Exhibit 1.01 - Conflict Minerals Report
Brocade Communications Systems, Inc.
130 Holger Way
San Jose, CA 95134
Calendar Year 2016
1. Introduction
Background
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd Frank Act”). Section 1502 of the Dodd Frank Act specifically relates to “conflict minerals” (gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten) and added Section 13(p) to the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 (the “Rule”) and Form SD adopted by the Securities and Exchange Commission (“SEC”) require companies subject to the Rule to perform certain procedures to determine the source of conflict minerals that are determined to be necessary to the functionality or production of the products these companies manufacture or contract to manufacture. Specifically, companies are required to conduct a reasonable country-of-origin inquiry (“RCOI”) to determine whether the conflict minerals used in their products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, the “covered countries”) or were from recycled or scrap sources. If, as a result of the RCOI, a company determines that some of the necessary conflict minerals in its supply chain did originate in the covered countries (and are not from recycled or scrap sources) or if the company was unable to determine the countries of origin of all of its necessary conflict minerals, the company is required to perform due diligence on the source and chain of custody of the necessary conflict minerals to determine whether the conflict minerals were used, directly or indirectly, to finance or benefit armed groups in the covered countries, and to disclose information about the due diligence procedures the company performed.
In accordance with the Rule, Brocade Communications Systems, Inc. (“Brocade” or the “Company”) conducted an RCOI and performed due diligence on the source and chain of custody of its conflict minerals. This Conflict Minerals Report (“CMR”) describes the RCOI and due diligence activities performed in good faith for necessary conflict minerals used in Brocade’s products the manufacture of which was completed in calendar year 2016 (“CY 2016”), based on information available at the time of filing. This CMR also describes Brocade’s plans to improve its due diligence activities in calendar year 2017 (“CY 2017”).
Company and Product Overview
Brocade is a leading supplier of networking hardware, software, and services for businesses and organizations of various types and sizes. Its end customers include global enterprises and other organizations that use Brocade products and services as part of their communications infrastructure. In addition, service providers, such as telecommunication firms, cable operators, and mobile carriers, use Brocade products and services as part of their commercial operations. Brocade’s business is focused on two key markets. One is Storage Area Networking (“SAN”), where Brocade offers its SAN products, including modular directors, fixed-configuration and embedded switches, and network management and monitoring capabilities. The second is Internet Protocol (“IP”) Networking, where Brocade offers IP routers, Ethernet switches, wireless access points and controllers, network security, analytics, and monitoring, as well as products used to manage application delivery. Brocade’s IP Networking products are available in modular and fixed hardware-based form factors and can be deployed in both traditional network and next-generation fabric designs. Its IP Networking products also include a wide range of virtualized network software offerings. Brocade also provides product-related customer support and services across all its businesses.
On May 27, 2016, Brocade completed its acquisition of Ruckus Wireless, Inc. (“Ruckus”). Prior to the closing of the acquisition, Ruckus was a publicly-traded company listed on The NASDAQ Stock Market required to file reports with the SEC under the Exchange Act. Accordingly, this CMR covers products that Ruckus contracted to manufacture that contain conflict minerals necessary to the functionality or production of such products, the manufacture of which was completed during CY 2016, including during the portion of CY 2016 prior to Brocade’s acquisition of Ruckus (the “Ruckus products”). Because of the complexity of the supply chains of the respective organizations, and because Brocade’s planned integration of the businesses and operations of the two companies was expected to continue for the remainder of CY 2016, Brocade elected to manage independent RCOI and due diligence processes with respect to (i) the Ruckus products and (ii) “classic Brocade products” (that is, products manufactured or contracted to be manufactured by Brocade excluding Ruckus products). The RCOI and due diligence inquiries on the source and chain of custody of the necessary conflict minerals (defined below) in the Ruckus products and classic Brocade products were conducted on parallel but separate tracks, each reflected below in the sections entitled “RCOI” and “Due Diligence - Overview of Due Diligence Process”, and the results of these measures for the combined company are included in the section below entitled “Due Diligence - Due Diligence Results.”
This CMR relates to products (i) for which conflict minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during CY 2016. These products are referred to in this CMR as the “in-scope products” and include:
| |
| • | classic Brocade products, consisting of SAN hardware products (fibre channel directors, fixed -configuration and embedded switches and extensions) and IP Networking hardware products (IP routers and Ethernet switches); and |
| |
| • | the Ruckus products, consisting of wireless access points and controllers. |
Brocade conducted a good faith RCOI regarding the conflict minerals that were necessary to the functionality or production of the in-scope products (the “necessary conflict minerals”). This RCOI was reasonably designed to determine whether any of the necessary conflict minerals originated in the covered countries and whether any of the necessary conflict minerals may be from recycled or scrap sources.
As a downstream purchaser of products that contain conflict minerals, Brocade is many steps removed in the supply chain from the smelters or gold refiners (“SORs”) that process the minerals used in its products and from the mines of origin for the minerals. Brocade does not obtain any conflict minerals directly from mines or SORs where ores are processed; all necessary conflict minerals that may be present in the in-scope products are the result of incorporating various parts and components of products obtained from its suppliers. Therefore, Brocade determined that it was reasonable for the Company to rely on its suppliers to trace these minerals to their sources and provide information regarding the origin of the necessary conflict minerals in the in-scope products. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of conflict minerals, its ability to verify the accuracy of information reported by suppliers is limited.
