EXHIBIT 1.01
DORMAN PRODUCTS, INC.
Conflict Minerals Report
Explanatory Note
This Conflict Minerals Report (the “Report”) of Dorman Products, Inc. (the “Company,” “we,” “us,” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2016 to December 31, 2016 (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 “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to metallic forms of tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic 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 of certain of the Company’s products that the Company contracts to manufacture.
Company and the Product Overview
| I. | Introduction |
The Company is a supplier of replacement parts and fasteners for passenger cars, light trucks and heavy duty trucks in the automotive aftermarket, many of which the Company designs and engineers. Conflict Minerals are necessary to the functionality of certain of the Company’s products that the Company contracted to manufacture and for which the manufacture was completed during the Reporting Period (the “Covered Products”). The Covered Products include products in the following product categories:
Power-train products which includes intake and exhaust manifolds, cooling products, harmonic balancers, fluid lines, fluid reservoirs, connectors, 4 wheel drive components and axles, drain plugs, and other engine, transmission and axle components.
Automotive body products which includes door handles and hinges, window lift motors, window regulators, switches and handles, wiper components, lighting, electrical, and other interior and exterior automotive body components.
Chassis products which includes brake hardware and hydraulics, wheel and axle hardware, suspension arms, knuckles, links, bushings, and other suspension, steering and brake components.
Hardware products which includes threaded bolts, auto body and home fasteners, automotive and home electrical wiring components, and other hardware assortments and merchandise.
The Company’s supply chain with respect to the Covered Products is complex and there are many parties in the supply chain between the manufacturer of the Covered Products and the original source of the Conflict Minerals. As a contract manufacturer, we do not purchase Conflict Minerals directly from mines or smelters/refiners. Rather, we rely on the manufacturers to acquire the raw materials necessary for the Covered Products. The Company must therefore rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in the Covered Products. Additionally, we believe that the smelters/refiners of the Conflict Minerals are best suited to identify the sources of such minerals, and we have requested that our vendors take steps to identify the applicable smelters/refiners of the Conflict Minerals in our supply chain.
| II. | Reasonable Country of Origin Inquiry |
The Company conducted a good faith Reasonable Country of Origin Inquiry (“RCOI”) with respect to the Conflict Minerals included in the Covered Products. Such RCOI was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products originated in the Covered Countries and whether any of the Conflict Minerals may be from scrap or recycled sources.
We began this year’s RCOI by using internal product expertise to update our list of products that we contract to manufacture which may contain Conflict Minerals. We then identified the names of our largest thirty seven vendors that accounted for 85% by dollars spent on Covered Products from whom we contracted to manufacture such products. Once identified, we sent each such vendor a Conflict Minerals reporting template (described below) and a letter with instructions on how to complete the reporting template. We have adopted the Electronic Industry Citizenship Coalition (EICC) Conflict Minerals Reporting Template (the “Template”) as a standard questionnaire for conducting inquiries into our vendor’s sources of metals. This Template was created by the EICC and the Global e-Sustainability Initiative (GeSI) as a common means for the collection of sourcing information related to Conflict Minerals. As a part of this process, we provided assistance to vendors about the specifics of the Rule and the information requested by the Template, including the types of evidence/documents that vendors could use to find/back-up their answers in the Template.
In completing the Template, vendors were asked, among other questions, whether the products or components they supplied to us or manufactured for us contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; to determine the smelter/refiner or mine origin or whether the Conflict Minerals were sourced from scrap or recycled sources. The vendors were asked to return a copy
of the Template once completed. Upon return of the Template, responses from vendors were evaluated for completeness, consistency, plausibility, and gaps in information. If information on a Template returned from a vendor appeared to be incomplete, incorrect, or not trustworthy, our purchasing team would return the Template to the vendor by email with a request to complete or correct the questionable information.
