Exhibit 1.01 to Form SD
Conflict Minerals Report
CREE, INC.
For The Year Ended December 31, 2016
This Conflict Minerals Report (CMR) of Cree, Inc. (Cree, the Company, we, us, or our) for the year ended December 31, 2016 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule) promulgated by the Securities and Exchange Commission (the SEC) pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). This CMR has been prepared on behalf of Cree management.
This CMR contains forward-looking statements regarding our business and conflict minerals efforts, including steps we intend to take to mitigate the risk that conflict minerals in our products benefit certain armed groups. Words such as “expects,” “intends,” “believes,” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this CMR. Additionally, statements concerning future matters that are not historical are forward-looking statements. Forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Risks, uncertainties, assumptions, and other factors that could cause or contribute to such differences in results and outcomes include, among other things, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program and our ability to identify and mitigate related risks in our supply chain. We undertake no obligation to review or update any forward-looking statements to reflect events or circumstances occurring after filing this CMR with the SEC.
Cree has performed due diligence measures as required by the Rule with the goal of determining the chain of custody and country of origin information for the necessary conflict minerals, 1 also referred to as 3TGs, used in our products manufactured in 2016. In particular, we sought to determine whether any of the necessary conflict minerals in our product supply chains may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country, also referred to as the Covered Countries, and whether any conflict minerals originating in the Covered Countries directly or indirectly financed or benefited armed groups in the Covered Countries. As used herein, the term “manufactured” includes products manufactured or contracted to be manufactured by Cree.
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| 1 | The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. |
Because not all suppliers have provided smelter and refiner data and the data provided by some of our suppliers is incomplete, Cree is unable at this time to determine the exact origin of the conflict minerals in all of the assemblies, components, and minerals supplied to us. Therefore, we cannot exclude the possibility that some conflict minerals used in our products manufactured in 2016 may have originated in the Covered Countries, come from sources other than recycled or scrap sources, or come from sources that directly or indirectly financed or benefited armed groups in the Covered Countries. We have obtained no information, however, to indicate that any conflict minerals used in our products manufactured in 2016 originated in the Covered Countries and directly or indirectly financed or benefited armed groups in the Covered Countries.
Pursuant to the Rule, Cree is submitting this CMR as an Exhibit to its Form SD.
Company and Product Overview
Cree is a leading innovator of lighting-class light emitting diode (LED) products, lighting products, and semiconductor products for power and radio-frequency (RF) applications. Our products are targeted for applications such as indoor and outdoor lighting, video displays, transportation, electronic signs and signals, power supplies, solar inverters, and wireless systems.
We develop and manufacture semiconductor materials and devices primarily based on silicon carbide (SiC), gallium nitride (GaN), and related compounds. Our LED products consist of LED components, LED chips, and SiC materials. Our lighting products primarily consist of LED lighting systems, lamps and bulbs. We design, manufacture and sell lighting systems, lamps, and bulbs for indoor and outdoor applications, with our primary focus on LED lighting systems for the commercial and industrial markets. In addition, we develop, manufacture and sell power products made from SiC and RF devices made from GaN.
The majority of our products are manufactured at our production facilities located in North Carolina, Wisconsin, and China. We also use contract manufacturers for certain aspects of product fabrication, assembly, and packaging.
Our SiC materials, in the form of substrates and boules, do not contain any 3TGs, and thus no further due diligence is required with respect to those products. All other Cree products have the potential to include one or more of the conflict minerals. Table 1 below outlines Cree’s products and provides typical conflict mineral content along with the percent of revenue per business unit.
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Table 1
| Cree Business Unit | Percent of Cree Revenue* | Products | Percentage of Products that contain Conflict Minerals? | Typical Conflict Mineral Content by Weight Percentage | |||
| Au | Sn | W | Ta | ||||
| LED Lighting Products | 51% | LED Lamps and Bulbs | 100% | 0.1 - 1% | 0.1 - 1% | < 0.1% | < 0.1% |
| LED Lighting | 100% | 0.05 - 1% | 0.1 - 1% | < 0.1% | < 0.05% | ||
| Accessories | 50-75% | < 0.1% | 0 - 1% | < 0.05% | < 0.1% | ||
| LED Products | 35% | LED Chips | 100% | 0.5 - 3% | 0.2 - 10% | 0 - 0.6% | 0% |
| LED Components | 100% | 0.1 - 0.3% | 0 - 0.3% | 0 - 0.1% | 0 - 0.1% | ||
| Modules + Drivers | 100% | 0.1 - 0.3% | 0.1 - 0.5% | 0 - 0.01% | 0 - 0.1% | ||
| Accessories | 30-50% | < 0.1% | < 0.5% | 0% | 0% | ||
| Wolfspeed Products | 14% | Materials | 0% | N/A | N/A | N/A | N/A |
| RF Die | 100% | 0.5 - 35% | 0.2 - 10% | 0 - 0.6% | 0% | ||
| Power Diodes | 100% | < 0.05% | < 0.05% | < 0.1% | 0% | ||
| RF Transistor Packages | 100% | 0.01 - 0.1% | < 0.01% | 0 - 85% | < 0.05% | ||
*Note: Based on reported revenue for six months ended December 25, 2016.
Conflict Minerals Policy
Cree has adopted a Conflict Minerals Policy under which it expects its suppliers to develop internal conflict mineral policies, due diligence frameworks, and management systems that meet the minimum requirements of the guidelines developed by the Organisation for Economic Co-operation and Development (OECD). Our suppliers’ conflict minerals policies must be designed to identify and eliminate from use in products sold to Cree any conflict minerals which are known to come from sources funding armed groups in the DRC region. Cree requires its direct suppliers to source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program such as the Conflict-Free Sourcing Initiative (CFSI) or its equivalent. Cree fully expects our suppliers to cooperate with us and to provide information to support these efforts, even if the supplier is not directly subject to the Act. Suppliers that do not reasonably comply with Cree’s Conflict Mineral Policy will be reviewed by Cree’s supply chain management to assess whether Cree will conduct business with those suppliers in the future.
