CONFLICT MINERALS REPORT OF RUCKUS WIRELESS, INC.
FOR THE REPORTING PERIOD FROM JANUARY 1, 2015 TO DECEMBER 31, 2015
Background
This Conflict Minerals Report of Ruckus Wireless, Inc. (“Ruckus”) for calendar year 2015 (the “Reporting Period”) has been prepared in accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934 (the “Rule”). 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 (“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. The specified minerals, which are collectively referred 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 adjoining countries, which currently include 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 has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.
As described in this Report, certain of Ruckus’ operations contract to manufacture products and Conflict Minerals are necessary to the functionality or production of those products.
Company Overview
Ruckus is a global supplier of advanced Wi-Fi solutions. Ruckus’ solutions, referred to as Smart Wi-Fi, are used by service providers and enterprises to solve a range of network capacity, coverage and reliability challenges associated with increasing wireless traffic demands created by the growth in the number of users equipped with more powerful smart wireless devices and using increasingly data rich applications and services. Ruckus markets and sells its products and technology directly and indirectly through a vast network of channel partners to a variety of service providers and enterprises around the world. Ruckus’ Smart Wi-Fi solutions offer features and functionalities such as enhanced reliability, consistent performance, extended range, and massive scalability. Ruckus’ products include high capacity controllers, indoor and outdoor access points, wireless bridges, controller software platforms, software management solutions including reporting and analytics and unique Wi-Fi-related cloud services, such as location-based positioning, and certificate-based security and onboarding of Wi-Fi devices. These hardware and software products and cloud services incorporate various elements of Ruckus’ proprietary technologies, including Smart Radio, SmartCast, SmartMesh and Smart Scaling, to enable high performance in a variety of challenging operating environments.
Description of the 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 Ruckus; 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: SmartZone controllers, ZoneDirector controllers, ZoneFlex access points, Unleashed access points and Xclaim access points.
Supply Chain Overview
All of Ruckus’ products are either manufactured by contract manufacturers or otherwise purchased by Ruckus from third parties for resale. As a purchaser, Ruckus is many steps removed from the mining of Conflict Minerals; Ruckus does not purchase raw ore or unrefined Conflict Minerals, and does no purchasing in the Covered Countries. Ruckus’ 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. In this regard, Ruckus does not
purchase the Conflict Minerals directly from mines, smelters or refiners. As explained further below, Ruckus must therefore rely on its contract manufacturers and suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products.
Reasonable Country-of-Origin Inquiry
Ruckus has conducted a good faith RCOI regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products (the “Necessary Conflict Minerals”). This RCOI was reasonably designed to determine whether any of the Necessary Conflict Minerals originated in the Covered Countries and whether any of the necessary 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. Because, as a result of the RCOI, Ruckus knows or has reason to believe that a portion of its Necessary Conflict Minerals originated or may have originated in the “Covered Countries” and knows or has reason to believe that those Necessary Conflict Minerals may not be from recycled or scrap sources, Ruckus also performed due diligence on the source and chain of custody of the Necessary Conflict Minerals to seek to determine whether or not the Covered Products were “DRC conflict free” (i.e., that the Necessary Conflict Minerals in the Covered Products either came from recycled or scrap sources or did not directly or indirectly finance or benefit armed groups in the Covered Countries).
Due Diligence Performed
Design of Due Diligence
Ruckus designed its due diligence measures to be in conformity with, in all material respects, the internationally recognized 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, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Framework”), consistent with Ruckus’ position as a downstream company. Ruckus integrated the five-step OECD Framework into its due diligence measures as described below.
Description of Due Diligence Measures
Ruckus’ due diligence measures performed with respect to Covered Products included the following:
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| 1. | OECD Step 1 - Establish Strong Company Management Systems |
Conflict Minerals policy. Ruckus adopted a policy statement regarding Conflict Minerals that outlines its commitment to sourcing products from suppliers that conduct business in a socially responsible and ethical manner. This statement is available on Ruckus’ website at www.ruckuswireless.com under “Investors - Corporate Governance,” and contract manufacturers and suppliers are expected to follow this policy and provide Ruckus with conflict-free parts and products. In addition, in connection with Ruckus’ outreach described below, a letter communicating Ruckus’ commitment to sourcing responsibly was sent to contract manufacturers and suppliers.
