UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D. C. 20549
FORM SD
Specialized Disclosure Report
ON Semiconductor Corporation
(Exact name of registrant as specified in its charter)
| Delaware | 000-30419 | 36-3840979 | ||
| (State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
| ON Semiconductor Corporation 5005 East McDowell Road Phoenix, Arizona |
85008 | |
| (Address of principal executive offices) | (Zip Code) |
George H. Cave
ON Semiconductor Corporation
(602) 244-6600
(Name and telephone number, including area code, of the
person to contact in connection with this report)
Check the appropriate box to indicate the rule filing pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
| SECTION 1. | CONFLICT MINERALS DISCLOSURE |
| Item 1.01. | Conflict Minerals Disclosure and Report |
Pursuant to Rule 13p-1 and Section 13(p) of the Securities Exchange Act of 1934, as amended, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Regulations”), ON Semiconductor Corporation (the “Company”) was required to make certain inquiries and perform certain due diligence with respect to any “conflict minerals” (as defined by paragraph (d)(3) of Item 1.01 of Form SD) that are necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries.
As a result of its inquiry, the Company determined that conflict minerals are necessary to the functionality of the Company’s products. After conducting a country of origin and a supply chain due diligence inquiry, the Company has been unable to conclusively determine that certain of its conflict minerals did not originate in the Democratic Republic of the Congo or an adjoining an country, or that such conflict minerals did not directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining an country. Accordingly, because of the foregoing determinations, the Company is describing its products as “DRC conflict undeterminable” as such designations exists under the Conflict Regulations.
Conflict Minerals Disclosure
The Company has filed a Conflicts Minerals Report which is attached hereto as Exhibit 1.01 and is incorporated herein by reference. Such report is also publicly available on the Company website at the following link: http://www.onsemi.com/social-responsibility.
| Item 1.02. | Exhibit |
Information concerning Conflict Minerals required by the Conflict Regulations is included in Exhibit 1.01 to this Specialized Disclosure Report on Form SD.
| SECTION 2. | EXHIBITS |
| Item 2.01. | Exhibits |
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report for the year ended December 31, 2014 as required by Items 1.01 and 1.02 of this Form. | |
2
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| ON SEMICONDUCTOR CORPORATION | ||||
| (Registrant) | ||||
| Date: May 29, 2015 | ||||
| By: | /s/ George H. Cave | |||
| George H. Cave | ||||
| Executive Vice President, General Counsel, Chief Compliance and Ethics Officer, Chief Risk Officer and Corporate Secretary | ||||
3
EXHIBIT INDEX
| Exhibit No. |
Description | |
| 1.01 | Conflict Minerals Report for the year ended December 31, 2014 as required by Items 1.01 and 1.02 of this Form. | |
4
EXHIBIT 1.01
CONFLICT MINERALS REPORT
This unaudited Conflict Minerals Report (this “Report”) of ON Semiconductor Corporation (the “Company”) is attached as Exhibit 1.01 to the Form SD for the year ended December 31, 2014. This Report is also publicly available on the Company’s website at the following link: http://www.onsemi.com/social-responsibility.
The Company is a broad based supplier of semiconductor components that serve a variety of end markets, including automotive, consumer, computing, industrial, wireless, networking, military-aerospace and medical. Our extensive portfolio of power and signal management, logic, discrete and custom devices helps customers efficiently solve their design challenges in advanced electronic systems and products. As a purchaser of products containing the minerals tin, tantalum, tungsten or gold from suppliers for use in our manufacturing process, the Company continues to be concerned about the reports of violence and human rights violations resulting from the sourcing of such minerals from the Democratic Republic of the Congo and adjoining countries (“Covered Countries”). The Company’s Corporate Social Responsibility Report is available at http://www.onsemi.com/social-responsibility.
