Exhibit 1.01
INTERNATIONAL BUSINESS MACHINES CORPORATION
Conflict Minerals Report
For the reporting period from January 1, 2014 to December 31, 2014
This Conflict Minerals Report (the “Report”) of International Business Machines Corporation (“IBM”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the period from January 1, 2014 to December 31, 2014 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, Conflict Minerals are necessary to the functionality or production of certain products that IBM’s operations manufacture or contract to manufacture.
Design of IBM’s Conflict Minerals Program
IBM’s Conflict Minerals Program is run by a full-time, dedicated team of experienced supply chain professionals within IBM’s Global Procurement organization. The Conflict Minerals Program team members report to IBM’s Vice President and Chief Procurement Officer, who has responsibility for IBM’s external supply base for IBM’s products. IBM’s Conflict Minerals team gathers information on the sources of Conflict Minerals in IBM’s supply chain and drives suppliers to source Conflict Minerals from conflict-free sources.
Description of IBM’s Products
This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by IBM; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are referred to in this Report collectively as the “Covered Products,” include the following product categories that were manufactured or contracted to be manufactured by IBM’s Systems and Technology Group in 2014:
(1) Systems: a range of general purpose and integrated systems designed and optimized for specific business, public and scientific computing needs. These systems—System z, Power Systems and System x—are typically the core technology in data centers that provide required infrastructure for business and institutions.
(2) Storage: data storage products and solutions that allow clients to retain and manage rapidly growing, complex volumes of digital information. These solutions address critical client requirements for information retention and archiving, security, compliance and storage optimization, including data deduplication, availability and virtualization. The portfolio consists of a broad range of disk and tape storage systems and software, including Flash storage and solutions.
(3) Microelectronics: semiconductor design and manufacturing primarily for use in IBM’s systems and storage products, as well as delivering semiconductors and related services to external clients.
Reasonable Country of Origin Inquiry
IBM conducted a good faith reasonable country of origin inquiry (RCOI) regarding the Conflict Minerals. This good faith RCOI was designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources.
IBM’s Conflict Minerals Due Diligence Framework
IBM’s due diligence measures for Conflict Minerals conform to the framework set forth in the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas, including the related supplements pertaining to downstream companies.
Since IBM is not a direct purchaser of ore or unrefined minerals, it is several tiers “downstream” from the smelters or refiners (SORs) of such minerals. SORs are at the point in the supply chain where ores, concentrates and/or scrap material are converted to a metal. IBM, like many downstream companies, does not have direct business relationships with SORs or visibility to the extraction and movement of Conflict Minerals between SORs and upstream entities. This position increases the difficulty of determining the origin of the Conflict Minerals in the Covered Products and, as a result, IBM relies on industry processes and information from its suppliers.
Description of Due Diligence Performed
IBM’s due diligence reflects the principles of IBM’s Conflict Minerals Standard and IBM’s position in the supply chain as a downstream company (as defined by OCED guidance). IBM’s RCOI and due diligence process, including its efforts to determine the mine or location of origin, leveraged multiple industry processes and tools, and centered on the Conflict-Free Sourcing Initiative (CFSI) Conflict-Free Smelter Program (CFSP), an initiative in which an independent
third party audits SOR procurement and tolling activities and determines if the SOR demonstrated that all of the Conflict Minerals they processed originated from “conflict-free” sources. The CFSP aims to enable companies to source conflict-free minerals by evaluating the SOR sites’ policies and implementation, and performing a material analysis to demonstrate that the sources of the Conflict Minerals procured by the SOR site are conflict-free.
Below is a detailed description of IBM’s due diligence performed for the reporting period as it corresponds to the OECD framework.
1. Maintained a strong company management system.
· Enhanced the IBM Conflict Minerals team within IBM’s Global Procurement organization that has responsibility for implementing IBM’s Conflict Minerals Program.
· Continued to host IBM’s Conflict Minerals Standard on IBM’s Conflict Minerals-dedicated public website, www.ibm.com/conflictminerals.
· Conveyed Conflict Minerals information to in-scope direct suppliers from the IBM Global Procurement and CFSI websites.
· Delivered Conflict Minerals education to suppliers attending IBM Asia Pacific Product Environmental Compliance Seminar in March 2014.
· Provided an online grievance mechanism for internal and external parties to confidentially report concerns regarding Conflict Minerals to IBM’s Ombudsman.