Brocade utilized certain conflict minerals tools and processes developed by the Conflict-Free Sourcing Initiative (“CFSI”), a consortium of the Electronic Industry Citizenship Coalition (“EICC”), and the Global e-Sustainability Initiative (“GeSI”), specifically:
| |
| • | The industry standard Conflict Minerals Reporting Template (“CMRT”) for surveying in-scope suppliers for critical conflict minerals information; and |
| |
| • | The list of known SORs with assigned identification (“ID”) numbers provided as part of the CMRT. |
Brocade’s process involved collecting and evaluating completed CMRTs from its suppliers that contracted to manufacture in-scope products or provided parts and components to Brocade that were incorporated into in-scope products and that Brocade determined were likely to contain conflict minerals. Brocade considered these suppliers to be “in-scope” for the purposes of its assessment. This information included declarations regarding the presence of conflict minerals in supplier parts incorporated into the in-scope products and, to the extent such information was available, the SORs where such conflict minerals were processed and the mines of origin for such conflict minerals. Suppliers that were reluctant or unable to provide the required information were escalated to Brocade’s supply base management team or the Ruckus business unit conflict minerals team, as applicable, in order to help maximize supplier responsiveness.
Brocade surveyed a total of 190 in-scope suppliers for classic Brocade products and 240 in-scope suppliers for Ruckus products. In cases of overlap between suppliers for classic Brocade and Ruckus products, these suppliers were surveyed separately and their responses were reviewed independently by Brocade’s supply base management team and the Ruckus business unit conflict minerals team.
For CY 2016 Brocade received responses from 100% of its in-scope suppliers, including from 100% of suppliers for classic Brocade products and 100% of suppliers for Ruckus products. These suppliers identified 359 SORs that may be in Brocade’s supply chain. Based on an analysis of the completed CMRTs and information made available by the CFSI to its members, Brocade also concluded that many of these SORs sourced conflict minerals entirely from outside of the covered countries, including from recycled or scrap sources. In the course of completing its RCOI, the Company determined that some suppliers:
| |
| • | Did not provide complete information regarding the origins of the conflict minerals in their products, i.e., they reported that they collected data from less than 100% of their supply chain; |
| |
| • | Responded that they were unable to determine the origins of certain conflict minerals in their products; |
| |
| • | Reported that they are sourcing conflict minerals from SORs that have not undergone an audit by the Conflict-Free Sourcing Program (“CFSP”) developed by the CFSI to be certified as conflict-free or that are not active in the CFSP process; or |
| |
| • | Provided company-level responses regarding all conflict minerals used for every product they manufacture instead of more specific product- or component-level information that would be limited to the specific types of components or products supplied to the Company; as a result, there were conflict mineral sources reported to Brocade that may not actually be used in the Company’s products. |
As a result, for CY 2016, Brocade was unable to determine the origin of at least a portion of the necessary conflict minerals in its in-scope products. Based on the results of the RCOI, Brocade determined that it was required to conduct due diligence for CY 2016. These due diligence efforts are discussed below.
Overview of Due Diligence Process
Brocade designed its due diligence measures to be in conformity in all material respects with the internationally recognized due diligence 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, Third Edition, 2016, including the related supplements on gold, tin, tantalum and tungsten (“OECD Guidance”), consistent with Brocade’s position as a downstream company. Brocade integrated the five-step OECD Guidance into its due diligence measures described below.
OECD Step 1 - Establish strong company management systems
| |
| • | Conflict minerals statement. Brocade adopted a conflict minerals statement that outlines its commitment to responsible sourcing of conflict minerals. The statement sets forth Brocade’s expectation of its suppliers to source minerals responsibly, conduct due diligence on the source and chain of custody of conflict minerals in their products, and provide related information to Brocade on an annual basis. The statement was approved by certain key stakeholders, communicated internally and to in-scope suppliers (including suppliers for Ruckus products) during CY 2016, and is posted on the Company’s external website at: http://www.brocade.com/en/about-us/corporate-responsibility/governance.html. |
| |
| • | Conflict minerals team. Brocade developed a resource plan identifying both internal and external resources and responsibilities for implementing various aspects of its conflict minerals program. Representatives from Brocade’s environmental compliance and supply chain team (in the case of classic Brocade products) and the Ruckus business unit’s operations team (in the case of Ruckus products) managed the conflict minerals program, with cross-functional support from other departments including corporate affairs, internal audit and compliance, finance and legal. Members of the conflict minerals project teams met regularly over the course of 2016 and into 2017 to review the status of the conflict minerals program. Members of the executive team (including from the Ruckus business unit) had oversight responsibility for the work done by the conflict minerals teams and fully supported their efforts. In addition, the Company retained outside contractors to implement various aspects of its conflict minerals program, including outreach to and data collection from suppliers. Separate contractors were retained to assist with the conflict minerals program with respect to classic Brocade products and Ruckus products. |
| |
| • | Systems of controls and transparency. In an effort to enhance its due diligence processes and improve the accuracy and completeness of supplier data, Brocade documented detailed standard operating procedures used in its conflict minerals program for each of the classic Brocade and Ruckus product lines. These documented procedures covered supplier scoping, supplier outreach and follow-up, data collection, review and validation of supplier responses, escalation of issues (e.g., non-responsive suppliers, data quality issues such as incomplete or inconsistent responses, or failure to meet other requirements) and action plans for addressing such issues. As discussed above, Brocade’s primary method for gathering information from suppliers was through the collection and evaluation of CMRTs. Brocade maintained reviewable records of conflict minerals program documents including information tracking and summarizing the status of collecting and validating supplier responses. |
