Exhibit 1.01
NeoPhotonics Corporation
Conflict Minerals Report
For the reporting period from January 1, 2016 to December 31, 2016
This Conflict Minerals Report (this “Report”) of NeoPhotonics Corporation (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2016 to December 31, 2016. The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture a product and any mineral specified in the Rule is necessary for the functionality or production of such products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo and its adjoining countries, which include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary for the functionality or production of those products.
Description of the Company’s Products Covered by this Report
This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the calendar year 2016.
The Company is a leading provider of optical components, modules and subsystems based on PIC (photonic integrated circuit) technology that enable the delivery of video, voice and data over telecommunications, datacom, and cable TV networks. Our products, which are referred to in this Report collectively as the “Covered Products,” include electro-optical transceivers for telecom and datacom applications, optical semiconductor devices for amplication and modulation of optical signals, semiconductor lasers and laser assemblies for transmission and modulation of optical signals, passive optical devices for optical signal management, MEMS-based optical attenuation devices and optical receivers.
The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its direct suppliers to provide information regarding the origin of Conflict Minerals that are included in the Covered Products, including sources of Conflict Minerals that are supplied to them by sub-tier suppliers. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best suited to identify the sources of Conflict Minerals, and therefore has taken steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals in its Covered Products. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled scrap or scrap sources. In designing its reasonable country of origin inquiry, the Company employed a combination of measures, as described in this Report, to determine whether the Conflict Minerals in its Covered Products originated from the Covered Countries and, to the extent applicable, these measures were the same as the processes and procedures the Company used for its due diligence as described below, including in particular Step 1 and Step 2 below.
In connection with its reasonable country of origin inquiry, the Company has requested information regarding Conflict Minerals in its supply chain from all of the Company’s direct suppliers sourcing materials in the Company’s products, using the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (the “Conflict Minerals Survey”). During the course of the year, the Company also followed up with those suppliers who had not responded to the Company’s previous requests for completion of the Conflict Minerals Survey and who previously provided incomplete responses to the Conflict Minerals Survey.
Based on the results of its reasonable country of origin inquiry, the Company has reason to believe that, during the period covered by this Report, certain Conflict Minerals used in its Covered Products may have originated in the Covered Countries and, as a result, the Company was required to conduct due diligence for 2016. These due diligence efforts are discussed below.
Due Diligence Process
Based on the results of the Company’s reasonable country of origin inquiry, the Company exercised due diligence on the source and chain of custody of the Conflict Minerals in its Covered Products. The Company’s due diligence measures are designed to attempt to ascertain the facilities used to process any Conflict Minerals in our Covered Products, the country of origin of any Conflict Minerals in our Covered Products and the mine(s) or location of origin with the greatest possible specificity.
The Company’s due diligence measures have been designed to conform in all material respects to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas.
Step 1: Establish Strong Company Management Systems
(i) Supply Chain Policy for Conflict Minerals. The Company has adopted a policy relating to Conflict Minerals (the “Conflict Minerals Statement”). The Conflict Minerals Statement states that the Company is committed to working with our global supply chain to ensure compliance with the OECD Guidance and regulations promulgated by the SEC concerning Conflict Minerals. We also note in our statement that our supplier agreements include conflict mineral due diligence and reporting requirements. The Company will make best efforts to ensure that any direct sourcing by the Company of tin, tungsten, tantalum and gold will only be from sources that are DRC conflict-free, as defined in the Rule. If we become aware of instances where Conflict Minerals in our supply chain potentially finance armed groups, as defined in the Rule, we will work with our suppliers to find alternate conflict-free sources. Our Conflict Minerals Statement is publicly available in the section on Social Responsibility on the Company’s website at www.neophotonics.com.
(ii) Management Support. To enable compliance with the SEC’s regulations concerning Conflict Minerals, the Company has developed a process that is aligned with its Conflict Minerals Statement, and is documented in the Company’s controlled procedure entitled “Conflict Materials Management and Control Procedure.” The Company initiated a program to address the SEC’s conflict minerals requirements in early 2013. This program is managed by a team of subject matter experts from relevant functions within the Company, including Supply Chain Management, Supplier Quality Engineering, Quality Systems, Research and Development, Product Application Engineering and Customer Service (the “Conflict Minerals Compliance Team”) and is led by our Vice President of Global Product Engineering & Quality Assurance. This global activity is overseen by our Conflict Minerals Free Management Committee composed of our Vice President of Global Product Engineering & Quality Assurance as well as our General Counsel and Director of Global Supply Chain Management.
