UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_______________
Form SD
Specialized Disclosure Report
Finisar Corporation
(Exact name of registrant as specified in its charter)
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| | | | |
| Delaware | | 000-27999 | | 94-3038428 |
| (State or other jurisdiction of incorporation) | | (Commission File No.) | | (I.R.S. Employer Identification No.) |
1389 Moffett Park Drive, Sunnyvale, CA 94089
(Address of principal executive offices)
Josh Shinnick (408) 548-1000
(Name and telephone number, including area code, of the person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016
Section 1. Conflict Minerals Disclosure
Item 1.01. Conflict Minerals Disclosure and Report
This Form SD of Finisar Corporation (the “Company”) is filed pursuant to Rule 13p‑1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2016 to December 31, 2016.
The Company has determined that certain Conflict Minerals (as defined in Exhibit 1.01. the Introduction) are necessary to the functionality or production of certain products manufactured by the Company and has reason to believe that, during the period covered by this report, certain of such conflict minerals potentially originated in the Democratic Republic of the Congo (“the DRC”) and/or one or more of the countries that share an internationally recognized border with the DRC. Accordingly, the Company has prepared a Conflict Minerals Report, a copy of which is attached hereto as Exhibit 1.01. The Conflict Minerals Report is also publicly available on the Company’s website at www.finisar.com.
Item 1.02. Exhibit
As noted in item 1.01, the Company is filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2. Exhibits
The following exhibits are filed as a part of this report:
Exhibit 1.01 - Conflict Minerals Report of Finisar Corporation
Exhibit 1.02 – List of Smelters
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.
Date: May 30, 2017
Finisar Corporation
By: /s/ Kurt Adzema
Kurt Adzema
Executive Vice President, Finance, and
Chief Financial Officer
Exhibit Index
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| | |
| Exhibit No. | | Description |
| 1.01 | | Conflict Minerals Report of Finisar Corporation |
| 1.02 | | List of Smelters |
Finisar Corporation
Conflict Minerals Report
For the reporting period from January 1, 2016 to December 31, 2016
Introduction
This Conflict Minerals Report (this “Report”) of Finisar Corporation has been prepared pursuant to Rule 13p‑1 and Form SD promulgated under the Securities Exchange Act of 1934 (collectively, the “Rule”) for the reporting period from January 1, 2016 to December 31, 2016.
The Rule requires disclosure of certain information when a registrant manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this Report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo (“the DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. For purposes of this Report, reference to “Finisar,” “we,” “our” or the “Company” mean Finisar Corporation and its subsidiaries. As further described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products for which certain Conflict Minerals are necessary to the functionality or production of those products.
The Company and its Products
The Company is a leading provider of optical subsystems and components that are incorporated by its customers into larger systems used in a variety of data communication and telecommunication applications.
Subsystem Products: The Company’s optical subsystems provide the fundamental optical-electrical, or optoelectronic, interface for interconnecting the equipment used in wireline and wireless communication networks, including switches, routers and servers. These products rely on the use of semiconductor lasers and photodetectors in conjunction with integrated circuits, or ICs, and optoelectronic packaging to provide a cost-effective means for transmitting and receiving digital signals over fiber optic cable at speeds ranging from less than 1 gigabit per second, or Gbps, to more than 100 Gbps, over distances of less than 10 meters to more than 2,000 kilometers. These optical subsystems include the following products:
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| • | Transmitters which use a laser plus direct or indirect modulation to convert electrical signals into optical signals for transmission over fiber optics; |
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| • | Receivers which incorporate photodetectors and convert incoming optical signals into electrical signals; |
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| • | Transceivers which combine both transmitter and receiver functions in a single device; |
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| • | Transponders which include a data serializer-deserializer function that would otherwise reside in the customer’s equipment if a transceiver were used; and |
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| • | Active Optical Cables that combine two transceivers and a fiber optic cable that are built into an integrated cable assembly. |
The Company’s optical subsystem products support a wide range of network protocols, transmission speeds, fiber types, wavelengths, transmission distances, physical configurations and software enhancements.
The Company also offers products known as wavelength selective switches, or WSS. In long-haul and metro networks, each fiber may carry 50 to 100 different high-speed optical channels, each with its own specific optical wavelength. WSS are switches that are used to dynamically switch network traffic from one optical fiber to multiple other fibers without first converting the optical signal to an electronic signal. The wavelength selective feature means the WSS enable any wavelength or combination of wavelengths to be switched from the input fiber to the output fibers. WSS products are sometimes combined with other components and sold as linecards that plug into a system chassis referred to as a Reconfigurable Optical Add-Drop Multiplexer (ROADM).
Component Products: The Company manufactures a number of active and passive optical components including vertical cavity surface emitting lasers (VCSELs), Fabry-Perot, (FP) lasers, distributed feedback (DFB) lasers, tunable lasers, positive intrinsic negative (PIN), detectors, fused fiber couplers, isolators, filters, polarization beam combiners, interleavers, splitters and amplifiers. Most of these optical components are used internally in the manufacture of the Company’s optical subsystems. Some of these components are also sold in the so-called “merchant market” to other subsystems manufacturers.
Covered Products: This report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by the Company and (iii) for which the manufacture was completed during calendar year 2015. These products, which are referred to in this Report collectively as “Covered Products” consist of all of the Company’s subsystem products and component products.
Manufacturing and Supply Chain
We manufacture most of our optical subsystems at our production facilities in Ipoh, Malaysia and Wuxi, China. We manufacture short wavelength parallel optical transceiver products and certain passive optical components used in our long wavelength transceiver products, as well as ROADM linecards products and WSS assemblies, at our facility in Shanghai, China. We also manufacture WSS products at our facility near Sydney, Australia. We conduct a substantial portion of our new product introduction activities at our Sunnyvale, California, Horsham, Pennsylvania, and Sydney, Australia facilities. We also conduct a portion of our new product introduction operations at our Ipoh and Shanghai facilities. We conduct wafer fabrication operations for the manufacture of VCSELs used in short wavelength transceiver products at our facility in Allen, Texas. We conduct wafer fabrication operations for the manufacture of long wavelength FP and DFB lasers at our facility in Fremont, California. We conduct wafer fabrication operations for the manufacturing of tunable lasers and photonic integrated circuits (PICs), in our facility in Järfälla, Sweden. We use contract manufacturers for a portion of our manufacturing needs, primarily printed circuit board assemblies.
