UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
EchoStar Corporation
(Exact name of registrant as specified in its charter)
Nevada | 001-33807 | 26-1232727 | ||
(State or Other Jurisdiction of Incorporation or Organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
100 Inverness Terrace East, Englewood, Colorado | 80112-5308 | |
(Address of Principal Executive Offices) | (Zip Code) | |
Dean A. Manson
Executive Vice President, General Counsel and Secretary
(303) 706-4000
(Name and telephone number, including area code, of person to contact in connection with this report)
Hughes Satellite Systems Corporation
(Exact name of registrant as specified in its charter)
Colorado | 333-179121 | 45-0897865 | ||
(State or Other Jurisdiction of Incorporation or Organization) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
100 Inverness Terrace East, Englewood, Colorado | 80112-5308 | |
(Address of Principal Executive Offices) | (Zip Code) | |
Dean A. Manson
Executive Vice President, General Counsel and Secretary
(303) 706-4000
(Name and telephone number, including area code, of 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, 2016.
EXPLANATORY NOTE
EchoStar Corporation (“EchoStar”) and its subsidiary, Hughes Satellite Systems Corporation (“Hughes”), each has prepared this Specialized Disclosure Report on Form SD (“Form SD”) pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period of January 1 to December 31, 2016. Unless the context indicates otherwise, any reference in this Form SD to the “Company,” “we,” “us” and “our” refer to EchoStar, Hughes and their respective subsidiaries through December 31, 2016. Each of EchoStar and Hughes is filing this Form SD and the attached Conflict Minerals Report separately and on its own behalf.
SECTION 1—CONFLICT MINERALS DISCLOSURE
ITEM 1.01. Conflict Minerals Disclosure and Report
Introduction
The Rule requires disclosure of certain information when a registrant manufactures, or contracts to manufacture, products whose manufacture was completed during the reporting period that contain certain minerals that are necessary to the functionality or production of such products (the “Covered Products”). The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”). For the Covered Products, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or certain adjoining countries (each, a “Covered Country” and collectively, the “Covered Countries”). If, based on such inquiry, a registrant knows or has reason to believe that any of the Conflict Minerals contained in its products originated or may have originated in a Covered Country and that such Conflict Minerals are not or may not be solely from recycled or scrap sources, the registrant must conduct due diligence with respect to the source and chain of custody of the Conflict Minerals to determine if they directly or indirectly finance or benefit armed groups in the Covered Countries.
Conclusion Based on Reasonable Country of Origin Inquiry
In accordance with the Rule, for the reporting period of January 1 to December 31, 2016, the Company:
• | Determined that the Company manufactured, or contracted to manufacture, Covered Products. |
• | Conducted a good faith reasonable country of origin inquiry which was reasonably designed to determine whether any of the Conflict Minerals in our Covered Products originated in the Covered Countries and, if so, whether any of such Conflict Minerals may be from recycled or scrap sources. Based on that inquiry, the Company has reason to believe that some of the Conflict Minerals in our Covered Products may have originated in one or more of the Covered Countries and that such Conflict Minerals may not be from recycled or scrap sources. |
• | Conducted due diligence with respect to the source and chain of custody of such Conflict Minerals. |
Based on the information obtained through our reasonable country of origin inquiry and our due diligence efforts, which significantly overlap, the Company has reasonably determined that countries of origin of the Conflict Minerals in the Covered Products, to the extent known, include the Covered Countries of Rwanda, Tanzania and Zambia.
Conflict Minerals Disclosure
Based on the results of the procedures described above, the Company has filed this Form SD and the attached Conflict Minerals Report. A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD, and is publicly available on the Company’s website at http://sats.client.shareholder.com/sec.cfm. Unless otherwise stated in this Form SD and the Conflict Minerals Report filed as Exhibit 1.01 hereto, any documents, third-party materials or references to websites, including the Company’s, are not incorporated by reference in, or considered to be a part of, this Form SD and the attached Conflict Minerals Report.
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Forward-Looking Statements
This Form SD and the attached Conflict Minerals Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Exchange Act, including but not limited to statements about our estimates, expectations, plans, objectives, strategies, and financial condition, expected impact of regulatory developments and legal proceedings, opportunities in our industries and businesses and other trends and projections for the future. All statements, other than statements of historical facts, may be forward-looking statements. Forward-looking statements may also be identified by words such as “anticipate,” “intend,” “plan,” “goal,” “seek,” “believe,” “estimate,” “expect,” “predict,” “continue,” “future,” “will,” “would,” “could,” “can,” “may” and similar expressions that convey uncertainty of future events or outcomes and the negatives of those terms. These forward-looking statements are based on information available to us as of the date of this Form SD and the attached Conflict Minerals Report and represent management’s current views and assumptions about future events. Forward-looking statements are not guarantees of future performance, actions, events or results and involve potential known and unknown risks, uncertainties and other factors, many of which may be beyond our control and may pose a risk to our operating and financial condition. Accordingly, actual performance, events or results could differ materially from those expressed or implied in the forward-looking statements due to a number of factors. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in EchoStar’s and Hughes’s respective reports, including EchoStar’s and Hughes’s respective annual reports on Form 10-K for the fiscal year ended December 31, 2016, EchoStar’s and Hughes’s respective quarterly reports on Form 10-Q and other documents that each of EchoStar and Hughes files with or furnishes to the Securities and Exchange Commission from time to time. You should not put undue reliance on any forward-looking statements. Unless we are required to do so under U.S. federal securities laws or other applicable laws, we do not intend to update or revise any forward-looking statements. All cautionary statements made herein should be read as being applicable to all forward-looking statements wherever they appear. Investors should consider the risks and uncertainties described herein and should not place undue reliance on any forward-looking statements, which speak only as of the date hereof. We do not undertake, and specifically disclaim, any obligation to publicly release the results or any revisions that may be made to any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by law.
ITEM 1.02. Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing our Conflict Minerals Report as Exhibit 1.01 to this Form SD.
SECTION 2—EXHIBITS
ITEM 2.01. Exhibits
The following exhibit is filed as part of this Form SD.
