UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549




FORM SD
SPECIALIZED DISCLOSURE REPORT

KIMBERLY-CLARK CORPORATION
(Exact name of the registrant as specified in its charter)

Delaware
1-225
39-0394230
(State or other jurisdiction
(Commission File
(IRS Employer
of incorporation or organization)
Number)
Identification No.)

P.O. Box 619100, Dallas, Texas
75261-9100
(Address of principal executive offices)
(Zip Code)


Mark A. Buthman, Executive Vice President (972) 281-1200
(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
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD of Kimberly-Clark Corporation is for the period from January 1, 2014 to December 31, 2014. Unless the context indicates otherwise, “Kimberly-Clark,” “we,” “us,” and “our” refer to Kimberly-Clark Corporation and its consolidated subsidiaries.
During 2014, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to their functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. Accordingly, we have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.
Information about our RCOI, as well as the steps we have taken to exercise due diligence on the source and chain of custody of any 3TGs in our Covered Products, is included in our Conflict Minerals Report, which is filed as an exhibit to this Form SD. In addition, our Conflict Minerals Report is publicly available at: http://www.kimberly-clark.com/sustainability/people/CSC.aspx.
Forward-Looking Statements
This Specialized Disclosure Report on Form SD, including the Conflict Minerals Report exhibit, contains forward-looking statements that are based upon management’s expectations and beliefs concerning future events impacting Kimberly-Clark. Certain matters contained herein concerning the future, including risk mitigation steps, constitute forward-looking statements and are based upon management's expectations and beliefs. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. For a description of certain factors that could cause our future results to differ materially from those expressed in any forward-looking statement, see Item 1A of our Annual Report on Form 10-K for the year ended December 31, 2014, entitled “Risk Factors.”
Inherent Limitations on Due Diligence Procedures
As a downstream purchaser of 3TGs, or components containing 3TGs, our due diligence procedures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of such materials. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of 3TGs. We also rely, to a large extent, on information collected and provided by third parties. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
Item 1.02     Exhibit
We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.
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



SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 
 
 
KIMBERLY-CLARK CORPORATION
 
 
 
 
 
Date:
May 22, 2015
 
By:
/s/ Mark A. Buthman
 
 
 
 
Mark A. Buthman
Executive Vice President




2



EXHIBIT INDEX
1.01    Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD





3




Exhibit 1.01

Kimberly-Clark Corporation
Conflict Minerals Report
for the Year Ended December 31, 2014

This Conflict Minerals Report of Kimberly-Clark Corporation has been prepared for the period from January 1, 2014 to December 31, 2014. Unless the context indicates otherwise, “Kimberly-Clark,” “we,” “us” and “our” refer to Kimberly-Clark Corporation and its consolidated subsidiaries.

During 2014, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs (as defined below) are necessary to their functionality or production (“Covered Products”). The term “3TGs” refers to columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten. In 2014, we manufactured or contracted for manufacture Covered Products through our K-C Professional business and, prior to its spin-off on October 31, 2014, our health care business. Electronic components account for a significant majority of any 3TGs present in our Covered Products. Electronic components commonly contain 3TGs for a variety of reasons (e.g., tin may be present in solder).

Our K-C Professional business helps transform workplaces for employees and patrons, making them healthier, safer and more productive, through a range of solutions and supporting products such as apparel, wipers, soaps, sanitizers, tissue and towels. Prior to its spin-off, our health care business provided essentials that help restore patients to better health and improve the quality of patients’ lives by offering surgical and infection prevention products for the operating room, and a portfolio of innovative medical devices focused on pain management, respiratory and digestive health.

We have developed a conflict minerals compliance program reasonably designed to identify whether the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia) (collectively, the “Covered Countries”), or whether any of the 3TGs in our Covered Products are from recycled or scrap sources. Our conflict minerals compliance program is overseen by a team of subject matter experts from key functions, including from our global regulatory affairs, finance, legal, procurement and research and engineering departments, with assistance from a third-party consulting firm that executed certain procedures under our direction, supervision and oversight. Senior management is informed about the progress and results of the program.

