MRVL Marvell Technology Inc

 

 

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

Form SD

 

 

SPECIALIZED DISCLOSURE REPORT

 

 

Marvell Technology Group Ltd.

(Exact name of registrant as specified in its charter)

 

 

 

Bermuda		0-30877		77-0481679
(State or other jurisdiction of incorporation or organization)		(Commission File No.)		(I.R.S. Employer Identification No.)

Canon’s Court

22 Victoria Street

Hamilton HM 12, Bermuda

(Address of principal executive offices)

Tom Savage

Vice President, Legal

and Governmental Policy,

General Counsel

(408) 222-9753

(Name and telephone number, including area code, of

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 report applies:

 

x	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period January 1, 2014 to December 31, 2014.

 

 

 

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Item 1.01. Conflict Minerals Disclosure and Report.

Conflict Minerals Disclosure

A copy of the Conflict Minerals Report of Marvell Technology Group Ltd. (the “Company”) for the reporting period January 1, 2014 to December 31, 2014 is filed as Exhibit 1.01 to this specialized disclosure report on Form SD and is also available at the Company’s website at www.marvell.com under the heading “Investor Relations - Corporate Governance and Social Responsibility.”

Item 1.02. Exhibit.

As noted in Item 1.01, the Company is filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Item 2.01. Exhibit.

The following exhibit is filed as a part of this report:

 

Exhibit No.		Description
1.01		Conflict Minerals Report of Marvell Technology Group Ltd. for the reporting period January 1, 2014 to December 31, 2014.

 

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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.

Date: May 29, 2015

 

 

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EXHIBIT INDEX

 

Exhibit No.		Description
1.01		Conflict Minerals Report of Marvell Technology Group Ltd. for the reporting period January 1, 2014 to December 31, 2014.

 

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Exhibit 1.01

MARVELL TECHNOLOGY GROUP LTD.

CONFLICT MINERALS REPORT

(For the reporting period January 1, 2014 to December 31, 2014)

This Conflict Minerals Report (this “Report”) of Marvell Technology Group Ltd. has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934 (collectively, the “Rule”) for the reporting period January 1, 2014 to December 31, 2014.

The Rule imposes certain reporting obligations on Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain certain minerals that are necessary to the functionality or production of their products. The specified minerals, which are collectively referred to in this Report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which the SEC has currently limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. For purposes of this Report, references to “Marvell,” “we,” “us,” “our” or the “Company” mean Marvell Technology Group Ltd. and its consolidated subsidiaries.

To comply with the Rule, we conducted due diligence on the origin, source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture to ascertain whether these Conflict Minerals originated in a Covered Country and financed or benefited armed groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) in any of these countries.

Pursuant to SEC guidance issued April 29, 2014 and the SEC order issued May 2, 2014, Marvell is not required to describe any of its products as “DRC conflict free” (as defined in Section 1, Item 1.01(d)(4) of Form SD), “DRC conflict undeterminable” (as defined in Section 1, Item 1.01(d)(5) of Form SD) or “having not been found to be “DRC conflict free,” and therefore makes no conclusion in this regard in the report presented herein.

I. Marvell and Its Products

We are a fabless provider of high-performance, application-specific standard semiconductor products. Our core strength is the development of complex system-on-a-chip (“SoC”) and System-in-a-Package (SiP”) devices, leveraging our extensive portfolio of intellectual property in the areas of analog, mixed-signal, digital signal processing and embedded and stand-alone integrated circuits. We also develop platforms that we define as integrated hardware along with software that incorporates digital computing technologies designed and configured to provide an optimized computing solution.

Our current product portfolio principally addresses three broad end markets: mobile and wireless, storage and networking.

Mobile and Wireless Products. We offer a broad range of products for the mobile and wireless end market, including integrated communications and applications processors, thin modem devices, connectivity solutions and mobile computing products.

Storage Products. We offer a broad range of integrated data storage products that operate across all major technologies. Our storage products include: hard disk drive controllers, solid-state drive controllers, and integrated SoCs for storage markets.

Networking Products. We offer several families of products supporting the build-out of new network architectures for residential, enterprise and service provider networks. These products include a variety of platform and SoC solutions, as well as switches, transceivers and other connectivity products.

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Other Products. We also offer SoC products that power laser and ink jet printers and multi-function peripherals, as well as our smart home product portfolio, including SoCs and other products designed to enable the next generation of connected consumer platforms.