| |
| • | Supplier engagement. Brocade developed a supplier engagement process designed to help its suppliers understand the objectives and expectations of its conflict minerals program and strategy, and ultimately strengthen supplier commitment to conflict minerals management and responsible sourcing. Key elements of this process included developing and disseminating an initial communication regarding the information required from in-scope suppliers, distributing and collecting completed CMRTs, communicating Brocade’s publicly available conflict minerals statement to in-scope suppliers (including Ruckus suppliers), developing various additional supplier communication letters and emails (e.g., to follow up with non-responsive suppliers or request additional information or other required action items) and providing or maintaining access to training sessions and other informational materials. Outreach to and engagement of suppliers for classic Brocade and Ruckus products were conducted on separate tracks, each of which involved the key elements described above. In addition, Brocade engaged with suppliers for classic Brocade products that it shared with certain key customers to encourage their adoption of conflict minerals management processes. |
| |
| • | Establish a company grievance mechanism. Brocade enabled its employees, suppliers, customers and other stakeholders to report any concerns relating to its corporate responsibility platform or practices (including its conflict minerals program) by contacting CorporateResponsibility@brocade.com, as communicated on its publicly available website at http://www.brocade.com/en/about-us/corporate-responsibility/governance.html. As a proactive measure, on a quarterly basis or more frequently, if needed, Brocade engaged with certain customers to understand their approaches to managing conflict minerals and to help ensure Brocade provided appropriate and responsive information. |
OECD Step 2 - Identify and assess risk in the supply chain
Brocade’s efforts to identify and assess risk in its supply chain included the processes and procedures outlined above under the section entitled “RCOI” and, to the extent applicable, the section entitled “Due Diligence - Overview of Due Diligence Process - OECD Step 1 - Establish strong company management systems.”
In addition, through the Company’s membership in the EICC (since July 2015), Brocade became a member of the CFSI and has attended monthly CFSI plenary meetings. Brocade utilized public and members-only conflict minerals tools and processes developed by the CFSI, including specifically:
| |
| • | The CFSP, under which the CFSI conducts third-party audits of SORs utilizing a standard audit protocol to determine whether an SOR is conflict-free (i.e., compliant with CFSP protocols), and the published list of SORs that are compliant under the CFSP, which list is available at: www.conflictfreesourcing.org, and is updated periodically; and |
| |
| • | The CFSI’s Compliant Smelter Sourcing Information list, which is available only to CFSI members and provides country-of-origin information for SORs that are certified as conflict-free through the CFSP. |
Brocade and its outside contractors reviewed the responses received from in-scope suppliers for plausibility, consistency and gaps in information, followed up with suppliers that submitted responses that triggered specified quality control flags, and monitored and tracked these suppliers’ progress in addressing any identified issues. Responses from suppliers for classic Brocade and Ruckus products were reviewed independently by Brocade’s supply base management team and the Ruckus business unit conflict minerals team with the assistance of their respective outside contractors, and necessary follow-up was conducted on separate tracks. Brocade reviewed the overall results of the combined company, which are reported in the section below entitled “Due Diligence - Due Diligence Results.”
CMRTs were reviewed for completeness, with a focus on whether each supplier provided all of the required information at the level of detail expected and on the correct version of the CMRT. Templates found to be incomplete or on the incorrect version of the CMRT were returned to the suppliers, which were requested to resubmit them with all of the required information.
CMRTs were also reviewed from a consistency and risk perspective to identify:
| |
| • | Supplier responses for which it was not reasonable to believe the information provided; and |
| |
| • | Key issues for which supplier follow-up was needed, including to meet Brocade’s program objectives and, in the case of classic Brocade products, certain customer requirements. |
Based on the results of the review, suppliers were asked to clarify their responses, provide additional information or resubmit their CMRTs to address identified issues.
Brocade compared the names of SOR entities listed by in-scope suppliers in completed CMRTs with and without CFSI IDs to the list made available by the CFSI to determine whether the entities were in fact SORs. Brocade then compared the list of SORs identified by its in-scope suppliers to the list of SORs that had received a “conflict-free” designation by the CFSP. For SORs identified by Brocade’s suppliers that had not received a “conflict-free” designation, Brocade, with the assistance of its outside contractors, conducted additional external research to gain more information about the sourcing practices of such SORs, including countries of origin, whether there were any internal due diligence procedures or other processes the SOR may have undertaken to track the chain of custody to the source of their mineral ores, and their plans for complying with CFSP requirements. In addition, Brocade, through its outside contractor, monitored and tracked the improvement in status of such SORs when there was an available update from the CFSI.
OECD Step 3 - Design and implement a strategy to respond to identified risks
The suppliers’ responses to requested follow-up actions and requests for additional information were reviewed by Brocade and its outside contractors and, where necessary, an appropriate response on Brocade’s part was initiated. In the case of suppliers for classic Brocade products, Brocade’s responses were guided by pre-determined action plans triggered by specified risk paths. Where the outcome of these additional actions by certain suppliers did not completely address the identified risks and, as a result, those suppliers did not meet Brocade’s program objectives and requirements, Brocade developed a corrective action plan for these suppliers that Brocade currently expects to implement during its CY 2017 conflict minerals RCOI and due diligence processes. In the case of suppliers for Ruckus products, the Ruckus business unit conflict minerals team determined on a case-by-case basis the appropriate risk strategy for supply chain risks identified in the course of due diligence efforts.
