Exhibit 1.01
CONFLICT MINERALS REPORT FOR CALENDAR YEAR 2016
Part I: Introduction
This document constitutes Merck & Co., Inc.’s Conflict Minerals Report (the “Report” or "CMR") for the year ended December 31, 2016. 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 ("RCOI"). If, as a result of a 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, Healthcare Services and Alliances. 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 product 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 materials and products introduced in our supply chain for this reporting period and confirmed there were no new materials or products containing 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. 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 product delivery systems and ancillary devices to support the use of our 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 2016 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 five direct material suppliers (including contract manufacturers) were in scope for the RCOI survey. Accordingly, we sent the RCOI survey to these five 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 ("BPCC"), Conflict Minerals basic training material, and the reasons why we contacted them. We also provided these suppliers with additional resources provided by CFSI, such as the CMRT completion guide, Conflict Minerals Training Modules, supplier communication introduction letter in five languages, and the smelters and refiners conflict free 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 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 five direct material suppliers that were in the RCOI survey. All five direct material suppliers were in the RCOI survey last year, and their responses were consistent with the last survey. These 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. Four of the five direct material suppliers 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 Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance"), 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 an established 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 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 Compliance, Supplier Management, Business Development, and Technical Experts that supervise and manage our Conflict Minerals Program. This team provides program status to senior management of Procurement and the Executive Vice President 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 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 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.
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., suppliers with no smelters/refiners identified, 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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| • | Continued to use our Conflict Minerals Program which is integrated in our Company’s sourcing and decision-making processes to evaluate any new suppliers and new products and materials. |
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| • | Continued to roll out the training to new staff involved in direct material sourcing activities. |
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| • | A cross-functional team, consisting of representatives from Compliance, Procurement, Business Development and Technical Operations, oversees our Company’s Conflict Minerals compliance program. |
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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 complete 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 2016. |
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| • | Reviewed CMRT survey responses received to identify potential red flags based on criteria defined in our Company’s Conflict Minerals compliance 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 to discuss how to improve our Conflict Minerals Program; to review the status of the 2016 RCOI survey responses and due diligence outcomes; and to 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 contain any 3TG; however, Merck does have reason to believe 3TG is necessary to the functionality or production of a small number of its delivery systems and ancillary devices to support the use of our 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 all five suppliers who confirmed 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 86% of their identified smelters/refiners were at company-level of their upstream suppliers and therefore potentially not relevant to the materials or products 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, London Bullion Market Association and Responsible Jewellery Council) 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 | 414 | 226 | 201 | 3 |
Note:
“Confirmed” means smelters/refiners appear on the Standard Smelter List of the CFSI’s CMRT.
“Compliant” means 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 March 3, 2017.
“Active” is a CFSP designation that means 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 March 3, 2017.
Part VI: Future Due Diligence Measures
Merck is continuing to execute and discuss potential enhancement to 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 are reported below.
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| Metal | Smelter/Refiner Facility Name | Location of Facility |
| Gold | Matsuda Sangyo Co., Ltd.* | Japan |
| Gold | Singway Technology Co., Ltd.* | Taiwan |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V* | Mexico |
| Gold | Solar Applied Materials Technology Corp. * | Taiwan |
| Gold | Advanced Chemical Company* | United States |
| Gold | Metalor Technologies (Hong Kong) Ltd.* | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. * | Singapore |
| Gold | Metalor Technologies SA* | Switzerland |
| Gold | Metalor USA Refining Corporation* | United States |
| Gold | Asahi Refining Canada Limited* | Canada |
