Exhibit 1.01
Best Buy Co., Inc.
Conflict Minerals Report
For The Year Ended December 31, 2016
This Conflict Minerals Report for Best Buy Co., Inc. (“Best Buy”, “we”, “us” or “our”) covers the reporting period from January 1st to December 31st, 2016, and is presented in accordance with the Securities Exchange Act of 1934, Rule 13p-1 (the “conflict minerals law”).
This Conflict Minerals Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD and is also posted on our website at www.investors.bestbuy.com
Introduction
The Democratic Republic of the Congo (“DRC”) and its adjoining countries have reserves of tin, tantalum, tungsten and gold (collectively known as “3TG”), all of which are commonly used in the manufacturing of many consumer products. Occasionally, these minerals are illegally sourced and traded in the eastern DRC and surrounding areas by armed groups who are responsible for human rights violations. As such, these minerals are known as “conflict minerals.”
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1502 of the Act specifically relates to conflict minerals and requires companies covered under the Act to annually file a Form SD with the United States Securities and Exchange Commission (“SEC”) to disclose whether the 3TG used in their products directly or indirectly benefited armed groups in the DRC. This Conflict Minerals Report, which is an exhibit to our Specialized Disclosure Report on Form SD, describes the design of our conflict minerals program and provides an account of how our program was implemented in 2016 to determine, to the best of our ability, the source, chain of custody and facilities used to process the minerals used in Best Buy Exclusive Brands (“ExB”) products.
Historically, we have had very limited engagement with parties beyond the first-tier suppliers in our supply chain. Consequently, identifying, with certainty, the smelters, refiners and recyclers and the source of the materials they process is a significant challenge. We seek to address this challenge in part by participating in and, in some cases, leading collaborative industry efforts that seek to gather accurate data about the sources of 3TG and encourage smelters to be validated as conflict-free.
Products
Best Buy is a leading provider of technology products, services and solutions. We offer these products and services to the customers who visit our stores, engage with Geek Squad Agents or use our websites or mobile applications. We have retail operations in the U.S., Canada and Mexico.
The ExB product categories, under brand names Insignia, Dynex, Rocketfish, Platinum and Modal, in which we believe contain necessary 3TG and are therefore within scope of our Reasonable Country of Origin Inquiry (“RCOI”) and due diligence efforts include the following:
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| Product Category | Product Examples |
| Audio Products and Accessories | Stereos, speakers, sound bars, radio, etc. |
| Computing and Accessories | Tablets, monitors, keyboards, mouse, chargers, etc. |
| Mobile Phone Accessories | Mobile chargers, cables, etc. |
| Office and Household Products | Shredders, coffee makers, toasters, blenders, etc. |
| Video Game Accessories | Charging stations, power packs, steering wheel combo, etc. |
| Video Products and Accessories | TVs, DVD players, video cables, etc. |
Reasonable Country of Origin Inquiry
Pursuant to the conflicts minerals law, we conducted a RCOI on the source of 3TG necessary to the functionality and/or production (“necessary 3TG”) of our products in order to determine whether any of the necessary 3TG originated in the DRC or an adjoining country or were from recycled or scrap sources. As part of our RCOI process, we conducted the following activities:
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| • | Reviewed past Conflict Minerals Reporting Templates ("CMRTs"), utilized a 3TG risk assessment tool and consulted with our engineering team in order to identify 86 active, first-tier suppliers we knew or had reason to believe used necessary 3TG in the production of ExB products (“relevant suppliers”); |
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| • | Used the CMRT created by the Electronics Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”) to survey relevant suppliers, requesting the identification of the facilities that processed the necessary 3TG they utilized and the country of origin from which the ores were sourced; |
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| • | Reviewed information provided by the 86 relevant suppliers in order to determine the completeness and reasonableness of their responses and verified the processing facilities they identified by comparing against the list of known smelters and refiners as provided by the Conflict Free Sourcing Initiative (“CFSI”); |
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| • | Reviewed country of origin information available to Best Buy through our membership in CFSI (member ID V1720151223); and |
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| • | Conducted additional research on the 3TG processing facilities identified by relevant suppliers, including direct contact, in an attempt to augment the country of origin information gathered through our membership in CFSI. |
Based on the results of our RCOI, we had reason to believe that some of the necessary 3TG used in ExB products may have been processed by facilities that sourced from the DRC or an adjoining country and may not have been from recycled or scrap sources. In compliance with the Act, we then exercised due diligence on the source and chain of custody of the necessary 3TG processed by these facilities that conformed to an internationally recognized due diligence framework.
