Exhibit 1.01
CONFLICT MINERALS REPORT
TO
FORM SD SPECIALIZED DISCLOSURE REPORT
OF
ECOLAB INC.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of the future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG (as such term is defined below) benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of the filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document or to reflect the occurrence of unanticipated events.
I. Introduction
Except where the context otherwise requires, references in this Conflict Minerals Report to “Ecolab,” “Company,” “we” and “our” are to Ecolab Inc. and its subsidiaries, collectively. As used herein and consistent with the Conflict Minerals Rule (as such term is defined below), (1) “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold and wolframite, and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals, and (2) the “Conflict Minerals Rule” is, collectively, Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD.
Applicability of the Conflict Minerals Rule to Our Company
We are the global leader in water, hygiene and energy technologies and services that protect people and vital resources. We deliver comprehensive programs and services to promote safe food, maintain clean environments, optimize water and energy use and improve operational efficiencies for customers in the food, energy, healthcare, industrial and hospitality markets in more than 170 countries. Our cleaning and sanitizing programs and products, pest elimination services, and equipment maintenance and repair services support customers in the foodservice,
food and beverage processing, hospitality, healthcare, government and education, retail, textile care and commercial facilities management sectors. Our products and technologies are also used in water treatment, pollution control, energy conservation, oil production and refining, steelmaking, papermaking, mining and other industrial processes.
We are required to make filings pursuant to the Conflict Minerals Rule because some of the products that we manufacture or contract to manufacture, in particular certain components of our control and dispensing equipment and healthcare product offerings, contain 3TG that are necessary to the functionality or production of the products. Not all of our products contain 3TG. The 3TG content in our products accounts for only a small percentage of the total materials content and our products with 3TG content accounted for less than 1% of our 2015 total sales. Our in-scope products taken together as a whole include all four 3TG, though each in-scope product does not include all four 3TG.
We do not directly source 3TG from mines, smelters or refiners, and we believe that we are in most cases many levels removed from these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy described below.
Reasonable Country of Origin Information
As required by the Conflict Minerals Rule, for 2015, we conducted a “reasonable country of origin inquiry” (“RCOI”) of the direct suppliers of the components, parts or products believed by us to contain 3TG. Our RCOI was reasonably designed to determine in good faith whether any of the 3TG in our in-scope products originated in the DRC or an adjoining country or from recycled or scrap sources. For our RCOI, we utilized the processes and procedures contemplated by Steps 1 and 2 of the OECD Guidance (as defined below). These steps of the OECD Guidance are described under “Design of Due Diligence Measures” and “Due Diligence Measures Performed by Ecolab.”
In connection with our RCOI, suppliers identified to us 389 smelters and refiners that processed the necessary 3TG contained in our in-scope products. As of May 3, 2016, 202 of these smelters and refiners were listed as “compliant” by the Conflict-Free Sourcing Initiative (the “CFSI”) and 30 were listed as having agreed to an audit. Of the remaining 157 smelters and refiners, 130 could be verified as smelters and refiners and 27 facilities could not be verified. The smelters and refiners (other than those that could not be verified) and their compliance status are listed on Annexes I and II.
As we did last year, to help achieve a greater level of specificity in determining the countries of origin of the 3TG processed by the smelters and refiners identified by our suppliers, we enlisted the services of a third party service provider (the “Reviewer”) to review the smelters and refiners identified to us and provide us with a list of the related countries of origin known to it. The identified countries of origin are listed below under “Product, Smelter and Refiner and Country of Origin Information.” Our country of origin determinations are derived from the information provided to us by the Reviewer. Certain of the other compliance activities described in this Conflict Minerals Report were performed on our behalf by the Reviewer.
Based on the information provided by the Reviewer and our own analysis, we had reason to believe that some of the identified smelters and refiners sourced from the DRC and its adjoining countries. Accordingly, pursuant to the Conflict Minerals Rule, based on the results of our
RCOI, we were required to conduct due diligence for 2015. These due diligence efforts are discussed below.
II. Design of Due Diligence Measures
We designed our 3TG compliance procedures based on, and in conformity in all material respects with, the applicable portions of the five step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2013 Second Edition), including the supplements on tin, tantalum and tungsten and gold (the “OECD Guidance”). Selected elements of our program design are discussed below. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2015 are discussed below under “Due Diligence Measures Performed by Ecolab.”
1. Establish strong company management systems
a. We have a team of responsible personnel from our regulatory affairs, global supply chain and legal functions for the management and continued implementation of our 3TG compliance strategy. We also utilize specialist outside counsel and other advisors to assist us with our compliance efforts.
b. We have adopted and communicate to our suppliers and the public a company policy regarding 3TG (the “Conflict Minerals Policy”) for our supply chain. Among other things, the Conflict Minerals Policy contains our expectations that our suppliers: (i) supply materials to Ecolab that are “DRC Conflict-Free”; (ii) adopt policies and management systems with respect to 3TG and require their suppliers to adopt similar policies and systems; (iii) establish their own due diligence program to ensure conflict-free supply chains; and (iv) respond to survey requests in a timely manner, and with full disclosure, following the specific instructions provided. The Conflict Minerals Policy indicates that, in the event Ecolab determines that a supplier’s efforts to comply with the Conflict Minerals Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Ecolab reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier.
