NeoPhotonics Corporation
Conflict Minerals Report
For the reporting period from January 1, 2015 to December 31, 2015
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, 2015 to December 31, 2015. 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 2015.
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.
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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 has 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 2015. 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 under Corporate Citizenship 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 |
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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 as well as the list of known conflict mineral processing facilities published by the U.S. Department of Commerce. 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 2015 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.
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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 under Corporate Citizenship 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 277 smelters and refiners identified by its direct suppliers in the Conflict Minerals Survey. Among them, 207 are on CFSI’s list of “Compliant” smelters and refiners and 25 are included on CFSI’s list of “Active” smelters and refiners. See Annex A for definitions of Compliant and Active.
Country of Origin Information and Efforts to Determine Mine Location
The identified countries of origin of the Conflict Minerals processed by the compliant smelters and refiners listed in Annex A may have included the countries in the categories listed below. The listed countries of origin are derived from information made available by the CFSI. Except for the DRC, the CFSI does not indicate individual countries of origin of the Conflict Minerals processed by compliant smelters and refiners. Instead, the CFSI indicates country of origin by category.
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of materials containing Conflict Minerals out of these regions: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Côte 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 of America, Vietnam, Zimbabwe.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing Conflict Minerals: 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.
Alternatively, or in addition, some of the compliant smelters and refiners did source or may have sourced from recycled or scrap sources.
Because the CFSI generally does not indicate individual countries of origin of the Conflict Minerals processed by compliant smelters and refiners, we are not able to determine the countries of origin of the Conflict Minerals processed by the listed compliant smelters and refiners with greater specificity. In addition, for some of the listed compliant smelters and refiners, origin information may not be disclosed by the CFSI. We did not determine the countries of origin of the Conflict Minerals processed by other smelters and refiners listed on Annex A.
Risk Mitigation Efforts
In the next compliance period, the Company will take the following steps to improve its due diligence and mitigate
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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.
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Annex A
Smelter and Refiner Information
Metal | Name of Smelter or Refiner | Smelter or Refiner Status* |
Gold | Advanced Chemical Company | CFSP Active Smelter |
Gold | Aida Chemical Industries Co., Ltd. | CFSP Compliant Smelter |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CFSP Compliant Smelter |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CFSP Active Smelter |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | CFSP Compliant Smelter |
Gold | Argor-Heraeus S.A. | CFSP Compliant Smelter |
Gold | Asahi Pretec Corp. | CFSP Compliant Smelter |
