CONFLICT MINERALS REPORT OF CONTROL4 CORPORATION
FOR THE REPORTING PERIOD FROM JANUARY 1, 2015 TO DECEMBER 31, 2015
Background
This Conflict Minerals Report of Control4 Corporation (“Control4”) has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (17 CFR 240.13p-1) (the “Rule”) promulgated by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to how companies source certain minerals as directed by the Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. These 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 currently 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 adjoining countries, namely the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company knows or has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, and may not be from recycled or scrap sources, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.
Company Overview
Control4 is a leading provider of personalized, smart home solutions that are designed to enhance the daily lives of its customers. Smart home solutions provide consumers with the ability to integrate audio, video, lighting, temperature, security, communications and other functionalities into a unified home-automation solution, customized to match their lifestyle, and Control4’s advanced software, delivered through our controller products, cloud services and user-interface products, powers this customized experience, enabling cohesive interoperability with thousands of connected Control4 and third-party devices in the home.
Description of the Products Covered by this Report
This Report relates to Control4’s products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were contracted to be manufactured by Control4; and (iii) for which the manufacture was completed during calendar year 2015. These products, which are referred to in this Report collectively as the “Covered Products,” are the following:
| · | | Controllers: These devices contain Control4’s proprietary software that serves as a central hub to connect and control connected Control4 and third-party devices throughout the home. Our controllers use a ZigBee transceiver and a WiFi transceiver to interface to the home network. |
| · | | Interfaces: Interface products include remote controls, mountable touch screens, and door station units. |
| · | | Audio/Visual Products: Audio/Visual products are designed to deliver audio and video to multiple rooms within a home automation system, and include amplifiers and audio matrix switches. |
| · | | Lighting: Lighting products include dimmers, relays, switches and configurable keypads and allow lighting control and automation throughout the home. |
| · | | Climate Control: Climate control products include thermostats and fireplace switches and integrate existing heating and cooling systems with the home automation system. |
Supply Chain Overview
Control4 does not directly manufacture any of its products, but instead relies on contract manufacturers to fabricate its products. Thus, Control4 is completely removed from the sourcing and mining of Conflict Minerals. We do not purchase the Conflict Minerals directly from mines, smelters or refiners. Control4’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals that are used to make the Covered Products’ component parts. Therefore, we must rely on our contract manufacturers and suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products as explained in greater detail below.
Reasonable Country-of-Origin Inquiry and Due Diligence Performed
Control4 has conducted a good faith RCOI regarding the Conflict Minerals that was designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Covered Countries and/or whether any of the Conflict Minerals may be from recycled or scrap
sources. The RCOI comprised the conduct described under the caption “Description of Due Diligence Measures -- Identify and Assess Risk in the Supply Chain” below. As a result of the RCOI, Control4 has reason to believe that a portion of the Conflict Minerals in its Covered Products may have originated in the “Covered Countries” and that these necessary Conflict Minerals may not be from recycled or scrap sources, so Control4 also performed due diligence on the source and chain of custody of the necessary Conflict Minerals. Control4 designed its due diligence process based on the due diligence framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, (the “OECD Framework”), and to be consistent with Control4’s distance in the supply chain from the direct procurement of Conflict Minerals.
Description of Due Diligence Measures
Control4 integrated OECD’s Five-Step Framework into its due diligence measures as described below.