| Gold | Aida Chemical Industries Co., Ltd. * | Japan |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. * | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) * | Uzbekistan |
| Gold | Mitsubishi Materials Corporation* | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. * | Japan |
| Gold | Sumitomo Metal Mining Co., Ltd. * | Japan |
| Gold | Moscow Special Alloys Processing *Plant | Russian Federation |
| Gold | AngloGold Ashanti* | Brazil |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. * | Turkey |
| Gold | Argor-Heraeus SA* | Switzerland |
| Gold | Asahi Pretec Corporation* | Japan |
| Gold | Asaka Riken Co., Ltd. * | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. * | Japan |
| Gold | Aurubis AG* | Germany |
| Gold | Nihon Material Co., Ltd. * | Japan |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) * | Philippines |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM* | China |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. * | China |
| Gold | Heimerle + Meule GmbH* | Germany |
| Gold | Heraeus Ltd. Hong Kong* | China |
| Gold | Boliden AB* | Sweden |
| Gold | Heraeus Precious Metals GmbH & Co. KG* | Germany |
| Gold | Tokuriki Honten Co., Ltd. * | Japan |
| Gold | Torecom* | Korea, Republic of |
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| Gold | C. Hafner GmbH + Co. KG* | Germany |
| Gold | Ohura Precious Metal Industry Co., Ltd. * | Japan |
| Gold | CCR Refinery - Glencore Canada Corporation* | Canada |
| Gold | Cendres + Métaux SA* | Switzerland |
| Gold | Umicore Brasil Ltda. * | Brazil |
| Gold | Umicore Precious Metals Thailand* | Thailand |
| Gold | Umicore SA Business Unit Precious Metals Refining* | Belgium |
| Gold | PAMP SA* | Switzerland |
| Gold | United Precious Metal Refining, Inc. * | United States |
| Gold | Chimet S.p.A. * | Italy |
| Gold | Valcambi SA* | Switzerland |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited* | China |
| Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia |
| Gold | Western Australian Mint trading as The Perth Mint* | Australia |
| Gold | Ishifuku Metal Industry Co., Ltd. * | Japan |
| Gold | Istanbul Gold Refinery* | Turkey |
| Gold | Japan Mint* | Japan |
| Gold | Jiangxi Copper Company Limited* | China |
| Gold | Daejin Indus Co., Ltd. * | Korea, Republic of |
| Gold | PX Precinox SA* | Switzerland |
| Gold | Daye Non-Ferrous Metals Mining Ltd. * | China |
| Gold | Yamamoto Precious Metal Co., Ltd. * | Japan |
| Gold | Rand Refinery (Pty) Ltd. * | South Africa |
| Gold | DSC (Do Sung Corporation) * | Korea, Republic of |
| Gold | Asahi Refining USA Inc. * | United States |
| Gold | DODUCO GmbH* | Germany |
| Gold | Yokohama Metal Co., Ltd. * | Japan |
| Gold | Republic Metals Corporation* | United States |
| Gold | JX Nippon Mining & Metals Co., Ltd. * | Japan |
| Gold | Kazzinc* | Kazakhstan |
| Gold | Royal Canadian Mint* | Canada |
| Gold | Kennecott Utah Copper LLC* | United States |
| Gold | Dowa* | Japan |
| Gold | Kojima Chemicals Co., Ltd. * | Japan |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery* | China |
| Gold | Schone Edelmetaal B.V. * | Netherlands |
| Gold | Eco-System Recycling Co., Ltd. * | Japan |
| Gold | SEMPSA Joyería Platería SA* | Spain |
| Gold | Kyrgyzaltyn JSC* | Kyrgyzstan |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. * | China |
| Gold | LS-NIKKO Copper Inc. * | Korea, Republic of |
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| Gold | Sichuan Tianze Precious Metals Co., Ltd. * | China |
| Gold | Materion* | United States |
| Gold | Navoi Mining and Metallurgical Combinat# | Uzbekistan |
| Gold | So Accurate Group, Inc. | United States |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Bangalore Refinery | India |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Elemetal Refining, LLC | United States |
| Gold | Caridad | Mexico |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | HwaSeong CJ Co. Ltd | Korea, Republic of |
| Gold | Chugai Mining | Japan |
| Gold | Yunnan Copper Industry Co Ltd | China |
| Gold | Remondis Argentia B.V. | Netherlands |
| Gold | Sabin Metal Corp. | United States |
| Gold | SAMWON METALS Corp. | Korea, Republic of |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China |
| Gold | Luo yang Zijin Yinhui Metal Smelt Co Ltd | China |
| Tantalum | Solikamsk Magnesium Works OAO* | Russian Federation |
| Tantalum | Metallurgical Products India Pvt., Ltd. * | India |
| Tantalum | Mineração Taboca S.A. * | Brazil |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. * | China |
| Tantalum | Global Advanced Metals Aizu* | Japan |
| Tantalum | Global Advanced Metals Boyertown* | United States |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. * | Japan |
| Tantalum | NPM Silmet AS* | Estonia |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. * | China |
| Tantalum | H.C. Starck Co., Ltd. * | Thailand |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH* | 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 | Telex Metals* | United States |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. * | China |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. * | China |
| Tantalum | Hi-Temp Specialty Metals, Inc. * | United States |
| Tantalum | Ulba Metallurgical Plant JSC* | Kazakhstan |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. * | China |
| Tantalum | Conghua Tantalum and Niobium Smeltry* | China |
| Tantalum | D Block Metals, LLC* | United States |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. * | China |
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| Tantalum | QuantumClean* | United States |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. * | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. * | China |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. * | China |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. * | China |