Through our RCOI, some of our vendors disclosed to us that scrap/recycled sources of Conflict Minerals were identified in their supply chains and did not require due diligence. After reviewing the balance of the results of our RCOI and comparing the smelters/refiners identified in the supply-chain survey against verified lists produced by the Conflict Minerals Sourcing Initiative (CFSI), we determined that we had reason to believe that some of the Conflict Minerals necessary for the functionality of our Covered Products may have originated in a Covered Country. Therefore, we determined that the Rule required that we exercise due diligence on the source and chain of custody of such Conflict Minerals.
| III. | Design of Due Diligence Framework |
We designed our due diligence framework to conform in all material respects with theOECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition.
| IV. | Due Diligence Measures Performed by the Company |
The due diligence measures that we performed for Covered Products included, but were not limited to, the following:
| • | Maintaining a multi-disciplinary internal team to implement our Conflict Minerals due diligence measures. Our Conflict Minerals project team is headed by our Vice President of Purchasing and includes members from our supply chain, engineering, quality, finance and legal departments. The team meets on a quarterly basis to discuss the due diligence process and progress. |
| • | Communicating our Conflict Minerals Policy Statement (the “Conflict Minerals Policy”) to our vendors. A copy of the Company’s Conflict Minerals Policy is available at www.dormanproducts.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference into this Form SD. |
| • | Maintaining a database which was internally developed to store our supply chain Conflict Minerals records, including all returned Templates. All team members have access to this database. |
| • | Including contractual provisions in agreements with our vendors that require the vendor to abide by the terms of the Company’s Conflict Minerals Policy. |
| • | Reporting to senior management on vendors’ responses to our Conflict Minerals information requests. |
| • | Using a third party service, compared smelters/refiners identified by vendors to the CFSI lists of validated conflict free facilities and conducted our own supplemental research on smelters/refiners. |
Appendix A contains a list of known smelters/refiners reported by the Company’s vendors which may have been used to process the Conflict Minerals utilized in the Covered Products. Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to those Covered Products purchased from its vendors to determine the country of origin of the Conflict Minerals in all Covered Products. At the same time, the Company received no information from its vendors indicating that the Conflict Minerals in the Company’s Covered Products directly or indirectly financed or benefitted armed groups in the Covered Countries. In some cases information was provided to us for the entire supply chain of a vendor, and was not necessarily limited to facilities that have been confirmed to contribute necessary Conflict Minerals to a Covered Product. Accordingly, we have been unable to definitely link the identified smelters/refiners to only those products/materials in our supply chain; therefore our smelter/refiner list likely contains more processing facilities than are actually in our supply chain or Covered Products. However, based on the information that was obtained, the Company has reasonably determined that countries of origin of the Conflict Minerals may include the countries listed within Appendix A.
As a contract manufacturer, we are a downstream indirect purchaser of Conflict Minerals. Accordingly, the efforts we have undertaken to identify the source and chain of custody of the Conflict Minerals in our products reflect our circumstances and position in the supply chain. As a result, our inquiry can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals necessary to the functionality of the Covered Products. Our process relies on data obtained directly from our vendors who seek similar information within their supply chain to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.
| V. | Steps to Further Mitigate Risk and Improve Due Diligence in 2017 |
The Company 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 Company’s products finance or benefit armed groups in the Covered Countries:
| • | the Company will continue to engage with vendors in its supply chain to improve the completeness and accuracy of information provided to the Company; |
| • | the Company will continue to monitor changes in vendor circumstances that may impact their compliance with the Company’s Conflict Minerals Policy, and in turn may impact the Company’s continued engagement of and relationship with certain vendors; |
| • | the Company will continue to review new vendors for compliance with the Company’s Conflict Minerals Policy during the initial business review of each new vendor; |
| • | the Company will continue to encourage its vendors to take similar measures with their suppliers to ensure alignment with the Company’s sourcing philosophy throughout the supply chain; |
| • | the Company will continue to encourage its vendors to have only verified “conflict free” sources; and |
| • | the Company will continue to engage, through a third party service or through its supply chain, with the smelters/refiners set forth on Appendix A and others that may be identified in 2017 in order to identify the country of origin and mine or location of origin of the Conflict Minerals in the Covered Products. |
APPENDIX A
SMELTERS/REFINERS
Set forth below are known smelters/refiners reported by the Company’s vendors which may have been used to process the Conflict Minerals utilized in the Covered Products (“Vendor-Reported Facilities”). Table 1 consists of the Vendor-Reported Facilities for which we were able to obtain country of origin information. Table 2 consists of the Vendor-Reported Facilities for which we were unable to obtain country of origin information.
