Exhibit 1.02
Windstream Holdings, Inc.
Windstream Corporation
Conflict Minerals Report
For the Year ended December 31, 2013
This report for the year ended December 31, 2013, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”) for the purposes of this report.
If a registrant can establish that the conflict minerals originated from sources other than the Democratic Republic of the Congo (“DRC”) or adjoining countries (collectively, with the DRC, the “Covered Countries”), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry (“RCOI”) completed.
If a registrant has reason to believe that any conflict minerals in its supply chain may have originated in the Covered Countries, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report, to the SEC that includes a description of those due diligence measures.
The report presented herein has not been subject to an independent private sector audit as allowed by the Rule which provides a temporary accommodation for the first two years.
Company Overview
This report has been prepared by management of Windstream Holdings, Inc. (“Windstream Holdings”) and Windstream Corporation (“Windstream Corp.”). Unless the context indicates otherwise, the terms “Windstream,” “we,” or “our” refer to Windstream Holdings and its subsidiaries, including Windstream Corp.
Windstream is a leading provider of advanced network communications, including cloud computing and managed services, to businesses nationwide. We also offer broadband, phone and digital TV services to consumers primarily in rural areas. We offer a robust portfolio of services and products to meet the communication and technology needs of our customers. Our basic offerings are classified in the following categories: business, consumer, wholesale and other. Our key business service offerings include: integrated voice and data services, multi-site networking, data center services, managed services, high-speed Internet, voice, and carrier services. Our consumer services primarily consist of high-speed Internet, voice and video services. Our wholesale offerings include switched access services provided to long-distance companies and other local exchange carriers for access to our network in connection with the completion of long-distance calls.
To provide the services above, Windstream typically sources customer premise network and communication equipment from outside suppliers. However, with the acquisition of PAETEC Holding Corp. (“PAETEC”) in 2011, Windstream acquired Allworx Corp. (“Allworx”), a wholly-owned subsidiary of PAETEC. Allworx designs and supports its own customer premise equipment that is manufactured by two contract manufacturers. This equipment, primarily VoIP phones and PBX servers (“Allworx CPE”), is comprised of components that contain 3TG, and these components are sourced by the contract manufacturers. Windstream does not make direct purchases of raw ore or unrefined conflict minerals and makes no direct purchases in the Covered Countries. Allworx CPE sales accounted for less than 1.0 percent of Windstream’s overall revenue for the year ended December 31, 2013.
Accordingly, for the purposes of this report only the direct suppliers of these two contract manufacturers were considered.
Supply Chain Overview
Windstream relies upon our suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from sub-tier suppliers. Our suppliers are expected to provide the 3TG sourcing information to us.
In addition, Windstream has performed a comprehensive analysis of our products, and the role that suppliers play throughout our manufacturing and product delivery processes. We defined the scope of our conflict minerals due diligence by
identifying and reaching out to our suppliers that engage in manufacturing activities that are likely to contain 3TG. We worked closely with the contract manufacturers identified to launch our conflict minerals due diligence communication survey to their direct suppliers using either the standard Conflict Minerals Reporting Template established by the Conflict-Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative, or a simplified version of the template.
Due Diligence Process
Windstream undertook due diligence to determine the conflict minerals status of the necessary conflict minerals used in the Allworx CPE. Our due diligence processes and efforts have been developed in conjunction with the 2nd edition of The Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold and for tin, tantalum and tungsten.
Our conflict minerals due diligence process includes: establishment of an internal cross functional team, communication to, and engagement of, suppliers, due diligence compliance process and measurement, record keeping and escalation procedures. Our internal cross functional team includes a team of subject matter experts from relevant functions such as, purchasing, quality assurance, manufacturing and external reporting. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by our Senior Consultant of External Reporting. Windstream’s Disclosure Committee comprised of members of executive and senior management and the Audit Committee of the Board of Directors are briefed about the results of our due diligence efforts on a regular basis.
