Exhibit 1.01 to Form SD
CREE, INC. CONFLICT MINERALS REPORT
For the Year Ended December 31, 2020
This Conflict Minerals Report (CMR) of Cree, Inc. (referred to collectively with its wholly-owned subsidiaries as Cree, the Company, we, us, or our) for the year ended December 31, 2020 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, and wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG originating from the Democratic Republic of the Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If an issuer has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures. This CMR has been prepared on behalf of Cree management.
This CMR is based on due diligence activities performed in good faith through May 21, 2021 for the reporting period from January 1 to December 31, 2020 (the “2020 reporting period”) and is based on information available at the time of this filing, unless otherwise indicated. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter and refiner (collectively referred to as “smelters”) data, errors or omissions by suppliers or smelters, ongoing certifications of smelters, continued guidance or amendments to the Rule, and other issues. This CMR contains forward-looking statements that reflect steps we will strive to achieve in the future as we continue to improve our responsible sourcing program. These forward-looking statements are based on current expectations and assumptions that are subject to risks and uncertainties. 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 that could cause actual results and performance to differ materially from the results and outcomes expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source Conflict Minerals, (3) internal and external resource constraints, and (4) political and regulatory developments, whether in the DRC region, the United States or elsewhere. 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 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 used in our products manufactured in 2020. In particular, we sought to determine whether any of the necessary conflict minerals in our product supply chain may have originated in the Covered Countries, and whether any conflict minerals originating in the Covered Countries directly or indirectly financed or benefited armed conflict. As used herein, the term “manufactured” includes products manufactured or contracted to be manufactured by Cree.
Because not all suppliers have provided smelter and/or 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 the assemblies, components, and minerals supplied to us. Therefore, we cannot exclude the possibility that some conflict minerals used in our products manufactured in 2020 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 2020 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 an innovator of wide bandgap semiconductor products for power and radio frequency (RF) applications. Our products are targeted for applications such as transportation, power supplies, inverters, and wireless systems.
Our continuing operations consist of our Wolfspeed business unit, which includes silicon carbide and gallium nitride (GaN) materials, power devices and RF devices based on wide bandgap semiconductor materials and silicon. Our materials products and power devices are used in electric vehicles, motor drives, power supplies, solar and transportation applications. Our materials products and RF devices are used in military communications, radar, satellite and telecommunication applications.
During the 2020 reporting period, we also designed, manufactured, and sold specialty lighting-class light emitting diode (LED) products targeted for use in indoor and outdoor lighting, electronic signs and signals and video displays. On March 1, 2021, we completed the sale of certain assets and subsidiaries comprising our former LED Products segment (the “LED Business”) to SMART Global Holdings, Inc. (“SGH”) and its wholly owned newly-created acquisition subsidiary CreeLED, Inc. (“CreeLED” and collectively with SGH, “SMART”).
The majority of our products are manufactured at our production facilities located in North Carolina, California, and Arkansas. During the 2020 reporting period, we also manufactured products for the LED Business in China. We also use contract manufacturers for certain products and aspects of product fabrication, assembly, and packaging. Additionally, we are in the process of building a silicon carbide device fabrication facility in New York.
2
Our silicon carbide 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 produced during the 2020 reporting period 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.
Table 1
| Cree Business Unit | Products | Percentage of Products that contain Conflict Minerals? | Typical Conflict Mineral Content by Weight Percentage | |||||||||||||||||
| Au | Sn | W | Ta | |||||||||||||||||
| Wolfspeed Products | Materials | 0% | NA | NA | NA | NA | ||||||||||||||
| 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% | |||||||||||||||
| LED Products* | 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% | |||||||||||||||
*Cree sold the LED Business to SMART in a transaction that closed in March 2021.