Products Covered by this Report. All of the products contracted by the Company to be manufactured for which manufacturing was completed during calendar year 2014 consisted of integrated circuits or products incorporating integrated circuits and contained small amounts of gold, tantalum, tin and tungsten. These Conflict Minerals are necessary to the functionality or production of each of our integrated circuit products and components. For purposes of this Report, therefore, “products” refers to the products in the product categories listed above for which the manufacturing was completed during calendar year 2014, and “suppliers” refers to our product suppliers.

II. Manufacturing and Supply Chain

We employ a “fabless” model for the manufacture, assembly and testing of our integrated circuits. We do not own or operate our own foundries or manufacturing facilities. We outsource our integrated circuit manufacturing to third-party foundries, primarily in Asia. We also outsource all product assembly, packaging and testing of our products to several assembly and test subcontractors in Asia.

As a result of our fabless model, we are a downstream actor in a complex supply chain. Our semiconductor products typically contain many parts obtained from a global network of direct suppliers. Furthermore, we often do not have meaningful leverage over upstream actors in the supply chain, as there are multiple tiers of suppliers between us and the ultimate sources of the raw materials used in the manufacture of our integrated circuit products and our other products that incorporate integrated circuits. Raw materials purchased by our direct and indirect suppliers contain gold, tantalum, tin and tungsten obtained from smelters and refiners that, in turn, source those minerals from traders and mines in various countries. Because we do not purchase materials directly from any of these processing facilities, we have relied on our direct suppliers, and on information available from industry sources, for purposes of this Report.

III. Reasonable Country of Origin Inquiry

We requested that our direct suppliers complete in full the Electronics Industry Citizenship Coalition (“EICC”)–Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (the “CMRT”). The CMRT is designed to request from suppliers sufficient information regarding such suppliers’ practices with respect to the sourcing of Conflict Minerals to enable Marvell to comply with its requirements under the Rule.

Based on the results of our reasonable country of origin inquiry (“RCOI”), we are unable to determine whether the Conflict Minerals present in our products originate in the Covered Countries. We are therefore required by the Rule to file with the SEC a Form SD and a Conflict Minerals Report as an exhibit thereto.

IV. Due Diligence Design

On the basis of the information obtained as a result of our RCOI, we conducted a broader due diligence investigation regarding the source and chain of custody of the Conflict Minerals contained in our products. There is significant overlap between our RCOI and due diligence processes, and the due diligence measures that we put in place are an extension of the CMRT-based RCOI process. These due diligence measures have been designed to conform, in all material respects, with the framework specified in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), specifically as the OECD Guidance pertains to downstream purchasers in the minerals supply chain. The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas.

 

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V. Due Diligence Performed

Step 1: Establish Strong Company Management Systems.

 

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Marvell maintains a Policy Statement on Conflict Minerals (the “Conflict Minerals Policy”), which provides that Marvell does not support the use of Conflict Minerals that are mined, transported or traded to fund human rights violations, social unrest, political repression or conflict or the use of metal derived from such Conflict Minerals. The Conflict Minerals Policy has been posted on our website at www.marvell.com under the heading “Investor Relations - Corporate Governance and Social Responsibility.”

 

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Marvell also maintains a Supplier Code of Conduct that, among other things, requires our suppliers to comply with the Conflict Minerals Policy, as well as with the Marvell Code of Ethics and the EICC Code of Conduct. The Supplier Code of Conduct is also posted on our website at www.marvell.com under the heading “Investor Relations - Corporate Governance and Social Responsibility.”

 

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The implementation of Marvell’s RCOI and the conducting of due diligence on the source and chain of custody of Marvell’s necessary Conflict Minerals are managed by a cross-functional Conflict Minerals Working Group under the direction of the Corporate Social Responsibility section of our Legal Department and with oversight by our Corporate Social Responsibility Committee (the “ CSR Committee”). The Conflict Minerals Working Group, comprised of subject matter experts from the Quality Systems group within our Operations organization and from our Legal Department, reports its activities to the CSR Committee at each of its meetings, and a representative of the CSR Committee reports at least once a year to the Audit Committee of our Board of Directors. The CSR Committee includes representatives from our Facilities, Finance, Human Resources, Internal Audit, Legal and Operations Departments.