Gold | Asaka Riken Co., Ltd. | CFSP Compliant Smelter |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CFSP Standard Smelter List |
Gold | Aurubis AG | CFSP Compliant Smelter |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CFSP Compliant Smelter |
Gold | Boliden AB | CFSP Compliant Smelter |
Gold | C. Hafner GmbH + Co. KG | CFSP Compliant Smelter |
Gold | Caridad | CFSP Standard Smelter List |
Gold | CCR Refinery - Glencore Canada Corporation | CFSP Compliant Smelter |
Gold | Cendres + Métaux S.A. | CFSP Active Smelter |
Gold | Yunnan Copper Industry Co., Ltd. | CFSP Standard Smelter List |
Gold | Chimet S.p.A. | CFSP Compliant Smelter |
Gold | Chugai Mining | CFSP Standard Smelter List |
Gold | Daejin Indus Co., Ltd. | CFSP Active Smelter |
Gold | DSC (Do Sung Corporation) | CFSP Active Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Gold | DODUCO GmbH | CFSP Compliant Smelter |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CFSP Standard Smelter List |
Gold | Dowa | CFSP Compliant Smelter |
Gold | Eco-System Recycling Co., Ltd. | CFSP Compliant Smelter |
Gold | OJSC Novosibirsk Refinery | CFSP 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 Compliant Smelter |
Gold | Heraeus Ltd. Hong Kong | CFSP Compliant Smelter |
Gold | Heraeus Precious Metals GmbH & Co. KG | CFSP Compliant Smelter |
Gold | Hunan Chenzhou Mining Co., Ltd. | CFSP Standard Smelter List |
Gold | Hwasung CJ Co., Ltd. | CFSP Standard Smelter List |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CFSP Compliant Smelter |
Gold | Ishifuku Metal Industry Co., Ltd. | CFSP Compliant Smelter |
Gold | Istanbul Gold Refinery | CFSP Compliant Smelter |
Gold | Japan Mint | CFSP Compliant Smelter |
Gold | Jiangxi Copper Co., Ltd. | CFSP Compliant Smelter |
Gold | Asahi Refining USA Inc. | CFSP Compliant Smelter |
Gold | Asahi Refining Canada Ltd. | CFSP Compliant Smelter |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CFSP Compliant Smelter |
Gold | JSC Uralelectromed | CFSP Compliant Smelter |
Gold | JX Nippon Mining & Metals Co., Ltd. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Gold | Kazakhmys Smelting LLC | CFSP Standard Smelter List |
Gold | Kazzinc | CFSP Compliant Smelter |
Gold | Kennecott Utah Copper LLC | CFSP Compliant Smelter |
Gold | Kojima Chemicals Co., Ltd. | CFSP Compliant Smelter |
Gold | Korea Metal Co., Ltd. | CFSP Standard Smelter List |
Gold | Kyrgyzaltyn JSC | CFSP Standard Smelter List |
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 Compliant Smelter |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CFSP Standard Smelter List |
Gold | Materion | CFSP Compliant Smelter |
Gold | Matsuda Sangyo Co., Ltd. | CFSP Compliant Smelter |
Gold | Metalor Technologies (Suzhou) Ltd. | CFSP Active Smelter |
Gold | Metalor Technologies (Hong Kong) Ltd. | CFSP Compliant Smelter |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | CFSP Compliant Smelter |
Gold | Metalor Technologies S.A. | CFSP Compliant Smelter |
Gold | Metalor USA Refining Corporation | CFSP Compliant Smelter |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CFSP Compliant Smelter |
Gold | Mitsubishi Materials Corporation | CFSP Compliant Smelter |
Gold | Mitsui Mining and Smelting Co., Ltd. | CFSP Compliant Smelter |
Gold | Moscow Special Alloys Processing Plant | CFSP Compliant Smelter |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Gold | Navoi Mining and Metallurgical Combinat | CFSP Active Smelter |
Gold | Nihon Material Co., Ltd. | CFSP Compliant Smelter |
Gold | Elemetal Refining, LLC | CFSP Compliant Smelter |
Gold | Ohura Precious Metal Industry Co., Ltd. | CFSP Compliant Smelter |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CFSP Compliant Smelter |
Gold | PAMP S.A. | CFSP Compliant Smelter |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CFSP Standard Smelter List |
Gold | Prioksky Plant of Non-Ferrous Metals | CFSP Compliant Smelter |
Gold | PT Aneka Tambang (Persero) Tbk | CFSP Compliant Smelter |
Gold | PX Précinox S.A. | CFSP Compliant Smelter |