To view Cree’s complete Conflict Minerals Policy, visit our webpage located at: http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals. With this reference we are incorporating into this Conflict Minerals Report only our Conflicts Minerals Policy and not the entire contents of our webpage.
Description of Our RCOI Process
Cree’s scoping process included creating a master supplier list of potential in-scope suppliers for 2016 by filtering our supplier database to remove suppliers known to be outside of the scope of the reasonable country of origin inquiry (RCOI), such as service providers, equipment vendors, and
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indirect material suppliers. The objective of filtering was to identify only suppliers that provided to Cree items potentially containing 3TGs that were incorporated into final products in the calendar year 2016.
Once filtered, the master list was provided to Cree’s third-party conflict mineral compliance service provider (the CSP) to conduct a survey using the Conflict Minerals Reporting Template (CMRT). The CMRT was developed by the CFSI; an initiative sponsored by the Electronic Industry Citizenship Coalition, or the EICC, and the Global e-Sustainability Initiative, or the GeSI, and requires suppliers to identify the smelters and refiners that process the necessary conflict minerals contained in the items supplied and the country of origin thereof. During the supplier survey process, suppliers were contacted and responses were tracked using the CSP’s interactive cloud- based platform. This platform allows suppliers to upload completed survey forms directly to the system for review and management.
The CSP launched Cree’s 2016 campaign by providing information about itself and training materials to educate the suppliers believed to be in-scope on 3TGs and the CSP’s reporting system. The full campaign involved multiple communications by the CSP and/or Cree to each supplier, including automated emails, personalized emails, and in some instances phone calls. All significant communications were monitored and tracked in the CSP’s platform for transparency and future reporting.
Based on supplier feedback, the CSP and Cree determined which surveyed suppliers were also outside the scope of the RCOI. These suppliers were marked out-of-scope on the master list. In all other cases, the CSP and Cree reviewed the information provided by each supplier to determine the quality and nature of the response and to determine whether further action was needed to meet Cree’s expectations at this point in the process.
Although 98% of Cree’s in-scope suppliers responded to the RCOI, up from 93% in 2015, some of those suppliers have not yet provided complete smelter or refiner data after several requests by Cree and the CSP. For the suppliers that responded and provided smelter or refiner data, the CSP reviewed all supplier responses that claimed in the declaration section of the CMRT to have known DRC sourced material. The CSP compared the smelting and refining facilities identified in each of these surveys to the list of facilities that have received a “conflict-free” designation from the Conflict-Free Smelter (CFS) program, another resource developed by the CFSI, to determine whether each facility has been certified “conflict-free.”
Because there is considerable overlap between our RCOI and due diligence processes, the determinations we were able to make based on our survey efforts are discussed in more detail in the section below entitled “Due Diligence Results.”
Design of Our Due Diligence Process
Cree’s due diligence measures have been designed to conform in all material respects with the 5-step framework in The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the OECD Guidance) as it relates to our position in the
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conflict minerals supply chain. A summary of the correlation between our due diligence measures and the 5-step framework set forth in the OECD Guidance is described below.
Step 1: Establish strong company management systems
Cree has established a strong management system to address our compliance with the Rule. Our management system is sponsored by the Company’s Chief Financial Officer with support from a team of internal subject matter experts from relevant functions such as Compliance, Engineering, Procurement, Legal, and Internal Audit. The team of subject matter experts is responsible for implementing Cree’s conflict minerals compliance strategy and reports to the CFO, who serves as the conflict minerals program manager. The program manager informs senior management about the results of our due diligence efforts on a regular basis and briefs the Company’s Audit Committee at least quarterly.
As described above, Cree has adopted a Conflict Minerals Policy that includes our commitment and requirement for responsible sourcing of Conflict Minerals. Cree has developed a due diligence strategy to implement our policy that includes using a CSP to educate Cree’s suppliers on the requirements of the Rule annually, or more frequently when deemed necessary, survey our suppliers using the CMRT, review and analyze results, and maintain records for transparency, reporting, and accountability purposes. Consistent with the OECD Guidelines, documentation relevant to Cree’s compliance with the Rule will be retained for a minimum period of five years after the date the related CMR is submitted to the SEC.
We have strengthened engagement with our suppliers by providing education, through the CSP and CFSI resources, on the Rule as well as by communicating, through our Conflict Minerals Policy and contractual provisions, our expectations for suppliers desiring to continue to do business with Cree. Specifically, this includes adding to our standard contracts language that obligates suppliers to exercise due diligence to comply with our Conflict Minerals Policy, which includes a requirement that the supplier must source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program, such as the CFSI or a mutually agreed equivalent. As existing contracts are renewed with suppliers, the new conflict mineral language is being incorporated as well. We have also leveraged the existing communications between Cree’s procurement team and our suppliers to encourage the suppliers to interact with the CSP.
Cree’s Supplier Code of Conduct requires among other things that each Cree in-scope supplier eliminate from use in its products sold to Cree any Conflict Minerals which are known to come from sources funding armed groups in the DRC region. To assist in determining in-scope suppliers and to provide an opportunity for earlier interaction, our new supplier setup procedures include a section asking the new supplier to indicate if any product(s) sold to Cree may contain 3TG material. Lastly, we have a Cree conflict minerals on-line platform that provides employees, suppliers, and other stakeholders a place to report any grievances or concerns with our conflict minerals program (http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals/conflict-minerals-form).