We do not seek to embargo responsible sourcing of 3TG from the DRC region, nor do we condone a general embargo on sourcing from the region.
c. We utilize the Conflict Minerals Reporting Template (the “Conflict Minerals Reporting Template”) developed by the CFSI to identify smelters and refiners in our supply chain. The Conflict Minerals Reporting Template requests suppliers to provide information concerning the usage and source of 3TG in their products, as well as information concerning their related compliance efforts.
d. We are a member of the CFSI. Additionally, we participate as a member of the Conflict Minerals Task Force in the Twin Cities (Minneapolis-St.
Paul) for the purpose of aligning our approach and establishing best practices with other firms with respect to compliance with the Conflict Minerals Rule.
e. We have implemented an IT solution to engage our direct suppliers and to maintain responses relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, in an electronic format for at least five years.
f. Our forms of purchase order terms and conditions contain provisions relating to the sourcing of 3TG to be contained in our products.
g. We include as a part of our supplier quality review process inquiries concerning the supplier’s policies and procedures relating to 3TG sourcing.
h. In addition to other reporting methods set forth on our web site and in our Code of Conduct, we have a dedicated email address, conflictminerals@ecolab.com, which can be used by interested parties to contact Ecolab with respect to its supplier surveys, Conflict Minerals Policy and related matters.
2. Identify and assess risk in the supply chain
a. We request that suppliers provide us with information concerning the usage and source of 3TG in the parts that they sell to us and their related compliance efforts through the completion of a Conflict Minerals Reporting Template. We follow up by email with suppliers that do not respond to the request within a specified time frame.
b. Our IT solution utilizes programming logic to review the Conflict Minerals Reporting Templates that we receive from suppliers and flags responses not conforming to specified criteria.
c. Smelter and refiner data is reviewed for us by the Reviewer to verify, to the extent known by the Reviewer based on its research, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG obtained by such smelters and refiners and (d) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country.
Design and implement a strategy to respond to identified risks
We have procedures for monitoring and reporting on risk to designated senior management on an ongoing basis. Pursuant to these procedures, our 3TG compliance team reports the findings of its compliance efforts to a steering committee comprised of management personnel from our global supply chain, regulatory affairs, legal, research and development and sustainability functions.
We utilize a risk mitigation framework that allows for a flexible response commensurate with the risks identified. Under the framework, actions range from supplier education and follow-up to discontinuing purchases from a supplier.
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
With our membership in the CFSI, we support an industry initiative that audits smelters’ and refiners’ due diligence activities. The data on which we relied for certain statements in this Conflict Minerals Report was obtained through our membership in the CFSI.
Report on supply chain due diligence
We file a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and make these documents available on our website at http://www.ecolab.com/investor.
III. Due Diligence Measures Performed by Ecolab
Ecolab has performed the due diligence and related measures set forth below in respect of 2015. These are not all of the measures that we took in respect of 2015 in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance.
We sent requests to our in-scope suppliers to provide us with a completed Conflict Minerals Reporting Template. We followed up by email with the suppliers that did not provide a response within the specified time frame.
We reviewed the completed responses received from the suppliers based on our approved review criteria to identify incomplete responses and specified sourcing risks and sent follow-up emails to suppliers providing incomplete or non-conforming responses.
We enlisted the services of the Reviewer to verify, to the extent known by the Reviewer based on its research, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG obtained by such smelters and refiners and (d) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country.
Our 3TG compliance team reported the findings of its compliance efforts in respect of 2015 to our management steering committee.
We participated in independent third-party audits of smelters and refiners through our membership in the CFSI. In addition, one of the members of our Conflict Minerals practices team was a member of the CFSI due diligence practices team.
IV. Product, Smelter and Refiner and Country of Origin Information
In-Scope Product Categories
For 2015, our in-scope products were in the following product categories:
A. Equipment used for the control and dispensing of chemical products.
B. Healthcare patient management systems and other miscellaneous components related to our Healthcare products.
Identified Smelters and Refiners
In connection with our due diligence, the suppliers identified to us the verified smelters and refiners listed in Annex I and Annex II below as having processed the necessary 3TG contained in our in-scope products in 2015. However, not all of the included smelters and refiners may have processed the necessary 3TG contained in our in-scope products. In some cases, suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners listed in the Annexes may not be all of the smelters and refiners in our supply chain, since the suppliers may have been unable to identify the smelters and refiners of some of the necessary 3TG content contained in our in-scope products and because not all suppliers responded to our inquiries.
