Silicon Graphics International Corp.
Conflict Minerals Report
For The Year Ended December 31, 2015
This Conflict Minerals Report for the year ended December 31, 2015 is presented by Silicon Graphics International Corp. to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("the Rule").
This Conflict Minerals Report ("this Report") contains forward-looking statements regarding our business, products, and conflict minerals efforts, including steps we intend to take to mitigate the risk that 3TGs in our products benefit armed groups (identified as a perpetrator of serious human rights abuses) in the Democratic Republic of the Congo (DRC) or an adjoining country. Words such as "expects," intends," "believes," strives," and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. Additionally, statements concerning future matters that are not historical are forward-looking statements.
Although forward-looking statements in this Report reflect our good faith judgment, such statements can only be based on facts and factors currently known by us. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include without limitation: the risk that information reported to us by our suppliers from which we directly procure finished goods, components, materials and/or services for our products (direct suppliers), or industry information used by us, may be inaccurate; the risk that smelters or refiners (processing facilities) may not participate in the Conflict Free Smelter Program (CFSP), which is a voluntary initiative in which independent third parties audit processing facilities' procurement and processing activities and determine if the processing facilities maintain sufficient documentation to reasonably demonstrate conflict-free sourcing; as well as risks discussed under the heading "Risk Factors" in our most recent Quarterly Report on Form 10-Q related to our customer concentrations, our dependence on a limited number of third-party suppliers and our being subject to government regulations and policies. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this Report. We undertake no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report. Throughout this Report, whenever a reference is made to our website, such reference does not incorporate information from the website by reference into this Report unless specifically identified as such.
Silicon Graphics International Corp. (herein referred to as "SGI," the "Company," "we," "us," or "our") manufactures or contracts to manufacture products as to which tin, tungsten, tantalum and/or gold (herein referred to as 3TGs) are necessary to the functionality or production of such products. The term "conflict minerals" is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.
Based on a reasonable country of origin inquiry ("RCOI"), SGI has reason to believe that a portion of its necessary 3TGs may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, sometimes referred to as the "Covered Countries") and has reason to believe that those necessary 3TGs may not be from recycle or scrap sources, but it is currently unknown if those 3TGs finance conflict. Due to this determination SGI conducted due diligence on the source of these necessary conflict minerals and prepared this Conflict Minerals Report.
Company Overview
This Report has been prepared by SGI and includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated. It does not include the activities of variable interest entities that are not required to be consolidated.
SGI is a global leader in high performance solutions for compute, data analytics and data management, that enable customers to accelerate time to discovery, innovation, and profitability. We are focused on helping customers solve their most demanding business and technology challenges.
We develop, market and sell a broad line of low cost, mid-range and high-end scale-out and scale-up servers, enterprise-class storage, differentiating software and designed-to-order solutions for large-scale data center deployments, coupled with global support and highly experienced professional services. SGI solutions are designed to deliver high impact results with lower total cost of ownership and to achieve industry-leading speed, scale and efficiency.
SGI solutions are utilized by scientific, business and government communities to fulfill highly compute-intensive application needs in petascale and exascale environments. Delivering industry-leading computing power and fast and efficient data movement, both within the computing system and to and from large-scale data storage installations, SGI systems enable customers to access, analyze, transform, manage and visualize information in real and near real-time.
Our goal is to accelerate time to results in key markets, including federal government, defense and strategic systems, weather and climate, physical and life sciences, energy (including oil and gas), aerospace, automotive manufacturing, internet, financial services, education and research institutions and media and entertainment.
SGI achieves competitive differentiation through compute and storage solutions built with innovative architectural advantages utilizing industry standard components and tight integration. By designing for performance, power, density and scalability; optimizing interconnections between layers; and engineering to reduce overhead and accelerate deployment, SGI solutions deliver industry leading speed, scale and efficiency.
SGI has approximately 1,100 employees and approximately 550 granted and pending patents and patent applications worldwide. SGI serves over 3,800 customers and sells products and services in about 50 countries through a direct and indirect sales force, including original equipment manufacturers, system integrators and value added resellers. SGI has over 130 active partners. During our fiscal years of 2013 through 2016, international revenue has ranged between 35 to 55% of total revenue.