We address 3TGs sourced from the Covered Countries in our Supplier Social Compliance Standards, which are embedded in our Purchase Order Terms and Conditions and certain of our supplier agreements, as well as posted on our corporate website at: http://www.kimberly-clark.com/sustainability/people/CSC.aspx.

Our suppliers are required to source responsibly and adhere to our Supplier Social Compliance Standards which require suppliers to source 3TGs from mines and smelters that are either outside of the Covered Countries or that are designated as “conflict-free” by the Conflict-Free Sourcing Initiative (“CFSI”) of the Electronic Industry Citizenship Coalition - Global eSustainability Initiative (“EICC-GeSI”). These standards further require our suppliers to develop and provide written evidence of their own due diligence programs to promote “conflict-free” supply chains. We engage independent third-party audit firms to conduct Supplier Social Compliance audits (on-site inspections) of selected suppliers of certain commodity categories, particularly contract manufacturers.  If an assessment reveals that the supplier is in violation of our Supplier Social Compliance Standards, we require that the supplier submit documentation showing that violations have been addressed and remediated.  We conduct additional follow-up audits at our discretion to confirm compliance with our Supplier Social Compliance Standards. Any concerns regarding suppliers or our compliance program can be reported to our Corporate Social Compliance team as specified on our Corporate Social Compliance website.

In addition, to ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to our suppliers through webinars, videos and substantial one-on-one discussions.



1



Description of Our Reasonable Country of Origin Inquiry

We have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated from one of the Covered Countries or was from recycled or scrap sources.

In conducting our RCOI, we used a risk-based approach. First, we identified our products which contain or potentially contain 3TGs necessary to their functionality or production. Second, we identified the direct suppliers of the materials, components and finished goods supplied to us for those products. Third, we categorized the suppliers as “high risk,” “medium risk,” “low risk” and “very low risk,” based on the likelihood that the materials they supply to us contain 3TGs. Fourth, we conducted a supply chain survey of our direct suppliers to provide information on the origin of any 3TGs contained in materials supplied to us in our Covered Products, including sources of 3TGs supplied to these direct suppliers from second-tier suppliers, as well as suppliers further upstream.
Our survey included all high risk and medium risk suppliers. We determined that it would not be necessary to survey all of our low risk and very low risk suppliers; rather, we developed a representative sample of those suppliers, taking into account, among other factors, whether the supplier was a U.S. publicly-held company and the amount of the supplier’s business with Kimberly-Clark. In addition, we conducted a supply-chain survey of all low risk and very low risk suppliers that previously received a survey for a prior reporting period but failed to respond.
We implemented and administered our supply chain survey with the assistance of our third-party consultant. The survey employed the Conflict Minerals Reporting Template (the “CMRT”) developed by the EICC-GeSI. The CMRT was developed to facilitate general disclosures and information regarding smelters that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers and identification of the smelters used by the supplier.

As of May 15, 2015, approximately 93% of our direct suppliers included in the supply chain survey have responded, including all of our high risk and medium risk suppliers. Ten suppliers indicated that their supply chain includes smelters or refiners sourcing from the Covered Countries; however, we have validated in the due diligence process described below that each of these smelters and refiners has been certified as “conflict-free” by an internationally-recognized validation scheme for 3TG smelters and refiners. A significant majority of the responses received were unable to specify all smelters or refiners used for materials supplied to us. Furthermore, many of the responses were provided at the company or division level, rather than the product level, and indicated that the origin of 3TGs was “unknown.”

Due Diligence Process

Following our RCOI, we conducted a due diligence review of the source and chain of custody of the 3TGs contained in our Covered Products. Our due diligence measures were designed to conform in all material respects with the framework in 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 (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten.

As part of this due diligence process, we reviewed the suppliers’ responses to the surveys discussed above against criteria developed to determine which responses required further engagement with the suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the CMRT. We developed and implemented a risk management plan that includes the following elements:

Incorporation of conflict minerals compliance language into our contracts with direct suppliers as they are entered into or renewed.

Communication directly with executive officers of our suppliers of our conflict minerals requirements under our Supplier Social Compliance Standards, as described above.