· Retained records related to Conflict Minerals in conformance with IBM’s records retention policy.
· Created a monthly management review process by IBM Global Procurement, IBM’s Legal Department, and other IBM business units to review status, progress, and any areas of concern.
· Deployed contractual language requiring suppliers’ products to contain conflict-free sources for any Conflict Minerals.
2. Identified and assessed risks in the supply chain.
· Requested IBM’s in-scope direct suppliers to identify SORs and related Conflict Minerals information through the use of the CFSI Conflict Minerals Reporting Template (CMRT).
· Gathered CMRTs from in-scope direct suppliers and reviewed the information provided in the CMRTs against IBM’s validation guidelines for reasonableness of process, accuracy and level of completion.
· Reviewed the in-scope direct suppliers’ CMRTs for completeness and accuracy and contacted those suppliers for corrections or clarifications, when needed.
· Escalated suppliers to IBM Global Procurement when CMRTs were delinquent or incomplete.
· Assessed RCOI information derived from the CFSP and third-party research to ascertain whether any Conflict Minerals in the Covered Products may have originated in the Covered Countries.
· Compared SORs identified by the in-scope direct suppliers against the CFSP list of valid SORs to determine the conflict-free status of the SORs in IBM’s supply chain.
· Requested updated CMRTs from in-scope direct suppliers.
· Engaged a third-party consultant to research SORs sourcing Conflict Minerals from Covered Countries and worked with CFSI to gather additional facts regarding these SORs’ sources and to help drive the SORs into the CFSP.
3. Designed and implemented a strategy to respond to identified risks.
· Reported to IBM’s Global Procurement management on progress of CMRT collection and progress of driving identified SORs toward CFSP listing.
· Formed action plans to manage potential areas of concern and execute solutions on an on-going basis.
· Monitored Conflict Minerals developments and SOR status through participation in CFSI.
· Participated in four SOR site visits to Indonesia in conjunction with CFSI members to encourage participation in CFSP.
· Contributed funds to, and participated in, the 2014 China Gold Conference in Beijing, China and established channels for smelter outreach and future participation in CFSP.
· Identified non-CFSP listed SORs that may be sourcing from the Covered Countries, and worked to gain their participation in CFSP; contacted other select SORs without a conflict-free designation to encourage their participation in CFSP or other independent third-party audit program.
4. Supported the implementation of independent third-party audits of supply chain due diligence.
· Supported CFSI tools development and initiatives through participation in CFSI workgroups.
· Worked in concert with CFSI to enhance SOR outreach to drive CFSP participation.
· Provided funding for CFSP Initial Audit Fund, a voluntary program managed by the CFSI designed to encourage CFSP-eligible smelters to participate.
5. Reported on supply chain due diligence.
· Pursuant to the Rule, filed Form SD and IBM’s 2013 Conflict Minerals Report (CMR).
· Published the 2013 CMR on IBM’s Conflict Minerals-dedicated public website, www.ibm.com/conflictminerals.
· Included Conflict Minerals information in IBM’s annual Corporate Responsibility Report.
Reporting Period Determination and Findings
After exercising the due diligence described above, IBM was unable to determine whether or not all of the Covered Products qualify as “DRC conflict free,” as defined under the Rule.
Based on the information that was provided by IBM’s in-scope direct suppliers and otherwise obtained through the due diligence process described herein, IBM believes that the facilities that may be used to process the Conflict Minerals contained in the Covered Products are listed in Appendix A. Furthermore, IBM has reasonably determined from information provided by the CFSP and otherwise obtained through the due diligence that countries of origin of the Conflict Minerals from the listed SORs are listed in Appendix B.
For calendar year 2014, IBM requested CMRTs from 324 in-scope direct suppliers and at year-end, we received responses from 95% of those suppliers (the remaining 5% of CMRTs were in process). The CMRTs yielded the information included in this Report and its appendixes. To provide a measure of overall progress of the program the following charts illustrate the change in the percentage of SORs in the upstream IBM supply chain assessed as conflict free for Conflict Minerals (comparing 2013 and 2014 SOR CFSP listing).
