Exhibit 1.01
DSP Group, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2017
Overview
This report has been prepared by DSP Group, Inc. (the “Company” or “DSP Group”) pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended. As permitted by the Rule, this report has not been subject to an independent private sector audit. DSP Group’s Conflict Minerals program and process are aimed at enabling safe sourcing so as to enhance the observance of human rights without eliminating sourcing from the DRC and Covered Countries. The implementation of our Conflict Minerals program is in line with the OECD Guidelines.
Applicability of the Conflict Minerals Rule to the Company
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (the “Conflict Minerals”). The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As per the rule, if a company has a reason to believe the minerals originated from the Covered Countries it should perform supply chain due diligence.
The Company is a leading global provider of wireless chipset solutions for converged communications. Delivering semiconductor system solutions with software and reference designs, DSP Group enables original equipment manufacturers, original design manufacturers, consumer electronics manufacturers and service providers to cost-effectively develop new revenue-generating products with fast time to market. At the forefront of semiconductor innovation and operational excellence for over two decades, DSP Group provides a broad portfolio of wireless chipsets integrating DECT (Digital Enhanced Cordless Telecommunications) and/CAT-iq (Cordless Advanced Technology - Internet Quality), ULE (Ultra Low Energy), Wi-Fi, PSTN (Public Switched Telephone Network), HDClear™ intelligent voice enhancement, always on, background noise elimination and speech recognition accuracy enhancement, video and VoIP (Voice over Internet Protocol) technologies. The Company sells its products primarily through distributors and directly to OEMs and ODMs, which incorporate its products into consumer products for the worldwide residential and wireless communications markets, and enterprise products for the worldwide office communications market.
The performance and functionality requirements imposed by the Company’s products (collectively, the “Subject Products”) require the use of advanced or sensitive materials that include a certain amount of tin, tantalum, tungsten and gold (“3TG”).
Supply Chain Overview
The Company conducted an analysis of whether the Conflict Minerals are necessary to the functionality or production of our products, and found that a certain amount of 3TG is necessary to the functionality or production of the Subject Products. However, the Company is a fabless company and does not manufacture any products. Therefore, it does not purchase any 3TG for the components within the Subject Products directly from mines, smelters or refiners. Rather, the Company contracts with various semiconductor manufacturers to manufacture its products, and they acquire the components necessary for the manufacture of the Subject Products from suppliers. The Company must therefore rely on its direct suppliers (which include its manufacturers) to provide information regarding the origins of the 3TG. The Company has relationships only with its direct suppliers but there are generally multiple tiers between the 3TG mines and its direct suppliers. Therefore, the Company relies on its direct suppliers to work with their downstream suppliers so they may provide the Company with accurate information about the origins of the 3TG in the Subject Products. The Company requires its direct suppliers to provide it with the necessary 3TG information.
Reasonable Country of Origin Inquiry
Our reasonable country of origin inquiry (“RCOI”) efforts have been an integral part of the Company’s due diligence process. The purpose of this phase is to determine whether the Conflict Minerals that are necessary to the functionality or production of our products are “DRC Conflict Free.” The Company identified the relevant direct suppliers for the RCOI process based on a list that was prepared by the Company’s production planning group. Additional review was performed by the engineering and purchasing team along with the Company’s Corporate Vice President of Operations. The total number of suppliers was ten,, which was then segmented into the following categories according to the type of material each supplier provides: Fab (five suppliers), Assembly and Bumping (four suppliers) and Modules (one supplier). The ten suppliers on the list were examined by the engineering and purchasing teams to determine if they provide components that contain Conflict Minerals. The result of the investigation was that all ten suppliers provide components that contain, to some extent, Conflict Minerals. In addition, the Company found that the number of smelters or refiners (“SORs”) that provided conflict minerals from 100% recycled or scrap sources stood at 108 SORs, or 45% of all SORs (out of 240 SORs), and the number of SORs that sourced conflict minerals from outside the Covered Countries stood at 122 SORs, or 50.83% of all SORs (out of 240 SORs).
