Lumentum Holdings Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2016
Introduction
Lumentum Holdings Inc. (“Lumentum”, also referred to as “we”, “our” and “us”) (NASDAQ: LITE) is an industry leading provider of optical and photonic products, defined by revenue and market share addressing a range of end-market applications including optical communications and commercial lasers. 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 July 2, 2016 filed with the U.S. Securities and Exchange Commission (“SEC”).
This Report has been prepared in accordance with the requirements of Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. 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 2016. 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 can be found on our website at www.lumentum.com/investors.
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 2016 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 316 unique smelter entities in Lumentum’s supply chain. Of these 316 smelters, 38 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 34 of the 38 smelters were certified as conflict free in 2016. The remaining 4 smelters sourcing from the Covered Countries were subject to Lumentum’s risk mitigation process.
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 sets forth five steps for supply due diligence. There is significant overlap between our reasonable country of origin inquiry (“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 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 2016. We retained a third-party consulting firm to assist with the RCOI and due diligence processes. As part of our RCOI, we contacted approximately 918 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. After this review, 316 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 316 smelters and performing a risk assessment regarding responses, 38 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 Rule, 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 contacted all 316 smelters and performed a risk assessment regarding responses. 38 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. These smelters 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 and Ongoing Risk Mitigation Efforts
Smelters
Of the 38 smelters that either confirmed they source Conflict Minerals from Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 34 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 2016. Lumentum has conducted and continues to conduct risk mitigation on the remaining 4 smelters. Lumentum has contacted all of its suppliers who have these 4 smelters in their supply chain and have either (i) requested confirmation that the identified smelter is not in the supply chain for products the supplier sells to Lumentum or (ii) demanded removal of the smelter from its supply chain. Lumentum’s risk mitigation efforts are ongoing. 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 2016 due diligence process, Lumentum has been unable to reach a definitive conclusion regarding its products manufactured during calendar year 2016.
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, 2016.
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Metal | Smelter |
Gold | Abington Reldan Metals, LLC |
Gold | Advanced Chemical Company |
Gold | Aida Chemical Industries Co., Ltd. |
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 S.A. |
Gold | Asahi Pretec Corp. |
Gold | Asahi Refining Canada Ltd. |
Gold | Asahi Refining USA Inc. |
Gold | Asaka Riken Co., Ltd. |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Gold | AU Traders and Refiners |
Gold | Aurubis AG |
Gold | Bangalore Refinery |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Gold | Boliden AB |
Gold | C. Hafner GmbH + Co. KG |
Gold | Caridad |
Gold | CCR Refinery - Glencore Canada Corporation |
Gold | Cendres + Métaux S.A. |
Gold | Chimet S.p.A. |
Gold | Chugai Mining |
Gold | Daejin Indus Co., Ltd. |
Gold | Daye Non-Ferrous Metals Mining Ltd. |
Gold | DODUCO GmbH |
Gold | Dowa |
Gold | DSC (Do Sung Corporation) |
Gold | Eco-System Recycling Co., Ltd. |
Gold | Elemetal Refining, LLC |
Gold | Emirates Gold DMCC |
Gold | Fidelity Printers and Refiners Ltd. |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. |
Gold | Geib Refining Corporation |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
Gold | Guangdong Jinding Gold Limited |
Gold | Gujarat Gold Centre |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
Gold | Heimerle + Meule GmbH |
Gold | Henan Yuguang Gold & Lead Co., Ltd. |
Gold | Heraeus Ltd. Hong Kong |
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Gold | Heraeus Precious Metals GmbH & Co. KG |
Gold | Hunan Chenzhou Mining Co., Ltd. |
Gold | Hwasung CJ Co., Ltd. |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
Gold | Ishifuku Metal Industry Co., Ltd. |
Gold | Istanbul Gold Refinery |
Gold | Japan Mint |
Gold | Jiangxi Copper Co., Ltd. |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Gold | JSC Uralelectromed |
Gold | JX Nippon Mining & Metals Co., Ltd. |
Gold | Kaloti Precious Metals |
Gold | Kazakhmys Smelting LLC |
Gold | Kazzinc |
Gold | Kennecott Utah Copper LLC |
Gold | KGHM Polska MiedŸ Spó³ka Akcyjna |
Gold | Kojima Chemicals Co., Ltd. |
Gold | Korea Zinc Co., Ltd. |
Gold | Kyrgyzaltyn JSC |
Gold | Kyshtym Copper-Electrolytic Plant ZAO |
Gold | L'azurde Company For Jewelry |
Gold | Lingbao Gold Co., Ltd. |
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 | Metalor Technologies (Hong Kong) Ltd. |