1. Establish Strong Company Management Systems
Control4 has a policy regarding Conflict Minerals that outlines its commitment to promote responsible sourcing practices and to promote the use of conflict-free minerals in our supply chain (the “Policy”). This policy is available on our website at http://www.control4.com/legal/conflict-minerals-policy. Control4 formed a cross-organizational committee to help us comply with our obligations under the Rule. The committee includes representatives from our product, supply chain, legal and finance teams. The committee met periodically over the course of 2015 and into 2016 to review Control4’s supply chain with respect to our use of components containing Conflict Minerals in 2015. Members of Control4’s executive team had oversight responsibility for the work done by this committee. Committee members reviewed the Rule, the OECD Framework, and various other supplementary materials provided by third parties, including the Conflict-Free Smelter & Refiners information provided by the Conflict-Free Sourcing Initiative (“CFSI”), an initiative founded by the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”), as well as seeking advice from its outside auditors and legal counsel. The committee was responsible for communicating with our suppliers in order to encourage reporting, including completing and returning the Conflict Minerals Reporting Template (“Template”) created by CFSI. In addition, Control4 established an internal electronic database for maintenance of business records relating to Conflict Minerals due diligence, including supplier responses to our inquiries, as well as spreadsheets containing aggregate data. If any investor has any concern about Control4’s Conflict Minerals Policy or sourcing, they may contact our board of directors in the manner described at http://investor.control4.com/directors.cfm.
2. Identify and Assess Risk in the Supply Chain
As the first step in the good faith RCOI and due diligence process, Control4 identified the suppliers believed to be potentially providing products and components that contain Conflict Minerals (the “Identified Suppliers”), which excluded packaging suppliers and suppliers of other products which do not contain any components that could contain Conflict Minerals. We then sent a letter to each of our Identified Suppliers communicating Control4’s commitment to sourcing responsibly and outlining our expectation that they do the same. To help suppliers understand Control4’s expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness to Control4’s inquiry, Control4 provided suppliers with background information about the Rule and references to training materials and other informational resources.
Control4 requested that each Identified Supplier complete and return the Template, which provides a standardized method for companies to collect representations, statements and data from their suppliers related to the presence, use, source and chain of custody of the Conflict Mineral. We requested our Identified Suppliers to use the Template to identify the smelters and refiners in the supply chain, as well as the country and mine of origin, of the Conflict Minerals used in our Covered Products.
A total of 68 out of 99 suppliers were classified as Identified Suppliers and were contacted as part of the due diligence process. As of the date of this Report, out of 68 Identified Suppliers, Control4 has received responses from 47 of Identified Suppliers. In instances where an Identified Supplier failed to return a completed Template, committee members had follow-up discussions and/or sent repeat requests to insist on completion of the Template. Even after providing our suppliers with explanatory materials, instructions and/or follow-up, in a number of instances Control4 received incomplete information regarding the facilities utilized to process necessary Conflict Minerals in supplier parts, as well as insufficient information regarding the mines or sources of origin of those Conflict Minerals. Some suppliers responded generally on a company-wide basis when a more tailored response would have been more appropriate.
To the extent that Control4 was able to identify smelters and refiners that might be in the supply chain based on data provided by its Identified Suppliers, the committee took steps to assess the smelters’ or refiners’ due diligence to the extent practicable. Control4 has not conducted its own supply chain audits, but rather, has relied on the information provided by the Conflict-Free Smelter Program (“CFSP”) developed by the CFSI to help assess the due diligence conducted by the identified smelters and refiners and to assess or verify their conflict-free status. The CFSP identifies smelters and refiners that an independent third-party audit has confirmed have systems in place that comply with the CFSP’s assessment protocols to assure sourcing of only conflict-free minerals. In particular, we compared the smelters and refiners identified by Identified Suppliers
against the list of smelter and refinery facilities that received a “conflict free” designation through the CFSP.
3. Design and Implement a Strategy to Respond to Risk
Through its Policy, contract provisions and interaction with suppliers, Control4 encourages its suppliers to promote responsible sourcing practices for any Conflict Minerals used in our Covered Products. Control4 determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts, including where suppliers do not cooperate or ultimately do not source from smelters that have been designated as “conflict free” by the CFSP. Potential outcomes typically include continuing to work with the supplier while risks are addressed, but could also include reassessing the relationship with, including looking for alternative sources and restricting or terminating our relationship with, the supplier. As we assess these relationships, we will also take additional factors into consideration including supplier size and capabilities, whether alternatives are available and Control4’s dependence on the supplier.
4. Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
Control4 does not have any direct relationships with any smelters or refiners in its supply chain, and it did not perform or direct audits of any entity within its supply chain. As an alternative, the Company has relied on publically available information provided by independent third-party audit programs, such as the CFSP.
5. Report on Supply Chain Due Diligence
As required under the Rule, Control4 has filed our Form SD with the SEC for the 2015 Reporting Period, which contains this Report as an exhibit, and we have posted this Report at www.control4.com.
Due Diligence Outcome
Based on the information gathered in connection with our due diligence efforts, we do not have any basis at present for believing that any of the necessary Conflict Minerals in our products financed or benefitted armed groups in the Covered Countries. However, given that not all our suppliers responded to our inquiries and of those that did respond not all of the smelters identified were certified as “conflict free” by the CFSP and that a number of supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain, or unknown, overbroad, or incomplete, Control4 cannot determine that no necessary Conflict
Minerals in Covered Products did not finance or benefit, directly or indirectly, armed groups in the Covered Countries.
The statements above are based on the RCOI process and due diligence performed in good faith by Control4 as described above, but as noted, Control4 is a downstream entity, and does not purchase Conflict Minerals directly from mines, smelters or refiners. Tracing these minerals to their sources is a challenge that requires the Company to rely on its suppliers in its efforts to achieve supply chain transparency. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, incomplete product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers in their reporting, errors or omissions by smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries sourced materials being declared secondary materials, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.
Identified Smelters and Refiners
While some of Control4’s contract suppliers provided information for the particular products they supply to Control4, the majority provided this information on a company-wide basis. When the Identified Suppliers provided product-level information, Control4 has listed in Schedule 1 of this Report the smelters or refiners identified. However, with the exception of our largest supplier, Sanmina Corporation, when the Identified Suppliers provided only company-level information, Control4 determined that it did not have sufficient information to reasonably identify the particular smelter or refiner that processed the Conflict Minerals contained in the particular type of component in the Covered Products, and thus did not include the smelters or refiners in Schedule 1. In addition, the smelters and refiners listed on Schedule 1 include only those reported entities that were listed on the CFSI Standard Smelter List tab of the Template, because those are the only reported entities that Control4 was able to determine were smelters or refiners. Based solely on information provided by suppliers and the CFSP, of the 296 smelters and refiners identified on Schedule 1, 146 have been certified as “conflict free” by the CFSP, and an additional 66 of these smelters and refiners were previously certified as “conflict free” but the certifications have subsequently expired, with 28 of these 66 currently actively involved in the re-audit process.
Identified Countries of Origin of Necessary Conflict Minerals
Control4 has listed in Schedule 2 of this Report the countries of origin of the Necessary Conflict Minerals provided to us in the Templates of Identified Suppliers that reported product-level information and Sanmina Corporation, where such information was included.
Future Due Diligence and Risk Mitigation
Control4 expects to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the necessary Conflict Minerals in Control4’s products benefit armed groups in the Covered Countries, including:
1. Control4 intends to continue to work with contract manufacturers and suppliers that provided incomplete or insufficient information, or were unresponsive to the information request, in an effort to obtain complete and accurate information in 2016.
2. Control4 intends to request that contract manufacturers and suppliers complete the Templates by providing product- or component-specific information and provide responses that identify materials down to the smelter and countries of origin of the Conflict Minerals.
3. Control4 intends to engage in continuing education to employees who are involved with material, component and supplier selection.