Supply chain management is coordinated from our Sunnyvale, California facility and our international purchasing office in Shenzhen, China. Our supply chain is complex. The majority of the commercially available off-the-shelf components used in our products are purchased through distributors. As such, Finisar may not have a direct relationship with the supplier(s). Our component suppliers and their respective sub-tier suppliers are principally responsible for the procurement of the raw materials used in the manufacture of the components used in our Covered Products. Raw materials purchased by our direct and indirect suppliers contain minerals, including Conflict Minerals, obtained from smelters or refiners that, in turn, source those minerals from brokers and/or traders who procure minerals from various countries. Because we do not purchase materials directly from these smelters and refiners, we have relied on our suppliers, and on information available from industry sources, for purposes of this Report.
Reasonable Country of Origin Inquiry
Beginning Beginning in 2011, we have conducted an annual, good faith Reasonable Country of Origin Inquiry (RCOI) regarding the Conflict Minerals used in, or in connection with, the production of the Covered Products. The RCOI was reasonably designed to determine whether any Conflict Minerals originated in the Covered Countries and whether any Conflict Minerals may have come from recycled or scrap sources. This investigation uses the Conflict Free Smelter Initiative’s (CFSI, www.conflictfreesourcing.org ) Conflict Minerals Reporting Template (CMRT) for gathering data from our suppliers.
Finisar’s supply chain spend data consistently shows that 90% of our supply chain spend is with our top 100 suppliers as ranked by total spend. Accordingly, the “Top 100” Suppliers was established as the starting point for the scope of the conflict minerals RCOI survey. Expanding the survey effort to cover 100% of spend increases the scope to ~900 suppliers. The scope is adjusted to include those suppliers who may have been in the “Top 100” in a prior year - and are now ranked below #100. Suppliers may be removed from the database if: they cease operations, are purchased by another organization, or if the level of Finisar’s business with them falls so low, there is no value in keeping that supplier active in the survey Additionally, a few of the “Top 100” rankings are claimed by component distributors. Therefore, Finisar expands the survey to include those component suppliers purchased through any distributor in the “Top 100”.
For 2016, our fourth year of supply chain surveys regarding conflict minerals, the survey covered 217 active suppliers.
Despite year-over-year improvements in supply chain transparency and RCOI data quality, we do not have complete information regarding the potential presence of conflict minerals across our supply chain. In 2016, many suppliers (89 of 217, 41%) provided company-level conflict minerals declarations. However, we also saw an increase in the number of suppliers who were able to provide more focused, product-level conflict mineral declarations (75 of 217, 34%), which
improves the overall data accuracy for Finisar’s consolidated report. For those suppliers who provide, company-wide reports, such reports do not identify which smelters specifically are used in the sourcing for the specific products supplied to Finisar. Therefore, Finisar reports all smelters, as being potentially in our supply chain, with any minerals originating in the conflict region as potentially supplied to Finisar. The results of our RCOI, program metrics, and due diligence efforts consider these limitations. By preferring a company-level CMRT whenever possible, our conflict minerals reporting addresses the status of our supply chain, even as the specific components sourced from each supplier may change throughout the year.
Considering the 217 suppliers in the CY2016 database, suppliers’ responses to Question 2 from the CMRT Declaration, “Is Tin, Tungsten, Tantalum, or Gold intentionally added to your product?”, shows that:
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| • | 140 of our direct suppliers confirmed the use of gold, tin, tantalum, or tungsten in the products supplied to Finisar; |
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| • | 49 of our direct suppliers reported that the products supplied to Finisar do not include any gold, tin, tantalum, or tungsten; |
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| • | 28 of our direct suppliers provided no data as to whether the products supplied to Finisar include gold, tin, tantalum, or tungsten |
Table 1, below, summarizes our suppliers’ responses to Question 6 from the CMRT Declaration, (“Have you identified all of the smelters supplying gold, tin, tantalum, or tungsten to your supply chain?”)
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| Table 1: Percentage of Supplier Reporting 100% of Smelters Identified |
| Mineral | Identified 100% | Identified <100% | Other* |
| Gold | 112 | 52% | 21 | ~10% | 84 | 39% |
| Tin | 97 | 45% | 24 | 11% | 96 | 44% |
| Tungsten | 61 | 28% | 18 | 8% | 138 | 64% |
| Tantalum | 61 | 28% | 18 | 8% | 138 | 64% |
| *Other includes "not answered" and "not applicable" |
In total, our suppliers identified 276 legitimate smelters (by CFSI identification number, or CID) who reported ore country of origin locations in 37 countries. The geographic profile based on the smelter data, shows that <1% of the Gold smelters identified by Finisar suppliers are located in Africa, including Covered Countries and non-covered countries - specifically South Africa. Our suppliers reported no Tin, Tungsten, or Tantalum smelters in Africa. Table 2 and Table 3 below summarize the findings from our 2016 Reasonable Country of Origin Inquiry, based on unique CID. Smelter status was updated to reflect the information listed in the CFSI database as of 18-May-2016:
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| Table 2: Percent Compliant per Mineral | | Table 3: Smelter Status as per CFSI Members' Access Database |
| Mineral | Compliant | Not yet Compliant | Percent Compliant | | Smelter Status, 18-May-2016 | Qty | Pctg |
| Gold | 92 | 27 | 77% | | Compliant | 231 | 84% |
| Tin | 59 | 13 | 82% | | On the CFSP Active List | 10 | ~4% |
| Tungsten | 38 | 4 | 90% | | In Communication with CFSP | 4 | ~2% |
| Tantalum | 42 | — | 100% | | Outreach Needed - push to join CFSP | 24 | ~9% |
| Total | 231 | 44 | | | Other Status | 5 | ~2% |
| | | | | | Non-Compliant | 1 | — |
| | | | | | Total | 275 | |
At the end of CY2014, in an effort to drive improvement through the supply chain, we established internal goals for improving the “percent compliant” position of each mineral, with the aim of driving more smelters to achieve CFSI compliance, and for our supply chain to source more material from CFSI-compliant smelters. The CY2016 goals were met or exceeded for Gold, Tungsten, and Tantalum.