Communication with suppliers who do not satisfy our due diligence requests to obtain more complete and accurate responses.



2




Additional follow up, due diligence, and/or risk mitigation activities, as appropriate, upon learning of changes in supplier circumstances or information.
  
Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We do not have direct relationships with 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. We compared these facilities listed in the responses to the lists of smelters and refiners maintained by the CFSI, the United States Department of Commerce (“DoC”) and the London Bullion Market Association (“LBMA”) and, if a supplier indicated that the facility was certified as conflict-free, confirmed that the name was listed by one of the internationally-recognized validation schemes for 3TG smelters and refiners. Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates which of these smelters and refiners have been certified as conflict-free. The large majority of the responses received either provided data at a company or divisional level or did not specify the smelters or refiners used for materials supplied to us. We are therefore unable to determine whether the smelters or refiners reported by certain suppliers processed the 3TGs in the materials supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Attachment B contains an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the CFSI.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products with the greatest possible specificity, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners using the CFSI, DoC and LBMA lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable. Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years.

Risk Mitigation

We have taken or intend to take the following steps to further mitigate the risk that the 3TGs in our Covered Products could benefit armed groups in the Covered Countries:

Continue to review the refinement and expansion of the CFSI, DoC and LBMA lists of smelters and refiners to validate the smelters and refiners provided by suppliers.

Educate and train suppliers with respect to developments in conflict minerals compliance programs and encourage them to establish procedures to identify the origin of 3TGs.

Further improve our direct supplier surveys and due diligence process to gather data regarding the sources of any 3TGs contained in materials supplied to us by continuing to engage with suppliers and direct them to training resources in order to increase the survey response rate and improve response content.

Encourage suppliers that provided company or division level information for 2014 to provide product level information for 2015 through ongoing communications with these suppliers.

Maintain a supplier screening program that requires our suppliers to provide information regarding 3TGs and requires each new in-scope direct supplier we add to our supply chain to provide a completed CMRT.

Continue to incorporate conflict minerals compliance language into our contracts with direct suppliers as they are entered into or renewed.





3



Attachment A
2014 Facility List

The following lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains and indicates (with the * symbol) which of these smelters and refiners have been certified as conflict-free.
 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Gold
 
Aida Chemical Industries Co. Ltd.*
 
JAPAN
Gold
 
Allgemeine Gold-und Silberscheideanstalt A.G.*
 
GERMANY
Gold
 
Almalyk Mining and Metallurgical Complex (AMMC)
 
UZBEKISTAN
Gold
 
AngloGold Ashanti Córrego do Sítio Minerção*
 
BRAZIL
Gold
 
Argor-Heraeus SA*
 
SWITZERLAND
Gold
 
Asahi Pretec Corporation*
 
JAPAN
Gold
 
Asaka Riken Co Ltd.
 
JAPAN
Gold
 
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.*
 
TURKEY
Gold
 
Aurubis AG*
 
GERMANY
Gold
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
 
PHILIPPINES
Gold
 
Bauer Walser AG
 
GERMANY
Gold
 
Boliden AB*
 
SWEDEN
Gold
 
C. Hafner GmbH + Co. KG*
 
GERMANY
Gold
 
Caridad
 
MEXICO
Gold
 
CCR Refinery – Glencore Canada Corporation*
 
CANADA
Gold
 
Cendres + Métaux SA
 
SWITZERLAND
Gold
 
Chimet S.p.A.*
 
ITALY
Gold
 
China National Gold Group Corporation
 
CHINA
Gold
 
Chugai Mining
 
JAPAN
Gold
 
Colt Refining
 
UNITED STATES
Gold
 
Daejin Indus Co. Ltd.
 
KOREA, REPUBLIC OF
Gold
 
Daye Non-Ferrous Metals Mining Ltd.
 
CHINA
Gold
 
Do Sung Corporation
 
KOREA, REPUBLIC OF
Gold
 
Doduco
 
GERMANY
Gold
 
Dowa*
 
JAPAN
Gold
 
Eco-System Recycling Co., Ltd.*
 
JAPAN
Gold
 
FSE Novosibirsk Refinery
 
RUSSIAN FEDERATION
Gold
 
Gansu Seemine Material Hi-Tech Co Ltd.
 