Conflict Minerals team. Ruckus formed a committee consisting of individuals from the operations team as well as the legal team to review Ruckus’ supply chain for Conflict Minerals. The committee met periodically over the course of 2015 and into 2016 to review Ruckus’ supply chain for Conflict Minerals for 2015. The executive team at Ruckus had oversight responsibility for the work done by the committee and fully supported the committee’s efforts. The committee reported to the executive team as needed. Committee members have been trained regarding the Rule, Conflict Minerals and properly reviewing and validating supplier responses, and consulted with outside advisors regarding certain aspects of Ruckus’ efforts to comply with the Rule. In addition, Ruckus engaged a third-party service provider (Source Intelligence) to, among other things: assist the committee with management of supplier engagement; collect, process and store data from supplier responses through its online platform; work with the committee to review and validate supplier responses; and enhance the committee’s quality assurance processes by helping to identify and resolve quality control flags. As discussed in more detail below, the committee worked collaboratively with Source Intelligence in connection with its due diligence efforts.
System of controls and transparency. In addition, in an effort to enhance its due diligence processes and improve the accuracy and completeness of supplier data, the committee worked with Source Intelligence to agree on and document internal standard operating procedures for scoping suppliers, conducting supplier outreach and follow-up, reviewing supplier responses, escalating to the committee issues related to non-responsive suppliers and data quality control and addressing such issues. Source Intelligence maintained an online data collection platform for Ruckus including the status of supplier outreach, records of supplier responses,
validation of responses, and information relating to quality control efforts. The committee regularly reviewed and monitored the online platform and collaborated with Source Intelligence throughout the due diligence process, including via weekly meetings.
Strengthen engagement with suppliers. To help suppliers understand Ruckus’ expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness to Ruckus’ inquiry, Ruckus provided suppliers with background information about the Rule. In addition, suppliers were offered access to an online “Supplier Resource Center” maintained by Source Intelligence that included tools to facilitate a deeper understanding of Ruckus’ compliance program and why the information was being requested, including links to multi-lingual training materials and other informational resources. Representatives of Source Intelligence also offered assistance to suppliers over the phone as needed in connection with the follow-up outreach described below.
Establish a company grievance mechanism. Ruckus maintains a whistleblower hotline that is available to report, confidentially and anonymously, violations of company policies or other illegal or unethical behavior, online at www.ruckuswireless.ethicspoint.com or by phone at (888) 581-2151 (a toll-free number for calls from outside of the United States or Canada can be obtained by visiting www.ruckuswireless.ethicspoint.com). Concerned parties who wish to report information regarding Ruckus’ sourcing and use of Conflict Minerals in its products can do so through this existing hotline.
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| 2. | OECD Step 2 - Identify and Assess Risk in the Supply Chain |
To identify risks in Ruckus’ supply chain, the committee relied on contract manufacturers and suppliers to provide information on the origin of the Conflict Minerals contained in components that are included in the Covered Products. The committee engaged Source Intelligence to ask each contract manufacturer of the Covered Products, as well as all component suppliers on Ruckus’ approved vendor list for such products (but excluding packaging, documentation and labeling suppliers) to complete the Conflict Minerals Reporting Template (“Template”) developed by the Conflict-Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition Global e-Sustainability Initiative (“EICC-GeSI”). Ruckus considered these contract manufacturers and suppliers to be “in scope” for purposes of its assessment.
The Template provided a standardized method for Ruckus to use in the collection of representations, statements and data from Ruckus’ contract manufacturers and suppliers related to the presence, use, source and chain of custody of the Conflict Minerals in supplier parts that are incorporated in the Covered Products. The Template requested contract manufacturers and suppliers to include the country of origin of any Conflict Minerals and the facilities used to process these minerals. Suppliers were asked to provide information specific to the particular products they supply to Ruckus and to identify materials down to the smelter and mine. Ruckus accepted information at a more general scope (i.e., at division- or company-level) only where the supplier certified that it was unable to provide a product-specific declaration and indicated a reason.