Because only ten direct suppliers were identified by the Company as in-scope vendors for Conflict Mineral regulatory purposes, the Company contacted all of those direct suppliers (such direct suppliers are collectively referred to herein as the “Surveyed Suppliers”).
The Company requested that all Surveyed Suppliers provide information regarding the origins of the 3TG and identified smelters and refiners using the most current template developed by the Responsible Minerals Initiative (RMI), formerly the Conflict Free Sourcing Initiative (CFSI)., known as the Conflict Minerals Reporting Template (the “CMRT”), revision 5.10. The Company believes that requesting the Surveyed Suppliers to complete the CMRTs represents its reasonable best efforts to determine the mines or locations of origin of 3TG in its supply chain. As part of our annual meeting with our suppliers, we review their Conflict Minerals materials and endeavor to educate them on best practices for conducting a supply chain inquiry.
The Company’s supplier engagement process included solicitation of survey responses from all Surveyed Suppliers and an assessment of such suppliers’ responses, including the identification of inconsistent, incomplete or inaccurate responses. The Company received completed CMRTs from all Surveyed Suppliers and the response rate from all Surveyed Suppliers was 100%. In addition, we performed a supplier follow up, including an analysis of their submission compared to our expectations. We also compared suppliers’ responses against the list of facilities that received a "Conflict Free" designation by the RMI and documented Country of Origin information.
According to the findings of the RCOI and conclusion of our RCOI efforts, the Company conducted due diligence activities and detailed its findings in this Conflict Minerals Report. It should be noted that there is an overlap between the due diligence efforts and the RCOI results.
Design of Due Diligence
The Company’s due diligence measures have been designed to conform, in all material respects, with the due diligence framework presented by The Organization for Economic Co-operation and Development (“OECD”) in the publication OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing and the related supplements for 3TG.
Due Diligence Performed
Pursuant to the Rule, the Company performed due diligence on the source and origins of the 3TG in the Subject Products.
The due diligence measures the Company performed are presented below in accordance with the five-step framework established by the OECD.
Step 1. Establish Strong Company Management Systems
Conflict Minerals Policy
The Company has adopted a conflict minerals policy related to its sourcing of Conflicts Minerals. The Company believes that its commitment to integrity and citizenship extends to its worldwide supply base. As part of the Company’s Code of Business Conduct and Ethics, The Company is committed to sourcing its products responsibly, and it expects its direct suppliers to, source materials from responsible suppliers. The Company has communicated its policy and due diligence efforts to its suppliers and employees. The Company bases its efforts on the RMI’s materials to improve the traceability of minerals and ensure responsible sourcing. As mentioned in our policy, while working with the Surveyed Suppliers and when the Company believes it is necessary, the Company asks those direct suppliers to provide reasonable proof of the due diligence performed in order to support the country of origin certification and any other information provided by those direct suppliers.
The Company’s conflict minerals policy is publically available in the governance section of the Investor Relations page of the Company’s website at: http://ir.dspg.com/phoenix.zhtml?c=101665&p=irol-govhighlights . The Company endeavors to regularly communicate the substance of the policy to its relevant direct suppliers and employees.
Internal Team
The Company has established a management system to support supply chain due diligence related to the 3TG. The Company’s management system includes an executive steering committee sponsored by the senior responsible executive, and a team of subject matter experts from functions such as supplier management, engineering, finance and law. The team of subject matter experts is responsible for implementing the Company’s conflict minerals compliance strategy and is led by the Corporate Vice President of Operations.
Control Systems
Controls include a company-wide code of business conduct and ethics that outlines expected behaviors for all of the Company’s employees in a number of subject areas, including the Company’s relationships with its direct suppliers.
In addition, the Company has adopted the RMI's reporting template, i.e. the CMRT, and is using a systematic managing tool for tracking and managing direct suppliers’ responses.
Maintain Records
The Company has adopted a process to maintain business records relating to 3TG due diligence, including retention of records of the Company’s due diligence processes, findings and resulting decisions for a period of at least 5 years.