(iii) Controls and Transparency. To establish a system of controls and transparency over the conflict minerals supply chain, the Company incorporated into its due diligence procedures a requirement for suppliers to provide information regarding the smelters and refiners in the supply chain using the Conflict Minerals Survey. The Conflict Minerals Survey is designed by CFSI, a recognized industry coalition that focuses on addressing conflict minerals in the supply chain. The Conflict Minerals Survey requires suppliers to provide information concerning the usage and source of Conflict Minerals in their components, parts and products, as well as information concerning their related compliance efforts. The Company elected to use the Conflict Minerals Survey because it is a commonly used reported template used in numerous industries, thereby easing the potential for confusion or misunderstanding by the Company’s suppliers.
(iv) Engagement with Suppliers. As the Company does not have a direct relationship with conflict mineral smelters and refiners, the Company relies on its suppliers to provide up-to-date and accurate smelter and refiner sourcing information. The Company’s adoption and utilization of the industry standard CFSI templates, tools and auditing program aided us in establishing consistency and transparency throughout the Company’s supply chain. In addition, the Company has communicated its requirements to suppliers that the products they supply to the Company be compliant with its Conflict Minerals Statement.
(v) Grievance Mechanism. The Company accepts the reporting of known or suspected false information or other grievances concerns its Conflict Minerals programs and practices through its ethics hotline. Information about how to access the ethics hotline is available in the Company’s Code of Business Conduct available in the Investors section of the Company’s website at www.neophotonics.com.
Step 2: Identify and Assess Risk in the Supply Chain
As described above, the requests for information regarding Conflict Minerals in the Company’s products were sent to all of the Company’s direct suppliers sourcing materials in the Company’s products, using the Conflict Minerals Survey. Members of the Conflict Minerals Compliance Team collected and reviewed supplier responses to the Conflict Minerals Survey to identify incomplete, inaccurate or inconsistent responses, and consolidated this information in a central database. The Company followed up with those suppliers that failed to respond to the Conflict Minerals Survey or that submitted incomplete responses or responses that contained inaccuracies or inconsistencies or were otherwise determined not to be suitable. The Company also continues to work with those suppliers who have not yet provided responses or have provided incomplete responses.
To the extent that a completed response identified a smelter or refiner, the Company reviewed this information against the list of conflict free and “active” smelters and refiners and country of origin information published by the CFSI’s Conflict Free Smelter Program. For non-certified smelters and refiners, we attempted outreach to encourage their participation in certification programs. The Company also attempted to ascertain whether the smelter or refiner information provided was specific to the products supplied to the Company to determine whether the identified smelters are in the Company’s supply chain.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
The Conflict Minerals Compliance Team reported the findings of its compliance efforts in respect of 2016 to the Conflict Minerals Free Management Committee who will report on an annual basis to the Board of Directors.
Pursuant to our Conflict Minerals Statement, if the Company becomes aware of instances where Conflict Minerals in our supply chain potentially finance armed groups, as defined in the Rule, we will work with our suppliers to find alternate conflict-free sources.
Further, to mitigate the risk that Conflict Minerals in our supply chain potentially finance armed groups, we intend to engage in the additional measures discussed under “Risk Mitigation Efforts” below.
Step 4: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Because the Company does not source Conflict Minerals directly from smelters or refiners, we rely on third parties, including the CFSI, to coordinate and conduct third party audits of these facilities. The Company utilizes the published results of these third-party audits to determine whether a specified smelter or refiner processes Conflict Minerals that directly or indirectly finance or benefit armed groups.
Step 5: Report on Supply Chain Due Diligence
The Company has filed a Form SD and this Conflict Minerals Report with the SEC and has made the Conflict Minerals Report available in the section on Social Responsibility on the Company’s website at www.neophotonics.com.
Identified Smelters and Refiners
In connection with the our reasonable country of origin inquiry or due diligence, as applicable, the Company’s suppliers identified to us the smelters and refiners listed on Annex A as having processed the necessary Conflict Minerals contained in the Covered Products. Due to the Company’s position in the supply chain, the Company relies on its suppliers for accurate smelter and refiner information. The Company’s due diligence measures cannot provide absolute certainty regarding the source and chain of custody of the necessary Conflict Minerals contained in the Covered Products.