 

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We used a multi-layer approach to convey our supplier responsibility expectations to our direct suppliers. All of our direct suppliers have been provided with our Conflict Minerals Policy, Supplier Code of Conduct and Product and Manufacturing Specifications, and these documents are provided to new suppliers as part of our Conflict Minerals due diligence process. Marvell’s Product and Manufacturing Specifications contain provisions requiring that suppliers (i) comply with the Conflict Minerals Policy and the Supplier Code of Conduct and (ii) cooperate with Marvell in providing the information required by the CMRT, and also stipulate the consequences of breaching such provisions.

 

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We maintain a data retention policy to retain material conflict-minerals related records electronically for a period of at least five (5) years from the date of creation.

 

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We maintain our Marvell Concern Line, managed by an independent firm, which is available to our employees and the general public to enable them to anonymously ask questions regarding compliance and ethical issues and to report illegal and unethical activities, including general inquiries and grievances. Access to the Marvell Concern Line has been specifically extended to our direct suppliers.

Step 2: Identify and Assess Risk in the Supply Chain.

 

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We received completed CMRTs from 100% of our direct suppliers and used our suppliers’ completed CMRTs to identify smelters and refiners and determine mine and country of origin.

 

•     We are a member of the EICC and the EICC and GeSI Conflict-Free Sourcing Initiative (“CFSI”) working groups. As a member of the CFSI, a leading industry program that helps its members to manage risk by improving supply chain transparency with respect to Conflict Minerals, Marvell has access to CFSI RCOI data that aids us in determining the mine or location of origin of the Conflict Minerals in our supply chain.

 

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We cross-checked information received from our suppliers against data made available by these industry organizations and against additional information obtained from our customers and our own research to determine whether such facilities are validated by the Conflict-Free Sourcing Program (the “CFSP”) developed by the CFSI. When necessary, we engaged with smelters and refiners that we identified as high-risk to encourage such facilities to obtain a “conflict-free” designation from an independent third-party audit program.

Step 3: Design and Implement a Strategy to Respond to Identified Risks.

 

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We have developed procedures for sending CMRTs to our suppliers on a bi-annual basis, reviewing their responses, consolidating the information in a central database and following up with the suppliers to address any incomplete or inconsistent responses.

 

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We encourage our suppliers to conduct investigations of any smelters or refiners that we identified as high-risk, work with our suppliers to mitigate such risk and, where unsuccessful, transition their processing to CFSP validated smelters or refiners.

 

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If, on the basis of red flags that are identified as a result of either (i) the supplier data acquisition or engagement processes or (ii) the receipt of information from other sources, Marvell determines that there is a reasonable risk that a supplier is sourcing Conflict Minerals that are directly or indirectly financing or benefiting armed groups, Marvell will enforce the Conflict Minerals Policy and the Supplier Code of Conduct and the other policies incorporated therein by means of a series of escalations.

 

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Such escalations shall be determined at the discretion of the Conflict Minerals Working Group and, as appropriate, of the CSR Committee and the Audit Committee of the Board of Directors, and may range from prompt engagement with the supplier to resolve the sourcing issue, to requiring such supplier to implement a risk management plan (which plan may involve, as appropriate, remedial action up to and including disengagement from upstream suppliers), to disengagement by Marvell from the applicable supplier.

Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence.

Given that we do not source Conflict Minerals directly from smelters and refiners, we rely on third parties, including the CFSP, to coordinate and conduct third-party audits of these facilities. We rely on the published results of these third-party audits to validate the responsible sourcing practices of the smelters and refiners in our supply chain.

Step 5: Report on Supply Chain Due Diligence.

As required by the Rule, we have filed a Form SD and a Conflict Minerals Report as an exhibit thereto for the 2014 calendar year reporting period. The Form SD and Conflict Minerals Report are also available on our website at www.marvell.com under the heading “Investor Relations - Corporate Governance and Social Responsibility.”

VI. Conflict Minerals Processing Facilities

Based on the information provided by our direct suppliers, and otherwise obtained through the due diligence process described above, we have provided information regarding the processing facilities from which we source the Conflict Minerals contained in our products on Appendix A to this Report. Because some of our direct suppliers provided supply chain information on a company level rather than on a product level, this list may include facilities that did not actually process Conflict Minerals contained in our products.