Gold | Metalor Technologies (Singapore) Pte., Ltd. |
Gold | Metalor Technologies (Suzhou) Ltd. |
Gold | Metalor Technologies S.A. |
Gold | Metalor USA Refining Corporation |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. |
Gold | Mitsubishi Materials Corporation |
Gold | Mitsui Mining and Smelting Co., Ltd. |
Gold | MMTC-PAMP India Pvt., Ltd. |
Gold | Modeltech Sdn Bhd |
Gold | Morris and Watson |
Gold | Moscow Special Alloys Processing Plant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. |
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 Krastsvetmet) |
Gold | OJSC Novosibirsk Refinery |
Gold | PAMP S.A. |
Gold | Penglai Penggang Gold Industry Co., Ltd. |
Gold | Prioksky Plant of Non-Ferrous Metals |
Gold | PT Aneka Tambang (Persero) Tbk |
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Gold | PX Précinox S.A. |
Gold | Rand Refinery (Pty) Ltd. |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
Gold | Remondis Argentia B.V. |
Gold | Republic Metals Corporation |
Gold | Royal Canadian Mint |
Gold | SAAMP |
Gold | Sabin Metal Corp. |
Gold | SAFINA A.S. |
Gold | Sai Refinery |
Gold | Samduck Precious Metals |
Gold | SAMWON Metals Corp. |
Gold | SAXONIA Edelmetalle GmbH |
Gold | Schone Edelmetaal B.V. |
Gold | SEMPSA Joyería Platería S.A. |
Gold | Shandong Humon Smelting Co., Ltd. |
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 | Sudan Gold Refinery |
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 | Tokuriki Honten Co., Ltd. |
Gold | Tongling Nonferrous Metals Group Co., Ltd. |
Gold | Tony Goetz NV |
Gold | TOO Tau-Ken-Altyn |
Gold | Torecom |
Gold | Umicore Brasil Ltda. |
Gold | Umicore Precious Metals Thailand |
Gold | Umicore S.A. Business Unit Precious Metals Refining |
Gold | United Precious Metal Refining, Inc. |
Gold | Universal Precious Metals Refining Zambia |
Gold | Valcambi S.A. |
Gold | Western Australian Mint trading as The Perth Mint |
Gold | WIELAND Edelmetalle GmbH |
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 |
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Tantalum | D Block Metals, LLC |
Tantalum | Duoluoshan |
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 | 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 | Jiangxi Tuohong New Raw Material |
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 | Power Resources Ltd. |
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 Co., Ltd. |
Tin | An Vinh Joint Stock Mineral Processing Company |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
Tin | China Tin Group Co., Ltd. |
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Tin | CNMC (Guangxi) PGMA Co., Ltd. |
Tin | Cooperativa Metalurgica de Rondônia Ltda. |
Tin | CV Ayi Jaya |
Tin | CV Dua Sekawan |
Tin | CV Gita Pesona |
Tin | CV Serumpun Sebalai |
Tin | CV Tiga Sekawan |
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. |
Tin | EM Vinto |
Tin | Estanho de Rondônia S.A. |
Tin | Fenix Metals |
Tin | Gejiu Jinye Mineral Company |
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 Hill Tin Industry Co., Ltd. |
Tin | Huichang Jinshunda Tin Co., Ltd. |
Tin | Jiangxi Ketai Advanced Material 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 | Modeltech Sdn Bhd |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
Tin | O.M. Manufacturing Philippines, Inc. |
Tin | Operaciones Metalurgical S.A. |
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 Tin Industry |
Tin | PT Belitung Industri Sejahtera |
Tin | PT Bukit Timah |
Tin | PT Cipta Persada Mulia |
Tin | PT DS Jaya Abadi |
Tin | PT Eunindo Usaha Mandiri |
Tin | PT Inti Stania Prima |
Tin | PT Justindo |
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Tin | PT Karimun Mining |
Tin | PT Kijang Jaya Mandiri |
Tin | PT Mitra Stania Prima |
Tin | PT O.M. Indonesia |
Tin | PT Panca Mega Persada |
Tin | PT Prima Timah Utama |
Tin | PT Refined Bangka Tin |
Tin | PT Sariwiguna Binasentosa |
Tin | PT Stanindo Inti Perkasa |
Tin | PT Sukses Inti Makmur |
Tin | PT Sumber Jaya Indah |
Tin | PT Timah (Persero) Tbk Kundur |
Tin | PT Timah (Persero) Tbk Mentok |
Tin | PT Tinindo Inter Nusa |
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 Company Limited |
Tungsten | A.L.M.T. TUNGSTEN Corp. |
Tungsten | ACL Metais Eireli |
Tungsten | Asia Tungsten Products Vietnam Ltd. |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. |
Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
Tungsten | Ganzhou Jiangwu Ferrotungsten 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 Co., Ltd. |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
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 Dayu Longxintai Tungsten Co., Ltd. |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
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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 | Moliren Ltd |
Tungsten | Niagara Refining LLC |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
Tungsten | Philippine Chuangxin Industrial Co., Inc. |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. |
Tungsten | Unecha Refractory Metals Plant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. |
Tungsten | Wolfram Bergbau und Hütten AG |
Tungsten | Woltech Korea Co., Ltd. |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
Tungsten | Xiamen Tungsten Co., Ltd. |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
38 of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. Under the 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 DRC, Rwanda, Burundi, and Tanzania.