SD
ON SEMICONDUCTOR CORP filed this Form SD on 05/27/2016
Entire Document
 
Form SD

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D. C. 20549

 

 

FORM SD

 

 

Specialized Disclosure Report

 

 

ON Semiconductor Corporation

(Exact name of registrant as specified in its charter)

 

 

 

Delaware   000-30419   36-3840979

(State or other jurisdiction

of incorporation)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

ON Semiconductor Corporation

5005 East McDowell Road

Phoenix, Arizona

  85008
(Address of principal executive offices)   (Zip Code)

George H. Cave

ON Semiconductor Corporation

(602) 244-6600

(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 filing 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, 2015.

 

 

 


SECTION 1. CONFLICT MINERALS DISCLOSURE

 

Item 1.01. Conflict Minerals Disclosure and Report

Pursuant to Rule 13p-1 and Section 13(p) of the Securities Exchange Act of 1934, as amended, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Regulations”), ON Semiconductor Corporation (the “Company”) was required to make certain inquiries and perform certain due diligence with respect to any “conflict minerals” (as defined by paragraph (d)(3) of Item 1.01 of Form SD) that are necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries.

Conflict minerals are necessary to the functionality of certain of the Company’s products. As required in the Conflict Regulations, the Company has conducted a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or are from recycled or scrap sources. Based on its RCOI, the Company has determined that certain of the conflict minerals contained in its products may have originated in the Democratic Republic of the Congo or an adjoining country and may not be from recycled or scrap sources. Therefore, the Company was required to exercise due diligence on the source and chain of custody of its conflict minerals in accordance with the Conflict Regulations and Form SD and to file a Conflict Minerals Report.

Conflict Minerals Disclosure

The Company has filed a Conflicts Minerals Report which is attached hereto as Exhibit 1.01 and is incorporated herein by reference. Such report is also publicly available on the Company website at the following link: http://www.onsemi.com/social-responsibility.

 

Item 1.02. Exhibit

Information concerning Conflict Minerals required by the Conflict Regulations is included in Exhibit 1.01 to this Specialized Disclosure Report on Form SD.

 

SECTION 2. EXHIBITS

 

Item 2.01. Exhibits

 

Exhibit
No.

  

Description

1.01    Conflict Minerals Report for the year ended December 31, 2015 as required by Items 1.01 and 1.02 of this Form.

 

2


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 undersigned hereunto duly authorized.

 

    ON SEMICONDUCTOR CORPORATION
    (Registrant)
Date: May 27, 2016    
  By:  

/s/ GEORGE H. CAVE

    George H. Cave
    Executive Vice President, General Counsel, Chief Compliance and Ethics Officer, Chief Risk Officer and Corporate Secretary

 

3


EXHIBIT INDEX

 

Exhibit
No.

  

Description

1.01    Conflict Minerals Report for the year ended December 31, 2015 as required by Items 1.01 and 1.02 of this Form.

 

4

Exhibit 1.01

Exhibit 1.01

 

LOGO

CONFLICT MINERALS REPORT

This unaudited Conflict Minerals Report (this “Report”) of ON Semiconductor Corporation (the “Company”) is attached as Exhibit 1.01 to the Form SD for the year ended December 31, 2015. This Report is also publicly available on the Company’s website at the following link: http://www.onsemi.com/social-responsibility. The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.

Pursuant to Rule 13p-1 and Section 13(p) of the Securities Exchange Act of 1934, as amended, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Regulations”), the Company was required to make certain inquiries and perform certain due diligence with respect to any “conflict minerals” (as defined by paragraph (d)(3) of Item 1.01 of Form SD) that are necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries.

The Company is a broad based supplier of semiconductor components that serve a variety of end markets, including automotive, consumer, computing, industrial, wireless, networking, military-aerospace and medical. Our extensive portfolio of power and signal management, logic, discrete and custom devices helps customers efficiently solve their design challenges in advanced electronic systems and products.