Pursuant to Rule 13p-1 and Section 13(p) of the Securities Exchange Act of 1934, as amended, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Conflict Regulations”), the Company was required to make certain inquiries and perform certain due diligence with respect to any “conflict minerals” (as defined by paragraph (d)(3) of Item 1.01 of Form SD) that are necessary to the functionality or production of a product manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries. For purposes of this report, the term “products” is used to describe products manufactured (or contracted to be manufactured) by the Company or any of its subsidiaries. As a result, when conducting its conflict minerals analysis as required by the federal securities rules, the Company has considered its sole product to be semiconductor components.
As a result of its inquiry, the Company determined that conflict minerals are necessary to the functionality of the Company’s products. In particular, these minerals provide internal electrically conductive connections to the various circuit elements required to manufacture a working semiconductor device and/or provide an electrically conductive path to connect the semiconductor device to the electronic application in which it is utilized.
After conducting a reasonable country of origin inquiry (“RCOI”) and a supply chain due diligence inquiry, the Company has been unable to determine that certain of its conflict minerals did not originate in the Covered Countries or come from recycled or scrap sources, or that such conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries.
Conflict minerals are obtained from sources worldwide, and the Company does not desire to eliminate those originating in Covered Countries. However, the Company is committed to ensuring conflict free sourcing of minerals from our supply chain through collaboration with our suppliers, specifically, as a member of the Electronic Industry Citizenship Coalition (“EICC”) and a participant in the Conflict Free Sourcing Initiative (“CFSI”) which began as a joint effort between the EICC and Global e-Sustainability Initiative (“GeSI”). Being a member of the initiative requires that members engage in reasonable due diligence with their supply chain to assure such minerals are not being sourced from entities supporting armed conflict within the Covered Countries. The Company also recognizes the importance of supporting responsible mineral sourcing from the Covered Countries so as not to negatively impact the economies of those countries.
Due Diligence
As discussed above, based on the Company’s RCOI, the Company was unable to reasonably conclude that all of its conflict minerals did not originate in a Covered Country or come from recycled or scrap sources, or directly or indirectly finance or benefit armed groups in a Covered Country, and the Company continues its diligence on the source and chain of custody of its conflict minerals. In connection with this supply chain diligence, the Company used the framework advocated by the Organization for Economic Co-operation and Development (“OECD”) and, among other actions, implemented the following guidance of the OECD:
| • | OECD: Step 1: Established a strong management system |
| • | The Company continually reviews and updates policies as appropriate to reflect the procedures by which the Company and its suppliers should conduct conflict minerals related diligence. |
| • | The Company established an internal management team to support supply chain due diligence. The internal management team includes appropriate employees within the Company’s quality, supply chain, finance, operations and legal departments. Regular reports generated as a result of this internal management team’s efforts were provided to the Audit Committee of the Company. |
| • | The Company utilized the form conflicts minerals reporting template, standardized by the EICC, to collect sourcing information from its suppliers to identify whether (i) conflict minerals sourced by such suppliers originated in Covered Countries and (ii) whether or not smelters used by such suppliers (or such suppliers’ suppliers) have been validated as compliant in accordance with the Conflict Free Smelter Program. Appendix A sets forth a list of smelters, provided by our suppliers, from which the Company obtains product, including mineral type, standard smelter names, and whether the smelter is on the Conflict-Free Sourcing Initiative Compliant Smelter List. In addition, a summary of conflict minerals and countries of origin information, collected as a result of our RCOI efforts, is attached hereto as Appendix B. |