Due Diligence
To determine, to the best of our ability, the source and chain of custody of the necessary 3TG used in ExB products, we conducted due diligence on our supply chain. Our due diligence measures were developed to ascertain if the minerals originated from the DRC or an adjoining country and, if so, whether armed groups directly or indirectly benefited as a result. Additional measures were designed to mitigate risks identified through the implementation of our due diligence process.
Design of our Due Diligence Measures
Our due diligence process is designed to conform to, in all material aspects given our downstream position in the supply chain, the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and the related supplements on Tin, Tantalum, Tungsten and Gold (collectively, the “OECD Guidance”), an internationally recognized due diligence framework. In accordance with the 5-step OECD Guidance, the design of our due diligence includes, but is not limited to, the following:
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| 1. | Establishing a strong company management system through the adoption of a Conflict Minerals Policy, the implementation of a conflict minerals governance structure and strengthened engagement with our suppliers. |
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| 2. | Identifying and assessing risks by identifying relevant suppliers to engage in our RCOI and due diligence efforts, determining a reasonable engagement approach to gather conflict mineral sourcing information, and reviewing and validating smelter information provided by suppliers in order to determine risks. |
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| 3. | Responding to identified risks by reporting to senior management the findings derived from our RCOI and due diligence efforts, designing training for relevant suppliers to improve their systems of transparency and control and devising a risk management strategy that seeks to ensure necessary 3TG in the supply chain are conflict-free. |
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| 4. | Auditing supply chain due diligence via our support for an industry developed audit program that is administered by independent, third-party auditors. |
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| 5. | Reporting on due diligence through our Specialized Disclosure Report on Form SD and Conflict Minerals Report filed with the SEC and the inclusion of conflict minerals content in our annual Corporate Responsibility and Sustainability report. |
Due Diligence Measures Performed
We worked with peers across multiple industries in an effort to ensure that the implementation of our due diligence process was aligned with the OECD Guidance and complemented and amplified the industry approach. The primary objective of this alignment was to maximize the efficiency and effectiveness of our efforts to identify smelters and refiners and encourage their participation in CFSI’s Conflict-Free Smelter Program (“CFSP”) or an equivalent program, including the London Bullion
Market Association’s (“LBMA”) Good Delivery program and the Responsible Jewellery Council’s (“RJC”) Chain of Custody program. For this reporting period, we performed the due diligence measures described below on the source and chain of custody of necessary 3TG in the ExB supply chain:
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| • | We published a Conflict Minerals Policy that established ExB commitments regarding the sourcing of conflict minerals, including alignment with the OECD Guidance, supporting industry efforts, and seeking to avoid sourcing necessary 3TG that directly or indirectly benefit armed groups. The policy also sets similar expectations for our suppliers, which we reinforced when we conducted a social compliance audit at a supplier’s factory; |
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| • | We maintained a conflict minerals governance structure comprised of an operations team, an advisory team and an executive committee that includes senior executives from our Legal, External Reporting, Communications, Public Affairs, Corporate Responsibility & Sustainability, Human Resources and Private Label departments; |
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| • | We strengthened the engagement with relevant ExB suppliers by providing in-person and online training regarding the Conflict Minerals law and their role in supporting our RCOI and due diligence efforts, as set forth below: |
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| Conflict Mineral Program Key Performance Indicators | |
| Percent of relevant ExB suppliers who attended training (in-person or via a webinar) | 90% |
| Percent of relevant ExB suppliers who received training material | 100% |
| Percent of products containing necessary 3TG that have had their supply chains surveyed | 100% |
| Percent of relevant ExB suppliers who returned a CMRT | 100% |
