Exhibit 1.01
Advanced Semiconductor Engineering, Inc.
Conflict Minerals Report
For the year ended December 31, 2015
Corporate Overview and Product Scope
Advanced Semiconductor Engineering, Inc. (“ASE”, “we”, “our”, “us”) is among the leading providers of semiconductor packaging and testing services based on 2015 revenues. Our services include semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten which are necessary to deliver our packaging, materials and electronic manufacturing services.
We have manufacturing facilities located in Taiwan, China, Malaysia, Japan, Singapore, Korea and the United States that provide packaging, testing and materials services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services to the wafers, and delivering a completed, packaged integrated circuit back to the customer. In the performance of packaging and materials services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten and tantalum. We do not use gold, tin, tungsten or tantalum in our testing services.
Since our acquisition of a controlling interest in Universal Scientific Industrial Co., Ltd. in February 2010, we provide a broad range of electronic manufacturing services to a global customer base. We have manufacturing facilities located in Taiwan, China and Mexico that provide electronic manufacturing services. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products. Typical materials and components which we utilize include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.
All packaging and materials services and electronic manufacturing services we provide contain one or more of the conflict minerals: gold, tin, tungsten or tantalum.
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Reasonable Country of Origin Inquiry (RCOI)
For our packaging and materials services, we purchase gold, tin, tungsten and tantalum from 116 suppliers. Each of these 116 suppliers has supplied us with the information required in a Conflict Minerals Reporting Template (CMRT) authored by the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative, or EICC-GeSI, with an accounting of their conflict mineral Smelters or Refiners (SoRs). Each of these 116 suppliers is in receipt of our conflict minerals policy, and each has confirmed their understanding of its principles and their willingness to comply.
For our electronic manufacturing services, we performed an assessment of all 1,316 suppliers who provided us with gold, tin, tungsten or tantalum in 2015 and selected 262 suppliers for our 2015 Conflict Minerals Report based on (1) suppliers from whom we purchased greater than USD $6 million in purchase volume (which collectively accounted for 95% of our total purchase volume) and (2) suppliers whose conflict minerals are used in the services we provide to our top three customers.
Below are the results of our Reasonable Country of Origin Inquiry, or RCOI.
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Gold – Packaging and Materials Services
| 1. | During 2015, we purchased gold for our packaging and materials services from a total of 51 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on data we collected, we identified a total of 122 SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services. All 51 of our gold suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced gold during 2015, representing 100% of our total expenditure for gold during 2015 for our packaging and materials services. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 95 of the SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services are participants in at least one of (i) the Conflict-Free Smelter Program (CFSP) operated by the Conflict-Free Sourcing Initiative (CFSI), (ii) the Gold Industry—London Bullion Market Association (LBMA), or (iii) the Gold Industry— Responsible Jewellery Council (RJC). |
| 3. | The following table summarizes our RCOI results for gold purchased for our packaging and materials services in 2015. |
| Companies supplying gold for our packaging and materials services | Number | % |
| Companies from which we purchased gold | 51 | 100% |
| Companies that provided SoR source information | 51 | 100% |
| Companies that were not able to provide SoR source information | 0 | 0% |
| SoRs of gold for our packaging and materials services | ||
| SoRs from which we indirectly purchased gold | 122 | 100% |
| SoRs with Smelter ID, CFSI, LBMA or RJC Compliant | 82 | 67% |
| SoRs with Smelter ID, CFSI Active | 13 | 11% |
| SORs not involved in CFSP, LBMA or RJC | 27 | 22% |
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Gold – Electronic Manufacturing Services
| 1. | During 2015, we purchased gold for our electronic manufacturing services from a total of 182 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on data we collected, we identified 132 SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services. One-hundred eighty of our gold suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced gold during 2015. Two did not respond. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 97 of the SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services are participants in at least one of (i) the CFSP operated by the CFSI, (ii) the LBMA, or (iii) the RJC. |
| 3. | The following table summarizes our RCOI results for gold purchased for our electronic manufacturing services in 2015. |
| Companies supplying gold for our electronic manufacturing services | Number | % |
| Companies from which we purchased gold | 182 | 100% |
| Companies that provided SoR source information | 180 | 99% |
| Companies that were not able to provide SoR source information | 2 | 1% |
| SoRs of gold for our electronic manufacturing services | ||
| SoRs from which we indirectly purchased gold | 132 | 100% |
| SoRs with Smelter ID, CFSI, LBMA or RJC Compliant | 81 | 61% |
| SoRs with Smelter ID, CFSI Active | 16 | 12% |
| SORs not involved in CFSP, LBMA or RJC | 35 | 27% |
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Tin – Packaging and Materials Services
| 1. | During 2015, we purchased tin for our packaging and materials services from a total of 63 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified a total of 82 SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services. All 63 of our tin suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tin during 2015, representing 100% of our total expenditure for tin during 2015 for our packaging and materials services. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 66 of the SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI. |
| 3. | The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015. |
| Companies supplying tin for our packaging and materials services | Number | % |
| Companies from which we purchased tin | 63 | 100% |
| Companies that provided SoR source information | 63 | 100% |
| Companies that were not able to provide SoR source information | 0 | 0% |
| SoRs of tin for our packaging and materials services | ||
| SoRs from which we indirectly purchased tin | 82 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 57 | 70% |
| SoRs with Smelter ID, CFSI Active | 9 | 11% |