As a purchaser of products containing the minerals tin, tantalum, tungsten or gold from suppliers for use in our manufacturing process, the Company continues to be concerned about the reports of violence and human rights violations resulting from the sourcing of such minerals from the Democratic Republic of the Congo and adjoining countries (“Covered Countries”). The Company’s Corporate Social Responsibility Report is available at http://www.onsemi.com/social-responsibility.

For purposes of this report, the term “products” is used to describe products manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries. As a result, when conducting its conflict minerals analysis as required by the federal securities rules, the Company has considered its sole product to be semiconductor components.

This Report relates to the process undertaken for products that were manufactured, or contracted to be manufactured, during calendar year 2015 and that contain conflict minerals. This Report is unaudited, as an independent private sector audit is not required pursuant to the guidance provided by the Securities and Exchange Commission in its “Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014.

As a result of its inquiry, the Company determined that conflict minerals are necessary to the functionality of the Company’s products. In particular, these minerals provide internal electrically conductive connections to the various circuit elements required to manufacture a working semiconductor device and/or provide an electrically conductive path to connect the semiconductor device to the electronic application in which it is utilized.

Conflict minerals are obtained from sources worldwide, and the Company does not desire to eliminate those originating in Covered Countries. However, the Company is committed to ensuring conflict free sourcing of minerals from our supply chain through collaboration with our suppliers, specifically, as a member of the Electronic Industry Citizenship Coalition (“EICC”) and a participant in the Conflict Free Sourcing Initiative (“CFSI”), which began as a joint effort between the EICC and Global e-Sustainability Initiative (“GeSI”). Being a member of the initiative requires that members engage in reasonable due diligence with their supply chain to assure such minerals are not being sourced from entities supporting armed conflict within the Covered Countries. The Company also recognizes the importance of supporting responsible mineral sourcing from the Covered Countries so as not to negatively impact the economies of those countries.


Due Diligence

Based on the Company’s reasonable country of origin inquiry (“RCOI”), the Company was unable to reasonably conclude that all of its conflict minerals did not originate in a Covered Country or come from recycled or scrap sources, and the Company continues its diligence on the source and chain of custody of its conflict minerals. In connection with this supply chain diligence, the Company used 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) and the related Supplements on tantalum, tin, tungsten and gold (collectively, the “OECD Guidance”) and, among other actions, implemented the following:

 

    OECD: Step 1: Established a strong management system

 

    The Company continually reviews and updates policies as appropriate to reflect the procedures by which the Company and its suppliers should conduct conflict minerals related diligence.

 

    The Company established an internal management team to support supply chain due diligence. The internal management team includes appropriate employees within the Company’s quality, supply chain, finance, operations and legal departments. Regular reports generated as a result of this internal management team’s efforts were provided to the Audit Committee of the Company.

 

    The Company utilized the form conflicts minerals reporting template (“CMRT”), standardized by the EICC, to collect sourcing information from its suppliers to identify whether (i) conflict minerals sourced by such suppliers originated in Covered Countries and (ii) whether or not smelters used by such suppliers (or such suppliers’ suppliers) have been validated as compliant in accordance with the Conflict Free Smelter Program (“CFSP”). Appendix A sets forth a list of smelters, provided by our suppliers, from which the Company obtains product, including mineral type, standard smelter names, and whether the smelter is on the Conflict-Free Sourcing Initiative Compliant Smelter List. In addition, a summary of conflict minerals and countries of origin information, collected as a result of our RCOI efforts, is attached hereto as Appendix B.

 

    The CFSI developed an audit protocol for verification of entities as compliant with the CFSP in accordance with the OECD Guidance and in conjunction with complementary traceability schemes in the Covered Countries. The Conflict Free Smelter List is composed of entities that were determined to be compliant with the CFSP and that have been subject to an independent third party audit to assess whether the entity employed policies, practices, and procedures to source conflict free minerals. ON Semiconductor uses the CFSP compliant smelter list and any other lists that have been recognized by the CFSI, including the London Bullion Metal Association (LBMA) and Responsible Jewelry Council (RJC) lists for gold. We are a member of CFSI and have access to CFSI country of origin information (RCOI) for entities on the Conflict Free Smelter List.

