UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
HEWLETT-PACKARD COMPANY
(Exact name of the registrant as specified in its charter)
DELAWARE |
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1-4423 |
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94-1081436 |
(State or other jurisdiction of |
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(Commission File Number) |
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(IRS Employer Identification No.) |
incorporation or organization) |
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3000 HANOVER STREET, PALO ALTO, CA |
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94304 |
(Address of principal executive offices) |
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(Zip Code) |
Rishi Varma
Senior Vice President, Deputy General Counsel and Assistant Secretary
(650) 857-1501
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Hewlett-Packard Company (HP) is a leading global provider of products, technologies, software, solutions and services to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. We have a long-standing commitment to global citizenship. As part of our commitment, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HPs Supply Chain Social and Environmental Responsibility Policy, which is available on our website at http://www8.hp.com/us/en/hp-information/global-citizenship/society/supplier-ser-requirements.html. In 2011, we added to this policy a section on conflict minerals (as defined in Item 1.01 of Form SD) and communicated our expectations with respect to these conflict minerals to our supply chain.
Conflict Minerals Disclosure
A copy of the Conflict Minerals Report filed for the calendar year ended December 31, 2014 is publicly available electronically at http://www.hp.com/hpinfo/globalcitizenship/environment/pdf/conflictminerals.pdf.
Item 1.02 Exhibit
The Conflict Minerals Report for the calendar year ended December 31, 2014 is filed as Exhibit 1.01 hereto.
Section 2 Exhibits
Item 2.01 Exhibits
Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.
1
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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HEWLETT-PACKARD COMPANY |
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May 28, 2015 |
By: |
/s/ JOHN F. SCHULTZ |
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Name: |
John F. Schultz |
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Title: |
Executive Vice President, |
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General Counsel and Secretary |
2
EXHIBIT 1.01
CONFLICT MINERALS REPORT OF HEWLETT-PACKARD COMPANY
PURSUANT TO RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
Hewlett-Packard Company (HP) presents this Conflict Minerals Report for the reporting period of January 1, 2014 to December 31, 2014 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and associated guidance issued by the Securities and Exchange Commission. Unless otherwise specified or unless the context otherwise requires, references to HP, we, us or our refer to Hewlett-Packard Company and its consolidated subsidiaries. Terms or phrases that are italicized the first time they appear have the meanings given in Item 1.01 of Form SD.
Overview of our Conflict Minerals Program
HP is a leading global provider of products, technologies, software, solutions and services to individual consumers, small- and medium-sized businesses and large enterprises, including customers in the government, health and education sectors. As part of our long-standing commitment to global citizenship, we expect our suppliers to conduct their worldwide operations in a socially and environmentally responsible manner pursuant to HPs Supply Chain Social and Environmental Responsibility Policy, which is available on our website at http://www8.hp.com/us/en/hp-information/global-citizenship/society/supplier-ser-requirements.html. In 2011, we added to this policy a section on conflict minerals. We engage in ongoing supplier outreach and communications regarding the substance of our conflict minerals policy, our expectations of suppliers with respect to conflict minerals, and our objective of responsible mineral sourcing.
HP collaboratively works with other businesses, nongovernmental organizations, government agencies, and our extensive network of direct suppliers to advance the use of responsibly sourced minerals, including from the Democratic Republic of the Congo (DRC) and adjoining countries (collectively, the Covered Countries). Our work began in 2008 when we helped establish the working group that was the precursor to the Conflict Free Sourcing Initiative (CFSI) and in 2010 we began investigating the uses of tantalum in our products. This year we are able to announce that all of the tantalum smelters reported to be in the supply chain for our products are compliant with the Conflict Free Smelter Program. Other examples of our engagement and contributions to industry and multi-stakeholder groups, as well as in-region sourcing projects, include the Kemet Partnership for Social and Economic Sustainability, the former Conflict Free Tin Initiative, the International Tin Research Institutes Tin Supply Chain Initiative, the Public-Private Alliance for Responsible Mineral Trade, Responsible Sourcing Networks Multi-Stakeholder Group, and the Solutions for Hope Project.
HP Products
Conflict minerals in the form of gold and the derivatives tin, tantalum, and tungsten (collectively, 3TG) were necessary to the functionality or production (necessary conflict minerals) of the following categories of products that we manufactured or contracted to manufacture during 2014.
· Enterprise Products. Server, storage and networking products, and certain accessories.
· Personal Systems Products. Consumer and commercial personal computers, workstations, calculators, tablets, and certain accessories.
