UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
WESTELL TECHNOLOGIES, INC.
(Exact name of registrant as specified in its charter)
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Delaware | 0-27266 | 36-3154957 |
(State or other jurisdiction of incorporation) | (Commission File Number) | (IRS Employer Identification No.) |
750 North Common Drive, Aurora, IL 60504
(Address of principal executive offices) (Zip Code)
Thomas P. Minichiello
Senior Vice President, Chief Financial Officer,
Treasurer and Secretary
(630) 898-2500
(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, 2014. |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Westell Technologies, Inc. (“Westell”) has determined that the conflict minerals necessary to the functionality or production of products manufactured, or contracted to be manufactured, by Westell are required to be reported in the calendar year covered by this specialized disclosure report. Based on its reasonable country of origin inquiry, Westell exercised due diligence on the source and chain of custody of its conflict minerals for the reporting period from January 1 to December 31, 2014, as discussed in Exhibit 1.01 hereto.
Conflict Minerals Disclosure
Westell has filed, as Exhibit 1.01 to this Form SD, the Conflict Minerals Report required by Item 1.01. The Conflict Minerals Report is publicly available on Westell’s website at http://www.westell.com/about-us/product-compliance/conflict-minerals.
Item 1.02 Exhibit
See Item 2.01 of this Form.
Section 2 - Exhibits
Item 2.01 Exhibits
The following exhibit is being filed as part of this Form SD:
Exhibit 1.01 - Westell’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2014 as required by Items 1.01 and 1.02 of this Form.
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.
WESTELL TECHNOLOGIES, INC.
(Registrant)
By: /s/ Thomas P. Minichiello May 29, 2015
Thomas P. Minichiello (Date)
Senior Vice President, Chief Financial Officer,
Treasurer and Secretary
Exhibit 1.01
CONFLICT MINERALS REPORT OF
Westell Technologies, Inc.
IN ACCORDANCE WITH RULE 13p-1
UNDER THE SECURITIES EXCHANGE ACT OF 1934
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2014
I. Introduction
This is the Conflict Minerals 1 Report (the “Report”) of Westell Technologies, Inc. (“Westell”, the “Company,” “we,” “us,” or “our”) prepared for calendar year 2014 (except for conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”).
In accordance with Rule 13p-1, we undertook efforts to determine whether the conflict minerals necessary to the functionality or production of products that we manufacture or contract to manufacture were sourced from the Democratic Republic of Congo or an adjoining country (the “Covered Countries”) or are from recycled or scrap sources. The Company designed its efforts in conformity with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Due Diligence Guidance”) and related supplements for each of the conflict minerals (the “Supplements”).
The statements below are based on the due diligence activities performed to date by Westell and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance from the Securities and Exchange Commission (the “SEC”) and other issues.
About Westell
Westell Technologies, Inc., is a leading provider of in-building wireless, intelligent site management, cell site optimization, and outside plant solutions focused on innovation and differentiation at the edge of telecommunication networks, where end users connect. The Company’s comprehensive set of products and solutions enable telecommunication service providers, cell tower operators, and other network operators to reduce operating costs and improve network performance. With millions of products successfully deployed worldwide, the Company is a trusted partner for transforming networks into high quality, reliable systems.
The Company designs, develops, assembles and markets a wide variety of products and solutions. In-building wireless solutions include distributed antenna systems (DAS) interface panels, high-performance digital repeaters and bi-directional amplifiers (BDAs), and system components and antennas, all used by wireless
1The term “conflict mineral” is defined by the SEC as (A) columbite-tantalite (coltan); cassiterite; gold; wolframite; or their derivatives, which are limited to tantalum, tin and tungsten; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
service providers and neutral-party hosts to fine tune radio frequency (RF) signals that helps extend coverage to areas not served well or at all by traditional cell sites. Intelligent site management solutions include a suite of Remote monitoring and control devices which, when combined with the Company’s Optima management system, provides comprehensive machine-to-machine (M2M) communications that enable operators to remotely monitor, manage, and control site infrastructure and support systems. Cell site optimization solutions consist of tower mounted amplifiers (TMAs), small outdoor-hardened units mounted next to antennas on cell towers, enabling wireless service providers to improve the overall performance of a cell site, including increasing data throughput and reducing dropped connections. Outside plant solutions, which are sold to wireline and wireless service providers as well as industrial network operators, consist of a broad range of offerings, including cabinets, enclosures, and mountings; synchronous optical networks/time division multiplexing (SONET/TDM) network interface units; power distribution units; copper and fiber connectivity panels; hardened Ethernet switches; and systems integration services. For more information, please visit www.westell.com.