| SORs not involved in CFSP | 16 | 19% |
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Tin – Electronic Manufacturing Services
| 1. | During 2015, we purchased tin for our electronic manufacturing services from a total of 212 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified 96 SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015. Two-hundred ten of our tin suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tin during 2015. Two did not respond. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 68 of the SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI. |
| 3. | The following table summarizes our RCOI results for tin purchased for our electronic manufacturing services in 2015. |
| Companies supplying tin for our electronic manufacturing services | Number | % |
| Companies from which we purchased tin | 212 | 100% |
| Companies that provided SoR source information | 210 | 99% |
| Companies that were not able to provide SoR source information | 2 | 1% |
| SoRs of tin for our electronic manufacturing services | ||
| SoRs from which we indirectly purchased tin | 96 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 55 | 57% |
| SoRs with Smelter ID, CFSI Active | 13 | 14% |
| SORs not involved in CFSP | 28 | 29% |
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Tungsten – Packaging and Materials Services
| 1. | During 2015, we purchased tungsten for our packaging and materials services from a total of 4 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from a SoR or another third party. Based on data we collected, we identified 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015. Our 4 tungsten suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tungsten during 2015, representing 100% of our total expenditure for tungsten for our packaging and materials services during 2015. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, the 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015 are participants in the CFSP operated by CFSI or participants in the Tungsten Industry—Conflict Minerals Council, or TI-CMC. |
| 3. | The following table summarizes our RCOI results for tungsten purchased for our packaging and materials services in 2015. |
| Companies supplying tungsten for our packaging and materials services | Number | % |
| Companies from which we purchased tungsten | 4 | 100% |
| Companies that provided SoR source information | 4 | 100% |
| Companies that were not able to provide SoR source information | 0 | 0% |
| SoRs of tungsten for our packaging and materials services | ||
| SoRs from which we indirectly purchased tungsten | 5 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 5 | 100% |
| SoRs with Smelter ID, CFSI Active or TI-CMC Progressing | 0 | 0% |
| SoRs not involved in CFSP or TI-CMC | 0 | 0% |
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Tungsten – Electronic Manufacturing Services
| 1. | During 2015, we purchased tungsten for our electronic manufacturing services from a total of 119 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from SoRs or from other third parties. Based on data we collected, we identified 45 SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015. One hundred seventeen of our tungsten suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tungsten during 2015. Two did not reply. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 41 of the SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015 are participants in either the CFSP operated by the CFSI or the TI-CMC program. |
| 3. | The following table summarizes our RCOI results for tungsten purchased for our electronic manufacturing services in 2015. |
| Companies supplying tungsten for our electronic manufacturing services | Number | % |
| Companies from which we purchased tungsten | 119 | 100% |
| Companies that provided SoR source information | 117 | 98% |
| Companies that were not able to provide SoR source information | 2 | 2% |
| SoRs of tungsten for our electronic manufacturing services | ||
| SoRs from which we indirectly purchased tungsten | 45 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 29 | 64% |
| SoRs with Smelter ID, CFSI Active or TI-CMC Progressing | 12 | 27% |
| SoRs not involved in CFSP or TI-CMC | 4 | 9% |
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Tantalum – Packaging and Materials Services
| 1. | During 2015, we purchased tantalum for our packaging and materials services from a total of 2 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on data we collected, we identified a total of 2 SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services. All 2 of our tantalum suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tantalum during 2015, representing 100% of our total expenditure for tantalum during 2015 for our packaging and materials services. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 2 of the SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI. |
| 3. | The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015. |
| Companies supplying tantalum for our packaging and materials services | Number | % |
| Companies from which we purchased tantalum | 2 | 100% |
| Companies that provided SoR source information | 2 | 100% |
| Companies that were not able to provide SoR source information | 0 | 0% |
| SoRs of tantalum for our packaging and materials services | ||
| SoRs from which we indirectly purchased tantalum | 2 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 2 | 100% |
| SoRs with Smelter ID, CFSI Active | 0 | 0% |
| SORs not involved in CFSP | 0 | 0% |
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Tantalum – Electronic Manufacturing Services
| 1. | During 2015, we purchased tantalum for our electronic manufacturing services from a total of 89 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the data collected, we identified 49 SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015. Eighty-seven of our tantalum suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tantalum during 2015. Two did not reply. |
| 2. | Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 47 of the SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI. |
| 3. | The following table summarizes our RCOI results for tantalum purchased for our electronic manufacturing services in 2015. |
| Companies supplying tantalum for our electronic manufacturing services | Number | % |
| Companies from which we purchased tantalum | 89 | 100% |
| Companies that provided SoR source information | 87 | 98% |
| Companies that were not able to provide SoR source information | 2 | 2% |
| SoRs of tantalum for our electronic manufacturing services | ||
| SoRs from which we indirectly purchased tantalum | 49 | 100% |
| SoRs with Smelter ID, CFSI Compliant | 46 | 94% |
| SoRs with Smelter ID, CFSI Active | 1 | 2% |
| SORs not involved in CFSP | 2 | 4% |
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Part I. Due Diligence
Design of Due Diligence
ASE designed its due diligence measures to conform to the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, including the related supplements on tantalum, tin, tungsten, and gold.