Gold | Rand Refinery (Pty) Ltd. | CFSP Compliant Smelter |
Gold | Royal Canadian Mint | CFSP Compliant Smelter |
Gold | Sabin Metal Corp. | CFSP Standard Smelter List |
Gold | Samduck Precious Metals | CFSP Active Smelter |
Gold | SAMWON Metals Corp. | CFSP Standard Smelter List |
Gold | Schone Edelmetaal B.V. | CFSP Compliant Smelter |
Gold | SEMPSA Joyería Platería S.A. | CFSP Compliant Smelter |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CFSP Standard Smelter List |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CFSP Compliant Smelter |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CFSP Compliant Smelter |
Gold | So Accurate Group, Inc. | CFSP Standard Smelter List |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CFSP Compliant Smelter |
Gold | Solar Applied Materials Technology Corp. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Gold | Sumitomo Metal Mining Co., Ltd. | CFSP Compliant Smelter |
Gold | Tanaka Kikinzoku Kogyo K.K. | CFSP 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 Compliant Smelter |
Gold | Tokuriki Honten Co., Ltd. | CFSP Compliant Smelter |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CFSP Standard Smelter List |
Gold | Torecom | CFSP Active Smelter |
Gold | Umicore Brasil Ltda. | CFSP Compliant Smelter |
Gold | Umicore S.A. Business Unit Precious Metals Refining | CFSP Compliant Smelter |
Gold | United Precious Metal Refining, Inc. | CFSP Compliant Smelter |
Gold | Valcambi S.A. | CFSP Compliant Smelter |
Gold | Western Australian Mint trading as The Perth Mint | CFSP Compliant Smelter |
Gold | Yamamoto Precious Metal Co., Ltd. | CFSP Compliant Smelter |
Gold | Yokohama Metal Co., Ltd. | CFSP Compliant Smelter |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CFSP Compliant Smelter |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CFSP Compliant Smelter |
Gold | Morris and Watson | CFSP Standard Smelter List |
Gold | Guangdong Jinding Gold Limited | CFSP Standard Smelter List |
Gold | Umicore Precious Metals Thailand | CFSP Compliant Smelter |
Gold | Faggi Enrico S.p.A. | CFSP Active Smelter |
Gold | Geib Refining Corporation | CFSP Active Smelter |
Gold | MMTC-PAMP India Pvt., Ltd. | CFSP Compliant Smelter |
Gold | Republic Metals Corporation | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Gold | Singway Technology Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Conghua Tantalum and Niobium Smeltry | CFSP Compliant Smelter |
Tantalum | Duoluoshan | CFSP Compliant Smelter |
Tantalum | Exotech Inc. | CFSP Compliant Smelter |
Tantalum | F&X Electro-Materials Ltd. | CFSP Compliant Smelter |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Hi-Temp Specialty Metals, Inc. | CFSP Compliant Smelter |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Jiujiang Tanbre Co., Ltd. | CFSP Compliant Smelter |
Tantalum | King-Tan Tantalum Industry Ltd. | CFSP Compliant Smelter |
Tantalum | LSM Brasil S.A. | CFSP Compliant Smelter |
Tantalum | Metallurgical Products India Pvt., Ltd. | CFSP Compliant Smelter |
Tantalum | Mineração Taboca S.A. | CFSP Compliant Smelter |
Tantalum | Mitsui Mining & Smelting | CFSP Compliant Smelter |
Tantalum | Molycorp Silmet A.S. | CFSP Compliant Smelter |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CFSP Compliant Smelter |
Tantalum | QuantumClean | CFSP Compliant Smelter |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Solikamsk Magnesium Works OAO | CFSP Compliant Smelter |
Tantalum | Taki Chemicals | CFSP Compliant Smelter |
Tantalum | Telex Metals | CFSP Compliant Smelter |
Tantalum | Ulba Metallurgical Plant JSC | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tantalum | Zhuzhou Cemented Carbide | CFSP Compliant Smelter |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CFSP Compliant Smelter |
Tantalum | D Block Metals, LLC | CFSP Compliant Smelter |
