Exhibit 1.01
CONFLICT MINERALS REPORT
OVERVIEW
This report for the reporting period from January 1, 2015 to December 31, 2015 has been prepared by SYNNEX Corporation (the “Company,” “we,” “us” or “our”) pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
We are a business process services company offering a comprehensive range of services to resellers, retailers, original equipment manufacturers, financial and insurance institutions and several other industry verticals worldwide. We operate in two segments: Technology Solutions and Concentrix. Our Technology Solutions segment distributes peripherals, information technology systems (including data center server and storage solutions), system components, software, networking equipment, consumer electronics, and complementary products. Within the Technology Solutions segment, our distribution services are complemented by systems design and integration services. Our Concentrix segment offers a range of global business outsourcing services around process optimization, customer engagement strategy and back office automation to customers in various industry verticals. Our revenues for 2015 largely were from distribution and global business services that were not in-scope for purposes of our compliance with the Conflict Minerals Rule.
PRODUCT SCOPING; REASONABLE COUNTRY OF ORIGIN INQUIRY; DUE DILIGENCE DETERMINATION
A portion of the systems design and integration business within our Technology Solutions segment involved our manufacture, through assembly or integration, of data center servers and storage products. 3TG were necessary to the functionality or production of these manufactured products. Accordingly, these products were in-scope for purposes of our compliance with the Conflict Minerals Rule. Taken as a whole, our in-scope products contained all four 3TG, but each individual product did not contain all four 3TG.
We purchase only finished components and do not purchase 3TG directly from any smelter, refiner or mine. We have relationships with an extensive network of suppliers throughout the world, and we believe that there are generally multiple tiers between the mines, smelters, refiners and our direct suppliers. Therefore, we have
requested our direct suppliers to work with their upstream suppliers so that they may provide us with information about the origin of 3TG in the components we purchase for inclusion in the products that we manufacture.
To determine whether any of the 3TG in the components contained in our data center servers and storage products originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or were from recycled or scrap sources, we conducted a reasonable country of origin inquiry (“RCOI”) within the meaning of the Conflict Minerals Rule, requesting that suppliers of the components we included in our manufactured products for 2015 complete the Conflict-Free Sourcing Initiative (“CFSI”) Conflict Minerals Reporting Template (“CMRT”), which includes questions regarding identified smelters and refiners in the supplier’s supply chain and the supplier’s compliance procedures. We determined that requesting that our suppliers complete the CMRT represented our reasonable best efforts to determine the mines or locations of origin of 3TG in our supply chain. We used a third-party consultant to assist in our supplier outreach and follow-up. Our RCOI utilized the processes and procedures contemplated by Steps 1 and 2 of the OECD Guidance (as defined below). Selected elements of those steps are discussed under “Due Diligence.”
Most of the suppliers that completed CMRTs provided data at the company level, with a small minority reporting at a level specific to the components that we purchased from them. Some suppliers indicated that 3TG contained in their components were not sourced from the Covered Countries, and some suppliers indicated that their products contain minerals sourced from the Covered Countries but from smelters which were certified as compliant by an independent third party. There were also suppliers that indicated they used some recycled or scrap 3TG content in the types of components they sell.
After conducting an RCOI and exercising the due diligence described in this Conflict Minerals Report, as applicable, and in light of the limited information specific to our products provided to us by our suppliers, we concluded for 2015 that each of our data center servers and storage products contained 3TG of undetermined origin. Based on the information provided by the suppliers that completed CMRTs, we believe that the facilities that may have been used to process necessary 3TG contained in our in-scope products include the smelters and refiners listed in the Annex at the end of this Conflict Minerals Report and we believe that the countries of origin of the 3TG contained in such products may include the countries listed in the Annex. We endeavored to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the suppliers provide us with a completed CMRT and through the other procedures followed by us and the third party consultant that are described in this Conflict Minerals Report.
DUE DILIGENCE
Our due diligence measures have been designed to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development in the publication OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
(Second Edition, 2013), including the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Our implementation of the OECD Guidance in respect of 2015 is discussed below, but these were not all of the discrete measures that we took in furtherance of our conflict minerals policy (which is discussed below) or pursuant to the Conflict Minerals Rule and the OECD Guidance.
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| 1. | Establish Strong Company Management Systems |
We have a management system to support supply chain due diligence related to 3TG. Our management system included a team of subject matter experts from legal, finance, product management, and sales. The team of subject matter experts was responsible for managing our 3TG compliance strategy and was led by our Senior Vice President, General Counsel and Corporate Secretary, and our President, Hyve Solutions Corporation. We also retained specialist outside counsel and a 3TG consultant to assist us with our compliance efforts. Some of our activities described in this Conflict Minerals Report were performed on our behalf by the consultant.