Responsible Minerals Sourcing Policy
Cree believes in the responsible sourcing of Conflict Minerals and has adopted a Responsible Minerals Sourcing Policy under which we require our suppliers to establish and maintain a publicly available policy on responsible minerals sourcing that aligns with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OEDC Guidance”) to assure that the high-risk minerals in the products they manufacture do not contribute to ongoing conflicts or human rights abuses in conflict-affected areas; design and implement due diligence frameworks and management systems consistent with OECD Guidance to achieve responsible mineral supply chains; and verify and inform Cree whether the minerals included in materials or component parts are conflict-affected or high-risk minerals. Cree also requires our suppliers to source only from smelters and refiners validated by a third-party audit program such as the Responsible Minerals Initiative’s (“RMI”) Responsible Minerals Assurance Process; the London Bullion Market Association (“LBMA”); and the Responsible Jewellery Council (“RJC”), and make reasonable efforts to remove all non-participating and non-validated smelters or refiners from Cree’s supply chain. Cree fully expects our suppliers to respond to our inquiries for reporting templates and due diligence information, and promptly implement corrective actions identified and requested by Cree. If these requirements are not met, Cree will proactively work with the supplier to further develop their capabilities in responsible mineral due diligence to ensure alignment to Cree’s supplier requirements. Cree will terminate relationships with suppliers that do not make substantive and prompt efforts to comply with our policy.
3
To view Cree’s complete Responsible Minerals Sourcing Policy, visit our webpage located at: https://www.cree.com/about/suppliers-contractors/cree-supplier-resources/conflict-minerals. With this reference we are incorporating into this CMR only our Responsible Conflict Minerals Sourcing Policy and not the entire contents of our webpage.
Description of Our RCOI Process
Cree’s scoping process included creating a master list of potential in-scope suppliers for 2020 by filtering our supplier database to remove those known to be outside the scope of the reasonable country of origin inquiry (“RCOI”), such as service providers, equipment vendors, and indirect material suppliers. The objective of filtering was to identify only the suppliers that provided to Cree items potentially containing 3TGs that were incorporated into final products in calendar year 2020.
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”) created by the RMI. The CMRT is the industry standard template developed to facilitate the transfer of information through the supply chain regarding mineral country of origin and smelters being utilized. During the RCOI, suppliers were contacted, and responses were tracked, using the CSP’s interactive cloud-based platform. Suppliers were given the option to submit their completed CMRT via email or by uploading it to a supplier-specific website on the CSP platform.
The CSP launched Cree’s 2020 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 relevant 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 greater than 99% of Cree’s in-scope suppliers responded to the RCOI, 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 “conformant” designation through an independent third-party audit of smelter/refiner management systems and sourcing practices to validate conformance with protocols of the RMI Responsible Minerals Assurance Process and current global standards.
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.”
4
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 Guidance, Third Edition, and the related Supplements for gold and for tin, tantalum and tungsten, as it relates to our position in the 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 Responsible Minerals Sourcing 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 RMI resources, on the Rule as well as by communicating, through our Responsible Minerals Sourcing 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 Responsible Minerals Sourcing Policy, which includes a requirement that the supplier must source conflict minerals originating in the Covered Countries from smelters whose due diligence practices have been validated by an independent third-party audit program, such as the RMI 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 prompting the new supplier to indicate if any product(s) sold to Cree may contain 3TG material. In
5
addition, 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/conflictminerals-form). Lastly, Cree monitors the RMI Grievance Report and discussions for any applicable issues.
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 RMI 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, RJC’s Chain-of-Custody Certification Program, and LBMA’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 Responsible Minerals Sourcing Policy, which indicates that we expect all of our suppliers to develop their own responsible mineral sourcing 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
6
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 Policy. For 2020, all known DRC sources identified in our supply chain were either RMI “conformant” 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 Responsible Minerals Assurance Process driven by the RMI and other reputable auditors. The RMI publishes a list of smelters, by conflict mineral, found to be conformant with the protocols of the RMAP. Pursuant to the RMAP, 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 RMAP, the smelter will be considered RMAP-conformant.
The RMI also makes available to its members information on the countries of origin of the conflict minerals processed by each conformant smelter. We are an active member of the RMI 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 RMAP 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 2020 to exercise due diligence on the source and chain of custody of our conflict minerals were as follows:
•communicated our Responsible Minerals Sourcing 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 RMAP-conformant;
7
•sent outreach letters to in-scope suppliers to influence and leverage, or ultimately remove SORs who are not conformant; 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 Cree any conflict minerals that are known to come from sources funding armed groups in the Covered Countries. Our Supplier Code of Conduct is located at https://www.cree.com/about/suppliers-contractors/cree-supplier-resources.