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| • | We reviewed data collected via our RCOI and due diligence efforts to determine if smelters in our supply chain may have been sourcing from a covered country and directly or indirectly financed or benefited armed groups in the DRC or an adjoining country; |
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| • | We conducted outreach to smelters and refiners who had not been audited to determine their compliance to the CFSI standard or another independent third-party’s standard in order to encourage their participation in such a program; |
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| • | We met with 12 smelters and refiners to assess their sourcing practices and request country of origin information and/or to better understand the challenges they face to demonstrate their alignment with the OECD Guidance; |
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| • | We contributed to the development and implementation of an effective smelter audit program through our membership in the CFSI, which administers Conflict Free Smelter Program audits; |
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| • | We attended the annual CFSI conference in order to gather best practices and collaborate with industry peers; |
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| • | We made a financial donation to the EICC Foundation, which is used, in part, to cover audit costs for smelters who successfully complete their initial audit; |
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| • | We continued to serve as a single-point-of-contact to help support smelters and refiners prepare for a CFSP audit and complete corrective action plans post-audit, as needed; |
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| • | We took steps to remove five smelters from our supply chain who were assessed as high-risk and had refused to be transparent about their sourcing practices and locations; |
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| • | We met directly with Chinese and U.S. government bodies, the OECD and several Chinese-based smelters to discuss and influence the development of a Chinese due diligence standard for the responsible sourcing of 3TG; |
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| • | We supported many CFSI activities including serving on the CFSI Steering Committee, which sets the strategic direction for the organization, serving as Chair of the Smelter Engagement Team (“SET”), which conducts coordinated outreach to known smelters around the world to encourage them to participate in the CFSP or an equivalent program and leading the China SET, which works with smelters and refiners based in China; |
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| • | We sought to optimize the CFSI’s Smelter Engagement Team structure, process and tools in order to improve the program’s effectiveness; and |
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| • | We disclosed information regarding our due diligence effort on the sourcing of 3TG via our Specialized Disclosure Report on Form SD and this Exhibit 1.01 Conflict Minerals Report filed with the SEC and we will include information on our conflict minerals due diligence efforts in our fiscal 2017 Corporate Responsibility and Sustainability Report, which we plan to release in the summer of 2017. |
Results of Due Diligence Performed
We conducted the due diligence process described above in order to ascertain source and chain of custody information for the necessary 3TG in our ExB supply chain. To date, nearly 90% of the processing facilities reported by relevant suppliers have been found complaint to the CFSI standard via an independent, third-party audit or they have committed to go through an audit. Nevertheless, based on our due diligence process and the subsequent information we gathered, we are unable to determine the origin of all the 3TG used in our products and whether armed groups directly or indirectly benefited primarily due to the lack of transparency among smelters who have not yet been audited. While there have been improvements in the systems of transparency and control for the sourcing of necessary 3TG, these results are not unexpected, especially given our downstream position as a retailer and manufacturer of private label products.
Of the smelter and refinery information provided by our suppliers, CFSI and other sources, we identified 37 smelters who we had reason to believe that at least a portion of the 3TG they processed may have originated in the DRC or an adjoining country and may not have been from recycled or scrap sources. All 37 of these processing facilities have been found compliant through CFSP or another independent, third-party audit scheme. Furthermore, we have not identified a supplier, smelter or refiner who we have reason to believe may be sourcing from the DRC or an adjoining country and, directly or indirectly, benefiting armed groups.
Please see the table below for the status of facilities reported to us by relevant ExB suppliers and see Attachment A for the list of smelters and refiners.