Due Diligence Measures Performed
| OECD Step 1 | Establish strong company management systems |
A. Adopt and clearly communicate to suppliers and public
| TheASE Group Corporate Policy for Sourcing Conflict Minerals is posted on our website (and attached here as Annex A) as well as distributed to each of our suppliers of conflict minerals who must agree in writing that the policy will be complied with.
Additionally, we require each supplier to certify they understand our conflict minerals policy and will comply with its covenants.
Finally, every factory manager must certify they comply with our conflict minerals policy. They are also responsible for communicating the policy throughout their organizations and implementing procedures to ensure compliance. |
B. Structure internal management to support due diligence
| Our conflict minerals management team is a comprehensive cross-functional team under the direction of our Chief Operating Officer. The team provides planning, analysis, management, tracking, monitoring and communication for the business wide initiative. They hold regular and frequent meetings to ensure progress against requirements. |
C. Establish a system of controls and transparency over the mineral supply chain
| Conflict minerals procedures are documented in our specifications system and managed by our quality control organization. The bills-of-materials required for different customer products across all manufacturing operations are controlled by our manufacturing execution system software.
The primary method for gathering conflict mineral data is through the deployment and gathering of Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Templates (CMRTs). We store this data on a comprehensive filing system and maintain other related records for a minimum of five years.
Aligned with industry practice, we designed a conflict minerals data tool with simple functions that manages large number of supplier CMRTs, auto-validates smelter status with real-time CFSI smelter list and aggregates smelter reporting for our customers. |
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D. Strengthen company engagement with suppliers
| In addition to formal written documentation, ASE is building person-to-person links between employees and suppliers to improve the quality and consistency of vendor communications.
We held an annual supplier seminar to announce new requirements, and provided training to suppliers to enable them to better understand how to set up their conflict minerals monitoring mechanism and to improve smelter data quality.
We amended and added conflict minerals terms to ourASE Group Purchase Order pursuant to which our suppliers agree (i) to use industry standard efforts to ensure that gold, tantalum, tungsten and tin in materials covered by the purchase order and sourced from mines in the Democratic Republic of the Congo or its adjacent regions do not directly or indirectly finance illegal militia in the Democratic Republic of the Congo or its adjacent regions, (ii) to promptly notify us if any materials covered by the purchase order do contain conflict minerals that are not DRC Conflict Free and to provide a report on the mine and/or smelter of origin of the conflict minerals and the related chain of custody and (iii) to only supply us with materials that contain DRC Conflict Free minerals sourced from certified DRC Conflict Free smelter and refinery programs. |
| E. Establish grievance mechanism | ASE encourages suppliers and employees to have open and honest dialog on issues of mutual interest.
We provide two email addresses (ASE_CM@aseglobal.com andconflictminerals@ms.usi.com.tw) for general surveys, inquiries and grievances regarding our conflict minerals program. |
| OECD Step 2 | Identify and assess risk in the supply chain |
A. Identify risks in the supply chain
| Our process for identifying conflict minerals risk in the supply chain is as follows:
(a) Identify all direct materials and components in the supply chain that contain conflict minerals.
(b) Identify suppliers of materials and components that contain conflict minerals.
(c) Gather CMRTs from our suppliers of conflict minerals.
(d) Depending on the enormity and complexity of the supply chain:
· Assess the value of the annual purchase volume of all conflict minerals.
· Prioritize conflict mineral sources by dollar volume to leverage impact from available analytical resources. |
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| B. Assess risks of adverse impacts | (a) Assess data gathered on templates to identify potential inconsistencies or “red flags.”