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Step 2: Identify and assess risk in the supply chain
Because of our size, the complexity of our products, our position in the supply chain, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify sources of conflict minerals upstream from our direct suppliers. Further, we typically do not have direct relationships with 3TG smelters or refiners. Accordingly, we must rely on our direct suppliers to provide information on the origin of the 3TGs contained in assemblies, components, and materials supplied to us - including sources of 3TGs that are supplied to them from upstream sources.
The RCOI activities described above are an integral part of Cree’s efforts to identify and assess the risks in our supply chain. As further described below regarding our due diligence process, our CSP’s system is designed to automatically identify and flag missing information and inconsistencies in supplier CMRTs. Flagged suppliers are contacted to gather pertinent data and perform an assessment of the supplier's commitment to the due diligence process. A revised CMRT is requested and stored in the CSP’s database along with all of the information and findings from this process. During the RCOI process, known DRC sources are identified, and the smelter or refiner (SOR) status is validated against the current CFSI status. If further investigation of a SOR is deemed necessary, we gather additional information through other independent third party audit programs such as TI-CMC, the Responsible Jewellery Council’s Chain-of-Custody Certification Program, and the London Bullion Market Association’s Responsible Gold Programme.
Step 3: Design and implement a strategy to respond to identified risks
While many risks exist in the search for the origin of the conflict minerals used in assemblies, components, and materials supplied to Cree, we believe that one of the greatest risks to Cree is the inability to obtain complete and accurate information to make determinations about our own products. Without this information, we in turn become an obstacle to our customers making determinations about their products.
While there are numerous initiatives working to improve transparency and accountability at the smelter and refiner levels of the supply chain, we can only benefit from the information being developed by these initiatives if our suppliers are able to trace back the conflict minerals in their products to a specific smelter or refiner.
This objective is reflected in our Conflict Minerals Policy, which indicates that we expect all of our suppliers to develop their own conflict mineral policies, due diligence frameworks, and management systems, and to provide us all information reasonably needed for us to comply with the Rule. We have included similar obligations in our contractual agreements with our direct suppliers. Our primary focus has shifted from ascertaining whether our immediate suppliers have undertaken efforts to build their own due diligence capabilities meeting the expectations set forth in our Conflicts Minerals Policy to collecting and validating smelter information in completed CMRTs. Our due diligence framework also includes a corrective action management plan designed to move our suppliers toward compliance with our Conflict Minerals Policy. This includes a requirement that any suppliers identified as utilizing a smelter that is known to process Conflict Minerals from sources funding armed groups in the DRC region be placed in escalation mode for further review by our supply chain management and interaction with the supplier in accordance with our Conflict Minerals
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Policy. For 2016, all known DRC sources identified in our supply chain were either CFSI “compliant” or “active”.
Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
We typically do not have direct relationships with any 3TG smelter or refiner, so it is impracticable, if not impossible, for us to perform or direct audits of these entities within our supply chain. Rather, we have relied on audits conducted under the CFS program operated by the CFSI and other reputable auditors. The CFSI publishes a list of smelters, by conflict mineral, found to be compliant with the CFS protocol. Pursuant to the CFS program, a smelter voluntarily submits to an independent third party evaluation of its procurement activities and an assessment as to whether the materials processed by the smelter originated from conflict-free sources. If the smelter is able to demonstrate that the materials it processes are conflict-free, based on the sourcing location requirements of the CFS program, the smelter will be considered CFS-compliant.
The CFSI also makes available to its members information on the countries of origin of the conflict minerals processed by each CFS-compliant smelter. We are an active member of the CFSI in order to support their efforts and to have broader access to the country of origin information as well as other valuable tools and resources provided to its members.
Cree management has determined that it is reasonable and appropriate to rely on the results of the CFS program audits and other comparable audits. Given our position in the supply chain, however, our due diligence measures can provide only reasonable assurances, not guarantees, regarding the chain of custody and country of origin of the necessary conflict minerals in our products.
Step 5: Report on supply chain due diligence
The measures we took in 2016 to exercise due diligence on the source and chain of custody of our conflict minerals were as follows:
| • | communicated our Conflict Minerals Policy to our suppliers and posted a copy on our webpage at http://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals; |
| • | directed our in-scope suppliers to provide information concerning SORs in their supply chains by completing and sending to us the Conflict Minerals Reporting Template (CMRT) that provides a common means for suppliers to provide customers with information on the source of conflict minerals; |
| • | analyzed suppliers’ CMRT responses for completeness and accuracy and pursued further information from the supplier when warranted; |
| • | sent outreach letters to SORs to influence and leverage their participation to becoming CFS-compliant; |
| • | sent outreach letters to our in-scope suppliers to influence and leverage, or ultimately remove SORs who are not CFS-compliant; and |
| • | communicated our Supplier Code of Conduct defining our expectations of our in-scope suppliers to develop internal Conflict Minerals policies, due diligence frameworks, and management systems that are designed to identify and eliminate from use in products sold to |
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Cree any conflict minerals that are known to come from sources funding armed groups in the DRC region. Our Supplier Code of Conduct is located at http://www.cree.com/about/suppliers-contractors/cree-supplier-resources.
No other contents from our website are intended to be incorporated into the Conflict Minerals Report by these website references.
Description of Our Due Diligence Process
Cree’s due diligence process reflects our strategy for identifying, assessing, and responding to the risk that conflict minerals known to have directly or indirectly financed or benefited armed groups in the Covered Countries may be included in our product supply chains. This description is of our process only and is not intended to imply that we have fully implemented this process for all of our suppliers in calendar year 2016.