CHINA
Gold
 
Guangdong Jinding Gold Limited
 
CHINA
Gold
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
 
CHINA
Gold
 
Heimerle + Meule GmbH*
 
GERMANY
Gold
 
Heraeus Ltd. Hong Kong*
 
HONG KONG
Gold
 
Heraeus Precious Metals GmbH & Co. KG*
 
GERMANY
Gold
 
Hunan Chenzhou Mining Group Co., Ltd.
 
CHINA
Gold
 
Hwasung CJ Co. Ltd.
 
KOREA, REPUBLIC OF
Gold
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
 
CHINA



4



 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Gold
 
Ishifuku Metal Industry Co., Ltd.*
 
JAPAN
Gold
 
Istanbul Gold Refinery*
 
TURKEY
Gold
 
Japan Mint*
 
JAPAN
Gold
 
Jiangxi Copper Company Limited
 
CHINA
Gold
 
Johnson Matthey Inc.*
 
UNITED STATES
Gold
 
Johnson Matthey Ltd.*
 
CANADA
Gold
 
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
 
RUSSIAN FEDERATION
Gold
 
JSC Uralelectromed*
 
RUSSIAN FEDERATION
Gold
 
JX Nippon Mining & Metals Co., Ltd.*
 
JAPAN
Gold
 
Kazzinc Ltd.*
 
KAZAKHSTAN
Gold
 
Kennecott Utah Copper LLC*
 
UNITED STATES
Gold
 
Kojima Chemicals Co., Ltd.*
 
JAPAN
Gold
 
Korea Metal Co. Ltd.
 
KOREA, REPUBLIC OF
Gold
 
Kyrgyzaltyn JSC
 
KYRGYZSTAN
Gold
 
L' azurde Company For Jewelry*
 
SAUDI ARABIA
Gold
 
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
 
CHINA
Gold
 
LS-NIKKO Copper Inc.*
 
KOREA, REPUBLIC OF
Gold
 
Luoyang Zijin Yinhui Metal Smelt Co Ltd.
 
CHINA
Gold
 
Materion*
 
UNITED STATES
Gold
 
Matsuda Sangyo Co., Ltd.*
 
JAPAN
Gold
 
Metalor Technologies (Hong Kong) Ltd.*
 
HONG KONG
Gold
 
Metalor Technologies (Singapore) Pte. Ltd.*
 
SINGAPORE
Gold
 
Metalor Technologies SA*
 
SWITZERLAND
Gold
 
Metalor USA Refining Corporation*
 
UNITED STATES
Gold
 
Met-Mex Peñoles, S.A.*
 
MEXICO
Gold
 
Mitsubishi Materials Corporation*
 
JAPAN
Gold
 
Mitsui Mining and Smelting Co., Ltd.*
 
JAPAN
Gold
 
Moscow Special Alloys Processing Plant
 
RUSSIAN FEDERATION
Gold
 
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
 
TURKEY
Gold
 
Navoi Mining and Metallurgical Combinat
 
UZBEKISTAN
Gold
 
Nihon Material Co. LTD.*
 
JAPAN
Gold
 
Ohio Precious Metals, LLC*
 
UNITED STATES
Gold
 
Ohura Precious Metal Industry Co., Ltd.*
 
JAPAN
Gold
 
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
 
RUSSIAN FEDERATION
Gold
 
OJSC Kolyma Refinery
 
RUSSIAN FEDERATION
Gold
 
PAMP SA*
 
SWITZERLAND
Gold
 
Penglai Penggang Gold Industry Co Ltd.
 
CHINA
Gold
 
Prioksky Plant of Non-Ferrous Metals
 
RUSSIAN FEDERATION
Gold
 
PT Aneka Tambang (Persero) Tbk*
 
INDONESIA
Gold
 
PX Précinox SA*
 
SWITZERLAND
Gold
 
Rand Refinery (Pty) Ltd.*
 
SOUTH AFRICA



5



 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Gold
 
Royal Canadian Mint*
 
CANADA
Gold
 
Sabin Metal Corp.
 