Table 1
We identified country of origin information for the following Vendor-Reported Facilities (i) that have achieved Conflict Free designation by the Conflict Free Smelter Initiative (CFSI) or an audit program with which CFSI has mutual recognition, (ii) that are actively in the process of obtaining the designations; or (iii) through independent research on such Vendor-Reported Facilities.
| Metal | Smelter/Facility | |
| Gold | Advanced Chemical Company | |
| Gold | Aida Chemical Industries Co., Ltd. | |
| Gold | Al Etihad Gold | |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | |
| Gold | AngloGold Ashanti | |
| Gold | Argor-Heraeus SA | |
| Gold | Asahi Pretec Corporation | |
| Gold | Asahi Refining Canada Limited | |
| Gold | Asahi Refining USA Inc. | |
| Gold | Asaka Riken Co., Ltd. | |
| Gold | AU Traders and Refiners | |
| Gold | Aurubis AG | |
| Gold | Bangalore Refinery | |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | |
| Gold | Boliden AB | |
| Gold | C. Hafner GmbH + Co. KG | |
| Gold | CCR Refinery – Glencore Canada Corporation | |
| Gold | Cendres + Métaux SA | |
| Gold | Chimet S.p.A. | |
| Gold | Daejin Indus Co., Ltd. | |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | |
| Gold | DODUCO GmbH | |
| Gold | Dowa | |
| Gold | DSC (Do Sung Corporation) | |
| Gold | Eco-System Recycling Co., Ltd. | |
| Gold | Emirates Gold DMCC | |
| Gold | Geib Refining Corporation | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd | |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | |
| Gold | Heimerle + Meule GmbH | |
| Gold | Heraeus Metals Hong Kong Ltd | |
| Gold | Heraeus Precious Metals GmbH & Co. KG | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Metal | Smelter/Facility | |
| Gold | Istanbul Gold Refinery | |
| Gold | Japan Mint | |
| Gold | Jiangxi Copper Company Limited | |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | |
| Gold | JSC Uralelectromed | |
| Gold | JX Nippon Mining & Metals Co., Ltd. | |
| Gold | Kazzinc | |
| Gold | Kennecott Utah Copper LLC | |
| Gold | KGHM Polska Miedź Spółka Akcyjna | |
| Gold | Kojima Chemicals Co., Ltd. | |
| Gold | Korea Zinc Co., Ltd. | |
| Gold | Kyrgyzaltyn JSC | |
| Gold | LS-NIKKO Copper Inc. | |
| Gold | Materion | |
| Gold | Matsuda Sangyo Co., Ltd. | |
| Gold | Metalor Technologies (Hong Kong) Ltd. | |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | |
| Gold | Metalor Technologies (Suzhou) Co Ltd | |
| Gold | Metalor Technologies SA | |
| Gold | Metalor USA Refining Corporation | |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | |
| Gold | Mitsubishi Materials Corporation | |
| Gold | Mitsui Mining and Smelting Co., Ltd. | |
| Gold | MMTC-PAMP India Pvt., Ltd. | |
| Gold | Modeltech Sdn Bhd | |
| Gold | Moscow Special Alloys Processing Plant | |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | |
| Gold | Navoi Mining and Metallurgical Combinat | |
| Gold | Nihon Material Co., Ltd. | |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | |
| Gold | Ohura Precious Metal Industry Co., Ltd. | |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | |
| Gold | OJSC Novosibirsk Refinery | |
| Gold | PAMP S.A. | |
| Gold | Prioksky Plant of Non-Ferrous Metals | |
| Gold | PT Aneka Tambang (Persero) Tbk | |
| Gold | PX Precinox SA | |
| Gold | Rand Refinery (Pty) Ltd. | |
| Gold | Republic Metals Corporation | |
| Gold | Royal Canadian Mint | |
| Gold | SAAMP | |
| Gold | Samduck Precious Metals | |
| Gold | SAXONIA Edelmetalle GmbH | |
| Gold | Schone Edelmetaal B.V. | |
| Gold | SEMPSA Joyería Platería SA | |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | |
| Gold | Singway Technology Co., Ltd. | |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | |
| Gold | Solar Applied Materials Technology Corp. | |
| Gold | Sumitomo Metal Mining Co., Ltd. | |
| Gold | T.C.A S.p.A |
| Metal | Smelter/Facility | |
