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.
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% |
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% |
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% |
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% |
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% |
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% |
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% |
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% |
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. |
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.
|
|
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. |
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.
Part
III – Independent Private Sector Audit
We
obtained an independent private sector audit by KPMG. This report is set forth in “Annex B”.
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.
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 |
| • | 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
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
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 |
|
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