Conflict |
| 2013 Assessed |
| 2013 Assessed |
| 2014 Assessed |
| 2014 Assessed |
|
Tantalum |
| 21 of 24 |
| 88 | % | 43 of 45 |
| 96 | % |
Tin |
| 7 of 58 |
| 12 | % | 22 of 68 |
| 32 | % |
Tungsten |
| 0 of 21 |
| 0 | % | 9 of 39 |
| 23 | % |
Gold |
| 30 of 86 |
| 35 | % | 56 of 112 |
| 50 | % |
Total |
| 58 of 189 |
| 31 | % | 130 of 264 |
| 49 | % |
IBM’s Next Steps to Mitigate Conflict Minerals Risk
IBM expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups in the Covered Countries:
· By participating in the CFSI, contribute to the continued development of collaborative tools and resources for companies to use to help assess their supply chains and avoid inclusion of Conflict Minerals in the extended supply chain.
· Remain aware of developments in Conflict Minerals due diligence processes by participation in the CFSI and apply that knowledge to IBM’s Conflict Minerals risk assessment and mitigation actions.
· Work in concert with CFSI members and in-scope direct suppliers to contact SORs to better understand their sourcing circumstances and gain their commitment to a CFSP assessment or another recognized validation scheme.
· Seek resolution for the identified SORs in IBM’s supply chain that are not currently on CFSI’s list of recognized SORs and drive additional identified SORs in IBM’s supply chain into the CFSP.
· Improve CMRT response completeness from in-scope direct suppliers through IBM’s review and feedback to suppliers using the most current smelter information.
· Drive in-scope direct suppliers to provide product-specific CMRTs instead of company-level CMRTs, as company-level CMRTs may include SORs not used in the supply chain
for Covered Products; use of product-specific CMRTs by suppliers will enable IBM to have a more precise list of SORs used in the Covered Products.
· Continue to influence upstream sourcing practices to require the usage of CFSP-compliant SORs, including the use of conflict-free contract clauses.
IBM’s Support of CFSI
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which IBM’s due diligence is based, we support an industry initiative that audits the due diligence activities of SORs. That industry initiative is the EICC and GeSI’s Conflict-Free Sourcing Initiative. The data on which we relied for certain statements in this Report was obtained through our membership in the CFSI, using the RCOI report for IBM’s member ID: MIBM.
Appendix A
Smelters or Refiners (SORs) that may be used to process the Conflict Minerals contained in the Covered Products.
SOR Status: “CFSP Listed” indicates SOR is publically listed on the CFSP web site and considered conflict-free as of the date indicated based on the criteria used by CFSI to assess SORs. “Unknown” indicates SOR is either in process for CFSP assessment or has not started the process as of the date indicated.
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| China |
| CFSP Listed |
Tantalum |
| D Block Metals, LLC |
| United States |
| CFSP Listed |
Tantalum |
| Duoluoshan |
| China |
| CFSP Listed |
Tantalum |
| Exotech Inc. |
| United States |
| CFSP Listed |
Tantalum |
| F&X Electro-Materials Ltd. |
| China |
| CFSP Listed |
Tantalum |
| FIR Metals & Resource., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Global Advanced Metals Aizu |
| Japan |
| CFSP Listed |
Tantalum |
| Global Advanced Metals Boyertown |
| United States |
| CFSP Listed |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
| China |
| CFSP Listed |
Tantalum |
| H.C. Starck Co., Ltd. |
| Thailand |
| CFSP Listed |
Tantalum |
| H.C. Starck GmbH Goslar |
| Germany |
| CFSP Listed |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| Germany |
| CFSP Listed |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| Germany |
| CFSP Listed |
Tantalum |
| H.C. Starck Inc. |
| United States |
| CFSP Listed |
Tantalum |
| H.C. Starck Ltd. |
| Japan |
| CFSP Listed |
Tantalum |
| H.C. Starck Smelting GmbH & Co.KG |
| Germany |