| • | The Conflict Free Sourcing Initiative developed an audit protocol for verification of entities as compliant with the Conflict Free Smelter Program (“CFSP”) in accordance with the OECD Guidance and in conjunction with complementary traceability schemes in the Covered Countries. The Conflict Free Smelter List is composed of entities that are compliant with the CFSP and that have been subject to an independent third party audit to assess whether the entity employed policies, practices, and procedures to source conflict free minerals. ON Semiconductor uses the CFSP compliant smelter list and any other lists that have been recognized by the CFSI, including the London Bullion Metal Association (LBMA) and Responsible Jewelry Council (RJC) lists for gold. We are a member of CFSI and have access to CFSI country of origin information (RCOI) for entities on the Conflict Free Smelter List. |
| • | The Company finalized an internal compliance audit to assess and confirm that the due diligence approach followed by the Company was in accordance with OECD framework. |
| • | OECD: Step 2: Risk Identification and Assessment |
Identified supply chain risk
| • | The Company has determined 100% of the suppliers who provide it with tin, tantalum, tungsten and gold (“3T&G”) and has, through its supply chain diligence, been able to exclude from this inquiry suppliers who do not provide 3T&G to the Company. As of December 31, 2014, the Company received declaration from 100% of its suppliers of conflict minerals using the Conflict Free Reporting template (“CMRT”). |
| • | The Company employs Ipoint, a third party web based software platform, to collect, manage and aggregate the CMRT declarations received from its suppliers and to report the results to its customers. This software ensures the company has an auditable ‘chain of custody’ regarding receipt of declarations and information received from suppliers. |
| • | OECD Step 3: Strategy to respond to Identified risks |
Implemented strategy to address that risk
| • | The Company has developed a date and version controlled document and conflict minerals audit checklist for use in auditing its major suppliers of conflict minerals and has incorporated this checklist into its ongoing supplier audit process. |
| • | All suppliers receive a letter through Ipoint requesting them to: |
| • | Adopt a policy to reasonably assure that the 3T&G in their products does not directly or indirectly finance or benefit armed groups in the Covered Countries. |
| • | Identify all 3T&G smelters in their supply chain. |
| • | Report back to the Company by filling in the CMRT. |
| • | The status is discussed internally in monthly reviews with the conflict minerals team and reported to senior management. |
| • | OECD Step 4: Smelter audits |
Independent auditing of smelters
| • | In collaboration with several fellow EICC member companies, the Company participated in audits and pre-audits of certain smelters for conflict minerals in Indonesia, Brazil and Japan. Additionally, our Conflict Mineral coordinators are members of the CFSI working teams that continue to encourage smelters to participate in the CFSP. To that end, the Company approaches, through direct communication and smelter outreach, both the smelters and their customers (our suppliers) in our supply chain, as well as others as assigned to us. The Company also supports CFSI group campaigns to engage smelters. |
| • | OECD Step 5: Report on supply chain due diligence. |
Inherent limitations on due diligence measures
| • | The Company is an indirect purchaser of conflict minerals, and our due diligence measures provide reasonable, not absolute, assurance regarding the source and chain of custody of conflict minerals. Our due diligence processes seek data from our direct suppliers and those suppliers seek similar information within their supply chains to identify the original sources of the conflict minerals. Such sources of information may produce inaccurate or incomplete information and may be subject to fraud. |
Products
As indicated above, the Company has been unable to determine the origins of certain of the conflict minerals contained in its products. Because the Company cannot determine the origins of the minerals, the Company is not able to state that products containing such minerals do not contain conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries.