 

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VII. Country of Origin of Conflict Minerals

Based on the information provided by our direct suppliers, and otherwise obtained through the due diligence process described above, some of the Conflict Minerals necessary to the functionality or production of our products may have originated from mines located in the Covered Countries. As shown on Appendix A, we determined during our due diligence that many of the smelters and refiners providing minerals to our direct suppliers, which may have originated from mines located in the Covered Countries, are CFSP-validated or actively engaged in the CFSP compliance process. For the CFSP “known smelters” whose status is unknown, we have not received information indicating or suggesting that our sourcing of necessary Conflict Minerals benefitted armed groups in any of the Covered Countries.

VIII. Efforts to Determine Mine or Location of Origin

As a downstream company, the primary focus of our due diligence on the source and chain of custody of the Conflict Minerals in our supply chain was on the collection and assessment of the CMRT data provided by our direct suppliers. As described above, we supplemented that data using data obtained from the CFSI, our customers and our own research. We were unable to ascertain the country of origin of all necessary Conflict Minerals contained in our products because certain smelters and refiners had not yet received a “conflict-free” designation from an independent third-party audit program and did not respond to our requests for country of origin data.

IX. Results of Conflict Minerals Due Diligence

Based on the results of the due diligence process with respect to the source and chain of custody of the Conflict Minerals contained in our products conducted for the 2014 reporting year, we do not have sufficient information to determine whether or not the Conflict Minerals contained in our products directly or indirectly finance or benefit armed groups in the Covered Countries.

X. Independent Private Sector Audit

Given that Marvell has not voluntarily elected to describe any of its products as “DRC conflict free,” an independent private sector audit of this Report has not been conducted.

XI. Steps to Mitigate Risk

The Company intends to take the following steps, among others, to further mitigate the risk that the Conflict Minerals necessary to the functionality or production of our products benefit armed groups in the Covered Countries:

 

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We intend to continue to monitor our direct suppliers’ Conflict Minerals sourcing practices to ensure that our direct suppliers remain in compliance with our Conflict Minerals Policy and Supplier Code of Conduct.

 

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We intend to continue to engage with our direct suppliers, and, when necessary, the smelters and refiners from which our suppliers source Conflict Minerals, to obtain current, accurate and complete information regarding our supply chain, including CFSI “known smelters” listed on the CFSI’s Standard Smelter List and the location of the mines from which the Conflict Minerals originate.

 

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We intend to continue to encourage our direct suppliers to adhere to our Conflict Minerals Policy and our Supplier Code of Conduct and in turn encourage their smelters and refiners to obtain a “conflict-free” designation from an independent third-party audit program.

 

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We intend to continue to, when necessary, directly encourage the smelters and refiners from which our suppliers source Conflict Minerals to obtain a “conflict-free” designation from an independent third-party audit program.

 

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We intend to advise any of our direct suppliers found to be sourcing from smelters or refiners that we identify as high-risk to establish an alternative source for Conflict Minerals.

 

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We intend to continue to engage in EICC, CSFI and other industry initiatives promoting “conflict-free” supply chains.

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FORWARD LOOKING STATEMENTS

Statements relating to due diligence improvements are forward-looking in nature and are based on Marvell’s management’s current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors that may be outside of Marvell’s control and that could cause actual events to differ materially from those expressed or implied by the statements made herein.

DOCUMENTS INCORPORATED BY REFERENCE

Unless otherwise stated herein, any documents, third-party materials or references to websites (including Marvell’s) are not incorporated by reference in, or considered to be a part of, this CMR, unless expressly incorporated by reference herein.

 

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Appendix A

Conflict Minerals Processing Facilities as of May 13, 2015

For the 2014 reporting year, our suppliers identified 235 smelters and refiners as potential sources of conflict minerals. Of such smelters and refiners, 152 have been validated as “conflict-free” by the CFSP or other independent third-party audit program and an additional 34 are active with the CFSP, which represents a total of 79 percent of the smelters in our supply chain. The following tables contain the names of CFSI “known smelters” listed on the CFSI’s Standard Smelter List that are used by our direct suppliers and that have been identified by the CFSP or other independent third-party audit program as:

 

1.

“Validated” with the CFSP assessment and audit protocol or other independent third-party audit program;

 

2.

“Active” toward CFSP validation as a result of agreeing to complete a CFSP validation audit conducted by an independent third-party auditor; or

 

3.

“Not Active” as a result of appearing on the CFSI’s Standard Smelter List but not having agreed to complete a CFSP validation audit conducted by an independent third-party auditor.

This list does not include processing facilities that have not been identified as “known smelters” by the CFSI.

