NeoPhotonics Corporation
Conflict Minerals Report
For the reporting period from January 1, 2018 to December 31, 2018
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, 2018 to December 31, 2018. 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 “3TG 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, the Covered Products (as defined below), and the 3TG 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 3TG 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 2018.
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 3TG Minerals. In this regard, the Company does not purchase 3TG Minerals directly from mines, smelters or refiners. The Company must therefore rely on its direct suppliers to provide information regarding the origin of 3TG Minerals that are included in the Covered Products, including sources of 3TG Minerals that are supplied to them by sub-tier suppliers. Moreover, the Company believes that the smelters and refiners of the 3TG Minerals are best suited to identify the sources of 3TG Minerals, and therefore has taken steps to identify the applicable smelters and refiners of 3TG 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 3TG Minerals in its Covered Products. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the 3TG Minerals originated in the Covered Countries and whether any of the 3TG 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 3TG 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 3TG Minerals in its supply chain from all of the Company’s direct suppliers sourcing materials in the Covered Products, using the Conflict Minerals Reporting Template (the “Conflict Minerals Survey”) developed by the Responsible Minerals Initiative (RMI). 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. The Company’s outreach for 2018 included 134 suppliers, 92% of which responded to our request for information and 9.7% of which responded that the products they supply to the Company do not include 3TG Minerals. In addition, for 2018, the Company did not send a Conflicts Minerals Survey to suppliers of its packing, chemical and optical products after concluding that 3TG Minerals are not necessary to the functionality or production of such products.
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 3TG 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 2018. 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 3TG Minerals in its Covered Products. The Company’s due diligence measures are designed to attempt to ascertain the facilities used to process any 3TG Minerals in our Covered Products, the country of origin of any 3TG 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: Third 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 statement and a policy relating to 3TG Minerals (the “Conflict Minerals Statement” and the “Conflict Minerals Policy,” respectively). 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 3TG Minerals. We also note in our statement that our supplier agreements include conflict mineral due diligence and reporting requirements. The Conflict Minerals Policy further provides that 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 3TG 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 and Conflict Minerals Policy are 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 3TG Minerals, the Company has developed a process that is aligned with its Conflict Minerals Statement and Conflict Minerals Policy, 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 RMI, 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 3TG 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 RMI 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 concerning its 3TG Minerals programs and practices, including compliance with the Conflict Minerals Statement and the Conflict Minerals Policy, by emailing conflict.minerals@neophotonics.com or by reporting a concern to the Company’s 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 3TG 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 RMI’s Responsible Minerals Assurance Process. 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 2018 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 and Conflict Minerals Policy, if the Company becomes aware of instances where 3TG 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 3TG 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 3TG Minerals directly from smelters or refiners, we rely on third parties, including RMI, 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 3TG 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 3TG 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 3TG Minerals contained in the Covered Products.
As indicated in the table in Annex A, the Company has gathered the names of 340 smelters and refiners identified by its direct suppliers in the Conflict Minerals Survey. Among them, 256 are on RMI’s list of “Conformant” smelters and refiners, six are included on RMI’s list of “Active” smelters and refiners, and 58 are included on RMI’s list of “Standard” smelters and refiners. See Annex A for definitions of Conformant, Active and Standard.
Due to our position in the supply chain, which we discuss above, we rely on our suppliers for accurate smelter and refiner information. Our due diligence measures cannot provide adequate certainty regarding the source and chain of custody of the 3TG Minerals contained in the Covered Products. Of the suppliers that responded to the Conflict Minerals Survey and confirmed that 3TG Minerals are included in the products supplied to the Company, a majority (92%) of the responses received provided smelter and refiner information at the company 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 3TG 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, 13% 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. Accordingly, the list of smelters and refiners in the table in Annex A may contain smelters and refiners that are not in our supply chain and there may be other smelters and refiners not yet identified in our due diligence process. We will continue to update the list as our information improves.