The collection process included an introductory email from Ruckus to all of its contract manufacturers and in-scope suppliers describing the compliance requirements and identifying Source Intelligence as its partner in the process. Source Intelligence then followed up with instructions for accessing the online data collection platform, and requesting completion of the Template. Multiple reminder emails were sent to non-responsive suppliers requesting survey completion. Source Intelligence then contacted suppliers that remained unresponsive by telephone (sometimes, on multiple occasions) to confirm contact information, remind the supplier about the information request and offer assistance. Ruckus’ system protocol then required escalation to Ruckus, after which the committee would then engage in direct follow-up with these suppliers. The committee monitored the status of Source Intelligence’s outreach and supplier responses through information made available via the online platform, and requested additional follow-up or engaged in direct follow-up as appropriate.
Source Intelligence reviewed supplier responses and validated the information against its smelter/refiner database, identifying (a) smelters and refiners that have been verified as metal processors (based on information from the CFSI, U.S. Department of Commerce, or Source Intelligence’s internet research and direct smelter outreach), (b) which companies are known to Source Intelligence to be exclusive recyclers, and (c) DRC conflict-free certification status. Source Intelligence evaluated supplier responses for plausibility, consistency, and gaps in information, and sent additional follow-up emails to suppliers in order to request clarification or additional information or otherwise address quality control flags. The committee reviewed Source Intelligence’s quality control process through information made available via the online platform.
Source Intelligence compared the list of verified smelters and refiners against lists of smelters or refiners that have been certified as conflict-free by independent third-party audit programs, specifically the Conflict Free-Smelter Program (“CFSP”) developed by the CFSI, the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewellery Council (“RJC”) Chain-of-Custody Certification.
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| 3. | OECD Step 3 - Design and Implement a Strategy to Respond to Risk |
Ruckus 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, notwithstanding encouragement from Ruckus, do not source from smelters or refiners that have been designated as “conflict free” by an independent, third-party auditor. Potential outcomes under this risk mitigation strategy include continuing to work with the supplier while risks are addressed, suspending the relationship on a temporary basis while risk mitigation is pursued or discontinuing the relationship with the supplier where risk mitigation efforts have failed. Under this risk mitigation strategy, to the extent that risks that require mitigation are identified, if applicable, the committee will adopt procedures for supplier training, monitoring and tracking the performance of the risk mitigation efforts and reporting these efforts back to members of the executive team as appropriate. Under these procedures, the committee also will take additional factors into consideration including supplier size and capabilities, whether alternatives are available and Ruckus’ dependence on the supplier.
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| 4. | OECD Step 4 - Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices |
As Ruckus has no direct relationship with smelters or refiners in its supply chain, it did not perform or direct audits of these entities within its supply chain. As an alternative, the committee relied on Source Intelligence’s review of publicly available data collected and published by independent third-party audit programs, namely the CFSP, the LBMA Good Delivery Program and the RJC Chain-of Custody Certification. These independent third-party audit programs evaluate smelter and refiner procurement activities and determine whether the smelter or refiner demonstrated that it has systems and controls in place to ensure that all materials it processed originated from conflict-free sources.
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| 5. | OECD Step 5 - Report on Supply Chain Due Diligence |
As required under the Rule, Ruckus has filed its Form SD, which contains this Report as an exhibit, with the SEC for the reporting period commencing January 1, 2015 and ending December 31, 2015. Ruckus expects to report annually, as required by the Rule, and has posted this Report on its website.
Due Diligence Outcome
As of the date of this Report, Ruckus has received responses from 308 out of 310 (99%) contract manufacturers and in-scope suppliers that were contacted in connection with its due diligence process. The committee continues to follow up with 52 in-scope suppliers for more complete or accurate information.
Given that not all smelters identified by our suppliers were certified as “conflict free” by an independent third-party audit program, and that a number of supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain or unknown (including because some suppliers were only able to provide responses at the company-level rather than information specific to Ruckus products), Ruckus was unable to precisely determine whether or not all supplier parts in its supply chain for the Covered Products contain necessary Conflict Minerals from the Covered Countries or, in the alternative, utilized Conflict Minerals in their manufacture that either financed or benefited, directly or indirectly, armed groups in the Covered Countries. As such, Ruckus’ due diligence in 2015 found that Ruckus products containing or utilizing Conflict Minerals are DRC conflict undeterminable.
The statements above are based on the RCOI process and due diligence performed in good faith by Ruckus. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or third-party service providers, 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, companies’ not continuing in business in 2015 or 2016, certification programs that are not equally advanced for all industry segments and metals, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.