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| Table 4: Percent Compliant Smelter – 2015 and 2016 Goals and Results |
| Mineral | CY2015 Internal Goal | CY2015 Results | CY2015 Goal Achieved | CY2016 Internal Goal | CY2016 Results | CY2016 Goal Achieved |
| Gold | 75% | 67% | No | 75% | 77% | Yes |
| Tin | 55% | 81% | Yes | 85% | 82% | No |
| Tungsten | 55% | 74% | Yes | 80% | 90% | Yes |
| Tantalum | 100% | 100% | Yes | 100% | 100% | Yes |
Due Diligence Process
On the basis of the findings in our RCOI, we conducted a broader due diligence investigation regarding the source and chain of custody of the Conflict Minerals used in the Covered Products. The Company’s due diligence measures have been designed to conform to the framework in the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas.
Step 1: Establish Strong Company Management Systems.
The first step in the OECD framework is to establish strong internal systems, including record-keeping and chain of custody tracking and/or traceability systems. To implement Step 1, we have taken the following actions:
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| • | In April 2011, we adopted our Conflict Minerals policy, which was revised in 2012, 2014 and 2016. The current policy statement is posted on our website (www.finisar.com ). The October 2014 revision clarified our corporate policy to not purchase from known conflict sources, and our expectation that our suppliers abide by the same standard. Further, this policy established the corporate goal to purchase from only responsible, conflict-free sources, as validated by the Conflict Free Sourcing Initiative (the "CFSI"); |
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| • | We established a cross-functional Conflict Minerals Working Group under the direction of our Global Quality System Manager and including representatives of our Legal, Finance, Global Supply Chain, and Internal Audit Departments. This group reports its activities to our executive management at quarterly-scheduled meetings and bi-annually to the Audit Committee of our Board of Directors; |
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| • | We adopted our Conflict Minerals Due Diligence and Reporting procedure in 2013 to receive inquiries and grievances regarding our conflict minerals programs and practices. This procedure was refined in February, 2014 to define the requirements regarding follow-up investigations after the report of alleged suspect conflict sources, and in October 2014 to incorporate best-practices identified from the September 2014 CFSI member workshop. The July-2016 update to our procedure incorporated feedback learned through the CFSP peer-review program offered by CFSI’s Due Diligences Practices team following the May-2016 filing deadline; |
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| • | We communicated the Company Policy to our direct suppliers and requested that they conduct their own RCOI and return a completed CFSI Conflict Minerals Reporting Template. In 2014, we added the topic of Conflict Minerals to our Supplier Assessment process in our supply chain to better understand and assess our suppliers’ RCOI and due diligence efforts regarding Conflict Minerals. |
Step 2: Identify and Assess Risk in the Supply Chain.
The second step in the OECD framework requires an assessment of conflict-related risks in the supply chain. To implement Step 2, we have taken the following actions:
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| • | Following the process designed in 2012, we compiled a list of our top 100 suppliers based on FY15-Q3 spend data. Each of these suppliers received a request for a current assessment using the CMRT to report the down-stream smelters and refiners for tin, tungsten, tantalum, and/or gold. Suppliers with incomplete survey responses in 2014 were automatically included in the 2015 survey. Suppliers, were sent follow-up inquiries if survey answers were inconsistent or incomplete, or if the accompanying smelter list required review and clarification; |
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| • | The supplier responses for smelter and mine data were de-duplicated to develop a single smelter list. We used our suppliers’ responses to identify smelters, refiners and country of origin data; |
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| • | We followed the guidelines established by the Conflict-Free Sourcing Initiative (www.conflictfreesourcing.org), and referenced the CFSI master smelter database to confirm compliance status for each smelter reported from our supply chain. This database is queried periodically to update smelter status for follow-up reports and due diligence efforts; and, |
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| • | We established a follow up investigation procedure to respond to customers’ or other interested parties’ inquiries regarding potential suspect suppliers. If we become aware of concerns about suspect mineral sourcing, we require the supplier purchasing from the suspect source to investigate and conduct traceability of materials, implement corrective actions if necessary, and provide assurance of a conflict-free supply chain. |
Step 3: Design and Implement a Strategy to Respond to Identified Risks.
The third step in the OECD framework is the development of a strategy to mitigate and regularly monitor risks in the supply chain. To implement Step 3, we have taken the following actions:
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| • | We have developed procedures for sending supply-chain inquiries to our top 100 suppliers on an annual basis, reviewing their responses, consolidating the information in a central database, and conducting follow-up inquiries and/or action items to address any incomplete or inconsistent responses; |
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| • | We continue to follow and consult the EICC guidelines, CFSI, and other industry-sponsored programs, events, and best practices. In September 2014, Finisar became a member of CFSI in order to leverage the research and data analysis available to member companies as part of our Conflict Free RCOI and due diligence efforts. Additionally we began participating in an informal working group comprised of several similarly situated Silicon Valley companies. The aim of this group is to share insights and best practices regarding RCOI, data management, and due diligence efforts around issues of supply chain transparency and ethical sourcing, including conflict minerals; |
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| • | We report information on the sources and chain of custody of Conflict Minerals used in our products to our executive management and the Audit Committee of our Board of Directors; |
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| • | We require our suppliers to conduct investigations of any smelters identified as high-risk and work with our suppliers to address compliance issues and to transition their processing to CFSP compliant smelters; and |
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| • | We will take appropriate action, including the discontinuation of the supply relationships, when we determine that our suppliers are not adhering to the Company Policy. |
Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence.
The fourth step in the OECD framework is to obtain audits of due diligence practices employed by smelters and refiners supplying minerals from conflict-affected and high-risk areas. Because we do not source Conflict Minerals directly from smelters or other processing facilities, we rely on third parties, including the CFSP, to coordinate and conduct third-party audits of these facilities. We rely upon the published results of these third-party audits to validate the responsible sourcing practices of the smelters and other processing facilities in our supply chain.
Step 5: Report on Supply Chain Due Diligence.