Tantalum | FIR Metals & Resource Ltd. | CFSP Compliant Smelter |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CFSP Compliant Smelter |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CFSP Compliant Smelter |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CFSP Compliant Smelter |
Tantalum | KEMET Blue Metals | CFSP Compliant Smelter |
Tantalum | Plansee SE Liezen | CFSP Compliant Smelter |
Tantalum | H.C. Starck Co., Ltd. | CFSP Compliant Smelter |
Tantalum | H.C. Starck GmbH Goslar | CFSP Compliant Smelter |
Tantalum | H.C. Starck GmbH Laufenburg | CFSP Compliant Smelter |
Tantalum | H.C. Starck Hermsdorf GmbH | CFSP Compliant Smelter |
Tantalum | H.C. Starck Inc. | CFSP Compliant Smelter |
Tantalum | H.C. Starck Ltd. | CFSP Compliant Smelter |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | CFSP Compliant Smelter |
Tantalum | Plansee SE Reutte | CFSP Compliant Smelter |
Tantalum | Global Advanced Metals Boyertown | CFSP Compliant Smelter |
Tantalum | Global Advanced Metals Aizu | CFSP Compliant Smelter |
Tantalum | KEMET Blue Powder | CFSP Compliant Smelter |
Tantalum | Jiangxi Tuohong New Raw Material | CFSP Compliant Smelter |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CFSP Standard Smelter List |
Tin | Alpha | CFSP Compliant Smelter |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | CFSP Compliant Smelter |
Tin | CV Gita Pesona | CFSP Compliant Smelter |
Tin | PT Justindo | CFSP Compliant Smelter |
Tin | PT Aries Kencana Sejahtera | CFSP Compliant Smelter |
Tin | CV Serumpun Sebalai | CFSP Compliant Smelter |
Tin | CV United Smelting | CFSP Compliant Smelter |
Tin | Dowa | CFSP Compliant Smelter |
Tin | EM Vinto | CFSP Compliant Smelter |
Tin | Estanho de Rondônia S.A. | CFSP Standard Smelter List |
Tin | Feinhütte Halsbrücke GmbH | CFSP Standard Smelter List |
Tin | Fenix Metals | CFSP Compliant Smelter |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CFSP Compliant Smelter |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CFSP Standard Smelter List |
Tin | Huichang Jinshunda Tin Co., Ltd. | CFSP Standard Smelter List |
Tin | Gejiu Kai Meng Industry and Trade LLC | CFSP Active Smelter |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CFSP Standard Smelter List |
Tin | China Tin Group Co., Ltd. | CFSP Compliant Smelter |
Tin | Malaysia Smelting Corporation (MSC) | CFSP Compliant Smelter |
Tin | Metallic Resources, Inc. | CFSP Compliant Smelter |
Tin | Mineração Taboca S.A. | CFSP Compliant Smelter |
Tin | Minsur | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tin | Mitsubishi Materials Corporation | CFSP Compliant Smelter |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CFSP Standard Smelter List |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CFSP Compliant Smelter |
Tin | Operaciones Metalurgical S.A. | CFSP Compliant Smelter |
Tin | PT Alam Lestari Kencana | CFSP Standard Smelter List |
Tin | PT Artha Cipta Langgeng | CFSP Compliant Smelter |
Tin | PT Babel Inti Perkasa | CFSP Compliant Smelter |
Tin | PT Bangka Kudai Tin | CFSP Standard Smelter List |
Tin | PT Bangka Timah Utama Sejahtera | CFSP Standard Smelter List |
Tin | PT Bangka Tin Industry | CFSP Compliant Smelter |
Tin | PT Belitung Industri Sejahtera | CFSP Compliant Smelter |
Tin | PT BilliTin Makmur Lestari | CFSP Compliant Smelter |
Tin | PT Bukit Timah | CFSP Compliant Smelter |
Tin | PT DS Jaya Abadi | CFSP Compliant Smelter |
Tin | PT Eunindo Usaha Mandiri | CFSP Compliant Smelter |
Tin | PT Fang Di MulTindo | CFSP Standard Smelter List |
Tin | PT Karimun Mining | CFSP Active Smelter |
Tin | PT Mitra Stania Prima | CFSP Compliant Smelter |
Tin | PT Panca Mega Persada | CFSP Compliant Smelter |
Tin | PT Prima Timah Utama | CFSP Compliant Smelter |
Tin | PT Refined Bangka Tin | CFSP Compliant Smelter |
Tin | PT Sariwiguna Binasentosa | CFSP Compliant Smelter |
Tin | PT Seirama Tin Investment | CFSP Standard Smelter List |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tin | PT Stanindo Inti Perkasa | CFSP Compliant Smelter |
Tin | PT Sumber Jaya Indah | CFSP Compliant Smelter |
Tin | PT Timah (Persero) Tbk Kundur | CFSP Compliant Smelter |
