UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

Specialized Disclosure Report

 

 

 

ADVANCED SEMICONDUCTOR ENGINEERING, INC.

 

Taiwan, Republic of China

Jurisdiction of incorporation

 

001-16125

Commission File Number

 

26 Chin Third Road

Nantze Export Processing Zone

Nantze, Kaohsiung, Taiwan

Republic of China

 

Joseph Tung

Chief Financial Officer

886-2-8780-5489

 

    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 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

 

Conflict Minerals Disclosure

 

Our Form SD and our Conflict Minerals Report for the year ended December 31, 2014 filed as Exhibit 1.01 to this Form SD are available at http://www.aseglobal.com/en/Csr/SupplyChainDevelopment.asp.

 

 
 

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2014 to December 31, 2014

 

* * * * *

 

 

 

SIGNATURE

 

Advanced Semiconductor Engineering, Inc.

 

 

By:

/s/ Jason C.S. Chang

Jason C.S. Chang

Chief Executive Officer

Date: May 31, 2015
 

 

 

 

EXHIBIT INDEX

 

Exhibit    
Number   Description
1.01   Conflict Minerals Report for the reporting period January 1, 2014 to December 31, 2014



 

Exhibit 1.01

 

Advanced Semiconductor Engineering, Inc.

Conflict Minerals Report

For the year ended December 31, 2014

 

Corporate Overview and Product Scope

 

Advanced Semiconductor Engineering, Inc. (“ASE”, “we”, “our”, “us”) is the world’s largest independent provider of semiconductor packaging and materials services based on 2014 revenues. Our services include semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten which are necessary to deliver our packaging, materials and electronic manufacturing services.

 

We have twelve facilities located in Taiwan, China, Malaysia, Japan, Singapore and Korea that provide packaging, testing and materials services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services to the wafers, and delivering a completed, packaged integrated circuit back to the customer. In the performance of packaging and materials services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten and tantalum. We do not use gold, tin, tungsten or tantalum in our testing services.

 

Since our acquisition of a controlling interest in Universal Scientific Industrial Co., Ltd. in February 2010, we provide a broad range of electronic manufacturing services to a global customer base. We have seven facilities located in Taiwan, China and Mexico that provide electronic manufacturing services. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products. Typical materials and components which we utilize include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.

 

All packaging and materials services and electronic manufacturing services we provide contain one or more of the conflict minerals: gold, tin, tungsten or tantalum.

 

Reasonable Country of Origin Inquiry (RCOI)

 

For our packaging and materials services, we purchase gold, tin and tungsten from 101 suppliers. Each of these 101 suppliers has supplied us with the information required in a Conflict Minerals Reporting Template (CMRT) authored by the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative, or EICC-GeSI, with an accounting of their conflict mineral Smelters or Refiners (SoRs). Each of these 101 suppliers is in receipt of our conflict minerals policy, and each has confirmed their understanding of its principles and their willingness to comply.

 

For our electronic manufacturing services, we performed a supplier assessment of all 1,194 suppliers who provided us with gold, tin, tungsten or tantalum in 2014. We organized the list by annual purchase volume (purchase expenditure in dollars) from largest to smallest and made a determination that for our 2014 Conflict Minerals Report we would analyze suppliers supplying us a purchase volume of greater than $1 million. The purchase volume of the resulting 232 companies accounted for 95% of our total purchase volume in 2014.

 

Below are the results of our Reasonable Country of Origin Inquiry, or RCOI.

 

1 

 

 

Gold – Packaging and Materials Services

 

1.During 2014, we purchased gold for our packaging and materials services from a total of 53 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on data we collected, we identified a total of 58 SoRs from which we indirectly purchased gold in 2014 for our packaging and materials services. All 53 of our gold suppliers for our packaging and materials services responded to our request, representing 100% of our total expenditure for gold during 2014 for our packaging and materials services.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 48 of the SoRs from which we indirectly purchased gold in 2014 for our packaging and materials services are participants in the Conflict-Free Smelter Program, or CFSP, operated by the Conflict-Free Sourcing Initiative, or CFSI.

 

3.The following table summarizes our RCOI results for gold purchased for our packaging and materials services in 2014.

 

Companies supplying gold for our packaging and materials services Number %
Companies from which we purchased gold 53 100%
   Companies that provided SoR source information 53 100%
   Companies that were not able  provide SoR source information 0 0%
     
SoRs of gold for our packaging and materials services    
SoRs from which we indirectly purchased gold 58 100%
   SoRs with Smelter ID, CFSI Compliant 42 73%
   SoRs with Smelter ID, CFSI Active 6 10%
   SORs not involved in CFSP 10 17%

 

 

2 

 

 

 

Gold – Electronic Manufacturing Services

 

1.During 2014, we purchased gold for our electronic manufacturing services from a total of 180 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on data collected, 122 SoRs were identified from which we indirectly purchased gold in 2014 for our electronic manufacturing services. One-hundred seventy-two of our gold suppliers for our electronic manufacturing services responded to our request to identify the SoRs for gold during 2014. Eight did not respond.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 62 of the SoRs from which we indirectly purchased gold in 2014 for our electronic manufacturing services are participants in the CFSP operated by the CFSI.

 

3.The following table summarizes our RCOI results for gold purchased for our electronic manufacturing services in 2014.

 

Companies supplying gold for our electronic manufacturing services Number %
Companies from which we purchased gold 180 100%
   Companies that provided SoR source information 172 95%
   Companies that were not able provide SoR source information 8 5%
     
SoRs of gold for our electronic manufacturing services    
SoRs from which we indirectly purchased gold 122 100%
   SoRs with Smelter ID, CFSI Compliant 53 43%
   SoRs with Smelter ID,CFSI Active 9 7%
   SORs not involved in CFSP 60 50%

 

 

3 

 

 

 

Tin – Packaging and Materials Services

 

1.During 2014, we purchased tin for our packaging and materials services from a total of 67 suppliers. None of these suppliers are SoRs, and all of these suppliers purchased tin from SoRs or from other third parties. Based on the data we collected, we identified a total of 46 SoRs from which we indirectly purchased tin in 2014 for our packaging and materials services. All 67 of our tin suppliers for our packaging and materials services responded to our request, representing 100% of our total expenditure for tin during 2014 for our packaging and materials services.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 38 of the SoRs from which we indirectly purchased tin in 2014 for our packaging and materials services are participants in the CFSP operated by the CFSI.