As indicated in the table in Annex A, the Company has gathered the names of 321 smelters and refiners identified by its direct suppliers in the Conflict Minerals Survey. Among them, 245 are on CFSI’s list of “Compliant” smelters and refiners, 12 are included on CFSI’s list of “Active” smelters and refiners, and 56 are included on CFSI’s list of “Standard” smelters and refiners. See Annex A for definitions of Compliant , Active and Standard.
Country of Origin Information and Efforts to Determine Mine Location
A majority (59.84%) of the responses received provided smelter and refiner information at a company or divisional level, or were unable to specify the smelters and refiners used for products supplied to the Company. The Company is unable to determine whether any of the Conflict Minerals reported by these suppliers were contained in components or parts supplied to us, or to validate that any of these smelters and refiners are actually in the Company’s supply chain. In addition, 4.1% of responses to Conflict Minerals Survey Question 6 (Have you identified all of the smelters supplying the 3TG to your supply chain?) were “No”. Therefore, in addition to being unable to determine whether reported smelters and refiners are part of the Company’s supply chain, we are also unsure as to the completeness of the population of smelters and refiners received. Based on the Company’s due diligence efforts to date, the Company does not have sufficient information to determine the country of origin of the conflict minerals in its products or the facilities used to process the conflict minerals, including whether the conflict minerals were from recycled or scrap sources.
Risk Mitigation Efforts
In the next compliance period, the Company will take the following steps to improve its due diligence and mitigate any risk that the Conflict Minerals in the Covered Products could benefit armed groups in the Covered Countries:
· Continue to follow up with suppliers who have not responded or have submitted incomplete responses to the Conflict Minerals Survey, clarify any issues and encourage responses;
· Continue to encourage suppliers that provided company level information in their prior responses to the Conflict Minerals Survey to provide product level information through ongoing outreach with these suppliers;
· Continue to encourage our suppliers to implement responsible sourcing of Conflict Minerals; and
· Continue to encourage our suppliers to require the smelters and refiners in their supply chain to obtain conflict-free designations from an independent, third party auditor.
Annex A
Smelter and Refiner Information
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| Advanced Chemical Company |
| CFSP Full Compliant Smelter |
Gold |
| Aida Chemical Industries Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| CFSP Full Compliant Smelter |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| CFSP Full Compliant Smelter |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| CFSP Full Compliant Smelter |
Gold |
| Argor-Heraeus S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Asahi Pretec Corp. |
| CFSP Full Compliant Smelter |
Gold |
| Asaka Riken Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| CFSP Standard Smelter List |
Gold |
| Aurubis AG |
| CFSP Full Compliant Smelter |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| CFSP Full Compliant Smelter |
Gold |
| Boliden AB |
| CFSP Full Compliant Smelter |
Gold |
| C. Hafner GmbH + Co. KG |
| CFSP Full Compliant Smelter |
Gold |
| Caridad |
| CFSP Standard Smelter List |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CFSP Full Compliant Smelter |
Gold |
| Cendres + Métaux S.A. |
| CFSP Standard Smelter List |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Chimet S.p.A. |
| CFSP Full Compliant Smelter |
Gold |
| Chugai Mining |
| CFSP Standard Smelter List |
Gold |
| Daejin Indus Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| CFSP Standard Smelter List |
Gold |
| DSC (Do Sung Corporation) |
| CFSP Full Compliant Smelter |
Gold |
| DODUCO GmbH |
| CFSP Full Compliant Smelter |
Gold |
| Dowa |
| CFSP Full Compliant Smelter |
Gold |
| Eco-System Recycling Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| OJSC Novosibirsk Refinery |
| CFSP Full Compliant Smelter |
