Exhibit 1.01
CONFLICT MINERALS REPORT
FOR CALENDAR YEAR 2015
Part I: Introduction
This document constitutes Merck & Co., Inc.’s Conflict Minerals Report (the “Report”) for the year ended December 31, 2015. We have prepared this Report and are issuing it in accordance with the requirements of Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and in connection with Merck & Co., Inc.’s disclosure filed on the specialized disclosure form (“Form SD”). Any references to “Merck,” “the Company,” “we,” “us,” and “our” refer to Merck & Co., Inc. and its consolidated subsidiaries.
In August 2012, the U.S. Securities and Exchange Commission (“SEC”) issued rules implementing the “Conflict Minerals” disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “SEC Conflict Minerals Reporting Rule” or the “Rule”). If an SEC registrant manufactures (or contracts to have manufactured) products containing columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin and tungsten (collectively, “3TG” or “Conflict Minerals”), and the 3TG is necessary to such products’ functionality or production, the Rule requires that registrant to undertake a reasonable country of origin inquiry. If, as a result of a Reasonable Country of Origin Inquiry (“RCOI”), the company knows or has reason to believe that any 3TG originated in the Democratic Republic of Congo or an adjoining country as defined in the Rule (the “Covered Countries”), and is not from recycled or scrap sources, the registrant must exercise due diligence on the source and chain of custody of such minerals. Specifically, registrants must determine whether: (a) any 3TG which is necessary to the functionality or production of a product manufactured or contracted to be manufactured originated in the Covered Countries; and (b) the minerals directly or indirectly finance or benefit armed groups in the Covered Countries.
Overview
Merck is a global health care company that delivers innovative health solutions through its prescription medicines, vaccines, biologic therapies and animal health products, which it markets directly and through its joint ventures. The Company’s operations are principally managed on a product basis and are comprised of four operating segments: Pharmaceutical, Animal Health, Alliances and Healthcare Services. The Pharmaceutical segment includes human health pharmaceutical and vaccine products marketed either directly by the Company or through joint ventures. Human health pharmaceutical products consist of therapeutic and preventive agents, generally sold by prescription, for the treatment of human disorders. Vaccine products consist of preventative pediatric, adolescent and adult vaccines, primarily administered at physician offices. The Company also has animal health operations that discover, develop, manufacture and market animal health products, including vaccines. The Company’s Healthcare Services segment provides services and solutions that focus on engagement, health analytics and clinical services to improve the value of care delivered to patients. The Healthcare Services segment does not contain any products covered by this report. The Company was incorporated in New Jersey in 1970.
Merck has thousands of direct material suppliers and an extensive internal and external network of manufacturing sites around the world. Given the size and complexity of Merck’s supply chain, Merck is several tiers removed from smelters/refiners and has no direct business relationship with them. As a result, Merck must rely on its direct material suppliers to provide information on their upstream supplier sourcing; this includes country of origin determinations for Conflict Minerals that may go into the materials or products
provided by those direct material suppliers to Merck. In addition, the amount of reliable information available globally on the traceability and sourcing of Conflict Minerals is limited, which presents another challenge to our ability to precisely track any Conflict Minerals back to their source and origin, thereby making us more reliant on the information provided by our direct material suppliers and industrial initiatives such as the Conflict Free Sourcing Initiative (“CFSI”).
Our Conflict Minerals Policy
Merck has established a Conflict Minerals Policy governing its position and commitment on managing the use of Conflict Minerals in its supply chain.
Our Conflict Minerals Policy can be found on our website: http://www.merck.com/about/views-and-positions/conflict_minerals_policy.pdf.
Our Scoping Assessment
Merck completed the scoping assessment activities of all purchased materials and products in our supply chain to determine the presence of any Conflict Minerals that may be necessary to the functionality or production of our products, including those made by contract manufacturers or that Merck manufactures along with its joint ventures. Technical experts from our various business segments reviewed the composition and functionality of these materials and products (including active ingredients and excipients), devices, and delivery systems to determine whether: (a) they were within the scope of Rule 13p-1; and/or (b) 3TG was, or could possibly be, necessary to their functionality or production. Consistent with the Company’s last filing, Merck has determined that none of our Pharmaceutical or Animal Health medicines, vaccines or biologic products contains 3TG. Merck does, however, have reason to believe that 3TG is necessary to the functionality or production of a small number of its delivery systems and ancillary products. As a result, Merck is taking the actions described in Part II and conducting a RCOI of these in-scope products.