 

3.The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2014.

 

Companies supplying tin for our packaging and materials services Number %
Companies from which we purchased tin 67 100%
   Companies that provided SoR source information 67 100%
   Companies that were not able provide SoR source information 0 0%
     
SoRs of tin for our packaging and materials services    
SoRs from which we indirectly purchased tin 46 100%
   SoRs with Smelter ID, CFSI Compliant 20 44%
   SoRs with Smelter ID, CFSI Active 18 39%
   SORs not involved in CFSP 8 17%

 

 

4 

 

 

 

Tin – Electronic Manufacturing Services

 

1.During 2014, we purchased tin for our electronic manufacturing services from a total of 189 suppliers. None of these suppliers are SoRs and all these suppliers purchased tin from SoRs or from other third parties. Based on data collected, 102 SoRs were identified from which we indirectly purchased tin for our electronic manufacturing services in 2014. One-hundred eighty one of our tin suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tin during 2014. Eight did not respond.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 46 of the SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2014 are participants in the CFSP operated by the CFSI.

 

3.The following table summarizes our RCOI results for tin purchased for our electronic manufacturing services in 2014.

 

Companies supplying tin for our electronic manufacturing services Number %
Companies from which we purchased tin 189 100%
   Companies that provided SoR source information 181 96%
   Companies that were not able provide SoR source information 8 4%
     
SoRs of tin for our electronic manufacturing services    
SoRs from which we indirectly purchased tin 102 100%
   SoRs with Smelter ID, CFSI Compliant 23 22%
   SoRs with Smelter ID, CFSI Active 23 22%
   SoRs not involved in CFSP 56 56%

 

 

5 

 

 

 

Tungsten – Packaging and Materials Services

 

1.During 2014, we purchased tungsten for our packaging and materials services from a total of 2 suppliers. None of these suppliers are SoRs, and did purchase tungsten from a SoR or another third party. Based on data we collected, we identified 2 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2014. Our 2 tungsten suppliers for our packaging and materials services responded to our request, representing 100% of our total expenditure for tungsten for our packaging and materials services during 2014.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, the 2 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2014 are participants in the CFSP operated by CFSI or participants in the Tungsten Industry—Conflict Minerals Council, or TI-CMC.

 

3.The following table summarizes our RCOI results for tungsten purchased for our packaging and materials services in 2014.

 

Companies supplying tungsten for our packaging and materials services Number %
Companies from which we purchased tungsten 2 100%
   Companies that provided SoR source information 2 100%
   Companies that  were not able provide SoR source information 0 0%
     
SoRs of tungsten for our packaging and materials services    
SoRs from which we indirectly purchased tungsten 2 100%
   SoRs with Smelter ID, CFSI Compliant 2 100%
   SoRs with Smelter ID, CFSI Active or TI-CMC Progressing 0 0%
   SoRs not involved in CFSP or TI-CMC 0 0%

 

 

6 

 

 

 

Tungsten – Electronic Manufacturing Services

 

1.During 2014, we purchased tungsten for our electronic manufacturing services from a total of 114 suppliers. None of these suppliers are SoRs and all these suppliers purchased tungsten from SoRs or from other third parties. Based on data collected, 36 SoRs were identified from which we indirectly purchased tungsten for our electronic manufacturing services in 2014. One hundred six of our tungsten suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tungsten during 2014. Eight did not reply.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 9 of the SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2014 are participants in either the CFSP operated by the CFSI or the TI-CMC program.

 

3.The following table summarizes our RCOI results for tungsten purchased for our electronic manufacturing services in 2014.

 

Companies supplying tungsten for our electronic manufacturing services Number %
Companies from which we purchased tungsten 114 100%
   Companies that provided SoR source information 106 93%
   Companies that were not able provide SoR source information 8 7%
     
SoRs of tungsten for our electronic manufacturing services    
SoRs from which we indirectly purchased tungsten 36 100%
   SoRs with Smelter ID, CFSI Compliant 8 22%
   SoRs with Smelter ID, CFSI Active or TI-CMC Progressing 1 3%
   SoRs not involved in CFSP or TI-CMC 27 75%

 

 

7 

 

 

 

Tantalum – Packaging and Materials Services

 

1.During 2014, we purchased tantalum for our packaging and materials services from 1 supplier. This supplier is not an SoR, and it purchased tantalum from an SoR or from third party. Based on data we collected, we identified a total of 1 SoR from which we indirectly purchased tantalum in 2014 for our packaging and materials services. Our tantalum supplier for our packaging and materials services responded to our request, representing 100% of our total expenditure for tantalum during 2014 for our packaging and materials services.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, the SoR from which we indirectly purchased tantalum in 2014 for our packaging and materials services is a participant in the CFSP operated by the CFSI.

 

3.The following table summarizes our RCOI results for tantalum purchased for our packaging and materials services in 2014.

 

Companies supplying tantalum for our packaging and materials services Number %
Companies from which we purchased tantalum 1 100%
   Companies that provided SoR source information 1 100%
   Companies that were not able provide SoR source information 0 0%
     
SoRs of tantalum for our packaging and materials services    
SoRs from which we indirectly purchased tantalum 1 100%
   SoRs with Smelter ID, CFSI Compliant 1 100%
   SoRs with Smelter ID, CFSI Active 0 0%
   SORs not involved in CFSP 0 0%

 

 

8 

 

 

 

Tantalum – Electronic Manufacturing Services

 

1.During 2014, we purchased tantalum for our electronic manufacturing services from a total of 86 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the data collected, 41 SoRs were identified from which we indirectly purchased tantalum for our electronic manufacturing services in 2014. Seventy-eight of our tantalum suppliers for our electronic manufacturing services responded to our request to identify the SoRs for tantalum during 2014. Eight did not reply.

 

2.Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2014, 38 of the SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2014 are participants in the CFSP operated by the CFSI.