Mitigation of Risk Related to Benefiting Armed Groups
The Company continues to improve its processes and procedures to mitigate the risk that its necessary conflict minerals benefit armed groups. In particular, the Company has taken the following steps to improve its due diligence processes:
| • | The Company has incorporated conflict minerals compliance requirements into its supplier handbook for all suppliers. |
| • | The Company has incorporated conflict minerals requirements and checkpoints into its business processes for new product introduction, new supplier qualification and change management. |
APPENDIX A
CONFLICT MINERALS SOURCING INFORMATION
| METAL | STANDARD SMELTER NAME | CONFLICT FREE STATUS | ||
| Gold | Aida Chemical Industries Co. Ltd. | CFSP Validated | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CFSP Validated | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CFSP Validated | ||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | CFSP Validated | ||
| Gold | Argor-Heraeus SA | CFSP Validated | ||
| Gold | Asahi Pretec Corporation | CFSP Validated | ||
| Gold | Asaka Riken Co Ltd | CFSP Validated | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CFSP Validated | ||
| Gold | Aurubis AG | CFSP Validated | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CFSP Validated | ||
| Gold | Boliden AB | CFSP Validated | ||
| Gold | C. Hafner GmbH + Co. KG | CFSP Validated | ||
| Gold | Caridad | CFSP Validated | ||
| Gold | CCR Refinery – Glencore Canada Corporation | CFSP Validated | ||
| Gold | Cendres + Métaux SA | CFSP Validated | ||
| Gold | Chimet S.p.A. | CFSP Validated | ||
| Gold | Chugai Mining | CFSP Validated | ||
| Gold | Daejin Indus Co. Ltd | CFSP Validated | ||
| Gold | Do Sung Corporation | CFSP Validated | ||
| Gold | Dowa | CFSP Validated | ||
| Gold | Eco-System Recycling Co., Ltd. | CFSP Validated | ||
| Gold | FSE Novosibirsk Refinery | CFSP Validated | ||
| Gold | Guangdong Jinding Gold Limited | CFSP Validated | ||
| Gold | Heimerle + Meule GmbH | CFSP Validated | ||
| Gold | Heraeus Ltd. Hong Kong | CFSP Validated | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | CFSP Validated | ||
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | CFSP Validated | ||
| Gold | Hwasung CJ Co. Ltd | CFSP Validated | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CFSP Validated | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | CFSP Validated | ||
| Gold | Istanbul Gold Refinery | CFSP Validated | ||
| Gold | Japan Mint | CFSP Validated | ||
| Gold | Jiangxi Copper Company Limited | CFSP Validated | ||
| Gold | Johnson Matthey Inc | CFSP Validated | ||
| Gold | Johnson Matthey Ltd | CFSP Validated | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CFSP Validated | ||
| Gold | JSC Uralelectromed | CFSP Validated | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | CFSP Validated | ||
| Gold | Kazzinc Ltd | CFSP Validated | ||
| Gold | Kennecott Utah Copper LLC | CFSP Validated | ||
| Gold | Kojima Chemicals Co., Ltd | CFSP Validated | ||
| Gold | Korea Metal Co. Ltd | CFSP Validated | ||
| Gold | Kyrgyzaltyn JSC | CFSP Validated | ||
| Gold | L’ azurde Company For Jewelry | CFSP Validated | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CFSP Validated | ||
| Gold | LS-NIKKO Copper Inc. | CFSP Validated | ||
| Gold | Materion | CFSP Validated | ||
| Gold | Matsuda Sangyo Co., Ltd. | CFSP Validated | ||
| Gold | Metalor Technologies (Hong Kong) Ltd | CFSP Validated | ||
| Gold | Metalor Technologies Ltd. (Suzhou) | CFSP Validated | ||
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | CFSP Validated | ||
| Gold | Metalor Technologies SA | CFSP Validated | ||
| Gold | Metalor USA Refining Corporation | CFSP Validated | ||
| Gold | Met-Mex Peñoles, S.A. | CFSP Validated | ||
| Gold | Mitsubishi Materials Corporation | CFSP Validated | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | CFSP Validated | ||
| Gold | Moscow Special Alloys Processing Plant | CFSP Validated | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A. | CFSP Validated | ||