Annex I sets forth smelters and refiners listed by CFSI as compliant or participating in third-party 3TG audit programs such as the CFSI’s Conflict-Free Smelter Program and those carried out by the London Bullion Market Association, the Responsible Jewellery Council, ITRI through its Tin Supply Chain Initiative and the Tungsten Industry - Conflict Minerals Council. Annex II provides a list of verified smelters and refiners that were not included on the aforementioned CFSI list. The Reviewer was unable to verify the status of 27 smelters and refiners provided to us by the suppliers. Such unverified smelters and refiners are not listed on the Annexes. We are continuing to investigate these and, if they are determined to be smelters/refiners, we will incorporate them into our due diligence process.
Potential Countries of Origin
In addition to sourcing from recycled and scrap sources, based on information received from the Reviewer, Ecolab believes the country of origin of the 3TG sourced by the smelters and refiners in the Annexes may include the following: Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bolivia, Brazil, Burundi, Canada, Chile, China, the DRC, Egypt, Estonia, Ethiopia, France, Germany, Ghana, Greece, Guinea, Guyana, Hong Kong, India, Indonesia, Italy, Japan, Jersey, Kazakhstan, Kyrgyzstan, Laos, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Romania, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, South Africa, South Korea, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, United Kingdom, United States, Uzbekistan, Vietnam, Zambia, Zimbabwe.
Of the 362 smelters and refiners listed in the Annexes, 32 smelters and refiners were identified by the Reviewer as sourcing 3TG from the DRC or an adjoining country, with 31 of such smelters and refiners listed as compliant under a third party audit program as of May 3, 2016.
For 2015, notwithstanding our compliance efforts, we were unable to determine the facilities at which at least a portion of the necessary 3TG contained in each of our in-scope products were processed. Accordingly, we also were unable to determine the country of origin for at least a portion of the necessary 3TG contained in each of our in-scope products. However, none of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. We did not
conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
We endeavored to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the suppliers provide us with a completed Conflict Minerals Reporting Template and through the other measures described in this Conflict Minerals Report. Additionally, the Reviewer assisted us in determining whether the smelters and refiners identified to us by our suppliers obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country to the extent such information was reasonably available.
V. Steps to Improve Due Diligence
We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:
Continue follow-up with direct suppliers that were unresponsive or provided non-conforming responses to improve response rates and quality of information.
Continue our membership in CFSI.
Contribute to the CFSI Initial Audit Fund.
Provide list of unverified facilities to the CFSI smelter engagement team.
Provide additional training and engage additional personnel to support supplier outreach efforts.
ANNEX I
Aggregated List of Facilities Participating in Audit Programs (CFSI, RJC, LBMA, TI-CMC)
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or |
Aida Chemical Industries Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Allgemeine Gold-und Silberscheideanstalt A.G. |
| Gold |
| Compliant |
| Germany |
Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold |
| Active |
| Uzbekistan |
Argor-Heraeus SA |
| Gold |
| Compliant |
| Switzerland |
Asahi Pretec Corporation |
| Gold |
| Compliant |
| Japan |
Asahi Refining Canada Limited |
| Gold |
| Compliant |
| Canada |
Asahi Refining USA Inc. |
| Gold |
| Compliant |
| United States |
Asaka Riken Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Aurubis AG |
| Gold |
| Compliant |
| Germany |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold |
| Compliant |
| Philippines |
Boliden AB |
| Gold |
| Compliant |
| Sweden |
C. Hafner GmbH + Co. KG |
| Gold |
| Compliant |
| Germany |
CCR Refinery - Glencore Canada Corporation |
| Gold |
| Compliant |
| Canada |
Chimet S.p.A. |
| Gold |
| Compliant |
| Italy |
Cendres + Métaux SA |
| Gold |
| Active |
| Switzerland |
Daeijin Indus Co., Ltd. |
| Gold |
| Active |
| South Korea |
DODUCO GmbH |
| Gold |
| Compliant |
| Germany |
Dowa |
| Gold |
| Compliant |
| Japan |
DSC (Do Sung Corporation) |
| Gold |
| Active |
| South Korea |