II. Design of Due Diligence Measures
The Company designed its overall conflict minerals program based on the five-step framework of the OECD Due Diligence Guidance and its Supplements.
Westell's implementation of the five-step framework consisted of the following overarching steps, which are discussed in further detail in Section III.
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5: Report annually on supply chain due diligence
We relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from smelters or refiners who may provide those minerals to companies in our supply chain. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals; the Company does not purchase raw ore or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries.
III. Due Diligence Measures Performed
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence with regard to the mineral supply chain in conformance with the OECD Due Diligence Guidance for calendar year 2014.
Step 1: Establish strong company management systems
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a. | Conflict Minerals Team - Westell has established a management system for complying with the applicable rules. Our management system includes our internal cross-functional Conflict Minerals Team, which consists of personnel from relevant functions such as purchasing, quality manufacturing, legal and accounting. The team was responsible for implementing our conflict minerals compliance strategy. Senior management was periodically briefed on the results of our due diligence efforts as well as issues requiring escalation. |
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b. | Conflict Minerals Policy - Westell is committed to ensuring that products we receive from our suppliers are responsibly sourced and we have a policy that sets forth the expectations of our suppliers related |
to the use of conflict minerals. The policy resides on our corporate website at http://www.westell.com/about-us/product-compliance/conflict-minerals/. The policy is periodically reviewed and will be updated, if necessary.
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c. | Company level grievance mechanism - Westell has a grievance mechanism as a risk-awareness system for conflict minerals issues. All Westell internal and external stakeholders can communicate directly and confidentially with our conflict minerals team. |
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d. | Document Retention - Westell is retaining documentation regarding its due diligence efforts for calendar year 2014 in accordance with its record retention policy. |
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
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a. | Identify products in-scope and assess supply chain - Our Conflict Minerals Team reviewed the products that we manufacture or contract to manufacture to determine those that should be deemed in-scope for purposes of Rule 13p-1 and Form SD. The Conflict Minerals Team assessed our supply chain to determine the suppliers of the products deemed in-scope |
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b. | Conduct Reasonable Country of Origin Inquiry (“RCOI”) - Westell utilized the industry-developed Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”) to query our direct suppliers identified in our assessment of our supply chain who may provide material and components that are within the scope of Rule 13p-1. As part of our due diligence efforts, we received CMRTs from our suppliers, evaluated the responses, and followed up as appropriate, to determine our reporting obligation. |
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c. | Identify smelters/processors - Westell collected a list of smelters/processors that were in our supply chain during 2014 by utilizing the CMRT. |
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
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a. | Validate Responses - We reviewed the responses from our suppliers, and followed up as appropriate, to determine whether they were complete and provided the information necessary to identify the content and origin of minerals in our products. |
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b. | Verify Smelters - As part of the risk mitigation process, we compared the list of smelters/processors collected from our suppliers to the conflict-free smelter lists published by the CFSI. |
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Westell is relying on the CFSI’s published lists to verify the conflict-free status of smelters/processors that source from Covered Countries and, as a downstream consumer of conflict minerals, does not perform direct audits of smelters/refiners in its supply chain.
Step 5: Report annually on supply chain due diligence
This Report (and the related Form SD) has been filed with the SEC and is available on our website at http://www.westell.com/about-us/product-compliance/conflict-minerals/.
IV. Product Determination
On the basis of the measures described above, for calendar year 2014, the Company does not have sufficient information from suppliers or other sources at this time to determine whether the conflict minerals in the
products it manufactures, or contracts to manufacture, originated in the Covered Countries and, if so, whether the conflict minerals were from recycled or scrap sources. In addition, the Company also does not have sufficient information from its suppliers to determine the facilities used to process the necessary conflict minerals in its products, the country of origin of the necessary conflict minerals in its products and the mine or location of origin of such conflict minerals with specificity at this time.
V. Product Description and Identified Facilities
Products - The products subject to the disclosure include those described in “About Westell” above.
Processing Facilities - Based on our due diligence process and the information received from our suppliers, the facilities listed on Appendix A to this Report may have been used to process conflict minerals used in our products in 2014.