SGI is committed to taking the necessary steps to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("the Dodd-Frank Act") that was approved by the U.S. Securities and Exchange Commission ("SEC") and SGI is implementing a due-diligence process to meet our obligations. SGI's goal is to eliminate conflict minerals that benefit armed groups in Covered Countries from SGI's products. SGI supports its suppliers in seeking a mutually sustainable solution for SGI's entire supply chain, including its indirect suppliers, by providing educational materials, guidance, and a supplier portal for the submission of conflict minerals information.
For additional information, please see http://www.sgi.com/company_info/environment/conflict_minerals.html.
SGI Products
SGI develops, markets, and sells a broad line of low cost, mid-range and high-end scale-out and scale-up servers, enterprise-class storage, differentiating software and designed-to-order solutions for large-scale data center deployments, coupled with global support and highly experienced professional services. SGI solutions are designed to deliver high impact results with lower total cost of ownership at the extremes of speed, scale and efficiency. Our broad and complex product range may contain 3TGs within the following list of components among others:
· | Tin in soldered components, circuit boards and tin plating |
· | Tungsten in coatings, alloys, heating elements and electrodes |
· | Gold in circuit boards, electrodes, semiconductors, electric plating and electronic components. |
Reasonable Country of Origin Inquiry
SGI's reasonable country of origin inquiry (RCOI) employed a combination of measures to determine whether the necessary 3TGs in SGI products originated from the Covered Countries. The primary means of determining country of origin of necessary 3TGs was to analyze the supply base and then conduct a supply chain survey with SGI's direct suppliers, including contract manufacturers, using the Electronic Industry Citizenship Coalition ("EICC") and Global e-Sustainability Initiative ("GeSI") Conflict Minerals Reporting Template ("CMRT"), version 4.01b. To assist SGI with its overall conflict minerals program implementation, SGI contracted with Assent Compliance, a leading compliance solutions service provider, who conducted the survey on SGI's behalf. In addition, SGI also provided support to its direct suppliers to facilitate their obtaining conflict minerals information down through the SGI supply chain.
For the RCOI, SGI began the analysis and scoping process by extracting current suppliers from SGI's Preferred Supplier List. The list was then filtered to remove suppliers of services only and inactive suppliers from which SGI did not purchase in 2015 with the resulting list representing SGI suppliers that provided SGI with components used in its products during 2015. As a further step, the list of direct suppliers, along with their current contact information, was further screened for the following the factors:
· | Parts supplied by supplier that did not end up in the final product. (This includes equipment used to make the product but is not a part of the actual product sold by SGI; i.e.: Industrial equipment, computers, etc.) |
· | Suppliers were test labs service providers. (i.e.: Providers that test the resistance or durability of a product.) |
· | Suppliers supplied parts to SGI for SGI products that were no longer sold by SGI on or after January 1, 2015. |
Following the analysis and screening, the supplier survey was conducted of the remaining suppliers. Each one received letters of explanation about the requirements of the Conflict Minerals Rule and the industry-standard CMRT form to be completed. Suppliers were asked to respond to SGI's service provider electronically via a SaaS platform that enables suppliers to complete and track communications and upload their completed CMRT forms directly to the tool for validation, risk assessment and management. Suppliers were also requested to provide Smelter or Refiners (SORs) information on the Smelter Tab of the CMRT. The results of this can be found in Appendix A below.
Communication to SGI's direct, pre-screened suppliers also included training and education on the completion of the CMRT form to alleviate confusion and ensure the accuracy of supplier responses. Educational resources also included training or support in risk mitigation to its suppliers. In order to ensure that suppliers are aware of their requirements for conflict minerals, SGI began to include our conflict minerals policy in supplier contracts and in purchase order terms and conditions.
SGI's communication included follow-up to non-responsive, in-scope suppliers who were contacted a minimum of three times through the platform and then were also contacted by SGI's service provider team in one-on-one communications. Supplier survey responses received were reviewed for completeness and consistency. Supplier reports submitted with missing information or inconsistent responses to the survey questions were classified as "invalid," and the supplier was contacted and requested to resubmit a valid report. SGI's RCOI inquiry and our program for 2015 included automated data validation on all submitted CMRTs. The goal of data validation was to increase the accuracy of submissions and identify any contradictory answers in the CMRT.