Identified Smelters and Refiners
While nearly half of Ruckus’ contract manufacturers and suppliers provided information for the particular products they supply to Ruckus, the remainder provided this information on a division or company-wide basis. When the contract manufacturers and
suppliers provided product-level information, Ruckus has listed in Schedule 1 of this Report the smelters or refiners identified. However, when the contract manufacturers and suppliers provided only division or company-level information, Ruckus 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 Source Intelligence was able to verify as a known smelter or refiner. Based solely on information provided by suppliers and the CFSP, LBMA Good Delivery Program and the RJC Chain-of-Custody Certification, of the 293 smelters and refiners identified on Schedule 1, 203 have been certified as “conflict free” by at least one of these independent third-party audit programs, and an additional 15 are actively moving through the certification process or have committed to undergo an audit.
Identified Countries of Origin of Necessary Conflict Minerals
When the contract manufacturers or suppliers provided product-level information, Ruckus has listed in Schedule 2 of this Report the countries of origin of the Necessary Conflict Minerals. Where a Covered Country was identified as the country of origin, Ruckus confirmed that the identified smelter or refiner was either certified as “conflict-free” by an independent third-party audit program, actively moving through the certification process or had committed to undergo an audit.
Efforts to Determine Mine or Location of Origin
Ruckus’ efforts to determine the mines or locations of origin of the Necessary Conflict Minerals with the greatest possible specificity included the use of the RCOI and due diligence measures described above.
Future Due Diligence and Risk Mitigation
Ruckus 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 Ruckus’ products benefit armed groups in the Covered Countries, including:
1. Ruckus 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 more complete and accurate information in 2016.
2. Ruckus intends to continue 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 mine.
3. Ruckus intends to further develop, refine and implement its risk mitigation strategy for supply chain risks identified in the course of its due diligence.
4. In connection with Ruckus’ 2016 Conflict Minerals reporting, Ruckus plans to continue to engage a third-party service provider to assist with data collection, facilitating supplier outreach efforts and tracking and analyzing supplier responses through an online platform.
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 facts contained in this Report, including without limitation, statements regarding the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, are forward-looking statements. In some cases, you can identify forward-looking statements by terminology such as “believe,” “will,” “may,” “estimate,” “continue,” “anticipate,” “intend,” “should,” “plan,” “expect,” “predict,” “could,” “potentially” and similar expressions that convey uncertainty of future events or outcomes are intended to identify forward-looking statements. These forward looking statements are subject to risks and uncertainties that could cause actual results and events to differ materially and adversely from those anticipated or implied which include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on Source Intelligence’s and Ruckus’ ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, and the other risks identified above under the Caption “Due Diligence Outcome.” Ruckus undertakes no obligation to revise or publicly release the results of any revision to these forward-looking statements, except as required by law. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.
Schedule 1
Smelter and Refiner Information
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| Metal | Standard Smelter Names | Smelter Facility Location: Country |
| Gold (Au) | Advanced Chemical Company | United States |
| Gold (Au) | Aida Chemical Industries Co., Ltd. | Japan |