(b) Define annual supplier risk criteria.
(c) Carry out on-site or document audit for suppliers determined as at-risk suppliers according to the risk criteria.
(d) Follow up as appropriate to resolve items of concern. |
| OECD Step 3 | Design and implement a strategy to respond to identified risks |
| A. Report finding to designated senior management | Periodic reviews are held among team members and with senior management to ensure they are aware of current conflict minerals compliance status. |
B. Devise and adopt a risk management plan
| In 2015, we compared supplier smelter data to CFSI RCOI data (when available) to identify actual smelter origins.
We used a corporate standard conflict minerals audit checklist and implemented an on-site or document audit process to validate suppliers’ mechanisms related to important aspects of conflict minerals management. |
C. Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management
| Our packaging and materials services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers. (b) For compliance year 2015, we received CMRTs from 100% of our conflict mineral suppliers.
Our electronic manufacturing services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers. (b) For compliance year 2015, our electronic manufacturing services identified 262 suppliers that accounted for 95% of our total purchase volume and whose conflict minerals are used in the services we provide to our top 3 customers; we received CMRTs from 99.2% of these conflict mineral suppliers. |
| D. Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of | We have begun supplier audits to assess the accuracy of data and statements made by larger suppliers. This program will be broadened over time.
As a member (code: ASEG) of the EICC and CFSI, RCOI data is accessible |
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| circumstances | to use and to manage our supplier smelter data. |
| OECD Step 4 | Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain |
For CY 2015, ASE has undertaken an Independent Private Sector Audit (IPSA) of our Conflict Minerals Report in compliance with the requirements set forth in the SEC Conflict Minerals Final Rule and subsequent SEC Guidance.
In addition, as a member of CFSI, we leverage the due diligence conducted on smelters by the CFSP which uses independent third-party auditors to audit the source of the conflict minerals used by smelters.
| |
| OECD Step 5 | Report on supply chain due diligence. |
| ASE filed a Form SD and Conflict Minerals Report for Compliance Year 2015 with the US Securities and Exchange Commission on or before the May 31, 2016 deadline in compliance with the SEC Conflict Minerals Final Rule and subsequent guidance. |
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Part II. Due Diligence Determination and Product Declaration
Product Declaration
Our RCOI results did not provide us a sufficient level of confidence to enable us to report that all our products are conflict-free. Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, we therefore conducted additional due diligence on the source and chain of custody of the necessary conflict minerals in our products in order to obtain reasonable and reliable evidence that thegold, tin, tungsten or tantalum used by us in 2015 either (i) did not directly or indirectly benefit violent organizations inthe Democratic Republic of the Congo or adjacent regions or (ii) came from recycled or scrap sources.
Based on our RCOI analysis and due diligence measures described in this report, we made the following product determinations.
Packaging and Materials Services:
We reasonably believe that the identified SoRs used in all our packaging and materials services products are DRC Conflict-Free.
Electronic Manufacturing Services:
We reasonably believe that the identified SoRs used in our System in Module and System in Package products are DRC Conflict-Free. And all other products from our electronic manufacturing services are DRC Conflict Undeterminable.
Glossary
A glossary of abbreviations and terms is included in Annex C.
Facilities used to Process Conflict Minerals
A list of Smelters and Refiners that sourced conflict minerals utilized in our services is provided in Annex D.
Conflict Minerals Country of Origin
A list of countries where conflict minerals were mined or extracted is listed in Annex E. These minerals may have been smelted or refined in the country of extraction or in facilities around the world.
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Part III – Future Due Diligence Improvements
ŸSet conflict minerals requirements for new suppliers. Beginning from 2016, we have required new suppliers to first agree to submit a CMRT and a representation letter confirming that they are in compliance with ASE’s conflict minerals policy and requirements.
ŸWork with tier 1 suppliers to ensure that smelters are actively participating or progressing toward CFSP listing or otherThirdParty Audit Programs.
ŸAssess suppliers’ due diligence processes through on-site audits so as to assist suppliers to build up and improve their internal management systems.
Ÿ Enhance our conflict minerals data tool with advanced management and analysis functionalities.
Ÿ Annually hold supplier seminars to assist suppliers with their conflict minerals programs.
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Part IV – Independent Private Sector Audit
We obtained an independent private sector audit by KPMG. This report is set forth in Annex B.
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Annex A – ASE Group Corporate Policy for Sourcing Conflict Minerals
The mining and distribution of “conflict minerals”1originating from the Democratic Republic of the Congo are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Group is dedicated to the elimination of these conflict minerals in our supply chain, and to use only conflict-free minerals2responsibly sourced around the world. It is also our objective to support the continued use of conflict-free minerals from the DRC and the adjacent regions such that responsible mining is not diminished.