Exhibit No. | Description | |
1.01 | Conflict Minerals Report of EchoStar Corporation and Hughes Satellite Systems Corporation for the reporting period January 1 to December 31, 2016. | |
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, each registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
ECHOSTAR CORPORATION HUGHES SATELLITE SYSTEMS CORPORATION | ||
By: | /s/ Dean A. Manson | |
Dean A. Manson | ||
May 24, 2017 | Executive Vice President, General Counsel and Secretary | |
EXHIBIT INDEX
Exhibit No. | Description | |
1.01 | Conflict Minerals Report of EchoStar Corporation and Hughes Satellite Systems Corporation for the reporting period January 1 to December 31, 2016. | |
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Exhibit 1.01
ECHOSTAR CORPORATION
HUGHES SATELLITE SYSTEMS CORPORATION
Conflict Minerals Report
For the reporting period from January 1 to December 31, 2016
Introduction and Background
This Conflict Minerals Report (the “Report”) of EchoStar Corporation (“EchoStar”) and Hughes Satellite Systems Corporation (“Hughes” and, together with EchoStar and the respective subsidiaries of EchoStar and Hughes through December 31, 2016, the “Company,” “we,” “our” and/or “us”) has been prepared pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 to December 31, 2016. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”) that originated in the Democratic Republic of the Congo (“DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
Pursuant to the Rule, the Company has concluded, in good faith, that during the reporting period from January 1 to December 31, 2016:
• | the Company manufactured, or contracted to manufacture, products whose manufacture was completed in calendar year 2016 as to which Conflict Minerals are necessary to the functionality or production of those products (our “Covered Products”); and |
• | based on its good faith reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals in our Covered Products, the Company had reason to believe that certain of the Conflict Minerals necessary to the functionality or production of our Covered Products may have originated in one or more of the Covered Countries and that such Conflict Minerals may not be from recycled or scrap sources. |
Therefore, the Company performed due diligence on the source and chain of custody of such Conflict Minerals in our Covered Products. The Company is filing this Report with its Specialized Disclosure Report on Form SD (the “Form SD”) to comply with the requirements of the Rule. This Report has not been subject to an independent private sector audit.
PART I. COMPANY OVERVIEW AND DESCRIPTION OF PRODUCTS COVERED BY THIS REPORT
Description of Products
During the reporting period, we were a global provider of satellite operations, video delivery solutions, digital set top boxes, and broadband satellite technologies and services for home and small office customers, delivering innovative network technologies, managed services, and solutions for enterprise and government customers. This Report relates to our Covered Products under our Hughes and EchoStar Technologies business segments, which consist of:
Hughes:
Broadband Satellite Systems — The Company’s broadband and satellite products during the reporting period included broadband systems and terminals, mobile satellite systems, handheld devices and IP data terminals for mobile satellite operators, all of which support the delivery of a wide range of bandwidth-intensive services as well as privately-branded service offerings, including high-speed internet/intranet access, video conferencing, distance learning, telemedicine, newsgathering, fleet operations and broadband on planes, trains and maritime.
EchoStar Technologies:
SAGE by Hughes —The Company’s integrated home automation and self-monitoring system, which incorporated a Hub (principal control unit) and peripheral devices designed to allow individual users remote access to a variety of home control and home monitoring features. In July 2016, the Company made the decision not to proceed with this product offering and the associated services. The Company completed the process of shutting down all activities, services and operations related to this product offering in 2016.
Digital Set-Top Boxes — The Company’s digital set-top boxes during the reporting period included digital set-top boxes used by consumers for the viewing of television content delivered via satellite or cable or over the air. Certain models of the Company’s digital set-top boxes also contained internal hard drives to enable digital video recorder features as well as software-enabled advanced capabilities and functionalities. In addition to digital set-top boxes, the Company designed and developed related products during the reporting period, including satellite dishes and remote controls.
Slingbox™ Units — The Company’s Slingbox units during the reporting period enabled “placeshifting” technology, which allowed a customer, at his or her option, to watch and control digital television content anywhere in the world via a broadband internet connection.
Certain of our Covered Products were designed, developed, engineered, manufactured, assembled and/or distributed by us; however, we also outsourced a significant portion of these functions to third parties. We worked with third-party vendors for the development and manufacture of components that are integrated into our Covered Products. We developed dual sourcing capabilities for critical parts when practical and we evaluated outsourced subcontract vendors on a periodic basis.
On January 31, 2017, EchoStar and certain of its subsidiaries entered into a Share Exchange Agreement (the “Share Exchange Agreement”) with DISH Network and certain of its subsidiaries. Pursuant to the Share Exchange Agreement, on February 28, 2017, among other things, EchoStar and certain of its subsidiaries received all of the shares of the Hughes Retail Preferred Tracking Stock issued by EchoStar (the “EchoStar Tracking Stock”) and the Hughes Retail Preferred Tracking Stock issued by Hughes Satellite System Corporation (the “HSS Tracking Stock”, together with the EchoStar Tracking Stock, the “Tracking Stock”) in exchange for 100% of the equity interests of certain EchoStar subsidiaries that held substantially all of the EchoStar Technologies businesses and certain other assets (collectively, the “Share Exchange”). Following consummation of the Share Exchange, EchoStar no longer operates the EchoStar Technologies business segment, which produced the digital set-top boxes and the Slingbox™ units.
PART II. DESIGN OF OUR DUE DILIGENCE MEASURES
We designed our due diligence measures based on the five-step framework laid out by the Organization for Economic Co-operation and Development in its OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (2016), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”). Summarized below are the components of our due diligence measures as they relate to the five-step framework from the OECD Guidance.
Establish Strong Company Management Systems for Conflict Minerals Supply Chain Due Diligence
Designate Internal Corporate Team
The Company has an internal team, composed of senior members of the Company’s supply chain and procurement operations and the legal department, which evaluates the Company’s supply chain processes and sourcing procedures and designs and supports the Company’s due diligence efforts. The team meets periodically to develop and refine a due diligence process that:
• | is consistent with the OECD Guidance, |
• | conforms to the requirements of the Rule, and |
• | is appropriate given the structure and operations of the Company’s supply chain departments. |
The Company’s internal audit department monitors the diligence process, provides feedback and reviews the due diligence results.
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Each existing and new supplier and manufacturer (collectively referred to as “suppliers”) is assigned to a specific employee within the supply chain department who reports to a senior supply chain manager. A senior supply chain manager disseminates all necessary information and documentation to each employee in the supply chain department responsible for interfacing directly with suppliers.