Gold |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Heimerle + Meule GmbH |
| CFSP Full Compliant Smelter |
Gold |
| Heraeus Ltd. Hong Kong |
| CFSP Full Compliant Smelter |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| CFSP Full Compliant Smelter |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| HwaSeong CJ Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Istanbul Gold Refinery |
| CFSP Full Compliant Smelter |
Gold |
| Japan Mint |
| CFSP Full Compliant Smelter |
Gold |
| Jiangxi Copper Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Asahi Refining USA Inc. |
| CFSP Full Compliant Smelter |
Gold |
| Asahi Refining Canada Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| CFSP Full Compliant Smelter |
Gold |
| JSC Uralelectromed |
| CFSP Full Compliant Smelter |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Kazakhmys Smelting LLC |
| CFSP Standard Smelter List |
Gold |
| Kazzinc |
| CFSP Full Compliant Smelter |
Gold |
| Kennecott Utah Copper LLC |
| CFSP Full Compliant Smelter |
Gold |
| Kojima Chemicals Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Kyrgyzaltyn JSC |
| CFSP Full Compliant Smelter |
Gold |
| L’azurde Company For Jewelry |
| CFSP Standard Smelter List |
Gold |
| Lingbao Gold Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| LS-NIKKO Copper Inc. |
| CFSP Full Compliant Smelter |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Materion |
| CFSP Full Compliant Smelter |
Gold |
| Matsuda Sangyo Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Metalor Technologies S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Metalor USA Refining Corporation |
| CFSP Full Compliant Smelter |
Gold |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| CFSP Full Compliant Smelter |
Gold |
| Mitsubishi Materials Corporation |
| CFSP Full Compliant Smelter |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Moscow Special Alloys Processing Plant |
| CFSP Full Compliant Smelter |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| CFSP Full Compliant Smelter |
Gold |
| Navoi Mining and Metallurgical Combinat |
| CFSP active smelter |
Gold |
| Nihon Material Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Elemetal Refining, LLC |
| CFSP Standard Smelter List |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| CFSP Full Compliant Smelter |
Gold |
| PAMP S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| CFSP Full Compliant Smelter |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| CFSP Full Compliant Smelter |
Gold |
| PX Précinox S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Rand Refinery (Pty) Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Royal Canadian Mint |
| CFSP Full Compliant Smelter |
Gold |
| Sabin Metal Corp. |
| CFSP Standard Smelter List |
Gold |
| Samduck Precious Metals |
| CFSP Full Compliant Smelter |
Gold |
| Samwon Metals Corp. |
| CFSP Standard Smelter List |
Gold |
| Schone Edelmetaal B.V. |
| CFSP Full Compliant Smelter |
Gold |
| SEMPSA Joyería Platería S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| So Accurate Group, Inc. |
| CFSP Standard Smelter List |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| CFSP Full Compliant Smelter |
Gold |
| Solar Applied Materials Technology Corp. |
| CFSP Full Compliant Smelter |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| CFSP Full Compliant Smelter |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CFSP Standard Smelter List |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Tokuriki Honten Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CFSP Standard Smelter List |
Gold |
| Torecom |
| CFSP Full Compliant Smelter |
Gold |
| Umicore Brasil Ltda. |
| CFSP Full Compliant Smelter |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| CFSP Full Compliant Smelter |
Gold |
| United Precious Metal Refining, Inc. |
| CFSP Full Compliant Smelter |
Gold |
| Valcambi S.A. |
| CFSP Full Compliant Smelter |
Gold |
| Western Australian Mint trading as The Perth Mint |
| CFSP Full Compliant Smelter |
Gold |
| Yamamoto Precious Metal Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Yokohama Metal Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CFSP Full Compliant Smelter |
Gold |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CFSP Full Compliant Smelter |
