Based on our assessment of survey responses for calendar 2018, we implemented due diligence measures with respect to suppliers who (1) may have manufactured retail merchandise for us containing Subject Minerals and (2) had not reliably demonstrated that the Subject Minerals were not sourced from Covered Countries. These measures included:
• Performance of targeted follow-up with suppliers who did not initially respond to the survey.
• Verification of information regarding smelters and refiners provided by our suppliers with the RMI’s list of conformant smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we validated one supplier’s response that the Subject Minerals in all the products it supplied to us did not originate in the Covered Countries, and we determined that the smelters and refiners in the Covered Countries that were identified by three of our suppliers were all compliant with the RMI’s RMAP.
• Requests for additional information (e.g., certificate of material analysis and bill of materials) from suppliers whom we determined supplied items containing Subject Minerals and who provided information that was insufficient for us to determine reliably the source of Subject Minerals in retail merchandise manufactured for us. Through this effort, we were able to obtain more reliable information about the presence of Subject Minerals in items supplied to us and obtain additional smelter and refiner information.
• Encouragement of suppliers who provided insufficient information regarding their supply chain to develop more robust supply chain information programs and policies.
• Encouragement of suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-compliant smelters or refiners to source from smelters and refiners who are compliant with the relevant RMAP assessment protocols of the RMI, or from another accredited organization."