· Printing Products. Consumer and commercial printer hardware, scanning devices, certain associated supplies, and certain accessories.
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (RCOI) to determine whether any of the necessary conflict minerals in our 2014 products originated in the Covered Countries, or were conflict minerals from recycled or scrap sources. To make this determination, we focused on engaging our suppliers to identify the smelters and refiners (facilities) of necessary conflict minerals that may have been contained in our products and that are recognized by CFSI to be processors of conflict minerals (Potential 3TG Facilities), and reviewing available information on the sourcing of conflict minerals by Potential 3TG Facilities.
Our RCOI included:
· a survey of 950 of our direct suppliers using the CFSI Conflict Minerals Reporting Template (the Template), from which we identified the 418 direct suppliers of materials, parts, components or products containing necessary conflict minerals (3TG Direct Suppliers);
· requiring, as part of the survey and our accompanying communications, that suppliers use the Template to obtain and provide to HP information from their supply chains regarding Potential 3TG Facilities and the origin of necessary conflict minerals processed at these facilities;
· conducting follow-up with 3TG Direct Suppliers to clarify, update or complete information reported to us through the survey;
· obtaining responses from 3TG Direct Suppliers estimated to represent more than 95% of our 2014 spend with such suppliers;
· reviewing any information on countries of origin available through our membership in CFSI (member ID HPQQ) for Potential 3TG Facilities; and
· engaging an external expert consultant to review other publicly available information to assist us in determining whether or not Potential 3TG Facilities may have sourced from the Covered Countries.
For reporting year 2014, we have determined with respect to our products containing necessary conflict minerals that we know or have reason to believe that some of the necessary conflict minerals originated or may have originated in the Covered Countries. Further, we know or have reason to believe that these necessary conflict minerals may not be conflict minerals from recycled or scrap sources.
Accordingly, we conducted due diligence on the source and chain of custody of necessary conflict minerals processed by Potential 3TG Facilities and have prepared this Conflict Minerals Report.
Design of Our Due Diligence Measures
We designed our due diligence measures to conform with applicable portions of the Organisation 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, OECD 2013)
2
and the related Supplements (collectively, the OECD Guidance), which is a nationally or internationally recognized due diligence framework. The design of our due diligence measures took into account our individual facts and circumstances, particularly our downstream position in the minerals supply chain, the OECD recommendations for downstream actors that have no direct relationships to smelters or refiners(1), and the use of independent facility assessment programs to provide information about smelters or refiners.
Consistent with the OECD Guidance, the design of our due diligence has the following features:
(1) Establishment of strong internal company management systems, including a Conflict Minerals Policy; a Conflict Minerals Program team with senior management support; a Supply Chain Transparency System; engagement with suppliers to communicate and reinforce HP expectations; and a company level grievance mechanism that is available internally and externally to report concerns, including those related to conflict minerals.
(2) Identification and assessment of risks in the supply chain, including through the Supply Chain Transparency System, the mechanism by which risks are identified and assessed in the supply chain. The system is designed to support the Conflict Minerals Program team in systematically surveying, collecting, and analyzing information relating to the use of necessary conflict minerals in the supply chain for our products.
(3) Design and implementation of a strategy to respond to such risks as they are identified, including assessment of information on the due diligence practices of Potential 3TG Facilities, formulation of a risk management plan, and reporting to senior management.
(4) Support of industry organizations to carry out independent third-party audits of facilities due diligence practices, including through our membership in CFSI, the industry initiative that conducts audits of facilities due diligence activities, and assisting CFSI by making facility visits to recruit facilities to participate in the Conflict Free Smelter Program.
(5) Annual reporting through this Conflict Minerals Report, supplemented with additional information about our Conflict Minerals Program in our annual Living Progress Report.
Description of Due Diligence Measures Performed
We undertook due diligence on the source and chain of custody of necessary conflict minerals processed by Potential 3TG Facilities and reviewed our results with senior supply chain management.
Due diligence measures:
· compared the Potential 3TG Facilities to the facilities that are listed by CFSI as either compliant or in process(2) with the Conflict Free Smelter Program;
(1) The OECD Guidance distinguishes between upstream and downstream actors. Upstream refers to the minerals supply chain from the mine to the smelter or refiner, and upstream companies include miners, local traders or exporters, international concentrate traders, and mineral re-processors. Downstream refers to the minerals supply chain from smelters and refiners to retailers and includes companies like HP; it also includes metal traders, component manufacturers, product manufacturers, original equipment manufacturers and retailers.