Supplier Engagement
The Company’s supplier engagement team continues to hold meetings to discuss best practices among its direct suppliers. The Company also requires its direct suppliers to provide it with the necessary 3TG information. The Company holds annual meetings with suppliers, in which we review their Conflict Minerals materials and endeavor to educate them on best practices for conducting a supply chain inquiry, thereby endeavor to help facilitate capacity building and partnerships with these suppliers.
Grievance Mechanism
The Company has processes to listen to and act on concerns expressed by employees, suppliers and other stakeholders regarding possible improper or unethical business practices or violations of the Company’s stated policies. The Company’s Conflict Minerals policy includes a grievance and reporting mechanism to enable concerns and violations of such policy to be reported to the Chairman of Company’s Board of Directors or the Company’s Chief Financial Officer.
Step 2. Identify and Assess Risks in the Supply Chain
The Company identified ten suppliers whose products may contain 3TG.
The Company conducted a supply chain survey using the last revision of the CMRT (5.10). The Company reviewed all of the Surveyed Suppliers’ responses, against common criteria such as completeness, accuracy and consistency to determine whether further engagement was necessary. Some responses included incomplete responses as well as inconsistencies and inaccuracies within the data reported by those direct suppliers. In such cases, the Company worked directly with the Surveyed Suppliers in an effort to secure revised responses. The Company performed a comparison of smelters and refiners identified by the supply chain survey against the list of facilities that received a "Conflict Free" designation by RMI’s Responsible Mineral Assurance Process (RMAP). Through this process, the Company has identified, to the best of its efforts, the smelters/refiners in its supply chain and country of origin information for the smelters and refiners identified by the supply chain survey.
Part of the Company’s findings were that all of the Surveyed Suppliers have adopted a conflict minerals policy and have implemented due diligence measures for conflict free sourcing.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
Due diligence within the Company is an on-going process and the Company is continuously working to improve its due diligence processes with respect to 3TG. Below is a non-exhaustive list of implementation steps:
• | The Company maintains a risk management plan to respond to identified risks. As part of the plan, and in order to ensure responsible sourcing throughout its supply chain, we require our suppliers to identify all smelters in their supply chain by name and to provide an updated CMRT containing their company’s response. |
• | The Company engages in regular ongoing risk assessment, largely relying on direct suppliers’ annual data submissions, as well as, where appropriate, targeted follow-up activities, such as (i) contacting direct suppliers whose responses were identified as incomplete, inconsistent or inaccurate, (ii) escalating non-responsive direct suppliers to higher level executives within the Company, (iii) comparing smelters/refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation as per the RMI and (iv) for those smelters that have not received a “conflict free” designation, the Company requests that they provide a risk mitigation plan. |
• | In cases where the Company finds uncertified smelters in its suppliers’ responses, it follows up with the supplier, asking for further clarifications or corrective action plans. |
• | The Company has established procedures for employees, stockholders, direct suppliers, and customers to communicate concerns about the Company’s policies. |
• | Senior management is briefed about the Company’s due diligence efforts. Senior management includes, among others: CEO, CFO and Corporate VP of Operations. |
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
The Company does not manufacture any products and is a downstream consumer of 3TG. The Company does not directly purchase 3TG from smelters or refiners and is many steps removed from smelters and refiners who provide minerals and ores. The Company’s due diligence efforts relied on freely available information received by cross-industry initiatives such as those led by the RMI, including the RMAP audit program, to perform validation checks of its smelter or refiner list.
Step 5. Report Annually on Supply Chain Due Diligence
This Conflict Minerals Report constitutes the Company’s annual report on its Conflicts Minerals due diligence, is publicly available in the governance section of the Investor Relations page of the Company’s website at: http://ir.dspg.com/phoenix.zhtml?c=101665&p=irol-govhighlights and is filed with the U.S. Securities and Exchange Commission.
Results of Assessment
The Company surveyed all of its direct suppliers, which amounted to ten suppliers in the aggregate. Those suppliers are referred to as Surveyed Suppliers in this Conflict Minerals Report. The survey response rate among the Surveyed Suppliers was 100%.