We used the CMRT to identify smelters and refiners that were possibly in our supply chain. We maintain business records relating to 3TG due diligence in respect of 2015, including records of due diligence processes, findings and resulting decisions, on a computerized database, and relevant materials are preserved for appropriate periods consistent with the OECD Guidance.
We have a conflict minerals policy, which is available on our website at http://ir.synnex.com/corporate-governance-document.cfm (the “Conflict Minerals Policy”). The Conflict Minerals Policy sets forth our expectation that the suppliers in our supply chain procure 3TG responsibly and avoid sourcing that funds armed conflict contributing to the crisis in the Covered Countries. Our Conflict Minerals Policy also sets forth our expectation that our suppliers facilitate our efforts at supply chain transparency by providing us with appropriate information when we request and conducting necessary due diligence to identify smelters, refiners, and/or mines from which the 3TG in their respective supply chains originate. We have a public email address (conflictmineralsinquiries@synnex.com) available on our website for general inquiries and grievances regarding our 3TG program and sources of 3TG.
We do not support the embargo of 3TG from the Covered Countries.
To further our efforts in identifying and assessing 3TG sourcing risks in our supply chain, we have included a 3TG flow-down clause in new supplier contracts that requires suppliers to provide us with information about the source of 3TG.
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| 2. | Identify and Assess Risks in the Supply Chain |
To determine whether any of the necessary 3TG contained in our data center servers and storage products originated in the Covered Countries, we requested that direct suppliers of the components we used in the
assembly or integration of the data center servers and storage products complete the CMRT. We requested our suppliers’ cooperation in gathering information from their respective suppliers and ultimately from smelters and refiners in the supply chain. Our consultant assisted us in our supplier outreach, in tracking supplier communications, educating suppliers regarding the CMRT and 3TG generally, and assessing risk in and quality of supplier responses. Our consultant followed up with nonresponsive suppliers through its software tool and by direct telephone or e-mail communications by its personnel.
We reviewed the completed responses received from our suppliers. Our consultant followed up with any supplier that submitted a response containing errors or inaccuracies pertinent to our assessment or that otherwise provided a written response determined not to be suitable to us. To the extent that a completed response identified a smelter or refiner, our consultant reviewed that information against the Smelter Reference List tab of the CMRT and the list of compliant smelters and refiners published by the CFSI. We also consulted other publicly available information to determine if the listed entity is a smelter or refiner. We also used the CMRT responses to review our direct suppliers’ due diligence activities, such as whether they had a conflict minerals policy and required their own suppliers to source from processing facilities validated by an independent audit.
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| 3. | Design and Implement a Strategy to Respond to Identified Risks |
Senior management was briefed about our due diligence efforts. We developed a risk management plan that outlines our responses in general terms to identified risks.
We intend to take the additional steps discussed under “Additional Risk Mitigation Efforts” to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups.
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| 4. | Carry Out Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
In connection with our due diligence, we utilized information made available by the CFSI concerning independent third-party audits of smelters and refiners. We do not have a direct relationship with any smelters or refiners and do not perform or direct audits of those entities within our supply chain.
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| 5. | Report on Supply Chain Due Diligence |
This Conflict Minerals Report and our Form SD, which constitute our annual report on our 3TG due diligence, are available on our website and are filed with the Securities and Exchange Commission. Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the 3TG in our products include the smelters and refiners listed in Annex A below.
ADDITIONAL RISK MITIGATION EFFORTS
We intend to take the following additional steps to improve the due diligence conducted to further mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups in the DRC and adjoining countries:
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| • | Request that suppliers send us, for the applicable calendar year or shorter period, CMRTs that are completed at the product level. |
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| • | Engage with suppliers and direct them to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
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| • | Engage in regular ongoing risk assessment through our suppliers’ submissions of 3TG data. |
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| Caution Concerning Forward-Looking Statements |
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| Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” and “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, such as our plans to improve the due diligence conducted to further mitigate the risk that the 3TG in our products benefit armed groups in the Covered Countries, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. These risks, uncertainties and changes include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political and regulatory developments, whether in the Covered Countries, the United States or elsewhere. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws. |
ANNEX
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
Smelters and Refiners(1)
The following list includes smelters and refiners in “product level” CMRTs that we received and may not include all of the smelters and refiners that processed 3TG in the products that we manufactured for 2015, as (i) the list contains only smelters and refiners confirmed as smelters and refiners by the CFSI, (ii) not all of our suppliers completed CMRTs, and (iii) many of the suppliers only identified a portion of the smelters and refiners in their supply chain.
