Lumentum Holdings Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2020
Introduction
Lumentum Holdings Inc. (“we”, “our”, “Lumentum” or the “Company”) 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 (“OpComms”) and Commercial Lasers (“Lasers”) for manufacturing, inspection and life-science applications. We seek to use our core optical and photonic technology and our volume manufacturing capability to expand into attractive emerging markets that benefit from advantages that optical or photonics-based solutions provide, including 3D sensing for consumer electronics and diode light sources for a variety of consumer and industrial applications. The majority of our customers tend to be original equipment manufacturers (“OEMs”) that incorporate our products into their products which then address end-market applications. For example, we sell fiber optic components that our network equipment manufacturer (“NEM”) customers assemble into communications networking systems, which they sell to network service providers or enterprises with their own networks. Similarly, many of our customers for our Lasers products incorporate our products into tools they produce, which are used for manufacturing processes by their customers. For 3D sensing, we sell diode lasers to manufacturers of consumer electronics products for mobile, personal computing, and gaming who then integrate our devices within their products, for eventual resale to consumers and also into other industrial applications. Lumentum has a global marketing and sales footprint that enables us to address global market opportunities for our products. Lumentum has manufacturing capabilities and facilities in North America, Asia-Pacific, and Europe, with employees engaged in R&D, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum’s Annual Report on Form 10-K for the fiscal year ended June 27, 2020, filed with the U.S. Securities and Exchange Commission (“SEC”) on August 25, 2020.
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 2020. 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 2020 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 308 unique smelter entities in Lumentum’s supply chain. Of these 308 smelters, 39 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the “DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 33 of the 39 smelters were Responsible Minerals Assurance Process (“RMAP”) conformant in 2020. The remaining six (6) smelters sourcing from the Covered Countries were subject to Lumentum’s risk mitigation process described below.
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: Third Edition (the “OECD Guidance”). The OECD Guidance sets forth five steps for supply chain 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 RCOI 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 2020. We retained a third-party consulting firm to assist with the RCOI and due diligence processes. As part of our RCOI, we contacted approximately380 suppliers and original manufacturers. Each direct supplier was asked to provide Conflict Minerals data in the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Greater than 90% of these suppliers responded. Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this review, 308 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After performing a risk assessment on each of the 308 smelters regarding their 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 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. Risks that arise are 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 308 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 RMAP and for smelters that were not identified by the RMAP as conflict free, Lumentum conducted risk mitigation. 239 of the 308 smelters identified (greater than 75%) have undergone a RMAP audit. 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 39 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 33 smelters were recognized as RMAP Conformant at the end of 2020. Lumentum has conducted and continues to conduct risk mitigation on the remaining six (6) smelters that are not RMAP Conformant. Lumentum has contacted all of its suppliers who have these six (6) smelters in their supply chain and has 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 for the remaining six (6) smelters (African Gold Refinery, Dijllah Gold Refinery FZC, Fujairah Gold FZC, International Precious Metal Refiners, Kaloti Precious Metals, and Tony Goetz NV), which have been identified by a sole supplier, to determine if they are actually used in parts purchased by Lumentum. 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 2020 due diligence process, Lumentum has been unable to reach a definitive conclusion regarding its products manufactured during calendar year 2020.
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 Minerals 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 determinations regarding the status of our supply chain with respect to Conflict Minerals. 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, 2020.
| | | | | |
| Metal | Smelter |
| Gold | 8853 S.p.A. |
| Gold | Abington Reldan Metals, LLC |
| Gold | Advanced Chemical Company |
| Gold | African Gold Refinery |
| 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 | C.I Metales Procesados Industriales SAS |
| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Métaux S.A. |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dijllah Gold Refinery FZC |
| Gold | DODUCO Contacts and Refining GmbH |
| Gold | Dowa |
| Gold | DS PRETECH Co., Ltd. |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Emirates Gold DMCC |
| Gold | Fujairah Gold FZC |
| Gold | Geib Refining Corporation |
| Gold | Gold Coast Refinery |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| | | | | |
| 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 | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Precious Metals GmbH & Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ Co., Ltd. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | International Precious Metal Refiners |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | JALAN & Company |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JSC Uralelectromed |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
| Gold | K.A. Rasmussen |
| Gold | Kaloti Precious Metals |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedź Spółka 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 | L'Orfebre S.A. |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | LS-NIKKO Copper Inc. |
| Gold | LT Metal Ltd. |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold | Marsam Metals |
| 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 | NH Recytech Company |
| 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 | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Précinox S.A. |
| Gold | QG Refining, LLC |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | SAMWON Metals Corp. |
| Gold | SAXONIA Edelmetalle GmbH |
| 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 | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
| 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 Precious Metals Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| |
| Tantalum | Asaka Riken Co., Ltd. |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| 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 | H.C. Starck Co., Ltd. |
| 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 | H.C. Starck Tantalum and Niobium GmbH |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| 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 | LSM Brasil S.A. |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineração Taboca S.A. |
| Tantalum | Mitsui Mining & Smelting |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | PRG Dooel |
| Tantalum | QuantumClean |
| Tantalum | Resind Indústria e Comércio Ltda. |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
| | | | | |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| |
| Tin | Alpha |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CV Ayi Jaya |
| Tin | CV Venus Inti Perkasa |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Dowa |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | EM Vinto |
| Tin | Estanho de Rondônia S.A. |
| Tin | Fenix Metals |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Fengming Metallurgy Chemical Plant |
| 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 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Luna Smelter, Ltd. |
| Tin | Ma'anshan Weitai Tin 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 Belgium N.V. |
| Tin | Metallo Spain S.L.U. |
| Tin | Mineração Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Modeltech Sdn Bhd |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalúrgicas S.A. |
| Tin | Pongpipat Company Limited |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Serumpun |
| Tin | PT Bukit Timah |
| Tin | PT Cipta Persada Mulia |
| | | | | |
| Tin | PT Lautan Harmonis Sejahtera |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Mitra Sukses Globalindo |
| Tin | PT Prima Timah Utama |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | PT Rajehan Ariq |
| Tin | PT Refined Bangka Tin |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | Resind Indústria e Comércio Ltda. |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Super Ligas |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. |
| Tin | Thaisarco |
| Tin | Tin Technology & Refining |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | White Solder Metalurgia e Mineração Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Tin Company Limited |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| |
| Tungsten | A.L.M.T. Corp. |
| Tungsten | ACL Metais Eireli |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten | China Molybdenum Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Global Tungsten & Powders Corp. |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten | Hunan Litian Tungsten Industry 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 Yaosheng Tungsten Co., Ltd. |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | KGETS Co., Ltd. |
| Tungsten | Lianyou Metals Co., Ltd. |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Masan Tungsten Chemical LLC (MTC) |
| Tungsten | Moliren Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. |
| Tungsten | Unecha Refractory Metals Plant |
| 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. |
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 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, Tanzania, and Uganda.