Country of Origin Information and Efforts to Determine Mine Location
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 3TG Minerals in its Covered Products or the facilities used to process the 3TG Minerals, including whether the 3TG 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 3TG 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 3TG 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 |
| RMAP Conformant Smelter |
Gold |
| Aida Chemical Industries Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| RMAP Conformant Smelter |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| RMAP Conformant Smelter |
Gold |
| AngloGold Ashanti Corrego do Sitio Mineracao |
| RMAP Conformant Smelter |
Gold |
| Argor-Heraeus S.A. |
| RMAP Conformant Smelter |
Gold |
| Asahi Pretec Corp. |
| RMAP Conformant Smelter |
Gold |
| Asaka Riken Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| RMAP Standard Smelter List |
Gold |
| Aurubis AG |
| RMAP Conformant Smelter |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| RMAP Conformant Smelter |
Gold |
| Boliden AB |
| RMAP Conformant Smelter |
Gold |
| C. Hafner GmbH + Co. KG |
| RMAP Conformant Smelter |
Gold |
| Caridad |
| RMAP Standard Smelter List |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| RMAP Conformant Smelter |
Gold |
| Cendres + Metaux S.A. |
| RMAP Conformant Smelter |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Chimet S.p.A. |
| RMAP Conformant Smelter |
Gold |
| Chugai Mining |
| RMAP Active smelter |
Gold |
| Daejin Indus Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| RMAP Standard Smelter List |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| DSC (Do Sung Corporation) |
| RMAP Conformant Smelter |
Gold |
| DODUCO Contacts and Refining GmbH |
| RMAP Conformant Smelter |
Gold |
| Dowa |
| RMAP Conformant Smelter |
Gold |
| Eco-System Recycling Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| OJSC Novosibirsk Refinery |
| RMAP Conformant Smelter |
Gold |
| Refinery of Seemine Gold Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| HeeSung Metal Ltd. |
| RMAP Conformant Smelter |
Gold |
| Heimerle + Meule GmbH |
| RMAP Conformant Smelter |
Gold |
| Heraeus Metals Hong Kong Ltd. |
| RMAP Conformant Smelter |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| RMAP Conformant Smelter |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| HwaSeong CJ CO., LTD. |
| RMAP Standard Smelter List |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Istanbul Gold Refinery |
| RMAP Conformant Smelter |
Gold |
| Japan Mint |
| RMAP Conformant Smelter |
Gold |
| Jiangxi Copper Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Asahi Refining USA Inc. |
| RMAP Conformant Smelter |
Gold |
| Asahi Refining Canada Ltd. |
| RMAP Conformant Smelter |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RMAP Standard Smelter List |
Metal |
| Name of Smelter or Refiner |
| Smelter or��Refiner Status* |
Gold |
| JSC Uralelectromed |
| RMAP Conformant Smelter |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Kazakhmys Smelting LLC |
| RMAP Standard Smelter List |
Gold |
| Kazzinc |
| RMAP Conformant Smelter |
Gold |
| Kennecott Utah Copper LLC |
| RMAP Conformant Smelter |
Gold |
| Kojima Chemicals Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Kyrgyzaltyn JSC |
| RMAP Conformant Smelter |
Gold |
| L’azurde Company For Jewelry |
| RMAP Standard Smelter List |
Gold |
| Lingbao Gold Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| LS-NIKKO Copper Inc. |
| RMAP Conformant Smelter |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Materion |
| RMAP Conformant Smelter |
Gold |
| Matsuda Sangyo Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| RMAP Conformant Smelter |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| RMAP Conformant Smelter |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Metalor Technologies S.A. |
| RMAP Conformant Smelter |
Gold |
| Metalor USA Refining Corporation |
| RMAP Conformant Smelter |
Gold |
| Metalurgica Met-Mex Penoles S.A. De C.V. |
| RMAP Conformant Smelter |
Gold |
| Mitsubishi Materials Corporation |