Potential outcomes under Brocade’s risk management plan include continued communication with suppliers to reinforce Brocade’s expectations for its supply chain, preparing internal reports for Brocade’s senior management including recommendations to further mitigate supply chain risk, managing the supply chain risk through suspension or termination of contracts with suppliers, or working with suppliers to actively assist them in developing a conflict-free supply chain (i.e., through use of the CFSP or other means). For example, Brocade used industry-adopted tools and templates provided by the CFSI to reach out to its suppliers for classic Brocade products that identified SORs that have not received a conflict-free designation to request that they engage with such SORs to encourage and assist their participation in the CFSP. In addition, Brocade has directly communicated with the non-compliant tungsten smelters identified by its in-scope suppliers for classic Brocade products to encourage their participation in the CFSP.
OECD Step 4 - Independent third-party audits of SORs
As a downstream company, Brocade relies on the CFSI to perform independent third-party audits of SORs. Furthermore, as a contributing member of the EICC and a CFSI member, Brocade has demonstrated its support of independent third party audits of SORs by programs such as the CFSP.
In addition, and based on the outcome of its risk review and any follow-up actions, Brocade selected a group of 21 suppliers for classic Brocade products to participate in “desktop” audits. This group consisted of certain top suppliers that indicated that they sourced conflict minerals from the covered countries, as well as one “control” supplier that indicated that it did not source conflict minerals from the covered countries. The objective of these audits was to verify the information provided in their CMRTs regarding the source and chain of custody of any conflict minerals in their products.
The audits were conducted by an experienced auditor from Brocade’s outside contractor, who was independent of the data collection process, and included: (1) independently verifying information provided by each supplier to the extent possible (e.g., by reviewing each supplier’s company website regarding its conflict minerals policy and other relevant publicly available information, such as information on identified SORs) and (2) contacting each supplier by email to request follow-up information, including additional SOR information, if needed, and completion of a questionnaire regarding its conflict minerals management system, how it derived its information on the CMRT, source of supply, and to ascertain whether the metal(s) could have come from scrap or recycled sources.
Six suppliers did not complete the requested questionnaire; however, sufficient information was provided on the companies’ CMRTs, websites, or via email responses for the auditor to complete the process. In all cases, the suppliers reported that they were collecting information from the supply chains using the CMRT and were conducting due diligence on that information. Only one of the suppliers in the desktop audit reported receiving less than 100% of the data it needed from its suppliers. Additional information regarding conflict minerals policies and reporting was publicly available for all 21 suppliers. After reviewing the results of the desktop audit, Brocade determined that the information provided by the audited suppliers in their CMRTs generally appeared to be verifiable and accurate.
OECD Step 5 - Report on supply chain due diligence
As required under the Rule, Brocade has filed its Form SD, which contains this CMR as an exhibit, with the SEC for CY 2016. Brocade expects to report annually, to the extent required by the Rule, and has posted this CMR on the Company’s website at http://www.brocade.com/en/about-us/corporate-responsibility/governance.html.
Due Diligence Results
Following the completion of its due diligence process, Brocade determined that at least some of the necessary conflict minerals incorporated in its in-scope products may have originated in the covered countries and may not be solely from recycled or scrap sources. This conclusion is based on information provided by Brocade’s in-scope suppliers for the CY 2016 reporting period and other sources, including information made available by the CFSI and other publicly available information. Given that not all SORs identified by Brocade’s in-scope suppliers have been certified as conflict-free by the CFSP, information provided by suppliers was in some instances unverifiable or incomplete, a number of suppliers responded that information regarding the source and chain of custody of necessary conflict minerals in the in-scope products was uncertain or unknown, and many in-scope suppliers provided company-level responses regarding all conflict minerals used for every product they manufacture rather than responses specific to Brocade’s in-scope products, Brocade was unable to verify with certainty the source and chain of custody of all of the necessary conflict minerals in its in-scope products. Therefore, Brocade is unable at this time to make any specific determinations regarding the status of its in-scope products for CY 2016.
Identified Smelters and Refiners
Based on SOR information provided by Brocade’s in-scope suppliers in completed CMRTs and information published by the CFSI or otherwise made available to its members as of March 6, 2017, Brocade prepared the following lists, which together comprise all of the SORs identified by Brocade’s in-scope suppliers:
| |
| • | Appendix A contains a list of SORs identified by Brocade’s in-scope suppliers that have been certified by the CFSP as conflict-free (i.e., compliant with CFSP protocols). |
| |
| • | Appendix B contains a list of SORs identified by Brocade’s in-scope suppliers that have not been certified by the CFSP as conflict-free, but that are “active” in the CFSP process (i.e., they have agreed to participate in the CFSP but the audit process has not yet been completed). |
| |
| • | Appendix C contains a list of SORs identified by Brocade’s in-scope suppliers that have not been certified by the CFSP as conflict-free (i.e., “non-compliant”) and are not known to be participating in the CFSP process. This list includes companies identified as SORs by Brocade’s in-scope suppliers that have not been assigned CFSI ID numbers. |
Brocade’s due diligence activities for CY 2016 revealed:
| |
| • | Brocade’s in-scope suppliers reported 359 SORs. |
| |
| • | 73% of the SORs reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP. |
| |
| • | 100% of the tantalum smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP. |
| |
| • | 77% of the tungsten smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP. |
| |
| • | 67% of the gold refiners reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP. |
| |
| • | 67% of the tin smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP. |
| |
| • | 3% of the total SORs reported to Brocade by its in-scope suppliers do not have CFSI ID numbers. |
As previously discussed, many of Brocade’s in-scope suppliers provided company-level responses regarding all conflict minerals used for every product they manufacture rather than responses specific to Brocade’s in-scope products; as a result, certain conflict mineral sources reported to Brocade and listed on Appendices A, B and C may not actually be used in Brocade’s in-scope products.