Gold |
| Morris and Watson |
| CFSP Standard Smelter List |
Gold |
| SAFINA A.S. |
| CFSP active smelter |
Gold |
| Guangdong Jinding Gold Limited |
| CFSP Standard Smelter List |
Gold |
| Umicore Precious Metals Thailand |
| CFSP Full Compliant Smelter |
Gold |
| Geib Refining Corporation |
| CFSP Full Compliant Smelter |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Republic Metals Corporation |
| CFSP Full Compliant Smelter |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| CFSP active smelter |
Gold |
| Fidelity Printers and Refiners Ltd. |
| CFSP Standard Smelter List |
Gold |
| Singway Technology Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| Al Etihad Gold Refinery DMCC |
| CFSP Full Compliant Smelter |
Gold |
| Emirates Gold DMCC |
| CFSP Full Compliant Smelter |
Gold |
| T.C.A S.p.A |
| CFSP Full Compliant Smelter |
Gold |
| Remondis Argentia B.V. |
| CFSP Standard Smelter List |
Gold |
| Korea Zinc Co., Ltd. |
| CFSP Full Compliant Smelter |
Gold |
| TOO Tau-Ken-Altyn |
| CFSP Standard Smelter List |
Gold |
| Abington Reldan Metals, LLC |
| CFSP Standard Smelter List |
Gold |
| SAAMP |
| CFSP Standard Smelter List |
Gold |
| SAXONIA Edelmetalle GmbH |
| CFSP Full Compliant Smelter |
Gold |
| WIELAND Edelmetalle GmbH |
| CFSP Full Compliant Smelter |
Gold |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| CFSP Full Compliant Smelter |
Gold |
| AU Traders and Refiners |
| CFSP Full Compliant Smelter |
Gold |
| AURA-II |
| CFSP Standard Smelter List |
Gold |
| Gujarat Gold Centre |
| CFSP Standard Smelter List |
Gold |
| Sai Refinery |
| CFSP Standard Smelter List |
Gold |
| Universal Precious Metals Refining Zambia |
| CFSP Standard Smelter List |
Gold |
| Modeltech Sdn Bhd |
| CFSP active smelter |
Gold |
| Bangalore Refinery |
| CFSP active smelter |
Gold |
| Bauer Walser AG |
| Smelter not listed |
Gold |
| Sen Silver |
| Smelter not listed |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| CFSP Full Compliant Smelter |
Tantalum |
| Duoluoshan |
| CFSP Full Compliant Smelter |
Tantalum |
| Exotech Inc. |
| CFSP Full Compliant Smelter |
Tantalum |
| F&X Electro-Materials Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| CFSP Full Compliant Smelter |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| LSM Brasil S.A. |
| CFSP Full Compliant Smelter |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Mineração Taboca S.A. |
| CFSP Full Compliant Smelter |
Tantalum |
| Mitsui Mining and Smelting Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Molycorp Silmet A.S. |
| CFSP Full Compliant Smelter |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| QuantumClean |
| CFSP Full Compliant Smelter |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Solikamsk Magnesium Works OAO |
| CFSP Full Compliant Smelter |
Tantalum |
| Taki Chemical Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Telex Metals |
| CFSP Full Compliant Smelter |
Tantalum |
| Ulba Metallurgical Plant JSC |
| CFSP Full Compliant Smelter |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| D Block Metals, LLC |
| CFSP Full Compliant Smelter |
Tantalum |
| FIR Metals & Resource Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| KEMET Blue Metals |
| CFSP Full Compliant Smelter |
Tantalum |
| Plansee SE Liezen |
| CFSP Standard Smelter List |
Tantalum |
| H.C. Starck Co., Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| H.C. Starck GmbH Goslar |
| CFSP Full Compliant Smelter |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| CFSP Standard Smelter List |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| CFSP Full Compliant Smelter |
Tantalum |
| H.C. Starck Inc. |
| CFSP Full Compliant Smelter |
Tantalum |
| H.C. Starck Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| CFSP Full Compliant Smelter |
Tantalum |
| Plansee SE Reutte |
| CFSP Standard Smelter List |
Tantalum |
| Global Advanced Metals Boyertown |
| CFSP Full Compliant Smelter |
Tantalum |
| Global Advanced Metals Aizu |
| CFSP Full Compliant Smelter |
Tantalum |
| KEMET Blue Powder |
| CFSP Full Compliant Smelter |
Tantalum |
| Tranzact, Inc. |
| CFSP Full Compliant Smelter |
Tantalum |
| E.S.R. Electronics |
| CFSP Standard Smelter List |
Tantalum |
| Resind Indústria e Comércio Ltda. |