The fifth step in the OECD framework requires companies to publicly report on their supply chain due diligence policies and practices. To implement Step 5, have taken or intend to take the following actions:
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| • | We will file an annual report with the Securities and Exchange Commission (SEC) on Form SD, together with any required Conflict Minerals Report and report of independent private sector auditor; |
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| • | We will make all such SEC reports available on our website; |
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| • | We will provide our CFSI Conflict Minerals Reporting template to customers and other qualified interested parties upon request. |
Additionally, we may refer to our conflict minerals program, as appropriate, in other public statements reports filed with the SEC.
Conflict Minerals Smelters and Refiners
Based on the CY2016 information reported by our direct suppliers, the top five smelter locations by country, consolidated for all four minerals, were China, Indonesia, Japan, United States, and Brazil.
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| Table 5: Geographic Profile of Smelter Locations |
| | Americas | Europe | Asia / Pacific | Africa |
| Gold | 17 | 38 | 63 | 1 |
| Tin | 13 | 2 | 57 | — |
| Tungsten | 5 | 5 | 32 | — |
| Tantalum | 13 | 6 | 23 | — |
Country of Origin of Conflict Materials in the Covered Products
Based on the information provided by our direct suppliers, and otherwise obtained to date through the due diligence process described above, we have reason to believe that some of the Conflict Minerals necessary to the functionality or production of the Covered Products originated from the following Covered Countries: the Democratic Republic of the Congo, Burundi, and Rwanda. Although at this time we cannot give any firm assurance, based on the findings from our RCOI, Finisar is not aware of any of its products containing Conflict Minerals whose mining, smelting, or refining has benefited armed conflict and other human rights or environmental abuses in any of the Covered Countries.
Further Steps in Our Due Diligence Process
For 2017, the Company plans to take the following steps, among others, to improve its due diligence process and to further mitigate the risk that the Conflict Minerals necessary to the functionality or production of the Covered Products benefits armed conflict and other human rights or environmental abuses in any of the Covered Countries:
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| • | We will continue to engage with our direct suppliers and, in partnership with those suppliers, engage with their supply chain, smelters and processing facilities, to obtain current, accurate and complete information regarding our Conflict Mineral sources; |
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| • | We will continue to encourage our direct suppliers to adhere to Finisar’s Ethical Souring and Conflict Minerals Policy, to refine their own due diligence program, and to encourage smelters in the supply chain to obtain a “conflict-free” designation from an independent, third-party audit program; |
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| • | We will advise our suppliers that we intend to cease doing business with suppliers who continue to source Conflict Minerals from smelters that are not confirmed as “conflict-free” or actively engaged with CFSP, with a clear roadmap and timeline to become compliant; |
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| • | For CY2017, we will continue our annual survey of all active suppliers surveyed in a prior year and the current year’s "Top 100" suppliers, based on the framework described in Step 2. This survey will leverage the recently updated CMRT version 4.20/4.50 and its updated smelter identification look-up tables. Additional due diligence inquiries will be based on a supplier’s answers to survey questions, and the smelters / countries named in their declaration; and, |
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| • | Our on-going follow-up efforts will continue toward on improving the “percent compliant” position for each of the four minerals (see Table 4, on Pg. 4). Our CY2017 goals for each mineral are: Tantalum = 100%, Tin ≥ 90%, Tungsten ≥ 100%, and Gold ≥ 85%, sourcing from compliant smelters. |
Exhibit 1.02 - List of Smelters -- Consolidated Results from 2015 Survey Responses
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| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Gold | CID002777 | GERMANY | SAXONIA Edelmetalle GmbH | Compliant |
| Gold | CID002580 | ITALY | T.C.A S.p.A | Compliant |
| Gold | CID002516 | TAIWAN | Singway Technology Co., Ltd. | Compliant |
| Gold | CID002509 | INDIA | MMTC-PAMP India Pvt., Ltd. | Compliant |
| Gold | CID001326 | RUSSIAN FEDERATION | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Compliant |
| Gold | CID000929 | RUSSIAN FEDERATION | JSC Uralelectromed | Compliant |
| Gold | CID000927 | RUSSIAN FEDERATION | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Compliant |
| Gold | CID000823 | JAPAN | Japan Mint | Compliant |
| Gold | CID000801 | CHINA | Inner Mongolia Qiankun Gold and Silver Refinery Share Co. | Compliant |