| Gold | Tanaka Kikinzoku Kogyo K.K. | |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | |
| Gold | Tokuriki Honten Co., Ltd. | |
| Gold | Torecom | |
| Gold | Umicore Brasil Ltda. | |
| Gold | Umicore Precious Metals Thailand | |
| Gold | Umicore SA Business Unit Precious Metals Refining | |
| Gold | United Precious Metal Refining, Inc. | |
| Gold | Valcambi SA | |
| Gold | Western Australian Mint trading as The Perth Mint | |
| Gold | WIELAND Edelmetalle GmbH | |
| Gold | Yamamoto Precious Metal Co., Ltd. | |
| Gold | Yokohama Metal Co., Ltd. | |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | |
| Tantalum | Conghua Tantalum and Niobium Smeltry | |
| Tantalum | D Block Metals, LLC | |
| Tantalum | Duoluoshan | |
| Tantalum | Exotech Inc. | |
| Tantalum | F&X Electro-Materials Ltd. | |
| Tantalum | FIR Metals & Resource Ltd. | |
| Tantalum | Global Advanced Metals Aizu | |
| Tantalum | Global Advanced Metals Boyertown | |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | |
| Tantalum | H.C. Starck Co., Ltd. | |
| Tantalum | H.C. Starck Hermsdorf GmbH | |
| Tantalum | H.C. Starck Inc. | |
| Tantalum | H.C. Starck Ltd. | |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | |
| Tantalum | Hi-Temp Specialty Metals, Inc. | |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | |
| Tantalum | Jiangxi Tuohong New Raw Material | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | |
| Tantalum | KEMET Blue Metals | |
| Tantalum | Kemet Blue Powder | |
| Tantalum | King-Tan Tantalum Industry Ltd. | |
| Tantalum | LSM Brasil S.A. | |
| Tantalum | Metallurgical Products India Pvt., Ltd. | |
| Tantalum | Mineração Taboca S.A. | |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | |
| Tantalum | NPM Silmet AS | |
| Tantalum | Power Resources Ltd. | |
| Tantalum | QuantumClean | |
| Tantalum | Resind Indústria e Comércio Ltda. | |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | |
| Tantalum | Solikamsk Magnesium Works OAO | |
| Tantalum | Taki Chemical Co., Ltd. |
| Metal | Smelter/Facility | |
| Tantalum | Telex Metals | |
| Tantalum | Tranzact, Inc. | |
| Tantalum | Ulba Metallurgical Plant JSC | |
| Tantalum | XinXing Haorong Electronic Material Co., Ltd. | |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | |
| Tin | Alpha | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | |
| Tin | China Tin Group Co., Ltd. | |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | |
| Tin | CV Gita Pesona | |
| Tin | CV Serumpun Sebalai | |
| Tin | CV United Smelting | |
| Tin | Dowa | |
| Tin | EM Vinto | |
| Tin | Fenix Metals | |
| Tin | Gejiu Kai Meng Industry and Trade LLC | |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | |
| Tin | Malaysia Smelting Corporation (MSC) | |
| Tin | Metallic Resources, Inc. | |
| Tin | Metallo-Chimique N.V. | |
| Tin | Mineração Taboca S.A. | |
| Tin | Minsur | |
| Tin | Mitsubishi Materials Corporation | |
| Tin | MMC (Mitsubishi Materials Corporation) | |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | |
| Tin | O.M. Manufacturing Philippines, Inc. | |
| Tin | Operaciones Metalurgical S.A. | |
| Tin | PT Aries Kencana Sejahtera | |
| Tin | PT Artha Cipta Langgeng | |
| Tin | PT ATD Makmur Mandiri Jaya | |
| Tin | PT Babel Inti Perkasa | |
| Tin | PT Bangka Tin Industry | |
| Tin | PT Belitung Industri Sejahtera | |
| Tin | PT Bukit Timah | |
| Tin | PT DS Jaya Abadi | |
| Tin | PT Eunindo Usaha Mandiri | |
| Tin | PT Inti Stania Prima | |
| Tin | PT Karimun Mining | |
| Tin | PT Mitra Stania Prima | |
| Tin | PT Panca Mega Persada | |
| Tin | PT Prima Timah Utama | |
| Tin | PT Refined Bangka Tin | |
| Tin | PT Sariwiguna Binasentosa | |
| Tin | PT Stanindo Inti Perkasa | |
| Tin | PT Sumber Jaya Indah | |
| Tin | PT Timah (Persero) Tbk Kundur | |
| Tin | PT Timah (Persero) Tbk Mentok | |
| Tin | PT Tinindo Inter Nusa | |
| Tin | PT WAHANA PERKIT JAYA |