(2) Throughout this Conflict Minerals report, in process refers to facilities that are listed by CFSI as (a) currently in the process of becoming Conflict Free Smelter Program compliant or (b) Tungsten Industry-Conflict Minerals Council (TI-CMC) Category A members.
3
· directly engaged Potential 3TG Facilities through 11 facility visits and 61 email communications to provide conflict minerals education, collect information on necessary conflict minerals related to the supply chain for our products, or further encourage participation in the Conflict Free Smelter Program;
· implemented a risk management plan including engagement with the relevant 3TG Direct Supplier when a conflict minerals risk was identified with that supplier;
· supported the Conflict Free Smelter Program through leadership participation in sub-committees and on the CFSI Steering Committee; and
· asked 3TG Direct Suppliers to encourage the Potential 3TG Facilities in their supply chain to join the Conflict Free Smelter Program.
Results
We made strong progress toward our objective of responsible minerals sourcing. Of the 257 total Potential 3TG Facilities identified, we believe 22 may source necessary conflict minerals from the Covered Countries. As of April 20, 2015, all 22 of these facilities were listed by CFSI as compliant with the Conflict Free Smelter Program. Globally, 76% of the Potential 3TG Facilities are now Conflict Free Smelter Program compliant or in process to become compliant. All of the tantalum smelters reported to be in our supply chain, whether or not they are sourcing from the Covered Countries, are also compliant with the Conflict Free Smelter program.
Table 1 provides a breakdown of our progress with Potential 3TG Facilities. We more than doubled the number of Potential 3TG Facilities that are compliant as well as the number of Potential 3TG Facilities that are in process to become compliant.
Table 1: Progress in Facility Status
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2013 |
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2014 |
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Number |
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% of Total |
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Number |
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% of Total |
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Compliant |
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60 |
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30 |
% |
152 |
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59 |
% |
In process |
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21 |
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10 |
% |
44 |
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17 |
% |
Not yet participating |
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120 |
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60 |
% |
61 |
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24 |
% |
Total |
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201 |
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257 |
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4
Table 2 further illustrates our results by providing, for each metal, the number and percentage of Potential 3TG Facilities that were either Conflict Free Smelter Program compliant or in process to become compliant as of April 20, 2015.
Table 2: 2014 Compliant or in process facilities, by metal
Tantalum Facilities |
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40 of 40 (100%) |
Tin Facilities |
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51 of 71 (72%) |
Tungsten Facilities |
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32 of 34 (94%) |
Gold Facilities |
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73 of 112 (65%) |
Total |
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196 of 257 (76%) |
Attachment A to this Conflict Minerals Report sets forth the name and status of the 257 Potential 3TG Facilities we identified, and is reasonably believed by us to include the facilities that processed necessary conflict minerals contained in our products.
Attachment B to this Conflict Minerals Report sets forth the countries reasonably believed by us to include the countries of origin of the necessary conflict minerals contained in our products.
Efforts to Determine the Mine or Location of Origin with Greatest Possible Specificity
As a downstream actor we rely upon independent facility assessment programs to collect and review the majority of the upstream information, such as the mine or location of origin of necessary conflict minerals. Consistent with the key role set forth by the OECD Guidance for a downstream actor like HP, our efforts to facilitate upstream mine or location of origin determinations were focused on support of independent facility assessment programs such as the Conflict Free Smelter Program.
To determine the mine or location of origin of necessary conflict minerals, or to facilitate such determinations by independent facility assessment programs, we:
· surveyed 3TG Direct Suppliers during the reporting period of this Conflict Minerals Report using the Template (which included questions about the mine or location of origin) and required those suppliers to make similar efforts to survey their supply chains using the Template;
· reviewed information obtained through those surveys on the 3TG facilities reported by our suppliers, i.e., our Potential 3TG Facilities, and any mine or location of origin information if it was provided;
· assessed any information on countries of origin available through our membership in CFSI for Potential 3TG Facilities (as part of the Conflict Free Smelter Program audit protocol, the independent auditor makes an examination of the countries of origin as well as the location of the mine, even if the specific mine or location of origin for these minerals within a given country is not provided to CFSI members);
· engaged an external expert consultant to review publicly available information that was self-declared by the facility, or found in publicly available media or reports, for further analysis of Potential 3TG Facilities; and
5
· took into account other information on the mine or location of origin of minerals as available, for example, as part of our direct outreach to facilities.