| CFSP Listed |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| United States |
| CFSP Listed |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., LTD |
| China |
| CFSP Listed |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co, Ltd |
| China |
| CFSP Listed |
Tantalum |
| KEMET Blue Metals |
| Mexico |
| CFSP Listed |
Tantalum |
| KEMET Blue Powder |
| United States |
| CFSP Listed |
Tantalum |
| King-Tan Tantalum Industry Ltd |
| China |
| Unknown |
Tantalum |
| LSM Brasil S.A. |
| Brazil |
| CFSP Listed |
Tantalum |
| Metallurgical Products India (Pvt.) Ltd. |
| India |
| CFSP Listed |
Tantalum |
| Mineração Taboca S.A. |
| Brazil |
| CFSP Listed |
Tantalum |
| Mitsui Mining & Smelting |
| Japan |
| CFSP Listed |
Tantalum |
| Molycorp Silmet A.S. |
| Estonia |
| CFSP Listed |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| China |
| CFSP Listed |
Tantalum |
| Phoenix Metal Ltd |
| Rwanda |
| Unknown |
Tantalum |
| Plansee SE Liezen |
| Austria |
| CFSP Listed |
Tantalum |
| Plansee SE Reutte |
| Austria |
| CFSP Listed |
Tantalum |
| QuantumClean |
| United States |
| CFSP Listed |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd |
| China |
| CFSP Listed |
Tantalum |
| Solikamsk Magnesium Works OAO |
| Russian Federation |
| CFSP Listed |
Tantalum |
| Taki Chemicals |
| Japan |
| CFSP Listed |
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status |
Tantalum |
| Telex |
| United States |
| CFSP Listed |
Tantalum |
| Ulba |
| Kazakhstan |
| CFSP Listed |
Tantalum |
| XinXing HaoRong Electronic Material CO.,LTD |
| China |
| CFSP Listed |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd |
| China |
| CFSP Listed |
Tantalum |
| Zhuzhou Cement Carbide |
| China |
| CFSP Listed |
Tin |
| Alpha |
| United States |
| CFSP Listed |
Tin |
| China Tin Group Co., Ltd. |
| China |
| Unknown |
Tin |
| CNMC (Guangxi) PGMA Co. Ltd. |
| China |
| Unknown |
Tin |
| Cooper Santa |
| Brazil |
| Unknown |
Tin |
| CV Gita Pesona |
| Indonesia |
| Unknown |
Tin |
| CV Nurjanah |
| Indonesia |
| Unknown |
Tin |
| CV Serumpun Sebalai |
| Indonesia |
| Unknown |
Tin |
| CV United Smelting |
| Indonesia |
| CFSP Listed |
Tin |
| CV Venus Inti Perkasa |
| Indonesia |
| Unknown |
Tin |
| Dowa |
| Japan |
| CFSP Listed |
Tin |
| EM Vinto |
| Bolivia |
| Unknown |
Tin |
| Estanho de Rondônia S.A. |
| Brazil |
| Unknown |
Tin |
| Fenix Metals |
| Poland |
| Unknown |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| China |
| Unknown |
Tin |
| Gejiu Non-Ferrous Metal Processing Co. Ltd. |
| China |
| CFSP Listed |
Tin |
| Gejiu Zi-Li |
| China |
| Unknown |
Tin |
| Huichang Jinshunda Tin Co. Ltd |
| China |
| Unknown |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| China |
| Unknown |
Tin |
| Linwu Xianggui Smelter Co |
| China |
| Unknown |
Tin |
| Magnu’s Minerais Metais e Ligas LTDA |
| Brazil |
| CFSP Listed |
Tin |
| Malaysia Smelting Corporation (MSC) |
| Malaysia |
| CFSP Listed |
Tin |
| Melt Metais e Ligas S/A |
| Brazil |
| Unknown |
Tin |
| Metallo Chimique |
| Belgium |
| Unknown |
Tin |
| Mineração Taboca S.A. |
| Brazil |
| CFSP Listed |
Tin |
| Minsur |
| Peru |
| CFSP Listed |
Tin |
| Mitsubishi Materials Corporation |
| Japan |
| CFSP Listed |
Tin |
| Nankang Nanshan Tin Manufactory Co., Ltd |
| China |
| Unknown |
Tin |
| Novosibirsk Integrated Tin Works |
| Russian Federation |
| Unknown |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| Thailand |
| Unknown |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| Philippines |
| Unknown |
Tin |
| OMSA |
| Bolivia |
| CFSP Listed |
Tin |
| PT Alam Lestari Kencana |
| Indonesia |
| Unknown |
Tin |
| PT Artha Cipta Langgeng |
| Indonesia |
| Unknown |
Tin |
| PT ATD Makmur Mandiri Jaya |
| Indonesia |
| CFSP Listed |
Tin |
| PT Babel Inti Perkasa |
| Indonesia |
| CFSP Listed |
Tin |
| PT Bangka Kudai Tin |
| Indonesia |
| Unknown |
Tin |
| PT Bangka Putra Karya |
| Indonesia |
| Unknown |
Tin |
| PT Bangka Timah Utama Sejahtera |
| Indonesia |
| Unknown |
Tin |