VI. Steps to Improve Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. We also will continue to monitor changes in circumstances that may impact the facts or our determination. Over time, we anticipate that the amount of information globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect our suppliers to take similar due diligence measures with their suppliers to ensure management throughout the supply chain.
In addition to those mentioned above, the Company intends to undertake the following steps during the next compliance period to improve the due diligence measures conducted and to further mitigate the risk that the necessary conflict minerals benefit armed groups, including:
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• | Continuing to collect responses from suppliers using tools such as the CMRT. |
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• | Comparing and validating CMRT results to information collected via independent conflict-free smelter validation programs such as the CFSI. |
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• | Informing and encouraging suppliers to transition to smelters identified by the due diligence process as “conflict-free” by an independent audit program such as the CFSI. |
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• | Continuing to allow verified conflict-free material from the region to enter our supply chain. |
VII. Independent Private Sector Audit
Pursuant to SEC rules and related guidance, an independent private sector audit of this Report was not required for calendar year 2014.
Appendix A
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Mineral | Smelter Name | Country | Status According to the CFSI* |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conflict-Free |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conflict-Free |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conflict-Free |
Gold | Argor-Heraeus SA | SWITZERLAND | Conflict-Free |
Gold | Asahi Pretec Corporation | JAPAN | Conflict-Free |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Conflict-Free |
Gold | Aurubis AG | GERMANY | Conflict-Free |
Gold | Boliden AB | SWEDEN | Conflict-Free |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conflict-Free |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conflict-Free |
Gold | Chimet S.p.A. | ITALY | Conflict-Free |
Gold | Dowa | JAPAN | Conflict-Free |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conflict-Free |
Gold | Heimerle + Meule GmbH | GERMANY | Conflict-Free |
Gold | Heraeus Ltd. Hong Kong | CHINA | Conflict-Free |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conflict-Free |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conflict-Free |
Gold | Istanbul Gold Refinery | TURKEY | Conflict-Free |
Gold | Japan Mint | JAPAN | Conflict-Free |
Gold | Johnson Matthey Inc. | UNITED STATES | Conflict-Free |
Gold | Johnson Matthey Limited | CANADA | Conflict-Free |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conflict-Free |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conflict-Free |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conflict-Free |
Gold | Kazzinc | KAZAKHSTAN | Conflict-Free |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Conflict-Free |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conflict-Free |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Conflict-Free |
Gold | LS-NIKKO Copper Inc. | REPUBLIC OF KOREA | Conflict-Free |
Gold | Materion | UNITED STATES | Conflict-Free |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conflict-Free |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conflict-Free |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conflict-Free |
Gold | Metalor Technologies SA | SWITZERLAND | Conflict-Free |
Gold | Metalor USA Refining Corporation | UNITED STATES | Conflict-Free |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Conflict-Free |
Gold | Mitsubishi Materials Corporation | JAPAN | Conflict-Free |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conflict-Free |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conflict-Free |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Conflict-Free |
Gold | Nihon Material Co., Ltd. | JAPAN | Conflict-Free |
Gold | Ohio Precious Metals, LLC | UNITED STATES | Conflict-Free |
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Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conflict-Free |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | Conflict-Free |
Gold | PAMP SA | SWITZERLAND | Conflict-Free |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conflict-Free |
Gold | PX Précinox SA | SWITZERLAND | Conflict-Free |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conflict-Free |
Gold | Republic Metals Corporation | UNITED STATES | Conflict-Free |
Gold | Royal Canadian Mint | CANADA | Conflict-Free |
Gold | Schone Edelmetaal | NETHERLANDS | Conflict-Free |
Gold | SEMPSA Joyería Platería SA | SPAIN | Conflict-Free |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conflict-Free |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conflict-Free |
Gold | Singway Technology Co., Ltd. | TAIWAN | Conflict-Free |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conflict-Free |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conflict-Free |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conflict-Free |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conflict-Free |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conflict-Free |
Gold | Umicore Brasil Ltda. | BRAZIL | Conflict-Free |
Gold | Umicore Precious Metals Thailand | THAILAND | Conflict-Free |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Conflict-Free |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conflict-Free |