Steps to Further Mitigate Risk and Improve Due Diligence in 2015
We have identified the following steps that are intended to improve the quality of information we receive from 3TG Direct Suppliers in 2015 and to further mitigate any risk that necessary conflict minerals in our products finance or benefit an armed group:
· engage with 3TG Direct Suppliers to improve the completeness and accuracy of information provided to us;
· repeat our request that 3TG Direct Suppliers encourage facilities they have identified in their supply chains to join the Conflict Free Smelter Program; and
· support the development of the CFSIs Conflict Free Smelter Program, including outreach efforts to encourage participation in the program.
6
Attachment A
Facility List
This Facility List is the result of our review of data from several sources, including information reported to us by our 3TG Direct Suppliers, obtained through supplemental engagement with facilities, and from CFSI. In many cases facility information was provided to us for the entire supply chain of our 3TG Direct Suppliers, and did not identify those facilities believed to contribute necessary conflict minerals to an HP product.
Metal |
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Facility Name(3) |
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Facility Status(4), (5) |
Gold |
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Advanced Chemical Company |
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Not yet participating |
Gold |
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Aida Chemical Industries Co. Ltd. |
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CFSP Compliant |
Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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CFSP Compliant |
Gold |
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Almalyk Mining and Metallurgical Complex (AMMC) |
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Not yet participating |
Gold |
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AngloGold Ashanti Córrego do Sítio Minerção |
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CFSP Compliant |
Gold |
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Argor-Heraeus SA |
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CFSP Compliant |
Gold |
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Asahi Pretec Corporation |
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CFSP Compliant |
Gold |
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Asaka Riken Co Ltd |
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In Process |
Gold |
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
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CFSP Compliant |
Gold |
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Aurubis AG |
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CFSP Compliant |
Gold |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
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Not yet participating |
Gold |
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Bauer Walser AG |
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Not yet participating |
Gold |
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Boliden AB |
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CFSP Compliant |
Gold |
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Caridad |
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Not yet participating |
Gold |
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CCR Refinery Glencore Canada Corporation |
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CFSP Compliant |
Gold |
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C. Hafner GmbH + Co. KG |
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CFSP Compliant |
(3) Entities that have been reported to us by 3TG Direct Suppliers as part of their supply chain for conflict minerals and that are recognized by CFSI as a smelter, refiner, recycler or scrap processor (as of April 20, 2015). The facility names are listed as they appear on the CFSI Smelter or Refiner Information Exchange. A company appears more than once if it was reported to us for more than one facility (i.e., smelter, refiner, recycler or scrap processor) that is processing different types of minerals or metals.
(4) Mine or location of origin likely outside of Covered Countries refers to tin processing facilities located in Indonesia that, after reasonable due diligence, we believe are not sourcing cassiterite from the Covered Countries.
(5) CFSP Compliant refers to facilities that are listed by CFSI (as of April 20, 2015) as (a) compliant with Conflict Free Smelter Program protocols or (b) certified or accredited by a similar independent facility assessment program such as the Responsible Jewellery Councils (RJC) Chain-of-Custody Certification Program, or the London Bullion Market Associations (LBMA) Responsible Gold Programme. In Process refers to facilities that are listed by CFSI (as of April 20, 2015) as (a) currently in the process of becoming Conflict Free Smelter Program compliant (In Process) or (b) Tungsten Industry-Conflict Minerals Council (TI-CMC) Category A members (In Process (TI-CMC Category A)). Not yet participating refers to facilities with sourcing practices that could not yet be determined.