 

3.The following table summarizes our RCOI results for tantalum purchased for our electronic manufacturing services in 2014.

 

Companies supplying tantalum for our electronic manufacturing services Number %
Companies from which we purchased tantalum 86 100%
   Companies that provided SoR source information 78 91%
   Companies that were not able provide SoR source information 8 9%
     
SoRs of tantalum for electronic manufacturing services    
SoRs from which we indirectly purchased tantalum 41 100%
   SoRs with Smelter ID, CFSI Compliant 38 93%
   SoRs with Smelter ID, CFSI Active 0 0%
   SORs not involved in CFSP 3 7%

 

 

9 

 

 

 

Part I. Due Diligence

 

Design of Due Diligence

 

ASE designed its due diligence measures to conform to 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: Second Edition, including the related supplements on tantalum, tin, tungsten, and gold.

 

Due Diligence Measures Performed

 

OECD Step 1 Establish strong company management systems

A. Adopt and clearly communicate to suppliers and public

The ASE Group Corporate Policy for Sourcing Conflict Minerals is posted on our website (and attached here as Annex A) as well as distributed to each of our suppliers of conflict minerals who must agree in writing that the policy will be complied with.

 

Additionally, we require each supplier to certify they understand our conflict minerals policy and will comply with its covenants.

 

Finally, every factory manager must certify they comply with our conflict minerals policy. They are also responsible for communicating the policy throughout their organizations and implementing procedures to ensure compliance.

 

B. Structure internal management to support due diligence

Our conflict minerals management team is a comprehensive cross-functional team under the direction of our Chief Operating Officer.  The team provides planning, analysis, management, tracking, monitoring and communication for the business wide initiative.  They hold regular and frequent meetings to ensure progress against requirements.

C. Establish a system of controls and transparency over the mineral supply chain

Conflict minerals procedures are documented in our specifications system and managed by our quality control organization. The bills-of-materials required for different customer products across all manufacturing operations are controlled by our manufacturing execution system software.

 

The primary method for gathering conflict mineral data is through the deployment and gathering of Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Templates (CMRTs). We store this data on a comprehensive filing system that supports ensuring the currency of the data.

 

D. Strengthen company engagement with suppliers

In addition to formal written documentation, ASE is building person-to-person links between employees and suppliers to improve the quality and consistency of vendor communications.  ASE is beginning to hold supplier orientation and training sessions to enable our manufacturing partners to better understand and serve our needs.

 

 

10 

 

 

 

E. Establish grievance mechanism ASE encourages suppliers and employees to have open and honest dialog on issues of mutual interest.  
OECD Step 2 Identify and assess risk in the supply chain

A. Identify risks in the supply chain

Our process for identifying conflict minerals risk in the supply chain is as follows:

 

(a)   Identify all direct materials and components in the supply chain that contain conflict minerals.

 

(b)   Identify suppliers of materials and components that contain conflict minerals.

 

(c)   Gather CMRTs from our suppliers of conflict minerals.

 

(d)   Depending on the enormity and complexity of the supply chain:

 

   Assess the value of the annual purchase volume of all conflict minerals.

   Prioritize conflict mineral sources by dollar volume to leverage impact from available analytical resources.

 

B. Assess risks of adverse impacts

(a) Assess data gathered on templates to identify potential inconsistencies or “red flags.”

 

(b) Follow up as appropriate to resolve items of concern.

OECD Step 3 Design and implement a strategy to respond to identified risks
A. Report finding to designated senior management Periodic reviews are held among team members and with senior management to ensure they are aware of current conflict minerals compliance status.

B. Devise and adopt a risk management plan

In 2014, we began selectively tracking below the smelter level using data contained in the CFSI RCOI database.  In 2015, we will begin supplier audits to validate declarations provided to us.

C. Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management

 Our packaging and materials services mitigate supply chain risk to conflict minerals in two ways:

 

(a)    We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.

 

(b)    For compliance year 2014, we received CMRTs from 100% of our conflict mineral suppliers.

 

 

 

11 

 

 

 

 

Our electronic manufacturing services mitigate supply chain risk to conflict minerals in two ways:

 

(a)    We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.

 

(b)    For compliance year 2014, our electronic manufacturing services identified 232 suppliers that accounted for 95% of our conflict minerals content. In 2015, we will increase the number of suppliers in order to further reduce our risk.

D. Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances

We have begun supplier audits to assess the accuracy of data and statements made by larger suppliers. This program will be broadened over time.

 

ASE has joined the EICC, which provides access to RCOI data in the CFSI database.

 

OECD Step 4 Carry out independent third-party audit of supply chain due diligence at
identified points in the supply chain
 

For CY 2014, ASE has undertaken an Independent Private Sector Audit (IPSA) of our Conflict Minerals Report in compliance with the requirements set forth in the SEC Conflict Minerals Final Rule and subsequent SEC Guidance.

 

In addition, as a member of CFSI, we leverage the due diligence conducted on smelters by the CFSP which uses independent third-party auditors to audit the source of the conflict minerals used by smelters.

 

OECD Step 5 Report on supply chain due diligence.
  ASE filed a Form SD and Conflict Minerals Report for Compliance Year 2014 with the US Securities and Exchange Commission on or before the June 1, 2015 deadline in compliance with the SEC Conflict Minerals Final Rule and subsequent guidance.

 

 

12 

 

 

 

Part II. Due Diligence Determination and Product Declaration

 

Product Declaration

Based on the RCOI analysis and due diligence process for both ASE’s packaging and materials services and electronic manufacturing services, we made the following product determinations.

 

  DRC Conflict Free DRC Conflict Undeterminable Not found to be DRC Conflict Free
Packaging and Materials Services products Packaging (wafer bumping) and materials services (substrate) All other packaging services No services fall in this category

Electronic Manufacturing

Services products

No services fall in this category All electronic manufacturing services No services fall in this category

 

 

Facilities used to Process Conflict Minerals

 

A list of Smelters and Refiners that sourced conflict minerals utilized in our services is provided in Annex D.

 

Conflict Minerals Country of Origin

 

A list of countries where conflict minerals were mined or extracted is listed in Annex E. These minerals may have been smelted or refined in the country of extraction or in facilities around the world.