| Gold | CID000493 | RUSSIAN FEDERATION | OJSC Novosibirsk Refinery | Compliant |
| Gold | CID000362 | GERMANY | DODUCO GmbH | Compliant |
| Gold | CID000041 | UZBEKISTAN | Almalyk Mining and Metallurgical Complex (AMMC) | Compliant |
| Gold | CID002511 | POLAND | KGHM Polska Miedz Spolka Akcyjna | Active |
| Gold | CID001029 | KYRGYZSTAN | Kyrgyzaltyn JSC | Compliant |
| Gold | CID000359 | KOREA (REPUBLIC OF) | DSC (Do Sung Corporation) | Compliant |
| Gold | CID000328 | KOREA (REPUBLIC OF) | Daejin Indus Co., Ltd. | Compliant |
| Gold | CID000956 | KAZAKHSTAN | Kazakhmys Smelting LLC | In Communication |
| Gold | CID000778 | KOREA (REPUBLIC OF) | HwaSeong CJ CO., LTD. | Communication Suspended - Not Interested |
| Gold | CID000180 | MEXICO | Caridad | Communication Suspended - Not Interested |
| Gold | CID002282 | NEW ZEALAND | Morris and Watson | Communication Suspended - Not Interested |
| Gold | CID001058 | CHINA | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Outreach Required |
| Gold | CID002312 | CHINA | Guangdong Jinding Gold Limited | Outreach Required |
| Gold | CID001032 | SAUDI ARABIA | L'azurde Company For Jewelry | Due Diligence Vetting Process |
| Gold | CID000767 | CHINA | Hunan Chenzhou Mining Co., Ltd. | Outreach Required |
| Gold | CID000103 | TURKEY | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Due Diligence Vetting Process |
| Gold | CID000185 | CANADA | CCR Refinery - Glencore Canada Corporation | Compliant |
| Gold | CID000711 | GERMANY | Heraeus Precious Metals GmbH & Co. KG | Compliant |
| Gold | CID000807 | JAPAN | Ishifuku Metal Industry Co., Ltd. | Compliant |
| Gold | CID001113 | UNITED STATES | Materion | Compliant |
| Gold | CID001188 | JAPAN | Mitsubishi Materials Corporation | Compliant |
| Gold | CID001193 | JAPAN | Mitsui Mining and Smelting Co., Ltd. | Compliant |
| Gold | CID001259 | JAPAN | Nihon Material Co., Ltd. | Compliant |
| Gold | CID002030 | AUSTRALIA | Western Australian Mint (T/a The Perth Mint) | Compliant |
| Gold | CID001622 | CHINA | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Compliant |
| Gold | CID000082 | JAPAN | Asahi Pretec Corp. | Compliant |
| Gold | CID001798 | JAPAN | Sumitomo Metal Mining Co., Ltd. | Compliant |
| Gold | CID001875 | JAPAN | Tanaka Kikinzoku Kogyo K.K. | Compliant |
| Gold | CID000937 | JAPAN | JX Nippon Mining & Metals Co., Ltd. | Compliant |
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| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Gold | CID001119 | JAPAN | Matsuda Sangyo Co., Ltd. | Compliant |
| Gold | CID001938 | JAPAN | Tokuriki Honten Co., Ltd. | Compliant |
| Gold | CID000401 | JAPAN | Dowa | Compliant |
| Gold | CID000981 | JAPAN | Kojima Chemicals Co., Ltd. | Compliant |
| Gold | CID000077 | SWITZERLAND | Argor-Heraeus S.A. | Compliant |
| Gold | CID000707 | CHINA | Heraeus Metals Hong Kong Ltd. | Compliant |
| Gold | CID000425 | JAPAN | Eco-System Recycling Co., Ltd. | Compliant |
| Gold | CID002561 | UNITED ARAB EMIRATES | Emirates Gold DMCC | Compliant |
| Gold | CID001761 | TAIWAN | Solar Applied Materials Technology Corp. | Compliant |
| Gold | CID001153 | SWITZERLAND | Metalor Technologies S.A. | Compliant |
| Gold | CID001980 | BELGIUM | Umicore S.A. Business Unit Precious Metals Refining | Compliant |
| Gold | CID001993 | UNITED STATES | United Precious Metal Refining, Inc. | Compliant |
| Gold | CID001149 | CHINA | Metalor Technologies (Hong Kong) Ltd. | Compliant |
| Gold | CID001322 | UNITED STATES | Elemetal Refining, LLC | Non Compliant |
| Gold | CID000035 | GERMANY | Allgemeine Gold-und Silberscheideanstalt A.G. | Compliant |
| Gold | CID000058 | BRAZIL | AngloGold Ashanti Corrego do Sitio Mineracao | Compliant |
| Gold | CID000019 | JAPAN | Aida Chemical Industries Co., Ltd. | Compliant |
| Gold | CID000090 | JAPAN | Asaka Riken Co., Ltd. | Compliant |
| Gold | CID000113 | GERMANY | Aurubis AG | Compliant |
| Gold | CID000233 | ITALY | Chimet S.p.A. | Compliant |
| Gold | CID000694 | GERMANY | Heimerle + Meule GmbH | Compliant |
| Gold | CID000920 | UNITED STATES | Asahi Refining USA Inc. | Compliant |
| Gold | CID000924 | CANADA | Asahi Refining Canada Ltd. | Compliant |
| Gold | CID000969 | UNITED STATES | Kennecott Utah Copper LLC | Compliant |
| Gold | CID001078 | KOREA (REPUBLIC OF) | LS-NIKKO Copper Inc. | Compliant |
| Gold | CID001955 | KOREA (REPUBLIC OF) | Torecom | Compliant |
| Gold | CID001157 | UNITED STATES | Metalor USA Refining Corporation | Compliant |
| Gold | CID001736 | CHINA | Sichuan Tianze Precious Metals Co., Ltd. | Compliant |
| Gold | CID001573 | NETHERLANDS | Schone Edelmetaal B.V. | Compliant |
| Gold | CID001325 | JAPAN | Ohura Precious Metal Industry Co., Ltd. | Compliant |
| Gold | CID001352 | SWITZERLAND | PAMP S.A. | Compliant |
| Gold | CID001512 | SOUTH AFRICA | Rand Refinery (Pty) Ltd. | Compliant |
| Gold | CID001534 | CANADA | Royal Canadian Mint | Compliant |
| Gold | CID001585 | SPAIN | SEMPSA Joyeria Plateria S.A. | Compliant |
| Gold | CID001555 | KOREA (REPUBLIC OF) | Samduck Precious Metals | Compliant |
| Gold | CID001386 | RUSSIAN FEDERATION | Prioksky Plant of Non-Ferrous Metals | Compliant |
| Gold | CID001916 | CHINA | The Refinery of Shandong Gold Mining Co., Ltd. | Compliant |
| Gold | CID001204 | RUSSIAN FEDERATION | Moscow Special Alloys Processing Plant | Compliant |