Design of Due Diligence Measures
SGI's due diligence measures have been designed to conform in all material respects with the 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 and the related Supplements for gold and for tin, tantalum and tungsten ("OECD Guidance"). When SGI designed our due diligence measures, we took into account our individual facts and circumstances, particularly our position in the supply chain, and the OECD recommendations for downstream actors with no direct relationships to smelters or refiners.
SGI is a purchaser of materials, parts, components and manufactured products and is many steps downstream in the minerals supply chain from smelters and refiners. SGI does not purchase raw ore or unrefined conflict minerals. Smelters and refiners are the consolidation points for raw ore and the OECD Guidance allocates to them the obligation to conduct due diligence on the source and chain of custody of the origin of raw ore. The key role for SGI as a downstream actor under the OECD Guidance is to identify the smelters and refiners in the supply chain for SGI's products and review the due diligence processes of those entities through information available to SGI via due diligence assessment programs such as the CFSI Conflict-Free Smelter Program.
SGI's design of due diligence measures features the following elements which are further set forth in the Description of Due Diligence Measures: (1) establishment of internal company management systems; (2) identification and assessment of conflict mineral risk in the supply chain; (3) design of a process to respond to risks as they are identified; (4) use of resources provided by industry organizations who carry out specific due diligence practices; and (5) preparation of this annual Conflict Minerals Report.
Description of Due Diligence Measures
(1) Establishment of Strong Internal Company Management Systems
SGI has established an internal management system for conflict minerals compliance and reporting, which is bolstered by operational controls instituted at SGI. Our management system is sponsored and overseen by SGI's Chief Operations Officer and is managed by a team of subject matter experts from relevant functions, including:
· | Product Design and Compliance Engineering |
· | Environmental, Health and Safety |
SGI's team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by SGI's Product Design and Compliance Manager who acts as the Conflict Minerals Program Manager. The Program Manager is responsible for overseeing the work performed by SGI's service provider engaged by SGI to help manage its conflict minerals program and for ensuring that follow up tasks and action items arising from the due diligence process are assigned to appropriate SGI personnel and completed. Senior management is briefed about the results of our due diligence efforts on a regular basis.
SGI has adopted a company conflict minerals policy which is posted on our website at:
http://www.sgi.com/company_info/environment/conflict_minerals.html
SGI's commitment to responsible sourcing is also described in our Supplier Guidelines at: http://www.sgi.com/company_info/supplier_guidelines/
It is SGI's policy to retain relevant documentation as required by law or regulation which would also apply to the conflict minerals regulation and any of its specific retention requirements. SGI's Records Retention Policy sets up an orderly program for maintaining and disposing of all types of information generated by SGI with the goal of enabling maximum compliance with applicable legal rules, minimizing accidental destruction of needed information, and facilitating SGI's operations by promoting efficiency and optimal use of valuable storage space. In accordance with the SGI's Records Retention Policy, SGI's General Counsel may periodically commission reviews of the specific records retention schedules to ensure that best efforts are being made to follow the Records Retention Policy as consistently as possible.
SGI's operational control systems include, but are not limited to, the SGI Code of Conduct which outlines expected behaviors for all SGI employees. To assist with the enforcement of SGI's Code of Conduct, SGI has grievance mechanisms in place whereby SGI employees can report violations to SGI's Policies, including an 800 number "Integrity Line" and a website for employee use with an internet reporting form and published email addresses that go directly to SGI's Compliance Officer or the Chair of the Board's Audit Committee.
Additional operational controls are in SGI's Supplier Guidelines and in compliance with laws and clauses in SGI contract templates and Purchase Order Terms and Conditions. Our current purchase order terms and conditions and contract templates require SGI suppliers to comply with laws and regulations as they relate to activities with SGI and also those which govern the SGI suppliers' products and product distribution; SGI suppliers are required to provide accurate information for compliance purposes.
With respect to the OECD requirement to strengthen engagement with suppliers, SGI has, through its service provider, provided education on the conflict minerals regulation and its requirements, and has further communicated SGI's expectations for a continuing business relationship. SGI has leveraged the existing communications within the company, specifically with procurement/supply chain to encourage supplier participation and understanding of the requirement for completion. Feedback from this engagement has resulted in enhanced focus by SGI's direct suppliers and allowed our suppliers to set clear communications down the supply chain.