Commit to a Supply Chain Policy for Minerals from Conflict-Affected and High-Risk Areas
The Company maintains a policy relating to Conflict Minerals (the “Policy”) stating that suppliers shall:
• | have a policy to reasonably assure that the Conflict Minerals in the products they manufacture for or supply to the Company do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Covered Countries; |
• | exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to the Company upon the Company’s request; and |
• | be prepared to assist the Company in meeting the Conflict Minerals reporting requirements under the Rule, as well as other national or international mineral reporting regimes that may arise in the future. |
The Policy is incorporated into the Company’s supplier code of conduct, which is available to our suppliers on our websites. All suppliers of the Company during the reporting period were obligated to comply with the supplier code of conduct.
Establish a System of Controls and Transparency over the Conflict Minerals Supply Chain
The Company employs a system of controls to promote transparency over our Conflict Minerals supply chain by utilizing the Conflict Minerals Reporting Template (“Conflict Minerals Reporting Template”), which is a supply chain survey designed to facilitate the transfer of information through the supply chain to identify the smelters and refiners that process the necessary Conflict Minerals in our Covered Products. The Conflict Minerals Reporting Template was developed by the Conflict-Free Sourcing Initiative (“CFSI”), an Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative. The Company maintains an automated database of the completed Conflict Minerals Reporting Templates submitted to the Company by our suppliers (the “Conflict Minerals Response Database”), which helps us process and analyze the information provided by our suppliers. Once in the Conflict Minerals Response Database, all completed Conflict Mineral Reporting Templates received from suppliers are stored electronically in a central location accessible to authorized employees involved in the due diligence process and are retained in accordance with the Company’s document retention guidelines.
The Company is a member of the CFSI, an organization committed to the responsible sourcing of Conflict Minerals that currently has over 350 participating companies and associations from around the world. As a member, the Company has access to a variety of tools and resources to better assess Conflict Minerals in our supply chain, including the Conflict-Free Smelter Program (the “CFSP”), an audit program designed to validate smelters’ and refiners’ sourcing practices.
Strengthen the Company’s Engagement with Suppliers
We inform our suppliers of our Policy, our due diligence consistent with OECD Guidance and our compliance with the Rule. Moreover, the Company’s purchase order and contract terms and conditions require that suppliers expressly support the supply chain due diligence process employed by the Company.
Establish a Company-Level Grievance Mechanism
The Company maintains an open reporting system through which employees and third parties may report concerns about potential or actual violations of the Policy. Concerns may be reported anonymously or for attribution through several channels, including through an employee’s immediate manager or the Company’s legal department.
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Identify and Assess the Risks in the Company’s Supply Chain
The Company does not purchase Conflict Minerals directly from mines, smelters or refiners and does not have a direct relationship with any mines, smelters or refiners. The Company’s supply chain with respect to our Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacturer of our Covered Products and the original sources of the Conflict Minerals. As a result, the Company designed its due diligence to conform to the requirements of the Rule and the OECD Guidance as applicable for downstream companies. Because the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, the Company relies on its communications with suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. In particular, the Company performs the following measures to identify Conflict Minerals in our Covered Products.
Identify Company Suppliers
The Company identifies our first-tier suppliers by generating reports from the Company’s manufacturing and procurement systems of all manufacturers who made, and all vendors who supplied components or products, for our Covered Products. For components delivered to the Company by distributors, the Company adds the distributors to the supplier list. Senior managers in the supply chain organization review and finalize the supplier list (the “Supplier List”) to create a list that includes all relevant suppliers for purposes of the Rule.
Request Conflict Minerals Reporting Templates from Suppliers
The Company uses good faith efforts to identify from the Conflict Minerals Reporting Templates the smelters and refiners used by our suppliers on the Supplier List. Annually, the Company sends a letter and the Conflict Minerals Reporting Template to the suppliers on the Supplier List. The letter (i) reiterates the requirements of the Rule and its applicability to the Company, (ii) requests that each supplier complete the Conflict Minerals Reporting Template for all Covered Products supplied to the Company for the reporting period, and (iii) encourages suppliers to use smelters and refiners which appear on the CFSI’s Compliant Smelter List (as described below). The Company contacts suppliers that do not respond to the Company’s request by a specified date and suppliers that submit incomplete or inaccurate requests for follow-on discussions and to request additional information, as applicable.
As set forth in the Conflict Minerals Reporting Template and the OECD Guidance, suppliers make representations or provide information regarding, among other things, (i) the country of origin for the Conflict Minerals contained in components or products provided by the supplier to the Company, (ii) whether such Conflict Minerals directly or indirectly finance armed conflict in the Covered Countries, (iii) all smelters and refiners in the supplier’s supply chain for such Conflict Minerals, (iv) whether such smelters and refiners have been validated in compliance with the CFSP, (v) whether such supplier uses the Conflict Minerals Reporting Template with its own suppliers to gather information, and (vi) whether the supplier has its owns conflict mineral policy that requires its direct suppliers to be conflict-free.
Analyze Surveys for CFSI Compliant and Active Smelters and Refiners
If correctly completed, each Conflict Minerals Reporting Template identifies the smelters and refiners within the applicable supplier’s supply chain. The Company reviews the information in the completed Conflict Minerals Reporting Templates against the CFSI’s Compliant Smelter List to determine whether the smelters or refiners associated with the applicable supplier qualify as “conflict-free” or are on the CFSI’s “active” list. We rely upon third party audits of smelters and refiners as part of the CFSI’s CFSP, an audit program designed to validate smelters’ and refiners’ sourcing practices as described below. Smelters and refiners receive a “conflict-free” designation from CFSI if (i) the audited smelter or refiner adheres to the CFSP’s assessment protocols by disclosing to independent auditors the identities and locations of the mines from which it sources Conflict Minerals and (ii) the independent auditor verifies separately that the smelter’s or refiner’s Conflict Minerals originated from conflict-free sources. The CFSI Conflict-Free Smelter List includes the names, locations and links to conflict minerals policies of all smelters and refiners deemed “compliant” with the CFSP’s assessment protocols. Smelters and refiners labeled as CFSI “active” have committed to undergo a CFSP audit but have not yet completed their audit or are participating in other cross-recognized certification programs. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase, but may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time.
The Company also uses good faith efforts to identify the country of origin information from the smelters and refiners provided by our suppliers on the Supply List through the Conflict Minerals Reporting Template.
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Design and Implement Strategies to Respond to Identified Risks
Participate in Existing Industry Conflict Minerals Initiatives
In light of the complexity of the Company’s and our suppliers’ supply chains, the Company is currently unable to assess adequately the risk that Conflict Minerals exist in our Covered Products or whether they finance armed conflict in the DRC. However, the Company continues to engage with suppliers to obtain current, accurate and complete information about our supply chains through the use of the Conflict Minerals Reporting Template and to promote “conflict-free” supply chains through our CFSI membership.
