Indonesia | Conformant |
Tin | PT Stanindo Inti Perkasa | Indonesia | Conformant |
Tin | PT Tinindo Inter Nusa | Indonesia | Conformant |
Gold | PX Precinox S.A. | Switzerland | Conformant |
Tantalum | QuantumClean | United States Of America | Conformant |
Gold | Rand Refinery (Pty) Ltd. | South Africa | Conformant |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
Gold | Samduck Precious Metals | Korea, Republic Of | Conformant |
Gold | SEMPSA Joyeria Plateria S.A. | Spain | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Non Conformant |
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Conformant |
Tantalum | Taki Chemical Co., Ltd. | Japan | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Conformant |
Gold | Torecom | Korea, Republic Of | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
Gold | Valcambi S.A. | Switzerland | Conformant |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant |
Tungsten | Wolfram Bergbau und Hutten AG | Austria | Conformant |
Gold | Yamakin Co., Ltd. | Japan | Conformant |
Gold | Yokohama Metal Co., Ltd. | Japan | Conformant |
Tin | Yunnan Tin Company Limited | China | Conformant |
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Metal | Smelter Name | Country | RMI Audit Status |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant |
Gold | SAFINA A.S. | Czechia | Conformant |
Gold | Umicore Precious Metals Thailand | Thailand | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
Tin | CV Venus Inti Perkasa | Indonesia | Active |
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
Tantalum | D Block Metals, LLC | United States Of America | Conformant |
Tantalum | FIR Metals & Resource Ltd. | China | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | India | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant |
Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
Tantalum | KEMET Blue Metals | Mexico | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | Conformant |
Tantalum | H.C. Starck Inc. | United States Of America | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant |
Tantalum | Global Advanced Metals Aizu | Japan | Conformant |
Gold | Emirates Gold DMCC | United Arab Emirates | Conformant |
Gold | T.C.A S.p.A | Italy | Conformant |
Gold | REMONDIS PMR B.V. | Netherlands | Conformant |
Tungsten | Niagara Refining LLC | United States Of America | Conformant |
Gold | Korea Zinc Co., Ltd. | Korea, Republic Of | Conformant |
Gold | Marsam Metals | Brazil | Conformant |
Gold | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
Tungsten | China Molybdenum Co., Ltd. | China | Conformant |
| | | | | | | | | | | |
Metal | Smelter Name | Country | RMI Audit Status |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China | Conformant |
Tungsten | Hydrometallurg, JSC | Russian Federation | Conformant |
Tin | Resind Industria e Comercio Ltda. | Brazil | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | Brazil | Conformant |
Tungsten | Unecha Refractory metals plant | Russian Federation | Conformant |
Gold | SAAMP | France | Conformant |
Gold | L'Orfebre S.A. | Andorra | Conformant |
Gold | 8853 S.p.A. | Italy | Conformant |
Gold | Italpreziosi | Italy | Conformant |
Gold | WIELAND Edelmetalle GmbH | Germany | Conformant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Conformant |
Tungsten | ACL Metais Eireli | Brazil | Conformant |
Tin | PT Menara Cipta Mulia | Indonesia | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | China | Conformant |
Tungsten | Moliren Ltd. | Russian Federation | Conformant |
Gold | Bangalore Refinery | India | Conformant |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of | Conformant |
Gold | Planta Recuperadora de Metales SpA | Chile | Conformant |
Gold | Safimet S.p.A | Italy | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant |
Tin | PT Bangka Serumpun | Indonesia | Conformant |
Tin | Tin Technology & Refining | United States Of America | Conformant |
Tin | Ma'anshan Weitai Tin Co., Ltd. | China | Conformant |
Tin | PT Rajawali Rimba Perkasa | Indonesia | Conformant |
Tin | Luna Smelter, Ltd. | Rwanda | Conformant |
Tungsten | KGETS Co., Ltd. | Korea, Republic Of | Conformant |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Non Conformant |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China | Conformant |
Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | Conformant |
Gold | Eco-System Recycling Co., Ltd. North Plant | Japan | Conformant |
Gold | Eco-System Recycling Co., Ltd. West Plant | Japan | Conformant |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of | Not Enrolled |
Gold | Sabin Metal Corp. | United States Of America | Not Enrolled |
Gold | Caridad | Mexico | Not Enrolled |
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | Conformant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Not Enrolled |
Gold | Yunnan Copper Industry Co., Ltd. | China | Not Enrolled |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China | Not Enrolled |
| | | | | | | | | | | |
Metal | Smelter Name | Country | RMI Audit Status |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Not Enrolled |
Tin | Estanho de Rondonia S.A. | Brazil | Conformant |
Gold | Refinery of Seemine Gold Co., Ltd. | China | Not Enrolled |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Not Enrolled |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Not Enrolled |
Gold | Hunan Chenzhou Mining Co., Ltd. | China | Not Enrolled |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | Not Enrolled |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Not Enrolled |
Gold | Kazakhmys Smelting LLC | Kazakhstan | Not Enrolled |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Non Conformant |
Gold | L'azurde Company For Jewelry | Saudi Arabia | Not Enrolled |
Gold | Lingbao Gold Co., Ltd. | China | Not Enrolled |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Not Enrolled |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Not Enrolled |
Tin | Novosibirsk Processing Plant Ltd. | Russian Federation | Conformant |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Not Enrolled |
Tin | PT Babel Inti Perkasa | Indonesia | Conformant |
Tin | PT Belitung Industri Sejahtera | Indonesia | Not Enrolled |
Tin | PT Bukit Timah | Indonesia | Conformant |
Tin | PT Panca Mega Persada | Indonesia | Not Enrolled |