| Tantalum | KEMET Blue Metals* | Mexico |
| Tantalum | Kemet Blue Powder* | United States |
| Tantalum | King-Tan Tantalum Industry Ltd. * | China |
| Tantalum | Duoluoshan* | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. * | China |
| Tantalum | Taki Chemical Co., Ltd. * | Japan |
| Tantalum | Exotech Inc. * | United States |
| Tantalum | F&X Electro-Materials Ltd. * | China |
| Tantalum | LSM Brasil S.A. * | Brazil |
| Tantalum | FIR Metals & Resource Ltd. * | China |
| Tin | Melt Metais e Ligas S.A. * | Brazil |
| Tin | Soft Metais Ltda. * | Brazil |
| Tin | Metallo-Chimique N.V. * | Belgium |
| Tin | Gejiu Kai Meng Industry and Trade LLC# | China |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.# | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. * | China |
| Tin | Mineração Taboca S.A. * | Brazil |
| Tin | Minsur* | Peru |
| Tin | Alpha* | United States |
| Tin | Mitsubishi Materials Corporation* | Japan |
| Tin | Thaisarco* | Thailand |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. * | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. * | Philippines |
| Tin | Operaciones Metalurgical S.A. * | Bolivia |
| Tin | China Tin Group Co., Ltd. * | China |
| Tin | PT Aries Kencana Sejahtera* | Indonesia |
| Tin | PT Artha Cipta Langgeng* | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia |
| Tin | PT Babel Inti Perkasa* | Indonesia |
| Tin | PT Bangka Tin Industry* | Indonesia |
| Tin | PT Belitung Industri Sejahtera* | Indonesia |
| Tin | PT Bukit Timah* | Indonesia |
| Tin | White Solder Metalurgia e Mineração Ltda. * | Brazil |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. * | Brazil |
| Tin | PT DS Jaya Abadi* | Indonesia |
| Tin | PT Eunindo Usaha Mandiri* | Indonesia |
| Tin | PT Inti Stania Prima* | Indonesia |
| Tin | PT Justindo* | Indonesia |
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| Tin | PT Karimun Mining* | Indonesia |
| Tin | PT Mitra Stania Prima* | Indonesia |
| Tin | PT Panca Mega Persada* | Indonesia |
| Tin | CV Ayi Jaya* | Indonesia |
| Tin | PT Prima Timah Utama* | Indonesia |
| Tin | CV Gita Pesona* | Indonesia |
| Tin | PT Refined Bangka Tin* | Indonesia |
| Tin | PT Sariwiguna Binasentosa* | Indonesia |
| Tin | CV Serumpun Sebalai* | Indonesia |
| Tin | CV United Smelting* | Indonesia |
| Tin | CV Venus Inti Perkasa* | Indonesia |
| Tin | PT Stanindo Inti Perkasa* | Indonesia |
| Tin | PT Sumber Jaya Indah* | Indonesia |
| Tin | PT Timah (Persero) Tbk Mentok* | Indonesia |
| Tin | PT Timah (Persero) Tbk Kundur* | Indonesia |
| Tin | PT Tinindo Inter Nusa* | Indonesia |
| Tin | PT Tommy Utama* | Indonesia |
| Tin | PT WAHANA PERKIT JAYA* | Indonesia |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. * | China |
| Tin | Yunnan Tin Group (Holding) Company Limited* | China |
| Tin | Rui Da Hung* | Taiwan |
| Tin | Dowa* | Japan |
| Tin | Elmet S.L.U. * | Spain |
| Tin | EM Vinto* | Bolivia |
| Tin | Fenix Metals* | Poland |
| Tin | Magnu's Minerais Metais e Ligas Ltda. * | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) * | Malaysia |
| Tin | Huichang Jinshunda Tin Co. Ltd | China |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China |
| Tin | Estanho de Rondônia S.A. | Brazil |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. * | China |
| Tungsten | A.L.M.T. TUNGSTEN Corp. * | Japan |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. * | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. * | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. * | China |
| Tungsten | Global Tungsten & Powders Corp. * | United States |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. * | China |
| Tungsten | Asia Tungsten Products Vietnam Ltd. * | Viet Nam |
| Tungsten | H.C. Starck GmbH* | Germany |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG* | Germany |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. * | Viet Nam |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | Viet Nam |
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| Tungsten | Hunan Chenzhou Mining Co., Ltd. * | China |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. * | China |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. * | China |
| Tungsten | Hydrometallurg, JSC* | Russian Federation |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. * | Viet Nam |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. * | China |
| Tungsten | Japan New Metals Co., Ltd. * | Japan |
| Tungsten | Wolfram Bergbau und Hütten AG* | Austria |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. * | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. * | China |
| Tungsten | Xiamen Tungsten Co., Ltd. * | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. * | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. * | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. * | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. * | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. * | China |
| Tungsten | Kennametal Fallon* | United States |
| Tungsten | Kennametal Huntsville* | United States |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. * | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China |
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 March 3, 2017 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, Benin, Bolivia, Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Eritrea, Estonia, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Netherlands, Nicaragua, Nigeria, Panama, Peru, Portugal, Russia, Senegal, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, Togo, United Kingdom, United States of America, Uzbekistan, 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: Mozambique and South Africa. |
L3 - Countries that are defined as the adjoining countries of the DRC: Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia. |
DRC - The Democratic Republic of the Congo. |