 

    The Company finalized an internal compliance audit to assess and confirm that the due diligence approach followed by the Company was in accordance with OECD Guidance.


    OECD: Step 2: Risk Identification and Assessment /

Identified supply chain risk

 

    The Company believes that it has identified 100% of the suppliers who provide it with tin, tantalum, tungsten and gold (“3TG”) and has, through its supply chain diligence, been able to exclude from this inquiry suppliers who do not provide 3TG to the Company. As of December 31, 2015, the Company received declaration from 100% of its suppliers of conflict minerals using the CMRT.

 

    The Company employs Ipoint, a third party web based software platform, to collect, manage and aggregate the CMRT declarations received from its suppliers and to report the results to its customers. This software ensures the company has an auditable ‘chain of custody’ regarding receipt of declarations and information received from suppliers.

 

    OECD Step 3: Strategy to respond to Identified risks/

Implemented strategy to address that risk

 

    The Company has developed a date and version controlled document and conflict minerals audit checklist for use in auditing its major suppliers of conflict minerals and has incorporated this checklist into its ongoing supplier audit process.

 

    All suppliers receive a letter through Ipoint requesting them to:

 

    Adopt a policy to reasonably assure that the 3TG in their products does not directly or indirectly finance or benefit armed groups in the Covered Countries.

 

    Identify all 3TG smelters in their supply chain.

 

    Report back to the Company by filling in the CMRT.

 

    The status is discussed internally in monthly reviews with the conflict minerals team and reported to senior management.

 

    OECD Step 4: Smelter audits /

Independent auditing of smelters

 

    The Company’s Conflict Mineral coordinators are members of the CFSI working teams that continue to encourage smelters to participate in the CFSP. To that end, the Company approaches, through direct communication and smelter outreach, both the smelters and their customers (the Company’s suppliers) in our supply chain, as well as others as assigned to us. The Company also supports CFSI group campaigns to engage smelters.

 

    OECD Step 5: Report on supply chain due diligence.

Inherent limitations on due diligence measures

 

    The Company is an indirect purchaser of conflict minerals, and its due diligence measures provide reasonable, not absolute, assurance regarding the source and chain of custody of conflict minerals. The Company’s due diligence processes seek data from its direct suppliers and those suppliers seek similar information within their supply chains to identify the original sources of the conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information may produce inaccurate or incomplete information and may be subject to fraud.


Due Diligence Results

As a result of its continuous due diligence with suppliers and smelters through CFSI’s smelter engagement team, the Company has determined that approximately 98% of our smelters are CFSP compliant or active in the program pursuing compliance as of December 31, 2015, compared to 53% as of December 31, 2014.

Smelters Status:

 

2015

   CFSP Compliant     CFSI Active List     CFSI Std List     Unknown     Total  

Gold

     59        3        3        0        65   

Tantalum

     38        0        0        0        38   

Tin

     53        9        1        0        63   

Tungsten

     20        4        0        0        24   
  

 

 

   

 

 

   

 

 

   

 

 

   

 

 

 

Total

     170        16        4        0        190   
  

 

 

   

 

 

   

 

 

   

 

 

   

 

 

 

%

     89.5     8.4     2.1     0.0     100

Products

As indicated above, the Company has been unable to determine the origins of certain of the conflict minerals contained in its products.

Mitigation of Risk Related to Benefiting Armed Groups

The Company continues to improve its processes and procedures to mitigate the risk that its necessary conflict minerals benefit armed groups. In particular, the Company has taken the following steps to improve its due diligence processes:

 

    The Company has incorporated conflict minerals compliance requirements into its supplier handbook for all suppliers.

 

    The Company has incorporated conflict minerals requirements and checkpoints into its business processes for new product introduction, new supplier qualification and change management.


