Exhibit 1.01
KEYSIGHT TECHNOLOGIES, INC.
Conflict Minerals Report
For The Year Ended December 31, 2015
This Conflict Minerals Report (the “Report”) of Keysight Technologies, Inc. (“Keysight” or “we”) for the year ended December 31, 2015 is designed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”).
Pursuant to the Rule, Keysight conducted due diligence regarding the source and chain of custody of the necessary conflict minerals in our products. Based on our efforts assessing our supply chain, and the uncertainty in responses we received from our suppliers, we cannot exclude the possibility that some of the tin, tungsten, tantalum and gold (collectively referred to herein as “conflict minerals” or “3TGs”) present in our supply chain may have originated in the Democratic Republic of Congo (“DRC”) or adjoining countries (collectively the “Covered Countries”). For this reason, we are required under the Rule to submit this Report as an Exhibit to Keysight’s Form SD.
This report has been prepared by Keysight with the assistance of our third-party vendor, Assent Compliance (“Assent”). The information 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.
1. Company Overview
Keysight designs and manufactures electronic measurement solutions for the communications, electronics and defense industries. We provide electronic measurement instruments and systems and related software, software design tools, and related services that are used in the design, development, manufacture, installation, deployment and operation of electronics equipment. Related services include start-up assistance, instrument productivity, application services and instrument calibration and repair. We also offer customization, consulting and optimization services throughout the customer's product lifecycle. Most instruments we manufacture utilize some amount of tungsten, tantalum, tin and gold.
2. Conflict Minerals Policy
Keysight is committed to complying with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) and requiring that same commitment from our supply chain partners. To that end, Keysight’s Supplier Environmental and Social Responsibility Code of Conduct requires suppliers to take reasonable measures to ensure products, parts, components and materials supplied to Keysight are “DRC (Democratic Republic of Congo) conflict free” as that term is used under Section 1502 of the Dodd-Frank Act. In addition, we maintain a Statement on Conflict Minerals publicly available on our website which sets out our position.
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1 The term “conflict mineral” 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. Tin, Tungsten, Tantalum and Gold will herein be referred to as the 3TGs for discussion purposes.
3. Description of Reasonable Country of Origin Inquiry
In undertaking the reasonable country of origin inquiry (“RCOI”), Keysight conducted a survey of all of its strategic and core suppliers, representing a majority portion of Keysight’s supplier spend in 2015.2 Keysight conducted analysis on our supply chain to remove suppliers based on the following criteria:
• | The company supplies Keysight with packaging only (excluding labels); |
• | The company supplies Keysight only with items that do not end up in Keysight’s products (including equipment used to make our products but not a part of the actual products themselves); |
• | The company is a test lab providing Keysight with product testing only; |
• | The company is a service provider only; |
• | The company has not supplied anything to Keysight in the last two years; and |
• | The company does not meet Keysight’s criteria for supplying items containing 3TGs. |
Keysight provided Assent a list of identified strategic and core suppliers for upload to the Assent Compliance Manager tool for tracking purposes. Keysight then conducted the supplier survey portion of the RCOI, using the EICC-GeSI Conflict Minerals Reporting Template (“CMRT”). Keysight contacted suppliers electronically and requested that they respond to the questions in the CMRT with respect to their supply chain items provided to Keysight. With the help of Assent, we followed up with nonresponsive suppliers a minimum of three times to encourage completion and assist with questions regarding the CMRT. Keysight also offered additional training and support to the suppliers through Assent’s training programs and individual support model.
The Keysight program continues to include automated data validation on all submitted supplier CMRTs. The goal of data validation is to identify the accuracy of submissions and identify any contradictory answers in the CMRT. In practice, data validation flags inconsistent answers by a supplier in the CMRT. For instance, if in response to Question 5 of the CMRT a supplier reports not having received relevant origin information from all of its conflict mineral suppliers, the supplier must also respond “no” to Question 4, which asks whether 100% of its conflict minerals from the Covered Countries come from recycled sources. Automated data validation screens for this and similar agreement in a CMRT.
All submitted CMRTs are accepted and classified as valid or invalid so that all data is retained. Suppliers are then contacted in regards to invalid forms and are encouraged to resubmit using a valid form. Of the invalid CMRTs that were flagged in the system, all but one was resolved and replaced by a valid submission.
4. Due Diligence Process
Design of Due Diligence
The due diligence Keysight has undertaken pursuant to the Rule has been designed to conform, in all respects, with the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold, tin, tantalum and tungsten. Below we summarize our approach to due diligence.
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2Strategic suppliers are those Keysight vendors that are globally managed and impact multiple business units or sites. They are considered strategic to our long-term success as a company and typically represent Keysight’s highest spend. Because they are integral to our business and fully integrated into our supply chain, they also pose significant business risk should they stop supplying Keysight for any reason. Core suppliers are those vendors we consider as foundational to the success of a Keysight site or business unit. They may be globally or locally managed and are moderately integrated into our supply chain. Like strategic suppliers, core suppliers also typically represent high spend and potential business impact should supply be interrupted.