Tin | PT Sariwiguna Binasentosa | Indonesia | Conformant |
Tin | PT Timah Nusantara | Indonesia | Active |
Gold | Samwon Metals Corp. | Korea, Republic Of | Not Enrolled |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Not Enrolled |
Gold | Super Dragon Technology Co., Ltd. | China | Not Enrolled |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Not Enrolled |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Not Enrolled |
Tin | VQB Mineral and Trading Group JSC | Viet Nam | Not Enrolled |
Gold | Morris and Watson | New Zealand | Not Enrolled |
Gold | Guangdong Jinding Gold Limited | China | Not Enrolled |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Not Enrolled |
Tin | PT Tirus Putra Mandiri | Indonesia | Not Enrolled |
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | Not Enrolled |
Gold | Shandong Humon Smelting Co., Ltd. | China | Not Enrolled |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | Not Enrolled |
Gold | International Precious Metal Refiners | United Arab Emirates | Not Enrolled |
Gold | Kaloti Precious Metals | United Arab Emirates | Not Enrolled |
Gold | Sudan Gold Refinery | Sudan | Not Enrolled |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non Conformant |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | Not Enrolled |
Gold | Fujairah Gold FZC | United Arab Emirates | Not Enrolled |
| | | | | | | | | | | |
Metal | Smelter Name | Country | RMI Audit Status |
Gold | Industrial Refining Company | Belgium | Non Conformant |
Gold | Shirpur Gold Refinery Ltd. | India | Not Enrolled |
Tin | PT Cipta Persada Mulia | Indonesia | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Not Enrolled |
Gold | Abington Reldan Metals, LLC | United States Of America | Active |
Tin | Super Ligas | Brazil | Active |
Tin | PT Sukses Inti Makmur | Indonesia | Active |
Gold | AU Traders and Refiners | South Africa | Non Conformant |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | Active |
Gold | Sai Refinery | India | Not Enrolled |
Gold | Modeltech Sdn Bhd | Malaysia | Non Conformant |
Tin | Modeltech Sdn Bhd | Malaysia | Non Conformant |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | Not Enrolled |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany | Not Enrolled |
Gold | Pease & Curren | United States Of America | Not Enrolled |
Gold | JALAN & Company | India | Not Enrolled |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania | Not Enrolled |
Gold | African Gold Refinery | Uganda | Not Enrolled |
Gold | Gold Coast Refinery | Ghana | Not Enrolled |
Gold | NH Recytech Company | Korea, Republic Of | Conformant |
Tin | Pongpipat Company Limited | Myanmar | Not Enrolled |
Gold | QG Refining, LLC | United States Of America | Not Enrolled |
Gold | Dijllah Gold Refinery FZC | United Arab Emirates | Not Enrolled |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Non Conformant |
Gold | CGR Metalloys Pvt Ltd. | India | Not Enrolled |
Gold | Sovereign Metals | India | Not Enrolled |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | Conformant |
Tin | Precious Minerals and Smelting Limited | India | Non Conformant |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Not Enrolled |
Tungsten | NPP Tyazhmetprom LLC | Russian Federation | Active |
Tungsten | GEM Co., Ltd. | China | Conformant |
Gold | C.I Metales Procesados Industriales SAS | Colombia | Active |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Active |
Tin | PT Mitra Sukses Globalindo | Indonesia | Active |
Gold | Augmont Enterprises Private Limited | India | Active |
Gold | Kundan Care Products Ltd. | India | Not Enrolled |
Tungsten | Cronimet Brasil Ltda | Brazil | Conformant |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Active |
Gold | Emerald Jewel Industry India Limited (Unit 1) | India | Not Enrolled |
Gold | Emerald Jewel Industry India Limited (Unit 2) | India | Not Enrolled |
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | Not Enrolled |
Gold | Emerald Jewel Industry India Limited (Unit 4) | India | Not Enrolled |
Gold | K.A. Rasmussen | Norway | Not Enrolled |
Gold | Alexy Metals | United States Of America | Active |
| | | | | | | | | | | |
Metal | Smelter Name | Country | RMI Audit Status |
Tin | CRM Synergies | Spain | Conformant |
Gold | Sancus ZFS (L’Orfebre, SA) | Colombia | Active |
Gold | Sellem Industries Ltd. | Mauritania | Not Enrolled |
Gold | MD Overseas | India | Not Enrolled |
Tungsten | Artek LLC | Russian Federation | Not Enrolled |
Gold | Metallix Refining Inc. | United States Of America | Not Enrolled |
Gold | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China | Conformant |
Tungsten | Fujian Xinlu Tungsten | China | Conformant |
Tungsten | OOO “Technolom” 2 | Russian Federation | Active |
Tungsten | OOO “Technolom” 1 | Russian Federation | Active |
Gold | WEEEREFINING | France | Active |
Gold | Value Trading | Belgium | Not Enrolled |
Tin | PT Aries Kencana Sejahtera | Indonesia | Active |
Tin | PT Tommy Utama | Indonesia | Not Enrolled |
9.Independent Private Sector Audit
Vera Bradley does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, the Company relies on third-party audits of smelters and refiners conducted as part of the RMAP. The RMAP uses independent private-sector auditors, and audits the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.
Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. Vera Bradley is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance.
10.Forward Looking Statements
This CMR contains forward-looking statements that are subject to risks and uncertainties. All statements other than statements of historical or current fact included in this report are forward-looking statements. Forward-looking statements refer to our current expectations and projections. You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These statements may include words such as “anticipate,” “estimate,” “expect,” “project,” “plan,” “intend,” “believe,” “may,” “might,” “will,” “should,” “can have,” and “likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. All forward-looking statements are subject to risks and uncertainties that may cause actual results to differ materially from those that we expected. The Company undertakes no obligation to update or revise any forward-looking statements to reflect subsequent events or circumstances.