No other contents from our website are intended to be incorporated into the CMR 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 suppliers in calendar year 2020.
Our due diligence process includes data evaluation in three phases, all of which are designed to move supplier responses toward compliance with our Responsible Minerals Sourcing 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 2020 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 2020, we first reviewed prior year minimum criteria for evaluation during Phase 1 and reaffirmed the applicability for 2020. In evaluating a supplier’s CMRT, we primarily look for three things: (1) effective date—is the information in the report current; (2) completeness—are all questions reasonably answered; and (3) 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 2020 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
8
from RMI and other reputable auditors on the country of origin of the conflict minerals processed by the known SORs in Cree’s supply chain.
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 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 RMI aliases, smelter status, and mine sourcing. This step allows Cree to determine the certification status of the smelters, as provided in Table 2 below.
Due Diligence Results
We received responses from 99% 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 substantially 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 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 supplied to us in
9
2020. 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 below lists the smelters reported by our suppliers as potentially in Cree’s supply chain in the 2020 reporting period.
Table 2
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Gold | 8853 S.p.A. | ITALY | ||||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||||||
| Gold | African Gold Refinery | UGANDA | ||||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | ||||||
| Gold | Asahi Pretec Corp. | JAPAN | ||||||
| Gold | Asahi Refining Canada Ltd. | CANADA | ||||||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||||||
| Gold | Augmont Enterprises Private Limited | INDIA | ||||||
| Gold | Aurubis AG | GERMANY | ||||||
| Gold | Bangalore Refinery | INDIA | ||||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||||||
| Gold | Boliden AB | SWEDEN | ||||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||||||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | ||||||
| Gold | Caridad | MEXICO | ||||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | ||||||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | ||||||
| Gold | Chimet S.p.A. | ITALY | ||||||
| Gold | Chugai Mining | JAPAN | ||||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||||||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||||||
| Gold | Dowa | JAPAN | ||||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||||||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||||||
10
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||||||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Gold Coast Refinery | GHANA | ||||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||||
| Gold | Heimerle + Meule GmbH | GERMANY | ||||||
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | ||||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||||||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||||||
| Gold | Industrial Refining Company | BELGIUM | ||||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||||||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | Istanbul Gold Refinery | TURKEY | ||||||
| Gold | Italpreziosi | ITALY | ||||||
| Gold | JALAN & Company | INDIA | ||||||
| Gold | Japan Mint | JAPAN | ||||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||||
| Gold | Kazzinc | KAZAKHSTAN | ||||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Kundan Care Products Ltd. | INDIA | ||||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||||||
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | ||||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||||||
11
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||||
| Gold | L'Orfebre S.A. | ANDORRA | ||||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||||||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||||
| Gold | Marsam Metals | BRAZIL | ||||||
| Gold | Materion | UNITED STATES OF AMERICA | ||||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | ||||||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||||||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Gold | Morris and Watson | NEW ZEALAND | ||||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||||||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||||||
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||||||
| Gold | PAMP S.A. | SWITZERLAND | ||||||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | ||||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||||||
| Gold | PX Precinox S.A. | SWITZERLAND | ||||||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||||||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||||||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | ||||||
| Gold | Royal Canadian Mint | CANADA | ||||||
| Gold | SAAMP | FRANCE | ||||||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||||||
| Gold | Safimet S.p.A | ITALY | ||||||
| Gold | SAFINA A.S. | CZECHIA | ||||||
| Gold | Sai Refinery | INDIA | ||||||
12
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||||||
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | ||||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||||||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | ||||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||||||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||||||
| Gold | Sovereign Metals | INDIA | ||||||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||||||
| Gold | Sudan Gold Refinery | SUDAN | ||||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||||||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Gold | T.C.A S.p.A | ITALY | ||||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | ||||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||||
| Gold | TSK Pretech | KOREA, REPUBLIC OF | ||||||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||||||