Part II. Reasonable Country of Origin Inquiry
For the 2015 reporting period, Merck continued to use the Conflict Minerals Reporting Template (“CMRT”) published by the CFSI for the RCOI survey to obtain countries of origin information for any Conflict Mineral smelters/refiners that may exist upstream in our supply chain. Our scoping assessment confirmed that ten direct material suppliers (including contract manufacturers) were in scope for the RCOI survey. Accordingly, we sent the RCOI survey to these ten suppliers. We requested our direct material suppliers to identify the smelters/refiners and countries of origin of the Conflict Minerals in products or materials they supply to us. Prior to the RCOI survey being sent, each direct material supplier received an introductory email from Merck that provided each supplier with information on the Rule, the name of the material or product in-scope for the survey, links to Merck’s Conflict Minerals Policy and Business Partner Code of Conduct, Conflict Minerals basic training material, and the reasons why we contacted them. As with the prior years’ surveys, we also provided these suppliers with free access to additional resources, such as frequently asked questions concerning Conflict Minerals tracing, Conflict Minerals tools and trainings, and news and background on the regulation and compliance program. Following the initial survey request, reminder emails were sent by Merck personnel asking suppliers to complete the RCOI survey. We also implemented an internal escalation process for suppliers who remained non-responsive after these reminders. For the direct material suppliers who responded to the survey, we reviewed the responses for completeness and consistency according to our Conflict Minerals Program and followed up with these suppliers as necessary. Merck also engaged with suppliers in the survey to help them understand the importance of sourcing from the compliant smelters/
refiners, and provided them with materials to further engage their upstream suppliers to identify the smelters/refiners. The status of the RCOI was provided to the senior management of Merck’s Procurement group.
We received responses from all ten direct material suppliers that were in the RCOI survey. Five of these suppliers stated that Conflict Minerals are not present and not necessary to the functionality or production of the materials or products purchased by Merck. The remaining five direct material suppliers stated that some 3TG is used in their materials or products, or is necessary to the functionality or production of the materials or products purchased by Merck. Of the latter group of suppliers, four were able to identify some smelters/refiners. Based on the RCOI survey responses received and subsequent smelter/refiner information verification, we have reason to believe that a number of the smelters/refiners disclosed by our direct material suppliers might be sourcing 3TG from Covered Countries and that the 3TG does not completely come from recycled or scrap sources. As a result, Merck designed and implemented a due diligence process.
Part III. Design of Conflict Minerals Program
We have designed our due diligence process to conform, in all material respects, with the Organization for Economic Co-Operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and related supplements for tin, tantalum, tungsten and gold. Summarized below are the design components of our Conflict Minerals Program as they relate to the five step framework from the OECD Guidance.
OECD Step 1: Establish strong company management systems
Conflict Minerals Policy: We have established a Conflict Minerals Policy. Our Conflict Minerals Policy is posted on our company website and is distributed to the direct material suppliers in the survey.
Conflict Minerals Expectations: We define our expectations for the responsible sourcing of minerals in our company’s Business Partner Code of Conduct (“BPCC”). All business partners that engage in the manufacture of our products or that supply direct materials are expected to maintain procedures to ensure the responsible sourcing of minerals.
Conflict Minerals Team: We maintain a cross-functional team consisting of Supplier Management, Technical Experts and Compliance that supervise and manage our Conflict Minerals Program. This team provides program status to senior management of Procurement and EVP and President of Merck Manufacturing Division periodically.
Conflict Minerals Training: We train staff that have responsibility for sourcing direct materials on the processes and procedures that must be followed when sourcing materials, including those that may potentially contain Conflict Minerals.
Conflict Minerals Information: We provide information and training materials on Conflict Minerals to direct materials suppliers identified as in-scope to receive an RCOI survey to help inform and educate them.