 

		Gold		Tantalum		Tin		Tungsten		Total
Validated		65		38		35		14		152 (65%)
Active		6		0		12		16		34 (14%)
Not Active		31		0		17		1		49 (21%)
Total		102		38		64		31		235

 

MINERAL		SMELTER NAME		STATUS
Gold		Aida Chemical Industries Co. Ltd.		Validated
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		Validated
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		Not Active
Gold		AngloGold Ashanti Córrego do Sítio Minerção		Validated
Gold		Argor-Heraeus SA		Validated
Gold		Asahi Pretec Corporation		Validated
Gold		Asaka Riken Co Ltd		Active
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		Validated
Gold		Aurubis AG		Validated
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		Not Active
Gold		Bauer Walser AG		Not Active
Gold		Boliden AB		Validated
Gold		C. Hafner GmbH + Co. KG		Validated
Gold		Caridad		Not Active
Gold		CCR Refinery – Glencore Canada Corporation		Validated
Gold		Cendres + Métaux SA		Active

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Gold		Chimet S.p.A.		Validated
Gold		Chugai Mining		Not Active
Gold		Daejin Indus Co. Ltd		Not Active
Gold		Daye Non-Ferrous Metals Mining Ltd.		Not Active
Gold		Do Sung Corporation		Not Active
Gold		Doduco		Active
Gold		Dowa		Validated
Gold		Eco-System Recycling Co., Ltd.		Validated
Gold		FSE Novosibirsk Refinery		Not Active
Gold		Gansu Seemine Material Hi-Tech Co Ltd		Not Active
Gold		Guangdong Jinding Gold Limited		Not Active
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		Not Active
Gold		Heimerle + Meule GmbH		Validated
Gold		Heraeus Ltd. Hong Kong		Validated
Gold		Heraeus Precious Metals GmbH & Co. KG		Validated
Gold		Hunan Chenzhou Mining Group Co., Ltd.		Not Active
Gold		Hwasung CJ Co. Ltd		Not Active
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited		Not Active
Gold		Ishifuku Metal Industry Co., Ltd.		Validated
Gold		Istanbul Gold Refinery		Validated
Gold		Japan Mint		Validated
Gold		Jiangxi Copper Company Limited		Not Active
Gold		Johnson Matthey Inc		Validated
Gold		Johnson Matthey Ltd		Validated
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		Validated
Gold		JSC Uralelectromed		Validated
Gold		JX Nippon Mining & Metals Co., Ltd.		Validated
Gold		Kazzinc Ltd		Validated
Gold		Kennecott Utah Copper LLC		Validated
Gold		Kojima Chemicals Co., Ltd		Validated
Gold		Korea Metal Co. Ltd		Not Active
Gold		Kyrgyzaltyn JSC		Not Active
Gold		L’ azurde Company For Jewelry		Validated
Gold		Lingbao Jinyuan Tonghui Refinery Co. Ltd.		Not Active
Gold		LS-NIKKO Copper Inc.		Validated
Gold		Luoyang Zijin Yinhui Metal Smelt Co Ltd		Not Active
Gold		Materion		Validated
Gold		Matsuda Sangyo Co., Ltd.		Validated
Gold		Metalor Technologies (Hong Kong) Ltd		Validated

 