All suppliers to ASE Group must support this policy by:
| (a) | Being diligent in their assessment and validation of their supply chains to ensure ASE Group’s objectives of a transparent supply chain and conflict-free purchases are inputs to the services and products we produce. |
| (b) | Be in compliance at all times with all regional and international regulations for conflict minerals. |
| (c) | Be in compliance at all times with industry standards for the sourcing and reporting of conflict minerals. |
| (d) | Being diligent and accurate in their formal assurances of conflict-free minerals provided to us. |
1Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in the Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934.
2 Conflict-free minerals are conflict minerals that through their distribution directly or indirectly do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions.
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Annex B –Independent Accountants’ Report
Independent Accountants’ Report
To the Board of Directors and Shareholders of Advanced Semiconductor Engineering Inc.:
We have examined:
| • | whether the design of Advanced Semiconductor Engineering Inc. (the “Company”) due diligence framework as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2015 (the “Conflict Minerals Report”), is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-operation and DevelopmentDueDiligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affectedand High-RiskAreas, Second Edition 2013 (“OECD Due Diligence Guidance”), and |
| • | whether the Company’s description of the due diligence measures it performed, as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook. |
Management from the Company is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination.
Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained inGovernment AuditingStandards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.
Our examination was not conducted for the purpose of evaluating:
| Ÿ | The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance; |
| Ÿ | The completeness of the Company’s description of the due diligence measures performed; |
| Ÿ | The suitability of the design or operating effectiveness of the Company’s due diligence process; |
| Ÿ | Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance; |
| Ÿ | The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or |
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| Ÿ | The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products. |
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the section titled “Part I. Due Diligence.”
In our opinion,
| • | the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2015, as set forth in the Company’s Conflict Minerals Report,is in conformity, in all material respects, with the OECD Due Diligence Guidance, and |
| • | the Company’s description of the due diligence measures it performed for the reporting period from January 1 to December 31, 2015 as set forth in its Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook. |
/s/ KPMG
Taipei, Taiwan ( the Republic of China)
May 31, 2016
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Annex C – Glossary
| Term | Explanation |
| ASE | Advanced Semiconductor Engineering, Inc. |
| CFSI | Conflict Free Sourcing Initiative |
| CFSP | Conflict Free Smelter Program |
| DRC Conflict Free | DRC Conflict-free minerals are conflict minerals that, through their mining or distribution, directly or indirectly, do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions. |
| EICC | Electronic Industry Citizenship Coalition |
| GeSI | Global eSustainability Initiative |
| OECD | Organisation for Economic Co-operation and Development |
| LBMA | London Bullion Market Association |
| RCOI | Reasonable Country of Origin Inquiry |
| RJC | Responsible Jewellery Council |
| SoR | Smelter or Refiner |
| TI-CMC | Tungsten Industry—Conflict Minerals Council |
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Annex D – Smelter List
| Material | CFSI ID | Smelter or Refiner Name | SoR Country Location |
| Gold | CID001754 | Accurate Refining Group | UNITED STATES |
| Gold | CID000015 | Advanced Chemical Company | UNITED STATES |
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | CID000028 | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
| Gold | CID002560 | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | CID000035 | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | CID000058 | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| Gold | CID001947 | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | CHINA |
| Gold | CID000077 | Argor-Heraeus SA | SWITZERLAND |
| Gold | CID000082 | Asahi Pretec Corporation | JAPAN |
| Gold | CID000924 | Asahi Refining Canada Limited | CANADA |
| Gold | CID000920 | Asahi Refining USA Inc. | UNITED STATES |
| Gold | CID000090 | Asaka Riken Co., Ltd. | JAPAN |
| Gold | CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | CID000113 | Aurubis AG | GERMANY |
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | CID000141 | Bauer Walser AG | GERMANY |
| Gold | CID000157 | Boliden AB | SWEDEN |
| Gold | CID000176 | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CID000180 | Caridad | MEXICO |
| Gold | CID000185 | CCR Refinery – Glencore Canada Corporation | CANADA |
| Gold | CID000189 | Cendres + Métaux S.A. | SWITZERLAND |
| Gold | CID000197 | CHALCO Yunnan Copper Co. Ltd. | CHINA |
| Gold | CID000233 | Chimet S.p.A. | ITALY |
| Gold | CID000242 | China National Gold Group Corporation | CHINA |
| Gold | CID000264 | Chugai Mining | JAPAN |