The Company’s conflict minerals due diligence process includes the five steps as defined by the OECD Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by the Company is outlined below.
Establish Strong Company Management Systems
Internal Team
Keysight has established a management system for conflict minerals compliance. Our management system includes an internal team comprised of members of the Legal, the Product Regulatory Affairs and Global Procurement departments. Their efforts are supported by Keysight’s General Counsel, as well as other executive-level representatives. The team of regulatory and legal subject matter experts includes (in alphabetical order):
• | Manoj Chaudhari, Procurement Compliance Program Manager |
• | Brendan Kelleher, Global Compliance Director |
• | Jeffrey Li, Vice President and Assistant General Counsel |
• | James C. Powell, Product Regulatory Compliance, Americas Program Manager |
• | Robert Tait, Global Product Regulatory Compliance Manager |
• | BT Khoo, Global Procurement and Materials Compliance Director |
The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by James C. Powell, who acts as the conflict minerals program manager. Senior management and our Board of Directors is briefed about the results of our program efforts as necessary.
Control Systems
We have put into place necessary controls to promote compliance with the Rule. One central control is our Standards of Business Conduct (“SBC”), Keysight’s employee code of conduct which outlines expected behaviors for all Keysight employees. The SBC includes instructions to employees to ensure that all third parties acting on behalf of Keysight comply with current laws on conflict minerals. We also provide multiple mechanisms whereby employees and suppliers can report violations of Keysight’s policies, including an anonymous hotline managed by the Compliance team within the Legal Department. Additionally, inquiries regarding conflict minerals may be submitted via dedicated e-mail address managed by Keysight’s Product Regulatory team.
Further, our Supplier Environmental and Social Responsibility Code of Conduct, directs all Keysight suppliers to “take reasonable measures to ensure products, parts, components and materials supplied to Keysight are ‘DRC (Democratic Republic of Congo) conflict free.’” Keysight communicates this requirement in writing to all suppliers, and suppliers must complete an online verification survey to ensure compliance with Keysight’s supply chain requirements. As we enter into new supplier agreements, or renew existing contracts, we add a clause requiring suppliers to provide information about the sources (including smelters) of conflict minerals in products they supply to Keysight.
Supplier Engagement
In an effort to come into line with the OECD requirement to strengthen engagement with suppliers, Keysight has, through Assent, offered and provided our suppliers with education on conflict minerals and the related requirements of the Rule. Feedback from this engagement has allowed us to enhance the training by focusing and adapting it to each user’s needs. It has also allowed us to make clear our expectations to suppliers in our supply chain.
Grievance Mechanism
Various communication channels exist to serve as grievance mechanisms for early-warning risk awareness. We have multiple longstanding grievance mechanisms whereby employees (internal) and suppliers (external) can report violations of Keysight’s policies. This includes, but is not limited to our whistleblower hotline, which is accessible online to internal and external parties alike. The web address for this hotline is included on every page of our publicly available SBC. Employees also may take advantage of Keysight’s open door policy to escalate concerns to management, Internal Audit or our Legal Department.
Maintain Records
Finally, we have adopted a policy to retain relevant documentation relating to our conflict minerals compliance efforts. Documentation will be retained for a period of 10 years.
Identify and Assess Risks in the Supply Chain
In accordance with OECD Guidelines, we believe it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified conflict-free pose a significant risk to our supply chain. We employ the Assent Compliance Manager software to assist in evaluating risk. The software provides us a classification of high, medium or low risk for each of our suppliers based on three criteria: (1) whether the supplier sources conflict minerals from a company verified as an actual smelter or refiner by the Conflict-Free Sourcing Initiative (“CFSI”) (2) the proximity of a supplier’s smelter to the Covered Countries; and (3) whether the supplier’s smelter is certified conflict-free by either the CFSI or the London Bouillon Market Association (“LBMA”) Responsible Gold Programme.
Keysight, with the help of Assent, reviewed all CMRT responses submitted by our strategic and core suppliers. We do not typically have a direct relationship with smelters and refiners of conflict minerals, and we do not perform or direct audits of these entities within our supply chain. Therefore, to examine the smelters and refiners listed by our suppliers in CMRTs, Assent compared these facilities to the list of smelters maintained by the CFSI, the United States Department of Commerce and the LBMA. If a supplier indicated on its CMRT that the facility was certified as conflict-free, Assent confirmed that the name was listed as such by CFSI.
Additionally, Keysight evaluates our suppliers on the strength of their conflict minerals compliance programs, which further assists us to identify risk in the supply chain. While conflict minerals compliance is a new concept and many companies do not have fulsome compliance programs, we believe tracking the strength of our suppliers’ programs meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions in the future. We focus on the following questions in the CMRT in evaluating the current status of suppliers’ compliance programs:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
Keysight deems suppliers to have a strong compliance program if they answer yes to each of these four questions. Anything less represents a weak program in our eyes and an opportunity for improvement by the supplier and Keysight.