Based on information from the Surveyed Suppliers pursuant to the due diligence inquiry, below are the countries of origin of the 3TG in the Subject Products:
Conflict Mineral | Country of Origin may include the following | |
Gold | Australia, United Status of America, Japan, Brazil, Republic of Korea, Indonesia, Province of Taiwan, China, Switzerland, Chile, Canada, Philippines, Peru, Argentina, Azerbaijan, Burkina Faso, Dominican Republic, Ecuador, Ghana, Guinea, Liberia, Malaysia, Mauritania, Peru, Tanzania, Guyana | |
Tantalum | Australia, Bolivia, Brazil, Burundi, Democratic Republic of Congo, Ethiopia, India, Mozambique, Namibia, Nigeria, Rwanda, Sierra Leone, Zimbabwe, United States of America, Russian Federation, Kazakhstan, Mozambique, Canada, China, Portugal, Spain, Vietnam, Germany, Japan, Thailand | |
Tin | Bolivia, Indonesia, Brazil, Malaysia, United States of America, China, Peru, Democratic Republic of Congo, Burundi, Rwanda, Uganda | |
Tungsten | China, Russian Federation, Canada, United States of America, Peru, Spain, Portugal, Bolivia, Australia, Vietnam, Mozambique, Brazil, Ethiopia, Indonesia |
In addition, the list of smelters and refiners identified by the Surveyed Suppliers as part of the Company’s due diligence process can be found in the attached Annex 1.
The Company does not gather information from the Surveyed Suppliers on a continuous, real-time basis. The Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals, since the information comes from direct and secondary suppliers and independent third party audit programs.
Further Risk Mitigation Efforts
The Company will continue to communicate its expectations and information requirements to its direct suppliers. The Company will also continue to monitor changes in circumstances that may impact the facts or its determination. The Company will continue to make inquiries with its direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. The Company expects its direct suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
Subject to the Rule, the Company intends or considers taking the following steps to improve its due diligence efforts:
• | Continue to require direct suppliers to provide the Company with the necessary 3TG information. |
• | In the event that any of the Company’s direct suppliers are found to provide the Company with Subject Products containing 3TG from sources that are not in compliance with independent third party audit programs, such as the RMI, the Company will continue to follow up with them asking for further clarification or corrective action plans. |
• | Continue to implement The Company's CM policy to the best of the Company’s abilities, namely methods of communication on CM policy to stakeholders and suppliers |
• | Continue to implement policies and management systems to support compliance with the Rule. |
The Company has provided information as of the date of this report. Subsequent events, such as the inability or unwillingness of any direct suppliers, smelters or refiners to comply with the Company’s policy and inquiries, may affect the Company’s future determinations under Rule 13p-1.
Caution Concerning Forward-Looking Statements
Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995, including, without limitation, statements concerning the additional steps that the Company intends to take to mitigate the risk that the 3TG used in the Subject Products finance or benefit armed groups. Words such as “intends,” “expects,” “plans,” “believes,” “estimates,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Other examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict, including, without limitation, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis, if at all, (2) the accuracy and reliability of the information the Company receives, and (3) political, legal and regulatory developments in the Covered Countries. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws. |
Annex 1
The following smelters and refiners were reported by our direct suppliers as being in their supply chains.
Metal
| Smelter Name
| Smelter Country
| |
Gold
| Advanced Chemical Company
| UNITED STATES OF AMERICA
| |
Gold
| Aida Chemical Industries Co., Ltd.
| JAPAN
| |
Gold
| Al Etihad Gold LLC
| 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
| AU Traders and Refiners
| SOUTH AFRICA
| |
Gold
| Aurubis AG
| GERMANY
| |
Gold
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
| PHILIPPINES
| |
Gold
| Boliden AB
| SWEDEN
| |
Gold
| C. Hafner GmbH + Co. KG
| GERMANY
| |
Gold
| CCR Refinery - Glencore Canada Corporation
| CANADA
| |
Gold
| Chimet S.p.A.
| ITALY
|
Gold
| Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | |
Gold
| DODUCO Contacts and Refining GmbH | GERMANY | |
Gold
| Dowa | JAPAN | |
Gold
| DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | |
Gold
| Eco-System Recycling Co., Ltd. | JAPAN | |
Gold
| Emirates Gold DMCC | UNITED ARAB EMIRATES | |
Gold
| Geib Refining Corporation | UNITED STATES OF AMERICA | |
Gold
| Gold Refinery of Zijin Mining Group Co., Ltd.