We have engaged a third-party data collection vendor, GreenSoft Technology, Inc., to conduct outreach and archive the received supplier responses to our RCOI for one of our two manufacturers. We worked closely with the other manufacturer to develop a survey, provide training, conduct outreach, and summarize results. The smelters and refiners identified in the supply chain survey were compared to the list of smelter and refining facilities which have been identified as “conflict free” by the CFSI's Conflict Free Smelter Program (“CFSP”) for tantalum, tin, tungsten and gold. Through the CFSP validation process, which is voluntary, an independent third party audits the procurement and processing activities of a smelter or refiner to determine if it showed sufficient documentation to demonstrate with reasonable confidence that the minerals the smelter or refiner processed originated from conflict free sources. CFSP-compliant smelters and refiners receive a “conflict free” designation from CFSI. The results of these processes are described below.
We do not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain the 3TG. However, we do rely upon the industry (for example, EICC and CFSI) efforts to influence smelters and refineries to get audited and certified through the CFSP.
Limitations on RCOI Efforts and Due Diligence Measures
Our RCOI efforts and due diligence measures are inherently limited. For example, because of our size, the breadth and complexity of our products, and the constant evolution of our supply chain, it is difficult to identify parties downstream from our contract manufacturers. Similarly, because we do not make direct purchases of raw ore or unrefined conflict minerals nor have direct contractual relationships with smelters and refiners, our RCOI efforts and due diligence processes rely on suppliers’ responses to our supply chain survey for information about the source of conflict minerals contained in the components supplied to us, and these suppliers are similarly reliant upon information provided by their suppliers. We also rely, to a large extent, on information collected and provided by third parties and third-party audit programs, like CFSI and CFSP. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud. As a result of the these and other limitations, our RCOI efforts and due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals.
RCOI and Due Diligence Results
As stated above, we conducted a supply chain survey of the direct suppliers of our contract manufacturers to obtain country of origin information for the necessary conflict minerals in the Allworx CPE. The supply chain survey requested the suppliers to identify the smelters, refineries, or recyclers and scrap supplier sources, as well as countries of origin of the conflict minerals in products they supply. We also leveraged data from CFSI and the CFSP to trace the mine of origin of the 3TG to its ore level and compared the smelters and refiners identified in the surveys against the lists of facilities which have received a “conflict free” designation by the CFSP, which provides country of origin information on the conflict minerals sourced by such facilities. Based on this RCOI, we know or have reason to believe that a portion of the necessary conflict minerals in the Allworx CPE originated or may have originated in the Covered Countries and, we know or have reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources.
Below is a summary of the country of origin information collected as a result of our RCOI efforts, as well as the results of the measures we performed for the reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products that we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources.
We have identified 106 direct suppliers to our contract manufacturers of the Allworx CPE. Of these suppliers, we received 100 responses to our supply chain survey. Among the 100 responses received, 5 of the direct suppliers to our contract manufacturers have indicated that they source at least 1 of the 3TG from the Covered Countries. Of these, 4 have indicated that their smelters and refiners, who are located outside the DRC, have been validated as CFSP compliant. The status of compliance with the CFSP for the other supplier was undeterminable at the time the survey was completed.
As the result of our due diligence, we have identified 293 smelters and refineries within our supply chain. Among these 293 smelters and refineries, 68 are on CFSI's list of CFSP-compliant smelters and refineries and considered to be conflict free, and with respect to the other 225, the CFSI has not provided an opinion as whether or not the minerals procured from these smelters and refineries originate from the Covered Countries.
We determined that certain components used in the Allworx CPE contain 3TG, which originated in the following countries: Argentina, Australia, Belgium, Bolivia, Brazil, Canada, Chile, China, DRC, Ethiopia, Germany, India, Indonesia, Japan, Kazakhstan, Korea, Malaysia, Mexico, Mozambique, Papua New Guinea, Peru, Portugal, Russia, Rwanda, South Africa, Spain, Switzerland, Taiwan, Thailand, United States of America, and Zimbabwe.