| RMAP Conformant Smelter |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Moscow Special Alloys Processing Plant |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.S. |
| RMAP Conformant Smelter |
Gold |
| Navoi Mining and Metallurgical Combinat |
| RMAP Standard Smelter List |
Gold |
| Nihon Material Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Elemetal Refining, LLC |
| Smelter not yet listed |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| RMAP Conformant Smelter |
Gold |
| PAMP S.A. |
| RMAP Conformant Smelter |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| RMAP Conformant Smelter |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| RMAP Conformant Smelter |
Gold |
| PX Precinox S.A. |
| RMAP Conformant Smelter |
Gold |
| Rand Refinery (Pty) Ltd. |
| RMAP Conformant Smelter |
Gold |
| Royal Canadian Mint |
| RMAP Conformant Smelter |
Gold |
| Sabin Metal Corp. |
| RMAP Standard Smelter List |
Gold |
| Samduck Precious Metals |
| RMAP Standard Smelter List |
Gold |
| Samwon Metals Corp. |
| RMAP Standard Smelter List |
Gold |
| Schone Edelmetaal B.V. |
| Smelter not yet listed |
Gold |
| SEMPSA Joyeria Plateria S.A. |
| RMAP Conformant Smelter |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| So Accurate Group, Inc. |
| Smelter not yet listed |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| Solar Applied Materials Technology Corp. |
| RMAP Conformant Smelter |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| RMAP Conformant Smelter |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| RMAP Standard Smelter List |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Tokuriki Honten Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Torecom |
| RMAP Conformant Smelter |
Gold |
| Umicore Brasil Ltda. |
| RMAP Conformant Smelter |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| RMAP Conformant Smelter |
Gold |
| United Precious Metal Refining, Inc. |
| RMAP Conformant Smelter |
Gold |
| Valcambi S.A. |
| RMAP Conformant Smelter |
Gold |
| Western Australian Mint (T/a The Perth Mint) |
| RMAP Conformant Smelter |
Gold |
| Yamakin Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Yokohama Metal Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| RMAP Conformant Smelter |
Gold |
| Gold Refinery of Zijin Mining Group Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Morris and Watson |
| RMAP Standard Smelter List |
Gold |
| SAFINA A.S. |
| RMAP Standard Smelter List |
Gold |
| Guangdong Jinding Gold Limited |
| RMAP Standard Smelter List |
Gold |
| Umicore Precious Metals Thailand |
| RMAP Conformant Smelter |
Gold |
| Geib Refining Corporation |
| RMAP Conformant Smelter |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| Republic Metals Corporation |
| Smelter not yet listed |
Gold |
| KGHM Polska Miedz Spolka Akcyjna |
| RMAP Active smelter |
Gold |
| Fidelity Printers and Refiners Ltd. |
| RMAP Standard Smelter List |
Gold |
| Singway Technology Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Shangdong Humon Smelting Co., Ltd. |
| RMAP Standard Smelter List |
Gold |
| Al Etihad Gold LLC |
| RMAP Conformant Smelter |
Gold |
| Emirates Gold DMCC |
| RMAP Conformant Smelter |
Gold |
| International Precious Metal Refiners |
| RMAP Standard Smelter List |
Gold |
| Kaloti Precious Metals |
| RMAP Standard Smelter List |
Gold |
| Sudan Gold Refinery |
| RMAP Standard Smelter List |
Gold |
| T.C.A S.p.A |
| RMAP Conformant Smelter |
Gold |
| Remondis Argentia B.V. |
| RMAP Conformant Smelter |
Gold |
| Fujairah Gold FZE |
| RMAP Standard Smelter List |
Gold |
| Tony Goetz NV |
| RMAP Standard Smelter List |
Gold |
| Korea Zinc Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Marsam Metals |
| RMAP Conformant Smelter |
Gold |
| TOO Tau-Ken-Altyn |
| RMAP Standard Smelter List |
Gold |
| Abington Reldan Metals, LLC |
| RMAP Standard Smelter List |
Gold |
| SAAMP |
| RMAP Conformant Smelter |
Gold |
| L’Orfebre S.A. |
| RMAP Conformant Smelter |
Gold |
| 8853 S.p.A. |
| RMAP Conformant Smelter |
Gold |
| Italpreziosi |
| RMAP Conformant Smelter |
Gold |