Eco-System Recycling Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Elemetal Refining, LLC |
| Gold |
| Compliant |
| United States |
Faggi Enrico S.p.A. |
| Gold |
| Active |
| Italy |
Geib Refining Corporation |
| Gold |
| Active |
| United States |
Heimerle + Meule GmbH |
| Gold |
| Compliant |
| Germany |
Heraeus Ltd. Hong Kong |
| Gold |
| Compliant |
| China |
Heraeus Precious Metals GmbH & Co. KG |
| Gold |
| Compliant |
| Germany |
Ishifuku Metal Industry Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Istanbul Gold Refinery |
| Gold |
| Compliant |
| Turkey |
Japan Mint |
| Gold |
| Compliant |
| Japan |
Jiangxi Copper Company Limited |
| Gold |
| Compliant |
| China |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold |
| Compliant |
| Russia |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or |
JSC Uralelectromed |
| Gold |
| Compliant |
| Russia |
JX Nippon Mining & Metals Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Kazzinc |
| Gold |
| Compliant |
| Kazakhstan |
Kennecott Utah Copper LLC |
| Gold |
| Compliant |
| United States |
KGHM Polska Miedź Spόtka Akcyjna |
| Gold |
| Active |
| Poland |
Kojima Chemicals Co., Ltd. |
| Gold |
| Compliant |
| Japan |
LS-NIKKO Copper Inc. |
| Gold |
| Compliant |
| South Korea |
Materion |
| Gold |
| Compliant |
| United States |
Matsuda Sangyo Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Metalor Technologies (Hong Kong) Ltd. |
| Gold |
| Compliant |
| China |
Metalor Technologies (Singapore) Pte., Ltd. |
| Gold |
| Compliant |
| Singapore |
Metalor Technologies (Suzhou) Co Ltd |
| Gold |
| Active |
| China |
Metalor Technologies SA |
| Gold |
| Compliant |
| Switzerland |
Metalor USA Refining Corporation |
| Gold |
| Compliant |
| United States |
Metalúrgica Met-Mex Peñoles S.A. de C.V. |
| Gold |
| Compliant |
| Mexico |
Mitsubishi Materials Corporation |
| Gold |
| Compliant |
| Japan |
Mitsui Mining & Smelting |
| Gold |
| Compliant |
| Japan |
MMTC-PAMP India Pvt., Ltd. |
| Gold |
| Compliant |
| India |
Moscow Special Alloys Processing Plant |
| Gold |
| Compliant |
| Russia |
Nadir Metal Rafineri San. Ve Tic A.Ş. |
| Gold |
| Compliant |
| Turkey |
Navoi Mining and Metallurgical Combinat |
| Gold |
| Active |
| Uzbekistan |
Nihon Material Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold |
| Compliant |
| Austria |
Ohura Precious Metal Industry Co., Ltd. |
| Gold |
| Compliant |
| Japan |
OJSC Novosibirsk Refinery |
| Gold |
| Compliant |
| Russia |
PAMP SA |
| Gold |
| Compliant |
| Switzerland |
Prioksky Plant of Non-Ferrous Metals |
| Gold |
| Compliant |
| Russia |
PT Aneka Tambang (Persero) Tbk |
| Gold |
| Compliant |
| Indonesia |
Rand Refinery (Pty) Ltd. |
| Gold |
| Compliant |
| South Africa |
Republic Metals Corporation |
| Gold |
| Compliant |
| United States |
Royal Canadian Mint |
| Gold |
| Compliant |
| Canada |
Samduck Precious Metals |
| Gold |
| Active |
| South Korea |
Saxonia Edelmetalle GmbH |
| Gold |
| Active |
| Germany |
Schöne Edelmetaal B.V. |
| Gold |
| Compliant |
| Netherlands |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold |
| Compliant |
| China |
Sichuan Tianze Precious Metals Co., Ltd. |
| Gold |
| Compliant |
| China |
Singway Technology Co., Ltd. |
| Gold |
| Compliant |
| Taiwan |
SOE Shyolkovsky Factory of Secondary Precious |
| Gold |
| Compliant |
| Russia |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or |
Metals |
|
|
|
|
|
|
Solar Applied Materials Technology Corp. |
| Gold |
| Compliant |
| Taiwan |
Sumitomo Metal Mining Co., Ltd. |
| Gold |
| Compliant |
| Japan |
T.C.A S.p.A |
| Gold |
| Compliant |
| Italy |
Tanaka Kikinzoku Kogyo K.K. |
| Gold |
| Compliant |
| Japan |
The Refinery of Shandong Gold Mining Co., Ltd. |
| Gold |
| Compliant |
| China |
Tokuriki Honten Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Torecom |
| Gold |
| Active |
| South Korea |
Umicore Brasil Ltda. |
| Gold |
| Compliant |
| Brazil |
Umicore Precious Metals Thailand |
| Gold |
| Compliant |
| Thailand |
Umicore SA Business Unit Precious Metals Refining |
| Gold |
| Compliant |
| Belgium |
United Precious Metal Refining, Inc. |
| Gold |
| Compliant |
| United States |
Valcambi SA |
| Gold |
| Compliant |
| Switzerland |
Western Australian Mint trading as The Perth Mint |
| Gold |
| Compliant |
| Australia |
Yamamoto Precious Metal Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Yokohama Metal Co., Ltd. |
| Gold |
| Compliant |
| Japan |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Gold |
| Compliant |
| China |
Zijin Mining Group Co., Ltd. Gold Refinery |
| Gold |
| Compliant |
| China |
Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Conghua Tantalum and Niobium Smeltry |