Smelters have been identified as being located in the following countries: Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Czech Republic, France, Germany, Hong Kong, Indonesia, Italy, Japan, Kazakhstan, Korea, Kyrgyzstan, Malaysia, Mexico, Netherlands, Peru, Philippines, Poland, Russia, Saudi Arabia, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, United Kingdom, United States of America, Uzbekistan, and Vietnam.
Set forth below is the list of smelters and refiners identified within our supply chain during 2013 as of March 31, 2014. For more details and the most current status of each smelter, please visit the CFSI website at www.conflictfreesourcing.org.
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| | Smelters | Metal |
| | Aida Chemical Industries Co. Ltd. | Gold |
| * | Allgemeine Gold- und Silberscheideanstalt A.G. | Gold |
| | Almalyk Mining and Metallurgical Complex (AMMC) | Gold |
| * | AngloGold Ashanti Mineração Ltda | Gold |
| * | Argor-Heraeus SA | Gold |
| | Asahi Pretec Corporation | Gold |
| | Asaka Riken Co.,Ltd. | Gold |
| | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold |
| | Aurubis AG | Gold |
| | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold |
| | Boliden AB | Gold |
| | Caridad | Gold |
| | Cendres & Métaux SA | Gold |
| | Central Bank of the DPR of Korea | Gold |
| * | Chimet SpA | Gold |
| | China's Nonferrous Mining Group Co., Ltd. | Gold |
| | Chugai Mining Co., Ltd. | Gold |
| | Codelco | Gold |
| | Daejin Indus Co. Ltd | Gold |
| | DaeryongENC | Gold |
| | Do Sung Corporation | Gold |
| | Dong Guan Shi Jing | Gold |
| | Dongguanshi Sutande Dianzi Cailiao Youxiangongsi | Gold |
| * | Dowa | Gold |
| | Echememi Enterprise Corp. | Gold |
| | Eco-System Recycling Co., Ltd. | Gold |
| | FSE Novosibirsk Refinery | Gold |
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| | Smelters | Metal |
| | Geiju Non-Ferrous Metal Processing Co. Ltd. | Gold |
| | Gold and Silver Refining Strokes Ltd. | Gold |
| | Guang Dong Jing Ding Co., Ltd. | Gold |
| | Harima Smelter | Gold |
| | Heesung Catalysts Corp. | Gold |
| | Heimerle + Meule GmbH | Gold |
| * | Heraeus Ltd Hong Kong | Gold |
| * | Heraeus Precious Metals GmbH & Co. KG | Gold |
| | Hung Cheong Metal Manufacturing Limited | Gold |
| | Hwasung CJ Co. Ltd. | Gold |
| | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Gold |
| * | Ishifuku Metal Industry Co., Ltd. | Gold |
| * | Istanbul Gold Refinery | Gold |
| | Japan Mint | Gold |
| | Jiangxi Copper Company Limited | Gold |
| | Jinlong Copper Co.,Ltd. | Gold |
| | Johnson Matthey HongKong Ltd. | Gold |
| * | Johnson Matthey Inc. | Gold |
| | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold |
| | JSC Uralectromed | Gold |
| * | JX Nippon Mining & Metals Co., Ltd. | Gold |
| | Kazzinc Ltd | Gold |
| * | Kennecott Utah Copper | Gold |
| * | Kojima Chemicals Co. Ltd. | Gold |
| | Korea Metal Co. Ltd. | Gold |
| | Kyrgyzaltyn JSC | Gold |
| | L' azurde Company For Jewelry | Gold |
| | LG-Nikko | Gold |