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| Metal | Compliant(2) | Active or TI-CMC Member(2) | Unknown(2) |
| Gold | 80% | 3% | 17% |
| Tantalum | 100% | 0% | 0% |
| Tin | 84% | 9% | 8% |
| Tungsten | 89% | 2% | 9% |
Future Steps to Optimize Our Due Diligence Efforts
Best Buy is committed to being a socially and environmentally responsible corporation and this commitment extends throughout the length of our value chain, from the sourcing of raw material to the responsible recycling of products. We recognize that this commitment is a journey and one that we cannot take on our own. This challenge is further complicated given the complexity of our supply chain, which is, in essence, in a constant state of transformation. As a result, we will continue to focus our efforts on collaborating across industries to improve the systems of transparency and control in our supply chain. We will also continue our engagement with relevant suppliers in order to build their knowledge so they are able to provide more complete and accurate information on the source of conflict minerals in our ExB supply chain and, furthermore, to impress upon them our expectation that they also apply the OECD Guidance in good faith.
Steps we intend to take in 2017 include:
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| • | Improving our ability to map the presence of 3TG necessary to the functionality and/or production of our products, thus improving our ability to accurately scope relevant suppliers and assess their CMRTs; |
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| • | Strengthening our Conflict Minerals Policy by requiring suppliers to only source 3TG from smelters and refiners validated as conflict free; and |
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| • | Participating in CFSI meetings in order to gather best practices and collaborate with industry peers. |
Attachment A
The vast majority of the CMRT responses we received from suppliers provided data at a company level, meaning they listed the names of smelters and refiners they believe supplied 3TG for all the products they produced, not just the products they produced for Best Buy. Therefore, the processing facilities listed in the table below represent the smelters and refiners provided by our suppliers, but we do not have sufficient information to confirm whether these are the actual smelters that processed necessary 3TG used in our products. Additionally, we are unable to conclusively determine the country of origin information for our necessary 3TG but based on the data gathered from suppliers, processing facilities and CFSI, we believe that the sources may include the countries listed in the table below.
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| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Gold | Advanced Chemical Company | United States of America | Compliant |
| Gold | Aida Chemical Industries Co., Ltd. | Japan | Compliant |
| Gold | Al Etihad Gold LLC | United Arab Emirates | Compliant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Compliant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Compliant |
| Gold | Argor-Heraeus S.A. | Switzerland | Compliant |
| Gold | Asahi Pretec Corp. | Japan | Compliant |
| Gold | Asahi Refining Canada Ltd. | Canada | Compliant |
| Gold | Asahi Refining USA Inc. | United States of America | Compliant |
| Gold | Asaka Riken Co., Ltd. | Japan | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Unknown |
| Gold | Aurubis AG | Germany | Compliant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Compliant |
| Gold | Boliden AB | Sweden | Compliant |
| Gold | C. Hafner GmbH + Co. KG | Germany | Compliant |
| Gold | Caridad | Mexico | Unknown |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | Compliant |
| Gold | Cendres + Metaux S.A. | Switzerland | Active |
| Gold | Chimet S.p.A. | Italy | Compliant |
| Gold | Chugai Mining | Japan | Unknown |
| Gold | Daejin Indus Co., Ltd. | Korea (Republic of) | Compliant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Compliant |
| Gold | DODUCO GmbH | Germany | Compliant |
| Gold | Dowa | Japan | Compliant |
| Gold | DSC (Do Sung Corporation) | Korea (Republic of) | Compliant |
| Gold | Eco-System Recycling Co., Ltd. | Japan | Compliant |
| Gold | Elemetal Refining, LLC | United States of America | Unknown |
| Gold | Emirates Gold DMCC | United Arab Emirates | Compliant |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China | Unknown |
| Gold | Geib Refining Corporation | United States of America | Compliant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Compliant |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China | Compliant |
| Gold | Guangdong Jinding Gold Limited | China | Unknown |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Unknown |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Unknown |
| Gold | Heimerle + Meule GmbH | Germany | Compliant |
| Gold | Heraeus Metals Hong Kong Ltd. | China | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Compliant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | Compliant |