Country-of-Origin Information and Efforts to Determine Mine or Location of Origin
Brocade endeavored to determine the mine or location of origin of the necessary conflict minerals contained in its in-scope products by conducting a supply chain survey with its in-scope suppliers using the CMRT and through the information made available by the CFSI to its members, as well as the other measures described in this CMR.
For country-of-origin information, the Company relied primarily on the CFSI’s Compliant Smelter Sourcing Information list, which the CFSI makes available only to its members and updates periodically, and supplemented that list with information derived from the CMRTs provided by its in-scope suppliers. The CFSI list indicates country-of-origin information for many of the SORs that have been certified to be conflict-free through the CFSP (i.e., compliant SORs). However, the list does not include any country-of-origin information for (i) SORs designated as “active” in the CFSP process that have not been certified as conflict-free (such as those identified by Brocade’s suppliers and listed on Appendix B) or (ii) SORs that are non-compliant and not known to be participating in the CFSP process (such as those identified by Brocade’s suppliers and listed on Appendix C). Moreover, this list does not indicate individual countries of origin of the conflict minerals (with the exception of the DRC); instead, it indicates countries of origin by category based on defined levels of sourcing risk.
Based on the CFSI’s Compliant Smelter Sourcing Information List as of March 3, 2017, and subject to the limitations of such list described above, the compliant SORs listed on Appendix A are identified by the CFSI as sourcing conflict minerals from each of the categories of countries defined by the CFSI (L1, L2, L3 and DRC) as set forth Appendix D under the section entitled “CFSI Compliant Smelter Sourcing Information List.” The list also indicates that some of the compliant SORs listed on Appendix A process conflict minerals originating solely from recycled or scrap sources.
In addition, based solely on information reported by Brocade’s in-scope suppliers for CY 2016 in completed CMRTs (which information Brocade has not verified as being accurate or complete), the additional countries listed on Appendix D under the section entitled “Additional Reported Countries of Origin” were identified by such suppliers as countries of origin for conflict minerals in their products.
Continuous Improvement and CY 2017 Activities
For its CY 2017 data collection process, Brocade currently expects to work with its suppliers that are determined to be in-scope for CY 2017 to refine SOR and country-of-origin information for its necessary conflict minerals and to strive to advance the effectiveness of its due diligence on the source and chain of custody for the necessary conflict minerals in its supply chain. In addition, Brocade is developing and expects to implement a corrective action plan for those suppliers for classic Brocade products that did not meet Brocade’s expectations as identified in its conflict minerals statement. Brocade plans to design the corrective action plan to reinforce Brocade’s expectations for its suppliers to provide better and more detailed information regarding the source of any conflict minerals in their products, to source minerals from conflict-free SORs, and to aggressively encourage non-compliant SORs to undergo certification as conflict-free. Brocade also intends to continuously monitor the CFSI’s list of SORs that have been certified as conflict-free by the CFSP for SORs that have been removed and to take the appropriate actions consistent with its risk mitigation strategy described in the section above entitled “Due Diligence -Overview of Due Diligence Process - OECD Step 3 - Design and implement a strategy to respond to identified risks.” In addition to continued engagement with suppliers, Brocade plans to follow up with the SORs to whom it has reached out directly in order to encourage their participation in the CFSP and to assess their progress.
| |
| 4. | Forward Looking Statements |
This CMR contains forward-looking statements regarding future events and future results. All statements other than statements of historical fact are statements that could be deemed forward-looking statements that involve risks and uncertainties, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts, strategy and future reporting. Words such as “expects,” “intends,” “plans,” “may,” “will,” and variations of such words and similar expressions are intended to identify such forward-looking statements. Readers are cautioned that these forward-looking statements are only predictions and are subject to risks, uncertainties, and assumptions that are difficult to predict (including, but not limited to, whether industry organizations and initiatives such as the EICC and the CFSI and other supply chain transparency efforts remain effective as a source of external support in the conflict minerals compliance process, risks and uncertainties associated with the possibility of inaccurate information, fraud and other irregularities, inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information, and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, as well as the possibility of future regulatory changes). Therefore, actual results may differ materially and adversely from those expressed or implied in any forward-looking statements. Furthermore, Brocade undertakes no obligation to revise or update any forward-looking statements for any reason.
