Lumentum Holdings Inc.
Conflict Minerals Report
For the Year Ended December 31, 2015
Introduction
Lumentum Holdings Inc. (“Lumentum”, also referred to as "we", "our" and "us") (NASDAQ: LITE) is a market-leading manufacturer of innovative optical and photonic products enabling optical networking and commercial laser customers worldwide. Lumentum’s optical components and subsystems are part of virtually every type of telecom, enterprise, and data center network. Lumentum’s commercial lasers enable advanced manufacturing techniques and diverse applications including next-generation 3D sensing capabilities. Lumentum is headquartered in Milpitas, California with R&D, manufacturing, and sales offices worldwide. For more information, please refer to our Annual Report on Form 10-K for the fiscal year ended June 27, 2016 filed with the U.S. Securities and Exchange Commission (“SEC”).
On August 1, 2015, Lumentum Holdings Inc. became an independent publicly-traded company through the distribution by JDS Uniphase Corporation (“JDSU”) to its stockholders of 80.1% of Lumentum’s outstanding common stock (the “Separation”). JDSU was renamed Viavi Solutions Inc. (“Viavi”) at the time of the distribution. Lumentum was incorporated in Delaware as a wholly owned subsidiary of Viavi on February 10, 2015 and is comprised of the former communications and commercial optical products segment and WaveReady product lines of Viavi. Lumentum’s Registration Statement on Form 10 was declared effective by the SEC on July 16, 2015. Lumentum’s common stock began trading “regular-way” under the ticker “LITE” on the NASDAQ stock market on August 4, 2015.
This Report covers the communications and commercial optical products segment and WaveReady product line of Viavi and the same product segment and product line that were transferred to Lumentum at the Separation for the remainder of 2015. Third-party products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report.
This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”) contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2015.
Executive Summary
Lumentum reviewed its entire affected supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2015 and contained Conflict Minerals. We then contacted these suppliers, each of which provided us with a list of smelter or refiner names (collectively, “smelters”). We identified 306 unique smelter entities in Lumentum’s supply chain. Of these 306 smelters, 39 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (“DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 37 of the 39 smelters were certified as conflict free in 2015. The remaining 2 smelters sourcing from the Covered Countries were subject to Lumentum’s risk mitigation process and did not require removal from Lumentum’s supply chain.
Design of Due Diligence
Lumentum designed its due diligence measures to conform to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, including the related supplements on tantalum, tin, tungsten, and gold (collectively, the “OECD Guidance”). The OECD Guidance set forth five steps for supply due diligence. There is significant overlap between our RCOI efforts and our due diligence measures performed, both of which are described below.
Management Systems
Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies, and maintain an e-
mail address conflictminerals@lumentum.com for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the reasonable country of origin inquiry and due diligence procedures described below. All relevant conflict minerals data is kept in our internal database system.
Reasonable Country of Origin Inquiry
Lumentum conducted a reasonable country of origin inquiry (“RCOI”) that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2015. We retained a third-party consulting firm to assist with the RCOI and due diligence processes. As part of our RCOI, we contacted approximately 1,186 suppliers and original manufacturers. Each direct supplier was provided with Lumentum’s conflict minerals policy and asked to provide conflict minerals data in the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”). Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. These suppliers provided 30,766 unique smelter names for the facilities used to process Conflict Minerals. Lumentum reviewed the aggregated smelter list to remove duplicate entries and errors (including multiple variations in the spelling of a single smelter’s name and entities incorrectly listed as smelters). After this review, 306 smelters were identified as conflict minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the CFSI. After directly contacting all 306 smelters and performing a risk assessment regarding responses, 39 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the smelters as well as other public information available at the time. In accordance with the SEC final rules for conflict minerals that are sourced from the Covered Countries, Lumentum is required to exercise due diligence on the conflict minerals’ source and chain of custody and to follow a nationally or internationally recognized due diligence framework.
Conflict Minerals Policy
Lumentum’s Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/corporate-responsibility/partner-responsibility-ethics-and-labor.