 

Glossary

 

A glossary of abbreviations and terms is included in Annex C.

 

 

13 

 

 

 

Part III – Independent Private Sector Audit

 

We obtained an independent private sector audit by KPMG. This report is set forth in “Annex B”.

 

 

 

14 

 

 

 

Annex A – ASE Group Corporate Policy for Sourcing Conflict Minerals

 

The mining and distribution of “conflict minerals”1 originating from the Democratic Republic of the Congo are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Group is dedicated to the elimination of these conflict minerals in our supply chain, and to use only conflict-free minerals2 responsibly sourced around the world. It is also our objective to support the continued use of conflict-free minerals from the DRC and the adjacent regions such that responsible mining is not diminished.

 

All suppliers to ASE Group must support this policy by:

 

(a)being diligent in their assessment and validation of their supply chains to ensure ASE Group’s objectives of a transparent supply chain, and conflict-free purchases as inputs to the services and products we produce.

 

(b)at all times be in compliance with all regional and international regulations for conflict minerals.

 

(c)at all times be in compliance with industry standards for the sourcing and reporting of conflict minerals.

 

(d)being diligent and accurate in their formal assurances of conflict-free minerals provided to us.

 

 

1 Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in the Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934.

 

2 Conflict-free minerals are conflict minerals that through their distribution directly or indirectly do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions.

 

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Annex B – Report of Independent Accountants

 

Independent Accountants Report

 

To the Supervisory Board and Shareholders of Advanced Semiconductor Engineering Inc.:

 

We have examined:

 

whether the design of the due diligence framework of Advanced Semiconductor Engineering Inc. (the “Company”) as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”), and

 

whether the Company’s description of the due diligence measures it performed, as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is consistent, in all material respects, with the due diligence process that the Company undertook.

 

Management from the Company is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination.

 

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.

 

Our examination was not conducted for the purpose of evaluating:

 

The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance;

 

The completeness of the Company’s description of the due diligence measures performed;

 

The suitability of the design or operating effectiveness of the Company’s due diligence process;

 

Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance;

 

The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or

 

 

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The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.

 

Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the section titled “Part I. Due Diligence.”

 

In our opinion,

 

the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2014, as set forth in the Company’s Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and

 

the Company’s description of the due diligence measures it performed as set forth in its Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is consistent, in all material respects, with the due diligence process that the Company undertook.

 

/s/ KPMG

 

Taipei, Taiwan (the Republic of China)

 

May 29, 2015

  

 

17 

 

 

 

Annex C – Glossary

 

Term Explanation
ASE Advanced Semiconductor Engineering, Inc.
CFSI Conflict Free Sourcing Initiative
CFSP Conflict Free Sourcing Program
DRC Conflict Free DRC Conflict-free minerals are conflict minerals that, through their mining or distribution, directly or indirectly, do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions.
EICC Electronic Industry Citizenship Coalition
GeSI Global eSustainability Initiative
OECD Organisation for Economic Co-operation and Development
RCOI Reasonable Country of Origin Inquiry
SoR Smelter or Refiner
TI-CMC Tungsten Industry—Conflict Minerals Council

 

 

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Annex D – Smelter List – Combined

 

Entity Legend

A+M Packaging and Materials Services

EMS Electronic Manufacturing Services

 

Material CFSI ID Smelter or Refiner Name Entity SoR Country Location
Gold CID000009 Acade Noble Metal (Zhao Yuan) Corporation EMS CHINA
Gold CID000019 Aida Chemical Industries Co. Ltd. A+M, EMS JAPAN
Gold CID000035 Allgemeine Gold-und Silberscheideanstalt A.G. A+M, EMS GERMANY
Gold CID000041 Almalyk Mining and Metallurgical Complex (AMMC) EMS UZBEKISTAN
Gold CID000058 AngloGold Ashanti Córrego do Sítio Minerção A+M, EMS BRAZIL
Gold CID000077 Argor-Heraeus SA A+M, EMS SWITZERLAND
Gold CID000082 Asahi Pretec Corporation A+M, EMS JAPAN
Gold CID000090 Asaka Riken Co Ltd A+M, EMS JAPAN
Gold CID000103 Atasay Kuyumculuk Sanayi Ve Ticaret A.S. A+M, EMS TURKEY
Gold CID000113 Aurubis AG A+M, EMS GERMANY
Gold CID002716 Austin Powder EMS UNKNOWN
Gold CID000128 Bangko Sentral ng Pilipinas (Central Bank Philippines) A+M, EMS PHILIPPINES
Gold CID000141 Bauer Walser AG EMS GERMANY
Gold CID000157 Boliden AB A+M, EMS SWEDEN
Gold CID000176 C. Hafner GmbH + Co. KG A+M, EMS GERMANY
Gold CID000180 Caridad A+M, EMS MEXICO
Gold CID000185 CCR Refinery – Glencore Canada Corporation (Xstrata) A+M, EMS CANADA
Gold CID000189 Cendres + Métaux SA EMS SWITZERLAND
Gold CID000233 Chimet S.p.A. A+M, EMS ITALY
Gold CID000242 China National Gold Group Corporation EMS CHINA
Gold CID000264 Chugai Mining A+M, EMS JAPAN
Gold CID000272 Cloud Hunan EMS CHINA
Gold CID000288 Colt Refining EMS USA
Gold CID000328 Daejin Indus Co. Ltd EMS KOREA, ROK
Gold CID000343 Daye Non-Ferrous Metals Mining Ltd. EMS CHINA
Gold CID000359 Do Sung Corporation EMS KOREA, ROK
Gold CID000362 Doduco EMS GERMANY
Gold CID000392 Dongguan Standard Electronic Material Co.,Ltd. EMS CHINA
Gold CID000393 Dongguanshi Sutande Dianzi Cailiao Youxiangongsi EMS CHINA
Gold CID000401 Dowa A+M, EMS JAPAN

 

 

19 

 

 

 