| PT Bangka Tin Industry |
| Indonesia |
| CFSP Listed |
Tin |
| PT Belitung Industri Sejahtera |
| Indonesia |
| Unknown |
Tin |
| PT BilliTin Makmur Lestari |
| Indonesia |
| Unknown |
Tin |
| PT Bukit Timah |
| Indonesia |
| CFSP Listed |
Tin |
| PT DS Jaya Abadi |
| Indonesia |
| CFSP Listed |
Tin |
| PT Eunindo Usaha Mandiri |
| Indonesia |
| Unknown |
Tin |
| PT HANJAYA PERKASA METALS |
| Indonesia |
| Unknown |
Tin |
| PT Inti Stania Prima |
| Indonesia |
| Unknown |
Tin |
| PT JusTindo |
| Indonesia |
| Unknown |
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status |
Tin |
| PT Karimun Mining |
| Indonesia |
| Unknown |
Tin |
| PT Mitra Stania Prima |
| Indonesia |
| Unknown |
Tin |
| PT Panca Mega Persada |
| Indonesia |
| Unknown |
Tin |
| PT Pelat Timah Nusantara Tbk |
| Indonesia |
| Unknown |
Tin |
| PT Prima Timah Utama |
| Indonesia |
| Unknown |
Tin |
| PT REFINED BANGKA TIN |
| Indonesia |
| CFSP Listed |
Tin |
| PT Sariwiguna Binasentosa |
| Indonesia |
| Unknown |
Tin |
| PT Seirama Tin investment |
| Indonesia |
| Unknown |
Tin |
| PT Stanindo Inti Perkasa |
| Indonesia |
| CFSP Listed |
Tin |
| PT Sumber Jaya Indah |
| Indonesia |
| Unknown |
Tin |
| PT Tambang Timah |
| Indonesia |
| CFSP Listed |
Tin |
| PT Timah (Persero), Tbk |
| Indonesia |
| CFSP Listed |
Tin |
| PT Tinindo Inter Nusa |
| Indonesia |
| Unknown |
Tin |
| PT Tirus Putra Mandiri |
| Indonesia |
| Unknown |
Tin |
| PT WAHANA PERKIT JAYA |
| Indonesia |
| Unknown |
Tin |
| Rui Da Hung |
| Taiwan |
| Unknown |
Tin |
| Soft Metais, Ltda. |
| Brazil |
| Unknown |
Tin |
| Thaisarco |
| Thailand |
| CFSP Listed |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| Brazil |
| CFSP Listed |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
| China |
| Unknown |
Tin |
| Yunnan Tin Company, Ltd. |
| China |
| CFSP Listed |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| Japan |
| Unknown |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| Vietnam |
| Unknown |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Dayu Jincheng Tungsten Industry Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Ganxian Shirui New Material Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Global Tungsten & Powders Corp. |
| United States |
| CFSP Listed |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| H.C. Starck GmbH |
| Germany |
| Unknown |
Tungsten |
| H.C. Starck Smelting GmbH & Co.KG |
| Germany |
| Unknown |
Tungsten |
| Hunan Chenzhou Mining Group Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Japan New Metals Co., Ltd. |
| Japan |
| CFSP Listed |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| China |
| Unknown |
Tungsten |
| Kennametal Fallon |
| United States |
| Unknown |
Tungsten |
| Kennametal Huntsville |
| United States |
| Unknown |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| China |
| CFSP Listed |
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status Dec 31, 2014 |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| Vietnam |
| Unknown |
Tungsten |
| Sanher Tungsten Vietnam Co., Ltd. |
| Vietnam |
| Unknown |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| Vietnam |
| Unknown |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd |
| Vietnam |
| Unknown |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| Austria |
| Unknown |
Tungsten |
| Wolfram Company CJSC |
| Russian Federation |
| Unknown |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| China |
| CFSP Listed |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| China |
| Unknown |
Gold |
| Advanced Chemical Company |
| United States |
| Unknown |
Gold |
| Aida Chemical Industries Co. Ltd. |
| Japan |
| Unknown |
Gold |
| Aktyubinsk Copper Company TOO |
| Russian Federation |
| Unknown |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| Germany |
| CFSP Listed |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| Uzbekistan |
| Unknown |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| Brazil |