APPENDIX A
List of Certified “Conflict-Free” (i.e., CFSP-compliant) SORs
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Advanced Chemical Company | CID000015 | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | BRAZIL |
| Gold | Argor-Heraeus S.A. | CID000077 | SWITZERLAND |
| Gold | Asahi Pretec Corp. | CID000082 | JAPAN |
| Gold | Asahi Refining Canada Limited | CID000924 | CANADA |
| Gold | Asahi Refining USA Inc. | CID000920 | UNITED STATES |
| Gold | Asaka Riken Co., Ltd. | CID000090 | JAPAN |
| Gold | AU Traders and Refiners | CID002850 | SOUTH AFRICA |
| Gold | Aurubis AG | CID000113 | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES |
| Gold | Boliden AB | CID000157 | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | CANADA |
| Gold | Chimet S.p.A. | CID000233 | ITALY |
| Gold | Daejin Indus Co., Ltd. | CID000328 | KOREA (REPUBLIC OF) |
| Gold | DODUCO GmbH | CID000362 | GERMANY |
| Gold | Dowa | CID000401 | JAPAN |
| Gold | DSC (Do Sung Corporation) | CID000359 | KOREA (REPUBLIC OF) |
| Gold | Eco-System Recycling Co., Ltd. | CID000425 | JAPAN |
| Gold | Emirates Gold DMCC | CID002561 | UNITED ARAB EMIRATES |
| Gold | Geib Refining Corporation | CID002459 | UNITED STATES |
| Gold | Heimerle + Meule GmbH | CID000694 | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CID000707 | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | GERMANY |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN |
| Gold | Istanbul Gold Refinery | CID000814 | TURKEY |
| Gold | Japan Mint | CID000823 | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN |
| Gold | Kazzinc | CID000957 | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | JAPAN |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Korea Zinc Co., Ltd. | CID002605 | KOREA (REPUBLIC OF) |
| Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN |
| Gold | LS-NIKKO Copper Inc. | CID001078 | KOREA (REPUBLIC OF) |
| Gold | Materion | CID001113 | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | CHINA |
| Gold | Metalor Technologies S.A. | CID001153 | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | CID001157 | UNITED STATES |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 | MEXICO |
| Gold | Mitsubishi Materials Corporation | CID001188 | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | ,INDIA |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | CID001220 | TURKEY |
| Gold | Nihon Material Co., Ltd. | CID001259 | JAPAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | CID000493 | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | CID001352 | SWITZERLAND |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA |
| Gold | PX Précinox S.A. | CID001498 | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | SOUTH AFRICA |
| Gold | Republic Metals Corporation | CID002510 | UNITED STATES |
| Gold | Royal Canadian Mint | CID001534 | CANADA |
| Gold | Samduck Precious Metals | CID001555 | KOREA (REPUBLIC OF) |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 | GERMANY |
| Gold | Schone Edelmetaal B.V. | CID001573 | NETHERLANDS |
| Gold | SEMPSA Joyería Platería S.A. | CID001585 | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | CHINA |
| Gold | Singway Technology Co., Ltd. | CID002516 | TAIWAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | TAIWAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN |
| Gold | T.C.A S.p.A | CID002580 | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | JAPAN |
| Gold | Torecom | CID001955 | KOREA (REPUBLIC OF) |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Umicore Brasil Ltda. | CID001977 | BRAZIL |
| Gold | Umicore Precious Metals Thailand | CID002314 | THAILAND |
| Gold | Umicore SA Business Unit Precious Metals Refining | CID001980 | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | CID001993 | UNITED STATES |
| Gold | Valcambi S.A. | CID002003 | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | CID002030 | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | GERMANY |
| Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 | CHINA |
| Tantalum | D Block Metals, LLC | CID002504 | UNITED STATES |
| Tantalum | Duoluoshan | CID000410 | CHINA |
| Tantalum | Exotech Inc. | CID000456 | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | CHINA |
| Tantalum | Global Advanced Metals Aizu | CID002558 | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | UNITED STATES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | CHINA |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | CID002545 | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | CID002546 | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | GERMANY |
| Tantalum | H.C. Starck Inc. | CID002548 | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | CID002549 | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 | GERMANY |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | CID000731 | UNITED STATES |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | CHINA |
| Tantalum | KEMET Blue Metals | CID002539 | MEXICO |
| Tantalum | KEMET Blue Powder | CID002568 | UNITED STATES |
| Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 | CHINA |
| Tantalum | LSM Brasil S.A. | CID001076 | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | INDIA |
| Tantalum | Mineração Taboca S.A. | CID001175 | BRAZIL |
| Tantalum | Mitsu Mining and Smelting Co., Ltd | CID001192 | JAPAN |
| Tantalum | Molycorp Silmet A.S. | CID001200 | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Tantalum | Plansee SE Liezen | CID002540 | AUSTRIA |
| Tantalum | Plansee SE Reutte | CID002556 | AUSTRIA |
| Tantalum | Power Resources Ltd. | CID002847 | MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
| Tantalum | QuantumClean | CID001508 | UNITED STATES |
| Tantalum | Resind Indústria e Comércio Ltda. | CID002707 | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION |
| Tantalum | Taki Chemical Co. Ltd | CID001869 | JAPAN |
| Tantalum | Telex Metals | CID001891 | UNITED STATES |