| Gold | HwaSeong CJ CO., LTD. | Korea (Republic of) | Unknown |
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| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Compliant |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Compliant |
| Gold | Istanbul Gold Refinery | Turkey | Compliant |
| Gold | Japan Mint | Japan | Compliant |
| Gold | Jiangxi Copper Co., Ltd. | China | Compliant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Compliant |
| Gold | JSC Uralelectromed | Russian Federation | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Compliant |
| Gold | Kaloti Precious Metals | United Arab Emirates | Unknown |
| Gold | Kazakhmys Smelting LLC | Kazakhstan | Unknown |
| Gold | Kazzinc | Kazakhstan | Compliant |
| Gold | Kennecott Utah Copper LLC | United States of America | Compliant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Active |
| Gold | Kojima Chemicals Co., Ltd. | Japan | Compliant |
| Gold | Korea Zinc Co., Ltd. | Korea (Republic of) | Compliant |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | Compliant |
| Gold | L'azurde Company For Jewelry | Saudi Arabia | Unknown |
| Gold | LS-NIKKO Copper Inc. | Korea (Republic of) | Compliant |
| Gold | Materion | United States of America | Compliant |
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Compliant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Compliant |
| Gold | Metalor Technologies (Suzhou) Ltd. | China | Compliant |
| Gold | Metalor Technologies S.A. | Switzerland | Compliant |
| Gold | Metalor USA Refining Corporation | United States of America | Compliant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Compliant |
| Gold | Mitsubishi Materials Corporation | Japan | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | India | Compliant |
| Gold | Morris and Watson | New Zealand | Unknown |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Active |
| Gold | Nihon Material Co., Ltd. | Japan | Compliant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Compliant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Compliant |
| Gold | OJSC Novosibirsk Refinery | Russian Federation | Compliant |
| Gold | PAMP S.A. | Switzerland | Compliant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Unknown |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Compliant |
| Gold | PX Precinox S.A. | Switzerland | Compliant |
| Gold | Rand Refinery (Pty) Ltd. | South Africa | Compliant |
| Gold | Republic Metals Corporation | United States of America | Compliant |
| Gold | Royal Canadian Mint | Canada | Compliant |
| Gold | SAAMP | France | Compliant |
| Gold | Sabin Metal Corp. | United States of America | Unknown |
| Gold | Samduck Precious Metals | Korea (Republic of) | Compliant |
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| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Gold | Samwon Metals Corp. | Korea (Republic of) | Unknown |
| Gold | SAXONIA Edelmetalle GmbH | Germany | Compliant |
| Gold | Schone Edelmetaal B.V. | Netherlands | Compliant |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain | Compliant |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | Compliant |
| Gold | Singway Technology Co., Ltd. | Taiwan | Compliant |
| Gold | So Accurate Group, Inc. | United States of America | Unknown |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Compliant |
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Compliant |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Compliant |
| Gold | T.C.A S.p.A | Italy | Compliant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | Japan | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China | Unknown |
| Gold | Torecom | Korea (Republic of) | Compliant |
| Gold | Umicore Brasil Ltda. | Brazil | Compliant |
| Gold | Umicore Precious Metals Thailand | Thailand | Compliant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Compliant |
| Gold | United Precious Metal Refining, Inc. | United States of America | Compliant |
| Gold | Valcambi S.A. | Switzerland | Compliant |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia | Compliant |
| Gold | WIELAND Edelmetalle GmbH | Germany | Compliant |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | Compliant |
| Gold | Yokohama Metal Co., Ltd. | Japan | Compliant |
| Gold | Yunnan Copper Industry Co., Ltd. | China | Unknown |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | Compliant |
| Tantalum | D Block Metals, LLC | United States of America | Compliant |
| Tantalum | Duoluoshan | China | Compliant |
| Tantalum | Exotech Inc. | United States of America | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | China | Compliant |
| Tantalum | FIR Metals & Resource Ltd. | China | Compliant |
| Tantalum | Global Advanced Metals Aizu | United States of America | Compliant |
| Tantalum | Global Advanced Metals Boyertown | United States of America | Compliant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Compliant |
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Compliant |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Compliant |
| Tantalum | H.C. Starck Inc. | United States of America | Compliant |