| Gold | CID000288 | Colt Refining | UNITED STATES |
| Gold | CID000328 | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID000333 | DaeryongENC | KOREA, REPUBLIC OF |
| Gold | CID000343 | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | CID000362 | DODUCO GmbH | GERMANY |
| Gold | CID000401 | Dowa | JAPAN |
| Gold | CID000359 | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | CID000425 | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | CID001322 | Elemetal Refining, LLC | UNITED STATES |
22
| Gold | CID002561 | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | CID002355 | Faggi Enrico S.p.A. | ITALY |
| Gold | CID002515 | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | CID000522 | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | CID002459 | Geib Refining Corporation | UNITED STATES |
| Gold | CID001909 | Great Wall Precious Metals Co,. LTD. | CHINA |
| Gold | CID002312 | Guangdong Gaoyao Co | CHINA |
| Gold | CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | CID000694 | Heimerle + Meule GmbH | GERMANY |
| Gold | CID000707 | Heraeus Ltd. Hong Kong | CHINA |
| Gold | CID000711 | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | CID000767 | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
| Gold | CID000778 | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | CID000814 | Istanbul Gold Refinery | TURKEY |
| Gold | CID000823 | Japan Mint | JAPAN |
| Gold | CID000855 | Jiangxi Copper Company Limited | CHINA |
| Gold | CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | CID000929 | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | CID002563 | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | CID000956 | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | CID000957 | Kazzinc | KAZAKHSTAN |
| Gold | CID000969 | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | CID002511 | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | CID000988 | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID002605 | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID001029 | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | CID001032 | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | CID001056 | Lingbao Gold Company Limited | CHINA |
| Gold | CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | CID001078 | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | CID001113 | Materion | UNITED STATES |
| Gold | CID001119 | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | CID002821 | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | CHINA |
23
| Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | CID001153 | Metalor Technologies SA | SWITZERLAND |
| Gold | CID001157 | Metalor USA Refining Corporation | UNITED STATES |
| Gold | CID001161 | Metalurgica Met-Mex Penoles, S.A. DE C.V. | MEXICO |
| Gold | CID001188 | Mitsubishi Materials Corporation | JAPAN |
| Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | CID002282 | Morris and Watson | NEW ZEALAND |
| Gold | CID001204 | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | CID001236 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | CID001259 | Nihon Material Co., Ltd. | JAPAN |
| Gold | CID002779 | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | CID001328 | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | CID001326 | OJSC Krastvetmet | RUSSIAN FEDERATION |
| Gold | CID000493 | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | CID001352 | PAMP SA | SWITZERLAND |
| Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | CID001498 | PX Précinox SA | SWITZERLAND |
| Gold | CID001512 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | CID002510 | Republic Metals Corporation | UNITED STATES |
| Gold | CID001534 | Royal Canadian Mint | CANADA |
| Gold | CID001546 | Sabin Metal Corp. | UNITED STATES |
| Gold | CID001555 | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | CID001562 | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
| Gold | CID002777 | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | CID001573 | Schöne Edelmetaal B.V. | NETHERLANDS |
| Gold | CID001585 | SEMPSA Joyería Platería SA | SPAIN |
| Gold | CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | CID002516 | Singway Technology Co., Ltd. | TAIWAN |
| Gold | CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | CID001761 | Solar Applied Materials Technology Corp. | TAIWAN |
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | CID002580 | T.C.A S.p.A | ITALY |
24
| Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | CID001916 | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | CID001955 | Torecom | KOREA, REPUBLIC OF |
| Gold | CID001977 | Umicore Brasil Ltda. | BRAZIL |
| Gold | CID002314 | Umicore Precious Metals Thailand | THAILAND |
| Gold | CID001980 | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | CID001993 | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | CID002003 | Valcambi SA | SWITZERLAND |
| Gold | CID002030 | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | CID002778 | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | CID002100 | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | CID000651 | Yantai NUS Safina tech environmental Refinery Co. Ltd. | CHINA |
| Gold | CID002129 | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | CID002243 | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Gold | Changshu Minfeng Electroplate Co., LTd (C2.C4 Workshop) | CHINA | |
| Gold | The Hutti Gold Mines | INDIA | |
| Gold | Yidong Electronic (Changshu) Co., Ltd. | CHINA | |
| Tantalum | CID002705 | Avon Specialty Metals Ltd | UNITED KINGDOM |