Gold | Valcambi SA | SWITZERLAND | Conflict-Free |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conflict-Free |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conflict-Free |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conflict-Free |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Conflict-Free |
Gold | Advanced Chemical Company | UNITED STATES | Not Determined |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Not Determined |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Not Determined |
Gold | Asaka Riken Co., Ltd. | JAPAN | Not Determined |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Not Determined |
Gold | Bauer Walser AG | GERMANY | Not Determined |
Gold | Caridad | MEXICO | Not Determined |
Gold | Cendres + Métaux SA | SWITZERLAND | Not Determined |
Gold | Chugai Mining | JAPAN | Not Determined |
Gold | Daejin Indus Co., Ltd. | REPUBLIC OF KOREA | Not Determined |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Determined |
Gold | Do Sung Corporation | REPUBLIC OF KOREA | Not Determined |
Gold | Doduco | GERMANY | Not Determined |
Gold | Faggi Enrico S.p.A. | ITALY | Not Determined |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Determined |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Not Determined |
Gold | Geib Refining Corporation | UNITED STATES | Not Determined |
Gold | Guangdong Jinding Gold Limited | CHINA | Not Determined |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Determined |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Determined |
Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Not Determined |
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Gold | Hwasung CJ Co., Ltd. | REPUBLIC OF KOREA | Not Determined |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Not Determined |
Gold | Jiangxi Copper Company Limited | CHINA | Not Determined |
Gold | KGHM Polska MiedŸ Spó³ka Akcyjna | POLAND | Not Determined |
Gold | Korea Metal Co., Ltd. | REPUBLIC OF KOREA | Not Determined |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Not Determined |
Gold | Lingbao Gold Company Limited | CHINA | Not Determined |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Determined |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Determined |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Not Determined |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Not Determined |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not Determined |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Not Determined |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Not Determined |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Determined |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Not Determined |
Gold | Sabin Metal Corp. | UNITED STATES | Not Determined |
Gold | Samduck Precious Metals | REPUBLIC OF KOREA | Not Determined |
Gold | SAMWON Metals Corp. | REPUBLIC OF KOREA | Not Determined |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Determined |
Gold | So Accurate Group, Inc. | UNITED STATES | Not Determined |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Not Determined |
Gold | The Great Wall Gold and Silver Refinery of China | CHINA | Not Determined |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Determined |
Gold | Torecom | REPUBLIC OF KOREA | Not Determined |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Not Determined |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Determined |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Conflict-Free |
Tantalum | D Block Metals, LLC | UNITED STATES | Conflict-Free |
Tantalum | Duoluoshan | CHINA | Conflict-Free |
Tantalum | Exotech Inc. | UNITED STATES | Conflict-Free |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conflict-Free |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conflict-Free |
Tantalum | Global Advanced Metals Aizu | JAPAN | Conflict-Free |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conflict-Free |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Conflict-Free |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conflict-Free |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Conflict-Free |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Conflict-Free |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conflict-Free |
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Tantalum | H.C. Starck Inc. | UNITED STATES | Conflict-Free |
Tantalum | H.C. Starck Ltd. | JAPAN | Conflict-Free |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conflict-Free |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Conflict-Free |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conflict-Free |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conflict-Free |
Tantalum | KEMET Blue Metals | MEXICO | Conflict-Free |
Tantalum | KEMET Blue Powder | UNITED STATES | Conflict-Free |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conflict-Free |
Tantalum | LSM Brasil S.A. | BRAZIL | Conflict-Free |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conflict-Free |
Tantalum | Mineração Taboca S.A. | BRAZIL | Conflict-Free |
Tantalum | Mitsui Mining & Smelting | JAPAN | Conflict-Free |
Tantalum | Molycorp Silmet A.S. | ESTONIA | Conflict-Free |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Plansee SE Liezen | AUSTRIA | Conflict-Free |
Tantalum | Plansee SE Reutte | AUSTRIA | Conflict-Free |
Tantalum | QuantumClean | UNITED STATES | Conflict-Free |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conflict-Free |
Tantalum | Taki Chemicals | JAPAN | Conflict-Free |
Tantalum | Telex Metals | UNITED STATES | Conflict-Free |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conflict-Free |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Zhuzhou Cemented Carbide | CHINA | Conflict-Free |
Tantalum | Phoenix Metal Ltd. | RWANDA | Not Determined |
Tin | Alpha | UNITED STATES | Conflict-Free |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Conflict-Free |
Tin | CV United Smelting | INDONESIA | Conflict-Free |