| Tantalum | Tranzact, Inc. | CID002571 | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | KAZAKHSTAN |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 | CHINA |
| Tantalum | Zhuzhou Cemented Carbide | CID002232 | CHINA |
| Tin | Alpha | CID000292 | UNITED STATES |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | CHINA |
| Tin | China Tin Group Co., Ltd. | CID001070 | CHINA |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | CID000295 | BRAZIL |
| Tin | CV Ayi Jaya | CID002570 | INDONESIA |
| Tin | CV Dua Sekawan | CID002592 | INDONESIA |
| Tin | CV Gita Pesona | CID000306 | INDONESIA |
| Tin | CV Serumpun Sebalai | CID000313 | INDONESIA |
| Tin | CV Tiga Sekawan | CID002593 | INDONESIA |
| Tin | CV United Smelting | CID000315 | INDONESIA |
| Tin | CV Venus Inti Perkasa | CID002455 | INDONESIA |
| Tin | Dowa | CID000402 | JAPAN |
| Tin | Elmet S.L.U. | CID002774 | SPAIN |
| Tin | EM Vinto | CID000438 | BOLIVIA |
| Tin | Fenix Metals | CID000468 | POLAND |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CID002848 | CHINA |
| Tin | Gejiu Jinye Mineral Company | CID002859 | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | CHINA |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | CID002500 | BRAZIL |
| Tin | Metallic Resources, Inc. | CID001142 | UNITED STATES |
| Tin | Metallo-Chimique N.V. | CID002773 | BELGIUM |
| Tin | Mineração Taboca S.A. | CID001173 | BRAZIL |
| Tin | Minsur | CID001182 | PERU |
| Tin | Mitsubishi Materials Corporation | CID001191 | JAPAN |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | PHILIPPINES |
| Tin | Operaciones Metalurgical S.A. | CID001337 | BOLIVIA |
| Tin | PT Aries Kencana Sejahtera | CID000309 | INDONESIA |
| Tin | PT Artha Cipta Langgeng | CID001399 | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA |
| Tin | PT Babel Inti Perkasa | CID001402 | INDONESIA |
| Tin | PT Bangka Prima Tin | CID002776 | INDONESIA |
| Tin | PT Bangka Tin Industry | CID001419 | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | CID001421 | INDONESIA |
| Tin | PT Bukit Timah | CID001428 | INDONESIA |
| Tin | PT DS Jaya Abadi | CID001434 | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | CID001438 | INDONESIA |
| Tin | PT Inti Stania Prima | CID002530 | INDONESIA |
| Tin | PT Karimun Mining | CID001448 | INDONESIA |
| Tin | PT Kijang Jaya Mandiri | CID002829 | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | CID002870 | INDONESIA |
| Tin | PT Menara Cipta Mulia | CID002835 | INDONESIA |
| Tin | PT Mitra Stania Prima | CID001453 | INDONESIA |
| Tin | PT O.M. Indonesia | CID002757 | INDONESIA |
| Tin | PT Panca Mega Persada | CID001457 | INDONESIA |
| Tin | PT Prima Timah Utama | CID001458 | INDONESIA |
| Tin | PT Refined Bangka Tin | CID001460 | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | CID001463 | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | CID001468 | INDONESIA |
| Tin | PT Sukses Inti Makmur | CID002816 | INDONESIA |
| Tin | PT Sumber Jaya Indah | CID001471 | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | CID001477 | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | CID001482 | INDONESIA |
| Tin | PT Tinindo Inter Nusa | CID001490 | INDONESIA |
| Tin | PT Tommy Utama | CID001493 | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda. | CID002706 | BRAZIL |
| Tin | Rui Da Hung | CID001539 | TAIWAN |
| Tin | Soft Metais Ltda. | CID001758 | BRAZIL |
| Tin | Thaisarco | CID001898 | THAILAND |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | BRAZIL |
| Tin | Yunnan Tin Company Limited | CID002180 | CHINA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | CHINA |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 | UNITED |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | CHINA |
| Tungsten | H.C. Starck GmbH | CID002541 | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | CHINA |
| Tungsten | Hydrometallurg, JSC | CID002649 | RUSSIAN FEDERATION |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | CHINA |
| Tungsten | Kennametal Fallon | CID000966 | UNITED STATES |
| Tungsten | Kennametal Huntsville | CID000105 | UNITED STATES |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA |
| Tungsten | Moliren Ltd | CID002845 | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | CID002589 | UNITED STATES |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 | VIET NAM |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | PHILIPPINES |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CID002815 | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | VIET NAM |
| Tungsten | Unecha Refractory metals plant | CID002724 | RUSSIAN FEDERATION |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | CID002843 | KOREA (REPUBLIC OF) |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | CHINA |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | CHINA |
APPENDIX B
List of SORs “Active” in the CSFP Process
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Abington Reldan Metals, LLC | CID002708 | UNITED STATES |
| Gold | Bangalore Refinery | CID002863 | INDIA |
| Gold | Cendres + Métaux S.A. | CID000189 | SWITZERLAND |
| Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 | POLAND |
| Gold | Modeltech Sdn Bhd | CID002857 | MALAYSIA |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN |
| Gold | Tony Goetz NV | CID002587 | BELGIUM |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | VIET NAM |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 | CHINA |
| Tin | Modeltech Sdn Bhd | CID002858 | MALAYSIA |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CID001231 | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | CHINA |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 | CHINA |
APPENDIX C
List of SORs that are Non-Compliant and with No Known Participation in the CFSP
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Johnson Matthey Chemicals Ltd. | | UNITED STATES |
| Gold | Suichang County Garden ridge Gold factory | | |