| SAXONIA Edelmetalle GmbH |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Gold |
| WIELAND Edelmetalle GmbH |
| RMAP Conformant Smelter |
Gold |
| Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| RMAP Conformant Smelter |
Gold |
| AU Traders and Refiners |
| RMAP Conformant Smelter |
Gold |
| GCC Gujrat Gold Centre Pvt. Ltd. |
| RMAP Standard Smelter List |
Gold |
| Sai Refinery |
| RMAP Standard Smelter List |
Gold |
| Universal Precious Metals Refining Zambia |
| RMAP Standard Smelter List |
Gold |
| Modeltech Sdn Bhd |
| RMAP Standard Smelter List |
Gold |
| Bangalore Refinery |
| RMAP Conformant Smelter |
Gold |
| Kyshtym Copper-Electrolytic Plant ZAO |
| RMAP Standard Smelter List |
Gold |
| Morris and Watson Gold Coast |
| RMAP Standard Smelter List |
Gold |
| Degussa Sonne / Mond Goldhandel GmbH |
| RMAP Standard Smelter List |
Gold |
| Pease & Curren |
| RMAP Standard Smelter List |
Gold |
| SungEel HiMetal Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| Planta Recuperadora de Metales SpA |
| RMAP Conformant Smelter |
Gold |
| Safimet S.p.A |
| RMAP Conformant Smelter |
Gold |
| State Research Institute Center for Physical Sciences and Technology |
| RMAP Standard Smelter List |
Gold |
| African Gold Refinery |
| RMAP Standard Smelter List |
Gold |
| NH Recytech Company |
| RMAP Active smelter |
Gold |
| DS PRETECH Co., Ltd. |
| RMAP Conformant Smelter |
Gold |
| QG Refining, LLC |
| RMAP Standard Smelter List |
Gold |
| Dijllah Gold Refinery FZC |
| RMAP Standard Smelter List |
Tantalum |
| Asaka Riken Co., Ltd. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Guangdong Rising Rare Metals-EO Materials Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Duoluoshan |
| Smelter not yet listed |
Tantalum |
| Exotech Inc. |
| RMAP Conformant Smelter |
Tantalum |
| F&X Electro-Materials Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| Smelter not yet listed |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| Smelter not yet listed |
Tantalum |
| LSM Brasil S.A. |
| RMAP Conformant Smelter |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Mineracao Taboca S.A. |
| RMAP Conformant Smelter |
Tantalum |
| Mitsui Mining and Smelting Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| NPM Silmet AS |
| RMAP Conformant Smelter |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| QuantumClean |
| RMAP Conformant Smelter |
Tantalum |
| RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Solikamsk Magnesium Works OAO |
| RMAP Conformant Smelter |
Tantalum |
| Taki Chemical Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Telex Metals |
| RMAP Conformant Smelter |
Tantalum |
| Ulba Metallurgical Plant JSC |
| RMAP Conformant Smelter |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| Smelter not yet listed |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| Smelter not yet listed |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| D Block Metals, LLC |
| RMAP Conformant Smelter |
Tantalum |
| FIR Metals & Resource Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| KEMET Blue Metals |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Co., Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Tantalum and Niobium GmbH |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Inc. |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| RMAP Conformant Smelter |
Tantalum |
| Global Advanced Metals Boyertown |
| RMAP Conformant Smelter |
Tantalum |
| Global Advanced Metals Aizu |
| RMAP Conformant Smelter |
Tantalum |
| KEMET Blue Powder |
| RMAP Conformant Smelter |
Tantalum |
| Resind Industria e Comercio Ltda. |
| RMAP Conformant Smelter |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| RMAP Conformant Smelter |
Tantalum |
| Power Resources Ltd. |
| RMAP Conformant Smelter |
Tantalum |
| Jiujiang Janny New Material Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| Smelter not yet listed |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tin |
| CNMC (Guangxi) PGMA Co., Ltd. |
| Smelter not yet listed |
Tin |
| Alpha |
| RMAP Conformant Smelter |
Tin |
| Cooperativa Metalurgica de Rondonia Ltda. |