Gold CID000425 Eco-System Recycling Co., Ltd. A+M, EMS JAPAN
Gold   Faggi Enrico SPA EMC UNKNOWN
Gold CID000465 Feinhutte Halsbrucke Gmbh EMC GERMANY
Gold CID000493 FSE Novosibirsk Refinery EMS RUSSIAN FED
Gold CID000522 Gansu Seemine Material Hi-Tech Co Ltd EMS CHINA
Gold CID000523 Gansu-based Baiyin Nonferrous Metals Corporation (BNMC) EMS CHINA
Gold CID002459 Geib Refining Corporation EMS USA
Gold CID002312 Guangdong Jinding Gold Limited A+M, EMS CHINA
Gold CID000671 Hangzhou Fuchunjiang Smelting Co., Ltd. EMS CHINA
Gold CID000694 Heimerle + Meule GmbH A+M, EMS GERMANY
Gold CID000707 Heraeus Ltd. Hong Kong A+M, EMS HONG KONG
Gold CID000711 Heraeus Precious Metals GmbH & Co. KG A+M, EMS GERMANY
Gold CID000767 Hunan Chenzhou Mining Industry Group EMS CHINA
Gold CID000778 Hwasung CJ Co. Ltd EMS KOREA, ROK
Gold CID000801 Inner Mongolia Qiankun Gold and Silver Refinery Share A+M, EMS CHINA
Gold CID000807 Ishifuku Metal Industry Co., Ltd. A+M, EMS JAPAN
Gold CID000814 Istanbul Gold Refinery EMS TURKEY
Gold CID000823 Japan Mint EMS JAPAN
Gold CID000855 Jiangxi Copper Company Limited EMS CHINA
Gold CID000920 Johnson Matthey Inc A+M, EMS USA
Gold CID000924 Johnson Matthey Ltd A+M, EMS CANADA
Gold CID000927 JSC Ekaterinburg Non-Ferrous Metal Processing Plant EMS RUSSIAN FED
Gold CID000929 JSC Uralectromed EMS RUSSIAN FED
Gold CID000937 JX Nippon Mining & Metals Co., Ltd. A+M, EMS JAPAN
Gold CID000957 KazZinc Ltd EMS KAZAKHSTAN
Gold CID000969 Kennecott Utah Copper LLC A+M, EMS USA
Gold CID000981 Kojima Chemicals Co., Ltd A+M, EMS JAPAN
Gold CID000988 Korea Metal Co. Ltd EMS KOREA, ROK
Gold CID001009 Kunshan Jinli Chemical Industry Reagents Co., Ltd. EMS CHINA
Gold CID001029 Kyrgyzaltyn JSC EMS KYRGYZSTAN
Gold CID001032 L' azurde Company For Jewelry EMS SAUDI ARABIA
Gold CID001056 Lingbao Gold Company Limited EMS CHINA
Gold CID001058 Lingbao Jinyuan Tonghui Refinery Co. Ltd. EMS CHINA
Gold CID001078 LS-NIKKO Copper Inc. A+M, EMS KOREA, ROK
Gold CID001093 Luoyang Zijin Yinhui Metal Smelt Co Ltd EMS CHINA
Gold CID001113 Materion A+M, EMS USA

 

 

20 

 

 

 

Gold CID001119 Matsuda Sangyo Co., Ltd. A+M, EMS JAPAN
Gold CID001149 Metalor Technologies (Hong Kong) Ltd A+M, EMS HONG KONG
Gold CID001152 Metalor Technologies (Singapore) Pte. Ltd. EMS SINGAPORE
Gold CID001147 Metalor Technologies Ltd. (Suzhou) EMS CHINA
Gold CID001153 Metalor Technologies SA A+M, EMS SWITZERLAND
Gold CID001157 Metalor USA Refining Corporation A+M, EMS USA
Gold CID001161 Met-Mex Penoles, S.A. de C.V. EMS MEXICO
Gold CID001188 Mitsubishi Materials Corporation A+M, EMS JAPAN
Gold CID001193 Mitsui Mining and Smelting Co., Ltd. A+M, EMS JAPAN
Gold CID001204 Moscow Special Alloys Processing Plant EMS RUSSIAN FED
Gold CID001220 Nadir Metal Rafineri San. Ve Tic. A.Ş. A+M, EMS TURKEY
Gold CID001236 Navoi Mining and Metallurgical Combinat A+M, EMS UZBEKISTAN
Gold CID001259 Nihon Material Co. LTD A+M, EMS JAPAN
Gold CID001322 Ohio Precious Metals, LLC A+M, EMS USA
Gold CID001325 Ohura Precious Metal Industry Co., Ltd EMS JAPAN
Gold CID001326 OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals” EMS RUSSIAN FED
Gold CID001328 OJSC Kolyma Refinery EMS RUSSIAN FED
Gold CID001352 PAMP SA - Produits Artistiques de Metaus Precieux SA A+M, EMS SWITZERLAND
Gold CID001362 Penglai Penggang Gold Industry Co Ltd EMS CHINA
Gold CID001386 Prioksky Plant of Non-Ferrous Metals EMS RUSSIAN FED
Gold CID001397 PT Aneka Tambang (Persero) Tbk EMS INDONESIA
Gold CID001498 PX Précinox SA EMS SWITZERLAND
Gold CID001512 Rand Refinery (Pty) Ltd A+M, EMS SO AFRICA
Gold CID001916 Refinery of Shandong Gold Mining A+M, EMS CHINA
Gold CID001534 Royal Canadian Mint A+M, EMS CANADA
Gold CID001546 Sabin Metal Corp. EMS USA
Gold CID001562 Samwon  Metals Corp. EMS KOREA, ROK
Gold CID001573 Schone Edelmetaal EMS NETHERLAND
Gold CID001585 SEMPSA Joyería Platería SA A+M, EMS SPAIN
Gold CID001619 Shandong Tiancheng Biological Gold Industrial Co., Ltd. EMS CHINA
Gold CID001622 Shandong Zhaojin Gold & Silver Refinery Co. Ltd A+M, EMS CHINA
Gold CID001754 So Accurate Group, Inc. EMS USA
Gold CID001756 SOE Shyolkovsky Factory of Secondary Precious Metals EMS RUSSIAN FED
Gold CID001761 Solar Applied Materials Technology Corp. A+M, EMS TAIWAN
Gold CID001798 Sumitomo Metal Mining Co., Ltd. A+M, EMS JAPAN
Gold CID001810 Super Dragon Technology Co., Ltd. EMS CHINA