| Tantalum |
| Compliant |
| China |
D Block Metals, LLC |
| Tantalum |
| Compliant |
| United States |
Duoluoshan |
| Tantalum |
| Compliant |
| China |
Exotech Inc. |
| Tantalum |
| Compliant |
| United States |
F&X Electro-Materials Ltd. |
| Tantalum |
| Compliant |
| China |
FIR Metals & Resource Ltd. |
| Tantalum |
| Compliant |
| China |
Global Advanced Metals Aizu |
| Tantalum |
| Compliant |
| Japan |
Global Advanced Metals Boyertown |
| Tantalum |
| Compliant |
| United States |
Guangdong Zhiyuan New Material Co., Ltd. |
| Tantalum |
| Compliant |
| China |
H.C. Starck Co., Ltd. |
| Tantalum |
| Compliant |
| Thailand |
H.C. Starck GmbH Goslar |
| Tantalum |
| Compliant |
| Germany |
H.C. Starck GmbH Laufenburg |
| Tantalum |
| Compliant |
| Germany |
H.C. Starck Hermsdorf GmbH |
| Tantalum |
| Compliant |
| Germany |
H.C. Starck Inc. |
| Tantalum |
| Compliant |
| United States |
H.C. Starck Ltd. |
| Tantalum |
| Compliant |
| Japan |
H.C. Starck Smelting GmbH & Co.KG |
| Tantalum |
| Compliant |
| Germany |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Hi-Temp Specialty Metals, Inc. |
| Tantalum |
| Compliant |
| United States |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd |
| Tantalum |
| Compliant |
| China |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Jiujiang Tanbre Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum |
| Compliant |
| China |
KEMET Blue Metals |
| Tantalum |
| Compliant |
| Mexico |
Kemet Blue Powder |
| Tantalum |
| Compliant |
| United States |
King-Tan Tantalum Industry Ltd. |
| Tantalum |
| Compliant |
| China |
LSM Brasil S.A. |
| Tantalum |
| Compliant |
| Brazil |
Metallurgical Products India Pvt., Ltd. |
| Tantalum |
| Compliant |
| India |
Mitsui Mining & Smelting |
| Tantalum |
| Compliant |
| Japan |
Molycorp Silmet A.S. |
| Tantalum |
| Compliant |
| Estonia |
Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Plansee SE Liezen |
| Tantalum |
| Compliant |
| Austria |
Plansee SE Reutte |
| Tantalum |
| Compliant |
| Austria |
QuantumClean |
| Tantalum |
| Compliant |
| United States |
Resind Indústria e Comércio Ltda. |
| Tantalum |
| Compliant |
| Brazil |
RFH Tantalum Smeltry Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Solikamsk Magnesium Works OAO |
| Tantalum |
| Compliant |
| Russia |
Taki Chemicals |
| Tantalum |
| Compliant |
| Japan |
Telex Metals |
| Tantalum |
| Compliant |
| United States |
Tranzact, Inc. |
| Tantalum |
| Compliant |
| United States |
Ulba Metallurgical Plant JSC |
| Tantalum |
| Compliant |
| Kazakhstan |
XinXing Haorong Electronic Material Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Yichun Jin Yang Rare Metal Co., Ltd. |
| Tantalum |
| Compliant |
| China |
Zhuzhou Cemented Carbide |
| Tantalum |
| Compliant |
| China |
Alpha |
| Tin |
| Compliant |
| United States |
An Vinh Joint Stock Mineral Processing Company |
| Tin |
| Active |
| Vietnam |
China Tin Group Co., Ltd. |
| Tin |
| Compliant |
| China |
CV Ayi Jaya |
| Tin |
| Compliant |
| Indonesia |
CV Gita Pesona |
| Tin |
| Compliant |
| Indonesia |
CV Serumpun Sebalai |
| Tin |
| Compliant |
| Indonesia |
CV United Smelting |
| Tin |
| Compliant |
| Indonesia |
CV Venus Inti Perkasa |
| Tin |
| Compliant |
| Indonesia |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or |
Dowa |
| Tin |
| Compliant |
| Japan |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin |
| Active |
| Vietnam |
Elmet S.L.U. (Metallo Group) |
| Tin |
| Compliant |
| Spain |
EM Vinto |
| Tin |
| Compliant |
| Bolivia |
Fenix Metals |
| Tin |
| Compliant |
| Poland |
Gejiu Kai Meng Industry and Trade LLC |
| Tin |
| Active |
| China |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin |
| Compliant |
| China |
Geiju Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin |
| Active |
| China |
Jiangxi Ketai Advanced Material Co., Ltd. |
| Tin |
| Compliant |
| China |
Magnu’s Minerais Metais e Ligas Ltda. |
| Tin |
| Compliant |
| Brazil |
Malaysia Smelting Corporation (MSC) |
| Tin |
| Compliant |
| Malaysia |
Melt Metais e Ligas S/A |
| Tin |
| Compliant |
| Brazil |
Metallic Resources, Inc. |
| Tin |
| Compliant |
| United States |
Metallo-Chimique N.V. |
| Tin |
| Compliant |
| Belgium |
Minsur |
| Tin |
| Compliant |
| Peru |
Mitsubishi Materials Corporation |
| Tin |
| Compliant |
| Japan |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin |
| Active |
| Vietnam |
O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin |
| Compliant |
| Thailand |
O.M. Manufacturing Philippines, Inc. |
| Tin |
| Compliant |
| Philippines |
Operaciones Metalurgical S.A. |
| Tin |
| Compliant |
| Bolivia |
Phoenix Metal Ltd |
| Tin |