| Smelter not yet listed |
Tin |
| CV Gita Pesona |
| RMAP Conformant Smelter |
Tin |
| PT Aries Kencana Sejahtera |
| RMAP Conformant Smelter |
Tin |
| PT Premium Tin Indonesia |
| RMAP Conformant Smelter |
Tin |
| CV United Smelting |
| RMAP Conformant Smelter |
Tin |
| Dowa |
| RMAP Conformant Smelter |
Tin |
| EM Vinto |
| RMAP Conformant Smelter |
Tin |
| Estanho de Rondonia S.A. |
| RMAP Standard Smelter List |
Tin |
| Fenix Metals |
| RMAP Conformant Smelter |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| RMAP Conformant Smelter |
Tin |
| China Tin Group Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Malaysia Smelting Corporation (MSC) |
| RMAP Conformant Smelter |
Tin |
| Metallic Resources, Inc. |
| RMAP Conformant Smelter |
Tin |
| Mineracao Taboca S.A. |
| RMAP Conformant Smelter |
Tin |
| Minsur |
| RMAP Conformant Smelter |
Tin |
| Mitsubishi Materials Corporation |
| RMAP Conformant Smelter |
Tin |
| Jiangxi New Nanshan Technology Ltd. |
| RMAP Conformant Smelter |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tin |
| Operaciones Metalurgical S.A. |
| RMAP Conformant Smelter |
Tin |
| PT Artha Cipta Langgeng |
| RMAP Conformant Smelter |
Tin |
| PT Babel Inti Perkasa |
| RMAP Conformant Smelter |
Tin |
| PT Babel Surya Alam Lestari |
| RMAP Conformant Smelter |
Tin |
| PT Bangka Tin Industry |
| RMAP Conformant Smelter |
Tin |
| PT Belitung Industri Sejahtera |
| RMAP Conformant Smelter |
Tin |
| PT Bukit Timah |
| RMAP Conformant Smelter |
Tin |
| PT DS Jaya Abadi |
| RMAP Conformant Smelter |
Tin |
| PT Eunindo Usaha Mandiri |
| Smelter not yet listed |
Tin |
| PT Karimun Mining |
| RMAP Conformant Smelter |
Tin |
| PT Mitra Stania Prima |
| RMAP Conformant Smelter |
Tin |
| PT Panca Mega Persada |
| RMAP Conformant Smelter |
Tin |
| PT Prima Timah Utama |
| RMAP Conformant Smelter |
Tin |
| PT Refined Bangka Tin |
| RMAP Conformant Smelter |
Tin |
| PT Sariwiguna Binasentosa |
| RMAP Conformant Smelter |
Tin |
| PT Stanindo Inti Perkasa |
| RMAP Conformant Smelter |
Tin |
| PT Sumber Jaya Indah |
| RMAP Conformant Smelter |
Tin |
| PT Timah (Persero) Tbk Kundur |
| RMAP Conformant Smelter |
Tin |
| PT Timah (Persero) Tbk Mentok |
| RMAP Conformant Smelter |
Tin |
| PT Tinindo Inter Nusa |
| RMAP Conformant Smelter |
Tin |
| PT Tommy Utama |
| RMAP Conformant Smelter |
Tin |
| Rui Da Hung |
| RMAP Conformant Smelter |
Tin |
| Soft Metais Ltda. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tin |
| Thaisarco |
| RMAP Conformant Smelter |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| VQB Mineral and Trading Group JSC |
| Smelter not yet listed |
Tin |
| White Solder Metalurgia e Mineracao Ltda. |
| RMAP Conformant Smelter |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Yunnan Tin Company Limited |
| RMAP Conformant Smelter |
Tin |
| CV Venus Inti Perkasa |
| RMAP Conformant Smelter |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| RMAP Conformant Smelter |
Tin |
| PT Tirus Putra Mandiri |
| RMAP Conformant Smelter |
Tin |
| Melt Metais e Ligas S.A. |
| RMAP Conformant Smelter |
Tin |
| PT ATD Makmur Mandiri Jaya |
| RMAP Conformant Smelter |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| RMAP Conformant Smelter |
Tin |
| PT Inti Stania Prima |
| RMAP Conformant Smelter |
Tin |
| CV Ayi Jaya |
| RMAP Conformant Smelter |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| RMAP Standard Smelter List |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| RMAP Standard Smelter List |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| RMAP Standard Smelter List |
Tin |
| CV Dua Sekawan |
| RMAP Conformant Smelter |
Tin |
| CV Tiga Sekawan |
| RMAP Conformant Smelter |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| RMAP Standard Smelter List |
Tin |
| Resind Industria e Comercio Ltda. |
| RMAP Conformant Smelter |
Tin |
| Super Ligas |
| RMAP Standard Smelter List |
Tin |
| Smelter not yet identified |
| Smelter not yet listed |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tin |
| Metallo Belgium N.V. |
| RMAP Conformant Smelter |
Tin |
| Metallo Spain S.L.U. |