| Gold | Zhongkuang Group Co,.Ltd. | | |
| Tin | Novosibirsk Integrated Tin Works | | |
| Tin | Shenzhen Xinhongtai Tin Co., Ltd | | |
| Tin | Super Ligas | | BRAZIL |
| Tin | Xianghualing Tin Industry Co., Ltd. | | CHINA |
| Tin | Yunnan Gejiu Jinye Minerals | OTH173 | CHINA |
| Tin | Zhongshan Jinye Smelting Co., Ltd | | |
| Gold | Aktyubinsk Copper Company TOO | CID000028 | KAZAKHSTAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY |
| Gold | AURA-II | CID002851 | UNITED STATES |
| Gold | Caridad | CID000180 | MEXICO |
| Gold | Chugai Mining | CID000264 | JAPAN |
| Gold | Colt Refining | CID000288 | UNITED STATES |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | CHINA |
| Gold | Elemetal Refining, LLC | CID001322 | UNITED STATES |
| Gold | Faggi Enrico S.p.A. | CID002355 | ITALY |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 | ZIMBABWE |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CID000522 | CHINA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | CHINA |
| Gold | Guangdong Jinding Gold Limited | CID002312 | CHINA |
| Gold | Gujarat Gold Centre | CID002852 | INDIA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | CHINA |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | CID002519 | CHINA |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 | CHINA |
| Gold | HwaSeong CJ Co., Ltd. | CID000778 | KOREA (REPUBLIC OF) |
| Gold | Kaloti Precious Metals | CID002563 | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | CID000956 | KAZAKHSTAN |
| Gold | Korea Metal Co., Ltd. | CID000988 | KOREA, REPUBLIC OF |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | CID001032 | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CID001056 | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | CHINA |
| Gold | Materials Eco-Refining CO.,LTD | CID003085 | |
| Gold | Metahub Industries Sdn. Bhd. | CID002821 | MALAYSIA |
| Gold | Morris and Watson | CID002282 | NEW ZEALAND |
| Gold | OJSC Kolyma Refinery | CID001328 | RUSSIAN FEDERATION |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | CHINA |
| Gold | Remondis Argentia B.V. | CID002582 | NETHERLANDS |
| Gold | SAAMP | CID002761 | FRANCE |
| Gold | Sabin Metal Corp. | CID001546 | UNITED STATES |
| Gold | SAFINA A.S. | CID002290 | CZECH REPUBLIC |
| Gold | Sai Refinery | CID002853 | INDIA |
| Gold | Samwon Metals Corp. | CID001562 | KOREA (REPUBLIC OF) |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | CHINA |
| Gold | Shenzhen Lianfeng Hardware Plastic Products Co., Ltd. | CID002406 | |
| Gold | So Accurate Group, Inc. | CID001754 | UNITED STATES |
| Gold | Sudan Gold Refinery | CID002567 | SUDAN |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | CHINA |
| Gold | TOO Tau-Ken-Altyn | CID002615 | KAZAKHSTAN |
| Gold | Universal Precious Metals Refining Zambia | CID002854 | ZAMBIA |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | CHINA |
| Tin | An Thai Minerals Co., Ltd. | CID002825 | VIET NAM |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | VIET NAM |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 | CHINA |
| Tin | Estanho de Rondônia S.A. | CID000448 | BRAZIL |
| Tin | Feinhütte Halsbrücke GmbH | CID000466 | GERMANY |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | CHINA |
| Tin | Global Advanced Metals | CID000566 | UNITED STATES |
| Tin | Hezhou Jinwei Tin Co., Ltd | CID000720 | CHINA |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CID001063 | CHINA |
| Tin | Metahub Industries Sdn. Bhd. | CID001136 | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | VIET NAM |
| Tin | Novosibirsk Processing Plant Ltd. | CID001305 | RUSSIAN FEDERATION |
| Tin | Phoenix Metal Ltd. | CID002507 | RWANDA |
| Tin | PT Alam Lestari Kencana | CID001393 | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | CID001406 | INDONESIA |
| Tin | PT Bangka Kudai Tin | CID001409 | INDONESIA |
| Tin | PT Bangka Putra Karya | CID001412 | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | CID001416 | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | CID001424 | INDONESIA |
| Tin | PT Cipta Persada Mulia | CID002696 | INDONESIA |
| Tin | PT Fang Di MulTindo | CID001442 | INDONESIA |
| Tin | PT Justindo | CID000307 | INDONESIA |
| Tin | PT Koba Tin | CID001449 | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | CID001486 | INDONESIA |
| Tin | PT Seirama Tin investment | CID001466 | INDONESIA |
| Tin | PT Tirus Putra Mandiri | CID002478 | INDONESIA |
| Tin | PT Wahana Perkit Jaya | CID002479 | INDONESIA |
| Tin | PT Yinchendo Mining Industry | CID001494 | INDONESIA |
| Tin | Shanghai Yueqiang Metal Products Co., Ltd | CID001642 | CHINA |
|
| | | |
| Metal | Smelter Name | Smelter Identification | Smelter Location |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | VIET NAM |
| Tungsten | ACL Metais Eireli | CID002833 | BRAZIL |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CID002518 | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CID000345 | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CID002531 | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CID002578 | CHINA |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | CHINA |
| Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. | CID001091 | CHINA |
| Tungsten | Pobedit, JSC | CID002532 | RUSSIAN FEDERATION |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | CID002538 | VIET NAM |
APPENDIX D
Country of Origin Information
CFSI Compliant Smelter Sourcing Information List
| |
| • | L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries: Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russia, Senegal, Sierra Leone, Spain, Thailand, Togo, United States of America, Uzbekistan, Vietnam and Zimbabwe |
| |
| • | L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing conflict minerals: Mozambique and South Africa. |
| |
| • | L3 - Countries adjoining the DRC: Burundi, Rwanda and Uganda |
| |
| • | DRC - The Democratic Republic of the Congo. |
Additional Reported Countries of Origin