Conflict Minerals Control System: We maintain a Conflict Minerals Program that is linked to our supplier sourcing decision-making process. We apply a conflict minerals supply chain system of controls and transparency through the use of the Conflict Minerals Reporting Template (“CMRT”) which is created and maintained by the CSFI to identify the smelters/refiners that process the necessary Conflict Minerals potentially contained in our products.
Conflict Minerals Recordkeeping: We keep business records that relate to our Conflict Minerals Program, including the results of RCOI surveys and smelter/refiner due diligence activities, and retain them for at least 5 years.
Conflict Minerals Contract Clause: We maintain a Conflict Minerals compliance clause for inclusion in current and future contracts with direct material suppliers whose materials or products are known to contain Conflict Minerals and for which Conflict Minerals are necessary to the functionality or production of the products.
Continuous Improvement: We engage a professional service firm to evaluate the design of our Conflict Minerals Program and identify opportunities to drive continuous improvement.
Grievance Mechanism: We maintain a mechanism to allow employees, suppliers, business partners and other stakeholders to report concerns, including those that relate to our Conflict Minerals Program. Concerns may be reported confidentially and anonymously through our company’s AdviceLine.
OECD Step 2: Identify and assess risks in our supply chain
Identify: We identify all direct material suppliers, including contract manufacturers and joint venture partners that supply materials and products to our company which may potentially contain Conflict Minerals and that are considered in-scope.
Survey: For all direct material suppliers whose materials or products are considered likely to contain Conflict Minerals and for which Conflict Minerals are necessary to the production or functionality of the materials or products, we survey these suppliers using the CMRT developed by CFSI, requesting them to identify smelters/refiners and countries of origin of the Conflict Minerals in the materials and products they provide to us.
Follow-Up: When direct material suppliers fail to provide complete and consistent responses to our RCOI survey request in a timely manner, the sourcing managers and representatives from our Conflict Minerals Team follow up to obtain the requested information.
Compare and Research: Upon receipt of the RCOI survey response, we compare each supplier’s reported list of smelters/refiners against the list of facilities that have received “compliant” or “active” designation from the Conflict Free Smelter Program (“CFSP”) or other independent third party audit programs, such as the London Bullion Market Association’s Responsible Gold Programme and the Responsible Jewelry Council’s Chain-of-Custody Certification program, to identify their “conflict-free” status. We rely on CFSI member data to ascertain the countries of origin of the Conflict Minerals processed by these facilities, and additionally, we leverage the research capabilities of a third party service provider to attempt to identify the countries of origin for supplier identified smelters/refiners that are not disclosed by the CFSI.
Document: At the conclusion of the process, we document the smelters/refiners and related countries of origin information for supplier identified smelters/refiners.
OECD Step 3: Execute a strategy to respond to identified risks
We develop and implement Conflict Minerals risk mitigation plans for all direct material suppliers identified as not meeting our company expectations for responsible sourcing of minerals (e.g., RCOI
survey non-responders, suppliers with Conflict Minerals sourced from non-compliant smelters/refiners etc.).
Our Conflict Minerals Team meets with relevant business sourcing managers to discuss and agree upon the actions Merck will take to maintain conformance with our Conflict Minerals Policy. We document and track the implementation of risk mitigation plans for each direct material supplier and present our progress annually to senior management.
Merck also provides information on smelter/refiner compliance status to direct material suppliers. For smelters/refiners that have not yet received a “compliant” or “active” designation from an independent third party audit program (e.g., CFSP), we encourage them indirectly through our direct material suppliers to participate in an internationally recognized independent third party audit program.
OECD Step 4: Carry out independent third-party audits
Merck supports the independent third-party audits of smelters/refiners through our membership contribution to CFSI. Merck’s CFSI member ID. No. is MERK.
OECD Step 5: Report annually on Supply Chain Due Diligence
Merck reports its annual Conflict Minerals due diligence results to the SEC and makes the report available on the company website at http://www.merck.com/about/how-we-operate/conflict_minerals_report.pdf. The information on this website is not incorporated by reference into this CMR and does not constitute a part of this CMR.