This year Keysight included additional follow-ups if, in response to Question 5 of the CMRT, a supplier reports not having received relevant origin information from all of its conflict mineral suppliers. If a supplier stated on their CMRT that it had received responses from less than 50% of its supply chain, these
suppliers were asked to verify if this statement was still true. If the supplier had updates to the statement, it was asked to submit an updated CMRT.
We believe that our approach focusing on suppliers’ smelters and conflict minerals compliance programs represent a reasonable effort to determine the mines or locations of origin of the conflict minerals in our products. Our current policy requires us to retain documentation of this inquiry for at least five years.
Design and Implement a Strategy to Respond to Identified Risks
Once a conflict mineral-related risk is identified, Keysight has a risk management plan that goes into effect to explore and mitigate the risk. As an initial step, we ensure that all suppliers understand our expectations regarding Dodd-Frank Act compliance by providing them documented instructions on CMRT completion. Escalations are sent to non-responsive suppliers to outline the importance of submitting a CMRT response and describe the cooperation required of our suppliers to ensure compliance to the Rule. Updates on this process are provided regularly to Keysight management.
Keysight communicates directly with suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries. As part of this communication, Keysight suggests that the supplier source 3TGs from sources that do not support such conflict, as provided in the OECD guidance. To date, we have not identified any instance in which it was necessary to terminate a contract or find an alternate supplier due to lack of compliance with the Rule or Keysight’s requirements.
Carry Out Independent Third-Party Audit
We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. We rely upon industry associations that administer independent third-party smelter and refinery audit programs. During this reporting year, Keysight became a member for CFSI and is working in support and promotion of its conflict-free smelter program (“CFSP”) audit programs.
Publicly Report on Supply Chain Due Diligence
Keysight reports annually on supply chain due diligence by filing a Form SD and Conflict Minerals Report with the SEC herein. This can be accessed via our company website at: http://about.keysight.com/en/companyinfo/environment/Keysight_Conflict_Minerals_Report.pdf.
5. Due Diligence Results
Evaluating Smelters
As of April 5th, 2016, we have validated 311 smelters or refiners in our supply chain based on information from CFSI, and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Attached to this CMR as Appendix A, we have included the current list of valid smelters disclosed to us by our suppliers.
Based on the smelter lists provided by suppliers via the CMRTs, we are aware of 214 smelters in our supply chain which are certified conflict-free. We also have identified a number of other smelters certified as conflict-free for which the source of raw materials is not disclosed.
Many suppliers are still unable to provide detailed or adequate information about the smelters or refiners used for materials supplied to us. Many supplier responses also were provided at the company or division level, rather than the product or part level. We therefore are unable to determine whether the conflict minerals reportedly in use by our suppliers were contained in components or parts supplied to us. Several
Keysight suppliers also are unable to conclude which of their smelters or refiners provided the conflict minerals used in their products supplied to Keysight.
Product Determination
We lack sufficient information from suppliers or other sources regarding all of the smelters and refiners that processed the necessary 3TGs in our products to conclude (i) whether the 3TGs originated in the Covered Countries and, if so (ii) whether the 3TGs were from recycled or scrap sources or from other conflict-free sources.
6. Next Steps
In the next reporting year, Keysight’s conflict minerals program will continue to focus on vetting smelter data including:
• | Requiring the use of smelter identification numbers; |
• | Requesting that suppliers connect any identified smelters with the products and parts the suppliers supply to Keysight; |
• | Comparing smelters reported by suppliers on the CMRT to CFSI’s list of smelters; and |
• | Promoting the CFSP audit programs through our supply chain. |
In addition, we intend to take the following steps to improve our due diligence process and to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries:
• | Include a conflict minerals flow-down clause in new or renewed supplier contracts; |
• | Continue to expand the number of suppliers requested to supply information; |
• | Continue to engage with suppliers and direct them to training resources to increase the response rate and improve the content quality of the supplier survey responses; and |
• | Engage any of our suppliers found to be supplying us with conflict minerals from sources that support conflict in the Covered Countries to establish an alternative source of conflict minerals that does not support such conflict. |
Appendix A:
The table below lists the smelters or refiners identified by our responsive suppliers that may have been used to process the minerals necessary to the functionality or production of our products during 2015.
Metal | Standard Smelter Name | Smelter 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 MiedŸ Spó³ka 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.ª. | 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 | 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 | 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 | 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 | VIETNAM | Unknown |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | 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 | VIETNAM | 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 | VIETNAM | 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 | VIETNAM | Unknown |
Tin | VQB Mineral and Trading Group JSC | VIETNAM | 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 | Asia Tungsten Products Vietnam Ltd. | VIETNAM | 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 | Yes |
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 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 | Niagara Refining LLC | UNITED STATES | Yes |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Yes |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Unknown |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM | Unknown |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Yes |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Yes |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
Appendix B:
The list below sets out possible countries of origin of 3TGs used in the manufacture of products containing necessary conflict minerals. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. However, for the reasons described in the CMR, these possible countries of origin cannot be linked to our products with reasonable certainty.
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.