Our due diligence process includes data evaluation in three phases, all of which are designed to move supplier responses toward compliance with our Conflict Minerals Policy:
Phase 1 - Did the supplier pass our minimum criteria for its CMRT, as assessed by our CSP?
Phase 2 - Did the supplier provide information in its 2016 CMRT survey response which passed Cree’s data validation criteria, as assessed by our CSP?
Phase 3 - Were the CSP’s conclusions reasonable, as assessed by Cree’s subject matter experts on the products supplied to us, and can the smelter information be validated by Cree?
In designing our due diligence process for calendar year 2016, we first reviewed prior year minimum criteria for evaluation during Phase 1 and reaffirmed the applicability for 2016. In evaluating a supplier’s CMRT, we primarily look for three things: effective date-is the information in the report current; completeness-are all of the questions reasonably answered; and consistency-are the supplier’s responses internally consistent.
Suppliers that do not meet these three requirements are contacted with the objective of helping them to understand the requirements for submitting a valid and complete CMRT. Phase 1 is essentially Cree’s corrective action management stage. By implementing supplier corrective action measures, Cree is helping to ensure its suppliers put policies and procedures in place that will produce the necessary data in an accurate and reliable manner.
During Phase 2, the CSP reviews the supplier’s information in its 2016 survey response to validate smelter and refiner information. Smelter and refiner information is reviewed and corrected, and duplicate information is removed whenever possible. All of this data and correspondence is stored in the CSP’s platform. Verified smelter and refiner information is used to obtain reliable information from CFSI and other reputable auditors on the country of origin of the conflict minerals processed by the known smelters or refiners in Cree’s supply chains.
If there are no obvious inaccuracies in the supplier’s CMRT responses, the supplier’s CMRT is deemed reliable by the CSP. If the supplier’s CMRT response is inadequate, the supplier’s survey
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response will be placed in escalation mode and corrective action measures will be applied.
After the CSP completes its analysis under the first two phases, Cree commences its own evaluation in Phase 3. During this evaluation, Cree’s subject matter experts review the information provided by each supplier and the conclusions reached by the CSP from that supplier’s survey data to determine whether those conclusions were reasonable based on information the experts have about the assemblies, components, or materials supplied to Cree. By bringing our specialized knowledge of the industry and Cree’s products into the analysis, Cree is able to identify inaccuracies and inconsistencies in the survey data that may not be obvious to the CSP. If Cree finds inaccuracies and inconsistencies in the survey data, the supplier’s survey response will be placed in escalation mode and corrective action measures will be applied.
Additionally, during Phase 3 Cree validates supplier provided smelter information against the most current known CFSI aliases, smelter status, and mine sourcing. This step allows Cree to determine the certification status of the smelters, as provided in Table 3 below.
There were many challenges in 2016 similar to the previous year’s RCOI, and it is clear that many suppliers do not fully understand the scope of the requirements of the Rule, and that many privately held companies put little or no effort into screening their SOR lists. This, coupled with SOR and recycler dynamics, such as acquisitions, mergers, relocation, or simply going out of business, resulted in uncertainty with respect to SOR accuracy at any given moment in time. We continue to be reminded that it is impractical to expect all supply chain participants to have completed their due diligence procedures or even to be at the same stage of completion. Accordingly, our goal at this point, as reflected in our multi-phase due diligence efforts, is to get all suppliers to demonstrate that they are on the right path to obtain and provide to Cree complete and accurate SOR data. We believe that this will enable us in future years to better determine the facilities used to process the necessary conflict minerals used in the assemblies, components, and materials supplied to us, the country of origin of the necessary conflict minerals in those items, and the mine or location of origin with the greatest possible specificity.
Due Diligence Results
We received responses from the majority of our suppliers known to be in scope. We reviewed the responses against the minimum criteria we developed to determine which ones required further assistance to progress through Phase 3. The CSP and Cree worked directly with the suppliers that required further assistance to obtain revised responses or a commitment to meet the minimum criteria within a reasonable period of time.
Of the responses received, most of our suppliers met our minimum criteria for Phase 1. Of the suppliers contacted for additional information and clarification, a significant percentage provided sufficient information in Phase 2 to validate the accuracy of the survey responses. Further, during our evaluation in Phase 3, Cree determined that the conclusions reached by the CSP in Phase 2 were correct in almost all cases and that most of the smelters could be validated and accurately classified.
Despite our efforts, our due diligence measures can provide only reasonable, not absolute, assurances regarding the source and chain of custody of the necessary conflict minerals because we
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are relying on source information provided by our suppliers, many of whom in turn obtained the information from their suppliers. We also are relying on information obtained and disseminated by independent third party audit programs, and such sources of information may provide inaccurate or incomplete information.
Additionally, a majority of the responses that included SOR data provided data at a company level as opposed to a product level. We were therefore unable to determine with certainty that the 3TGs reported by these suppliers were contained in assemblies, components, or materials actually supplied to us in 2016. None of the respondents, however, provided information that the necessary conflict minerals used in the assemblies, components, and materials they supplied to Cree were known to have directly or indirectly financed or benefited armed groups in the Covered Countries.
Table 2 lists the number of known and verified SORs identified by our suppliers as potentially having processed the necessary conflict minerals in each of Cree’s specific business units.
Table 2
| Cree Business Unit | Number of SORs* |
| LED Lighting Products | 305 |
| LED Products | 303 |
| Power & RF Products | 305 |
*It should be noted that the number of SORs in each Cree business unit is inflated from the actual number that would have provided necessary conflict minerals to Cree because most suppliers are reporting at a company level instead of a product level.
Table 3 below lists the SORs identified by our suppliers as potentially having processed the necessary conflict minerals in Cree’s products that are known and verified by the CFSI.