Risk Assessment and Response
Lumentum’s risk assessment plan was designed to define, identify, mitigate, and manage risks. Should a risk arise, it would be reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply chain and directly contacting all 306 smelters and performed a risk assessment regarding responses. 39 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the smelters as well as other public information available at the time. Lumentum then compared this list to the list provided by the Conflict Free Smelter Program (“CFSP”) and for smelters that were not identified by the CFSP as conflict free, Lumentum conducted risk mitigation. Thesesmelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.
Due Diligence Results
Smelters
Of the 39 smelters that either confirmed they source Conflict Minerals from Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 37 smelters were recognized as conflict free by the Conflict Free Smelter Program (“CFSP”) and listed on the CFSP’s website as conflict free certified at the end of 2015. Lumentum conducted risk mitigation on the remaining 2 smelters. Based on a review of publicly available sources, Lumentum has no reason to believe that either of these 2 smelters directly or indirectly financed or benefitted armed groups in the Covered Countries. A list of the identified smelters is listed on Annex A hereto.
Because Lumentum’s suppliers source from smelters that source from the Covered Countries and some of these smelters were not yet conflict free certified at the end of our 2015 due diligence process, Lumentum has be unable to reach a definitive conclusion regarding its products manufactured during calendar year 2015.
Steps to be Taken to Mitigate Risk
Lumentum is committed to continuous improvement in our due diligence process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their conflict mineral status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and
improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.
Additional Risk Factors
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our conflict free declaration. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in conflict free smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.
Annex A
Smelters and Refineries
Below is a list of the smelters reported to Lumentum as likely in Lumentum’s supply chain as of December 31, 2015.
Gold Advanced Chemical Company
Gold Aida Chemical Industries Co., Ltd.
Gold Aktyubinsk Copper Company TOO
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.
Gold Almalyk Mining and Metallurgical Complex (AMMC)
Gold AngloGold Ashanti Córrego do Sítio Mineração
Gold Argor-Heraeus SA
Gold Asahi Pretec Corporation
Gold Asahi Refining Canada Limited
Gold Asahi Refining USA Inc.
Gold Asaka Riken Co., Ltd.
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold Aurubis AG
Gold Bangalore Refinery (P) Ltd.
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold Bauer Walser AG
Gold Boliden AB
Gold C. Hafner GmbH + Co. KG
Gold Caridad
Gold CCR Refinery - Glencore Canada Corporation
Gold Cendres + Métaux SA
Gold Chimet S.p.A.
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation
Gold Doduco
Gold Dowa
Gold Eco-System Recycling Co., Ltd.
Gold Elemetal Refining, LLC
Gold Emirates Gold DMCC
Gold Faggi Enrico S.p.A.
Gold Fidelity Printers and Refiners Ltd.
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH
Gold Heraeus Ltd. Hong Kong
Gold Heraeus Precious Metals GmbH & Co. KG
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Gold Ishifuku Metal Industry Co., Ltd.
Gold Istanbul Gold Refinery
Gold Japan Mint
Gold Jiangxi Copper Company Limited
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold JSC Uralelectromed
Gold JX Nippon Mining & Metals Co., Ltd.
Gold Kazakhmys Smelting LLC
Gold Kazzinc
Gold Kennecott Utah Copper LLC
Gold KGHM Polska Miedź Spółka Akcyjna
Gold Kojima Chemicals Co., Ltd.
Gold Korea Metal Co., Ltd.
Gold Korea Zinc Co. Ltd.
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold Materion
Gold Matsuda Sangyo Co., Ltd.
Gold METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
Gold Metalor Technologies (Hong Kong) Ltd.
Gold Metalor Technologies (Singapore) Pte., Ltd.
Gold Metalor Technologies (Suzhou) Ltd.
Gold Metalor Technologies SA
Gold Metalor USA Refining Corporation
Gold Mitsubishi Materials Corporation
Gold Mitsui Mining and Smelting Co., Ltd.
Gold MMTC-PAMP India Pvt., Ltd.
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold Navoi Mining and Metallurgical Combinat
Gold Nihon Material Co., Ltd.
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold Ohura Precious Metal Industry Co., Ltd.
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet)
Gold OJSC Kolyma Refinery
Gold OJSC Novosibirsk Refinery
Gold PAMP SA
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold Prioksky Plant of Non-Ferrous Metals
Gold PT Aneka Tambang (Persero) Tbk
Gold PX Précinox SA
Gold Rand Refinery (Pty) Ltd.