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Gold | Advanced Chemical Company | United States | Active |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Compliant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Active |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil | Compliant |
| Gold | Argor-Heraeus SA | Switzerland | Compliant |
| Gold | Asahi Pretec Corporation | Japan | Compliant |
| Gold | Asaka Riken Co., Ltd. | Japan | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Reference List |
| Gold | Aurubis AG | Germany | Compliant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Compliant |
| Gold | Bauer Walser AG | Germany | Reference List |
| Gold | Boliden AB | Sweden | Compliant |
| Gold | C. Hafner GmbH + Co. KG | Germany | Compliant |
| Gold | Caridad | Mexico | Reference List |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Compliant |
| Gold | Cendres + Métaux SA | Switzerland | Active |
| Gold | Chimet S.p.A. | Italy | Compliant |
| Gold | Chugai Mining | Japan | Reference List |
| Gold | Daejin Indus Co., Ltd. | Republic of Korea | Active |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Reference List |
| Gold | Do Sung Corporation | Republic of Korea | Active |
| Gold | DODUCO GmbH | Germany | Compliant |
| Gold | Dowa | Japan | Compliant |
| Gold | Eco-System Recycling Co., Ltd. | Japan | Compliant |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China | Reference List |
| Gold | Guangdong Jinding Gold Limited | China | Reference List |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Reference List |
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Gold | Heimerle + Meule GmbH | Germany | Compliant |
| Gold | Heraeus Ltd. Hong Kong | China | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Compliant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | Reference List |
| Gold | Hwasung CJ Co., Ltd. | Republic of Korea | Reference List |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | Reference List |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Compliant |
| Gold | Istanbul Gold Refinery | Turkey | Compliant |
| Gold | Japan Mint | Japan | Compliant |
| Gold | Jiangxi Copper Company Limited | China | Compliant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Compliant |
| Gold | JSC Uralelectromed | Russian Federation | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Compliant |
| Gold | Kazzinc | Kazakhstan | Compliant |
| Gold | Kennecott Utah Copper LLC | United States | Compliant |
| Gold | Kojima Chemicals Co., Ltd. | Japan | Compliant |
| Gold | Korea Metal Co., Ltd. | Republic of Korea | Reference List |
| Gold | Kyrgyzaltyn JSC | Kyrgystan | Reference List |
| Gold | L' azurde Company For Jewelry | Saudi Arabia | Reference List |
| Gold | Lingbao Gold Company Limited | China | Reference List |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Reference List |
| Gold | LS-NIKKO Copper Inc. | Republic of Korea | Compliant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Reference List |
| Gold | Materion | United States | Compliant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Compliant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Compliant |
| Gold | Metalor Technologies SA | Switzerland | Compliant |
| Gold | Metalor USA Refining Corporation | United States | Compliant |
| Gold | Mitsubishi Materials Corporation | Japan | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | Compliant |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Active |
| Gold | Nihon Material Co., Ltd. | Japan | Compliant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Compliant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Compliant |
| Gold | OJSC Kolyma Refinery | Russian Federation | Reference List |
| Gold | OJSC Novosibirsk Refinery | Russian Federation | Compliant |
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Gold | PAMP SA | Switzerland | Compliant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Reference List |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Compliant |
| Gold | PX Précinox SA | Switzerland | Compliant |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Compliant |
| Gold | Republic Metals Corporation | United States | Compliant |
| Gold | Royal Canadian Mint | Canada | Compliant |
| Gold | Sabin Metal Corp. | United States | Reference List |
| Gold | Samduck Precious Metals | Republic of Korea | Active |
| Gold | SAMWON Metals Corp. | Republic of Korea | Reference List |
| Gold | Schone Edelmetaal B.V. | Netherlands | Compliant |
| Gold | SEMPSA Joyería Platería SA | Spain | Compliant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Reference List |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Compliant |
| Gold | Singway Technology Co., Ltd. | Taiwan | Compliant |
| Gold | So Accurate Group, Inc. | United States | Reference List |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Compliant |
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Compliant |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Compliant |
| Gold | T.C.A S.p.A | Italy | Compliant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Reference List |
| Gold | Torecom | Republic of Korea | Active |
| Gold | Umicore Brasil Ltda. | Brazil | Compliant |
| Gold | Umicore Precious Metals Thailand | Thailand | Compliant |
| Gold | Umicore SA Business Unit Precious Metals Refining | Belgium | Compliant |
| Gold | United Precious Metal Refining, Inc. | United States | Compliant |
| Gold | Valcambi SA | Switzerland | Compliant |
| Gold | Western Australian Mint trading as The Perth Mint | Australia | Compliant |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | Compliant |
| Gold | Yokohama Metal Co., Ltd. | Japan | Compliant |