APPENDIX A

CONFLICT MINERALS SOURCING INFORMATION

(as of December 31, 2015)

 

SN   METAL    STANDARD SMELTER NAME    CONFLICT FREE STATUS
1   Gold    Aida Chemical Industries Co., Ltd.    CFSP Validated as conflict-free
2   Gold    Allgemeine Gold-und Silberscheideanstalt A.G.    CFSP Validated as conflict-free
3   Gold    AngloGold Ashanti Córrego do Sítio Mineração    CFSP Validated as conflict-free
4   Gold    Argor-Heraeus SA    CFSP Validated as conflict-free
5   Gold    Asahi Pretec Corporation    CFSP Validated as conflict-free
6   Gold    Asahi Refining Canada Limited    CFSP Validated as conflict-free
7   Gold    Asahi Refining USA Inc.    CFSP Validated as conflict-free
8   Gold    Asaka Riken Co., Ltd.    CFSP Validated as conflict-free
9   Gold    Atasay Kuyumculuk Sanayi Ve Ticaret A.S.    CFSP Validated as conflict-free
10   Gold    Aurubis AG    CFSP Validated as conflict-free
11   Gold    Bangko Sentral ng Pilipinas (Central Bank of the Philippines)    CFSP Validated as conflict-free
12   Gold    Boliden AB    CFSP Validated as conflict-free
13   Gold    C. Hafner GmbH + Co. KG    CFSP Validated as conflict-free
14   Gold    CCR Refinery – Glencore Canada Corporation    CFSP Validated as conflict-free
15   Gold    Chimet S.p.A.    CFSP Validated as conflict-free
16   Gold    Dowa    CFSP Validated as conflict-free
17   Gold    Eco-System Recycling Co., Ltd.    CFSP Validated as conflict-free
18   Gold    Elemetal Refining, LLC    CFSP Validated as conflict-free
19   Gold    Heimerle + Meule GmbH    CFSP Validated as conflict-free
20   Gold    Heraeus Ltd. Hong Kong    CFSP Validated as conflict-free
21   Gold    Heraeus Precious Metals GmbH & Co. KG    CFSP Validated as conflict-free
22   Gold    Ishifuku Metal Industry Co., Ltd.    CFSP Validated as conflict-free
23   Gold    Istanbul Gold Refinery    CFSP Validated as conflict-free
24   Gold    Jiangxi Copper Company Limited    CFSP Validated as conflict-free
25   Gold    JX Nippon Mining & Metals Co., Ltd.    CFSP Validated as conflict-free
26   Gold    Kennecott Utah Copper LLC    CFSP Validated as conflict-free
27   Gold    Kojima Chemicals Co., Ltd.    CFSP Validated as conflict-free
28   Gold    LS-NIKKO Copper Inc.    CFSP Validated as conflict-free
29   Gold    Materion    CFSP Validated as conflict-free
30   Gold    Matsuda Sangyo Co., Ltd.    CFSP Validated as conflict-free
31   Gold    Metalor Technologies (Hong Kong) Ltd.    CFSP Validated as conflict-free
32   Gold    Metalor Technologies SA    CFSP Validated as conflict-free
33   Gold    Metalor USA Refining Corporation    CFSP Validated as conflict-free
34   Gold    METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V    CFSP Validated as conflict-free
35   Gold    Mitsubishi Materials Corporation    CFSP Validated as conflict-free
36   Gold    Mitsui Mining and Smelting Co., Ltd.    CFSP Validated as conflict-free
37   Gold    Nadir Metal Rafineri San. Ve Tic. A.Ş.    CFSP Validated as conflict-free
38   Gold    Nihon Material Co., Ltd.    CFSP Validated as conflict-free