Part IV: Due Diligence Performed
Below is a summary of the due diligence activities Merck performed for this reporting period:
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| • | Implemented a Conflict Minerals Program that is integrated with our company’s sourcing and decision-making processes. |
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| • | Developed an online Conflict Minerals training course and completed the roll-out of the training to staff involved in direct material sourcing activities. |
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| • | Formed a cross-functional team to complete an assessment of all our company’s materials and products to identify the in-scope direct material suppliers who supply materials and products to Merck that could potentially contain 3TG. |
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| • | Notified our in-scope direct material suppliers of our Conflict Minerals Policy, provided training materials on Conflict Minerals, and provided a link to our company’s BPCC, which contains information on how to confidentially report concerns. |
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| • | Issued requests to all in-scope direct material suppliers to compete and return a CMRT survey form to obtain smelters/refiners information and countries of origin information for the materials/ products they provided to Merck in 2015. |
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| • | Reviewed CMRT survey responses received to identify potential red flags based on criteria defined in our company’s Conflict Minerals Program. For direct material suppliers surveyed in the previous |
reporting period, we compared the responses received this reporting period against their prior submission to monitor progress and consistency of reporting.
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| • | Performed verification activities to determine if any of the smelters/refiners disclosed by suppliers are Conflict Minerals processing facilities, using the Standard Smelter List published by CFSI. Where a supplier-identified smelter/refiner was confirmed as a Conflict Minerals processing facility, we evaluated whether or not that smelter/refiner was certified as “compliant” or “active” using the CFSP, or other equivalent validation program. For smelters/refiners not listed on the CFSI’s Standard Smelter List, we attempted to verify whether or not they are Conflict Minerals processing facilities, using other publicly available sources of information (e.g., by conducting reviews of various government databases and industry/trade organization lists). |
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| • | Conducted internal Conflict Minerals program reviews. Our cross-functional team met at least quarterly during the current filing period to: (a) discuss how to improve our Conflict Minerals Program; (b) review the status of the 2015 RCOI survey responses and due diligence outcomes; and (c) identify additional actions, if any, Merck will take to further mitigate identified risks. |
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| • | Communicated the results of Conflict Minerals surveys, smelter due diligence outcomes and ongoing risk mitigation efforts to senior management, including those responsible for global supply chain management and oversight of our Conflict Minerals Program. Presented the program status to the Executive Vice President and President of Merck Manufacturing Division. |
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| • | Financially supported Conflict Minerals initiatives through our continued membership to the CFSI. Merck’s CFSI member ID. No. is MERK. |
Part V: Results of Due Diligence
During this reporting period, we confirmed that none of our Pharmaceutical or Animal Health medicines, vaccines or biologic products contains any 3TG; however, Merck does have reason to believe that 3TG is necessary to the functionality or production of a small number of its delivery systems and ancillary products. Merck cannot at this time draw any definitive conclusions about the countries of origin for, or the compliant status of, all identified smelters/refiners that may be necessary to its products’ functionality or production. Although our in-scope direct material suppliers have made progress to identify smelters/refiners, not all were able to identify all smelters/refiners in their supply chain. Of the five suppliers who confirmed that 3TG was necessary to the functionality or production of their materials or products, four were able to provide the names of the smelters/refiners. For them, approximately 96% of their identified smelters/refiners were at company-level of their upstream suppliers and therefore potentially not relevant to the materials or products that they supply to us. Although the information in Appendix I and Appendix II below ultimately may not be completely relevant to any Merck product, given the aforementioned reasons, Merck has chosen to aggregate the smelter/refiner data for all four suppliers and report it in the Appendices below. In addition, our direct material suppliers were not able to provide a complete list of smelters/refiners, nor were they able to provide the countries of origin for the ore that the smelters/refiners were processing. Our efforts to determine the countries of origin for supplier identified smelters/refiners is, as described in this report, reliant on the “compliant” smelter/refiner information provided by CFSI, internationally recognized industry associations (e.g., CFSI, LBMA and RJC) and research of publicly available information on other smelters/refiners whose countries of origin information was not provided by CFSI (e.g., various government databases and industry/trade organization lists).