Gold Republic Metals Corporation
Gold Royal Canadian Mint
Gold Sabin Metal Corp.
Gold Samduck Precious Metals
Gold SAMWON Metals Corp.
Gold SAXONIA Edelmetalle GmbH
Gold Schone Edelmetaal B.V.
Gold SEMPSA Joyería Platería SA
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold Sichuan Tianze Precious Metals Co., Ltd.
Gold Singway Technology Co., Ltd.
Gold So Accurate Group, Inc.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals
Gold Solar Applied Materials Technology Corp.
Gold Sumitomo Metal Mining Co., Ltd.
Gold Super Dragon Technology Co., Ltd.
Gold T.C.A S.p.A
Gold Tanaka Kikinzoku Kogyo K.K.
Gold The Great Wall Gold and Silver Refinery of China
Gold The Refinery of Shandong Gold Mining Co., Ltd.
Gold Tokuriki Honten Co., Ltd.
Gold Tongling Nonferrous Metals Group Co., Ltd.
Gold Torecom
Gold Umicore Brasil Ltda.
Gold Umicore Precious Metals Thailand
Gold Umicore SA Business Unit Precious Metals Refining
Gold United Precious Metal Refining, Inc.
Gold Valcambi SA
Gold Western Australian Mint trading as The Perth Mint
Gold Yamamoto Precious Metal Co., Ltd.
Gold Yokohama Metal Co., Ltd.
Gold Yunnan Copper Industry Co., Ltd.
Gold Zhongkuang Gold Industry Co., Ltd.
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold Zijin Mining Group Co., Ltd. Gold Refinery
Tantalum Changsha South Tantalum Niobium Co., Ltd.
Tantalum Conghua Tantalum and Niobium Smeltry
Tantalum Duoluoshan
Tantalum D Block Metals, LLC
Tantalum Exotech Inc.
Tantalum F&X Electro-Materials Ltd.
Tantalum FIR Metals & Resource Ltd.
Tantalum Global Advanced Metals Aizu
Tantalum Global Advanced Metals Boyertown
Tantalum Guangdong Zhiyuan New Material Co., Ltd.
Tantalum Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
Tantalum H.C. Starck Co., Ltd.
Tantalum H.C. Starck GmbH Goslar
Tantalum H.C. Starck GmbH Laufenburg
Tantalum H.C. Starck Hermsdorf GmbH
Tantalum H.C. Starck Inc.
Tantalum H.C. Starck Ltd.
Tantalum H.C. Starck Smelting GmbH & Co.KG
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum Hi-Temp Specialty Metals, Inc.
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum Jiujiang Tanbre Co., Ltd.
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum KEMET Blue Metals
Tantalum KEMET Blue Powder
Tantalum King-Tan Tantalum Industry Ltd.
Tantalum LSM Brasil S.A.
Tantalum Metallurgical Products India Pvt., Ltd.
Tantalum Mineração Taboca S.A.
Tantalum Mitsui Mining & Smelting
Tantalum Molycorp Silmet A.S.
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum Plansee SE Liezen
Tantalum Plansee SE Reutte
Tantalum QuantumClean
Tantalum Resind Indústria e Comércio Ltda.
Tantalum RFH Tantalum Smeltry Co., Ltd.
Tantalum Solikamsk Magnesium Works OAO
Tantalum Taki Chemicals
Tantalum Telex Metals
Tantalum Tranzact, Inc.
Tantalum Ulba Metallurgical Plant JSC
Tantalum XinXing HaoRong Electronic Material Co., Ltd.
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.
Tantalum Zhuzhou Cemented Carbide
Tin Alpha
Tin An Thai Minerals Company Limited
Tin An Vinh Joint Stock Mineral Processing Company
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin China Tin Group Co., Ltd.
Tin CNMC (Guangxi) PGMA Co., Ltd.
Tin Cooperativa Metalurgica de Rondônia Ltda.
Tin CV Ayi Jaya
Tin CV Gita Pesona
Tin CV Serumpun Sebalai
Tin CV United Smelting
Tin CV Venus Inti Perkasa
Tin Dowa
| |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Tin Elmet S.L.U (Metallo Group)
Tin EM Vinto
Tin Estanho de Rondônia S.A.