UNITED STATES
Gold
 
Samduck Precious Metals
 
KOREA, REPUBLIC OF
Gold
 
SAMWON METALS Corp.
 
KOREA, REPUBLIC OF
Gold
 
Schone Edelmetaal*
 
NETHERLANDS
Gold
 
SEMPSA Joyería Platería SA*
 
SPAIN
Gold
 
Shandong Zhaojin Gold & Silver Refinery Co. Ltd.*
 
CHINA
Gold
 
So Accurate Group, Inc.
 
UNITED STATES
Gold
 
SOE Shyolkovsky Factory of Secondary Precious Metals
 
RUSSIAN FEDERATION
Gold
 
Solar Applied Materials Technology Corp.*
 
TAIWAN
Gold
 
Sumitomo Metal Mining Co., Ltd.*
 
JAPAN
Gold
 
Tanaka Kikinzoku Kogyo K.K.*
 
JAPAN
Gold
 
The Great Wall Gold and Silver Refinery of China
 
CHINA
Gold
 
The Refinery of Shandong Gold Mining Co. Ltd.*
 
CHINA
Gold
 
Tokuriki Honten Co., Ltd.*
 
JAPAN
Gold
 
Tongling nonferrous Metals Group Co., Ltd.
 
CHINA
Gold
 
Torecom
 
KOREA, REPUBLIC OF
Gold
 
Umicore Brasil Ltda.*
 
BRAZIL
Gold
 
Umicore Precious Metals Thailand*
 
THAILAND
Gold
 
Umicore SA Business Unit Precious Metals Refining*
 
BELGIUM
Gold
 
United Precious Metal Refining, Inc.*
 
UNITED STATES
Gold
 
Valcambi SA*
 
SWITZERLAND
Gold
 
Western Australian Mint trading as The Perth Mint*
 
AUSTRALIA
Gold
 
YAMAMOTO PRECIOUS METAL CO., LTD.
 
JAPAN
Gold
 
Yokohama Metal Co Ltd.
 
JAPAN
Gold
 
Yunnan Copper Industry Co Ltd.
 
CHINA
Gold
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
 
CHINA
Gold
 
Zijin Mining Group Co. Ltd.*
 
CHINA
Tantalum
 
Changsha South Tantalum Niobium Co., Ltd.*
 
CHINA
Tantalum
 
Conghua Tantalum and Niobium Smeltry*
 
CHINA
Tantalum
 
Duoluoshan*
 
CHINA
Tantalum
 
Exotech Inc.*
 
UNITED STATES
Tantalum
 
F&X Electro-Materials Ltd.*
 
CHINA
Tantalum
 
Guangdong Zhiyuan New Material Co., Ltd.*
 
CHINA
Tantalum
 
Hengyang King Xing Lifeng New Materials Co., Ltd.*
 
CHINA
Tantalum
 
Hi-Temp*
 
UNITED STATES
Tantalum
 
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
 
CHINA
Tantalum
 
Jiujiang Tanbre Co., Ltd.*
 
CHINA
Tantalum
 
KEMET Blue Metals*
 
MEXICO
Tantalum
 
KEMET Blue Powder*
 
UNITED STATES
Tantalum
 
King-Tan Tantalum Industry Ltd.*
 
CHINA
Tantalum
 
LSM Brasil S.A.*
 
BRAZIL



6



 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Tantalum
 
Metallurgical Products India (Pvt.) Ltd.*
 
INDIA
Tantalum
 
Mineração Taboca S.A.*
 
BRAZIL
Tantalum
 
Mitsui Mining & Smelting*
 
JAPAN
Tantalum
 
Molycorp Silmet A.S.*
 
ESTONIA
Tantalum
 
Ningxia Orient Tantalum Industry Co., Ltd.*
 
CHINA
Tantalum
 
QuantumClean*
 
UNITED STATES
Tantalum
 
RFH Tantalum Smeltry Co., Ltd.*
 
CHINA
Tantalum
 
Shanghai Jiangxi Metals Co. Ltd.
 