| | London Bullion Market Association | Gold |
| * | LS-Nikko Copper Inc | Gold |
| | Malaysia Smelting Corp | Gold |
| * | Materion Advanced Metals | Gold |
| * | Matsuda Sangyo Co. Ltd. | Gold |
| * | Metalor Technologies (Hong Kong) Ltd. | Gold |
| * | Metalor Technologies SA | Gold |
| * | Metalor Technologies Singapore Pte Ltd. | Gold |
| * | Metalor USA Refining Corporation | Gold |
| | Met-Mex Peñoles, S.A. | Gold |
| * | Mitsubishi Materials Corporation | Gold |
| * | Mitsui Mining & Smelting | Gold |
| | MK electron | Gold |
| | Moscow Special Alloys Processing Plant | Gold |
| | N.E.Chemcat Corporation | Gold |
| | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Gold |
| | Nankang Metal Material Co. Ltd. | Gold |
| | Navoi Mining and Metallurgical Combinat | Gold |
| * | Nihon Material Co. Ltd. | Gold |
| | Niihama Nickel Refinery | Gold |
| | Ningbo Kangqiang | Gold |
| * | Ohio Precious Metals LLC. | Gold |
| | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” | Gold |
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| | Smelters | Metal |
| | OJSC Kolyma Refinery | Gold |
| | Orelec | Gold |
| * | PAMP SA | Gold |
| | Pan Pacific Copper Co. Ltd. | Gold |
| | Prioksky Plant of Non-Ferrous Metals | Gold |
| | PT Aneka Tambang (Persero) Tbk | Gold |
| | PT Koba Tin | Gold |
| | PT Tambang Timah | Gold |
| | PT Timah | Gold |
| | PX Précinox SA | Gold |
| * | Rand Refinery (Pty) Ltd. | Gold |
| * | Royal Canadian Mint | Gold |
| | Sabin Metal Corp. | Gold |
| | Safina a.s. | Gold |
| | Samwon Metals Corp. | Gold |
| | Schone Edelmetaal | Gold |
| * | SEMPSA Joyeria Plateria SA | Gold |
| | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold |
| | Shang Hai Gold Exchange | Gold |
| | Shanghai Gold Exchange | Gold |
| | So Accurate Refining Group | Gold |
| | SOE Shyolkovsky Factory of Secondary Precious Metals | Gold |
| * | Solar Applied Materials Technology Corp. | Gold |
| * | Sumitomo Metal Mining Co. Ltd. | Gold |
| | Suzhou Xingrui Noble | Gold |
| * | Tanaka Kikinzoku Kogyo K.K. | Gold |
| | Thaisarco | Gold |
| | The Great Wall Gold and Silver Refinery of China | Gold |
| | The Refinery of Shandong Gold Mining Co. Ltd. | Gold |
| * | Tokuriki Honten Co. Ltd | Gold |
| | Tongling Nonferrous Metals Group Holdings Co.,Ltd. | Gold |
| | Torecom | Gold |
| | Umicore Brasil Ltda | Gold |
| * | Umicore SA Business Unit Precious Metals Refining | Gold |
| * | United Precious Metal Refining, Inc. | Gold |
| * | Valcambi SA | Gold |
| * | Western Australian Mint trading as The Perth Mint | Gold |
| * | Xstrata Canada Corporation | Gold |
| | Yamamoto Precious Metal Co., Ltd. | Gold |
| | Yantai Zhaojin Kanfort Precious Metals Co., Ltd. | Gold |
| | Yokohama Metal Co Ltd. | Gold |
| | Yunnan Chengfeng | Gold |
| | Yunnan Metallurgical Group Co., Ltd. | Gold |
| | Yunnan Tin Company Group Limited | Gold |
| | Zhaojin Mining Industry Co., Ltd. | Gold |
| | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Gold |