| Gold (Au) | Aktyubinsk Copper Company TOO | Kazakhstan |
| Gold (Au) | Al Etihad Gold | United Arab Emirates |
| Gold (Au) | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold (Au) | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold (Au) | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
| Gold (Au) | Argor-Heraeus SA | Switzerland |
| Gold (Au) | Asahi Pretec Corporation | Japan |
| Gold (Au) | Asahi Refining Canada Limited | Canada |
| Gold (Au) | Asahi Refining USA Inc. | United States |
| Gold (Au) | Asaka Riken Co., Ltd. | Japan |
| Gold (Au) | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold (Au) | Aurubis AG | Germany |
| Gold (Au) | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold (Au) | Bauer Walser AG | Germany |
| Gold (Au) | Boliden AB | Sweden |
| Gold (Au) | C. Hafner GmbH + Co. KG | Germany |
| Gold (Au) | Caridad | Mexico |
| Gold (Au) | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold (Au) | Cendres + Métaux SA | Switzerland |
| Gold (Au) | Chimet S.p.A. | Italy |
| Gold (Au) | Chugai Mining | Japan |
| Gold (Au) | Daejin Indus Co., Ltd. | South Korea |
| Gold (Au) | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold (Au) | DODUCO GmbH | Germany |
| Gold (Au) | Dowa | Japan |
| Gold (Au) | DSC (Do Sung Corporation) | South Korea |
| Gold (Au) | Eco-System Recycling Co., Ltd. | Japan |
| Gold (Au) | Elemetal Refining, LLC | United States |
| Gold (Au) | Emirates Gold DMCC | United Arab Emirates |
| Gold (Au) | Faggi Enrico S.p.A. | Italy |
| Gold (Au) | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold (Au) | Gansu Seemine Material Hi-Tech Co Ltd | China |
| Gold (Au) | Geib Refining Corporation | United States |
| Gold (Au) | Guangdong Gaoyao Co | China |
| Gold (Au) | Guangdong Jinding Gold Limited | China |
| Gold (Au) | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold (Au) | Heimerle + Meule GmbH | Germany |
| Gold (Au) | Heraeus Ltd. Hong Kong | China |
| Gold (Au) | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold (Au) | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold (Au) | Hwasung CJ Co. Ltd | South Korea |
| Gold (Au) | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China |
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| Gold (Au) | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold (Au) | Istanbul Gold Refinery | Turkey |
| Gold (Au) | Japan Mint | Japan |
| Gold (Au) | Jiangxi Copper Company Limited | China |
| Gold (Au) | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russia |
| Gold (Au) | JSC Uralelectromed | Russia |
| Gold (Au) | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold (Au) | Kaloti Precious Metals | United Arab Emirates |
| Gold (Au) | Kazakhmys plc | Kazakhstan |
| Gold (Au) | Kazzinc | Kazakhstan |
| Gold (Au) | Kennecott Utah Copper LLC | United States |
| Gold (Au) | KGHM Polska Miedž Spółka Akcyjna | Poland |
| Gold (Au) | Kojima Chemicals Co., Ltd. | Japan |
| Gold (Au) | Korea Metal Co. Ltd | South Korea |
| Gold (Au) | Korea Zinc Co. Ltd. | South Korea |
| Gold (Au) | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold (Au) | L' azurde Company For Jewelry | Saudi Arabia |
| Gold (Au) | Lingbao Gold Company Ltd. | China |
| Gold (Au) | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China |
| Gold (Au) | LS-NIKKO Copper Inc. | South Korea |
| Gold (Au) | Luo yang Zijin Yinhui Metal Smelt Co Ltd | China |
| Gold (Au) | Materion | United States |
| Gold (Au) | Matsuda Sangyo Co., Ltd. | Japan |
| Gold (Au) | Metahub Industries Sdn. Bhd. | Malaysia |
| Gold (Au) | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold (Au) | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold (Au) | Metalor Technologies (Suzhou) Co Ltd | China |
| Gold (Au) | Metalor Technologies SA | Switzerland |
| Gold (Au) | Metalor USA Refining Corporation | United States |
| Gold (Au) | METALLJRGICA MET-MEX PEÑOLES, S.A. DE C.V | Mexico |
| Gold (Au) | Mitsubishi Materials Corporation | Japan |
| Gold (Au) | Mitsui Mining & Smelting | Japan |
| Gold (Au) | MMTC-PAMP India Pvt., Ltd. | India |
| Gold (Au) | Morris and Watson | New Zealand |
| Gold (Au) | Moscow Special Alloys Processing Plant | Russia |
