Apple filed its conflict minerals disclosure today with the United States Securities and Exchange Commission and in it detailed its process of ethical sourcing of minerals used in Apple products between January 1, 2013 and December 31, 2013.

Apple noted that it has identified 205 smelters and refiners of the “subject materials” that it works to ensure are conflict-free, but also admits it “does not have sufficient information to conclusively determine the country of origin of the Subject Minerals in its products or whether the Subject Minerals are from recycled or scrap sources.”

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In February 2014, Apple announced that all tantalum smelters in its supply chain had been designated “conflict free” by the CFSP or an equivalent independent third-party audit program. Apple is also continuing to increase the number of verified smelters and refiners for tin, tungsten and gold, and the majority of the smelters and refiners in Apple’s supply chain are either designated “conflict free” by the CFSP or an equivalent independent third-party audit program or are undergoing conflict minerals audits. Apple will keep up the pressure until all unaudited smelters and refiners are either certified or removed from Apple’s supply chain.

Apple says that of those 205 smelters and refiners, 21 were sources of Subject Minerals from the Democratic Republic of the Congo or adjoining regions, 17 were CFSP-compliant , and 4 are yet to be audited. Apple also detailed what it plans to do in order to keep improving its process:

Risk Mitigation and Future Due Diligence Measures

Apple will keep improving its due diligence measures by taking the following steps, among others:

  • Continuing to drive suppliers to ensure that their smelters and refiners obtain a “conflict free” designation from an independent third-party auditor of Subject Minerals;
  • Continuing to pressure smelters and refiners directly to become verified as having “conflict free” sources of Subject Minerals, or have them removed from Apple’s supply chain; and
  • Continuing to drive its suppliers to obtain current, accurate, and complete information about their smelters and refiners of Subject Minerals.

Some of the information in today’s filing was previously revealed in Apple’s 2014 environmental report, including the announcement that “all tantalum smelters in its supply chain had been designated “conflict free” by the CFSP.” Apple today said it would continue to increase the amount of smelters and refiners designated conflict-free for tin, tungsten and gold used in products and “keep up the pressure until all unaudited smelters and refiners are either certified or removed from Apple’s supply chain.”

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