Report Findings to Designated Senior Management
The members of the Company’s internal Conflicts Minerals team (consisting of senior members of the Company’s supply chain and procurement operations and the legal department) provide progress reports summarizing the findings from our due diligence efforts to the senior management of the Company.
Independent Third-Party Audits of Smelters/Refiners
Due to its downstream position in the supply chain, the Company does not have a direct relationship with smelters and refiners. Further, the complexity of our supply chain and the many third parties involved between the ultimate manufacturer of our Covered Products and the original sources of the Conflict Minerals hinders the Company’s ability to perform direct audits of smelters and refiners in our supply chain. Instead, we rely upon third party audits of smelters and refiners as part of the CFSI’s CFSP, an audit program designed to validate smelters’ and refiners’ sourcing practices. The CFSP’s audit process is discussed above in more detail in “Identify and Assess the Risks in the Company’s Supply Chain.”
Additionally, through our CFSI membership, we support the further development and implementation of due diligence practices and tools, such as the Conflict Minerals Reporting Template and the CFSP.
Report Annually on Supply Chain Due Diligence
The Company has filed with the Securities and Exchange Commission its Form SD, which includes this Report as Exhibit 1.01, for the reporting period of January 1 to December 31, 2016. In accordance with the OECD Guidance and the Rule, this Report is available on our website at http://sats.client.shareholder.com/sec.cfm.
PART III. DESCRIPTION OF DUE DILIGENCE MEASURES PERFORMED;
RESULTS OF OUR DUE DILIGENCE MEASURES
Compilation and Analysis of Responses
For the reporting period of January 1 to December 31, 2016, the Company identified approximately 470 relevant suppliers. In the fourth quarter of 2016 and the first quarter of 2017, the Company sent each such supplier on the Supplier List a letter requesting completion of the Conflict Minerals Reporting Template. The Company followed up with suppliers that did not respond to the Company’s request by the specified date or that submitted incomplete or inaccurate requests.
The Company received responses from approximately 457, or 97%, of the solicited suppliers, including completed Conflict Minerals Reporting Templates from 435, or approximately 93%, of the solicited suppliers. Through the use of the Conflict Minerals Response Database and access to the CFSP information, we were able to identify the smelters and refiners we believe were used to process the Conflict Minerals contained in our Covered Products as set forth in Annex 1 attached to this Report, as well as to identify which of those smelters and refiners were CFSP “conflict-free” or CFSP “active.”
Based on the information that was provided by the Company’s suppliers and information otherwise obtained by the Company during the due diligence process, the following table sets forth the number of CFSP “conflict-free” and CFSP “active” smelters and refiners in our supply chain as of the end of 2016 for each of the Conflict Minerals used in our Covered Products:
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Conflict Mineral | CFSP Conflict-Free Smelters or Refiners | CFSP Active Smelters or Refiners | |
Gold | 47 | 7 | |
Tantalum | 23 | 0 | |
Tin | 40 | 8 | |
Tungsten | 28 | 0 | |
As discussed in “Part II. Design of Our Due Diligence Analysis” above, the Company relies on the completed Conflict Minerals Reporting Templates received from our suppliers as our main source of documentation supporting the representations made by such suppliers regarding the source and chain of custody of relevant Conflict Minerals in our Covered Products during the reporting period. The smelters and refiners identified in Annex 1 to this Report were identified by our suppliers and the Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain.
Country of Origin of the Conflict Minerals in the Covered Products
Based on the information that was provided by the Company’s suppliers and information otherwise obtained by the Company during the due diligence process, the Company does not have sufficient information, with respect to our Covered Products, to determine the country of origin of all of the Conflict Minerals in all such Covered Products. However, based on the information that has been obtained, to the extent reasonably determinable by the Company, with respect to the smelters and refineries identified by the Company, such countries of origin are believed to include, the Covered Countries of Rwanda, Tanzania and Zambia.
Facilities Used to Process the Conflict Minerals in the Covered Products
Based on the information that was provided by the Company’s suppliers and information otherwise obtained through the due diligence process, the Company was unable to identify with certainty all of the facilities used to process the Conflict Minerals in our Covered Products. However, based on the information that was provided by the Company’s suppliers and information otherwise obtained through the due diligence process, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in our Covered Products are believed to include the smelters and refiners listed in Annex 1 attached to this Report. The smelters and refiners that the Company has been able to determine as CFSP “conflict-free” and CFSP “active” are identified in Annex 1. However, as discussed above, the smelters and refiners identified in Annex 1 to this Report were identified by our suppliers and the Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain.
PART IV. IMPLEMENTATION OF STRATEGIES TO RESPOND TO IDENTIFIED RISKS AND FUTURE STEPS
Due diligence is an ongoing, proactive and reactive process. The Company plans to continue engaging with our suppliers to obtain current, accurate and complete information about the supply chain and to continue our due diligence efforts. Further, reporting on Conflict Minerals is a contractual requirement for our suppliers through our supplier code of conduct. The Company has used our CFSI membership to gain a better understanding of the smelters and refiners in our supply chain and their CFSP compliance status, and we intend to continue to take advantage of the resources available to CFSI members with regard to conflict-free sourcing.