(2) Identification and Assessment of Risks
Based on the smelter lists provided by its suppliers, SGI is aware of 320 smelters or refiners from the list that have been validated by the CFSI. Of those valid smelters or refiners, 215 are certified conflict-free. Of the facilities that have not yet been certified conflict-free, 48 are currently in the process of being audited. Many suppliers are still unable to provide the smelters or refiners used for materials supplied to us. Furthermore, many of the responses provided at the company or division level indicated an "unknown" status in determining the origin of 3TGs.
In consonance with the OECD Guidelines, SGI endeavored to understand risk levels associated with smelters and refiners of conflict minerals in the supply chain that are not certified as DRC-Conflict Free. With the aid of the SGI service provider's software, the SGI supplier smelters and refiners were assigned a risk rating of High, Medium or Low based on the following scoring criteria: 1) the smelter or refiners recognition via a regulated body –which validates its facility designation (Smelter CID Number is the primary method), 2) the risk level of the country in which the smelter exists, 3) Smelter/Refiner certification via the Conflict-Free Sourcing Initiative (CFSI) or the London Bullion Market Association (LBMA) Responsible Gold Programme and 4) the supplier risk based on the likelihood the supplier provides 3TGs that may originate from non-Conflict-Free sources.
Additionally, SGI's direct suppliers were evaluated on the strength of their own programs to further assist in supply chain risk identification. SGI suppliers may still be undergoing their own conflict minerals due-diligence process and do not have answers beyond "unknown". For this reason, evaluating and tracking the strength of an SGI supplier's program assists SGI in meeting the OECD Due Diligence Guidelines and in making key risk mitigation decisions. The criteria used to evaluate the strength of an SGI supplier's program were:
· | Existence of a policy that includes DRC conflict-free sourcing |
· | Implementation of due diligence measures for conflict-free sourcing |
· | Verification efforts of information received from supply chain during due diligence by the SGI supplier |
· | Existence of corrective action management by the SGI supplier |
(3) Design and Implementation of a Process to Respond to Risks
SGI is taking the following steps to obtain additional information regarding smelters or refiners in its supply chain:
· | Work with suppliers to move to the most updated CMRT on which new smelter identification numbers have been assigned. |
· | Require the use of smelter identification numbers in order to deem supplier responses complete. |
· | Require suppliers to inform SGI of the correlation between smelters they identify and the products and parts they supply to SGI. |
· | Compare the list of facilities identified by suppliers to the CFSI, DoC or LBMA lists of certified smelters. |
· | Continue to assess the strength of the suppliers' compliance program. |
· | Consider replacing suppliers that are found to use smelters or refiners that have been linked to armed conflict in covered countries based on SGI's due diligence process. |
(4) Use of Resources Provided by Industry Organizations and Independent Third Party Audits of Refiner's Due Diligence Practices
SGI does not typically have a direct relationship with 3TG smelters and refiners and does not perform or direct audits of these entities within our supply chain. We rely on and will continue to rely on the audits conducted by independent third parties of smelters' and refiners' sourcing, such as those made available through the CFSI's Conflict-Free Smelter Program. SGI supplier responses to the CMRT which named facilities as smelters or refiners were compared to the list of smelters and refiners maintained by the Conflict-Free Sourcing Initiative ("CFSI"), the United States Department of Commerce (DoC) and the London Bullion Market Association (LBMA) to confirm that the named smelter was listed as valid and conflict-free.
(5) Preparation of Annual Conflict Minerals Report with Supply Chain Due Diligence
SGI reports annually on supply chain due diligence by filing a Form SD and Conflict Minerals Report with the SEC. SGI's Form SD and Conflict Minerals Report can be found in the list of SEC filing on SGI's Investor Relations page: http://investors.sgi.com/sec.cfm
Results
SGI reviewed the information reported by our direct suppliers through the survey process and available to SGI from the CFSI, among others. As of May 6th 2016, SGI had received responses from 97% of its surveyed suppliers. From the responses with completed forms, 278 of SGI direct suppliers were reported to provide products or have a supply chain that provides products containing 3TGs. Those which claimed that products they provide to SGI contain 3TGs were asked to include smelter and refiner information on the smelter tab of their CMRT.