39   Gold    Ohura Precious Metal Industry Co., Ltd.    CFSP Validated as conflict-free
40   Gold    PAMP SA    CFSP Validated as conflict-free
41   Gold    PX Précinox SA    CFSP Validated as conflict-free
42   Gold    Rand Refinery (Pty) Ltd.    CFSP Validated as conflict-free
43   Gold    Republic Metals Corporation    CFSP Validated as conflict-free
44   Gold    Royal Canadian Mint    CFSP Validated as conflict-free
45   Gold    SEMPSA Joyería Platería SA    CFSP Validated as conflict-free
46   Gold    Shandong Zhaojin Gold & Silver Refinery Co., Ltd.    CFSP Validated as conflict-free
47   Gold    Solar Applied Materials Technology Corp.    CFSP Validated as conflict-free
48   Gold    Sumitomo Metal Mining Co., Ltd.    CFSP Validated as conflict-free
49   Gold    Tanaka Kikinzoku Kogyo K.K.    CFSP Validated as conflict-free
50   Gold    The Refinery of Shandong Gold Mining Co., Ltd.    CFSP Validated as conflict-free
51   Gold    Tokuriki Honten Co., Ltd.    CFSP Validated as conflict-free
52   Gold    Umicore Precious Metals Thailand    CFSP Validated as conflict-free
53   Gold    Umicore SA Business Unit Precious Metals Refining    CFSP Validated as conflict-free
54   Gold    United Precious Metal Refining, Inc.    CFSP Validated as conflict-free
55   Gold    Valcambi SA    CFSP Validated as conflict-free
56   Gold    Western Australian Mint trading as The Perth Mint    CFSP Validated as conflict-free
57   Gold    Yamamoto Precious Metal Co., Ltd.    CFSP Validated as conflict-free
58   Gold    Yokohama Metal Co., Ltd.    CFSP Validated as conflict-free
59   Gold    Zhongyuan Gold Smelter of Zhongjin Gold Corporation    CFSP Validated as conflict-free
60   Gold    Zijin Mining Group Co., Ltd. Gold Refinery    CFSP Validated as conflict-free
61   Tantalum    Changsha South Tantalum Niobium Co., Ltd.    CFSP Validated as conflict-free
62   Tantalum    Conghua Tantalum and Niobium Smeltry    CFSP Validated as conflict-free
63   Tantalum    Duoluoshan    CFSP Validated as conflict-free
64   Tantalum    Exotech Inc.    CFSP Validated as conflict-free
65   Tantalum    F&X Electro-Materials Ltd.    CFSP Validated as conflict-free
66   Tantalum    Global Advanced Metals Aizu    CFSP Validated as conflict-free
67   Tantalum    Global Advanced Metals Boyertown    CFSP Validated as conflict-free
68   Tantalum    Guangdong Zhiyuan New Material Co., Ltd.    CFSP Validated as conflict-free
69   Tantalum    H.C. Starck Co., Ltd.    CFSP Validated as conflict-free
70   Tantalum    H.C. Starck GmbH Goslar    CFSP Validated as conflict-free
71   Tantalum    H.C. Starck GmbH Laufenburg    CFSP Validated as conflict-free
72   Tantalum    H.C. Starck Hermsdorf GmbH    CFSP Validated as conflict-free
73   Tantalum    H.C. Starck Inc.    CFSP Validated as conflict-free
74   Tantalum    H.C. Starck Ltd.    CFSP Validated as conflict-free
75   Tantalum    H.C. Starck Smelting GmbH & Co.KG    CFSP Validated as conflict-free
76   Tantalum    Hengyang King Xing Lifeng New Materials Co., Ltd.    CFSP Validated as conflict-free
77   Tantalum    Hi-Temp Specialty Metals, Inc.    CFSP Validated as conflict-free
78   Tantalum    JiuJiang JinXin Nonferrous Metals Co., Ltd.    CFSP Validated as conflict-free
79   Tantalum    Jiujiang Tanbre Co., Ltd.    CFSP Validated as conflict-free
80   Tantalum    KEMET Blue Metals    CFSP Validated as conflict-free
81   Tantalum    KEMET Blue Powder    CFSP Validated as conflict-free
82   Tantalum    King-Tan Tantalum Industry Ltd.    CFSP Validated as conflict-free