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Annex 1
CURRENTLY KNOWN SMELTER AND REFINERY LIST | |
Metal | Smelter Name | Country of Smelter Facility |
GOLD | ADVANCED CHEMICAL COMPANY | USA |
GOLD | ABINGTON RELDAN METALS. | USA** |
GOLD | AIDA CHEMICAL INDUSTRIES CO. | JAPAN* |
GOLD | AL ETIHAD GOLD REFINERY DMCC | UNITED ARAB EMIRATES |
GOLD | ANHUI TONGLING NONFERROUS METAL MINING CO. | CHINA |
GOLD | ARGOR-HERAEUS S.A. | SWITZERLAND* |
GOLD | ASAHI PRETEC CORP. | CHINA* |
GOLD | ASAHI REFINING USA | USA* |
GOLD | AU TRADERS AND REFINERS | SOUTH AFRICA |
GOLD | BAIYIN NONFERROUS METALS CORPORATION (BNMC) | CHINA |
GOLD | BANGALORE REFINERY | INDIA** |
GOLD | BANGKO SENTRAL NG PILIPINAS (CENTRAL BANK OF THE PHILIPPINES) | PHILIPPINES* |
GOLD | BOLIDEN AB | SWEDEN* |
GOLD | CHIN-LEEP ENTERPRISE CO. | CHINA |
GOLD | COMPAGNIE DES METAUX PRECIEUX PARIS | FRANCE |
GOLD | DAYE NONFERROUS METALS MINING | CHINA |
GOLD | DEGUSSA SONNE / MOND GOLDHANDEL GMBH | GERMANY |
GOLD | DOWA | JAPAN* |
GOLD | DSC (DO SUNG CORPORATION) | SOUTH KOREA |
GOLD | ECHEMI ENTERPRISE CORP. | CHINA |
GOLD | ELEMETAL REFINING | USA* |
GOLD | EMIRATES GOLD DMCC | UNITED ARAB EMIRATES* |
GOLD | FIDELITY PRINTERS AND REFINERS | ZIMBABWE |
GOLD | GANSU SEEMINE MATERIAL HI-TECH CO. | CHINA |
GOLD | GEIB REFINING CORP. | USA |
GOLD | GOLD MINING IN SHANDONG (LAIZHOU) LIMITED COMPANY | CHINA* |
GOLD | GREAT WALL PRECIOUS METALS CO. OF CBPM | CHINA |
GOLD | GUANGDONG JINDING GOLD LIMITED | CHINA |
GOLD | GUODA SAFINA HIGH-TECH ENVIRONMENTAL REFINERY CO. | CHINA |
GOLD | HANGZHOU FUCHUNJIANG SMELTING CO. | CHINA |
GOLD | HEESUNG CATALYSTS CORP. | SOUTH KOREA** |
GOLD | HENAN YUGUANG GOLD & LEAD CO. | CHINA* |
GOLD | HETAI GOLD MINERAL GUANGDONG CO. | CHINA |
GOLD | HOUSE OF CURRENCY OF BRAZIL (CASA DA MOEDA DO BRAZIL) | BRAZIL |
GOLD | HUNAN CHENZHOU MINING GROUP CO. | CHINA |
GOLD | HUNG CHEONG METAL MANUFACTURING LIMITED | CHINA |
GOLD | HWASUNG CJ CO. | SOUTH KOREA |
GOLD | INNER MONGOLIA QIANKUN GOLD AND SILVER REFINERY SHARE CO. | CHINA |
GOLD | ISTANBUL GOLD REFINERY | TURKEY* |
GOLD | JIANGXI COPPER CO. | CHINA* |
GOLD | JIN JINYIN REFINING COMPANY LIMITED | CHINA |
GOLD | JINLONG COPPER CO. | CHINA |
GOLD | JX NIPPON MINING & METALS CO. | JAPAN* |
GOLD | KALOTI PRECIOUS METALS | UNITED ARAB EMIRATES |
GOLD | KAZAKHMYS SMELTING | KAZAKHSTAN |
GOLD | KENNECOTT UTAH COPPER | USA* |
A-1
Metal | Smelter Name | Country of Smelter Facility |
GOLD | KGHM POLSKA MIED AKCYJNA | POLAND** |
GOLD | KOSAK SEIREN | JAPAN |
GOLD | KYSHTYM COPPER-ELECTROLYTIC PLANT ZAO | RUSSIA |
GOLD | LA CARIDAD | MEXICO |
GOLD | L'AZURDE COMPANY FOR JEWELRY | SAUDI ARABIA |
GOLD | LINGBAO GOLD CO. | CHINA |
GOLD | L'ORFEBRE S.A. | ANDORRA |
GOLD | LUOYANG ZIJIN YINHUI GOLD SMELTING CO. | CHINA |
GOLD | MARSAM METALS | BRAZIL** |
GOLD | METALOR TECHNOLOGIES (HONG KONG) | CHINA* |
GOLD | METALOR TECHNOLOGIES (SINGAPORE) PTE | SINGAPORE* |
GOLD | METALOR TECHNOLOGIES (SUZHOU) | CHINA |
GOLD | METALOR TECHNOLOGIES S.A. | SWITZERLAND* |
GOLD | METALOR USA REFINING CORPORATION | USA* |
GOLD | METALURGICA MET-MEX PENOLES S.A. DE C.V. | MEXICO* |
GOLD | MMTC-PAMP INDIA PVT | INDIA* |
GOLD | MORRIS AND WATSON | NEW ZEALAND |
GOLD | MOSCOW SPECIAL ALLOYS PROCESSING PLANT | RUSSIA* |
GOLD | NIHON MATERIAL CO. | JAPAN* |
GOLD | NYRSTAR METALS | USA |
GOLD | OGUSSA OSTERREICHISCHE GOLD- UND SILBER-SCHEIDEANSTALT GMBH | AUSTRIA* |
GOLD | OJSC "THE GULIDOV KRASNOYARSK NON-FERROUS METALS PLANT" (OJSC KRASTSVETMET) | RUSSIA* |
GOLD | OJSC NOVOSIBIRSK REFINERY | RUSSIA* |
GOLD | PAMP S.A. | SWITZERLAND* |
GOLD | PEASE & CURREN | USA |
GOLD | PENGLAI PENGGANG GOLD INDUSTRY CO. | CHINA |
GOLD | PRECIOUS METALS SALES CORP. | USA |
GOLD | PRIOKSKY PLANT OF NON-FERROUS METALS | RUSSIA* |
GOLD | PX PRÉCINOX S.A. | SWITZERLAND* |
GOLD | REALIZED THE ENTERPRISE CO. | CHINA |