A-1
Metal |
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Facility Name(3) |
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Facility Status(4), (5) |
Gold |
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Cendres + Métaux SA |
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In Process |
Gold |
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Chimet S.p.A. |
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CFSP Compliant |
Gold |
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Chugai Mining |
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Not yet participating |
Gold |
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Daejin Indus Co. Ltd |
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Not yet participating |
Gold |
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Daye Non-Ferrous Metals Mining Ltd. |
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Not yet participating |
Gold |
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Doduco |
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In Process |
Gold |
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Do Sung Corporation |
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Not yet participating |
Gold |
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Dowa |
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CFSP Compliant |
Gold |
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Eco-System Recycling Co., Ltd. |
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CFSP Compliant |
Gold |
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Faggi Enrico SPA |
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Not yet participating |
Gold |
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Gansu Seemine Material Hi-Tech Co Ltd |
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Not yet participating |
Gold |
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Geib Refining Corporation |
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Not yet participating |
Gold |
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The Great Wall Gold and Silver Refinery of China |
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Not yet participating |
Gold |
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Guangdong Jinding Gold Limited |
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Not yet participating |
Gold |
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Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
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Not yet participating |
Gold |
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Hangzhou Fuchunjiang Smelting Co., Ltd. |
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Not yet participating |
Gold |
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Heimerle + Meule GmbH |
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CFSP Compliant |
Gold |
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Heraeus Ltd. Hong Kong |
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CFSP Compliant |
Gold |
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Heraeus Precious Metals GmbH & Co. KG |
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CFSP Compliant |
Gold |
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Hunan Chenzhou Mining Group Co., Ltd. |
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Not yet participating |
Gold |
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Hwasung CJ Co. Ltd |
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Not yet participating |
Gold |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
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Not yet participating |
Gold |
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Ishifuku Metal Industry Co., Ltd. |
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CFSP Compliant |
Gold |
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Istanbul Gold Refinery |
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CFSP Compliant |
Gold |
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Japan Mint |
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CFSP Compliant |
Gold |
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Jiangxi Copper Company Limited |
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Not yet participating |
Gold |
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Johnson Matthey Inc |
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CFSP Compliant |
Gold |
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Johnson Matthey Ltd |
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CFSP Compliant |
Gold |
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
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CFSP Compliant |
Gold |
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JSC UralElectromed |
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CFSP Compliant |
Gold |
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JX Nippon Mining & Metals Co., Ltd. |
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CFSP Compliant |
Gold |
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Kazzinc |
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CFSP Compliant |
A-2
Metal |
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Facility Name(3) |
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Facility Status(4), (5) |
Gold |
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Kennecott Utah Copper LLC |
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CFSP Compliant |
Gold |
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Kojima Chemicals Co., Ltd |
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CFSP Compliant |
Gold |
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Korea Metal Co. Ltd |
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Not yet participating |