| Gold | CID002003 | SWITZERLAND | Valcambi S.A. | Compliant |
| Gold | CID002100 | JAPAN | Yamamoto Precious Metal Co., Ltd. | Compliant |
| Gold | CID002129 | JAPAN | Yokohama Metal Co., Ltd. | Compliant |
| Gold | CID002224 | CHINA | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Compliant |
|
| | | | |
| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Gold | CID002510 | UNITED STATES | Republic Metals Corporation | Compliant |
| Gold | CID000957 | KAZAKHSTAN | Kazzinc | Compliant |
| Gold | CID000015 | UNITED STATES | Advanced Chemical Company | Compliant |
| Gold | CID002779 | AUSTRIA | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Compliant |
| Gold | CID000128 | PHILIPPINES | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Compliant |
| Gold | CID000157 | SWEDEN | Boliden AB | Compliant |
| Gold | CID000176 | GERMANY | C. Hafner GmbH + Co. KG | Compliant |
| Gold | CID000814 | TURKEY | Istanbul Gold Refinery | Compliant |
| Gold | CID002778 | GERMANY | WIELAND Edelmetalle GmbH | Compliant |
| Gold | CID002605 | KOREA (REPUBLIC OF) | Korea Zinc Co., Ltd. | Compliant |
| Gold | CID002560 | UNITED ARAB EMIRATES | Al Etihad Gold LLC | Compliant |
| Gold | CID002459 | UNITED STATES | Geib Refining Corporation | Compliant |
| Gold | CID001147 | CHINA | Metalor Technologies (Suzhou) Ltd. | Compliant |
| Gold | CID000189 | SWITZERLAND | Cendres + Metaux S.A. | Active |
| Gold | CID001562 | KOREA (REPUBLIC OF) | Samwon Metals Corp. | In Communication |
| Gold | CID000264 | JAPAN | Chugai Mining | In Communication |
| Gold | CID001619 | CHINA | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Outreach Required |
| Gold | CID000651 | CHINA | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Outreach Required |
| Gold | CID001947 | CHINA | Tongling Nonferrous Metals Group Co., Ltd. | Outreach Required |
| Gold | CID001909 | CHINA | Great Wall Precious Metals Co., Ltd. of CBPM | Outreach Required |
| Gold | CID001754 | UNITED STATES | So Accurate Group, Inc. | Outreach Required |
| Gold | CID001546 | UNITED STATES | Sabin Metal Corp. | Outreach Required |
| Gold | CID001362 | CHINA | Penglai Penggang Gold Industry Co., Ltd. | Outreach Required |
| Gold | CID001093 | CHINA | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Outreach Required |
| Gold | CID001056 | CHINA | Lingbao Gold Co., Ltd. | Outreach Required |
| Gold | CID000671 | CHINA | Hangzhou Fuchunjiang Smelting Co., Ltd. | Outreach Required |
| Gold | CID000522 | CHINA | Gansu Seemine Material Hi-Tech Co., Ltd. | Outreach Required |
| Gold | CID000343 | CHINA | Daye Non-Ferrous Metals Mining Ltd. | Outreach Required |
| Gold | CID000197 | CHINA | Yunnan Copper Industry Co., Ltd. | Outreach Required |
| Gold | CID002314 | THAILAND | Umicore Precious Metals Thailand | Compliant |
| Gold | CID002243 | CHINA | Gold Refinery of Zijin Mining Group Co., Ltd. | Compliant |
| Gold | CID001977 | BRAZIL | Umicore Brasil Ltda. | Compliant |
| Gold | CID001756 | RUSSIAN FEDERATION | SOE Shyolkovsky Factory of Secondary Precious Metals | Compliant |
| Gold | CID001498 | SWITZERLAND | PX Precinox S.A. | Compliant |
| Gold | CID001397 | INDONESIA | PT Aneka Tambang (Persero) Tbk | Compliant |
| Gold | CID001220 | TURKEY | Nadir Metal Rafineri San. Ve Tic. A.S. | Compliant |
| Gold | CID001161 | MEXICO | Metalurgica Met-Mex Penoles S.A. De C.V. | Compliant |
| Gold | CID001152 | SINGAPORE | Metalor Technologies (Singapore) Pte., Ltd. | Compliant |
| Gold | CID000855 | CHINA | Jiangxi Copper Co., Ltd. | Compliant |
|
| | | | |
| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Gold | CID001236 | UZBEKISTAN | Navoi Mining and Metallurgical Combinat | Active |
| Tantalum | CID002707 | BRAZIL | Resind Industria e Comercio Ltda. | Compliant |
| Tantalum | CID002571 | UNITED STATES | Tranzact, Inc. | Compliant |
| Tantalum | CID002508 | CHINA | XinXing HaoRong Electronic Material Co., Ltd. | Compliant |
| Tantalum | CID002506 | CHINA | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Compliant |
| Tantalum | CID002505 | CHINA | FIR Metals & Resource Ltd. | Compliant |
| Tantalum | CID002568 | UNITED STATES | KEMET Blue Powder | Compliant |
| Tantalum | CID001522 | CHINA | RFH Tantalum Smeltry Co., Ltd. | Compliant |
| Tantalum | CID001508 | UNITED STATES | QuantumClean | Compliant |
| Tantalum | CID001200 | ESTONIA | NPM Silmet AS | Compliant |
| Tantalum | CID001163 | INDIA | Metallurgical Products India Pvt., Ltd. | Compliant |
| Tantalum | CID000973 | CHINA | King-Tan Tantalum Industry Ltd. | Compliant |
| Tantalum | CID000460 | CHINA | F&X Electro-Materials Ltd. | Compliant |
| Tantalum | CID002539 | MEXICO | KEMET Blue Metals | Compliant |
| Tantalum | CID002512 | CHINA | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Compliant |
| Tantalum | CID000211 | CHINA | Changsha South Tantalum Niobium Co., Ltd. | Compliant |
| Tantalum | CID000917 | CHINA | Jiujiang Nonferrous Metals Smelting Company Limited | Compliant |
| Tantalum | CID001192 | JAPAN | Mitsui Mining and Smelting Co., Ltd. | Compliant |
| Tantalum | CID001277 | CHINA | Ningxia Orient Tantalum Industry Co., Ltd. | Compliant |
| Tantalum | CID001769 | RUSSIAN FEDERATION | Solikamsk Magnesium Works OAO | Compliant |
| Tantalum | CID001869 | JAPAN | Taki Chemical Co., Ltd. | Compliant |
| Tantalum | CID001969 | KAZAKHSTAN | Ulba Metallurgical Plant JSC | Compliant |