GOLD | REMONDIS ARGENTIA B.V. | NETHERLANDS |
GOLD | REPUBLIC METALS CORPORATION | USA* |
GOLD | SAAMP | FRANCE |
GOLD | SAFINA A.S. | CZECH REPUBLIC |
GOLD | SAI REFINERY | INDIA |
GOLD | SAMDUCK PRECIOUS METALS | SOUTH KOREA |
GOLD | SAXONIA EDELMETALLE GMBH | GERMANY |
GOLD | SCHONE EDELMETAAL B.V. | NETHERLANDS* |
GOLD | SEMPSA JOYERÍA PLATERÍA S.A. | SPAIN* |
GOLD | SHAN DONG HUANGJIN | CHINA |
GOLD | SHANDON JIN JINYIN REFINING LIMITED | CHINA |
GOLD | SHANDONG TIANCHENG BIOLOGICAL GOLD INDUSTRIAL CO. | CHINA |
GOLD | SHANDONG ZHAOJIN GOLD & SILVER REFINERY CO. | CHINA* |
GOLD | SHANGDONG PENGLAI GOLD SMELTER | CHINA |
GOLD | SHENZHEN HENG ZHONG INDUSTRY CO. | CHINA |
GOLD | SHENZHEN ZHONGHENGLONG REAL INDUSTRY CO. | CHINA |
GOLD | SICHUAN TIANZE PRECIOUS METALS CO. | CHINA* |
GOLD | SINGWAY TECHNOLOGY CO. | CHINA* |
GOLD | SINO-PLATINUM METALS CO. | CHINA |
GOLD | SO ACCURATE GROUP | USA |
GOLD | SOLARTECH | CHINA* |
A-2
Metal | Smelter Name | Country of Smelter Facility |
GOLD | STENDER ELECTRONIC MATERIALS CO. | CHINA |
GOLD | SUDAN GOLD REFINERY | SUDAN |
GOLD | SUMITOMO METAL MINING CO. | JAPAN* |
GOLD | SUNGEEL HITECH | SOUTH KOREA** |
GOLD | SUPER DRAGON TECHNOLOGY CO. | CHINA |
GOLD | SUZHOU SHENCHUANG RECYCLING | CHINA |
GOLD | T.C.A S.P.A | ITALY* |
GOLD | TANAKA DENSHI KOGYO K.K. | JAPAN* |
GOLD | THE ROYAL CANADIAN MINT | CANADA* |
GOLD | TONY GOETZ NV | BELGIUM** |
GOLD | TOO TAU-KEN-ALTYN | KAZAKHSTAN |
GOLD | UMICORE PRECIOUS METALS THAILAND | THAILAND* |
GOLD | UMICORE S.A. BUSINESS UNIT PRECIOUS METALS REFINING | BELGIUM* |
GOLD | UNITED REFINING COMPANY | USA* |
GOLD | UNIVERSAL PRECIOUS METALS REFINING ZAMBIA | ZAMBIA |
GOLD | VALCAMBI S.A. | SWITZERLAND* |
GOLD | WESTERN AUSTRIALIAN MINT TRADING AS THE PERTH MINT | AUSTRALIA* |
GOLD | WIELAND EDELMETALLE GMBH | GERMANY |
GOLD | XTRATACANADIAN COPPER REFINERY (CCR) | CANADA* |
GOLD | YUEQING CHEMICAL & LIGHT INDUSTRY & BUILDING MATERIALS CO. | CHINA |
GOLD | YUNNAN COPPER INDUSTRY CO. | CHINA |
GOLD | ZHAOJIN MINING INDUSTRY CO. | CHINA |
GOLD | ZHE JIANG GUANG YUAN NOBLE METAL SMELTING FACTORY | CHINA |
GOLD | ZHOGKUANG GOLD INDUSTRY CO. | CHINA |
GOLD | ZIJIN KUANG YE REFINERY | CHINA* |
TANTALUM | ANHUI HERRMAN IMPEX CO. | CHINA |
TANTALUM | CABOT (GLOBAL ADVANCED METALS) | USA |
TANTALUM | CHANGSHA SOUTH TANTALUM NIOBIUM CO. | CHINA* |
TANTALUM | D BLOCK METALS | USA* |
TANTALUM | DUOLUOSHAN | CHINA* |
TANTALUM | GLOBAL ADVANCED METALS AIZU | JAPAN* |
TANTALUM | GLOBAL ADVANCED METALS BOYERTOWN | USA* |
TANTALUM | GOSLARLOWER SAXONY | GERMANY* |
TANTALUM | GUANGDONG ZHIYUAN NEW MATERIAL CO. | CHINA* |
TANTALUM | H.C. STARCK | JAPAN* |
TANTALUM | H.C. STARCK CO. | THAILAND* |
TANTALUM | H.C. STARCK CO. | USA* |
TANTALUM | H.C. STARCK GROUP | GERMANY |
TANTALUM | H.C. STARCK HERMSDORF GMBH | GERMANY* |
TANTALUM | H.C. STARCK SMELTING GMBH & CO. KG | GERMANY* |
TANTALUM | HENGYANG KING XING LIFENG NEW MATERIALS CO. | CHINA* |
TANTALUM | HUNAN CHENZHOU MINING CO. | CHINA |
TANTALUM | JIANGXI DINGHAI TANTALUM & NIOBIUM CO. | CHINA* |
TANTALUM | JIANGXI TUOHONG NEW RAW MATERIAL | CHINA |
TANTALUM | JIUJIANG ZHONGAO TANTALUM & NIOBIUM CO. | CHINA* |
TANTALUM | KEMET CORP. | USA |
TANTALUM | METALLURGICAL PRODUCTS INDIA PVT | INDIA* |
TANTALUM | NANTONG TONGJIE ELECTRICAL CO. | CHINA |
TANTALUM | NPM SILMET AS | ESTONIA* |
TANTALUM | POWER RESOURCES | MACEDONIA |
TANTALUM | QUANTUMCLEAN | USA* |
TANTALUM | RFH TANTALUM SMELTRY CO. | CHINA* |
A-3
Metal | Smelter Name | Country of Smelter Facility |
TANTALUM | SHANGHAI JIANGXI METALS CO. | CHINA |
TANTALUM | TAKI CHEMICAL CO. | JAPAN* |
TANTALUM | TRANZACT | USA* |
TANTALUM | XINXING HAORONG ELECTRONIC MATERIAL CO. | CHINA* |
TANTALUM | YICHUN JIN YANG RARE METAL CO. | CHINA* |
TIN | CHENZHOU YUNXIANG MINING AND METALLURGY CO. | CHINA |