CHINA
Tantalum
 
Solikamsk Magnesium Works OAO*
 
RUSSIAN FEDERATION
Tantalum
 
Taki Chemicals*
 
JAPAN
Tantalum
 
Telex*
 
UNITED STATES
Tantalum
 
Ulba*
 
KAZAKHSTAN
Tantalum
 
Yichun Jin Yang Rare Metal Co., Ltd.*
 
CHINA
Tantalum
 
Zhuzhou Cement Carbide*
 
CHINA
Tin
 
Alpha*
 
UNITED STATES
Tin
 
China Rare Metal Materials Company*
 
CHINA
Tin
 
China Tin Group Co., Ltd.
 
CHINA
Tin
 
CNMC (Guangxi) PGMA Co. Ltd.
 
CHINA
Tin
 
Cooper Santa
 
BRAZIL
Tin
 
CV Gita Pesona
 
INDONESIA
Tin
 
CV JusTindo
 
INDONESIA
Tin
 
CV Makmur Jaya
 
INDONESIA
Tin
 
CV Nurjanah
 
INDONESIA
Tin
 
CV Serumpun Sebalai
 
INDONESIA
Tin
 
CV United Smelting*
 
INDONESIA
Tin
 
Dowa*
 
JAPAN
Tin
 
EM Vinto*
 
BOLIVIA
Tin
 
Estanho de Rondônia S.A.
 
BRAZIL
Tin
 
Fenix Metals
 
POLAND
Tin
 
Gejiu Kai Meng Industry and Trade LLC
 
CHINA
Tin
 
Gejiu Non-Ferrous Metal Processing Co. Ltd.*
 
CHINA
Tin
 
Gejiu Zi-Li
 
CHINA
Tin
 
Huichang Jinshunda Tin Co. Ltd.
 
CHINA
Tin
 
Jiangxi Nanshan
 
CHINA
Tin
 
Linwu Xianggui Smelter Co
 
CHINA
Tin
 
Magnu's Minerais Metais e Ligas LTDA*
 
BRAZIL
Tin
 
Malaysia Smelting Corporation (MSC)*
 
MALAYSIA
Tin
 
Metallo Chimique*
 
BELGIUM
Tin
 
Mineração Taboca S.A.*
 
BRAZIL
Tin
 
Minsur*
 
PERU
Tin
 
Mitsubishi Materials Corporation*
 
JAPAN
Tin
 
Novosibirsk Integrated Tin Works
 
RUSSIAN FEDERATION



7



 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Tin
 
O.M. Manufacturing (Thailand) Co., Ltd.
 