| CHINA | |
Gold
| Heimerle + Meule GmbH | GERMANY | |
Gold
| Heraeus Metals Hong Kong Ltd. | CHINA | |
Gold
| Heraeus Precious Metals GmbH & Co. KG | GERMANY | |
Gold
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
| CHINA | |
Gold
| Ishifuku Metal Industry Co., Ltd. | JAPAN | |
Gold
| Istanbul Gold Refinery | TURKEY | |
Gold
| Japan Mint | JAPAN | |
Gold
| Jiangxi Copper Co., Ltd. | CHINA | |
Gold
| *JSC Ekaterinburg Non-Ferrous Metal Processing Plant
| RUSSIAN FEDERATION | |
Gold
| JSC Uralelectromed | RUSSIAN FEDERATION | |
Gold
| JX Nippon Mining & Metals Co., Ltd. | JAPAN | |
Gold
| Kazzinc | KAZAKHSTAN | |
Gold
| Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | |
Gold
| Kojima Chemicals Co., Ltd. | JAPAN |
Gold
| Korea Zinc Co., Ltd.
| KOREA, REPUBLIC OF
| |
Gold
| Kyrgyzaltyn JSC
| KYRGYZSTAN
| |
Gold
| LS-NIKKO Copper Inc.
| KOREA, REPUBLIC OF
| |
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
| Moscow Special Alloys Processing Plant
| RUSSIAN FEDERATION
| |
Gold
| Nadir Metal Rafineri San. Ve Tic. A.S.
| TURKEY
| |
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
| OJSC Novosibirsk Refinery
| RUSSIAN FEDERATION
| |
Gold
| PAMP S.A.
| SWITZERLAND
| |
Gold
| Prioksky Plant of Non-Ferrous Metals
| RUSSIAN FEDERATION
| |
Gold
| PT Aneka Tambang (Persero) Tbk
| INDONESIA
| |
Gold
| PX Precinox S.A.
| SWITZERLAND
| |
Gold
| Rand Refinery (Pty) Ltd.
| SOUTH AFRICA
| |
Gold
| Republic Metals Corporation
| UNITED STATES OF AMERICA
| |
Gold
| Royal Canadian Mint
| CANADA
| |
Gold
| Samduck Precious Metals
| KOREA, REPUBLIC OF
| |
Gold
| SAXONIA Edelmetalle GmbH
| GERMANY
| |
Gold
| *Schone Edelmetaal B.V.
| NETHERLANDS
| |
Gold
| SEMPSA Joyeria Plateria S.A.
| SPAIN
| |
Gold
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
| CHINA
| |
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
| Sumitomo Metal Mining Co., Ltd.
| JAPAN
| |
Gold
| T.C.A S.p.A
| ITALY
|
Gold
| Tanaka Kikinzoku Kogyo K.K.
| JAPAN
| |
Gold
| The Refinery of Shandong Gold Mining Co., Ltd.
| CHINA
| |
Gold
| Tokuriki Honten Co., Ltd.
| JAPAN
| |
Gold
| Torecom
| KOREA, REPUBLIC OF
| |
Gold
| Umicore Brasil Ltda.
| BRAZIL
| |
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
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation
| CHINA
| |
Tantalum
| Asaka Riken Co., Ltd.
| JAPAN
| |
Tantalum
| Changsha South Tantalum Niobium Co., Ltd.
| CHINA
| |
Tantalum
| Conghua Tantalum and Niobium Smeltry
| 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
| |
Tantalum
| Guangdong Zhiyuan New Material Co., Ltd.
| CHINA
| |
Tantalum
| H.C. Starck Co., Ltd.
| THAILAND
| |
Tantalum
| H.C. Starck Hermsdorf GmbH
| GERMANY
| |
Tantalum
| H.C. Starck Inc.
| UNITED STATES OF AMERICA
| |
Tantalum
| H.C. Starck Ltd.