| CFSP Listed |
Gold |
| Argor-Heraeus SA |
| Switzerland |
| CFSP Listed |
Gold |
| Asahi Pretec Corporation |
| Japan |
| CFSP Listed |
Gold |
| Asaka Riken Co Ltd |
| Japan |
| Unknown |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Turkey |
| Unknown |
Gold |
| Aurubis AG |
| Germany |
| CFSP Listed |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Philippines |
| Unknown |
Gold |
| Bauer Walser AG |
| Germany |
| Unknown |
Gold |
| Boliden AB |
| Sweden |
| CFSP Listed |
Gold |
| C. Hafner GmbH + Co. KG |
| Germany |
| Unknown |
Gold |
| Caridad |
| Mexico |
| Unknown |
Gold |
| CCR Refinery — Glencore Canada Corporation |
| Canada |
| CFSP Listed |
Gold |
| Cendres + Métaux SA |
| Switzerland |
| Unknown |
Gold |
| Chimet S.p.A. |
| Italy |
| CFSP Listed |
Gold |
| Chugai Mining |
| Japan |
| Unknown |
Gold |
| Daejin Indus Co. Ltd |
| Korea, Republic of |
| Unknown |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| China |
| Unknown |
Gold |
| Do Sung Corporation |
| Korea, Republic of |
| Unknown |
Gold |
| Doduco |
| Germany |
| Unknown |
Gold |
| Dowa |
| Japan |
| CFSP Listed |
Gold |
| Eco-System Recycling Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| Fidelity Printers and Refiners Ltd. |
| Zimbabwe |
| Unknown |
Gold |
| FSE Novosibirsk Refinery |
| Russian Federation |
| Unknown |
Gold |
| Gansu Seemine Material Hi-Tech Co Ltd |
| China |
| Unknown |
Gold |
| Guangdong Jinding Gold Limited |
| China |
| Unknown |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| China |
| Unknown |
Gold |
| Heimerle + Meule GmbH |
| Germany |
| CFSP Listed |
Gold |
| Heraeus Ltd. Hong Kong |
| Hong Kong |
| CFSP Listed |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| Germany |
| CFSP Listed |
Gold |
| Hunan Chenzhou Mining Group Co., Ltd. |
| China |
| Unknown |
Gold |
| Hwasung CJ Co. Ltd |
| Korea, Republic of |
| Unknown |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
| China |
| Unknown |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| Istanbul Gold Refinery |
| Turkey |
| CFSP Listed |
Gold |
| Japan Mint |
| Japan |
| CFSP Listed |
Gold |
| Jiangxi Copper Company Limited |
| China |
| Unknown |
Gold |
| Johnson Matthey Inc |
| United States |
| CFSP Listed |
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status |
Gold |
| Johnson Matthey Ltd |
| Canada |
| CFSP Listed |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Russian Federation |
| Unknown |
Gold |
| JSC Uralelectromed |
| Russian Federation |
| Unknown |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| Kazzinc Ltd |
| Kazakhstan |
| CFSP Listed |
Gold |
| Kennecott Utah Copper LLC |
| United States |
| CFSP Listed |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| Poland |
| Unknown |
Gold |
| Kojima Chemicals Co., Ltd |
| Japan |
| CFSP Listed |
Gold |
| Korea Metal Co. Ltd |
| Korea, Republic of |
| Unknown |
Gold |
| Kyrgyzaltyn JSC |
| Kyrgyzstan |
| Unknown |
Gold |
| L’ azurde Company For Jewelry |
| Saudi Arabia |
| Unknown |
Gold |
| Lingbao Gold Company Limited |
| China |
| Unknown |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
| China |
| Unknown |
Gold |
| LS-NIKKO Copper Inc. |
| Korea, Republic of |
| CFSP Listed |
Gold |
| Luoyang Zijin Yinhui Metal Smelt Co Ltd |
| China |
| Unknown |
Gold |
| Materion |
| United States |
| CFSP Listed |
Gold |
| Matsuda Sangyo Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| Metalor Technologies (Hong Kong) Ltd |
| Hong Kong |
| CFSP Listed |
Gold |
| Metalor Technologies (Singapore) Pte. Ltd. |
| Singapore |
| CFSP Listed |
Gold |
| Metalor Technologies SA |
| Switzerland |
| CFSP Listed |
Gold |
| Metalor USA Refining Corporation |
| United States |
| CFSP Listed |
Gold |
| METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
| Mexico |
| CFSP Listed |
Gold |
| Mitsubishi Materials Corporation |
| Japan |
| CFSP Listed |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| MMTC-PAMP India Pvt. Ltd |
| India |
| CFSP Listed |