THAILAND
Tin
 
OMSA*
 
BOLIVIA
Tin
 
PT Alam Lestari Kencana
 
INDONESIA
Tin
 
PT Artha Cipta Langgeng
 
INDONESIA
Tin
 
PT Babel Inti Perkasa*
 
INDONESIA
Tin
 
PT Babel Surya Alam Lestari
 
INDONESIA
Tin
 
PT Bangka Kudai Tin
 
INDONESIA
Tin
 
PT Bangka Putra Karya*
 
INDONESIA
Tin
 
PT Bangka Timah Utama Sejahtera
 
INDONESIA
Tin
 
PT Bangka Tin Industry*
 
INDONESIA
Tin
 
PT Belitung Industri Sejahtera*
 
INDONESIA
Tin
 
PT BilliTin Makmur Lestari
 
INDONESIA
Tin
 
PT Bukit Timah*
 
INDONESIA
Tin
 
PT DS Jaya Abadi*
 
INDONESIA
Tin
 
PT Eunindo Usaha Mandiri*
 
INDONESIA
Tin
 
PT Fang Di MulTindo
 
INDONESIA
Tin
 
PT HP Metals Indonesia
 
INDONESIA
Tin
 
PT Inti Stania Prima
 
INDONESIA
Tin
 
PT Karimun Mining
 
INDONESIA
Tin
 
PT Koba Tin
 
INDONESIA
Tin
 
PT Mitra Stania Prima*
 
INDONESIA
Tin
 
PT Panca Mega Persada*
 
INDONESIA
Tin
 
PT Pelat Timah Nusantara Tbk
 
INDONESIA
Tin
 
PT Prima Timah Utama*
 
INDONESIA
Tin
 
PT REFINED BANGKA TIN*
 
INDONESIA
Tin
 
PT Sariwiguna Binasentosa*
 
INDONESIA
Tin
 
PT Seirama Tin investment
 
INDONESIA
Tin
 
PT Stanindo Inti Perkasa*
 
INDONESIA
Tin
 
PT Sumber Jaya Indah
 
INDONESIA
Tin
 
PT Supra Sukses Trinusa
 
INDONESIA
Tin
 
PT Tambang Timah*
 
INDONESIA
Tin
 
PT Timah (Persero), Tbk*
 
INDONESIA
Tin
 
PT Tinindo Inter Nusa*
 
INDONESIA
Tin
 
PT Tommy Utama
 
INDONESIA
Tin
 
PT Yinchendo Mining Industry
 
INDONESIA
Tin
 
Rui Da Hung
 
TAIWAN
Tin
 
Soft Metais, Ltda.
 
BRAZIL
Tin
 
Thaisarco*
 
THAILAND
Tin
 
White Solder Metalurgia e Mineração Ltda.*
 
BRAZIL
Tin
 
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
 
CHINA
Tin
 
Yunnan Tin Company, Ltd.*
 
CHINA
Tungsten
 
A.L.M.T. Corp.
 
JAPAN



8



 Metal
 
Smelter / Refiner Name
 
 Smelter / Refiner Location
Tungsten
 
Chenzhou Diamond Tungsten Products Co., Ltd.
 
China
Tungsten
 
Chongyi Zhangyuan Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Dayu Weiliang Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Fujian Jinxin Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Huaxing Tungsten Products Co., Ltd.*
 
CHINA
Tungsten
 
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
 
CHINA
Tungsten
 
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Seadragon W & Mo Co., Ltd.*
 
CHINA
Tungsten
 
Global Tungsten & Powders Corp.*
 
UNITED STATES
Tungsten
 
Guangdong Xianglu Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Hunan Chenzhou Mining Group Co., Ltd.
 
CHINA
Tungsten
 
Hunan Chunchang Nonferrous Metals Co., Ltd.*
 
CHINA
Tungsten
 
Japan New Metals Co., Ltd.*
 
JAPAN
Tungsten
 
Jiangxi Gan Bei Tungsten Co., Ltd.*
 
CHINA
Tungsten
 
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Yaosheng Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Kennametal Fallon
 
UNITED STATES
Tungsten
 
Kennametal Huntsville
 
UNITED STATES
Tungsten
 
Malipo Haiyu Tungsten Co., Ltd.*
 
CHINA
Tungsten
 
Tejing (Vietnam) Tungsten Co., Ltd.
 
VIETNAM
Tungsten
 
Vietnam Youngsun Tungsten Industry Co., Ltd.*
 
VIETNAM
Tungsten
 
Wolfram Bergbau und Hütten AG*
 
AUSTRIA
Tungsten
 
Wolfram Company CJSC
 
RUSSIAN FEDERATION
Tungsten
 
Xiamen Tungsten (H.C.) Co., Ltd.*
 
CHINA
Tungsten
 
Xiamen Tungsten Co., Ltd.*
 
CHINA
Tungsten
 
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
 
CHINA
 
 
 
 
 



9



Attachment B
Countries of Origin

The following lists the countries of origin from which the reported facilities in Attachment A collectively source conflict minerals, based on information provided by our suppliers and the CFSI.

Argentina
Kenya
Australia
Malaysia
Austria
Mali
Bolivia
Mexico
Botswana
Mozambique
Brazil
Namibia
Bulgaria
Peru
Burkina Faso
Russia
Canada
Rwanda
Central African Republic
South Africa
Chile
Taiwan
China
Tanzania
Ivory Coast
Thailand
Egypt
Turkey
Ethiopia
United Arab Emirates
Finland
United States
Ghana
Vietnam
Guinea
Zambia
Indonesia
Zimbabwe
Kazakhstan
 
 
 




10
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