| JAPAN
| |
Tantalum
| H.C. Starck Smelting GmbH & Co. KG
| GERMANY
| |
Tantalum
| H.C. Starck Tantalum and Niobium GmbH
| GERMANY
| |
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 Nonferrous Metals Smelting Company Limited
| CHINA
| |
Tantalum
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
| CHINA
| |
Tantalum
| KEMET Blue Metals
| MEXICO
| |
Tantalum
| KEMET Blue Powder
| UNITED STATES OF AMERICA
| |
Tantalum
| LSM Brasil S.A.
| BRAZIL
| |
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
| Power Resources Ltd.
| MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
| |
Tantalum
| QuantumClean
| UNITED STATES OF AMERICA
| |
Tantalum
| RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
| CHINA
| |
Tantalum
| Solikamsk Magnesium Works OAO
| RUSSIAN FEDERATION
| |
Tantalum
| Taki Chemical Co., Ltd.
| JAPAN
| |
Tantalum
| Telex Metals
| UNITED STATES OF AMERICA
| |
Tantalum
| Ulba Metallurgical Plant JSC
| KAZAKHSTAN
| |
Tantalum
| XinXing HaoRong Electronic Material Co., Ltd.
| CHINA
| |
Tantalum
| *Yichun Jin Yang Rare Metal Co., Ltd.
| CHINA
| |
Tin
| Alpha
| UNITED STATES OF AMERICA
| |
Tin
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
| CHINA
| |
Tin
| China Tin Group Co., Ltd.
| CHINA
| |
Tin
| CV Ayi Jaya
| INDONESIA
| |
Tin
| CV Dua Sekawan
| INDONESIA
| |
Tin
| CV Gita Pesona
| INDONESIA
| |
Tin
| CV Serumpun Sebalai
| INDONESIA
| |
Tin
| CV Tiga Sekawan
| INDONESIA
| |
Tin
| CV United Smelting
| INDONESIA
|
Tin
| CV Venus Inti Perkasa
| INDONESIA
| |
Tin
| Dowa
| JAPAN
| |
Tin
| EM Vinto
| BOLIVIA (PLURINATIONAL STATE OF)
| |
Tin
| Fenix Metals
| POLAND
| |
Tin
| Gejiu Fengming Metallurgy Chemical Plant
| CHINA
| |
Tin
| Gejiu Jinye Mineral Company
| 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
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
| CHINA
| |
Tin
| Guanyang Guida Nonferrous Metal Smelting Plant
| CHINA
| |
Tin
| HuiChang Hill Tin Industry Co., Ltd.
| CHINA
| |
Tin
| Huichang Jinshunda Tin Co., Ltd.
| CHINA
| |
Tin
| Jiangxi Ketai Advanced Material 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
| Nankang Nanshan Tin Manufactory Co., Ltd.
| CHINA
| |
Tin
| O.M. Manufacturing (Thailand) Co., Ltd.
| THAILAND
| |
Tin
| O.M. Manufacturing Philippines, Inc.
| PHILIPPINES
| |
Tin
| Operaciones Metalurgical S.A.
| BOLIVIA (PLURINATIONAL STATE OF)
| |
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 Bangka Prima Tin
| INDONESIA
| |
Tin
| PT Bangka Tin Industry
| INDONESIA
| |
Tin
| PT Belitung Industri Sejahtera
| INDONESIA
| |
Tin
| PT Bukit Timah
| INDONESIA
| |
Tin
| PT DS Jaya Abadi
| INDONESIA
| |
Tin
| PT Eunindo Usaha Mandiri
| INDONESIA
| |
Tin
| PT Inti Stania Prima
| INDONESIA
| |
Tin
| PT Karimun Mining
| INDONESIA
| |
Tin
| PT Kijang Jaya Mandiri
| INDONESIA
| |
Tin
| PT Lautan Harmonis Sejahtera
| INDONESIA
| |
Tin
| PT Menara Cipta Mulia
| INDONESIA
|
Tin
| PT Mitra Stania Prima
| INDONESIA
| |
Tin
| PT Panca Mega Persada
| INDONESIA
| |
Tin
| PT Prima Timah Utama
| INDONESIA
| |
Tin
| PT Refined Bangka Tin
| INDONESIA
| |
Tin
| PT Sariwiguna Binasentosa
| INDONESIA
| |
Tin
| PT Stanindo Inti Perkasa
| INDONESIA
| |
Tin
| PT Sukses Inti Makmur
| INDONESIA
| |
Tin
| PT Sumber Jaya Indah
| INDONESIA
| |
Tin
| PT Timah (Persero) Tbk Kundur
| INDONESIA
| |
Tin
| PT Timah (Persero) Tbk Mentok
| INDONESIA
| |
Tin
| PT Tinindo Inter Nusa
| INDONESIA
| |
Tin
| PT Tommy Utama
| INDONESIA
| |
Tin
| Resind Industria e Comercio Ltda.