| CFSP Full Compliant Smelter |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| CFSP Full Compliant Smelter |
Tantalum |
| Power Resources Ltd. |
| CFSP Full Compliant Smelter |
Tantalum |
| Global Tungsten & Powders Corp. |
| Smelter not listed |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CFSP Standard Smelter List |
Tin |
| Alpha |
| CFSP Full Compliant Smelter |
Tin |
| Cooperativa Metalurgica de Rondônia Ltda. |
| CFSP Full Compliant Smelter |
Tin |
| CV Gita Pesona |
| CFSP Full Compliant Smelter |
Tin |
| PT Justindo |
| CFSP Standard Smelter List |
Tin |
| PT Aries Kencana Sejahtera |
| CFSP Full Compliant Smelter |
Tin |
| CV Serumpun Sebalai |
| CFSP Full Compliant Smelter |
Tin |
| CV United Smelting |
| CFSP Full Compliant Smelter |
Tin |
| Dowa |
| CFSP Full Compliant Smelter |
Tin |
| EM Vinto |
| CFSP Full Compliant Smelter |
Tin |
| Estanho de Rondônia S.A. |
| CFSP Standard Smelter List |
Tin |
| Fenix Metals |
| CFSP Full Compliant Smelter |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CFSP Standard Smelter List |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| CFSP active smelter |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CFSP active smelter |
Tin |
| China Tin Group Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Malaysia Smelting Corporation (MSC) |
| CFSP Full Compliant Smelter |
Tin |
| Metallic Resources, Inc. |
| CFSP Full Compliant Smelter |
Tin |
| Mineração Taboca S.A. |
| CFSP Full Compliant Smelter |
Tin |
| Minsur |
| CFSP Full Compliant Smelter |
Tin |
| Mitsubishi Materials Corporation |
| CFSP Full Compliant Smelter |
Tin |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CFSP active smelter |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Operaciones Metalurgical S.A. |
| CFSP Full Compliant Smelter |
Tin |
| PT Artha Cipta Langgeng |
| CFSP Full Compliant Smelter |
Tin |
| PT Babel Inti Perkasa |
| CFSP Full Compliant Smelter |
Tin |
| PT Bangka Tin Industry |
| CFSP Full Compliant Smelter |
Tin |
| PT Belitung Industri Sejahtera |
| CFSP Full Compliant Smelter |
Tin |
| PT Bukit Timah |
| CFSP Full Compliant Smelter |
Tin |
| PT DS Jaya Abadi |
| CFSP Full Compliant Smelter |
Tin |
| PT Eunindo Usaha Mandiri |
| CFSP Full Compliant Smelter |
Tin |
| PT Karimun Mining |
| CFSP Full Compliant Smelter |
Tin |
| PT Mitra Stania Prima |
| CFSP Full Compliant Smelter |
Tin |
| PT Panca Mega Persada |
| CFSP Full Compliant Smelter |
Tin |
| PT Prima Timah Utama |
| CFSP Full Compliant Smelter |
Tin |
| PT Refined Bangka Tin |
| CFSP Full Compliant Smelter |
Tin |
| PT Sariwiguna Binasentosa |
| CFSP Full Compliant Smelter |
Tin |
| PT Stanindo Inti Perkasa |
| CFSP Full Compliant Smelter |
Tin |
| PT Sumber Jaya Indah |
| CFSP Full Compliant Smelter |
Tin |
| PT Timah (Persero) Tbk Kundur |
| CFSP Full Compliant Smelter |
Tin |
| PT Timah (Persero) Tbk Mentok |
| CFSP Full Compliant Smelter |
Tin |
| PT Tinindo Inter Nusa |
| CFSP Full Compliant Smelter |
Tin |
| PT Tommy Utama |
| CFSP Full Compliant Smelter |
Tin |
| Rui Da Hung |
| CFSP Full Compliant Smelter |
Tin |
| Soft Metais Ltda. |
| CFSP Full Compliant Smelter |
Tin |
| Thaisarco |
| CFSP Full Compliant Smelter |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CFSP active smelter |
Tin |
| VQB Mineral and Trading Group JSC |
| CFSP Full Compliant Smelter |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| CFSP Full Compliant Smelter |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Yunnan Tin Company Limited |
| CFSP Full Compliant Smelter |
Tin |
| CV Venus Inti Perkasa |
| CFSP Full Compliant Smelter |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| CFSP Full Compliant Smelter |
Tin |
| PT Tirus Putra Mandiri |
| CFSP Standard Smelter List |
Tin |
| PT Wahana Perkit Jaya |
| CFSP Standard Smelter List |
Tin |
| Melt Metais e Ligas S.A. |
| CFSP Full Compliant Smelter |
Tin |
| PT ATD Makmur Mandiri Jaya |
| CFSP Full Compliant Smelter |
Tin |
| Phoenix Metal Ltd. |
| CFSP Standard Smelter List |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| CFSP Full Compliant Smelter |
Tin |
| PT Inti Stania Prima |
| CFSP Full Compliant Smelter |
Tin |
| CV Ayi Jaya |
| CFSP Full Compliant Smelter |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| CFSP active smelter |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| CFSP Standard Smelter List |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| CFSP Standard Smelter List |