Tin Feinhütte Halsbrücke GmbH
Tin Fenix Metals
Tin Gejiu Jinye Mineral Co., Ltd.
Tin Gejiu Kai Meng Industry and Trade LLC
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin Huichang Jinshunda Tin Co., Ltd.
Tin Jiangxi Ketai Advanced Material Co., Ltd.
Tin Linwu Xianggui Ore Smelting Co., Ltd.
Tin Magnu's Minerais Metais e Ligas Ltda.
Tin Malaysia Smelting Corporation (MSC)
Tin Melt Metais e Ligas S/A
Tin Metallic Resources, Inc.
Tin Metallo-Chimique N.V.
Tin Mineração Taboca S.A.
Tin Minsur
Tin Mitsubishi Materials Corporation
Tin Nankang Nanshan Tin Manufactory Co., Ltd.
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin O.M. Manufacturing Philippines, Inc.
Tin O.M. Manufacturing (Thailand) Co., Ltd.
Tin Operaciones Metalurgical S.A.
Tin Phoenix Metal Ltd.
Tin PT Alam Lestari Kencana
Tin PT Aries Kencana Sejahtera
Tin PT Artha Cipta Langgeng
Tin PT ATD Makmur Mandiri Jaya
Tin PT Babel Inti Perkasa
Tin PT Bangka Prima Tin
Tin PT Bangka Timah Utama Sejahtera
Tin PT Bangka Tin Industry
Tin PT Belitung Industri Sejahtera
Tin PT BilliTin Makmur Lestari
Tin PT Bukit Timah
Tin PT Cipta Persada Mulia
Tin PT DS Jaya Abadi
Tin PT Eunindo Usaha Mandiri
Tin PT Fang Di MulTindo
Tin PT Inti Stania Prima
Tin PT Justindo
Tin PT Karimun Mining
Tin PT Mitra Stania Prima
Tin PT Panca Mega Persada
Tin PT Pelat Timah Nusantara Tbk
Tin PT Prima Timah Utama
Tin PT Refined Bangka Tin
Tin PT Sariwiguna Binasentosa
Tin PT Stanindo Inti Perkasa
Tin PT Sumber Jaya Indah
Tin PT Timah (Persero) Tbk Kundur
Tin PT Timah (Persero) Tbk Mentok
Tin PT Tinindo Inter Nusa
Tin PT Tirus Putra Mandiri
Tin PT Tommy Utama
Tin PT Wahana Perkit Jaya
Tin Resind Indústria e Comércio Ltda.
Tin Rui Da Hung
Tin Soft Metais Ltda.
Tin Super Ligas
Tin Thaisarco
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin VQB Mineral and Trading Group JSC
Tin White Solder Metalurgia e Mineração Ltda.
Tin Xianghualing Tin Industry Co., Ltd.
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin Yunnan Tin Group (Holding) Company Limited
Tungsten A.L.M.T. TUNGSTEN Corp.
Tungsten Asia Tungsten Products Vietnam Ltd.
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Haichuang Tungsten Industry Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten Ganzhou Yatai Tungsten Co., Ltd.
Tungsten Global Tungsten & Powders Corp.
Tungsten Guangdong Xianglu Tungsten Co., Ltd.
Tungsten H.C. Starck GmbH
Tungsten H.C. Starck Smelting GmbH & Co.KG
Tungsten Hunan Chenzhou Mining Group Co., Ltd.
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten Hydrometallurg, JSC
Tungsten Japan New Metals Co., Ltd.
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten Kennametal Fallon
Tungsten Kennametal Huntsville
Tungsten Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd
Tungsten Malipo Haiyu Tungsten Co., Ltd.
Tungsten Niagara Refining LLC
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten Pobedit, JSC
Tungsten Sanher Tungsten Vietnam Co., Ltd.
Tungsten Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten Wolfram Bergbau und Hütten AG
Tungsten Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten Xiamen Tungsten Co., Ltd.
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.
39 of the smelters above declared to be sourcing or there was reason to believe they may be sourcing from the covered countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the covered countries and there is no requirement to identify the specific covered country by the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified covered countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania.