| RMAP Conformant Smelter |
Tin |
| PT Bangka Prima Tin |
| RMAP Conformant Smelter |
Tin |
| PT Sukses Inti Makmur |
| RMAP Conformant Smelter |
Tin |
| An Thai Minerals Co., Ltd. |
| Smelter not yet listed |
Tin |
| PT Kijang Jaya Mandiri |
| RMAP Conformant Smelter |
Tin |
| PT Menara Cipta Mulia |
| RMAP Conformant Smelter |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| RMAP Standard Smelter List |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| RMAP Conformant Smelter |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| RMAP Conformant Smelter |
Tin |
| Modeltech Sdn Bhd |
| RMAP Conformant Smelter |
Tin |
| Gejiu Jinye Mineral Company |
| RMAP Conformant Smelter |
Tin |
| PT Lautan Harmonis Sejahtera |
| RMAP Conformant Smelter |
Tin |
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| Chifeng Dajingzi Tin Industry Co., Ltd. |
| RMAP Conformant Smelter |
Tin |
| PT Bangka Serumpun |
| RMAP Conformant Smelter |
Tin |
| Pongpipat Company Limited |
| RMAP Standard Smelter List |
Tin |
| Tin Technology & Refining |
| RMAP Conformant Smelter |
Tin |
| Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| RMAP Active smelter |
Tin |
| PT Rajawali Rimba Perkasa |
| RMAP Active smelter |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| RMAP Conformant Smelter |
Tungsten |
| Kennametal Huntsville |
| RMAP Conformant Smelter |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| Smelter not yet listed |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Global Tungsten & Powders Corp. |
| RMAP Conformant Smelter |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Japan New Metals Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Kennametal Fallon |
| RMAP Conformant Smelter |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| Smelter not yet listed |
Tungsten |
| Wolfram Bergbau und Hutten AG |
| RMAP Conformant Smelter |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| RMAP Standard Smelter List |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| RMAP Conformant Smelter |
Metal |
| Name of Smelter or Refiner |
| Smelter or Refiner Status* |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| Smelter not yet listed |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| Smelter not yet listed |
Tungsten |
| H.C. Starck Tungsten GmbH |
| RMAP Conformant Smelter |
Tungsten |
| H.C. Starck Smelting GmbH & Co. KG |
| RMAP Conformant Smelter |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| RMAP Conformant Smelter |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| RMAP Conformant Smelter |
Tungsten |
| Niagara Refining LLC |
| RMAP Conformant Smelter |
Tungsten |
| Ganzhou Haichuang Tungsten Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| RMAP Standard Smelter List |
Tungsten |
| Hydrometallurg, JSC |
| RMAP Conformant Smelter |
Tungsten |
| Unecha Refractory metals plant |
| RMAP Conformant Smelter |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| RMAP Conformant Smelter |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| RMAP Conformant Smelter |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| ACL Metais Eireli |
| RMAP Conformant Smelter |
Tungsten |
| Woltech Korea Co., Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Moliren Ltd. |
| RMAP Conformant Smelter |
Tungsten |
| Hunan Litian Tungsten Industry Co., Ltd. |
| RMAP Active smelter |
* The information in this column is based on smelter or refiner information made publicly available by RMI as of
May 8, 2019. The terms used have the following meanings:
· “RMAP Conformant Smelter” means that a smelter or refiner participates in and has been listed as “conformant” by the Responsible Minerals Assurance Process (“RMAP”) or is listed as “Re-audit in process” by the RMAP.
· “RMAP Active Smelter” is a RMAP 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 RMAP or is participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.
· “RMAP Standard Smelter List” means that the smelter or refiner is listed on the RMI Standard Smelter Names tab of the Conflict Minerals Survey but is not listed as “Conformant” or “Active.”