| | Zijin Mining Group Co. Ltd. | Gold |
| | Changsha Southern | Tantalum |
| * | Conghua Tantalum and Niobium Smeltry | Tantalum |
| * | Duoluoshan | Tantalum |
| * | Exotech Inc. | Tantalum |
| * | F&X | Tantalum |
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| | Smelters | Metal |
| | Gannon & Scott | Tantalum |
| * | Global Advanced Metals | Tantalum |
| * | H.C. Starck GmbH | Tantalum |
| * | Hi-Temp | Tantalum |
| | JiuJiang JinXin Nonferrous Metals Co. Ltd. | Tantalum |
| * | JiuJiang Tambre Co. Ltd. | Tantalum |
| * | KEMET Blue Metals | Tantalum |
| * | Kemet Blue Powder | Tantalum |
| * | LMS Brasil S.A. | Tantalum |
| * | Mitsui Mining & Smelting | Tantalum |
| * | Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum |
| * | Plansee | Tantalum |
| * | RFH | Tantalum |
| | Shanghai Jiangxi Metals Co., Ltd. | Tantalum |
| * | Solikamsk Metal Works | Tantalum |
| * | Taki Chemicals | Tantalum |
| * | Tantalite Resources | Tantalum |
| * | Telex | Tantalum |
| * | Ulba | Tantalum |
| * | Zhuzhou Cement Carbide | Tantalum |
| | 5N Plus | Tin |
| | Alpha Metals Korea Ltd. | Tin |
| | Amalgamated Metal Corporation | Tin |
| | American Iron and Metal | Tin |
| | An Xin Xuan Xin Yue You Se Jin Shu Co. Ltd. | Tin |
| | Aoki Loboratories Ltd. | Tin |
| | BALVER ZINN Josef Jost GmbH & Co.KG | Tin |
| | Bangka | Tin |
| | Beijing Oriental Guide Welding Materials Co., Ltd. | Tin |
| | CFC Cooperativa dos Fundidores de Cassiterita da Amazonia Ltda. | Tin |
| | China Tin Smelter Co. Ltd. | Tin |
| | China YunXi mining | Tin |
| | CNMC (Guangxi) PGMA Co. Ltd. | Tin |
| * | Cookson | Tin |
| | Cookson Alpha Metals(Shenzhen)Co. Ltd. | Tin |
| | Cooper Santa | Tin |
| | COOPERMETAL - Cooperative Metalurgica de Rondonia Ltda. | Tin |
| | CV Duta Putra Bangka | Tin |
| | CV JusTindo | Tin |
| | CV Makmur Jaya | Tin |
| | CV Nurjanah | Tin |
| | CV Prima Timah Utama | Tin |
| | CV Serumpun Sebalai | Tin |
| | CV United Smelting | Tin |
| | EM Vinto | Tin |
| | Feinhütte Halsbrücke GmbH | Tin |
| | Fenix Metals | Tin |
| | FSE Novosibirsk Refinery | Tin |
| | Furukawa Electric | Tin |
| * | Geiju Non-Ferrous Metal Processing Co. Ltd. | Tin |
| | Gejiu Gold Smelter Minerals Co., Ltd. | Tin |
| | Gejiu Zi-Li | Tin |
| | Gold Bell Group | Tin |
| | Gomat-e-K. | Tin |
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| | Smelters | Metal |
| | Guangxi Huaxi Group Limited | Tin |
| | Heesung Metal Ltd. | Tin |
| | Heraeus Materials Singapore Pte, Ltd. | Tin |
| | Heraeus Oriental Hitec Co., Ltd. | Tin |
| | Heraeus Precious Metals GmbH & Co. KG | Tin |
| | Hitachi Cable | Tin |
| | HL Thorne | Tin |
| | Huaxi Guangxi Group | Tin |
| | Huichang Jinshunda Tin Co. Ltd. | Tin |
| | Huichang Shun Tin Kam Industries, Ltd. | Tin |
| | IBF IND Brasileira de Ferrolligas Ltda | Tin |
| | Jean Goldschmidt International | Tin |
| | Jiangxi Copper Company Limited | Tin |
| | Jiangxi Nanshan | Tin |
| | Kaimeng(Gejiu) Industry and Trade Co., Ltd. | Tin |
| | KIHONG T & G | Tin |