83   Tantalum    LSM Brasil S.A.    CFSP Validated as conflict-free
84   Tantalum    Metallurgical Products India Pvt., Ltd.    CFSP Validated as conflict-free
85   Tantalum    Mineração Taboca S.A.    CFSP Validated as conflict-free
86   Tantalum    Mitsui Mining & Smelting    CFSP Validated as conflict-free
87   Tantalum    Molycorp Silmet A.S.    CFSP Validated as conflict-free
88   Tantalum    Ningxia Orient Tantalum Industry Co., Ltd.    CFSP Validated as conflict-free
89   Tantalum    Plansee SE Liezen    CFSP Validated as conflict-free
90   Tantalum    Plansee SE Reutte    CFSP Validated as conflict-free
91   Tantalum    QuantumClean    CFSP Validated as conflict-free
92   Tantalum    RFH Tantalum Smeltry Co., Ltd.    CFSP Validated as conflict-free
93   Tantalum    Solikamsk Magnesium Works OAO    CFSP Validated as conflict-free
94   Tantalum    Taki Chemicals    CFSP Validated as conflict-free
95   Tantalum    Telex Metals    CFSP Validated as conflict-free
96   Tantalum    Ulba Metallurgical Plant JSC    CFSP Validated as conflict-free
97   Tantalum    Yichun Jin Yang Rare Metal Co., Ltd.    CFSP Validated as conflict-free
98   Tantalum    Zhuzhou Cemented Carbide    CFSP Validated as conflict-free
99   Tin    Alpha    CFSP Validated as conflict-free
100   Tin    China Tin Group Co., Ltd.    CFSP Validated as conflict-free
101   Tin    Cooperativa Metalurgica de Rondônia Ltda.    CFSP Validated as conflict-free
102   Tin    CV Ayi Jaya    CFSP Validated as conflict-free
103   Tin    CV Gita Pesona    CFSP Validated as conflict-free
104   Tin    CV Serumpun Sebalai    CFSP Validated as conflict-free
105   Tin    CV United Smelting    CFSP Validated as conflict-free
106   Tin    Dowa    CFSP Validated as conflict-free
107   Tin    Elmet S.L.U. (Metallo Group)    CFSP Validated as conflict-free
108   Tin    EM Vinto    CFSP Validated as conflict-free
109   Tin    Fenix Metals    CFSP Validated as conflict-free
110   Tin    Gejiu Non-Ferrous Metal Processing Co., Ltd.    CFSP Validated as conflict-free
111   Tin    Jiangxi Ketai Advanced Material Co., Ltd.    CFSP Validated as conflict-free
112   Tin    Magnu’s Minerais Metais e Ligas Ltda.    CFSP Validated as conflict-free
113   Tin    Malaysia Smelting Corporation (MSC)    CFSP Validated as conflict-free
114   Tin    Melt Metais e Ligas S/A    CFSP Validated as conflict-free
115   Tin    Metallic Resources, Inc.    CFSP Validated as conflict-free
116   Tin    Metallo-Chimique N.V.    CFSP Validated as conflict-free
117   Tin    Mineração Taboca S.A.    CFSP Validated as conflict-free
118   Tin    Minsur    CFSP Validated as conflict-free
119   Tin    Mitsubishi Materials Corporation    CFSP Validated as conflict-free
120   Tin    O.M. Manufacturing (Thailand) Co., Ltd.    CFSP Validated as conflict-free
121   Tin    O.M. Manufacturing Philippines, Inc.    CFSP Validated as conflict-free
122   Tin    Operaciones Metalurgical S.A.    CFSP Validated as conflict-free
123   Tin    PT Aries Kencana Sejahtera    CFSP Validated as conflict-free
124   Tin    PT Artha Cipta Langgeng    CFSP Validated as conflict-free
125   Tin    PT ATD Makmur Mandiri Jaya    CFSP Validated as conflict-free
126   Tin    PT Babel Inti Perkasa    CFSP Validated as conflict-free