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Gold		Metalor Technologies (Singapore) Pte. Ltd.		Validated
Gold		Metalor Technologies SA		Validated
Gold		Metalor USA Refining Corporation		Validated
Gold		METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V		Validated
Gold		Mitsubishi Materials Corporation		Validated
Gold		Mitsui Mining and Smelting Co., Ltd.		Validated
Gold		Moscow Special Alloys Processing Plant		Not Active
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		Validated
Gold		Navoi Mining and Metallurgical Combinat		Not Active
Gold		Nihon Material Co. LTD		Validated
Gold		Ohio Precious Metals, LLC		Validated
Gold		Ohura Precious Metal Industry Co., Ltd		Validated
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)		Validated
Gold		OJSC Kolyma Refinery		Not Active
Gold		PAMP SA		Validated
Gold		Penglai Penggang Gold Industry Co Ltd		Not Active
Gold		Prioksky Plant of Non-Ferrous Metals		Not Active
Gold		PT Aneka Tambang (Persero) Tbk		Validated
Gold		PX Précinox SA		Validated
Gold		Rand Refinery (Pty) Ltd		Validated
Gold		Royal Canadian Mint		Validated
Gold		Sabin Metal Corp.		Not Active
Gold		SAMWON METALS Corp.		Not Active
Gold		Schone Edelmetaal		Validated
Gold		SEMPSA Joyería Platería SA		Validated
Gold		Shandong Zhaojin Gold & Silver Refinery Co. Ltd		Validated
Gold		So Accurate Group, Inc.		Not Active
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		Active
Gold		Solar Applied Materials Technology Corp.		Validated
Gold		Sumitomo Metal Mining Co., Ltd.		Validated
Gold		Tanaka Kikinzoku Kogyo K.K.		Validated
Gold		The Great Wall Gold and Silver Refinery of China		Not Active
Gold		The Refinery of Shandong Gold Mining Co. Ltd		Validated
Gold		Tokuriki Honten Co., Ltd		Validated
Gold		Tongling nonferrous Metals Group Co.,Ltd		Not Active
Gold		Torecom		Active
Gold		Umicore Brasil Ltda		Validated
Gold		Umicore Precious Metals Thailand		Validated
Gold		Umicore SA Business Unit Precious Metals Refining		Validated

 

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Gold		United Precious Metal Refining, Inc.		Validated
Gold		Valcambi SA		Validated
Gold		Western Australian Mint trading as The Perth Mint		Validated
Gold		YAMAMOTO PRECIOUS METAL CO., LTD.		Validated
Gold		Yokohama Metal Co Ltd		Active
Gold		Yunnan Copper Industry Co Ltd		Not Active
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		Validated
Gold		Zijin Mining Group Co. Ltd		Validated
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		Validated
Tantalum		Conghua Tantalum and Niobium Smeltry		Validated
Tantalum		Duoluoshan		Validated
Tantalum		Exotech Inc.		Validated
Tantalum		F&X Electro-Materials Ltd.		Validated
Tantalum		Global Advanced Metals Aizu		Validated
Tantalum		Global Advanced Metals Boyertown		Validated
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		Validated
Tantalum		H.C. Starck Co., Ltd.		Validated
Tantalum		H.C. Starck GmbH Goslar		Validated
Tantalum		H.C. Starck GmbH Laufenburg		Validated
Tantalum		H.C. Starck Hermsdorf GmbH		Validated
Tantalum		H.C. Starck Inc.		Validated
Tantalum		H.C. Starck Ltd.		Validated
Tantalum		H.C. Starck Smelting GmbH & Co.KG		Validated
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		Validated
Tantalum		Hi-Temp		Validated
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		Validated
Tantalum		Jiujiang Tanbre Co., Ltd.		Validated
Tantalum		Kemet Blue Powder		Validated
Tantalum		Kemet Blue Metals		Validated
Tantalum		King-Tan Tantalum Industry Ltd		Validated
Tantalum		LSM Brasil S.A.		Validated
Tantalum		Metallurgical Products India (Pvt.) Ltd.		Validated
Tantalum		Mineração Taboca S.A.		Validated
Tantalum		Mitsui Mining & Smelting		Validated
Tantalum		Molycorp Silmet A.S.		Validated
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		Validated
Tantalum		Plansee SE Liezen		Validated
Tantalum		Plansee SE Reutte		Validated
Tantalum		QuantumClean		Validated

 