Tin |
| CV Dua Sekawan |
| CFSP Full Compliant Smelter |
Tin |
| CV Tiga Sekawan |
| CFSP Full Compliant Smelter |
Tin |
| PT Cipta Persada Mulia |
| CFSP Standard Smelter List |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| CFSP Standard Smelter List |
Tin |
| Resind Indústria e Comércio Ltda. |
| CFSP Full Compliant Smelter |
Tin |
| PT O.M. Indonesia |
| CFSP Full Compliant Smelter |
Tin |
| Metallo-Chimique N.V. |
| CFSP Full Compliant Smelter |
Tin |
| Elmet S.L.U. |
| CFSP Full Compliant Smelter |
Tin |
| PT Bangka Prima Tin |
| CFSP Full Compliant Smelter |
Tin |
| PT Sukses Inti Makmur |
| CFSP Full Compliant Smelter |
Tin |
| An Thai Minerals Co., Ltd. |
| CFSP Standard Smelter List |
Tin |
| PT Kijang Jaya Mandiri |
| CFSP Full Compliant Smelter |
Tin |
| PT Menara Cipta Mulia |
| CFSP Full Compliant Smelter |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| CFSP Full Compliant Smelter |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CFSP Full Compliant Smelter |
Tin |
| Modeltech Sdn Bhd |
| CFSP active smelter |
Tin |
| Gejiu Jinye Mineral Company |
| CFSP Full Compliant Smelter |
Tin |
| PT Lautan Harmonis Sejahtera |
| CFSP Full Compliant Smelter |
Tin |
| Galloo N.V. |
| Smelter not listed |
Tin |
| Global Advanced Metals |
| Smelter not listed |
Tin |
| JX Nippon Mining & Metals Co., Ltd. |
| Smelter not listed |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| CFSP Full Compliant Smelter |
Tungsten |
| Kennametal Huntsville |
| CFSP Full Compliant Smelter |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| CFSP Standard Smelter List |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Global Tungsten & Powders Corp. |
| CFSP Full Compliant Smelter |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Japan New Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Kennametal Fallon |
| CFSP Full Compliant Smelter |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| CFSP Full Compliant Smelter |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CFSP Standard Smelter List |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Dayu Jincheng Tungsten Industry Co., Ltd. |
| CFSP Standard Smelter List |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CFSP Standard Smelter List |
Tungsten |
| H.C. Starck GmbH |
| CFSP Full Compliant Smelter |
Tungsten |
| H.C. Starck Smelting GmbH & Co.KG |
| CFSP Full Compliant Smelter |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CFSP Full Compliant Smelter |
Tungsten |
| Niagara Refining LLC |
| CFSP Full Compliant Smelter |
Tungsten |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CFSP Standard Smelter List |
Tungsten |
| Hydrometallurg, JSC |
| CFSP Full Compliant Smelter |
Tungsten |
| Unecha Refractory metals plant |
| CFSP Full Compliant Smelter |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CFSP Full Compliant Smelter |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| CFSP Full Compliant Smelter |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| ACL Metais Eireli |
| CFSP active smelter |
Tungsten |
| Woltech Korea Co., Ltd. |
| CFSP Full Compliant Smelter |
Tungsten |
| Moliren Ltd |
| CFSP Full Compliant Smelter |
Tungsten |
| Ganzhou Haichuang W Co., Ltd |
| Smelter not listed |
Tungsten |
| Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. |
| Smelter not listed |
* The information in this column is based on smelter or refiner information made publicly available by CFSI as of May 12, 2017. The terms used have the following meanings:
· “CFSP Compliant Smelter” means that a smelter or refiner participates in and has been listed as “compliant” by the Conflict-Free Smelter Program (“CFSP”) or is listed as “Re-audit in process” by the CFSI.
· “CFSP Active Smelter” is a CFSI designation that means that the smelter or refiner is listed as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or is participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewellry Program Chain-of-Custody Certification.
· “CFSP Standard Smelter List “ means that the smelter or refiner is listed on the CFSI Standard Smelter Names tab of the Conflict Minerals Survey but is not listed as “Compliant” or “Active.”