127   Tin    PT Bangka Prima Tin    CFSP Validated as conflict-free
128   Tin    PT Bangka Tin Industry    CFSP Validated as conflict-free
129   Tin    PT Belitung Industri Sejahtera    CFSP Validated as conflict-free
130   Tin    PT BilliTin Makmur Lestari    CFSP Validated as conflict-free
131   Tin    PT Bukit Timah    CFSP Validated as conflict-free
132   Tin    PT Cipta Persada Mulia    CFSP Validated as conflict-free
133   Tin    PT DS Jaya Abadi    CFSP Validated as conflict-free
134   Tin    PT Eunindo Usaha Mandiri    CFSP Validated as conflict-free
135   Tin    PT Inti Stania Prima    CFSP Validated as conflict-free
136   Tin    PT Justindo    CFSP Validated as conflict-free
137   Tin    PT Mitra Stania Prima    CFSP Validated as conflict-free
138   Tin    PT Panca Mega Persada    CFSP Validated as conflict-free
139   Tin    PT Prima Timah Utama    CFSP Validated as conflict-free
140   Tin    PT Refined Bangka Tin    CFSP Validated as conflict-free
141   Tin    PT Sariwiguna Binasentosa    CFSP Validated as conflict-free
142   Tin    PT Stanindo Inti Perkasa    CFSP Validated as conflict-free
143   Tin    PT Timah (Persero) Tbk Kundur    CFSP Validated as conflict-free
144   Tin    PT Timah (Persero) Tbk Mentok    CFSP Validated as conflict-free
145   Tin    PT Tinindo Inter Nusa    CFSP Validated as conflict-free
146   Tin    PT Wahana Perkit Jaya    CFSP Validated as conflict-free
147   Tin    Resind Indústria e Comércio Ltda.    CFSP Validated as conflict-free
148   Tin    Rui Da Hung    CFSP Validated as conflict-free
149   Tin    Soft Metais Ltda.    CFSP Validated as conflict-free
150   Tin    Thaisarco    CFSP Validated as conflict-free
151   Tin    VQB Mineral and Trading Group JSC    CFSP Validated as conflict-free
152   Tin    White Solder Metalurgia e Mineração Ltda.    CFSP Validated as conflict-free
153   Tin    Yunnan Tin Group (Holding) Company Limited    CFSP Validated as conflict-free
154   Tungsten    A.L.M.T. TUNGSTEN Corp.    CFSP Validated as conflict-free
155   Tungsten    Chenzhou Diamond Tungsten Products Co., Ltd.    CFSP Validated as conflict-free
156   Tungsten    Chongyi Zhangyuan Tungsten Co., Ltd.    CFSP Validated as conflict-free
157   Tungsten    Fujian Jinxin Tungsten Co., Ltd.    CFSP Validated as conflict-free
158   Tungsten    Ganzhou Huaxing Tungsten Products Co., Ltd.    CFSP Validated as conflict-free
159   Tungsten    Ganzhou Jiangwu Ferrotungsten Co., Ltd.    CFSP Validated as conflict-free
160   Tungsten    Ganzhou Seadragon W & Mo Co., Ltd.    CFSP Validated as conflict-free
161   Tungsten    Global Tungsten & Powders Corp.    CFSP Validated as conflict-free
162   Tungsten    Guangdong Xianglu Tungsten Co., Ltd.    CFSP Validated as conflict-free
163   Tungsten    H.C. Starck GmbH    CFSP Validated as conflict-free
164   Tungsten    H.C. Starck Smelting GmbH & Co.KG    CFSP Validated as conflict-free
165   Tungsten    Hunan Chunchang Nonferrous Metals Co., Ltd.    CFSP Validated as conflict-free
166   Tungsten    Hydrometallurg, JSC    CFSP Validated as conflict-free
167   Tungsten    Japan New Metals Co., Ltd.    CFSP Validated as conflict-free
168   Tungsten    Kennametal Huntsville    CFSP Validated as conflict-free
169   Tungsten    Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC    CFSP Validated as conflict-free