| | Kovohute Pribram Nastupnicka, A.S. | Tin |
| | Kupol | Tin |
| | Laibin China Tin Smelting Co., Ltd. | Tin |
| | Linwu Xianggui Smelter Co | Tin |
| | Liuzhou China Tin | Tin |
| * | Malaysia Smelting Corp | Tin |
| | Metahub Industries Sdn. Bhd. | Tin |
| | Metallic Resources Inc | Tin |
| | Metallo Chimique | Tin |
| * | Mineração Taboca S.A. | Tin |
| | Minmetals Ganzhou Tin Co. Ltd. | Tin |
| * | Minsur | Tin |
| * | Mitsubishi Materials Corporation | Tin |
| | Nankang Nanshan Tin Manufactory Co., Ltd. | Tin |
| | Nathan Trotter & Co | Tin |
| | Nihon Kagaku Sangyo Co., Ltd. | Tin |
| | Novosibirsk Integrated Tin Works | Tin |
| * | OMSA | Tin |
| | PT Alam Lestari Kencana | Tin |
| | PT Artha Cipta Langgeng | Tin |
| | PT Babel Inti Perkasa | Tin |
| | PT Babel Surya Alam Lestari | Tin |
| | PT Bangka Kudai Tin | Tin |
| | PT Bangka Putra Karya | Tin |
| | PT Bangka Timah Utama Sejahtera | Tin |
| | PT Bangka Tin Industry | Tin |
| | PT Belitung Industri Sejahtera | Tin |
| | PT BilliTin Makmur Lestari | Tin |
| * | PT Bukit Timah | Tin |
| | PT DS Jaya Abadi | Tin |
| | PT Eunindo Usaha Mandiri | Tin |
| | PT Fang Di MulTindo | Tin |
| | PT HP Metals Indonesia | Tin |
| | PT Indra Eramulti Logam Industri | Tin |
| | PT Koba Tin | Tin |
| | PT Mitra Stania Prima | Tin |
| | PT Refined Banka Tin | Tin |
| | PT Sariwiguna Binasentosa | Tin |
| | PT Stanindo Inti Perkasa | Tin |
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| | Smelters | Metal |
| | PT Sumber Jaya Indah | Tin |
| * | PT Tambang Timah | Tin |
| * | PT Timah | Tin |
| | PT Timah Nusantara | Tin |
| | PT Tinindo Inter Nusa | Tin |
| | PT Yinchendo Mining Industry | Tin |
| | PT Citralogam Alphasejahtera | Tin |
| | Rui Da Hung | Tin |
| | Senju Metal Industry Co., Ltd. | Tin |
| | Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co. Ltd. | Tin |
| | ShangHai YueQiang Metal Products Co., Ltd. | Tin |
| | Singapore LME Tin | Tin |
| | Sinitron, Shenmao Solder (M) Sdn. Bhd. | Tin |
| | Sundwigger Messingwerk | Tin |
| | Taicang City Nancang Metal Material Co.,Ltd. | Tin |
| * | Thaisarco | Tin |
| | The Miller Company | Tin |
| | Tianshui Longbo Business & Trade Co., Ltd. | Tin |
| | Tongding Metallic Material Co., Ltd. | Tin |
| | Traxys | Tin |
| | WC Heraeus Hanau | Tin |
| | Westfalenzinn | Tin |
| | White Solder Metalurgia | Tin |
| | Wu Xi Shi Yi Zheng Ji Xie She Bei Company | Tin |
| | Wuxi Lantronic Electronic CO.,Ltd. | Tin |
| | Yokohama Metal Co Ltd | Tin |
| | Yunnan Chengfeng | Tin |
| | Yunnan Chengo Electric Smelting Plant | Tin |
| | YunNan Gejiu Yunxin Electrolyze Limited | Tin |
| * | Yunnan Tin Company Group Limited | Tin |
| | Zhejiang Huangyan Xinqian Electrical Equipment Fittings | Tin |
| | Zhuhai Quanjia | Tin |
| | A.L.M.T. Corp. | Tungsten |
| | Alldyne Powder Technologies | Tungsten |
| | ALMT | Tungsten |
| | Alta Group | Tungsten |
| | ATI Tungsten Materials | Tungsten |
| | Chaozhou Xianglu Tungsten IND Co., LTD. | Tungsten |
| | China Minmetals Nonferrous Metals Co Ltd. | Tungsten |