Gold |
| Moscow Special Alloys Processing Plant |
| Russian Federation |
| Unknown |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| Turkey |
| CFSP Listed |
Gold |
| Navoi Mining and Metallurgical Combinat |
| Uzbekistan |
| Unknown |
Gold |
| Nihon Material Co. LTD |
| Japan |
| CFSP Listed |
Gold |
| Ohio Precious Metals, LLC |
| United States |
| CFSP Listed |
Gold |
| Ohura Precious Metal Industry Co., Ltd |
| Japan |
| CFSP Listed |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
| Russian Federation |
| Unknown |
Gold |
| OJSC Kolyma Refinery |
| Russian Federation |
| Unknown |
Gold |
| PAMP SA |
| Switzerland |
| CFSP Listed |
Gold |
| Penglai Penggang Gold Industry Co Ltd |
| China |
| Unknown |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| Russian Federation |
| Unknown |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| Indonesia |
| Unknown |
Gold |
| PX Précinox SA |
| Switzerland |
| CFSP Listed |
Gold |
| Rand Refinery (Pty) Ltd |
| South Africa |
| CFSP Listed |
Gold |
| Republic Metals Corporation |
| United States |
| CFSP Listed |
Gold |
| Royal Canadian Mint |
| Canada |
| CFSP Listed |
Gold |
| Sabin Metal Corp. |
| United States |
| Unknown |
Gold |
| Samduck Precious Metals |
| Korea, Republic of |
| Unknown |
Gold |
| SAMWON METALS Corp. |
| Korea, Republic of |
| Unknown |
Gold |
| Schone Edelmetaal |
| Netherlands |
| CFSP Listed |
Gold |
| SEMPSA Joyería Platería SA |
| Spain |
| CFSP Listed |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
| China |
| Unknown |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd |
| China |
| Unknown |
Gold |
| Singway Technology Co., Ltd. |
| Taiwan |
| CFSP Listed |
Gold |
| So Accurate Group, Inc. |
| United States |
| Unknown |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| Russian Federation |
| Unknown |
Metal |
| Name of SOR |
| Country Location of |
| CFSP Status |
Gold |
| Solar Applied Materials Technology Corp. |
| Taiwan |
| CFSP Listed |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| Japan |
| CFSP Listed |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| Japan |
| CFSP Listed |
Gold |
| The Great Wall Gold and Silver Refinery of China |
| China |
| Unknown |
Gold |
| The Refinery of Shandong Gold Mining Co. Ltd |
| China |
| Unknown |
Gold |
| Tokuriki Honten Co., Ltd |
| Japan |
| CFSP Listed |
Gold |
| Tongling Nonferrous Metals Group Co.,Ltd |
| China |
| Unknown |
Gold |
| Torecom |
| Korea, Republic of |
| Unknown |
Gold |
| Umicore Brasil Ltda |
| Brazil |
| CFSP Listed |
Gold |
| Umicore Precious Metals Thailand |
| Thailand |
| CFSP Listed |
Gold |
| Umicore SA Business Unit Precious Metals Refining |
| Belgium |
| CFSP Listed |
Gold |
| United Precious Metal Refining, Inc. |
| United States |
| CFSP Listed |
Gold |
| Valcambi SA |
| Switzerland |
| CFSP Listed |
Gold |
| Western Australian Mint trading as The Perth Mint |
| Australia |
| CFSP Listed |
Gold |
| YAMAMOTO PRECIOUS METAL CO., LTD. |
| Japan |
| Unknown |
Gold |
| Yokohama Metal Co Ltd |
| Japan |
| Unknown |
Gold |
| Yunnan Copper Industry Co Ltd |
| China |
| Unknown |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| China |
| Unknown |
Gold |
| Zijin Mining Group Co. Ltd |
| China |
| Unknown |
Appendix B
Countries of Origin for Conflict Minerals associated with the SORs listed in Appendix A.
Level 1, 2, and 3 Source Definitions are from the CFSP Audit Protocols.
Level 1 countries are not identified as conflict regions or plausible areas of smuggling or export of conflict minerals from these regions
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Côte D’Ivoire, Czech Republic, Djibouti, 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
Level 2 countries are known or plausible countries for smuggling, export out of region or transit of conflict minerals
Kenya, Mozambique, South Africa
Level 3 countries are defined as the DRC and its nine adjoining countries
Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia