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| Metal | Total Number of Smelters/Refiners Identified By our Direct Material Suppliers | Number of Confirmed Smelters/Refiners | Number of “Compliant” Smelters/Refiners | Number of “Active” Smelters/Refiners |
| Total | 406 | 239 | 195 | 11 |
Note:
“Confirmed” means that smelters/refiners appear on the Standard Smelter List of the CFSI’s Conflict Minerals Reporting Template or the list of known conflict minerals processing facilities published by the U.S. Department of Commerce.
“Compliant” means that smelters/refiners are compliant with the CFSP assessment protocols. The compliance status reflected in the table is based solely on information published by CFSI as of May 3, 2016.
“Active” is a CFSP designation that means that smelters/refiners have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs. The active status reflected in the table is based solely on information published by CFSI as of May 3, 2016.
Part VI: Future Due Diligence Measures
Merck is continuing to execute and enhance the activities described in the Part III “Design of Conflict Minerals Program” and Part IV “Due Diligence Performed” for the next reporting period. Merck will continue to engage and educate our direct suppliers to endeavor to make further progress in identifying the smelters/refiners in their supply chain that are relevant to our materials and products in the survey. Merck will also continue to encourage our direct material suppliers to influence their upstream suppliers to participate in the CFSP or other equivalent program to become compliant smelters/refiners.
Appendix I Smelter or Refiner Information
The information provided in the list below is an aggregation of data received from our direct material suppliers and not a confirmation of Conflict Minerals contained in our products. Since most of the identified smelters/refiners were disclosed at the company-level by our direct material suppliers, Merck is unable to confirm which specific smelters/refiners were actually linked to our products. Therefore, there may be some smelters/refiners in the list below that do not relate directly to our products. Only the smelters/refiners whose facility names and locations were verified against the CFSI’s Standard Smelter List and the U.S. Department of Commerce List are reported below.
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| Metal | Smelter/Refiner Facility Name | Location of Facility |
| Gold | Advanced Chemical Company# | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd.* | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) # | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração* | BRAZIL |
| Gold | Argor-Heraeus SA* | SWITZERLAND |
| Gold | Asahi Pretec Corporation* | JAPAN |
| Gold | Asaka Riken Co., Ltd.* | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Aurubis AG* | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | PHILIPPINES |
| Gold | Bauer Walser AG | GERMANY |
| Gold | Boliden AB* | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG* | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | Xstrata Canada Corporation* | CANADA |
| Gold | Cendres + Métaux SA# | SWITZERLAND |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Chimet S.p.A.* | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daejin Indus Co., Ltd. # | KOREA, REPUBLIC OF |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Do Sung Corporation# | KOREA, REPUBLIC OF |
| Gold | Doduco* | GERMANY |
| Gold | Dowa* | JAPAN |
| Gold | Eco-System Recycling Co., Ltd.* | JAPAN |
| Gold | Heimerle + Meule GmbH* | GERMANY |
| Gold | Heraeus Ltd. Hong Kong* | HONG KONG |
| Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited* | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
| Gold | Istanbul Gold Refinery* | TURKEY |
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| Gold | Japan Mint* | JAPAN |
| Gold | Jiangxi Copper Company Limited* | CHINA |
| Gold | Johnson Matthey Inc* | UNITED STATES |
| Gold | Johnson Matthey Limited* | CANADA |
| Gold | JX Nippon Mining & Metals Co., Ltd.* | JAPAN |
| Gold | Kazzinc* | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC* | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd* | JAPAN |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | LS-NIKKO Copper Inc.* | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA |
| Gold | Materion* | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd.* | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd* | HONG KONG |
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
| Gold | Metalor Technologies SA* | SWITZERLAND |
| Gold | Metalor USA Refining Corporation* | UNITED STATES |
| Gold | Met-Mex Penoles, S.A.* | MEXICO |
| Gold | Mitsubishi Materials Corporation* | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
| Gold | Moscow Special Alloys Processing Plant* | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş.* | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat# | UZBEKISTAN |
| Gold | Nihon Material Co. LTD* | JAPAN |
| Gold | Ohio Precious Metals, LLC* | UNITED STATES |
| Gold | Ohura Precious Metal Industry Co., Ltd.* | JAPAN |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | PAMP SA* | SWITZERLAND |
| Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
| Gold | PX Précinox SA* | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd* | SOUTH AFRICA |
| Gold | Royal Canadian Mint* | CANADA |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
| Gold | Schone Edelmetaal B.V.* | NETHERLANDS |
| Gold | SEMPSA Joyería Platería SA* | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd* | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd.* | CHINA |
| Gold | So Accurate Group, Inc. | UNITED STATES |
| Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
| Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K.* | JAPAN |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
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| Gold | China's Shandong Gold Mining Co., Ltd* | CHINA |
| Gold | Tokuriki Honten Co., Ltd* | JAPAN |
| Gold | Torecom# | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda.* | BRAZIL |
| Gold | Umicore SA Business Unit Precious Metals Refining* | BELGIUM |
| Gold | United Precious Metal Refining, Inc.* | UNITED STATES |
| Gold | Valcambi SA* | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint* | AUSTRALIA |
| Gold | Yamamoto Precious Metal Co., Ltd.* | JAPAN |
| Gold | Yokohama Metal Co., Ltd.* | JAPAN |
| Gold | Zhongjin Gold Corporation Limited* | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery* | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Umicore Precious Metals Thailand* | THAILAND |
| Gold | Faggi Enrico S.p.A. # | ITALY |
| Gold | Republic Metals Corporation* | UNITED STATES |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry* | CHINA |
| Tantalum | Duoluoshan* | CHINA |
| Tantalum | Exotech Inc.* | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd.* | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | CHINA |
| Tantalum | Hi-Temp* | UNITED STATES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd.* | CHINA |
| Tantalum | King-Tan Tantalum Industry Ltd.* | CHINA |
| Tantalum | LSM Brasil S.A.* | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd.* | INDIA |
| Tantalum | Mineração Taboca S.A.* | BRAZIL |
| Tantalum | Mitsui Mining & Smelting* | JAPAN |
| Tantalum | Molycorp Silmet A.S.* | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
| Tantalum | QuantumClean* | UNITED STATES |
| Tantalum | RFH* | CHINA |
| Tantalum | Solikamsk Metal Works* | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals* | JAPAN |
| Tantalum | Telex* | UNITED STATES |
| Tantalum | Ulba* | KAZAKHSTAN |
| Tantalum | Zhuzhou Cement Carbide* | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.* | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | CHINA |
| Tantalum | D Block Metals, LLC* | UNITED STATES |
| Tantalum | FIR Metals & Resource Ltd.* | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CHINA |
| Tantalum | KEMET Blue Metals* | MEXICO |
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| Tantalum | Plansee SE Liezen* | AUSTRIA |
| Tantalum | H.C. Starck Co., Ltd.* | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar* | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg* | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
| Tantalum | H.C. Starck Inc.* | UNITED STATES |
| Tantalum | H.C. Starck Ltd.* | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG* | GERMANY |
| Tantalum | Plansee SE Reutte* | AUSTRIA |
| Tantalum | Global Advanced Metals Boyertown* | UNITED STATES |
| Tantalum | Global Advanced Metals Aizu* | JAPAN |
| Tantalum | KEMET Blue Powder* | UNITED STATES |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd.* | CHINA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | Alpha* | UNITED STATES |
| Tin | Cooperativa Metalurgica de Rondônia Ltda.* | BRAZIL |
| Tin | CV Gita Pesona* | INDONESIA |
| Tin | PT JusTindo* | INDONESIA |
| Tin | CV Nurjanah* | INDONESIA |
| Tin | CV Serumpun Sebalai* | INDONESIA |
| Tin | CV United Smelting* | INDONESIA |
| Tin | EM Vinto* | BOLIVIA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY |
| Tin | Fenix Metals* | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
| Tin | Gejiu Zi-Li | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC# | CHINA |
| Tin | Linwu Xianggui Smelter Co | CHINA |
| Tin | China Lai Bin tin smelting co.,ltd* | CHINA |
| Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
| Tin | Mineração Taboca S.A.* | BRAZIL |
| Tin | Minsur* | PERU |
| Tin | Mitsubishi Materials Corporation* | JAPAN |
| Tin | Jiangxi Nanshan | CHINA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
| Tin | Operaciones Metalurgical S.A.* | BOLIVIA |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | PT Artha Cipta Langgeng* | INDONESIA |
| Tin | PT Babel Inti Perkasa* | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT Bangka Tin Industry* | INDONESIA |
| Tin | PT Belitung Industri Sejahtera* | INDONESIA |
| Tin | PT BilliTin Makmur Lestari* | INDONESIA |
|
| | |
| Tin | PT Bukit Timah* | INDONESIA |
| Tin | PT DS Jaya Abadi* | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri* | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT Karimun Mining# | INDONESIA |
| Tin | PT Mitra Stania Prima* | INDONESIA |
| Tin | PT Panca Mega Persada* | INDONESIA |
| Tin | PT Prima Timah Utama* | INDONESIA |
| Tin | PT Refined Bangka Tin* | INDONESIA |
| Tin | PT Sariwiguna Binasentosa* | INDONESIA |
| Tin | PT Seirama Tin Investment | INDONESIA |
| Tin | PT Stanindo Inti Perkasa* | INDONESIA |
| Tin | PT Sumber Jaya Indah* | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur* | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok* | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | PT Tinindo Inter Nusa* | INDONESIA |
| Tin | Rui Da Hung* | TAIWAN |
| Tin | Soft Metais Ltda.* | BRAZIL |
| Tin | Thailand Smelting & Refining Co Ltd* | THAILAND |
| Tin | White Solder Metalurgia e Mineração Ltda.* | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.# | CHINA |
| Tin | China Yunnan Tin Co Ltd.* | CHINA |
| Tin | CV Venus Inti Perkasa* | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
| Tin | PT Wahana Perkit Jaya* | INDONESIA |
| Tin | Melt Metais e Ligas S/A* | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya* | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
| Tin | PT Inti Stania Prima* | INDONESIA |
| Tin | CV Ayi Jaya* | INDONESIA |
| Tin | Metallo-Chimique N.V.* | BELGIUM |
| Tin | Elmet S.L.U. (Metallo Group)* | SPAIN |
| Tungsten | A.L.M.T. TUNGSTEN Corp.* | JAPAN |
| Tungsten | Kennametal Huntsville* | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co Ltd* | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd.* | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd.* | CHINA |
| Tungsten | Global Tungsten & Powders Corp.* | UNITED STATES |
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd.* | CHINA |
| Tungsten | Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* | CHINA |
| Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Huaxin Tungsten Products* | CHINA |
|
| | |
| Tungsten | Kennametal Fallon* | UNITED STATES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG* | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd* | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | CHINA |
| Tungsten | H.C. Starck GmbH* | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG* | GERMANY |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA |
| Tungsten | Hydrometallurg, JSC* | RUSSIAN FEDERATION |
Note: As used in the table, the terms “compliant” and “active” have the meanings defined by the CFSI. The compliance status reflected in the table is based solely on information made publicly available by the CFSI as of May 3, 2016 without independent verification by us.
* Compliant smelter/refiner
# Active smelter/refiner
Appendix II Country of Origin Information
The countries of origin of the Conflict Minerals processed by the smelters/refiners listed above may have included the countries listed below, based on information provided by the CFSI to its members for the “compliant” smelters/refiners and our independent research of all other smelters/refiners disclosed. Because the CFSI generally does not indicate individual country of origin of the Conflict Minerals processed by “compliant” smelters/refiners, we were not able to determine the countries of origin of the Conflict Minerals processed by the listed “compliant” smelters/ refiners with greater specificity. In addition, for some of the listed “compliant” smelters/refiners, the country of origin information is not disclosed by CFSI.
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L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Côte 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 of America, Vietnam, Zimbabwe |
L2 - Countries that are known or plausible countries for smuggling, exporting out of region or transit of materials containing tantalum, tin, tungsten or gold: Kenya, Mozambique and South Africa. |
L3 - Countries that are defined as the adjoining countries of the DRC: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia. |
DRC - The Democratic Republic of the Congo. |