| Tantalum | H.C. Starck Ltd. | Japan | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | Compliant |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | Compliant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Compliant |
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States of America | Compliant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Compliant |
| Tantalum | Jiangxi Tuohong New Raw Material | China | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Compliant |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | China | Compliant |
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| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Compliant |
| Tantalum | KEMET Blue Metals | Mexico | Compliant |
| Tantalum | King-Tan Tantalum Industry Ltd. | China | Compliant |
| Tantalum | LSM Brasil S.A. | Brazil | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India | Compliant |
| Tantalum | Mineracao Taboca S.A. | Brazil | Compliant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Compliant |
| Tantalum | NPM Silmet AS | Estonia | Compliant |
| Tantalum | QuantumClean | United States of America | Compliant |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil | Compliant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | Compliant |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Compliant |
| Tantalum | Taki Chemical Co., Ltd. | Japan | Compliant |
| Tantalum | Telex Metals | United States | Compliant |
| Tantalum | Tranzact, Inc. | United States of America | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Compliant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China | Compliant |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | Compliant |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China | Compliant |
| Tin | Alpha | United States of America | Compliant |
| Tin | An Thai Minerals Co., Ltd. | Viet Nam | Unknown |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Unknown |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Compliant |
| Tin | China Tin Group Co., Ltd. | China | Compliant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | Unknown |
| Tin | Cooperativa Metalurgica de Rondonia Ltda. | Brazil | Compliant |
| Tin | CV Ayi Jaya | Indonesia | Compliant |
| Tin | CV Dua Sekawan | Indonesia | Compliant |
| Tin | CV Gita Pesona | Indonesia | Compliant |
| Tin | CV Serumpun Sebalai | Indonesia | Compliant |
| Tin | CV Tiga Sekawan | Indonesia | Compliant |
| Tin | CV United Smelting | Indonesia | Compliant |
| Tin | CV Venus Inti Perkasa | Indonesia | Compliant |
| Tin | Dowa | Japan | Compliant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Active |
| Tin | EM Vinto | Bolivia | Compliant |
| Tin | Fenix Metals | Poland | Compliant |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China | Compliant |
| Tin | Gejiu Jinye Mineral Company | China | Compliant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | Active |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Compliant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Active |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Unknown |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | Compliant |
| Tin | HeeSung Metal Ltd. | Korea, Republic of | Active |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China | Compliant |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China | Active |
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| | | |
| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | Compliant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Compliant |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Compliant |
| Tin | Melt Metais e Ligas S.A. | Brazil | Compliant |
| Tin | Metallo Belgium N.V. | Belgium | Compliant |
| Tin | Metallo Spain S.L.U. | Spain | Compliant |
| Tin | Mineracao Taboca S.A. | Brazil | Compliant |
| Tin | Minsur | Peru | Compliant |
| Tin | Mitsubishi Materials Corporation | Japan | Compliant |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China | Active |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Compliant |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | Compliant |
| Tin | Operaciones Metalurgical S.A. | Bolivia | Compliant |
| Tin | PT Aries Kencana Sejahtera | Indonesia | Compliant |
| Tin | PT Artha Cipta Langgeng | Indonesia | Compliant |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Compliant |
| Tin | PT Babel Inti Perkasa | Indonesia | Compliant |
| Tin | PT Bangka Prima Tin | Indonesia | Compliant |
| Tin | PT Bangka Tin Industry | Indonesia | Compliant |
| Tin | PT Belitung Industri Sejahtera | Indonesia | Compliant |
| Tin | PT Bukit Timah | Indonesia | Compliant |
| Tin | PT DS Jaya Abadi | Indonesia | Compliant |
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Compliant |
| Tin | PT Inti Stania Prima | Indonesia | Compliant |
| Tin | PT Karimun Mining | Indonesia | Compliant |
| Tin | PT Kijang Jaya Mandiri | Indonesia | Compliant |
| Tin | PT Mitra Stania Prima | Indonesia | Compliant |
| Tin | PT Panca Mega Persada | Indonesia | Compliant |
| Tin | PT Prima Timah Utama | Indonesia | Compliant |