Tin | Dowa | JAPAN | Conflict-Free |
Tin | EM Vinto | BOLIVIA | Conflict-Free |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conflict-Free |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conflict-Free |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conflict-Free |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conflict-Free |
Tin | Melt Metais e Ligas S/A | BRAZIL | Conflict-Free |
Tin | Mineração Taboca S.A. | BRAZIL | Conflict-Free |
Tin | Minsur | PERU | Conflict-Free |
Tin | Mitsubishi Materials Corporation | JAPAN | Conflict-Free |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Conflict-Free |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conflict-Free |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conflict-Free |
Tin | PT Babel Inti Perkasa | INDONESIA | Conflict-Free |
Tin | PT Bangka Putra Karya | INDONESIA | Conflict-Free |
Tin | PT Bangka Tin Industry | INDONESIA | Conflict-Free |
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Tin | PT Belitung Industri Sejahtera | INDONESIA | Conflict-Free |
Tin | PT Bukit Timah | INDONESIA | Conflict-Free |
Tin | PT DS Jaya Abadi | INDONESIA | Conflict-Free |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conflict-Free |
Tin | PT Mitra Stania Prima | INDONESIA | Conflict-Free |
Tin | PT Panca Mega Persada | INDONESIA | Conflict-Free |
Tin | PT Prima Timah Utama | INDONESIA | Conflict-Free |
Tin | PT Refined Bangka Tin | INDONESIA | Conflict-Free |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conflict-Free |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conflict-Free |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conflict-Free |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conflict-Free |
Tin | PT Tinindo Inter Nusa | INDONESIA | Conflict-Free |
Tin | PT Wahana Perkit Jaya | INDONESIA | Conflict-Free |
Tin | Thaisarco | THAILAND | Conflict-Free |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conflict-Free |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Conflict-Free |
Tin | China Tin Group Co., Ltd. | CHINA | Not Determined |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Determined |
Tin | CV Gita Pesona | INDONESIA | Not Determined |
Tin | CV Serumpun Sebalai | INDONESIA | Not Determined |
Tin | CV Venus Inti Perkasa | INDONESIA | Not Determined |
Tin | Estanho de Rondônia S.A. | BRAZIL | Not Determined |
Tin | Feinhütte Halsbrücke GmbH | GERMANY | Not Determined |
Tin | Fenix Metals | POLAND | Not Determined |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Not Determined |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Determined |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Not Determined |
Tin | Jiangxi Shunda Huichang Kam Tin Co., Ltd. | CHINA | Not Determined |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Not Determined |
Tin | Metallo-Chimique N.V. | BELGIUM | Not Determined |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Not Determined |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | Not Determined |
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | Not Determined |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Not Determined |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Not Determined |
Tin | Phoenix Metal Ltd. | RWANDA | Not Determined |
Tin | PT Alam Lestari Kencana | INDONESIA | Not Determined |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Not Determined |
Tin | PT Bangka Kudai Tin | INDONESIA | Not Determined |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Not Determined |
Tin | PT BilliTin Makmur Lestari | INDONESIA | Not Determined |
Tin | PT Fang Di MulTindo | INDONESIA | Not Determined |
Tin | PT Inti Stania Prima | INDONESIA | Not Determined |
Tin | PT Justindo | INDONESIA | Not Determined |
Tin | PT Karimun Mining | INDONESIA | Not Determined |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Not Determined |
Tin | PT Seirama Tin Investment | INDONESIA | Not Determined |
Tin | PT Sumber Jaya Indah | INDONESIA | Not Determined |
|
| | | |
Tin | PT Supra Sukses Trinusa | INDONESIA | Not Determined |
Tin | PT Tirus Putra Mandiri | INDONESIA | Not Determined |
Tin | Rui Da Hung | TAIWAN | Not Determined |
Tin | Soft Metais Ltda. | BRAZIL | Not Determined |
Tin | VQB Mineral and Trading Group JSC | VIETNAM | Not Determined |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Not Determined |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Conflict-Free |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conflict-Free |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conflict-Free |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM | Conflict-Free |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Conflict-Free |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conflict-Free |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Not Determined |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Not Determined |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Not Determined |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | H.C. Starck GmbH | GERMANY | Not Determined |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Not Determined |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Kennametal Fallon | UNITED STATES | Not Determined |
Tungsten | Kennametal Huntsville | UNITED STATES | Not Determined |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Not Determined |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Not Determined |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Not Determined |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Not Determined |
* The processing facilities identified as "Conflict-Free" were included on the CFSI's published smelter/refiner lists for the applicable mineral, while those identified as "Not Determined" were not on such lists.
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