| Gold (Au) | Nadir Metal Rafineri San. Ve Tic. A.Åž. | Turkey |
| Gold (Au) | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold (Au) | Nihon Material Co., Ltd. | Japan |
| Gold (Au) | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold (Au) | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold (Au) | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russia |
| Gold (Au) | OJSC Kolyma Refinery | Russia |
| Gold (Au) | OJSC Novosibirsk Refinery | Russia |
| Gold (Au) | PAMP SA | Switzerland |
| Gold (Au) | Penglai Penggang Gold Industry Co Ltd | China |
| Gold (Au) | Prioksky Plant of Non-Ferrous Metals | Russia |
| Gold (Au) | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold (Au) | PX Prcinox SA | Switzerland |
| Gold (Au) | Rand Refinery (Pty) Ltd. | South Africa |
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| Gold (Au) | Republic Metals Corporation | United States |
| Gold (Au) | Royal Canadian Mint | Canada |
| Gold (Au) | Sabin Metal Corp. | United States |
| Gold (Au) | Samduck Precious Metals | South Korea |
| Gold (Au) | SAMWON METALS Corp. | South Korea |
| Gold (Au) | SAXONIA Edelmetalle GmbH | Germany |
| Gold (Au) | Schone Edelmetaal B.V. | Netherlands |
| Gold (Au) | SEMPSA Joyería Platería SA | Spain |
| Gold (Au) | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold (Au) | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold (Au) | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold (Au) | Singway Technology Co., Ltd. | Taiwan |
| Gold (Au) | So Accurate Group, Inc. | United States |
| Gold (Au) | SOE Shyolkovsky Factory of Secondary Precious Metals | Russia |
| Gold (Au) | Solar Applied Materials Technology Corp. | Taiwan |
| Gold (Au) | Sudan Gold Refinery | Sudan |
| Gold (Au) | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold (Au) | T.C.A S.p.A | Italy |
| Gold (Au) | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold (Au) | The Great Wall Gold and Silver Refinery of China | China |
| Gold (Au) | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold (Au) | Tokuriki Honten Co., Ltd. | Japan |
| Gold (Au) | TongLing Nonferrous Metals Group Holdings Co., Ltd. | China |
| Gold (Au) | Torecom | South Korea |
| Gold (Au) | Umicore Brasil Ltda. | Brazil |
| Gold (Au) | Umicore Precious Metals Thailand | Thailand |
| Gold (Au) | Umicore SA Business Unit Precious Metals Refining | Belgium |
| Gold (Au) | United Precious Metal Refining, Inc. | United States |
| Gold (Au) | Valcambi SA | Switzerland |
| Gold (Au) | Western Australian Mint trading as The Perth Mint | Australia |
| Gold (Au) | WIELAND Edelmetalle GmbH | Germany |
| Gold (Au) | Yamamoto Precious Metal Co., Ltd. | Japan |
| Gold (Au) | Yantai Guodasafina High-tech Environmental Refinery CO., Ltd. | China |
| Gold (Au) | Yokohama Metal Co., Ltd. | Japan |
| Gold (Au) | Yunnan Copper Industry Co Ltd | China |
| Gold (Au) | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold (Au) | Zijin Mining Group Co., Ltd. Gold Refinery | China |
| Tantalum (Ta) | Avon Specialty Metals Ltd | United Kingdom |
| Tantalum (Ta) | Conghua Tantalum and Niobium Smeltry | China |
| Tantalum (Ta) | D Block Metals, LLC | United States |
| Tantalum (Ta) | Duoluoshan | China |
| Tantalum (Ta) | Exotech Inc. | United States |
| Tantalum (Ta) | F&X Electro-Materials Ltd. | China |
| Tantalum (Ta) | FIR Metals & Resource Ltd. | China |
| Tantalum (Ta) | Global Advanced Metals Aizu | Japan |
| Tantalum (Ta) | Global Advanced Metals Boyertown | United States |
| Tantalum (Ta) | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum (Ta) | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | China |
| Tantalum (Ta) | H.C. Starck Co., Ltd. | Thailand |
| Tantalum (Ta) | H.C. Starck GmbH Goslar | Germany |
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| Tantalum (Ta) | H.C. Starck GmbH Laufenburg | Germany |
| Tantalum (Ta) | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum (Ta) | H.C. Starck Inc. | United States |
| Tantalum (Ta) | H.C. Starck Ltd. | Japan |
| Tantalum (Ta) | H.C. Starck Smelting GmbH & Co.KG | Germany |