Table 3
| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 1 | Gold | Abington Reldan Metals, LLC | United States Of America |
| 2 | Gold | Advanced Chemical Company* | United States Of America |
| 3 | Gold | Aida Chemical Industries Co., Ltd.* | Japan |
| 4 | Gold | Al Etihad Gold LLC* | United Arab Emirates |
| 5 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | Germany |
| 6 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| 7 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | Brazil |
| 8 | Gold | Argor-Heraeus S.A.* | Switzerland |
| 9 | Gold | Asahi Pretec Corp.* | Japan |
| 10 | Gold | Asahi Refining Canada Ltd.* | Canada |
| 11 | Gold | Asahi Refining USA Inc.* | United States Of America |
| 12 | Gold | Asaka Riken Co., Ltd.* | Japan |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 13 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| 14 | Gold | AU Traders and Refiners* | South Africa |
| 15 | Gold | Aurubis AG* | Germany |
| 16 | Gold | Bangalore Refinery^ | India |
| 17 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | Philippines |
| 18 | Gold | Boliden AB* | Sweden |
| 19 | Gold | C. Hafner GmbH + Co. KG* | Germany |
| 20 | Gold | Caridad | Mexico |
| 21 | Gold | CCR Refinery - Glencore Canada Corporation* | Canada |
| 22 | Gold | Cendres + Metaux S.A. | Switzerland |
| 23 | Gold | Chimet S.p.A.* | Italy |
| 24 | Gold | Chugai Mining | Japan |
| 25 | Gold | Daejin Indus Co., Ltd.* | Korea, Republic Of |
| 26 | Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| 27 | Gold | DODUCO GmbH* | Germany |
| 28 | Gold | Dowa* | Japan |
| 29 | Gold | DSC (Do Sung Corporation)* | Korea, Republic Of |
| 30 | Gold | Eco-System Recycling Co., Ltd.* | Japan |
| 31 | Gold | Elemetal Refining, LLC | United States Of America |
| 32 | Gold | Emirates Gold DMCC* | United Arab Emirates |
| 33 | Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| 34 | Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China |
| 35 | Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| 36 | Gold | Geib Refining Corporation* | United States Of America |
| 37 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | China |
| 38 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| 39 | Gold | Guangdong Jinding Gold Limited | China |
| 40 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| 41 | Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| 42 | Gold | Heimerle + Meule GmbH* | Germany |
| 43 | Gold | Heraeus Metals Hong Kong Ltd.* | China |
| 44 | Gold | Heraeus Precious Metals GmbH & Co. KG* | Germany |
| 45 | Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| 46 | Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of |
| 47 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | China |
| 48 | Gold | Ishifuku Metal Industry Co., Ltd.* | Japan |
| 49 | Gold | Istanbul Gold Refinery* | Turkey |
| 50 | Gold | Japan Mint* | Japan |
| 51 | Gold | Jiangxi Copper Co., Ltd.* | China |
| 52 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant* | Russian Federation |
| 53 | Gold | JSC Uralelectromed* | Russian Federation |
| 54 | Gold | JX Nippon Mining & Metals Co., Ltd.* | Japan |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 55 | Gold | Kaloti Precious Metals | United Arab Emirates |
| 56 | Gold | Kazakhmys Smelting LLC | Kazakhstan |
| 57 | Gold | Kazzinc* | Kazakhstan |
| 58 | Gold | Kennecott Utah Copper LLC* | United States Of America |
| 59 | Gold | KGHM Polska Miedz Spolka Akcyjna^ | Poland |
| 60 | Gold | Kojima Chemicals Co., Ltd.* | Japan |
| 61 | Gold | Korea Zinc Co., Ltd.* | Korea, Republic Of |
| 62 | Gold | Kyrgyzaltyn JSC* | Kyrgyzstan |
| 63 | Gold | L'azurde Company For Jewelry | Saudi Arabia |
| 64 | Gold | Lingbao Gold Co., Ltd. | China |
| 65 | Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| 66 | Gold | LS-NIKKO Copper Inc.* | Korea, Republic Of |
| 67 | Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| 68 | Gold | Materion* | United States Of America |
| 69 | Gold | Matsuda Sangyo Co., Ltd.* | Japan |
| 70 | Gold | Metalor Technologies (Hong Kong) Ltd.* | China |
| 71 | Gold | Metalor Technologies (Singapore) Pte., Ltd.* | Singapore |
| 72 | Gold | Metalor Technologies (Suzhou) Ltd.* | China |
| 73 | Gold | Metalor Technologies S.A.* | Switzerland |
| 74 | Gold | Metalor USA Refining Corporation* | United States Of America |
| 75 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V.* | Mexico |
| 76 | Gold | Mitsubishi Materials Corporation* | Japan |
| 77 | Gold | Mitsui Mining and Smelting Co., Ltd.* | Japan |
| 78 | Gold | MMTC-PAMP India Pvt., Ltd.* | India |
| 79 | Gold | Modeltech Sdn Bhd^ | Malaysia |
| 80 | Gold | Morris and Watson | New Zealand |
| 81 | Gold | Moscow Special Alloys Processing Plant* | Russian Federation |
| 82 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey |
| 83 | Gold | Navoi Mining and Metallurgical Combinat^ | Uzbekistan |
| 84 | Gold | Nihon Material Co., Ltd.* | Japan |
| 85 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria |
| 86 | Gold | Ohura Precious Metal Industry Co., Ltd.* | Japan |
| 87 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | Russian Federation |
| 88 | Gold | OJSC Novosibirsk Refinery* | Russian Federation |
| 89 | Gold | PAMP S.A.* | Switzerland |
| 90 | Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| 91 | Gold | Prioksky Plant of Non-Ferrous Metals* | Russian Federation |
| 92 | Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia |
| 93 | Gold | PX Precinox S.A.* | Switzerland |
| 94 | Gold | Rand Refinery (Pty) Ltd.* | South Africa |
| 95 | Gold | Remondis Argentia B.V. | Netherlands |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 96 | Gold | Republic Metals Corporation* | United States Of America |