| BRAZIL
| |
Tin
| Rui Da Hung
| TAIWAN, PROVINCE OF CHINA
| |
Tin
| Soft Metais Ltda.
| BRAZIL
| |
Tin
| Thaisarco
| THAILAND
| |
Tin
| White Solder Metalurgia e Mineracao Ltda.
| BRAZIL
| |
Tin
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
| CHINA
| |
Tin
| Yunnan Tin Company Limited
| CHINA
| |
Tungsten
| A.L.M.T. TUNGSTEN Corp.
| JAPAN
| |
Tungsten
| ACL Metais Eireli
| BRAZIL
| |
Tungsten
| Asia Tungsten Products Vietnam Ltd.
| VIET NAM
| |
Tungsten
| Chenzhou Diamond Tungsten Products Co., Ltd.
| CHINA
|
Tungsten
| Chongyi Zhangyuan Tungsten Co., Ltd.
| CHINA
| |
Tungsten
| Fujian Jinxin 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 Smelting GmbH & Co. KG
| GERMANY
| |
Tungsten
| H.C. Starck Tungsten GmbH
| GERMANY
| |
Tungsten
| Hunan Chenzhou Mining Co., Ltd.
| CHINA
| |
Tungsten
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
| 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 Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
| CHINA
|
Tungsten
| Jiangxi Xinsheng Tungsten Industry Co., Ltd.
| CHINA
| |
Tungsten
| Jiangxi Yaosheng Tungsten Co., Ltd.
| CHINA
| |
Tungsten
| Kennametal Fallon
| UNITED STATES OF AMERICA
| |
Tungsten
| Kennametal Huntsville
| UNITED STATES OF AMERICA
| |
Tungsten
| Malipo Haiyu Tungsten Co., Ltd.
| CHINA
| |
Tungsten
| Niagara Refining LLC
| UNITED STATES OF AMERICA
| |
Tungsten
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
| VIET NAM
| |
Tungsten
| Philippine Chuangxin Industrial Co., Inc.
| PHILIPPINES
| |
Tungsten
| South-East Nonferrous Metal Company Limited of Hengyang City
| CHINA
| |
Tungsten
| Tejing (Vietnam) Tungsten Co., Ltd.
| VIET NAM
| |
Tungsten
| Vietnam Youngsun Tungsten Industry Co., Ltd.
| VIET NAM
| |
Tungsten
| Wolfram Bergbau und Hutten AG
| AUSTRIA
| |
Tungsten
| Woltech Korea Co., Ltd.
| KOREA, REPUBLIC OF
| |
Tungsten
| Xiamen Tungsten (H.C.) Co., Ltd.
| CHINA
| |
Tungsten
| Xiamen Tungsten Co., Ltd.
| CHINA
| |
Tungsten
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
| CHINA
| |
Tungsten
| Xinhai Rendan Shaoguan Tungsten Co., Ltd.
| CHINA
|
(*) The noted SORs were certified by the RMI's RMAP audit program up until the latest update of the list of RMAP Conformant Smelters and Refiners list in late May 2018. The noted SORs were removed from the RMAP's list close to the filing date. In line with the Company's due diligence efforts, we have followed up with the relevant suppliers that declared that they source from the noted SORs and they informed us that they have begun risk mitigation efforts with these SORs, including that they plan to discontinue sourcing from said SORs.
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