| Active |
| Rwanda |
PT Aries Kencana Sejahtera |
| Tin |
| Compliant |
| Indonesia |
PT Artha Cipta Langgeng |
| Tin |
| Compliant |
| Indonesia |
PT ATD Makmur Mandiri Jaya |
| Tin |
| Compliant |
| Indonesia |
PT Babel Inti Perkasa |
| Tin |
| Compliant |
| Indonesia |
PT Bangka Prima Tin |
| Tin |
| Compliant |
| Indonesia |
PT Bangka Tin Industry |
| Tin |
| Compliant |
| Indonesia |
PT Belitung Industri Sejahtera |
| Tin |
| Compliant |
| Indonesia |
PT BilliTin Makmur Lestari |
| Tin |
| Compliant |
| Indonesia |
PT Bukit Timah |
| Tin |
| Compliant |
| Indonesia |
PT Cipta Persada Mulia |
| Tin |
| Compliant |
| Indonesia |
PT DS Jaya Abadi |
| Tin |
| Compliant |
| Indonesia |
PT Eunindo Usaha Mandiri |
| Tin |
| Compliant |
| Indonesia |
PT Inti Stania Prima |
| Tin |
| Compliant |
| Indonesia |
PT Justindo |
| Tin |
| Compliant |
| Indonesia |
PT Karimun Mining |
| Tin |
| Active |
| Indonesia |
PT Mitra Stania Prima |
| Tin |
| Compliant |
| Indonesia |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or Refiner |
PT Panca Mega Persada |
| Tin |
| Compliant |
| Indonesia |
PT Prima Timah Utama |
| Tin |
| Compliant |
| Indonesia |
PT Refined Bangka Tin |
| Tin |
| Compliant |
| Indonesia |
PT Sariwiguna Binasentosa |
| Tin |
| Compliant |
| Indonesia |
PT Stanindo Inti Perkasa |
| Tin |
| Compliant |
| Indonesia |
PT Sumber Jaya Indah |
| Tin |
| Compliant |
| Indonesia |
PT Timah (Persero) Tbk Kundur |
| Tin |
| Compliant |
| Indonesia |
PT Timah (Persero) Tbk Mentok |
| Tin |
| Compliant |
| Indonesia |
PT Tinindo Inter Nusa |
| Tin |
| Compliant |
| Indonesia |
PT Tommy Utama |
| Tin |
| Compliant |
| Indonesia |
PT WAHANA PERKIT JAYA |
| Tin |
| Compliant |
| Indonesia |
Resind Indústria e Comércio Ltda. |
| Tin |
| Compliant |
| Brazil |
Rui Da Hung |
| Tin |
| Compliant |
| Taiwan |
Soft Metais Ltda. |
| Tin |
| Compliant |
| Brazil |
Thaisarco |
| Tin |
| Compliant |
| Thailand |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin |
| Active |
| Vietnam |
VQB Mineral and Trading Group JSC |
| Tin |
| Compliant |
| Vietnam |
White Solder Metalurgia e Mineraçăo Ltda. |
| Tin |
| Compliant |
| Brazil |
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
| Tin |
| Active |
| China |
Yunnan Tin Group (Holding) Company Limited |
| Tin |
| Compliant |
| China |
A.L.M.T. TUNGSTEN Corp. |
| Tungsten |
| Compliant |
| Japan |
Asia Tungsten Products Vietnam Ltd. |
| Tungsten |
| Compliant |
| Vietnam |
Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Dayu Jincheng Tungsten Industry Co., Ltd. |
| Tungsten |
| Category A |
| China |
Dayu Weiliang Tungsten Co., Ltd. |
| Tungsten |
| Category A |
| China |
Fujian Jinxin Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| Tungsten |
| Category A |
| China |
Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Ganzhou Yatai Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Global Tungsten & Powders Corp. |
| Tungsten |
| Compliant |
| United States |
Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
H.C. Starck GmbH |
| Tungsten |
| Compliant |
| Germany |
H.C. Starck Smelting GmbH & Co.KG |
| Tungsten |
| Compliant |
| Germany |
Hunan Chenzhou Mining Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| Tungsten |
| Compliant |
| China |
Smelter or Refiner Name |
| Mineral |
| Smelter or |
| Smelter or Refiner |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Hydrometallurg, JSC |
| Tungsten |
| Compliant |
| Russia |
Japan New Metals Co., Ltd. |
| Tungsten |
| Compliant |
| Japan |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten |
| Active |
| China |
Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten |
| Active |
| China |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten |
| Active |
| China |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten |
| Active |
| China |
Kennametal Fallon |
| Tungsten |
| Active |
| United States |
Kennametal Huntsville |
| Tungsten |
| Compliant |
| United States |
Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Niagara Refining LLC |
| Tungsten |
| Compliant |
| United States |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| Tungsten |
| Compliant |
| Vietnam |
Pobedit, JSC |
| Tungsten |
| Category A |
| Russia |
Tejing (Vietnam) Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| Vietnam |
Vietnam Youngsun Tungsten Industry Co., Ltd. |
| Tungsten |
| Compliant |
| Vietnam |
Xiamen Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| Tungsten |
| Compliant |
| China |
The following notes apply to Annex I above:
(1) “Compliant” means that a smelter or refiner was compliant with the applicable Conflict-Free Smelter Program (“CFSP”) assessment protocols.