 

 

21 

 

 

 

Gold CID001843 Tai Zhou Chang San Jiao Electron Co., Ltd. EMS CHINA
Gold CID001875 Tanaka Kikinzoku Kogyo K.K. A+M, EMS JAPAN
Gold CID001909 The Great Wall Gold and Silver Refinery of China EMS CHINA
Gold CID001938 Tokuriki Honten Co., Ltd A+M, EMS JAPAN
Gold CID001947 Tongling Nonferrous Metals Group Co.,Ltd EMS CHINA
Gold CID001955 Torecom EMS KOREA, ROK
Gold CID001977 Umicore Brasil Ltda EMS BRAZIL
Gold CID002314 Umicore Precious Metals Thailand EMS THAILAND
Gold CID001980 Umicore SA Business Unit Precious Metals Refining A+M, EMS BELGIUM
Gold CID001993 United Precious Metal Refining, Inc. A+M, EMS USA
Gold CID002003 Valcambi SA A+M, EMS SWITZERLAND
Gold CID002030 Western Australian Mint trading as The Perth Mint A+M, EMS AUSTRALIA
Gold CID002100 Yamamoto Precious Metal Co., Ltd. A+M, EMS JAPAN
Gold CID002559 Yantai Zhaojin lufu EMS UNKNOWN
Gold CID002129 Yokohama Metal Co Ltd A+M, EMS JAPAN
Gold CID000197 Yunnan Copper Industry Co., Ltd. EMS CHINA
Gold CID002204 Zhaojin Mining Industry Co., Ltd. EMS CHINA
Gold CID002221 Zhongshan Poison Material Monopoly Co. EMS CHINA
Gold CID002224 Zhongyuan Gold Smelter of Zhongjin Gold Corporation A+M, EMS CHINA
Gold CID002243 Zijin Mining Group Co. Ltd A+M, EMS CHINA
Tantalum CID000211 Changsha South Tantalum Niobium Co., Ltd. EMS CHINA
Tantalum CID000291 Conghua Tantalum and Niobium Smeltry EMS CHINA
Tantalum CID000410 Duoluoshan EMS CHINA
Tantalum CID000456 Exotech Inc. EMS USA
Tantalum CID000460 F&X Electro-Materials Ltd. EMS CHINA
Tantalum CID002558 Global Advanced Metals Aizu EMS JAPAN
Tantalum CID002557 Global Advanced Metals Boyertown EMS USA
Tantalum CID000616 Guangdong Zhiyuan New Material Co., Ltd. EMS CHINA
Tantalum CID002501 Guizhou Zhenhua Xinyun Technology Ltd, Kaili branch EMS CHINA
Tantalum CID002544 H.C. Starck Co., Ltd. EMS THAILAND
Tantalum CID002545 H.C. Starck GmbH Goslar EMS GERMANY
Tantalum CID002546 H.C. Starck GmbH Laufenburch EMS GERMANY
Tantalum CID002547 H.C. Starck Hermsdorf GmbH EMS GERMANY
Tantalum CID002548 H.C. Starck Inc. EMS USA
Tantalum CID002549 H.C. Starck Ltd. EMS JAPAN
Tantalum CID002550 H.C. Starck Smelting GmbH & Co.KG EMS GERMANY

 

 

22 

 

 

 

Tantalum CID002492 Hengyang King Xing Lifeng New Materials Co., Ltd. EMS CHINA
Tantalum CID000731 High Temp Specialty Metals EMS USA
Tantalum CID000914 JiuJiang JinXin Nonferrous Metals Co., Ltd. EMS CHINA
Tantalum CID000917 Jiujiang Tanbre Co., Ltd. EMS CHINA
Tantalum CID002539 KEMET Blue Metals EMS MEXICO
Tantalum CID002568 KEMET Blue  Powder EMS USA
Tantalum CID000973 King-Tan Tantalum Industry Ltd EMS CHINA
Tantalum CID001076 LSM Brasil S.A. EMS BRAZIL
Tantalum CID001163 Metallurgical Products India (Pvt.) Ltd. EMS INDIA
Tantalum CID001175 Mineração Taboca S.A. EMS BRAZIL
Tantalum CID001192 Mitsui Mining & Smelting EMS JAPAN
Tantalum CID001200 Molycorp Silmet A.S. EMS ESTONIA
Tantalum CID001277 Ningxia Orient Tantalum Industry Co., Ltd. EMS CHINA
Tantalum CID002540 Plansee SE Liezen EMS AUSTRIA
Tantalum CID002556 Plansee SE Reutte EMS AUSTRIA
Tantalum CID001508 QuantumClean EMS USA
Tantalum CID001522 RFH Tantalum Smeltry Co., Ltd EMS CHINA
Tantalum CID001634 Shanghai Jiangxi Metals Co. Ltd EMS CHINA
Tantalum CID001769 Solikamsk Magnesium Works OAO - Metal Works EMS RUSSIAN FED
Tantalum CID001869 Taki Chemicals EMS JAPAN
Tantalum CID001879 Tantalite Resources EMS SO AFRICA
Tantalum CID001891 Telex EMS USA
Tantalum CID001969 Ulba Metallurgical Plant A+M, EMS KAZAKHSTAN
Tantalum CID002307 Yichun Jin Yang Rare Metal Co., Ltd EMS CHINA
Tantalum CID002232 Zhuzhou Cement Carbide EMS CHINA
Tantalum CID002307 Yichun Jin Yang Rare Metal Co., Ltd EMS CHINA
Tin CID002662 5N Plus EMS UNKNOWN
Tin CID000292 Alpha (ATI Tungsten Materials) A+M, EMS USA
Tin CID000151 Best Metals EMS BRAZIL
Tin CID002673 Cendres & Metaux SA EMS SWITZERLAND
Tin CID000228 Chenzhou Yun Xiang Mining Smelting Co., Ltd. EMS CHINA
Tin CID000244 China Rare Metal Materials Company EMS CHINA
Tin CID001070 China Tin Group Co., Ltd. A+M, EMS CHINA
Tin CID000278 CNMC (Guangxi) PGMA Co. Ltd. A+M, EMS CHINA
Tin CID000295 Cooper Santa A+M, EMS BRAZIL
Tin CID000306 CV Gita Pesona EMS INDONESIA
Tin CID000307 CV JusTindo EMS INDONESIA
Tin CID000308 CV Makmur Jaya EMS INDONESIA