In spite of SGI's Due Diligence Measures, some suppliers within SGI's supply chain are still unable to provide the smelters or refiners used for products supplied. Furthermore, other suppliers provided responses at the company or division level and indicated an "unknown" status in terms of determining the origin of conflict minerals. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our service provider continues to follow up and urge these suppliers to resubmit with increased smelter information. There are some suppliers still unable to provide the smelters or refiners used for materials supplied to us.
Appendix A lists the 320 validated CFSI smelters and refiners that the surveyed suppliers reported to us as being in their supply chains. Appendix B includes an aggregated list of the countries of origin in which the reported facilities collectively source 3TGs, based on the information provided by suppliers and the CFSI.
The large majority of the responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to SGI. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain. Thus, the smelters or refiners identified by our direct suppliers contained in the tables below may contain smelters or refiners that processed conflict minerals that our Direct Suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during 2015. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during 2015, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals.
Steps to Further Mitigate Risk and Improve Due Diligence in 2016
SGI will continue to focus its efforts with its direct suppliers on gathering information via the CMRT reporting template and, as the program progresses, on requiring full completion of all necessary smelter and refiner identification information to enable the validation and disclosure of the smelters and refiners, as well as the tracing of the 3TGs to their location of origin.
Additionally, SGI intends to take the following due diligence steps to further mitigate any risk that the necessary 3TGs in products could benefit armed groups in the Covered Countries:
a. | Provide guidance to SGI's direct suppliers for appropriate management of responses to SGI supplier queries and provision of complete responses needed for conflict mineral regulations, including accurate smelter disclosures needed to trace 3TGs to their origin, and in doing so, work towards validating smelters identified by SGI direct suppliers. |
b. | Update the number of suppliers requested to supply information as the supplier base increases or changes. |
c. | Engage with SGI direct suppliers to educate them on the regulatory requirements with the aim of increasing the response rate and improving the content of the supplier survey responses. |
d. | If identified, engage SGI direct suppliers that provide SGI with 3TGs from sources supporting conflict in the Covered Countries, in order to establish an alternative source of 3TG that does not support such conflict. |
| e. | Stay abreast of the best practices and process changes recommended by OECD and relevant trade associations. |
f. Continue to leverage the expertise provided by third parties, including Assent.
Appendix A:
The table below provides the 320 CFSI-validated smelters or refiners from the total list identified by our direct suppliers that may have been used to process 3TGs necessary to the functionality or production of our products in 2015. Facilities that have been certified as conflict-free by an internationally-recognized validation organization for 3TG smelters and refiners are designated in the column furthest to the right, where the word "Yes" indicates that such an organization validated them as conflict-free.
Metal | Standard Smelter Name | Facility Location | Conflict Free? |
Gold | Advanced Chemical Company | UNITED STATES | Unknown |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Unknown |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Unknown |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Unknown |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes |
Gold | Argor-Heraeus SA | SWITZERLAND | Yes |
Gold | Asahi Pretec Corporation | JAPAN | Yes |
Gold | Asahi Refining Canada Limited | CANADA | Yes |
Gold | Asahi Refining USA Inc. | UNITED STATES | Yes |
Gold | Asaka Riken Co., Ltd. | JAPAN | Yes |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Unknown |
Gold | Aurubis AG | GERMANY | Yes |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes |
Gold | Bauer Walser AG | GERMANY | Unknown |
Gold | Boliden AB | SWEDEN | Yes |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes |
Gold | Caridad | MEXICO | Unknown |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes |
Gold | Cendres + Métaux SA | SWITZERLAND | Unknown |
Gold | Chimet S.p.A. | ITALY | Yes |
Gold | Chugai Mining | JAPAN | Unknown |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Unknown |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Unknown |
Gold | DODUCO GmbH | GERMANY | Yes |
Gold | Dowa | JAPAN | Yes |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes |
Gold | Elemetal Refining, LLC | UNITED STATES | Yes |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes |
Gold | Faggi Enrico S.p.A. | ITALY | Unknown |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unknown |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Unknown |