| Gold | Yunnan Copper Industry Co., Ltd. | China | Reference List |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Compliant |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China | Compliant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | Compliant |
| Tantalum | D Block Metals, LLC | United States | Compliant |
| Tantalum | Duoluoshan | China | Compliant |
| Tantalum | Exotech Inc. | United States | Compliant |
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Tantalum | F&X Electro-Materials Ltd. | China | Compliant |
| Tantalum | FIR Metals & Resource Ltd. | China | Compliant |
| Tantalum | Global Advanced Metals Aizu | Japan | Compliant |
| Tantalum | Global Advanced Metals Boyertown | United States | Compliant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Compliant |
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Compliant |
| Tantalum | H.C. Starck GmbH Goslar | Germany | Compliant |
| Tantalum | H.C. Starck GmbH Laufenburg | Germany | Compliant |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Compliant |
| Tantalum | H.C. Starck Inc. | United States | Compliant |
| Tantalum | H.C. Starck Ltd. | Japan | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | Germany | Compliant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Compliant |
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States | Compliant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Compliant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | Compliant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Compliant |
| Tantalum | KEMET Blue Metals | Mexico | Compliant |
| Tantalum | KEMET Blue Powder | United States | Compliant |
| Tantalum | King-Tan Tantalum Industry Ltd. | China | Compliant |
| Tantalum | LSM Brasil S.A. | Brazil | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Compliant |
| Tantalum | Mineração Taboca S.A. | Brazil | Compliant |
| Tantalum | Mitsui Mining & Smelting | Japan | Compliant |
| Tantalum | Molycorp Silmet A.S. | Estonia | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Compliant |
| Tantalum | Plansee SE Liezen | Austria | Compliant |
| Tantalum | Plansee SE Reutte | Austria | Compliant |
| Tantalum | QuantumClean | United States | Compliant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | Compliant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Compliant |
| Tantalum | Taki Chemicals | Japan | Compliant |
| Tantalum | Telex Metals | United States | Compliant |
| Tantalum | Tranzact, Inc. | United States | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Compliant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Compliant |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | Compliant |
| Tantalum | Zhuzhou Cemented Carbide | China | Compliant |
| Tin | Alpha | United States | Compliant |
| Tin | China Tin Group Co., Ltd. | China | Compliant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | Reference List |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil | Compliant |
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Tin | CV Ayi Jaya | Indonesia | Compliant |
| Tin | CV Gita Pesona | Indonesia | Compliant |
| Tin | CV Serumpun Sebalai | Indonesia | Compliant |
| Tin | CV United Smelting | Indonesia | Compliant |
| Tin | CV Venus Inti Perkasa | Indonesia | Compliant |
| Tin | Dowa | Japan | Compliant |
| Tin | Elmet S.L.U. (Metallo Group) | Spain | Compliant |
| Tin | EM Vinto | Bolivia | Compliant |
| Tin | Estanho de Rondônia S.A. | Brazil | Reference List |
| Tin | Feinhütte Halsbrücke GmbH | Germany | Active |
| Tin | Fenix Metals | Poland | Compliant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Active |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Compliant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Reference List |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Reference List |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | Reference List |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | Compliant |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | China | Reference List |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Compliant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Compliant |
| Tin | Melt Metais e Ligas S/A | Brazil | Compliant |
| Tin | Metallic Resources, Inc. | United States | Compliant |
| Tin | Metallo-Chimique N.V. | Belgium | Compliant |
| Tin | Mineração Taboca S.A. | Brazil | Compliant |
| Tin | Minsur | Peru | Compliant |
| Tin | Mitsubishi Materials Corporation | Japan | Compliant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Compliant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Compliant |
| Tin | Operaciones Metalurgical S.A. | Bolivia | Compliant |
| Tin | PT Alam Lestari Kencana | Indonesia | Reference List |
| Tin | PT Aries Kencana Sejahtera | Indonesia | Compliant |
| Tin | PT Artha Cipta Langgeng | Indonesia | Compliant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Compliant |
| Tin | PT Babel Inti Perkasa | Indonesia | Compliant |
| Tin | PT Bangka Kudai Tin | Indonesia | Reference List |
| Tin | PT Bangka Prima Tin | Indonesia | Compliant |
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | Reference List |
| Tin | PT Bangka Tin Industry | Indonesia | Compliant |
| Tin | PT Belitung Industri Sejahtera | Indonesia | Compliant |
| Tin | PT BilliTin Makmur Lestari | Indonesia | Compliant |
| Tin | PT Bukit Timah | Indonesia | Compliant |
| Tin | PT Cipta Persada Mulia | Indonesia | Compliant |
| Tin | PT DS Jaya Abadi | Indonesia | Compliant |
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| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Compliant |
| Tin | PT Fang Di MulTindo | Indonesia | Reference List |