| 97 | Gold | Royal Canadian Mint* | Canada |
| 98 | Gold | SAAMP | France |
| 99 | Gold | Sabin Metal Corp. | United States Of America |
| 100 | Gold | SAFINA A.S.^ | Czech Republic |
| 101 | Gold | Sai Refinery | India |
| 102 | Gold | Samduck Precious Metals* | Korea, Republic Of |
| 103 | Gold | Samwon Metals Corp. | Korea, Republic Of |
| 104 | Gold | SAXONIA Edelmetalle GmbH* | Germany |
| 105 | Gold | Schone Edelmetaal B.V.* | Netherlands |
| 106 | Gold | SEMPSA Joyeria Plateria S.A.* | Spain |
| 107 | Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| 108 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | China |
| 109 | Gold | Sichuan Tianze Precious Metals Co., Ltd.* | China |
| 110 | Gold | Singway Technology Co., Ltd.* | Taiwan, Province Of China |
| 111 | Gold | So Accurate Group, Inc. | United States Of America |
| 112 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | Russian Federation |
| 113 | Gold | Solar Applied Materials Technology Corp.* | Taiwan, Province Of China |
| 114 | Gold | Sudan Gold Refinery | Sudan |
| 115 | Gold | Sumitomo Metal Mining Co., Ltd.* | Japan |
| 116 | Gold | T.C.A S.p.A* | Italy |
| 117 | Gold | Tanaka Kikinzoku Kogyo K.K.* | Japan |
| 118 | Gold | The Refinery of Shandong Gold Mining Co., Ltd.* | China |
| 119 | Gold | Tokuriki Honten Co., Ltd.* | Japan |
| 120 | Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| 121 | Gold | Tony Goetz NV^ | Belgium |
| 122 | Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| 123 | Gold | Torecom* | Korea, Republic Of |
| 124 | Gold | Umicore Brasil Ltda.* | Brazil |
| 125 | Gold | Umicore Precious Metals Thailand* | Thailand |
| 126 | Gold | Umicore S.A. Business Unit Precious Metals Refining* | Belgium |
| 127 | Gold | United Precious Metal Refining, Inc.* | United States Of America |
| 128 | Gold | Universal Precious Metals Refining Zambia | Zambia |
| 129 | Gold | Valcambi S.A.* | Switzerland |
| 130 | Gold | Western Australian Mint (T/a The Perth Mint)* | Australia |
| 131 | Gold | WIELAND Edelmetalle GmbH* | Germany |
| 132 | Gold | Yamamoto Precious Metal Co., Ltd.* | Japan |
| 133 | Gold | Yokohama Metal Co., Ltd.* | Japan |
| 134 | Gold | Yunnan Copper Industry Co., Ltd. | China |
| 135 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China |
| 136 | Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China |
| 137 | Tantalum | Conghua Tantalum and Niobium Smeltry* | China |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 138 | Tantalum | D Block Metals, LLC* | United States Of America |
| 139 | Tantalum | Duoluoshan* | China |
| 140 | Tantalum | Exotech Inc.* | United States Of America |
| 141 | Tantalum | F&X Electro-Materials Ltd.* | China |
| 142 | Tantalum | FIR Metals & Resource Ltd.* | China |
| 143 | Tantalum | Global Advanced Metals Aizu* | Japan |
| 144 | Tantalum | Global Advanced Metals Boyertown* | United States Of America |
| 145 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | China |
| 146 | Tantalum | H.C. Starck Co., Ltd.* | Thailand |
| 147 | Tantalum | H.C. Starck Hermsdorf GmbH* | Germany |
| 148 | Tantalum | H.C. Starck Inc.* | United States Of America |
| 149 | Tantalum | H.C. Starck Ltd.* | Japan |
| 150 | Tantalum | H.C. Starck Smelting GmbH & Co. KG* | Germany |
| 151 | Tantalum | H.C. Starck Tantalum and Niobium GmbH* | Germany |
| 152 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | China |
| 153 | Tantalum | Hi-Temp Specialty Metals, Inc.* | United States Of America |
| 154 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | China |
| 155 | Tantalum | Jiangxi Tuohong New Raw Material* | China |
| 156 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China |
| 157 | Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited* | China |
| 158 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | China |
| 159 | Tantalum | KEMET Blue Metals* | Mexico |
| 160 | Tantalum | KEMET Blue Powder* | United States Of America |
| 161 | Tantalum | King-Tan Tantalum Industry Ltd.* | China |
| 162 | Tantalum | LSM Brasil S.A.* | Brazil |
| 163 | Tantalum | Metallurgical Products India Pvt., Ltd.* | India |
| 164 | Tantalum | Mineracao Taboca S.A.* | Brazil |
| 165 | Tantalum | Mitsui Mining and Smelting Co., Ltd.* | Japan |
| 166 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | China |
| 167 | Tantalum | NPM Silmet AS* | Estonia |
| 168 | Tantalum | Power Resources Ltd.* | Macedonia, The Former Yugoslav Republic Of |
| 169 | Tantalum | QuantumClean* | United States Of America |
| 170 | Tantalum | Resind Industria e Comercio Ltda.* | Brazil |
| 171 | Tantalum | RFH Tantalum Smeltry Co., Ltd.* | China |
| 172 | Tantalum | Solikamsk Magnesium Works OAO* | Russian Federation |
| 173 | Tantalum | Taki Chemical Co., Ltd.* | Japan |
| 174 | Tantalum | Telex Metals* | United States Of America |
| 175 | Tantalum | Tranzact, Inc.* | United States Of America |
| 176 | Tantalum | Ulba Metallurgical Plant JSC* | Kazakhstan |
| 177 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | China |
| 178 | Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.* | China |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 179 | Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd.* | China |
| 180 | Tin | Alpha* | United States Of America |
| 181 | Tin | An Thai Minerals Co., Ltd. | Viet Nam |
| 182 | Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| 183 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China |
| 184 | Tin | China Tin Group Co., Ltd.* | China |
| 185 | Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
| 186 | Tin | Cooperativa Metalurgica de Rondonia Ltda.* | Brazil |
| 187 | Tin | CV Ayi Jaya* | Indonesia |
| 188 | Tin | CV Dua Sekawan* | Indonesia |
| 189 | Tin | CV Gita Pesona* | Indonesia |