Gold | Geib Refining Corporation | UNITED STATES | Unknown |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unknown |
Gold | Guangdong Jinding Gold Limited | CHINA | Unknown |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unknown |
Gold | Heimerle + Meule GmbH | GERMANY | Yes |
Gold | Heraeus Ltd. Hong Kong | CHINA | Yes |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Unknown |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes |
Gold | Istanbul Gold Refinery | TURKEY | Yes |
Gold | Japan Mint | JAPAN | Yes |
Gold | Jiangxi Copper Company Limited | CHINA | Yes |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Unknown |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unknown |
Gold | Kazzinc | KAZAKHSTAN | Yes |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Unknown |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | Unknown |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Unknown |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Unknown |
Gold | Lingbao Gold Company Limited | CHINA | Unknown |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Unknown |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown |
Gold | Materion | UNITED STATES | Yes |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes |
Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Unknown |
Gold | Metalor Technologies SA | SWITZERLAND | Yes |
Gold | Metalor USA Refining Corporation | UNITED STATES | Yes |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes |
Gold | Mitsubishi Materials Corporation | JAPAN | Yes |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes |
Gold | Morris and Watson | NEW ZEALAND | Unknown |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Unknown |
Gold | Nihon Material Co., Ltd. | JAPAN | Yes |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Unknown |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes |
Gold | PAMP SA | SWITZERLAND | Yes |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unknown |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes |
Gold | PX Précinox SA | SWITZERLAND | Yes |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes |
Gold | Republic Metals Corporation | UNITED STATES | Yes |
Gold | Royal Canadian Mint | CANADA | Yes |
Gold | SAAMP | FRANCE | Unknown |
Gold | Sabin Metal Corp. | UNITED STATES | Unknown |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Unknown |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unknown |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Unknown |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes |
Gold | SEMPSA Joyería Platería SA | SPAIN | Yes |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes |
Gold | Singway Technology Co., Ltd. | TAIWAN | Yes |
Gold | So Accurate Group, Inc. | UNITED STATES | Unknown |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes |
Gold | Sudan Gold Refinery | SUDAN | Unknown |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes |
Gold | T.C.A S.p.A | ITALY | Yes |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unknown |
Gold | Tony Goetz NV | BELGIUM | Unknown |
Gold | Torecom | KOREA, REPUBLIC OF | Unknown |
Gold | Umicore Brasil Ltda. | BRAZIL | Yes |
Gold | Umicore Precious Metals Thailand | THAILAND | Yes |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes |
Gold | Valcambi SA | SWITZERLAND | Yes |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Unknown |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes |
Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | Unknown |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes |
Tantalum | D Block Metals, LLC | UNITED STATES | Yes |
Tantalum | Duoluoshan | CHINA | Yes |
Tantalum | E.S.R. Electronics | UNITED STATES | Unknown |
Tantalum | Exotech Inc. | UNITED STATES | Yes |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes |
Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Unknown |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes |
Tantalum | H.C. Starck Inc. | UNITED STATES | Yes |
Tantalum | H.C. Starck Ltd. | JAPAN | Yes |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes |
Tantalum | KEMET Blue Metals | MEXICO | Yes |
Tantalum | KEMET Blue Powder | UNITED STATES | Yes |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes |
Tantalum | LSM Brasil S.A. | BRAZIL | Yes |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes |
Tantalum | Mineração Taboca S.A. | BRAZIL | Yes |
Tantalum | Mitsui Mining & Smelting | JAPAN | Yes |
Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
Tantalum | Plansee SE Liezen | AUSTRIA | Yes |
Tantalum | Plansee SE Reutte | AUSTRIA | Yes |
Tantalum | QuantumClean | UNITED STATES | Yes |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes |
Tantalum | Taki Chemicals | JAPAN | Yes |
Tantalum | Telex Metals | UNITED STATES | Yes |
Tantalum | Tranzact, Inc. | UNITED STATES | Yes |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes |
Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes |
Tin | Alpha | UNITED STATES | Yes |
Tin | An Thai Minerals Company Limited | VIET NAM | Unknown |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Unknown |
Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | Unknown |
Tin | China Tin Group Co., Ltd. | CHINA | Yes |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes |
Tin | CV Ayi Jaya | INDONESIA | Yes |
Tin | CV Dua Sekawan | INDONESIA | Unknown |
Tin | CV Gita Pesona | INDONESIA | Yes |
Tin | CV Serumpun Sebalai | INDONESIA | Yes |
Tin | CV Tiga Sekawan | INDONESIA | Unknown |
Tin | CV United Smelting | INDONESIA | Yes |
Tin | CV Venus Inti Perkasa | INDONESIA | Yes |
Tin | Dowa | JAPAN | Yes |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Unknown |
Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes |
Tin | EM Vinto | BOLIVIA | Yes |
Tin | Estanho de Rondônia S.A. | BRAZIL | Unknown |
Tin | Feinhütte Halsbrücke GmbH | GERMANY | Unknown |
Tin | Fenix Metals | POLAND | Yes |
Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Unknown |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Unknown |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Unknown |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Unknown |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Unknown |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Unknown |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Unknown |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Yes |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
Tin | Melt Metais e Ligas S/A | BRAZIL | Yes |
Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
Tin | Metallic Resources, Inc. | UNITED STATES | Yes |
Tin | Metallo-Chimique N.V. | BELGIUM | Yes |
Tin | Mineração Taboca S.A. | BRAZIL | Yes |
Tin | Minsur | PERU | Yes |
Tin | Mitsubishi Materials Corporation | JAPAN | Yes |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Unknown |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes |
Tin | Phoenix Metal Ltd. | RWANDA | Unknown |
Tin | PT Alam Lestari Kencana | INDONESIA | Unknown |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes |
Tin | PT Artha Cipta Langgeng | INDONESIA | Yes |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes |
Tin | PT Babel Inti Perkasa | INDONESIA | Yes |
Tin | PT Bangka Kudai Tin | INDONESIA | Unknown |
Tin | PT Bangka Prima Tin | INDONESIA | Yes |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Unknown |
Tin | PT Bangka Tin Industry | INDONESIA | Yes |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes |
Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes |
Tin | PT Bukit Timah | INDONESIA | Yes |
Tin | PT Cipta Persada Mulia | INDONESIA | Yes |
Tin | PT DS Jaya Abadi | INDONESIA | Yes |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes |
Tin | PT Fang Di MulTindo | INDONESIA | Unknown |
Tin | PT Inti Stania Prima | INDONESIA | Yes |
Tin | PT Justindo | INDONESIA | Yes |
Tin | PT Karimun Mining | INDONESIA | Unknown |
Tin | PT Kijang Jaya Mandiri | INDONESIA | Unknown |
Tin | PT Mitra Stania Prima | INDONESIA | Yes |
Tin | PT Panca Mega Persada | INDONESIA | Yes |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Unknown |
Tin | PT Prima Timah Utama | INDONESIA | Yes |
Tin | PT Refined Bangka Tin | INDONESIA | Yes |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes |
Tin | PT Seirama Tin Investment | INDONESIA | Unknown |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes |
Tin | PT Sukses Inti Makmur | INDONESIA | Yes |
Tin | PT Sumber Jaya Indah | INDONESIA | Yes |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes |
Tin | PT Tinindo Inter Nusa | INDONESIA | Yes |
Tin | PT Tirus Putra Mandiri | INDONESIA | Unknown |
Tin | PT Tommy Utama | INDONESIA | Yes |
Tin | PT Wahana Perkit Jaya | INDONESIA | Yes |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
Tin | Rui Da Hung | TAIWAN | Yes |
Tin | Soft Metais Ltda. | BRAZIL | Yes |
Tin | Thaisarco | THAILAND | Yes |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes |
Tungsten | ACL Metais Eireli | BRAZIL | Unknown |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Unknown |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Unknown |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Unknown |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | H.C. Starck GmbH | GERMANY | Yes |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Unknown |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | Unknown |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Unknown |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Unknown |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Unknown |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Unknown |
Tungsten | Kennametal Fallon | UNITED STATES | Unknown |
Tungsten | Kennametal Huntsville | UNITED STATES | Yes |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Unknown |
Tungsten | Niagara Refining LLC | UNITED STATES | Yes |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes |
Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Yes |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Unknown |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | Unknown |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Unknown |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
Appendix B:
This list below includes possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in this Report, these possible countries of origin cannot necessarily be linked to our products.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.