TIN | ALPHA | SOUTH KOREA * |
TIN | AN THAI MINERALS CO. | VIETNAM |
TIN | AN VINH JOINT STOCK MINERAL PROCESSING COMPANY | VIETNAM |
TIN | ARCO ALLOYS | USA |
TIN | BANG MINERALS & METALLURGY JOINT STOCK COMPANY | CHINA** |
TIN | CHENGFENG METALS CO. PTE | CHINA** |
TIN | CHINA TIN GROUP CO. | CHINA* |
TIN | CHOFU WORKS | JAPAN |
TIN | CNMC (GUANGXI) PGMA CO. | CHINA |
TIN | COOPERATIVA METALURGICA DE RONDONIA A. | BRAZIL* |
TIN | CV AYI JAYA | INDONESIA* |
TIN | CV DUA SEKAWAN | INDONESIA |
TIN | CV GITA PESONA | INDONESIA* |
TIN | CV SERUMPUN SEBALAI | INDONESIA* |
TIN | CV TIGA SEKAWAN | INDONESIA |
TIN | CV VENUS INTI PERKASA | INDONESIA* |
TIN | DOWA METALS & MINING CO. | JAPAN* |
TIN | ELMET S.L.U. | SPAIN* |
TIN | EM VINTO | BOLIVIA* |
TIN | ESTANHO DE RONDONIA S.A. | BRAZIL |
TIN | FENIX METALS | POLAND* |
TIN | GEJIU FENGMING METALLURGY CHEMICAL PLANT | CHINA |
TIN | GEJIU JINYE MINERAL CO. | CHINA |
TIN | GEJIU KAI MENG INDUSTRY AND TRADE | CHINA** |
TIN | GEJIU NON-FERROUS METAL PROCESSING CO. | CHINA* |
TIN | GEJIU YUNXI GROUP CORP. | CHINA |
TIN | GEJIU YUNXIN COLORED ELECTROLYTIC CO. | CHINA** |
TIN | GEJIU ZI-LI | CHINA |
TIN | GUANGXI ZHONGSHAN GOLD BELL SMELTING CORP. | CHINA |
TIN | GUANYANG GUIDA NONFERROUS METAL SMELTING PLANT | CHINA |
TIN | HARADA METAL INDUSTRY CO. | JAPAN |
TIN | HECHI METALLURGICAL CHEMICAL FACTORY | CHINA |
TIN | HEZHOU JINWEI TIN CO. | CHINA |
TIN | HONGQIAO METALS (KUNSHAN) CO. | CHINA |
TIN | HUICHANG HILL TIN INDUSTRY CO. | CHINA |
TIN | HUICHANG JINSHUNDA TIN CO. | CHINA** |
TIN | HUNAN XIANGHUALING TIN | CHINA |
TIN | JAU JANQ ENTERPRISE CO. | CHINA |
TIN | JIANGXI HUAYU METAL CO. | CHINA |
TIN | JIANGXI KETAI ADVANCED MATERIAL CO. | CHINA* |
TIN | JIANGXI NANSHAN | CHINA** |
TIN | KUNMING HIGH-TECH INDUSTRIAL DEVELOPING AREA | CHINA |
TIN | LIAN XING PLATING FACTORY | CHINA |
TIN | MAGNU'S MINERAIS METAIS E LIGAS A. | BRAZIL* |
TIN | MALAYSIA SMELTER CORPORATION (MSC) | MALAYSIA* |
TIN | MATERIALS ECO-REFINING CO. | JAPAN |
TIN | MELT METAIS E LIGAS S.A | BRAZIL* |
A-4
Metal | Smelter Name | Country of Smelter Facility |
TIN | METAHUB INDUSTRIES SDN. BHD. | MALAYSIA |
TIN | METALLIC RESOURCES INC. | USA* |
TIN | METALLO-CHIMIQUE N.V. | BELGIUM* |
TIN | MING LI JIA SMELT METAL FACTORY | CHINA |
TIN | MINSUR | PERU* |
TIN | MISUR TIN SMELTER AND REFINERY | PERU |
TIN | MODELTECH SDN BHD | MALAYSIA** |
TIN | NEY METALS & ALLOYS | USA |
TIN | NGHE TIN NONFERROUS METAL | VIETNAM |
TIN | O.M. MANUFACTURING PHILIPPINES | PHILIPPINES* |
TIN | PT ATD MAKMUR MANDIRI JAYA | INDONESIA* |
TIN | PT BANGKA PRIMA TIN | INDONESIA* |
TIN | PT CIPTA PERSADA MULIA | INDONESIA* |
TIN | PT DS JAYA ABADI | INDONESIA* |
TIN | PT INTI STANIA PRIMA | INDONESIA* |
TIN | PT JUSTINDO | INDONESIA* |
TIN | PT KARIMUN MINING | INDONESIA |
TIN | PT KIJANG JAYA MANDIRI | INDONESIA |
TIN | PT LAUTAN HARMONIS SEJAHTERA | INDONESIA |
TIN | PT MENARA CIPTA MULIA | INDONESIA |
TIN | PT NURJANAH | INDONESIA* |
TIN | PT O.M. INDONESIA | INDONESIA |
TIN | PT PRIMA TIMAH UTAMA | INDONESIA* |
TIN | PT SARIWIGUNA BINASENTOSA | INDONESIA* |
TIN | PT SUKSES INTI MAKMUR | INDONESIA* |
TIN | PT TOMMY UTAMA | INDONESIA* |
TIN | RESIND INDUSTRIA E COMERCIO A. | BRAZIL* |
TIN | RUI DA HUNG | CHINA* |
TIN | SETTU CHEMICAL INDUSTRY | JAPAN |
TIN | SHAN TOU SHI YONG YUAN JIN SHU ZAI SHENG CO. | CHINA |
TIN | SHAPIRO | USA |
TIN | SHENZHEN ANCHEN SOLDER TIN PRODUCT CO. | CHINA |
TIN | SIGMA GROUP | CHINA |
TIN | SOFT METAIS A. | CHINA* |
TIN | SOLDER COAT CO. | JAPAN |
TIN | SPECTRO ALLOYS | USA |
TIN | STRETTI | MALAYSIA |
TIN | SUPER LIGAS | BRAZIL |
TIN | TABOCA/PARANAPANEMA | BRAZIL* |
TIN | TAICANG CITY NANCANG METAL MATERIAL CO. | CHINA |
TIN | TAINSHUI LING BO TECHNOLOGY CO. | CHINA |
TIN | TAP | USA |
TIN | THAI NGUYEN NONFERROUS METAL CO. | VIETNAM |
TIN | THAISARCO | THAILAND* |