Tin | PT Timah (Persero) Tbk Mentok | CFSP Compliant Smelter |
Tin | PT Pelat Timah Nusantara Tbk | CFSP Standard Smelter List |
Tin | PT Tinindo Inter Nusa | CFSP Compliant Smelter |
Tin | PT Tommy Utama | CFSP Compliant Smelter |
Tin | Rui Da Hung | CFSP Compliant Smelter |
Tin | Soft Metais Ltda. | CFSP Compliant Smelter |
Tin | Thaisarco | CFSP Compliant Smelter |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CFSP Active Smelter |
Tin | VQB Mineral and Trading Group JSC | CFSP Compliant Smelter |
Tin | White Solder Metalurgia e Mineração Ltda. | CFSP Compliant Smelter |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CFSP Active Smelter |
Tin | Yunnan Tin Company Limited | CFSP Compliant Smelter |
Tin | CV Venus Inti Perkasa | CFSP Compliant Smelter |
Tin | Magnu's Minerais Metais e Ligas Ltda. | CFSP Compliant Smelter |
Tin | PT Tirus Putra Mandiri | CFSP Standard Smelter List |
Tin | PT Wahana Perkit Jaya | CFSP Compliant Smelter |
Tin | Melt Metais e Ligas S.A. | CFSP Compliant Smelter |
Tin | PT ATD Makmur Mandiri Jaya | CFSP Compliant Smelter |
Tin | Phoenix Metal Ltd. | CFSP Active Smelter |
Tin | O.M. Manufacturing Philippines, Inc. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tin | PT Inti Stania Prima | CFSP Compliant Smelter |
Tin | CV Ayi Jaya | CFSP 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 Active Smelter |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CFSP Active Smelter |
Tin | PT Cipta Persada Mulia | CFSP Compliant Smelter |
Tin | An Vinh Joint Stock Mineral Processing Company | CFSP Active Smelter |
Tin | Resind Indústria e Comércio Ltda. | CFSP Compliant Smelter |
Tin | Metallo-Chimique N.V. | CFSP Compliant Smelter |
Tin | Elmet S.L.U. | CFSP Compliant Smelter |
Tin | PT Bangka Prima Tin | CFSP Compliant Smelter |
Tungsten | A.L.M.T. TUNGSTEN Corp. | CFSP Compliant Smelter |
Tungsten | Kennametal Huntsville | CFSP Compliant Smelter |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CFSP Standard Smelter List |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Global Tungsten & Powders Corp. | CFSP Compliant Smelter |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Japan New Metals Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CFSP Standard Smelter List |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tungsten | Kennametal Fallon | CFSP Active Smelter |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Wolfram Bergbau und Hütten AG | CFSP Compliant Smelter |
Tungsten | Xiamen Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CFSP Standard Smelter List |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CFSP Active Smelter |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CFSP Active Smelter |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CFSP Active Smelter |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Asia Tungsten Products Vietnam Ltd. | CFSP Compliant Smelter |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CFSP Compliant Smelter |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CFSP Standard Smelter List |
Tungsten | Pobedit, JSC | CFSP Standard Smelter List |
Tungsten | H.C. Starck GmbH | CFSP Compliant Smelter |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | CFSP Compliant Smelter |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CFSP Compliant Smelter |
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Metal | Name of Smelter or Refiner | Smelter or Refiner Status * |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CFSP Active Smelter |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CFSP Compliant Smelter |
Tungsten | Niagara Refining LLC | CFSP Compliant Smelter |
Tungsten | Hydrometallurg, JSC | CFSP Compliant Smelter |
*The information in this column is based on smelter or refiner information made publicly available by CFSI as of May 20, 2016. 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.”
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