170   Tungsten    Tejing (Vietnam) Tungsten Co., Ltd.    CFSP Validated as conflict-free
171   Tungsten    Wolfram Bergbau und Hütten AG    CFSP Validated as conflict-free
172   Tungsten    Xiamen Tungsten (H.C.) Co., Ltd.    CFSP Validated as conflict-free
173   Tungsten    Xiamen Tungsten Co., Ltd.    CFSP Validated as conflict-free
174   Gold    Metalor Technologies (Suzhou) Ltd.    CFSP Validated as active
175   Gold    Samduck Precious Metals    CFSP Validated as active
176   Tin    An Vinh Joint Stock Mineral Processing Company    CFSP Validated as active
177   Tin    Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company    CFSP Validated as active
178   Tin    Gejiu Kai Meng Industry and Trade LLC    CFSP Validated as active
179   Tin    Nghe Tinh Non-Ferrous Metals Joint Stock Company    CFSP Validated as active
180   Tin    Phoenix Metal Ltd.    CFSP Validated as active
181   Tin    Tuyen Quang Non-Ferrous Metals Joint Stock Company    CFSP Validated as active
182   Tin    Yunnan Chengfeng Non-ferrous Metals Co., Ltd.    CFSP Validated as active
183   Tungsten    Ganzhou Non-ferrous Metals Smelting Co., Ltd.    CFSP Validated as active
184   Tungsten    Jiangxi Xinsheng Tungsten Industry Co., Ltd.    CFSP Validated as active
185   Tungsten    Kennametal Fallon    CFSP Validated as active
186   Tungsten    Pobedit, JSC    CFSP Validated as active
187   Gold    Almalyk Mining and Metallurgical Complex (AMMC)    CFSP Validated as eligible smelter
188   Gold    Chugai Mining    CFSP Validated as eligible smelter
189   Gold    Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited    CFSP Validated as eligible smelter
190   Tin    Gejiu Zili Mining And Metallurgy Co., Ltd.    CFSP Validated as eligible smelter


APPENDIX B

Below is a summary of the minerals and country of origin information, collected as a result of the Company’s RCOI and due diligence:

 

CONFLICT MINERAL    COUNTRIES OF ORIGIN and other sources may include the following:
GOLD    L1, R/S, Australia; Belgium; Brazil; Canada; China; Germany; Italy; Japan; Korea, Republic of; Mexico; Philippines; South Africa; Spain; Sweden; Switzerland; Taiwan; Thailand; Turkey; UNITED STATES; Uzbekistan
TANTALUM    L1, L2, L3, DRC, R/S, Austria; Brazil; China; Estonia; Germany; India; Japan; Kazakhstan; Mexico; Russian Federation; Thailand; UNITED STATES
TIN    L1, L2, L3, DRC, R/S, Belgium; Bolivia; Brazil; China; Indonesia; Japan; Malaysia; Peru; Philippines; Poland; Rwanda; Spain; Taiwan; Thailand; UNITED STATES, Vietnam
TUNGSTEN    L1, L3, R/S, Austria; China; Columbia; Germany; Japan; Russian Federation; UNITED STATES; Vietnam
MINERAL SOURCING    COUNTRIES OF ORIGIN including the following:
L1    Argentina, Australia, Austria; Belgium; Bolivia; Brazil; Cambodia; Canada; Chile; China; Colombia; Côte D’Ivoire; Czech Republic; Djibouti; Ecuador; Egypt; Estonia; Ethiopia; France; Germany; Guyana; Hungary; India; Indonesia; Ireland; Israel; Japan; Kazakhstan; Laos; Luxembourg; Madagascar; Malaysia; Mongolia; Myanmar; Namibia; Netherlands; Nigeria; Peru; Portugal; Russia; Sierra Leone; Singapore; Slovakia; South Korea; Spain; Suriname; Switzerland; Taiwan; Thailand; United Kingdom; United States of America; Vietnam; Zimbabwe
L2    Kenya; Mozambique; South Africa
L3    Angola; Burundi; Central African Republic; Republic of Congo; Rwanda; South Sudan; Tanzania; Uganda; Zambia
DRC    Democratic Republic of Congo