Gold |
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Kyrgyzaltyn JSC |
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Not yet participating |
Gold |
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L azurde Company For Jewelry |
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CFSP Compliant |
Gold |
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Lingbao Gold Company Limited |
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Not yet participating |
Gold |
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Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
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Not yet participating |
Gold |
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LS-NIKKO Copper Inc. |
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CFSP Compliant |
Gold |
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Luoyang Zijin Yinhui Gold Refinery Co., Ltd |
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Not yet participating |
Gold |
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Materion |
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CFSP Compliant |
Gold |
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Matsuda Sangyo Co., Ltd. |
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CFSP Compliant |
Gold |
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Metalor Technologies (Hong Kong) Ltd |
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CFSP Compliant |
Gold |
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Metalor Technologies SA |
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CFSP Compliant |
Gold |
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Metalor Technologies (Singapore) Pte. Ltd. |
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CFSP Compliant |
Gold |
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Metalor Technologies (Suzhou) Ltd. |
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Not yet participating |
Gold |
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Metalor USA Refining Corporation |
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CFSP Compliant |
Gold |
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Metalúrgica Met-Mex Peñoles, S.A. DE C.V |
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CFSP Compliant |
Gold |
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Mitsubishi Materials Corporation |
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CFSP Compliant |
Gold |
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Mitsui Mining and Smelting Co., Ltd. |
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CFSP Compliant |
Gold |
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Moscow Special Alloys Processing Plant |
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Not yet participating |
Gold |
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Nadir Metal Rafineri San. Ve Tic. A.Ş. |
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CFSP Compliant |
Gold |
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Navoi Mining and Metallurgical Combinat |
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Not yet participating |
Gold |
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Nihon Material Co. LTD |
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CFSP Compliant |
Gold |
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Ohio Precious Metals, LLC |
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CFSP Compliant |
Gold |
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Ohura Precious Metal Industry Co., Ltd |
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CFSP Compliant |
Gold |
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OJSC Kolyma Refinery |
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Not yet participating |
Gold |
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OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastvetmet) |
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CFSP Compliant |
Gold |
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OJSC Novosibirsk Refinery |
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Not yet participating |
Gold |
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PAMP SA |
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CFSP Compliant |
Gold |
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Penglai Penggang Gold Industry Co Ltd |
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Not yet participating |
Gold |
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Prioksky Plant of Non-Ferrous Metals |
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Not yet participating |
Gold |
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PT Aneka Tambang (Persero) Tbk |
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CFSP Compliant |
A-3
Metal |
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Facility Name(3) |
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Facility Status(4), (5) |
Gold |
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PX Précinox SA |
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CFSP Compliant |
Gold |
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Rand Refinery (Pty) Ltd |
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CFSP Compliant |
Gold |
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The Refinery of Shandong Gold Mining Co. Ltd |
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CFSP Compliant |
Gold |
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Republic Metals Corporation |
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CFSP Compliant |
Gold |
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Royal Canadian Mint |
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CFSP Compliant |
Gold |
|
Sabin Metal Corp. |