| Tantalum | CID000211 | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | CID000291 | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | CID002504 | D-Block Metals, LLC | UNITED STATES |
| Tantalum | CID000410 | Duoluoshan | CHINA |
| Tantalum | CID000456 | Exotech Inc. | UNITED STATES |
| Tantalum | CID000460 | F & X Electro-Materials Limited | CHINA |
| Tantalum | CID002505 | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | CID002558 | Global Advanced Metals Aizu | JAPAN |
| Tantalum | CID002557 | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | CID000616 | Guandong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | CID002501 | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
| Tantalum | CID002544 | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | CID002545 | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | CID002546 | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | CID002547 | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | CID002548 | H.C. Starck Inc. | UNITED STATES |
| Tantalum | CID002549 | H.C. Starck Ltd. | JAPAN |
25
| Tantalum | CID002550 | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | CID000731 | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
| Tantalum | CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | CID002539 | KEMET Blue Metals | MEXICO |
| Tantalum | CID002568 | KEMET Blue Powder | UNITED STATES |
| Tantalum | CID000973 | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | CID001076 | LSM Brasil S.A. | BRAZIL |
| Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | CID001175 | Mineração Taboca S.A. | BRAZIL |
| Tantalum | CID001192 | Mitsui Mining & Smelting | JAPAN |
| Tantalum | CID001200 | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | CID002540 | Plansee SE Liezen | AUSTRIA |
| Tantalum | CID002556 | Plansee SE Reutte | AUSTRIA |
| Tantalum | CID001508 | QuantumClean | UNITED STATES |
| Tantalum | CID002707 | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | CID001522 | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | CID001634 | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | CID001769 | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | CID001869 | Taki Chemical | JAPAN |
| Tantalum | CID001879 | Tantalite Resources | SOUTH AFRICA |
| Tantalum | CID001891 | Telex Metals | UNITED STATES |
| Tantalum | CID002571 | Tranzact, Inc. | UNITED STATES |
| Tantalum | CID001969 | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | CID002307 | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | CID002232 | Zhuzhou Cemented Carbide | CHINA |
| Tin | CID000292 | Alpha | UNITED STATES |
| Tin | CID002825 | An Thai Minerals Co., Ltd. | VIET NAM |
| Tin | CID002703 | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | CID001070 | China Tin Group Co., Ltd. | CHINA |
| Tin | CID000278 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | CID000295 | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | CID002570 | CV Ayi Jaya | INDONESIA |
| Tin | CID002592 | CV Dua Sekawan | INDONESIA |
| Tin | CID000306 | CV Gita Pesona | INDONESIA |
26
| Tin | CID000308 | CV Makmur Jaya | INDONESIA |
| Tin | CID000313 | CV Serumpun Sebalai | INDONESIA |
| Tin | CID000315 | CV United Smelting | INDONESIA |
| Tin | CID002455 | CV Venus Inti Perkasa | INDONESIA |
| Tin | CID000402 | Dowa | JAPAN |
| Tin | CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | CID002774 | Elmet S.L.U (Metallo Group) | SPAIN |
| Tin | CID000438 | EM Vinto | BOLIVIA |
| Tin | CID000448 | Estanho de Rondônia S.A. | BRAZIL |
| Tin | CID000466 | Feinhütte Halsbrücke GmbH | GERMANY |
| Tin | CID000468 | Fenix Metals | POLAND |
| Tin | CID001305 | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
| Tin | CID000942 | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | CID000555 | Gejiu Zi-Li | CHINA |
| Tin | CID000760 | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | CID000244 | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | CID000864 | Jiangxi Nanshan | CHINA |
| Tin | CID001063 | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
| Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | CID001105 | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | CID002500 | Melt Metais e Ligas S/A | BRAZIL |
| Tin | CID001136 | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | CID001142 | Metallic Resources, Inc. | UNITED STATES |
| Tin | CID001143 | Metallo Chimique | BELGIUM |
| Tin | CID002773 | Metallo-Chemique N.V. | BELGIUM |
| Tin | CID001173 | Mineração Taboca S.A. | BRAZIL |
| Tin | CID001179 | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
| Tin | CID001182 | Minsur | PERU |
| Tin | CID001191 | Mitsubishi Materials Corporation | JAPAN |
| Tin | CID001231 | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| Tin | CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | CID001337 | Operaciones Metalurgical S.A. | BOLIVIA |
| Tin | CID002507 | Phoenix Metal Ltd. | RWANDA |
| Tin | CID001393 | PT Alam Lestari Kencana | INDONESIA |
| Tin | CID000309 | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | CID001399 | PT Artha Cipta Langgeng | INDONESIA |
| Tin | CID002503 | PT ATD Makmur Mandiri Jaya | INDONESIA |
27
| Tin | CID001402 | PT Babel Inti Perkasa | INDONESIA |
| Tin | CID001409 | PT Bangka Kudai Tin | INDONESIA |
| Tin | CID002776 | PT Bangka Prima Tin | INDONESIA |
| Tin | CID001412 | PT Bangka Putra Karya | INDONESIA |
| Tin | CID001416 | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | CID001419 | PT Bangka Tin Industry | INDONESIA |