(2) “Active” means that the smelter or refiner has submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or has agreed to complete a CFSP compliance audit conducted by an independent third party auditor.
(3) “Category A” means that the smelter has committed to complete a CFSP validation within two years of membership issuance by the Tungsten Industry — Council Minerals Council.
(4) The designations of Compliant, Active and Category A reflected in the table are based solely on information made publicly available by the CFSI, without independent verification by us.
ANNEX II
List of Verified Facilities Not Otherwise Listed as Compliant, Active or Category A
Smelter or Refiner Name |
| Mineral |
| Smelter or Refiner |
Advanced Chemical Company |
| Gold |
| United States |
Aktyubinsk Copper Company TOO |
| Gold |
| Kazakhstan |
Alpha |
| Gold |
| United States |
AngloGold Ashanti Córrego do Sítio Mineração |
| Gold |
| Brazil |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold |
| Turkey |
Bauer Walser AG |
| Gold |
| Germany |
Caridad |
| Gold |
| Mexico |
China Nonferrous Metal Mining (Group) Co., Ltd. |
| Gold |
| China |
Chugai Mining |
| Gold |
| Japan |
Codelco |
| Gold |
| Chile |
Daye Non-Ferrous Metals Mining Ltd. |
| Gold |
| China |
Eldorado Gold Corporation |
| Gold |
| Canada |
EM Vinto |
| Gold |
| Bolivia |
Gansu Seemine Material Hi-Tech Co Ltd |
| Gold |
| China |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Gold |
| China |
Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold |
| China |
Guangdong Jinding Gold Limited |
| Gold |
| China |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold |
| China |
Heraeus Materials Technology GmbH & Co. KG |
| Gold |
| Singapore |
Hunan Chenzhou Mining Co., Ltd. |
| Gold |
| China |
Hwasung CJ Co. Ltd |
| Gold |
| South Korea |
Inner Mongolia QianKun Gold and Refinery Share Company Limited |
| Gold |
| China |
Jinlong Copper Co., Ltd. |
| Gold |
| China |
Kazakhmys plc |
| Gold |
| Kazakhstan |
Korea Metal Co. Ltd |
| Gold |
| South Korea |
Kyrgyzaltyn JSC |
| Gold |
| Kyrgyzstan |
L’ azurde Company For Jewelry |
| Gold |
| Saudi Arabia |
Lingbao Gold Company Ltd. |
| Gold |
| China |
Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
| Gold |
| China |
Luo yang Zijin Yinhui Metal Smelt Co Ltd |
| Gold |
| China |
Metallic Resources, Inc. |
| Gold |
| United States |
Metallo-Chimique N.V. |
| Gold |
| Belgium |
Metalor USA Refining Corporation |
| Gold |
| United States |
Morris and Watson |
| Gold |
| New Zealand |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| Gold |
| Russia |
Smelter or Refiner Name |
| Mineral |
| Smelter or Refiner |
OJSC Kolyma Refinery |
| Gold |
| Russia |
Penglai Penggang Gold Industry Co Ltd |
| Gold |
| China |
PT Timah (Persero) Tbk Mentok |
| Gold |
| Indonesia |
Sabin Metal Corp. |
| Gold |
| United States |
SAMWON METALS Corp. |
| Gold |
| South Korea |
SEMPSA Joyería Platería SA |
| Gold |
| Spain |
Senju Metal Industry Co., Ltd. |
| Gold |
| Bolivia |
Shandong Gold Mining Co., Ltd. |
| Gold |
| China |
So Accurate Group, Inc. |
| Gold |
| United States |
Sumisho Material Corp. |
| Gold |
| Japan |
Technic Inc. |
| Gold |
| United States |
Thaisarco |
| Gold |
| Thailand |
TongLing Nonferrous Metals Group Holdings Co., Ltd. |
| Gold |
| China |
WIELAND Edelmetalle GmbH |
| Gold |
| Germany |
Yantai Guodasafina High-tech Environmental Refinery CO., Ltd. |
| Gold |
| China |
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
| Gold |
| China |
Yunnan Copper Industry Co Ltd |
| Gold |
| China |
Yunnan Tin Group (Holding) Company Limited |
| Gold |
| China |
Zhe Jiang Guang Yuan Noble Metal Smelting Factory |
| Gold |
| China |
AMG Advanced Metallurgical Group |
| Tantalum |
| United States |
Gannon & Scott |
| Tantalum |
| United States |
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