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Tantalum		RFH Tantalum Smeltry Co., Ltd		Validated
Tantalum		Solikamsk Magnesium Works OAO		Validated
Tantalum		Taki Chemicals		Validated
Tantalum		Telex		Validated
Tantalum		Ulba		Validated
Tantalum		Yichun Jin Yang Rare Metal Co., Ltd		Validated
Tantalum		Zhuzhou Cement Carbide		Validated
Tin		Alpha		Validated
Tin		China Tin Group Co., Ltd.		Active
Tin		CNMC (Guangxi) PGMA Co. Ltd.		Not Active
Tin		Cooperativa Metalurgica de Rondônia Ltda		Validated
Tin		CV Gita Pesona		Not Active
Tin		CV JusTindo		Active
Tin		CV Serumpun Sebalai		Not Active
Tin		CV United Smelting		Validated
Tin		Dowa		Validated
Tin		EM Vinto		Validated
Tin		Estanho de Rondônia S.A.		Not Active
Tin		Fenix Metals		Active
Tin		Gejiu Kai Meng Industry and Trade LLC		Not Active
Tin		Gejiu Non-Ferrous Metal Processing Co. Ltd.		Validated
Tin		Gejiu Zi-Li		Not Active
Tin		Huichang Jinshunda Tin Co. Ltd		Not Active
Tin		Jiangxi Ketai Advanced Material Co., Ltd.		Validated
Tin		Linwu Xianggui Smelter Co		Not Active
Tin		Magnu’s Minerais Metais e Ligas LTDA		Validated
Tin		Malaysia Smelting Corporation (MSC)		Validated
Tin		Melt Metais e Ligas S/A		Validated
Tin		Mineração Taboca S.A.		Validated
Tin		Minsur		Validated
Tin		Mitsubishi Materials Corporation		Validated
Tin		Nankang Nanshan Tin Manufactory Co., Ltd		Not Active
Tin		Novosibirsk Integrated Tin Works		Not Active
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		Active
Tin		OMSA		Validated
Tin		PT Alam Lestari Kencana		Not Active
Tin		PT Aries Kencana Sejahtera		Active
Tin		PT Artha Cipta Langgeng		Validated
Tin		PT ATD Makmur Mandiri Jaya		Validated

 

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Tin		PT Babel Inti Perkasa		Validated
Tin		PT Bangka Kudai Tin		Not Active
Tin		PT Bangka Putra Karya		Validated
Tin		PT Bangka Timah Utama Sejahtera		Not Active
Tin		PT Bangka Tin Industry		Validated
Tin		PT Belitung Industri Sejahtera		Validated
Tin		PT BilliTin Makmur Lestari		Active
Tin		PT Bukit Timah		Validated
Tin		PT DS Jaya Abadi		Validated
Tin		PT Eunindo Usaha Mandiri		Validated
Tin		PT Fang Di MulTindo		Not Active
Tin		PT Inti Stania Prima		Active
Tin		PT Karimun Mining		Active
Tin		PT Mitra Stania Prima		Validated
Tin		PT Panca Mega Persada		Validated
Tin		PT Pelat Timah Nusantara Tbk		Not Active
Tin		PT Prima Timah Utama		Validated
Tin		PT REFINED BANGKA TIN		Validated
Tin		PT Sariwiguna Binasentosa		Validated
Tin		PT Seirama Tin investment		Not Active
Tin		PT Stanindo Inti Perkasa		Validated
Tin		PT Sumber Jaya Indah		Active
Tin		PT Supra Sukses Trinusa		Not Active
Tin		PT Timah (Persero) Tbk Kundur		Validated
Tin		PT Timah (Persero) Tbk Mentok		Validated
Tin		PT Tinindo Inter Nusa		Validated
Tin		Rui Da Hung		Active
Tin		Soft Metais, Ltda.		Active
Tin		Thaisarco		Validated
Tin		White Solder Metalurgia e Mineração Ltda.		Validated
Tin		Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.		Active
Tin		Yunnan Tin Company, Ltd.		Validated
Tungsten		A.L.M.T. Corp.		Active
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		Validated
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		Active
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		Active
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		Validated
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		Validated
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		Validated

 

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Tungsten		Ganzhou Non-ferrous Metals Smelting Co., Ltd.		Active
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		Validated
Tungsten		Global Tungsten & Powders Corp.		Validated
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		Active
Tungsten		H.C. Starck GmbH		Active
Tungsten		H.C. Starck Smelting GmbH & Co.KG		Active
Tungsten		Hunan Chenzhou Mining Group Co., Ltd.		Active
Tungsten		Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.		Validated
Tungsten		Japan New Metals Co., Ltd.		Validated
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		Active
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		Validated
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		Not Active
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		Active
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		Active
Tungsten		Kennametal Fallon		Active
Tungsten		Kennametal Huntsville		Active
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		Validated
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		Active
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		Active
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd		Validated
Tungsten		Wolfram Bergbau und Hütten AG		Validated
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		Validated
Tungsten		Xiamen Tungsten Co., Ltd.		Validated
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		Active

The “Validated” smelters and refiners in the list above that report country of origin information to the CFSI reported that the Conflict Minerals processed by these facilities originated from the following countries:

Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Canada, Central African Republic, Chile, China, Colombia, Cote D’Ivoire, Czech Republic, Democratic Republic of the Congo, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, United Kingdom, United States of America, Uganda, Vietnam, Zambia and Zimbabwe.

 

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