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Not yet participating |
Gold |
|
Samduck Precious Metals |
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Not yet participating |
Gold |
|
SAMWON METALS Corp. |
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Not yet participating |
Gold |
|
Schone Edelmetaal |
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CFSP Compliant |
Gold |
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SEMPSA Joyería Platería SA |
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CFSP Compliant |
Gold |
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
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Not yet participating |
Gold |
|
Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
|
CFSP Compliant |
Gold |
|
Sichuan Tianze Precious Metals Co., Ltd. |
|
CFSP Compliant |
Gold |
|
So Accurate Group, Inc. |
|
Not yet participating |
Gold |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
In Process |
Gold |
|
Solar Applied Materials Technology Corp. |
|
CFSP Compliant |
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
|
CFSP Compliant |
Gold |
|
Tanaka Kikinzoku Kogyo K.K. |
|
CFSP Compliant |
Gold |
|
Tokuriki Honten Co., Ltd |
|
CFSP Compliant |
Gold |
|
Tongling nonferrous Metals Group Co.,Ltd |
|
Not yet participating |
Gold |
|
Torecom |
|
In Process |
Gold |
|
Umicore Brasil Ltda |
|
CFSP Compliant |
Gold |
|
Umicore Precious Metals Thailand |
|
CFSP Compliant |
Gold |
|
Umicore SA Business Unit Precious Metals Refining |
|
CFSP Compliant |
Gold |
|
United Precious Metal Refining, Inc. |
|
CFSP Compliant |
Gold |
|
Valcambi SA |
|
CFSP Compliant |
Gold |
|
Western Australian Mint trading as The Perth Mint |
|
CFSP Compliant |
Gold |
|
Yamamoto Precious Metal Co., Ltd. |
|
In Process |
Gold |
|
Yokohama Metal Co Ltd |
|
In Process |
Gold |
|
Yunnan Copper Industry Co Ltd |
|
Not yet participating |
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CFSP Compliant |
Gold |
|
Zijin Mining Group Co., Ltd. Gold Refinery |
|
CFSP Compliant |
A-4
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
CFSP Compliant |
Tantalum |
|
Duoluoshan |
|
CFSP Compliant |
Tantalum |
|
Exotech Inc. |
|
CFSP Compliant |
Tantalum |
|
F&X Electro-Materials Ltd. |
|
CFSP Compliant |
Tantalum |
|
Global Advanced Metals Aizu |
|
CFSP Compliant |
Tantalum |
|
Global Advanced Metals Boyertown |
|
CFSP Compliant |
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck GmbH Goslar |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck GmbH Laufenburg |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck Hermsdorf GmbH |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck Inc. |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck Ltd. |
|
CFSP Compliant |
Tantalum |
|
H.C. Starck Smelting GmbH & Co.KG |
|
CFSP Compliant |
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Hi-Temp Specialty Metals, Inc |
|
CFSP Compliant |
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co, Ltd |
|
CFSP Compliant |
Tantalum |
|
Kemet Blue Metals |
|
CFSP Compliant |
Tantalum |
|
Kemet Blue Powder |
|
CFSP Compliant |
Tantalum |
|
King-Tan Tantalum Industry Ltd |
|
CFSP Compliant |
Tantalum |
|
LSM Brasil S.A. |
|
CFSP Compliant |
Tantalum |
|
Metallurgical Products India (Pvt.) Ltd. |
|
CFSP Compliant |
Tantalum |
|
Mineração Taboca S.A. |
|
CFSP Compliant |
Tantalum |
|
Mitsui Mining & Smelting |
|
CFSP Compliant |
Tantalum |
|
Molycorp Silmet A.S. |
|
CFSP Compliant |
Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
CFSP Compliant |
Tantalum |
|
Plansee SE Liezen |
|
CFSP Compliant |
Tantalum |
|
Plansee SE Reutte |
|
CFSP Compliant |
A-5
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
Tantalum |
|
QuantumClean |
|
CFSP Compliant |
Tantalum |
|
RFH Tantalum Smeltry Co., Ltd |
|
CFSP Compliant |
Tantalum |
|
Solikamsk Magnesium Works OAO |
|
CFSP Compliant |
Tantalum |
|
Taki Chemicals |
|
CFSP Compliant |
Tantalum |
|
Telex Metals |
|
CFSP Compliant |
Tantalum |
|
Ulba Metallurgical Plant JSC |
|
CFSP Compliant |
Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd |
|
CFSP Compliant |
Tantalum |
|
Zhuzhou Cement Carbide |
|
CFSP Compliant |
Tin |
|
Alpha |
|
CFSP Compliant |
Tin |
|
China Tin Group Co., Ltd. |
|
In Process |
Tin |
|
CNMC (Guangxi) PGMA Co. Ltd. |
|
Not yet participating |
Tin |
|
Cooperativa Metalurgica de Rondônia Ltda. |
|
CFSP Compliant |
Tin |
|
CV Gita Pesona |
|
In Process |
Tin |
|
CV Serumpun Sebalai |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
CV United Smelting |
|
CFSP Compliant |
Tin |
|
Dowa |
|
CFSP Compliant |
Tin |
|
EM Vinto |
|
CFSP Compliant |
Tin |
|
Estanho de Rondônia S.A. |
|
Not yet participating |
Tin |
|
Feinhütte Halsbrücke GmbH |
|
Not yet participating |
Tin |
|
Fenix Metals |
|
In Process |
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
Not yet participating |
Tin |
|
Gejiu Non-Ferrous Metal Processing Co. Ltd. |
|
CFSP Compliant |
Tin |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
Not yet participating |
Tin |
|
Gejiu Zili Mining and Metallurgy Co., Ltd. |
|
Not yet participating |
Tin |
|
Huichang Jinshunda Tin Co. Ltd |
|
Not yet participating |
Tin |
|
Jiangxi Ketai Advanced Material Co., Ltd. |
|
CFSP Compliant |
Tin |
|
Linwu Xianggui Ore Smelting Co., Ltd |
|
Not yet participating |
Tin |
|
Magnus Minerais Metais e Ligas LTDA |
|
CFSP Compliant |
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
CFSP Compliant |
Tin |
|
Melt Metais e Ligas S/A |
|
CFSP Compliant |
A-6
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
Tin |
|
Metallic Resources Inc |
|
Not yet participating |
Tin |
|
Mineração Taboca S.A. |
|
CFSP Compliant |
Tin |
|
Minsur |
|
CFSP Compliant |
Tin |
|
Mitsubishi Materials Corporation |
|
CFSP Compliant |
Tin |
|
Nankang Nanshan Tin Manufactory Co., Ltd |
|
Not yet participating |