| Tin | PT Inti Stania Prima | Indonesia | Compliant |
| Tin | PT Justindo | Indonesia | Compliant |
| Tin | PT Karimun Mining | Indonesia | Active |
| Tin | PT Mitra Stania Prima | Indonesia | Compliant |
| Tin | PT Panca Mega Persada | Indonesia | Compliant |
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia | Reference List |
| Tin | PT Prima Timah Utama | Indonesia | Compliant |
| Tin | PT Refined Bangka Tin | Indonesia | Compliant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | Compliant |
| Tin | PT Seirama Tin Investment | Indonesia | Reference List |
| Tin | PT Stanindo Inti Perkasa | Indonesia | Compliant |
| Tin | PT Sukses Inti Makmur | Indonesia | Compliant |
| Tin | PT Sumber Jaya Indah | Indonesia | Compliant |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | Compliant |
| Tin | PT Tinindo Inter Nusa | Indonesia | Compliant |
| Tin | PT Wahana Perkit Jaya | Indonesia | Compliant |
| Tin | Resind Indústria e Comércio Ltda. | Brazil | Compliant |
| Tin | Rui Da Hung | Taiwan | Compliant |
| Tin | Soft Metais Ltda. | Brazil | Compliant |
| Tin | Thaisarco | Thailand | Compliant |
| Tin | VQB Mineral and Trading Group JSC | Vietnam | Compliant |
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | Compliant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Reference List |
| Tin | Yunnan Tin Group (Holding) Company Limited | China | Compliant |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | Compliant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam | Compliant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Compliant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | China | Active |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | Active |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | China | Reference List |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China | Active |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Global Tungsten & Powders Corp. | United States | Compliant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Compliant |
| Tungsten | H.C. Starck GmbH | Germany | Compliant |
|
| | | |
| Mineral | Smelter or Refiner Name | Country Location | Compliance Status as of 4/18/16 |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | Compliant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Compliant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Compliant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | Compliant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | Compliant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Active |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Reference List |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Active |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Active |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Active |
| Tungsten | Kennametal Fallon | United States | Active |
| Tungsten | Kennametal Huntsville | United States | Compliant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Niagara Refining LLC | United States | Compliant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | Compliant |
| Tungsten | Pobedit, JSC | Russian Federation | Active |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | Compliant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | Compliant |
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | Compliant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Compliant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | Compliant |
(1) We note the following in connection with the information contained in the foregoing table:
(a) All compliance status information in the table is as of April 18, 2016.
(b) “Compliant” means that a smelter or refiner was listed as compliant with the Conflict-Free Smelter Program’s (“CSFP”) assessment protocols, including through mutual recognition and those indicated as “Re-audit in process.” Included smelters and refiners were not necessarily Compliant for all or part of 2015 and may not continue to be Compliant for any future period. We do not have any information on the origin of the 3TG processed by any of the Compliant smelters and refiners prior to their respective compliance dates.
(c) “Active” means that the smelter or refiner was listed as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or, according to information published by the CFSI, the smelter has agreed to complete a CFSP validation audit within two years of membership issuance by the Tungsten Industry - Council Minerals Council.
(d) A smelter or refiner is listed as “Reference List” if it was not Compliant or Active.
(e) The compliance status indicated in the table is based solely on information made publicly available by the CFSI, LBMA and/or RJC, without independent verification by us.
(f) “Country Location” is the location of the smelter or refiner and is based solely on information made publicly available by the CFSI, without independent verification by us.
Country of Origin
The identified countries of origin of the 3TG processed by the Compliant smelters and refiners listed in the table above may have included the countries in the categories listed below. We have not been able to reliably determine the country of origin of the 3TG processed by any of the other smelters and refiners listed in the table. The countries below are categorized by risk.
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam and Zimbabwe.
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique and South Africa.
L3 - The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC - The Democratic Republic of the Congo.
In addition, some of the Compliant smelters and refiners may have sourced in whole or in part from recycled or scrap sources.