 

 

23 

 

 

 

Tin CID000309 CV Nurjanah EMS INDONESIA
Tin CID000313 CV Serumpun Sebalai A+M, EMS INDONESIA
Tin CID000315 CV United Smelting A+M, EMS INDONESIA
Tin CID000402 Dowa EMS JAPAN
Tin CID002270 Dr. Soldering Tin Products Co., Ltd EMS CHINA
Tin CID000438 Empresa Metalurgica Vinto (Government (100%) A+M, EMS BOLIVIA
Tin CID000448 Estanho de Rondônia S.A. EMS BRAZIL
Tin CID000466 Feinhutte Halsbrucke GmbH EMS GERMANY
Tin CID000468 Fenix Metals A+M, EMS POLAND
Tin CID000545 Gejiu Gold Smelter Minerals Co., Ltd. EMS CHINA
Tin CID000538 Gejiu Non-Ferrous Metal Processing Co. Ltd. A+M, EMS CHINA
Tin CID000555 Gejiu Zi-Li A+M, EMS CHINA
Tin CID000712 Heraeus Precious Metals GmbH & Co. KG EMS GERMANY
Tin CID000760 Huichang Jinshunda Tin Co. Ltd A+M, EMS CHINA
Tin CID000864 Jiangxi Nanshan A+M, EMS CHINA
Tin CID000942 Kai Unita Trade Limited Liability Company A+M, EMS CHINA
Tin CID000986 Koki Japan EMS THAILAND
Tin CID000992 Kovohute Pribram Nastupickna a.s. EMS CZECH REPUBLIC
Tin CID002467 Kurt J Lesker Company EMS UNKNOWN
Tin CID001063 Linwu Xianggui Smelter Co A+M, EMS CHINA
Tin CID001082 Lubeck GmbH EMS GERMANY
Tin CID002468 Magnu's Minerais Metais e Ligas LTDA A+M, EMS BRAZIL
Tin CID001105 Malaysia Smelting Corporation (MSC) A+M, EMS MALAYSIA
Tin CID001112 Materials Eco-Refining Co., Ltd. EMS JAPAN
Tin CID002500 Melt Metais e Ligas S/A EMS BRAZIL
Tin CID001136 Metahub Industries Sdn. Bhd. EMS MALAYSIA
Tin CID001142 Metallic Resources Inc. EMS USA
Tin CID001143 Metallo Chimique A+M, EMS BELGIUM
Tin CID001173 Mineração Taboca S.A. A+M, EMS BRAZIL
Tin CID001177 Ming Li Jia Smelt Metal Factory EMS CHINA
Tin CID001182 Minsur A+M, EMS PERU
Tin CID001191 Mitsubishi Materials Corporation A+M, EMS JAPAN
Tin CID002573 Nghe Tin Non-Ferrous Metal EMS VIETNAM
Tin CID001305 Novosibirsk Integrated Tin Works A+M, EMS RUSSIAN FED
Tin CID001314 O.M. Manufacturing (Thailand) Co., Ltd. A+M, EMS THAILAND
Tin CID002517 O.M. Manufacturing Philippines, Inc. EMS PHILIPPINES
Tin CID001337 Operaciones Metalurgica SA (OMSA) A+M, EMS BOLIVIA
Tin CID001393 PT Alam Lestari Kencana EMS INDONESIA

 

 

24 

 

 

 

Tin CID001399 PT Artha Cipta Langgeng A+M, EMS INDONESIA
Tin CID002503 PT ATD Makmur Mandiri Jaya EMS INDONESIA
Tin CID001402 PT Babel Inti Perkasa A+M, EMS INDONESIA
Tin CID001406 PT Babel Surya Alam Lestari EMS INDONESIA
Tin CID001409 PT Bangka Kudai Tin EMS INDONESIA
Tin CID001412 PT Bangka Putra Karya A+M, EMS INDONESIA
Tin CID001416 PT Bangka Timah Utama Sejahtera EMS INDONESIA
Tin CID001419 PT Bangka Tin Industry A+M, EMS INDONESIA
Tin CID001421 PT Belitung Industri Sejahtera A+M, EMS INDONESIA
Tin CID001424 PT BilliTin Makmur Lestari EMS INDONESIA
Tin CID001428 PT Bukit Timah Tbk A+M, EMS INDONESIA
Tin CID001434 PT DS Jaya Abadi A+M, EMS INDONESIA
Tin CID001438 PT Eunindo Usaha Mandiri A+M, EMS INDONESIA
Tin CID001442 PT Fang Di MulTindo EMS INDONESIA
Tin CID002287 PT Hanjaya Perkasa Metals EMS INDONESIA
Tin CID001445 PT HP Metals Indonesia EMS INDONESIA
Tin CID002530 PT Inti Stania Prima EMS INDONESIA
Tin CID001448 PT Karimun Mining A+M, EMS INDONESIA
Tin CID001449 PT Koba Tin EMS INDONESIA
Tin CID001453 PT Mitra Stania Prima A+M, EMS INDONESIA
Tin CID001457 PT Panca Mega Persada EMS INDONESIA
Tin CID001458 PT Prima Timah Utama A+M, EMS INDONESIA
Tin CID001460 PT Refined Bangka Tin A+M, EMS INDONESIA
Tin CID001463 PT Sariwiguna Binasentosa A+M, EMS INDONESIA
Tin CID001466 PT Seirama Tin investment EMS INDONESIA
Tin CID001468 PT Stanindo Inti Perkasa A+M, EMS INDONESIA
Tin CID001471 PT Sumber Jaya Indah EMS INDONESIA
Tin CID001476 PT Supra Sukses Trinusa EMS INDONESIA
Tin CID001477 PT Tambang Timah A+M, EMS INDONESIA
Tin CID001482 PT Timah (Persero), Tbk A+M, EMS INDONESIA
Tin CID001486 PT Timah Nusantara Tbk (Pelat) EMS INDONESIA
Tin CID001490 PT Tinindo Inter Nusa A+M, EMS INDONESIA
Tin CID001493 PT Tommy Utama EMS INDONESIA
Tin CID001494 PT Yinchendo Mining Industry EMS INDONESIA
Tin CID001539 Rui Da Hung A+M, EMS TAIWAN
Tin CID001606 Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. EMS CHINA
Tin CID001758 Soft Metais, Ltd. A+M, EMS BRAZIL
Tin CID001845 Taicang City Nancang Metal Material Co., Ltd. EMS CHINA