| Tantalum | CID002544 | THAILAND | H.C. Starck Co., Ltd. | Compliant |
| Tantalum | CID002545 | GERMANY | H.C. Starck Tantalum and Niobium GmbH | Compliant |
| Tantalum | CID002547 | GERMANY | H.C. Starck Hermsdorf GmbH | Compliant |
| Tantalum | CID002548 | UNITED STATES | H.C. Starck Inc. | Compliant |
| Tantalum | CID002549 | JAPAN | H.C. Starck Ltd. | Compliant |
| Tantalum | CID002550 | GERMANY | H.C. Starck Smelting GmbH & Co. KG | Compliant |
| Tantalum | CID002557 | UNITED STATES | Global Advanced Metals Boyertown | Compliant |
| Tantalum | CID002558 | JAPAN | Global Advanced Metals Aizu | Compliant |
| Tantalum | CID002504 | UNITED STATES | D Block Metals, LLC | Compliant |
| Tantalum | CID002492 | CHINA | Hengyang King Xing Lifeng New Materials Co., Ltd. | Compliant |
| Tantalum | CID002307 | CHINA | Yichun Jin Yang Rare Metal Co., Ltd. | Compliant |
| Tantalum | CID002232 | CHINA | Zhuzhou Cemented Carbide Group Co., Ltd. | Compliant |
| Tantalum | CID001891 | UNITED STATES | Telex Metals | Compliant |
| Tantalum | CID001175 | BRAZIL | Mineracao Taboca S.A. | Compliant |
| Tantalum | CID001076 | BRAZIL | LSM Brasil S.A. | Compliant |
| Tantalum | CID000914 | CHINA | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Compliant |
| Tantalum | CID000731 | UNITED STATES | Hi-Temp Specialty Metals, Inc. | Compliant |
| Tantalum | CID000616 | CHINA | Guangdong Zhiyuan New Material Co., Ltd. | Compliant |
|
| | | | |
| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Tantalum | CID000456 | UNITED STATES | Exotech Inc. | Compliant |
| Tantalum | CID000410 | CHINA | Duoluoshan | Compliant |
| Tantalum | CID000291 | CHINA | Conghua Tantalum and Niobium Smeltry | Compliant |
| Tin | CID001493 | INDONESIA | PT Tommy Utama | Compliant |
| Tin | CID002859 | CHINA | Gejiu Jinye Mineral Company | Compliant |
| Tin | CID002573 | VIET NAM | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Outreach Required |
| Tin | CID002572 | VIET NAM | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Active |
| Tin | CID001908 | CHINA | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Active |
| Tin | CID000942 | CHINA | Gejiu Kai Meng Industry and Trade LLC | Active |
| Tin | CID001448 | INDONESIA | PT Karimun Mining | Compliant |
| Tin | CID001231 | CHINA | Nankang Nanshan Tin Manufactory Co., Ltd. | Active |
| Tin | CID000555 | CHINA | Gejiu Zili Mining And Metallurgy Co., Ltd. | In Communication |
| Tin | CID002574 | VIET NAM | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Outreach Required |
| Tin | CID000760 | CHINA | Huichang Jinshunda Tin Co., Ltd. | Active |
| Tin | CID000278 | CHINA | CNMC (Guangxi) PGMA Co., Ltd. | Outreach Required |
| Tin | CID001182 | PERU | Minsur | Compliant |
| Tin | CID001477 | INDONESIA | PT Timah (Persero) Tbk Kundur | Compliant |
| Tin | CID001482 | INDONESIA | PT Timah (Persero) Tbk Mentok | Compliant |
| Tin | CID002592 | INDONESIA | CV Dua Sekawan | Compliant |
| Tin | CID000228 | CHINA | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Compliant |
| Tin | CID000315 | INDONESIA | CV United Smelting | Compliant |
| Tin | CID000438 | BOLIVIA | EM Vinto | Compliant |
| Tin | CID000538 | CHINA | Gejiu Non-Ferrous Metal Processing Co., Ltd. | Compliant |
| Tin | CID001105 | MALAYSIA | Malaysia Smelting Corporation (MSC) | Compliant |
| Tin | CID001173 | BRAZIL | Mineracao Taboca S.A. | Compliant |
| Tin | CID001191 | JAPAN | Mitsubishi Materials Corporation | Compliant |
| Tin | CID001337 | BOLIVIA | Operaciones Metalurgical S.A. | Compliant |
| Tin | CID001428 | INDONESIA | PT Bukit Timah | Compliant |
| Tin | CID001453 | INDONESIA | PT Mitra Stania Prima | Compliant |
| Tin | CID001460 | INDONESIA | PT Refined Bangka Tin | Compliant |
| Tin | CID001468 | INDONESIA | PT Stanindo Inti Perkasa | Compliant |
| Tin | CID001898 | THAILAND | Thaisarco | Compliant |
| Tin | CID002773 | BELGIUM | Metallo Belgium N.V. | Compliant |
| Tin | CID001438 | INDONESIA | PT Eunindo Usaha Mandiri | Compliant |
| Tin | CID002036 | BRAZIL | White Solder Metalurgia e Mineracao Ltda. | Compliant |
| Tin | CID002180 | CHINA | Yunnan Tin Company Limited | Compliant |
| Tin | CID001070 | CHINA | China Tin Group Co., Ltd. | Compliant |
| Tin | CID000292 | UNITED STATES | Alpha | Compliant |
| Tin | CID000295 | BRAZIL | Cooperativa Metalurgica de Rondonia Ltda. | Compliant |
| Tin | CID000309 | INDONESIA | PT Aries Kencana Sejahtera | Compliant |
|
| | | | |
| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Tin | CID000313 | INDONESIA | CV Serumpun Sebalai | Compliant |
| Tin | CID000402 | JAPAN | Dowa | Compliant |
| Tin | CID000468 | POLAND | Fenix Metals | Compliant |
| Tin | CID001399 | INDONESIA | PT Artha Cipta Langgeng | Compliant |
| Tin | CID001402 | INDONESIA | PT Babel Inti Perkasa | Compliant |
| Tin | CID001419 | INDONESIA | PT Bangka Tin Industry | Compliant |
| Tin | CID001421 | INDONESIA | PT Belitung Industri Sejahtera | Compliant |
| Tin | CID001434 | INDONESIA | PT DS Jaya Abadi | Compliant |
| Tin | CID001457 | INDONESIA | PT Panca Mega Persada | Compliant |
| Tin | CID001458 | INDONESIA | PT Prima Timah Utama | Compliant |
| Tin | CID001463 | INDONESIA | PT Sariwiguna Binasentosa | Compliant |
| Tin | CID001490 | INDONESIA | PT Tinindo Inter Nusa | Compliant |
| Tin | CID001539 | TAIWAN | Rui Da Hung | Compliant |