TIN | TIN PLATING GEJIU | CHINA |
TIN | TIN PLATING GEJIU | CHINA |
TIN | TIN PRODUCTS MANUFACTURING CO. | CHINA* |
TIN | TUYEN QUANG NON-FERROUS METALS JOINT STOCK COMPANY | VIETNAM |
TIN | UNIT METALURGI PT TIMAH (PERSERO ) TBK | INDONESIA* |
TIN | UNTRACORE CO. | THAILAND |
TIN | VQB MINERAL AND TRADING GROUP JSC | VIETNAM* |
TIN | WELLEY | CHINA |
TIN | WHITE SOLDER METALURGIA E MINERAÇÃO LTDA. | BRAZIL* |
A-5
Metal | Smelter Name | Country of Smelter Facility |
TIN | WU XI SHI YI ZHENG JI XIE SHE BEI COMPANY | CHINA |
TIN | XIANGHUALING TIN MINERALS | CHINA |
TIN | YIFENG TIN | CHINA |
TIN | YUN'AN DIAN'XI TIN MINE | CHINA |
TIN | YUNNAN CHENGFENG NON-FERROUS METALS CO. | CHINA** |
TIN | YUNNAN CHENGO ELECTRIC SMELTING PLANT | CHINA |
TIN | YUN'XIN NON-FERROUS ELECTROANALYSIS | CHINA |
TIN | ZHEJIANG STRONG SOLDERING MATERIALS CO. | GHANA |
TIN | ZHONGSHAN JINYE SMELTING CO. | CHINA |
TIN | ZHUHAI QUANJIA | CHINA |
TUNGSTEN | A.L.M.T. CORP. | JAPAN* |
TUNGSTEN | ACL METAIS EIRELI | BRAZIL |
TUNGSTEN | ASIA TUNGSTEN PRODUCTS VIETNAM | VIETNAM* |
TUNGSTEN | CHENZHOU DIAMOND TUNGSTEN PRODUCTS CO. | CHINA* |
TUNGSTEN | CHINA MINMETALS NONFERROUS METALS CO. | CHINA |
TUNGSTEN | CHONGYI ZHANGYUAN TUNGSTEN CO. | CHINA* |
TUNGSTEN | DAYU WEILIANG TUNGSTEN CO. | CHINA |
TUNGSTEN | FUJIAN JINXIN TUNGSTEN CO. | CHINA* |
TUNGSTEN | GANSHOU HAICHUANG TUNGSTEN INDUSTRY CO. | CHINA |
TUNGSTEN | GANZHOU GRAND SEA W & MO GROUP CO. | CHINA |
TUNGSTEN | GANZHOU HUAXIN TUNGSTEN PRODUCTS | CHINA* |
TUNGSTEN | GANZHOU JIANGWU FERROTUNGSTEN CO. | CHINA* |
TUNGSTEN | GANZHOU SEADRAGON W & MO CO. | CHINA* |
TUNGSTEN | GANZHOU YATAI TUNGSTEN CO. | CHINA* |
TUNGSTEN | GLOBAL TUNGSTEN & POWDERS CORP. | USA* |
TUNGSTEN | GUANGDONG XIANGLU TUNGSTEN CO. | CHINA* |
TUNGSTEN | H.C. STARCK GMBH | GERMANY* |
TUNGSTEN | HUNAN CHENZHOU MINING GROUP CO. | CHINA* |
TUNGSTEN | HUNAN CHUANGDA VANADIUM TUNGSTEN CO. WUJI | CHINA |
TUNGSTEN | HUNAN CHUNCHANG NONFERROUS METALS CO. | CHINA* |
TUNGSTEN | HYDROMETALLURG JSC | RUSSIA* |
TUNGSTEN | JAPAN NEW METALS CO. | JAPAN* |
TUNGSTEN | JIANGWU H.C. STARCK TUNGSTEN PRODUCTS CO. | CHINA |
TUNGSTEN | JIANGXI DAYU LONGXINTAI TUNGSTEN CO. | CHINA |
TUNGSTEN | JIANGXI GAN BEI TUNGSTEN CO. | CHINA* |
TUNGSTEN | JIANGXI RARE METALS TUNGSTEN HOLDINGS GROUP CO. | CHINA |
TUNGSTEN | JIANGXI TONGGU NON-FERROUS METALLURGICAL & CHEMICAL CO. | CHINA |
TUNGSTEN | JIANGXI XINSHENG TUNGSTEN INDUSTRY CO. | CHINA |
TUNGSTEN | JIANGXI XIUSHUI XIANGGAN NONFERROUS METALS CO. | CHINA* |
TUNGSTEN | JIANGXI YAOSHENG TUNGSTEN CO. | CHINA |
TUNGSTEN | KENNAMETAL FALLON | USA |
TUNGSTEN | KENNAMETAL HUNTSVILLE | USA* |
TUNGSTEN | LUOYANG MUDU TUNGSTEN & MOLYBDENUM TECHNOLOGY CO. | CHINA |
TUNGSTEN | MALIPO HAIYU TUNGSTEN CO. | CHINA* |
TUNGSTEN | MOLIREN | RUSSIA |
TUNGSTEN | NIAGARA REFINING | USA* |
TUNGSTEN | NUI PHAO H.C. STARCK TUNGSTEN CHEMICALS MANUFACTURING | VIETNAM* |
TUNGSTEN | PHILIPPINE CHUANGXIN INDUSTRIAL CO. | PHILIPPINES |
TUNGSTEN | SICHUAN METALS & METERIALS IMPORT & EXPORT CO. | CHINA |
TUNGSTEN | SOUTH-EAST NONFERROUS METAL COMPANY LIMITED OF HENGYANG CITY | CHINA |
TUNGSTEN | TEJING (VIETNAM) TUNGSTEN CO. | VIETNAM* |
A-6
Metal | Smelter Name | Country of Smelter Facility |
TUNGSTEN | UNECHA REFRACTORY METALS PLANT | RUSSIA |
TUNGSTEN | VIETNAM YOUNGSUN TUNGSTEN INDUSTRY CO. | VIETNAM* |
TUNGSTEN | WOLFRAM BERGBAU UND HUTTEN AG | AUSTRIA* |
TUNGSTEN | WOLFRAM COMPANY CJSC | RUSSIA |
TUNGSTEN | WOLTECH KOREA CO. | SOUTH KOREA |
TUNGSTEN | XIAMEN TUNGSTEN (H.C.) CO. | CHINA* |
TUNGSTEN | XIAMEN TUNGSTEN CO. | CHINA* |
TUNGSTEN | XINFENG HUARUI TUNGSTEN & MOLYBDENUM NEW MATERIAL CO. | CHINA |
TUNGSTEN | XINHAI RENDAN SHAOGUAN TUNGSTEN CO. | CHINA* |
TUNGSTEN | ZHUZHOU CEMENTED CARBIDE GROUP CO. | CHINA |
*CFSP Conflict-Free
**CFSP Active – in the process of becoming CFSP Conflict-Free.
A-7