| 190 | Tin | CV Serumpun Sebalai* | Indonesia |
| 191 | Tin | CV Tiga Sekawan* | Indonesia |
| 192 | Tin | CV United Smelting* | Indonesia |
| 193 | Tin | CV Venus Inti Perkasa* | Indonesia |
| 194 | Tin | Dowa* | Japan |
| 195 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company^ | Viet Nam |
| 196 | Tin | Elmet S.L.U.* | Spain |
| 197 | Tin | EM Vinto* | Bolivia (Plurinational State Of) |
| 198 | Tin | Estanho de Rondonia S.A. | Brazil |
| 199 | Tin | Fenix Metals* | Poland |
| 200 | Tin | Gejiu Fengming Metallurgy Chemical Plant* | China |
| 201 | Tin | Gejiu Jinye Mineral Company* | China |
| 202 | Tin | Gejiu Kai Meng Industry and Trade LLC^ | China |
| 203 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | China |
| 204 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.^ | China |
| 205 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| 206 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant* | China |
| 207 | Tin | HuiChang Hill Tin Industry Co., Ltd.* | China |
| 208 | Tin | Huichang Jinshunda Tin Co., Ltd.^ | China |
| 209 | Tin | Jiangxi Ketai Advanced Material Co., Ltd.* | China |
| 210 | Tin | Magnu's Minerais Metais e Ligas Ltda.* | Brazil |
| 211 | Tin | Malaysia Smelting Corporation (MSC)* | Malaysia |
| 212 | Tin | Melt Metais e Ligas S.A.* | Brazil |
| 213 | Tin | Metallic Resources, Inc.* | United States Of America |
| 214 | Tin | Metallo-Chimique N.V.* | Belgium |
| 215 | Tin | Mineracao Taboca S.A.* | Brazil |
| 216 | Tin | Minsur* | Peru |
| 217 | Tin | Mitsubishi Materials Corporation* | Japan |
| 218 | Tin | Modeltech Sdn Bhd^ | Malaysia |
| 219 | Tin | Nankang Nanshan Tin Manufactory Co., Ltd.^ | China |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 220 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| 221 | Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand |
| 222 | Tin | O.M. Manufacturing Philippines, Inc.* | Philippines |
| 223 | Tin | Operaciones Metalurgical S.A.* | Bolivia (Plurinational State Of) |
| 224 | Tin | PT Aries Kencana Sejahtera* | Indonesia |
| 225 | Tin | PT Artha Cipta Langgeng* | Indonesia |
| 226 | Tin | PT ATD Makmur Mandiri Jaya* | Indonesia |
| 227 | Tin | PT Babel Inti Perkasa* | Indonesia |
| 228 | Tin | PT Bangka Prima Tin* | Indonesia |
| 229 | Tin | PT Bangka Tin Industry* | Indonesia |
| 230 | Tin | PT Belitung Industri Sejahtera* | Indonesia |
| 231 | Tin | PT Bukit Timah* | Indonesia |
| 232 | Tin | PT DS Jaya Abadi* | Indonesia |
| 233 | Tin | PT Eunindo Usaha Mandiri* | Indonesia |
| 234 | Tin | PT Inti Stania Prima* | Indonesia |
| 235 | Tin | PT Karimun Mining* | Indonesia |
| 236 | Tin | PT Kijang Jaya Mandiri* | Indonesia |
| 237 | Tin | PT Lautan Harmonis Sejahtera* | Indonesia |
| 238 | Tin | PT Menara Cipta Mulia* | Indonesia |
| 239 | Tin | PT Mitra Stania Prima* | Indonesia |
| 240 | Tin | PT O.M. Indonesia* | Indonesia |
| 241 | Tin | PT Panca Mega Persada* | Indonesia |
| 242 | Tin | PT Prima Timah Utama* | Indonesia |
| 243 | Tin | PT Refined Bangka Tin* | Indonesia |
| 244 | Tin | PT Sariwiguna Binasentosa* | Indonesia |
| 245 | Tin | PT Stanindo Inti Perkasa* | Indonesia |
| 246 | Tin | PT Sukses Inti Makmur* | Indonesia |
| 247 | Tin | PT Sumber Jaya Indah* | Indonesia |
| 248 | Tin | PT Timah (Persero) Tbk Kundur* | Indonesia |
| 249 | Tin | PT Timah (Persero) Tbk Mentok* | Indonesia |
| 250 | Tin | PT Tinindo Inter Nusa* | Indonesia |
| 251 | Tin | PT Tommy Utama* | Indonesia |
| 252 | Tin | Resind Industria e Comercio Ltda.* | Brazil |
| 253 | Tin | Rui Da Hung* | Taiwan, Province Of China |
| 254 | Tin | Soft Metais Ltda.* | Brazil |
| 255 | Tin | Thaisarco* | Thailand |
| 256 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| 257 | Tin | VQB Mineral and Trading Group JSC* | Viet Nam |
| 258 | Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil |
| 259 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | China |
| 260 | Tin | Yunnan Tin Company Limited* | China |
| 261 | Tungsten | A.L.M.T. TUNGSTEN Corp.* | Japan |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 262 | Tungsten | ACL Metais Eireli^ | Brazil |
| 263 | Tungsten | Asia Tungsten Products Vietnam Ltd.* | Viet Nam |
| 264 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | China |
| 265 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | China |
| 266 | Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China |
| 267 | Tungsten | Fujian Jinxin Tungsten Co., Ltd.* | China |
| 268 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | China |
| 269 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China |
| 270 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China |
| 271 | Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China |
| 272 | Tungsten | Global Tungsten & Powders Corp.* | United States Of America |
| 273 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | China |
| 274 | Tungsten | H.C. Starck Smelting GmbH & Co. KG* | Germany |
| 275 | Tungsten | H.C. Starck Tungsten GmbH* | Germany |
| 276 | Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China |
| 277 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | China |
| 278 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | China |
| 279 | Tungsten | Hydrometallurg, JSC* | Russian Federation |
| 280 | Tungsten | Japan New Metals Co., Ltd.* | Japan |
| 281 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | China |
| 282 | Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China |
| 283 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | China |
| 284 | Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| 285 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | China |
| 286 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China |