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
In Process |
Tin |
|
Novosibirsk Processing Plant Ltd. |
|
Not yet participating |
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
In Process |
Tin |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
In Process |
Tin |
|
Operaciones Metalurgical S.A. |
|
CFSP Compliant |
Tin |
|
PT Alam Lestari Kencana |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Aries Kencana Sejahtera |
|
In Process |
Tin |
|
PT Artha Cipta Langgeng |
|
In Process |
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
CFSP Compliant |
Tin |
|
PT Babel Inti Perkasa |
|
CFSP Compliant |
Tin |
|
PT Bangka Kudai Tin |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Bangka Putra Karya |
|
CFSP Compliant |
Tin |
|
PT Bangka Timah Utama Sejahtera |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Bangka Tin Industry |
|
CFSP Compliant |
Tin |
|
PT Belitung Industri Sejahtera |
|
CFSP Compliant |
Tin |
|
PT BilliTin Makmur Lestari |
|
In Process |
Tin |
|
PT Bukit Timah |
|
CFSP Compliant |
Tin |
|
PT DS Jaya Abadi |
|
CFSP Compliant |
Tin |
|
PT Eunindo Usaha Mandiri |
|
CFSP Compliant |
Tin |
|
PT Fang Di MulTindo |
|
Mine or location of origin likely outside of Covered |
A-7
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
|
|
|
|
Countries |
Tin |
|
PT HANJAYA PERKASA METALS |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Inti Stania Prima |
|
In Process |
Tin |
|
PT JusTindo |
|
In Process |
Tin |
|
PT Karimun Mining |
|
In Process |
Tin |
|
PT Mitra Stania Prima |
|
CFSP Compliant |
Tin |
|
PT Panca Mega Persada |
|
CFSP Compliant |
Tin |
|
PT Pelat Timah Nusantara Tbk |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Prima Timah Utama |
|
CFSP Compliant |
Tin |
|
PT Refined Bangka Tin |
|
CFSP Compliant |
Tin |
|
PT Sariwiguna Binasentosa |
|
CFSP Compliant |
Tin |
|
PT Seirama Tin investment |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Stanindo Inti Perkasa |
|
CFSP Compliant |
Tin |
|
PT Sumber Jaya Indah |
|
In Process |
Tin |
|
PT Supra Sukses Trinusa |
|
Mine or location of origin likely outside of Covered Countries |
Tin |
|
PT Timah (Persero) Tbk Kundur |
|
CFSP Compliant |
Tin |
|
PT Timah (Persero) Tbk Mentok |
|
CFSP Compliant |
Tin |
|
PT Tinindo Inter Nusa |
|
CFSP Compliant |
Tin |
|
Rui Da Hung |
|
In Process |
Tin |
|
Soft Metais, Ltda. |
|
In Process |
Tin |
|
Thaisarco |
|
CFSP Compliant |
Tin |
|
VQB Mineral and Trading Group JSC |
|
In Process |
Tin |
|
White Solder Metalurgia e Mineração Ltda. |
|
CFSP Compliant |
Tin |
|
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
|
In Process |
A-8
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
Tin |
|
Yunnan Tin Group (Holding) Company Limited |
|
CFSP Compliant |
Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
|
In Process |
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
In Process |
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
In Process |
Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
In Process |
Tungsten |
|
Ganxian Shirui New Material Co., Ltd. |
|
Not yet participating |
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
|
In Process |
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Global Tungsten & Powders Corp. |
|
CFSP Compliant |
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
In Process |
Tungsten |
|
H.C. Starck GmbH |
|
In Process |
Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
|
In Process |
Tungsten |
|
Hunan Chenzhou Mining Group Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Japan New Metals Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. |
|
Not yet participating |
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
In Process |
Tungsten |
|
Kennametal Fallon |
|
In Process (TI-CMC Category A |
A-9
Metal |
|
Facility Name(3) |
|
Facility Status(4), (5) |
|
|
|
|
Member) |
Tungsten |
|
Kennametal Huntsville |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
|
In Process |
Tungsten |
|
Pobedit, JSC |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
In Process (TI-CMC Category A Member) |
Tungsten |
|
Vietnam Youngsun Tungsten Industry Co., Ltd |
|
CFSP Compliant |
Tungsten |
|
Wolfram Bergbau und Hütten AG |
|
CFSP Compliant |
Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
CFSP Compliant |
Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
In Process |
A-10
Attachment B
Countries of Origin
Based on information available from CSFI as of April 20, 2015 and additional research by our external expert consultant, we believe that the countries of origin of the necessary conflict minerals contained in our products include the following countries.
Covered Countries |
|
Outside Covered Countries |
Angola |
|
Argentina |
Burundi |
|
Australia |
Central African Republic |
|
Austria |
Democratic Republic of the Congo |
|
Belgium |
Republic of Congo |
|
Bolivia |
Rwanda |
|
Brazil |
South Sudan |
|
Cambodia |
Tanzania |
|
Canada |
Uganda |
|
Chile |
Zambia |
|
China |
|
|
Colombia |
|
|
Cote dIvoire |
|
|
Czech Republic |
|
|
Djibouti |
|
|
Egypt |
|
|
Estonia |
|
|
Ethiopia |
|
|
France |
|
|
Germany |
|
|
Guyana |
|
|
Hungary |
|
|
India |
|
|
Indonesia |
|
|
Ireland |
|
|
Israel |
|
|
Japan |
|
|
Kazakhstan |
|
|
Kenya |
|
|
The Kyrgyz Republic |
|
|
Laos |
|
|
Luxembourg |
|
|
Madagascar |
|
|
Malaysia |
|
|
Mongolia |
|
|
Mozambique |
|
|
Myanmar |
|
|
Namibia |
|
|
Netherlands |
|
|
Nigeria |
|
|
Peru |
B-1
Covered Countries |
|
Outside Covered Countries |
|
|
Philippines |
|
|
Portugal |
|
|
Russia |
|
|
Sierra Leone |
|
|
Singapore |
|
|
Slovakia |
|
|
South Africa |
|
|
South Korea |
|
|
Spain |
|
|
Suriname |
|
|
Switzerland |
|
|
Taiwan |
|
|
Thailand |
|
|
United Kingdom |
|
|
United States |
|
|
Uzbekistan |
|
|
Vietnam |
|
|
Zimbabwe |
B-2
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