| Tantalum (Ta) | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum (Ta) | Hi-Temp Specialty Metals, Inc. | United States |
| Tantalum (Ta) | Jiangxi Dinghai Tantalum & Niobium Co., Ltd | China |
| Tantalum (Ta) | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum (Ta) | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum (Ta) | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum (Ta) | KEMET Blue Metals | United States |
| Tantalum (Ta) | Kemet Blue Powder | United States |
| Tantalum (Ta) | King-Tan Tantalum Industry Ltd. | China |
| Tantalum (Ta) | LSM Brasil S.A. | Brazil |
| Tantalum (Ta) | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum (Ta) | Mineração Taboca S.A. | Brazil |
| Tantalum (Ta) | Molycorp Silmet A.S. | Estonia |
| Tantalum (Ta) | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum (Ta) | Plansee SE Liezen | Austria |
| Tantalum (Ta) | Plansee SE Reutte | Austria |
| Tantalum (Ta) | QuantumClean | United States |
| Tantalum (Ta) | Resind Indústria e Comércio Ltda. | Brazil |
| Tantalum (Ta) | RFH Tantalum Smeltry Co., Ltd. | China |
| Tantalum (Ta) | Solikamsk Magnesium Works OAO | Russia |
| Tantalum (Ta) | Taki Chemicals | Japan |
| Tantalum (Ta) | Telex Metals | United States |
| Tantalum (Ta) | Tranzact, Inc. | United States |
| Tantalum (Ta) | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum (Ta) | XinXing Haorong Electronic Material Co., Ltd. | China |
| Tantalum (Ta) | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tantalum (Ta) | Zhuzhou Cemented Carbide | China |
| Tin (Sn) | Alpha | United States |
| Tin (Sn) | An Thai Minerals Company Limited | Vietnam |
| Tin (Sn) | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin (Sn) | China Tin Group Co., Ltd. | China |
| Tin (Sn) | CNMC (Guangxi) PGMA Co. Ltd. | China |
| Tin (Sn) | Cooperativa Metalurgica de Rondônia Ltda. | Brazil |
| Tin (Sn) | CV Ayi Jaya | Indonesia |
| Tin (Sn) | CV Gita Pesona | Indonesia |
| Tin (Sn) | CV Serumpun Sebalai | Indonesia |
| Tin (Sn) | CV United Smelting | Indonesia |
| Tin (Sn) | CV Venus Inti Perkasa | Indonesia |
| Tin (Sn) | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin (Sn) | Elmet S.L.U. (Metallo Group) | Spain |
| Tin (Sn) | EM Vinto | Bolivia |
| Tin (Sn) | Estanho de Rondônia S.A. | Brazil |
| Tin (Sn) | Feinhutte Halsbrucke GmbH | Germany |
| Tin (Sn) | Fenix Metals | Poland |
|
| | |
| Tin (Sn) | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin (Sn) | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin (Sn) | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin (Sn) | Gejiu Zi-Li | China |
| Tin (Sn) | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin (Sn) | Linwu Xianggui Smelter Co | China |
| Tin (Sn) | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin (Sn) | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin (Sn) | Melt Metais e Ligas S/A | Brazil |
| Tin (Sn) | Metallic Resources, Inc. | United States |
| Tin (Sn) | Metallo-Chimique N.V. | Belgium |
| Tin (Sn) | Minsur | Peru |
| Tin (Sn) | Nankang Nanshan Tin Co., Ltd. | China |
| Tin (Sn) | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin (Sn) | Novosibirsk Integrated Tin Works | Russia |
| Tin (Sn) | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin (Sn) | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin (Sn) | Operaciones Metalurgical S.A. | Bolivia |
| Tin (Sn) | Phoenix Metal Ltd | Rwanda |
| Tin (Sn) | PT Alam Lestari Kencana | Indonesia |
| Tin (Sn) | PT Aries Kencana Sejahtera | Indonesia |
| Tin (Sn) | PT Artha Cipta Langgeng | Indonesia |
| Tin (Sn) | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin (Sn) | PT Babel Inti Perkasa | Indonesia |
| Tin (Sn) | PT Bangka Kudai Tin | Indonesia |
| Tin (Sn) | PT Bangka Prima Tin | Indonesia |
| Tin (Sn) | PT Bangka Timah Utama Sejahtera | Indonesia |
| Tin (Sn) | PT Bangka Tin Industry | Indonesia |
| Tin (Sn) | PT Belitung Industri Sejahtera | Indonesia |
| Tin (Sn) | PT BilliTin Makmur Lestari | Indonesia |
| Tin (Sn) | PT Bukit Timah | Indonesia |
| Tin (Sn) | PT Cipta Persada Mulia | Indonesia |
| Tin (Sn) | PT DS Jaya Abadi | Indonesia |
| Tin (Sn) | PT Eunindo Usaha Mandiri | Indonesia |
| Tin (Sn) | PT Fang Di MulTindo | Indonesia |