| Tin | PT Refined Bangka Tin | Indonesia | Compliant |
| Tin | PT Sariwiguna Binasentosa | Indonesia | Compliant |
| Tin | PT Stanindo Inti Perkasa | Indonesia | Compliant |
| Tin | PT Sukses Inti Makmur | Indonesia | Compliant |
| Tin | PT Sumber Jaya Indah | Indonesia | Compliant |
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | Compliant |
| Tin | PT Tinindo Inter Nusa | Indonesia | Compliant |
| Tin | PT Tommy Utama | Indonesia | Compliant |
| Tin | Resind Industria e Comercio Ltda. | Brazil | Compliant |
| Tin | Rui Da Hung | Taiwan | Compliant |
| Tin | Soft Metais Ltda. | Brazil | Compliant |
| Tin | Tanaka Kikinzoku Kogyo K.K. | Japan | Compliant |
| Tin | Thaisarco | Thailand | Compliant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | Unknown |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam | Compliant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | Compliant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Active |
| Tin | Yunnan Tin Company Limited | China | Compliant |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | Compliant |
|
| | | |
| Metal | Processing Facility Name(1) | Location of Facility(1) | Facility Status(2) |
| Tungsten | ACL Metais Eireli | Brazil | Active |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Compliant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Compliant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | Unknown |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Compliant |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | Unknown |
| Tungsten | Global Tungsten & Powders Corp. | United States of America | Compliant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | Compliant |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | Compliant |
| Tungsten | H.C. Starck Tungsten GmbH | Germany | Compliant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | Compliant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | Compliant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Compliant |
| Tungsten | Hydrometallurg, JSC | Russian Federation | Compliant |
| Tungsten | Japan New Metals Co., Ltd. | Japan | Compliant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China | Unknown |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Unknown |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | Compliant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Kennametal Fallon | United States of America | Compliant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Moliren Ltd. | Russian Federation | Compliant |
| Tungsten | Niagara Refining LLC | United States of America | Compliant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Viet Nam | Compliant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines | Compliant |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China | Compliant |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam | Compliant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Viet Nam | Compliant |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria | Compliant |
| Tungsten | Woltech Korea Co., Ltd. | Korea (Republic of) | Compliant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Compliant |
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Compliant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | Compliant |
| Tungsten | Zhuzhou Cemented Carbide Group Co., Ltd. | China | Compliant |
Country of origin for the gold processed by the facilities listed above may include: Australia, Austria, Belgium, Brazil, Canada, China, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea (Republic of), Kyrgyzstan, Mexico, Netherlands, New Zealand, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, United States of America, Uzbekistan, Zimbabwe |
Country of origin for the tantalum processed by the facilities listed above may include: Austria, Brazil, China, Estonia, Germany, India, Japan, Kazakhstan, Mexico, Russian Federation, Thailand, United States of America |
Country of origin for the tin processed by the facilities listed above may include: Belgium, Bolivia, Brazil, China, Germany, Indonesia, Japan, Korea (Republic of), Malaysia, Peru, Philippines, Poland, Russian Federation, Rwanda, Spain, Taiwan, Thailand, United States of America, Viet Nam |
Country of origin for the tungsten processed by the facilities listed above may include: Austria, Brazil, China, Germany, Japan, Korea (Republic of), Philippines, Russian Federation, United States of America, Viet Nam |
| |
| (1) | Facility name and location as reported by the Conflict Free Sourcing Initiative. |
| |
| (2) | Facility status is defined as the following: |
|
| |
| Smelter Status | Status Definition |
| Compliant | Facilities as of April 25, 2017 that are complaint with a 3rd party Due Diligence protocol |
| Active | Facilities that have committed to a CFSP audit or are participating in another independent 3rd-party audit program |
| TI-CMC Member | Facilities that have committed to complete a CFSP audit within two years of TI-CMC membership issuance |
| Unknown | Facilities that have not committed to undergo a CFSP audit and are not participating in another program |
