Exhibit 1.01
CONFLICT MINERALS REPORT
This report for the reporting period of January 1 to December 31, 2014, is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”).
COMPANY BACKGROUND
For more than a century, Huntington Ingalls Industries, Inc. (“HII” or the “Company,” “we,” “us,” or “our”) has been designing, building, overhauling, and repairing ships primarily for the U.S. Navy and the U.S. Coast Guard. We are the nation’s sole designer, builder, and refueler of nuclear-powered aircraft carriers, a builder of amphibious assault and expeditionary warfare ships for the U.S. Navy, the sole builder of National Security Cutters for the U.S. Coast Guard, one of only two companies currently designing and building nuclear-powered submarines for the U.S. Navy and one of only two companies that builds the Navy’s current fleet of DDG 51Arleigh Burke-class destroyers. We are the exclusive provider of Refueling and Complex Overhaul services for nuclear-powered aircraft carriers, a full-service systems provider for the design, engineering, construction, and life cycle support of major programs for surface ships and a provider of fleet support and maintenance services for the U.S. Navy.
We conduct most of our business with the U.S. Government, principally the Department of Defense. As prime contractor, principal subcontractor, team member or partner, we participate in many high-priority U.S. defense technology programs. We also provide a range of services to the energy and oil and gas industries as well as government customers.
HII procures a large variety of products from many different suppliers. Some of the products HII procures from suppliers contain conflict minerals, which are also referred to as “3TGs” ( “conflict minerals” and “3TGs” are tin, tantalum, tungsten and gold as more specifically described in and covered by the Securities and Exchange Commission’s regulations and guidance). HII is a downstream purchaser and is a number of steps removed in the supply chain from the mining and smelting of 3TGs. As a result, HII relies on its suppliers to represent whether the products they are supplying to HII contain 3TGs.
CONFLICT MINERALS POLICY
HII has adopted a conflict minerals policy and related procedures focused on HII’s commitment to sourcing components and materials from suppliers that share its ethical values and that support compliance with the Securities and Exchange Commission’s regulations as well as HII’s disclosure obligations related to conflict minerals. This policy and related procedures have guided HII’s development of internal systems, supply chain due diligence efforts and, ultimately, HII’s Reasonable Country of Origin Inquiry (“RCOI”).
Since October 2012, HII’s efforts related to conflict minerals have included: understanding and developing internal policies, procedures, practices, processes, and systems designed to obtain information about 3TGs and their origin that may be incorporated into HII’s products; providing transparency through its product supply chain; and, more generally, providing knowledge to and achieving engagement from its suppliers concerning the requisite conflict minerals issues. Additionally, HII belongs to and participates with several professional organizations that devote time and focus to understanding conflict mineral matters and how to appropriately design, improve and implement processes to better understand and obtain data about the sources of conflict minerals.
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REPORTING YEAR ACTIVITY
For products completed and delivered by HII in 2014, which included vessels, vessel components, water and air tight doors, radiological shielding and electrical distribution panels, HII conducted an RCOI as more specifically described below. The results of the RCOI led HII to conduct due diligence of a limited number of suppliers to four of the Company’s business units. The information provided by a limited number of those suppliers indicated that some 3TGs contained in certain of these suppliers’ products and supplied to these business units may have originated in a Covered Country (Democratic Republic of Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola), hereinafter referred to collectively as the “DRC.” As further discussed below, some of these suppliers reported sourcing from smelters that may procure some 3TGs from the DRC, but upon further inquiry HII found that such smelters have been verified by the Conflict Free Sourcing Initiative (“CFSI”) to only procure from conflict-free sources that do not support armed conflict in the DRC. Other smelters identified by suppliers are in the process of being audited by CFSI to determine if they only obtain 3TGs from conflict-free sources, while information about other smelters and the origin of the 3TGs they provide is unknown.
REASONABLE COUNTRY OF ORIGIN INQUIRY
In addition to the efforts described above, HII’s RCOI was designed to determine whether the 3TGs in its relevant products originated in the DRC. In part, HII’s RCOI process included:
| • | forming a long-term working group comprised of representatives from HII’s operational, compliance, legal and supply chain functions (at both the corporate and business-unit levels), as well as external advisors with conflict minerals subject matter expertise; |
| • | evaluating the Securities and Exchange Commission’s regulations, adopting initial policies to support compliance with these regulations, reviewing and updating practices and providing information to suppliers to make them knowledgeable of the Securities and Exchange Commission’s regulations, and, to the extent necessary, developing reasonable interpretations of these regulations that allow HII to apply the regulations to its specific operations and industry; |
| • | providing information to HII’s suppliers about, and linked access to, the Securities and Exchange Commission’s conflict minerals regulations and other supporting publications; |
| • | requiring suppliers as part of the purchase order process to represent if their products contain 3TGs, and if so, to further require the suppliers to provide either a completed HII-issued questionnaire, a completed Global e-Sustainability Initiative (“GeSI”) template, or some other form containing information about the type and origin of 3TGs in their products; |
| • | compiling data from supplier representations; |
| • | communicating with, and seeking information from, any major suppliers that did not timely respond to surveys or provided incomplete surveys; and |
| • | conducting periodic reviews with the Company’s long-term working group and the supply chain organizations to understand the data and information submitted by suppliers and additional steps that were taken to seek additional information from suppliers. |
DUE DILIGENCE MEASURES
HII has undertaken measures to develop due diligence processes that are informed by and track to the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. These due diligence measures include:
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Company Management Systems
| • | Publishing and maintaining a conflict minerals policy and related procedures to address HII’s commitment to comply with the Rule. Our policy and procedures include commitments such as: |
| ¡ | To the extent practicable, and consistent with its contractual obligations to its customers, HII is committed to refraining from relationships that could knowingly result in: |
| • | aiding, directly or indirectly, armed groups operating in the DRC through sales of 3TGs; or |
| • | the willful concealment of information related to the transport of 3TGs from the DRC and their use in manufactured products. |
| ¡ | Sourcing components and materials from suppliers that share its ethical values. Our procedures outline the requirements to survey our suppliers and obtain necessary details to support compliance with the Rule. They further identify the functional parties within the Company responsible for supporting the Rule and assessing the presence of any inconsistencies associated with supplier responses. |
| • | Utilizing electronic databases to collect RCOI responses from suppliers. |
| • | Maintaining communications with our supply chain through supplier websites, which include Frequently Asked Questions from the Aerospace Industries Association (“AIA”). |
| • | Employing mechanisms for interested persons to voice concerns or grievances, including our pre-existing OpenLine as the tool to capture and track concerns or grievances regarding aspects of the Rule either internally or externally. The OpenLine is available 24 hours a day, seven days a week, and can be accessed through either a phone number or website(1-877-631-0020,https://hii-openline.alertline.com/gcs/welcome). |
Assess Supply Chain Risk
| • | Requiring suppliers as part of the purchase order process to represent if their products contain 3TGs, and, if so, to further require the suppliers to provide a completed HII-issued questionnaire, a completed GeSI template, or some other form containing information about the type and origin of 3TGs in their products. |
| • | Including a purchase order clause that requires a supplier to provide HII an updated survey response if the status of any of their product(s) changes prior to final delivery. |
| • | Embracing a practice through the inclusion of a purchase order clause that allows HII to either withhold up to 10% of the purchase order price or terminate the purchase order if HII determines that any representation made by the supplier is inaccurate or incomplete in any respect, or if the supplier fails to timely submit the information required by the clause. |
Response to Supply Chain Risks
| • | Maintain membership and participation in the Manufacturer’s Alliance for Productivity and Innovation (“MAPI”), AIA, and the Electronic Industry Citizenship Coalition (“EICC”), to both participate in the development, and keep abreast, of industry “best practices” for conflict minerals due diligence efforts. |
| • | Obtain and review published information about due diligence and the results of audits of smelters and refiners as performed and reported by the EICC and GeSI Conflict-Free Sourcing Initiative. |
| • | Analyze supplier responses and evaluate information in a manner designed to provide the Company with a reasonable basis for its conclusions in the 2015 Form SD and this Conflict Minerals Report, including evaluating the raw number of supplier responses and relative dollar value of purchased products represented by such responses, as well as focusing on suppliers relevant to the Reporting Period. |
| • | Supporting information-sharing systems within industry aimed at improving assessment of supplier due diligence in the supply chain of minerals from conflict-affected and high-risk areas. |
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Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
| • | Due to the downstream nature of our business, HII does not have direct relationships with smelters or refiners and therefore does not perform audits of these entities. HII, however, supports the efforts of organizations that conduct audits in order to confirm the conflict-free status of impacted smelters and refiners. |
Report on Supply Chain Due Diligence
| • | This Conflict Minerals Report is our public annual report on the due diligence efforts of our supply chain. |
INFORMATION REGARDING COUNTRY OF ORIGIN
As noted above, in response to HII’s country of origin inquiries, a limited number of HII’s suppliers indicated that, due to a lack of definitive information from their supply chains, certain of their products may contain one or more 3TGs sourced from the DRC; however, none of those suppliers reported finding any indication that such 3TGs may have been used to finance armed conflict in the DRC. Accordingly, HII believes that the results of its RCOI indicated that it was appropriate to conduct due diligence measures to obtain additional information, as described below.
HII engaged with each supplier that suggested possible sourcing of 3TGs from the DRC to obtain further supporting documentation for their statements. These suppliers were only able to provide either (i) conflict minerals disclosure on a company-wide basis in which they were unable to verify whether the specific products sold to HII contained 3TGs sourced from the DRC, or (ii) additional information that indicated the names and locations of known smelters from which their 3TGs may have originated, but without additional information to verify whether the 3TGs in their products sold to HII originated from the DRC, or that their RCOI was ongoing and not yet complete. Appendix A lists the smelters named by those suppliers, but the inclusion of a smelter in Appendix A does not indicate that HII products necessarily contain 3TGs processed by that smelter. Comparing the list of those smelters named in Appendix A to the Compliant Smelter Detailed Sourcing Information published by CFSI, as well as other publicly-available information, indicated the following:
| – | 143 of the listed smelters had been audited as part of the CFSI initiative and were determined to source their 3TGs only from either countries other than those in and adjoining the DRC, or from conflict-free sources; |
| – | 13 of the listed smelters are in the process of arranging for or are being audited to determine if they source their 3TGs only from either countries other than the DRC and adjoining countries or otherwise from conflict-free sources; and |
| – | 82 of the listed smelters do not appear on the CFSI list. HII has insufficient information from or about these smelters to understand their sources for 3TGs. |
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our Company’s system is based, we support an industry initiative that audits smelters’ and refiners’ due diligence activities. That industry initiative is the EICC and the CFSI. The data on which we relied for certain statements in this report was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report available to CFSI members.
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ONGOING EFFORTS
HII is continuing its ongoing efforts to:
| • | Determine which supplier-provided products contain 3TGs; |
| • | Obtain additional information from direct suppliers as well as others in or with knowledge of the supply chain as to whether their products contain 3TGs and, if so, the origin of those 3TGs, as additional conflict minerals and smelter information becomes available to the supply chain; |
| • | Communicate knowledge and our expectations to suppliers about the type and level of detailed information needed by HII to understand the origin and source of 3TGs; |
| • | Remain actively involved in and participate with industry and other groups, including MAPI, AIA, and the EICC, in order to ascertain best and leading practices and to obtain and share information that may assist in determining whether purchased products contain 3TGs and, if so, the origin of those 3TGs and whether the 3TGs were sourced from conflict-free sources; and |
| • | Provide resources and information to non-issuer suppliers about the Securities and Exchange Commission’s conflict minerals reporting requirements as well as about the CFSI and other informative measures designed to educate about the importance of conflict-free sourcing. |
APPENDIX A
Listed below are the smelters to which we previously referred in this report.
Mineral | Smelter name | Country | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China | ||
| Tantalum | Conghua Tantalum and Niobium Smeltry* | China | ||
| Tantalum | Duoluoshan* | China | ||
| Tantalum | Exotech Inc.* | United States | ||
| Tantalum | F&X Electro-Materials Ltd.* | China | ||
| Tantalum | Global Advanced Metals Aizu* | Japan | ||
| Tantalum | Global Advanced Metals Boyertown* | United States | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | China | ||
| Tantalum | H.C. Starck Inc.* | United States | ||
| Tantalum | H.C. Starck GmbH Laufenburg* | Germany | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | China | ||
| Tantalum | Hi-Temp* | United States | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China | ||
| Tantalum | Jiujiang Tanbre Co., Ltd.* | China | ||
| Tantalum | KEMET Blue Powder* | United States | ||
| Tantalum | King-Tan Tantalum Industry Ltd* | China | ||
| Tantalum | LSM Brasil S.A.* | Brazil | ||
| Tantalum | Metallurgical Products India (Pvt.) Ltd.* | India | ||
| Tantalum | Mineração Taboca S.A.* | Brazil | ||
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Mineral | Smelter name | Country | ||
| Tantalum | Mitsui Mining & Smelting* | Japan | ||
| Tantalum | Molycorp Silmet A.S.* | Estonia | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | China | ||
| Tantalum | Plansee SE Liezen* | Austria | ||
| Tantalum | QuantumClean* | United States | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd* | China | ||
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | China | ||
| Tantalum | Taki Chemicals* | Japan | ||
| Tantalum | Solikamsk Magnesium Works OAO* | Russian Federation | ||
| Tantalum | Telex* | United States | ||
| Tantalum | Ulba* | Kazakhstan | ||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd* | China | ||
| Tantalum | Zhuzhou Cement Carbide* | China | ||
| Tin | Alpha* | United States | ||
| Tin | China Rare Metal Materials Company* | China | ||
| Tin | China Tin Group Co., Ltd. | China | ||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China | ||
| Tin | Cooper Santa* | Brazil | ||
| Tin | CV Serumpun Sebalai | Indonesia | ||
| Tin | CV United Smelting* | Indonesia | ||
| Tin | CV Gita Pesona | Indonesia | ||
| Tin | CV JusTindo | Indonesia | ||
| Tin | CV Makmur Jaya | Indonesia | ||
| Tin | CV Nurjanah | Indonesia | ||
| Tin | Dowa* | Japan | ||
| Tin | EM Vinto* | Bolivia | ||
| Tin | Estanho de Rondônia S.A. | Brazil | ||
| Tin | Fenix Metals | Poland | ||
| Tin | Gejiu Zi-Li | China | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd.* | China | ||
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Mineral | Smelter name | Country | ||
| Tin | Huichang Jinshunda Tin Co. Ltd | China | ||
| Tin | Jiangxi Nanshan | China | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||
| Tin | Linwu Xianggui Smelter Co | China | ||
| Tin | Malaysia Smelting Corporation (MSC)* | Malaysia | ||
| Tin | Melt Metais e Ligas S/A* | Brazil | ||
| Tin | Metallo Chimique | Belgium | ||
| Tin | Mineração Taboca S.A.* | Brazil | ||
| Tin | Minsur* | Peru | ||
| Tin | Mitsubishi Materials Corporation* | Japan | ||
| Tin | Novosibirsk Integrated Tin Works | Russian Federation | ||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin | OMSA* | Bolivia | ||
| Tin | PT Alam Lestari Kencana | Indonesia | ||
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia | ||
| Tin | PT Artha Cipta Langgeng* | Indonesia | ||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||
| Tin | PT Bangka Putra Karya* | Indonesia | ||
| Tin | PT Bangka Kudai Tin | Indonesia | ||
| Tin | PT Babel Inti Perkasa* | Indonesia | ||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | ||
| Tin | PT Bangka Tin Industry* | Indonesia | ||
| Tin | PT Belitung Industri Sejahtera* | Indonesia | ||
| Tin | PT Bukit Timah* | Indonesia | ||
| Tin | PT DS Jaya Abadi* | Indonesia | ||
| Tin | PT Eunindo Usaha Mandiri* | Indonesia | ||
| Tin | PT HP Metals Indonesia | Indonesia | ||
| Tin | PT Inti Stania Prima | Indonesia | ||
| Tin | PT Koba Tin | Indonesia | ||
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Mineral | Smelter name | Country | ||
| Tin | PT Mitra Stania Prima* | Indonesia | ||
| Tin | PT Panca Mega Persada* | Indonesia | ||
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia | ||
| Tin | PT Seirama Tin investment | Indonesia | ||
| Tin | PT Sumber Jaya Indah | Indonesia | ||
| Tin | PT Supra Sukses Trinusa | Indonesia | ||
| Tin | PT Tinindo Inter Nusa* | Indonesia | ||
| Tin | PT Tommy Utama | Indonesia | ||
| Tin | PT Yinchendo Mining Industry | Indonesia | ||
| Tin | PT Karimun Mining | Indonesia | ||
| Tin | PT Prima Timah Utama* | Indonesia | ||
| Tin | PT REFINED BANGKA TIN* | Indonesia | ||
| Tin | PT Sariwiguna Binasentosa* | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa* | Indonesia | ||
| Tin | PT Tambang Timah* | Indonesia | ||
| Tin | PT Timah (Persero), Tbk* | Indonesia | ||
| Tin | Rui Da Hung | Taiwan | ||
| Tin | Soft Metais, Ltda. | Brazil | ||
| Tin | Thaisarco* | Thailand | ||
| Tin | White Solder Metalurgia e Mineração Ltda.* | Brazil | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | China | ||
| Tin | Yunnan Tin Company, Ltd.* | China | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.** | Viet Nam | ||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd* | Viet Nam | ||
| Tungsten | Wolfram Bergbau und Hütten AG* | Austria | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China | ||
| Tungsten | Xiamen Tungsten Co., Ltd.* | China | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | China | ||
| Tungsten | A.L.M.T. Corp.** | Japan | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co. LTD** | China | ||
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Mineral | Smelter name | Country | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.** | China | ||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd.** | China | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd.* | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | China | ||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd.** | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China | ||
| Tungsten | Global Tungsten & Powders Corp.* | United States | ||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG** | Germany | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | China | ||
| Tungsten | Japan New Metals Co., Ltd.* | Japan | ||
| Tungsten | Kennametal Fallon** | United States | ||
| Tungsten | Kennametal Huntsville** | United States | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | China | ||
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | China | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.** | China | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.** | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.** | China | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China | ||
| Tungsten | Niagara Refining LLC** | United States | ||
| Tungsten | Wolfram Company CJSC | Russian Federation | ||
| Gold | Advanced Chemical Company | United States | ||
| Gold | Aida Chemical Industries Co. Ltd.* | Japan | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | Germany | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção* | Brazil | ||
| Gold | Argor-Heraeus SA* | Switzerland | ||
| Gold | Asahi Pretec Corporation* | Japan | ||
| Gold | Asaka Riken Co Ltd | Japan | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S.* | Turkey | ||
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Mineral | Smelter name | Country | ||
| Gold | Aurubis AG* | Germany | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold | Bauer Walser AG | Germany | ||
| Gold | Boliden AB* | Sweden | ||
| Gold | C. Hafner GmbH + Co. KG* | Germany | ||
| Gold | Caridad | Mexico | ||
| Gold | CCR Refinery – Glencore Canada Corporation* | Canada | ||
| Gold | Cendres + Métaux SA | Switzerland | ||
| Gold | Chimet S.p.A.* | Italy | ||
| Gold | China National Gold Group Corporation | China | ||
| Gold | Chugai Mining | Japan | ||
| Gold | Colt Refining | United States | ||
| Gold | Daejin Indus Co. Ltd | Korea, Republic Of | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||
| Gold | Do Sung Corporation | Korea, Republic Of | ||
| Gold | Doduco | Germany | ||
| Gold | Dowa* | Japan | ||
| Gold | Eco-System Recycling Co., Ltd.* | Japan | ||
| Gold | FSE Novosibirsk Refinery | Russian Federation | ||
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | China | ||
| Gold | Guangdong Jinding Gold Limited | China | ||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||
| Gold | Heimerle + Meule GmbH* | Germany | ||
| Gold | Heraeus Ltd. Hong Kong* | Hong Kong | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG* | Germany | ||
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | China | ||
| Gold | Hwasung CJ Co. Ltd | Korea, Republic Of | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | ||
| Gold | Ishifuku Metal Industry Co., Ltd.* | Japan | ||
| Gold | Istanbul Gold Refinery* | Turkey | ||
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Mineral | Smelter name | Country | ||
| Gold | Japan Mint* | Japan | ||
| Gold | Jiangxi Copper Company Limited | China | ||
| Gold | Johnson Matthey Inc* | United States | ||
| Gold | Johnson Matthey Ltd* | Canada | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant* | Russian Federation | ||
| Gold | JSC Uralelectromed* | Russian Federation | ||
| Gold | JX Nippon Mining & Metals Co., Ltd.* | Japan | ||
| Gold | Kazzinc Ltd* | Kazakhstan | ||
| Gold | Kennecott Utah Copper LLC* | United States | ||
| Gold | Kojima Chemicals Co., Ltd* | Japan | ||
| Gold | Korea Metal Co. Ltd | Korea, Republic Of | ||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold | Lingbao Gold Company Limited | China | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | ||
| Gold | LS-NIKKO Copper Inc.* | Korea, Republic Of | ||
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | China | ||
| Gold | Materion* | United States | ||
| Gold | Matsuda Sangyo Co., Ltd.* | Japan | ||
| Gold | Metallurgica Met-Mex Peñoles, S.A.* | Mexico | ||
| Gold | Metalor Technologies (Hong Kong) Ltd* | Hong Kong | ||
| Gold | Metalor Technologies (Singapore) Pte. Ltd.* | Singapore | ||
| Gold | Metalor Technologies SA* | Switzerland | ||
| Gold | Metalor USA Refining Corporation* | United States | ||
| Gold | Mitsubishi Materials Corporation* | Japan | ||
| Gold | Mitsui Mining and Smelting Co., Ltd.* | Japan | ||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş.* | Turkey | ||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||
| Gold | Nihon Material Co. LTD* | Japan | ||
| Gold | Ohio Precious Metals, LLC* | United States | ||
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Mineral | Smelter name | Country | ||
| Gold | Ohura Precious Metal Industry Co., Ltd* | Japan | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)* | Russian Federation | ||
| Gold | OJSC Kolyma Refinery | Russian Federation | ||
| Gold | PAMP SA* | Switzerland | ||
| Gold | Penglai Penggang Gold Industry Co Ltd | China | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||
| Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia | ||
| Gold | PX Précinox SA* | Switzerland | ||
| Gold | Rand Refinery (Pty) Ltd* | South Africa | ||
| Gold | Royal Canadian Mint* | Canada | ||
| Gold | Sabin Metal Corp. | United States | ||
| Gold | Samduck Precious Metals | Korea, Republic Of | ||
| Gold | SAMWON METALS Corp. | Korea, Republic Of | ||
| Gold | Schone Edelmetaal* | Netherlands | ||
| Gold | SEMPSA Joyería Platería SA* | Spain | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd* | China | ||
| Gold | So Accurate Group, Inc. | United States | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||
| Gold | Solar Applied Materials Technology Corp.* | Taiwan | ||
| Gold | Sumitomo Metal Mining Co., Ltd.* | Japan | ||
| Gold | Tanaka Kikinzoku Kogyo K.K.* | Japan | ||
| Gold | The Great Wall Gold and Silver Refinery of China | China | ||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd* | China | ||
| Gold | Tokuriki Honten Co., Ltd* | Japan | ||
| Gold | Torecom | Korea, Republic Of | ||
| Gold | Umicore Brasil Ltda* | Brazil | ||
| Gold | Umicore Precious Metals Thailand* | Thailand | ||
| Gold | Umicore SA Business Unit Precious Metals Refining* | Belgium | ||
| Gold | United Precious Metal Refining, Inc.* | United States | ||
| Gold | Valcambi SA* | Switzerland | ||
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Mineral | Smelter name | Country | ||
| Gold | Western Australian Mint trading as The Perth Mint* | Australia | ||
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD.* | Japan | ||
| Gold | Yokohama Metal Co Ltd | Japan | ||
| Gold | Yunnan Copper Industry Co Ltd | China | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China | ||
| Gold | Zijin Mining Group Co. Ltd* | China | ||
| * | Denotes smelters verified as conflict-free by CFSI |
| ** | Denotes smelters currently pursuing or undergoing audit by CFSI to determine their conflict-free status |
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our Company’s system is based, we support an industry initiative that audits smelters’ and refiners’ due diligence activities. That industry initiative is the EICC and the CFSI. The data on which we relied for certain statements in this report was obtained through our membership in the CFSI.
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