| 287 | Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | China |
| 288 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | China |
| 289 | Tungsten | Kennametal Fallon* | United States Of America |
| 290 | Tungsten | Kennametal Huntsville* | United States Of America |
| 291 | Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China |
| 292 | Tungsten | Moliren Ltd.* | Russian Federation |
| 293 | Tungsten | Niagara Refining LLC* | United States Of America |
| 294 | Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | Viet Nam |
| 295 | Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines |
| 296 | Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | China |
| 297 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | Viet Nam |
| 298 | Tungsten | Unecha Refractory metals plant* | Russian Federation |
| 299 | Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* | Viet Nam |
| 300 | Tungsten | Wolfram Bergbau und Hutten AG* | Austria |
| 301 | Tungsten | Woltech Korea Co., Ltd.* | Korea, Republic Of |
| 302 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China |
| 303 | Tungsten | Xiamen Tungsten Co., Ltd.* | China |
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| # | Mineral | Smelter or Refiner Facility Name | Country Location of Smelter |
| 304 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | China |
| 305 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | China |
* CFSI Compliant Smelters/refiners as of May 18, 2017
^ CFSI Active Smelters/refiners as of May 18, 2017
Based upon the RCOI data made available from the CFSI, the countries of origin of the conflict minerals sourced and processed by the CFS-compliant smelters and refiners identified as potentially being in Cree’s product supply chains may include, but are not necessarily limited to, the following:
Australia, Austria, Belgium, Bolivia (Plurinational State Of), Brazil, Canada, China, Czech Republic, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Republic Of, Kyrgyzstan, Macedonia, The Former Yugoslav Republic Of [Macedonia], Malaysia, Mexico, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Province Of China, Thailand, Turkey, United Arab Emirates, United States Of America, Uzbekistan, Viet Nam, Zambia and Zimbabwe.
We are not including any country of origin information relating to other smelters and refiners identified as potentially being in Cree’s product supply chains because we do not have reliable third party audit results, and we have not completed our due diligence process with respect to, these facilities.
This CMR describes Cree’s efforts to determine the SOR and the country of origin of the necessary conflict minerals in our products manufactured in 2016 with the greatest possible specificity. In response to our RCOI inquiry, our suppliers identified a total of 305 known and verified SORs that may have processed the necessary conflict minerals contained in the materials provided to Cree.
Based on the information obtained in our due diligence process, we have no reason to believe that any of these 305 SORs directly or indirectly finance or benefit armed groups in the Covered Countries. Since this does not reflect all of the SORs in our product supply chains, however, we are not in a position to conclude that all of the necessary conflict minerals in our products were obtained from conflict-free sources.
While we have not yet succeeded in obtaining a complete and accurate list of SORs for all of our products that include necessary conflict minerals, we believe that we have made good progress given the current state of the data available to us and the relative lack of sophistication of certain portions of our supply chain with respect to the requirements of the Rule.
Steps to Mitigate Risk
The previous parts of this CMR detail the steps taken in 2016 to mitigate risk. In the future, we plan to take or continue taking the following actions to improve the due diligence conducted on our supply chain to further mitigate any risk that the necessary 3TGs in our products could finance or
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benefit armed groups in the Covered Countries:
a. Leverage our direct suppliers that can most effectively and most directly mitigate the identified risks;
b. Continue to be an active CFSI member and, as a member, support SOR and recycler outreach programs by sending letters and/or emails to them explaining the importance of audit certification;
c. Work with upstream distributors in our supply chain and develop best practices to improve the quality and reporting of RCOI data;
d. Continue to strengthen engagement with relevant suppliers and to provide training, as appropriate, to help them understand and comply with Cree requirements related to 3TG minerals under the Rule;
e. Continue to seek qualitative improvements in supplier and smelter due diligence of conflict minerals;
f. Continue to seek qualitative improvements in supplier and smelter due diligence of conflict minerals; and
g. Monitor to determine if any additional changes in our procurement process are needed to improve visibility to necessary 3TGs in the assemblies, components, and materials purchased.
During the fifth year of Cree’s conflict minerals program, the Company will continue its focus on obtaining complete and reliable SOR and country of origin data by requiring suppliers to provide in a timely manner accurate smelter identification numbers and supplemental information that will allow Cree to determine the correlation between the identified SORs, countries of origin, and the assemblies, components, and materials supplied to Cree.
The Cree logo is a trademark of Cree, Inc.
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