| Metal | Smelter/Facility | |
| Tin | Rui Da Hung | |
| Tin | Soft Metais Ltda. | |
| Tin | Thaisarco | |
| Tin | White Solder Metalurgia e Mineração Ltda. | |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | |
| Tin | Yunnan Tin Group (Holding) Company Limited | |
| Tungsten | A.L.M.T. Corp. | |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | |
| Tungsten | Global Tungsten & Powders Corp. | |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | |
| Tungsten | H.C. Starck Tungsten GmbH | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | |
| Tungsten | Hydrometallurg, JSC | |
| Tungsten | Japan New Metals Co., Ltd. | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | |
| Tungsten | Kennametal Fallon | |
| Tungsten | Kennametal Huntsville | |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | |
| Tungsten | Unecha Refractory Metals Plant | |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | |
| Tungsten | Wolfram Bergbau und Hütten AG | |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | |
| Tungsten | Xiamen Tungsten Co., Ltd. | |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
Countries of origin identified: Angola, Argentina, Armenia, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo (Brazzaville), Czech Republic, Djibouti, DRC- Congo (Kinshasa), Ecuador, Egypt, Estonia, Ethiopia, Finland, Germany, Ghana, Guinea, Guyana, India, Indonesia, Ireland, Japan, Jersey, Kazakhstan, Kenya, Korea, Republic of, Kyrgyzstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Slovakia, South Africa, South Sudan, Spain, Suriname Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe
Table 2 – The following Vendor-Reported Facilities were validated as smelters/refiners but are unaudited by the CFSI (or other program) and country of origin information was unavailable. We continue to engage with our vendors to determine the source of Conflict Minerals processed at the following facilities and to engage in efforts to determine the mine or location of origin of the Conflict Minerals used with greater specificity.
| Metal | Smelter/Facility | |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | |
| Gold | AURA-II | |
| Gold | Caridad | |
| Gold | Chugai Mining | |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | |
| Gold | Elemetal Refining, LLC | |
| Gold | Fidelity Printers and Refiners Ltd. | |
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | |
| Gold | Guangdong Jinding Gold Limited | |
| Gold | Gujarat Gold Centre | |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | |
| Gold | Hunan Chenzhou Mining Co., Ltd. | |
| Gold | HwaSeong CJ Co. Ltd | |
| Gold | Johnson Matthey Chemicals Ltd. | |
| Gold | Kaloti Precious Metals | |
| Gold | Kazakhmys Smelting LLC | |
| Gold | L’azurde Company For Jewelry | |
| Gold | Lingbao Gold Company Ltd. | |
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | |
| Gold | Morris and Watson | |
| Gold | Penglai Penggang Gold Industry Co Ltd | |
| Gold | Remondis Argentia B.V. | |
| Gold | Sabin Metal Corp. | |
| Gold | SAFINA A.S. | |
| Gold | Sai Refinery | |
| Gold | SAMWON METALS Corp. | |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | |
| Gold | So Accurate Group, Inc. | |
| Gold | Sudan Gold Refinery | |
| Gold | TongLing Nonferrous Metals Group Holdings Co., Ltd. | |
| Gold | Tony Goetz NV | |
| Gold | TOO Tau-Ken-Altyn | |
| Gold | Universal Precious Metals Refining Zambia | |
| Gold | Yunnan Copper Industry Co Ltd | |
| Tin | An Vinh Joint Stock Mineral Processing Company | |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | |
| Tin | Estanho de Rondônia S.A. | |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | |
| Tin | Huichang Jinshunda Tin Co. Ltd | |
| Tin | Nankang Nanshan Tin Co., Ltd. | |
| Tin | PT Justindo | |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | |
| Tungsten | Jiangxi Rare Metals Tungsten Holdings Group |