| Tin | CID001421 | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | CID001424 | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | CID001428 | PT Bukit Timah | INDONESIA |
| Tin | CID002696 | PT Cipta Persada Mulia | INDONESIA |
| Tin | CID001434 | PT DS Jaya Abadi | INDONESIA |
| Tin | CID001438 | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | CID001442 | PT Fang Di MulTindo | INDONESIA |
| Tin | CID002530 | PT Inti Stania Prima | INDONESIA |
| Tin | CID000307 | PT Justindo | INDONESIA |
| Tin | CID001448 | PT Karimun Mining | INDONESIA |
| Tin | CID001449 | PT Koba Tin | INDONESIA |
| Tin | CID001453 | PT Mitra Stania Prima | INDONESIA |
| Tin | CID001457 | PT Panca Mega Persada | INDONESIA |
| Tin | CID001486 | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | CID001458 | PT Prima Timah Utama | INDONESIA |
| Tin | CID001460 | PT Refined Bangka Tin | INDONESIA |
| Tin | CID001463 | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | CID001466 | PT Seirama Tin Investment | INDONESIA |
| Tin | CID001468 | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | CID002816 | PT Sukses Inti Makmur | INDONESIA |
| Tin | CID001471 | PT Sumber Jaya Indah | INDONESIA |
| Tin | CID001476 | PT Supra Sukses Trinusa | INDONESIA |
| Tin | CID001477 | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | CID001482 | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | CID001490 | PT Tinindo Inter Nusa | INDONESIA |
| Tin | CID002478 | PT Tirus Putra Mandiri | INDONESIA |
| Tin | CID001493 | PT Tommy Utama | INDONESIA |
| Tin | CID002479 | PT Wahana Perkit Jaya | INDONESIA |
| Tin | CID002706 | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | CID001539 | Rui Da Hung | TAIWAN |
| Tin | CID001758 | Soft Metais Ltda. | BRAZIL |
| Tin | CID001898 | Thaisarco | THAILAND |
| Tin | CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | CID002015 | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | CID002036 | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
28
| Tin | CID002180 | Yunnan Tin Company Limited | CHINA |
| Tin | Gejiu Jinye Mineral Co., Ltd. | CHINA | |
| Tin | Kunshang Shing Lee Soldering Manufacture Co., Ltd. | CHINA | |
| Tin | Super Ligas | BRAZIL | |
| Tin | Tatcang Huaxia Electoplating Co., Ltd. | CHINA | |
| Tin | Xianghualing Tin Industry Co., Ltd. | CHINA | |
| Tungsten | CID000004 | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | CID002502 | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | CID002513 | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002518 | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | CID000345 | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | CID000499 | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002531 | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | CID000875 | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | CID002536 | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | CID000568 | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002541 | H.C. Starck GmbH | GERMANY |
| Tungsten | CID002542 | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | CID000766 | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | CID002579 | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | CID002578 | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
| Tungsten | CID000769 | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | CID002649 | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | CID000825 | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | CID000868 | Jiangxi Rare Metals Tungsten Holding Group Co., Ltd. | CHINA |
| Tungsten | CID002493 | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | CID002535 | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
29
| Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | CID000105 | Kennametal Huntsville | UNITED STATES |
| Tungsten | CID000966 | Kennametal Inc. | UNITED STATES |
| Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002589 | Niagara Refining LLC | UNITED STATES |
| Tungsten | CID002543 | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | CID002538 | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | CID001889 | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | CID002011 | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | CID002044 | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | CID002047 | Wolfram Company CJSC | RUSSIAN FEDERATION |
| Tungsten | CID002532 | Wolfram Company CJSC | RUSSIAN FEDERATION |
| Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002095 | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
30
Annex E – Countries of Origin of Conflict Minerals
It is likely that we used conflict minerals from many of the following sources as well as some that are not identified.
| Angola | Argentina | Australia | Austria |
| Belgium | Bolivia | Brazil | Burundi |
| Cambodia | Canada | Central African Republic | Chile |
| China | Colombia | Côte D'Ivoire | Czech Republic |
| Democratic Republic of the Congo | Djibouti | Ecuador | Egypt |
| Estonia | Ethiopia | France | Germany |
| Guyana | Hungary | India | Indonesia |
| Ireland | Israel | Japan | Kazakhstan |
| Kenya | Laos | Luxembourg | Madagascar |
| Malaysia | Mongolia | Mozambique | Myanmar |
| Namibia | Netherlands | Nigeria | Peru |
| Portugal | Republic of Congo | Russia | Rwanda |
| Sierra Leone | Singapore | Slovakia | South Africa |
| South Korea | South Sudan | Spain | Suriname |
| Switzerland | Taiwan | Tanzania | Thailand |
| Uganda | United Kingdom | United States of America | Vietnam |
| Zambia | Zimbabwe | Recycle/Scrap |
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