| Tin | CID001758 | BRAZIL | Soft Metais Ltda. | Compliant |
| Tin | CID002468 | BRAZIL | Magnu's Minerais Metais e Ligas Ltda. | Compliant |
| Tin | CID002517 | PHILIPPINES | O.M. Manufacturing Philippines, Inc. | Compliant |
| Tin | CID002530 | INDONESIA | PT Inti Stania Prima | Compliant |
| Tin | CID002816 | INDONESIA | PT Sukses Inti Makmur | Compliant |
| Tin | CID002158 | CHINA | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Active |
| Tin | CID002703 | VIET NAM | An Vinh Joint Stock Mineral Processing Company | Outreach Required |
| Tin | CID000448 | BRAZIL | Estanho de Rondonia S.A. | Outreach Required |
| Tin | CID002825 | VIET NAM | An Thai Minerals Co., Ltd. | Outreach Required |
| Tin | CID002776 | INDONESIA | PT Bangka Prima Tin | Compliant |
| Tin | CID002774 | SPAIN | Metallo Spain S.L.U. | Compliant |
| Tin | CID002706 | BRAZIL | Resind Industria e Comercio Ltda. | Compliant |
| Tin | CID002570 | INDONESIA | CV Ayi Jaya | Compliant |
| Tin | CID002503 | INDONESIA | PT ATD Makmur Mandiri Jaya | Compliant |
| Tin | CID002500 | BRAZIL | Melt Metais e Ligas S.A. | Compliant |
| Tin | CID002455 | INDONESIA | CV Venus Inti Perkasa | Compliant |
| Tin | CID002015 | VIET NAM | VQB Mineral and Trading Group JSC | Compliant |
| Tin | CID001471 | INDONESIA | PT Sumber Jaya Indah | Compliant |
| Tin | CID001314 | THAILAND | O.M. Manufacturing (Thailand) Co., Ltd. | Compliant |
| Tin | CID001142 | UNITED STATES | Metallic Resources, Inc. | Compliant |
| Tin | CID000306 | INDONESIA | CV Gita Pesona | Compliant |
| Tin | CID000244 | CHINA | Jiangxi Ketai Advanced Material Co., Ltd. | Compliant |
| Tungsten | CID002535 | CHINA | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Compliant |
| Tungsten | CID002502 | VIET NAM | Asia Tungsten Products Vietnam Ltd. | Compliant |
| Tungsten | CID000966 | UNITED STATES | Kennametal Fallon | Compliant |
| Tungsten | CID002082 | CHINA | Xiamen Tungsten Co., Ltd. | Compliant |
| Tungsten | CID000875 | CHINA | Ganzhou Huaxing Tungsten Products Co., Ltd. | Compliant |
| Tungsten | CID002845 | RUSSIAN FEDERATION | Moliren Ltd. | Compliant |
| Tungsten | CID002843 | KOREA (REPUBLIC OF) | Woltech Korea Co., Ltd. | Compliant |
| Tungsten | CID002827 | PHILIPPINES | Philippine Chuangxin Industrial Co., Inc. | Compliant |
|
| | | | |
| Metal | CID # | Country | Smelter Name | Audit Status per CFSI Database -- 10-May-17 |
| Tungsten | CID002536 | CHINA | Ganzhou Yatai Tungsten Co., Ltd. | Non Compliant |
| Tungsten | CID000258 | CHINA | Chongyi Zhangyuan Tungsten Co., Ltd. | Compliant |
| Tungsten | CID000769 | CHINA | Hunan Chunchang Nonferrous Metals Co., Ltd. | Compliant |
| Tungsten | CID002317 | CHINA | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Compliant |
| Tungsten | CID002494 | CHINA | Ganzhou Seadragon W & Mo Co., Ltd. | Compliant |
| Tungsten | CID002319 | CHINA | Malipo Haiyu Tungsten Co., Ltd. | Compliant |
| Tungsten | CID002318 | CHINA | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Compliant |
| Tungsten | CID002095 | CHINA | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Compliant |
| Tungsten | CID002011 | VIET NAM | Vietnam Youngsun Tungsten Industry Co., Ltd. | Compliant |
| Tungsten | CID000004 | JAPAN | A.L.M.T. TUNGSTEN Corp. | Compliant |
| Tungsten | CID000105 | UNITED STATES | Kennametal Huntsville | Compliant |
| Tungsten | CID000218 | CHINA | Guangdong Xianglu Tungsten Co., Ltd. | Compliant |
| Tungsten | CID000568 | UNITED STATES | Global Tungsten & Powders Corp. | Compliant |
| Tungsten | CID000825 | JAPAN | Japan New Metals Co., Ltd. | Compliant |
| Tungsten | CID001889 | VIET NAM | Tejing (Vietnam) Tungsten Co., Ltd. | Compliant |
| Tungsten | CID002044 | AUSTRIA | Wolfram Bergbau und Hutten AG | Compliant |
| Tungsten | CID002320 | CHINA | Xiamen Tungsten (H.C.) Co., Ltd. | Compliant |
| Tungsten | CID002541 | GERMANY | H.C. Starck Tungsten GmbH | Compliant |
| Tungsten | CID002542 | GERMANY | H.C. Starck Smelting GmbH & Co. KG | Compliant |
| Tungsten | CID002724 | RUSSIAN FEDERATION | Unecha Refractory metals plant | Compliant |
| Tungsten | CID002647 | CHINA | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | Outreach Required |
| Tungsten | CID002316 | CHINA | Jiangxi Yaosheng Tungsten Co., Ltd. | Compliant |
| Tungsten | CID002313 | CHINA | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Outreach Required |
| Tungsten | CID002833 | BRAZIL | ACL Metais Eireli | Active |
| Tungsten | CID002649 | RUSSIAN FEDERATION | Hydrometallurg, JSC | Compliant |
| Tungsten | CID002589 | UNITED STATES | Niagara Refining LLC | Compliant |
| Tungsten | CID002579 | CHINA | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Compliant |
| Tungsten | CID002551 | CHINA | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Compliant |
| Tungsten | CID002543 | VIET NAM | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Compliant |
| Tungsten | CID002513 | CHINA | Chenzhou Diamond Tungsten Products Co., Ltd. | Compliant |
| Tungsten | CID002321 | CHINA | Jiangxi Gan Bei Tungsten Co., Ltd. | Compliant |
| Tungsten | CID002315 | CHINA | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Compliant |
| Tungsten | CID000766 | CHINA | Hunan Chenzhou Mining Co., Ltd. | Compliant |
| Tungsten | CID000499 | CHINA | Fujian Jinxin Tungsten Co., Ltd. | Compliant |