| Tin (Sn) | PT Inti Stania Prima | Indonesia |
| Tin (Sn) | PT Justindo | Indonesia |
| Tin (Sn) | PT Karimun Mining | Indonesia |
| Tin (Sn) | PT Mitra Stania Prima | Indonesia |
| Tin (Sn) | PT Panca Mega Persada | Indonesia |
| Tin (Sn) | PT Pelat Timah Nusantara Tbk | Indonesia |
| Tin (Sn) | PT Prima Timah Utama | Indonesia |
| Tin (Sn) | PT Refined Bangka Tin | Indonesia |
| Tin (Sn) | PT Sariwiguna Binasentosa | Indonesia |
| Tin (Sn) | PT Seirama Tin investment | Indonesia |
| Tin (Sn) | PT Stanindo Inti Perkasa | Indonesia |
| Tin (Sn) | PT Sukses Inti Makmur | Indonesia |
| Tin (Sn) | PT Sumber Jaya Indah | Indonesia |
| Tin (Sn) | PT Timah (Persero) Tbk Kundur | Indonesia |
| Tin (Sn) | PT Timah (Persero) Tbk Mentok | Indonesia |
|
| | |
| Tin (Sn) | PT Tinindo Inter Nusa | Indonesia |
| Tin (Sn) | PT Tirus Putra Mandiri | Indonesia |
| Tin (Sn) | PT Tommy Utama | Indonesia |
| Tin (Sn) | PT WAHANA PERKIT JAYA | Indonesia |
| Tin (Sn) | Rui Da Hung | Taiwan |
| Tin (Sn) | Soft Metais Ltda. | Brazil |
| Tin (Sn) | Thaisarco | Thailand |
| Tin (Sn) | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin (Sn) | VQB Mineral and Trading Group JSC | Vietnam |
| Tin (Sn) | White Solder Metalurgia e Mineração Ltda. | Brazil |
| Tin (Sn) | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | China |
| Tin (Sn) | Yunnan Tin Group (Holding) Company Limited | China |
| Tungsten (W) | A.L.M.T. TUNGSTEN Corp. | Japan |
| Tungsten (W) | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten (W) | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten (W) | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten (W) | Dayu Jincheng Tungsten Industry Co., Ltd. | China |
| Tungsten (W) | Dayu Weiliang Tungsten Co., Ltd. | China |
| Tungsten (W) | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten (W) | Ganxian Shirui New Material Co., Ltd. | China |
| Tungsten (W) | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten (W) | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten (W) | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China |
| Tungsten (W) | Ganzhou Yatai Tungsten Co., Ltd. | China |
| Tungsten (W) | Global Tungsten & Powders Corp. | United States |
| Tungsten (W) | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten (W) | H.C. Starck GmbH | Germany |
| Tungsten (W) | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten (W) | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | China |
| Tungsten (W) | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
| Tungsten (W) | Hydrometallurg, JSC | Russia |
| Tungsten (W) | Japan New Metals Co., Ltd. | Japan |
| Tungsten (W) | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten (W) | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten (W) | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten (W) | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten (W) | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten (W) | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China |
| Tungsten (W) | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten (W) | Kennametal Fallon | United States |
| Tungsten (W) | Kennametal Huntsville | United States |
| Tungsten (W) | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten (W) | Niagara Refining LLC | United States |
| Tungsten (W) | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| Tungsten (W) | Pobedit, JSC | Russia |
| Tungsten (W) | Sanher Tungsten Vietnam Co., Ltd. | Vietnam |
| Tungsten (W) | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten (W) | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam |
| Tungsten (W) | Wolfram Bergbau und Hütten AG | Austria |
| Tungsten (W) | Xiamen Tungsten Co., Ltd. | China |
|
| | |
| Tungsten (W) | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
Schedule 2
Country of Origin of Conflict Minerals Information
Australia
Belgium
Bolivia
Brazil
Canada
Chile
China
Democratic Republic of the Congo
Ethiopia
Germany
Guyana
Hong Kong
India
Indonesia
Japan
Malaysia
Mexico
Mozambique
Namibia
Peru
Philippines
Poland
Portugal
Russia
Rwanda
Sierra Leone
South Africa
South Korea
Spain
Suriname
Switzerland
Thailand
United States
Zimbabwe