| Tantalum |
| China |
H.C. Starck GmbH |
| Tantalum |
| Germany |
JX Nippon Mining & Metals Co., Ltd. |
| Tantalum |
| Japan |
Materion |
| Tantalum |
| United States |
Nippon Mining & Metals Co. Ltd. |
| Tantalum |
| Japan |
POSCO |
| Tantalum |
| South Korea |
Asahi Pretec Corporation |
| Tin |
| Japan |
Aurubis AG |
| Tin |
| Germany |
Best Metais e Soldas SA |
| Tin |
| Brazil |
Caridad |
| Tin |
| Mexico |
CNMC (Guangxi) PGMA Co. Ltd. |
| Tin |
| China |
CSC Pure Technologies |
| Tin |
| Russia |
CV Duta Putra Bangka |
| Tin |
| Indonesia |
CV Prima Timah Utama |
| Tin |
| Indonesia |
Smelter or Refiner Name |
| Mineral |
| Smelter or Refiner |
Electroloy Metal Pte |
| Tin |
| Singapore |
Estanho de Rondônia S.A. |
| Tin |
| Brazil |
Feinhutte Halsbrucke GmbH |
| Tin |
| Germany |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tin |
| China |
Gejiu Zi-Li |
| Tin |
| China |
Heraeus Ltd. Hong Kong |
| Tin |
| China |
Heraeus Materials Technology GmbH & Co. KG |
| Tin |
| Singapore |
Heraeus Precious Metals GmbH & Co. KG |
| Tin |
| Germany |
Huichang Jinshunda Tin Co. Ltd |
| Tin |
| China |
Hyundai-Steel |
| Tin |
| South Korea |
Jean Goldschmidt International SA |
| Tin |
| Belgium |
Kennametal Huntsville |
| Tin |
| United States |
Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
| Tin |
| China |
Linwu Xianggui Smelter Co |
| Tin |
| China |
LS-NIKKO Copper Inc. |
| Tin |
| South Korea |
Materials Eco-Refining CO.,LTD |
| Tin |
| Japan |
Metahub Industries Sdn. Bhd. |
| Tin |
| Malaysia |
Metalor USA Refining Corporation |
| Tin |
| United States |
Mineração Taboca S.A. |
| Tin |
| Brazil |
Nankang Nanshan Tin Co., Ltd. |
| Tin |
| China |
Novosibirsk Integrated Tin Works |
| Tin |
| Russia |
OJSC Novosibirsk Refinery |
| Tin |
| Russia |
PBT |
| Tin |
| France |
POSCO |
| Tin |
| South Korea |
PT Alam Lestari Kencana |
| Tin |
| Indonesia |
PT Aneka Tambang (Persero) Tbk |
| Tin |
| Indonesia |
PT Bangka Kudai Tin |
| Tin |
| Indonesia |
PT Bangka Timah Utama Sejahtera |
| Tin |
| Indonesia |
PT Fang Di MulTindo |
| Tin |
| Indonesia |
PT Pelat Timah Nusantara Tbk |
| Tin |
| Indonesia |
PT Seirama Tin investment |
| Tin |
| Indonesia |
PT Tirus Putra Mandiri |
| Tin |
| Indonesia |
Pure Technology |
| Tin |
| Russia |
Senju Metal Industry Co., Ltd. |
| Tin |
| Bolivia |
SGS |
| Tin |
| Bolivia |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Tin |
| China |
Umicore SA Business Unit Precious Metals Refining |
| Tin |
| Belgium |
Vale Inco, Ltd. |
| Tin |
| Canada |
Smelter or Refiner Name |
| Mineral |
| Smelter or Refiner |
Xianghualing Tin Co., Ltd. |
| Tin |
| China |
Yokohama Metal Co., Ltd. |
| Tin |
| Japan |
Air Products |
| Tungsten |
| United States |
Alpha |
| Tungsten |
| United States |
Ganxian Shirui New Material Co., Ltd. |
| Tungsten |
| China |
Golden Egret Special Alloy Co. Ltd |
| Tungsten |
| China |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin |
| Tungsten |
| China |
Izawa Metal Co., Ltd |
| Tungsten |
| Japan |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| Tungsten |
| China |
JX Nippon Mining & Metals Co., Ltd. |
| Tungsten |
| Japan |
Materion |
| Tungsten |
| United States |
Metallo-Chimique N.V. |
| Tungsten |
| Belgium |
Mitsubishi Materials Corporation |
| Tungsten |
| Japan |
Mitsui Mining & Smelting |
| Tungsten |
| Japan |
Ningxia Orient Tantalum Industry Co., Ltd. |
| Tungsten |
| China |
North American Tungsten |
| Tungsten |
| Canada |
Sanher Tungsten Vietnam Co., Ltd. |
| Tungsten |
| Vietnam |
Solar Applied Materials Technology Corp. |
| Tungsten |
| Taiwan |
Sumitomo Metal Mining Co., Ltd. |
| Tungsten |
| Japan |
Voss Metals Company, Inc. |
| Tungsten |
| United States |
Xiamen Honglu Tungsten Molybdenum Industry Co.Ltd |
| Tungsten |
| China |
Zhuzhou Cemented Carbide |
| Tungsten |
| China |