 

 

25 

 

 

 

Tin CID001898 Thaisarco A+M, EMS THAILAND
Tin CID001946 Tongding Metal Material Co., Ltd EMS CHINA
Tin CID001986 Uniforce Metal  Industrial Corp. EMS TIAWAN
Tin CID002486 Vertex Metals Incorporated EMS TAIWAN
Tin CID002035 Westfalenzinn EMS GERMANY
Tin CID002036 White Solder Metalurgia e Mineração Ltda. A+M, EMS BRAZIL
Tin CID002054 Wu Xi Shi Yi Zheng Ji Xie She Bei EMS CHINA
Tin CID002430 Xin Tongding EMS UNKNOWN
Tin CID002559 Yantai ZhaoJin Kasfort Precious Incorporated Company EMS CHINA
Tin CID002121 Yifeng Tin Industry (Chenzhou) Co., Ltd. EMS CHINA
Tin CID002158 Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. A+M, EMS CHINA
Tin CID002180 Yunnan Tin Company, Ltd. A+M, EMS CHINA
Tin   Zhuzhou Smelter Group Co., Ltd EMS CHINA
Tin CID002229 Zhuhai Horyison Solder Co., Ltd. EMS CHINA
Tungsten CID000004 A.L.M.T. Corp. EMS JAPAN
Tungsten CID002344 Chengdu Hongbo Industrial Co., Ltd. EMS CHINA
Tungsten CID002513 Chenzhou Diamond Tungsten Products Co., Ltd. EMS CHINA
Tungsten CID000258 Chongyi Zhangyuan Tungsten Co Ltd EMS CHINA
Tungsten CID000345 Dayu Weiliang Tungsten Co., Ltd. EMS CHINA
Tungsten CID000499 Fujian Jinxin Tungsten Co., Ltd. EMS CHINA
Tungsten CID000875 Ganzhou Huaxing Tungsten Products Co. Ltd. EMS CHINA
Tungsten CID002315 Ganzhou Jiangwu Ferrotungsten Co. Ltd. EMS CHINA
Tungsten CID000868 Ganzhou Non-ferrous Metals Smelting Co., Ltd. EMS CHINA
Tungsten CID002494 Ganzhou Seadragon W & Mo Co., Ltd EMS CHINA
Tungsten CID000568 Global Tungsten & Powders Corp. A+M, EMS USA
Tungsten CID000218 Guangdong XiangLu Tungsten Co., Ltd. EMS CHINA
Tungsten CID002541 H.C. Starck GmbH EMS GERMANY
Tungsten CID002542 H.C. Starck Smelting GmbH & Co. KG EMS GERMANY
Tungsten CID000766 Hunan Chenzhou Mining Group Co., Ltd. EMS CHINA
Tungsten CID000769 Hunan Chunchang Nonferrous Metals Co., Ltd. EMS CHINA
Tungsten CID000825 Japan New Metals Co., Ltd. EMS JAPAN
Tungsten CID002551 Jiangwu H.C. Starck Tungsten Products Co., Ltd. EMS CHINA
Tungsten CID002321 Jiangxi Gan Bei Tungsten Co., Ltd. EMS CHINA
Tungsten CID002313 Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. EMS CHINA
Tungsten CID002493 Jiangxi Richsea New Material Co., Ltd. EMS CHINA
Tungsten CID002318 Jiangxi Tonggu Non-ferrous Metallurgical & Chem Co., EMS CHINA
Tungsten CID002317 Jiangxi Xinsheng Tungsten Industry Co., Ltd. EMS CHINA

 

 

26 

 

 

 

Tungsten CID000966 Kennametal Fallon EMS USA
Tungsten CID000105 Kennametal Inc. (previously ATI Alldyne) Huntsville EMS USA
Tungsten CID002319 Malipo Haiyu Tungsten Co., Ltd. EMS CHINA
Tungsten CID001277 Ningxia Orient Tantalum Industry Co., Ltd. EMS CHINA
Tungsten CID002543 Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC EMS VIETNAM
Tungsten CID002532 Pobedit EMS RUSSIAN FED
Tungsten CID001889 Tejing (Vietnam) Tungsten Co., Ltd. EMS VIETNAM
Tungsten CID002011 Vietnam Youngsun Tungsten Industry Co., Ltd EMS VIETNAM
Tungsten CID002044 Wolfram Bergbau und Hütten AG (Sandvik AB, 100%) EMS AUSTRIA
Tungsten CID002047 Wolfram Company CJSC EMS RUSSIAN FED
Tungsten CID002320 Xiamen Tungsten (H.C.) Co., Ltd. EMS CHINA
Tungsten CID002082 Xiamen Tungsten Co., Ltd. (CXTC) A+M, EMS CHINA
Tungsten CID002095 Xinhai Rendan Shaoguan Tungsten Co., Ltd. EMS CHINA

 

 

27 

 

 

 

Annex E – Countries of Origin of Conflict Minerals

 

It is likely that we used conflict minerals from many of the following sources as well as some that are not identified.

 

Angola Argentina Australia Austria
Belgium Bolivia Brazil Burundi
Canada Central  African Republic Chile China
Columbia Cote d ’Ivor 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 the Congo
Russia Rwanda Sierra Leone Singapore
Slovakia South Africa South Korea South Sudan
Spain Suriname Switzerland Taiwan
Tanzania Thailand Uganda United Kingdom
United States Vietnam Zambia Zimbabwe
Recycle/Scrap      



 

 

28 

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