| | Chongyi Zhangyuan Tungsten Co Ltd. | Tungsten |
| | Dayu Weiliang Tungsten Co., Ltd. | Tungsten |
| | Fujian Jinxin Tungsten Co., Ltd. | Tungsten |
| | Ganzhou Grand Sea W & Mo Group Co Ltd. | Tungsten |
| | Ganzhou Hongfei Tungsten & Molybdenum Materials Co., Ltd. | Tungsten |
| | Ganzhou Huaxing Tungsten Products Co., Ltd. | Tungsten |
| | Ganzhou Nonferrous Metals smelting Co Ltd. | Tungsten |
| | Ganzhou sinda W&Mo Co.,Ltd. | Tungsten |
| | Global Tungsten & Powders Corp | Tungsten |
| | H.C. Starck GmbH | Tungsten |
| | Hitachi Ltd. | Tungsten |
| | Hunan Chenzhou Mining Group Co | Tungsten |
| | Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | Tungsten |
| | Jada Electronic limited (JX Nippon Mining&Matel Co., Ltd) | Tungsten |
| | Japan New Metals Co Ltd. | Tungsten |
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| | Smelters | Metal |
| | Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | Tungsten |
| | JX Nippon Mining & Metals Co., Ltd | Tungsten |
| | Kanto Denka Kogyo Co., Ltd. | Tungsten |
| | Kennemetal Inc | Tungsten |
| | Kyoritsu Gokin Co., Ltd. | Tungsten |
| | Minmetals Ganzhou Tin Co., Ltd. | Tungsten |
| | Nanchang Cemented Carbide Limited Liability Company | Tungsten |
| | NingHua XingLuoKeng TungSten Mining CO.,LID | Tungsten |
| | North American Tungsten | Tungsten |
| | Plansee | Tungsten |
| | Sumitomo Metal Mining Co. Ltd. | Tungsten |
| | TaeguTec | Tungsten |
| | Tejing (Vietnam) Tungsten Co Ltd. | Tungsten |
| | Tosoh | Tungsten |
| | Wolfram Bergbau und Hütten AG | Tungsten |
| | Wolfram Company CJSC | Tungsten |
| | Xiamen Golden Egret Special Alloy Co. Ltd. | Tungsten |
| | Xiamen Honglu Tungsten Molybdenum Industry Co., Ltd. | Tungsten |
| | Xiamen Tungsten Co Ltd | Tungsten |
| | Zhuzhou Cement Carbide | Tungsten |
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| * | Indicates smelters and refiners which have received a “conflict free” designation from the CFSP. |
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Future Due Diligence Measures
Due to the breadth and complexity of our products and respective supply chain, it will take time for many of our suppliers toverify the origin of all of the minerals. Using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard CFSI/CFSP, and continuing our outreach efforts, we hope to further develop transparency into our supply chain.
As we move towards further developing our due diligence program, we intend to take the following steps to continue to mitigate any possible risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:
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| • | Enhance supplier communication to improve the response rate and accuracy of suppliers’ smelters surveys to determine conflict mineral status. |
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| • | Identify suppliers utilizing non-CFSP compliant smelters and remove them from the approved vendor list until such time as they become CFSP compliant. |