| Gold | Valcambi S.A. | SWITZERLAND | ||||||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||||
| Gold | Yamakin Co., Ltd. | JAPAN | ||||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||||||
| Tantalum | AMG Brasil | BRAZIL | ||||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||||||
13
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tantalum | KEMET de Mexico | MEXICO | ||||||
| Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | ||||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||||||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||||||
| Tantalum | NPM Silmet AS | ESTONIA | ||||||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||||||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | ||||||
| Tantalum | TANIOBIS GmbH | GERMANY | ||||||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | ||||||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||||||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | ||||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||||||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||||||
| Tin | Alpha | UNITED STATES OF AMERICA | ||||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | China Tin Group Co., Ltd. | CHINA | ||||||
| Tin | CV Ayi Jaya | INDONESIA | ||||||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||||||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||||||
| Tin | Dowa | JAPAN | ||||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | ||||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | ||||||
| Tin | Fenix Metals | POLAND | ||||||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||||||
14
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||||||
| Tin | Luna Smelter, Ltd. | RWANDA | ||||||
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | ||||||
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | ||||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||||||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||||||
| Tin | Metallo Belgium N.V. | BELGIUM | ||||||
| Tin | Metallo Spain S.L.U. | SPAIN | ||||||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||||||
| Tin | Minsur | PERU | ||||||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||||||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||||||
| Tin | Pongpipat Company Limited | MYANMAR | ||||||
| Tin | Precious Minerals and Smelting Limited | INDIA | ||||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||||||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||||||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | ||||||
| Tin | PT Bangka Serumpun | INDONESIA | ||||||
| Tin | PT Bukit Timah | INDONESIA | ||||||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | ||||||
| Tin | PT Menara Cipta Mulia | INDONESIA | ||||||
| Tin | PT Mitra Stania Prima | INDONESIA | ||||||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | ||||||
| Tin | PT Prima Timah Utama | INDONESIA | ||||||
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||||||
| Tin | PT Rajehan Ariq | INDONESIA | ||||||
| Tin | PT Refined Bangka Tin | INDONESIA | ||||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | ||||||
| Tin | PT Sukses Inti Makmur | INDONESIA | ||||||
| Tin | PT Timah Tbk Kundur | INDONESIA | ||||||
15
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Tin | PT Timah Tbk Mentok | INDONESIA | ||||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||||||
| Tin | Soft Metais Ltda. | BRAZIL | ||||||
| Tin | Super Ligas | BRAZIL | ||||||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||||||
| Tin | Thaisarco | THAILAND | ||||||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tin | Yunnan Tin Company Limited | CHINA | ||||||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | A.L.M.T. Corp. | JAPAN | ||||||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | ||||||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. | CHINA | ||||||
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | ||||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||||||
16
| Mineral | Name of Smelter or Refiner | Country Location | ||||||
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||||||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Masan High-Tech Materials | VIET NAM | ||||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||||||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||||||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | ||||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||||
Based upon the RCOI data made available from the RMI, the countries of origin of the conflict minerals sourced and processed by the RMAP-conformant smelters identified as potentially being in Cree’s product supply chains may include, but are not necessarily limited to, the following:
Andorra, Australia, Austria, Belgium, Bolivia (Plurinational State of), Brazil, Canada, Chile, China, Colombia, Czechia, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Lithuania, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Republic of North Macedonia, Peru, Philippines, Poland, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan (Province of China), Thailand, Turkey, Uganda, United Arab Emirates, United States of America, Uzbekistan, Vietnam, and Zimbabwe.
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 2020 with the greatest possible specificity. In response to our RCOI inquiry, our suppliers identified a total of 313 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 313 SORs directly or indirectly finance or benefit armed groups in the Covered Countries.
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 2020 to mitigate risk. In the future, we plan to take or continue taking the following actions to improve the due diligence conducted on our
17
supply chain to further mitigate any risk that the necessary 3TGs in our products could finance or 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 RMI 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. Enhance program transparency through improved monitoring, reporting and risk reviews; 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 ninth 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.
Cree® and Wolfspeed® are registered trademarks of Cree, Inc.
18