Cautionary Note on Forward-looking Statements
This Report includes forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements other than statements of historical fact contained in this Report are forward-looking statements. These forward-looking statements are made as of the date they were first issued, and were based on the then-current expectations, estimates, forecasts, and projections, as well as the beliefs and assumptions of management. Forward-looking statements are subject to a number of risks and uncertainties, many of which involve factors or circumstances that are beyond Control4’s control. Control4’s actual actions or results could differ materially from those stated or implied in forward-looking statements due to a number of factors, including but not limited to, risks detailed in Control4’s most recent Annual Report on Form 10-K and subsequent reports filed with the Securities and Exchange Commission, as well as other documents that may be filed by the company from time to time with the Securities and Exchange Commission. Past performance is not necessarily indicative of future results. The forward-looking statements included in this Report represent Control4’s views as of the date this Report was filed with the
SEC. Control4 anticipates that subsequent events and developments may cause its views to change. Control4 has no intention and undertakes no obligation to update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise. These forward-looking statements should not be relied upon as representing Control4’s views as of any date subsequent to the date of filing of this Report.
Schedule 1
Smelter and Refiner Information
| | |
Metal | Standard Smelter Names | Smelter Facility Location: Country |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
Gold | Argor-Heraeus SA | SWITZERLAND |
Gold | Asahi Pretec Corporation | JAPAN |
Gold | Asahi Refining Canada Limited | CANADA |
Gold | Asahi Refining USA Inc. | UNITED STATES |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Aurubis AG | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Bauer Walser AG | GERMANY |
Gold | Boliden AB | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Cendres + Métaux SA | SWITZERLAND |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DODUCO GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Elemetal Refining, LLC | UNITED STATES |
Gold | Faggi Enrico S.p.A. | ITALY |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Geib Refining Corporation | UNITED STATES |
Gold | Great Wall Gold and Silver Refinery of China | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Ltd. Hong Kong | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Company Limited | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Company Limited | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies SA | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP SA | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox SA | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint | CANADA |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyería Platería SA | SPAIN |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN |
Gold | So Accurate Group, Inc. | UNITED STATES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Sudan Gold Refinery | SUDAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Valcambi SA | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES |
Tantalum | Duoluoshan | CHINA |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck GmbH Goslar | GERMANY |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | KEMET Blue Powder | UNITED STATES |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineração Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining & Smelting | JAPAN |
Tantalum | Molycorp Silmet A.S. | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Plansee SE Liezen | AUSTRIA |
Tantalum | Plansee SE Reutte | AUSTRIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | Resind Indústria e Comércio Ltda | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | JAPAN |
Tantalum | Telex Metals | UNITED STATES |
Tantalum | Tranzact, Inc. | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tantalum | Zhuzhou Cemented Carbide | CHINA |
Tin | Alpha | UNITED STATES |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Gita Pesona | INDONESIA |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Dowa | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
Tin | EM Vinto | BOLIVIA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Feinhütte Halsbrücke GmbH | GERMANY |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S/A | BRAZIL |
Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
Tin | Metallic Resources, Inc. | UNITED STATES |
Tin | Metallo-Chimique N.V. | BELGIUM |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgical S.A. | BOLIVIA |
Tin | Phoenix Metal Ltd. | RWANDA |
Tin | PT Alam Lestari Kencana | INDONESIA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Bangka Kudai Tin | INDONESIA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT BilliTin Makmur Lestari | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT Cipta Persada Mulia | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | PT Fang Di MulTindo | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Justindo | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | PT Seirama Tin Investment | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | PT Tirus Putra Mandiri | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | PT Wahana Perkit Jaya | INDONESIA |
Tin | Resind Indústria e Comércio Ltda | BRAZIL |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | VQB Mineral and Trading Group JSC | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck GmbH | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Niagara Refining LLC | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
Schedule 2
Countries of Origin
Australia |
Austria |
Belgium |
Bolivia |
Brazil |
Canada |
Chile |
China |
Ethiopia |
Germany |
India |
Indonesia |
Japan |
Korea |
Malaysia |
Mexico |
Mozambique |
Namibia |
Peru |
Portugal |
Russia |
Rwanda1 |
Sierra Leone |
Spain |
Switzerland |
Taiwan |
Thailand |
United States |
Zimbabwe |
1 Where the Democratic Rwanda was identified as the country of origin, Control4confirmed that the identified smelter or refiner was certified as “conflict-free” by the CFSP.