| Gold | Navoi Mining and Metallurgical Combinat | CFSP Validated | ||
| Gold | Nihon Material Co. LTD | CFSP Validated | ||
| Gold | Ohio Precious Metals, LLC | CFSP Validated | ||
| Gold | Ohura Precious Metal Industry Co., Ltd | CFSP Validated | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | CFSP Validated | ||
| Gold | OJSC Kolyma Refinery | CFSP Validated | ||
| Gold | PAMP SA | CFSP Validated | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | CFSP Validated | ||
| Gold | PT Aneka Tambang (Persero) Tbk | CFSP Validated | ||
| Gold | PX Précinox SA | CFSP Validated | ||
| Gold | Rand Refinery (Pty) Ltd | CFSP Validated | ||
| Gold | Royal Canadian Mint | CFSP Validated | ||
| Gold | Sabin Metal Corp. | CFSP Validated | ||
| Gold | SAMWON METALS Corp. | CFSP Validated | ||
| Gold | Schone Edelmetaal | CFSP Validated | ||
| Gold | SEMPSA Joyería Platería SA | CFSP Validated | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CFSP Validated | ||
| Gold | So Accurate Group, Inc. | CFSP Validated | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CFSP Validated | ||
| Gold | Solar Applied Materials Technology Corp. | CFSP Validated | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | CFSP Validated | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | CFSP Validated | ||
| Gold | The Great Wall Gold and Silver Refinery of China | CFSP Validated | ||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | CFSP Validated | ||
| Gold | Tokuriki Honten Co., Ltd | CFSP Validated | ||
| Gold | Tongling nonferrous Metals Group Co.,Ltd | CFSP Validated | ||
| Gold | Torecom | CFSP Validated | ||
| Gold | Umicore Brasil Ltda | CFSP Validated | ||
| Gold | Umicore Precious Metals Thailand | CFSP Validated | ||
| Gold | Umicore SA Business Unit Precious Metals Refining | CFSP Validated | ||
| Gold | United Precious Metal Refining, Inc. | CFSP Validated | ||
| Gold | Valcambi SA | CFSP Validated | ||
| Gold | Western Australian Mint trading as The Perth Mint | CFSP Validated | ||
| Gold | Williams/ Williams Brewster | CFSP Validated | ||
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | CFSP Validated | ||
| Gold | Yantai Guodasafina High-Tech Environmental Refinery Co. Ltd. | CFSP Validated | ||
| Gold | Yokohama Metal Co Ltd | CFSP Validated | ||
| Gold | Yunnan Copper Industry Co Ltd | CFSP Validated | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CFSP Validated | ||
| Gold | Zijin Mining Group Co. Ltd | CFSP Validated | ||
| Gold | Codelco | Unknown | ||
| Gold | DaeryongENC | Unknown | ||
| Gold | Dongguan Standard Electronic Material.Co., Ltd | Unknown | ||
| Gold | Kunshan Jinli chemical industry reagents co., Ltd. | Unknown | ||
| Gold | MK electron | Unknown | ||
| Gold | Ningbo Kangqiang | Unknown | ||
| Gold | Remondis Argentia B.V. | Unknown | ||
| Gold | Scotia Mocatta | Unknown | ||
| Gold | Shanghai Gold exchange | Unknown | ||
| Gold | SHENZHEN TIANCHENG CHEMICAL CO LTD | Unknown | ||
| Gold | Suzhou Xingrui Noble | Unknown | ||
| Gold | Tai zhou chang san Jiao electron Co., Ltd | Unknown | ||
| Gold | Technic Inc | Unknown | ||
| Gold | The Hutti Gold Company | Unknown | ||
| Gold | Yantai Zhaojin Lai Fuk Precious Metals Ltd | Unknown | ||
| Gold | Zhongshan Public Security Bureau, Guangdong Province, China | Unknown | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CFSP Validated | ||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CFSP Validated | ||
| Tantalum | Duoluoshan | CFSP Validated | ||
| Tantalum | Exotech Inc. | CFSP Validated | ||
| Tantalum | F&X Electro-Materials Ltd. | CFSP Validated | ||
| Tantalum | Global Advanced Metals Boyertown | CFSP Validated | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CFSP Validated | ||
| Tantalum | H.C. Starck Co., Ltd. | CFSP Validated | ||
| Tantalum | H.C. Starck GmbH Goslar | CFSP Validated | ||
| Tantalum | H.C. Starck GmbH Laufenburg | CFSP Validated | ||
| Tantalum | H.C. Starck Hermsdorf GmbH | CFSP Validated | ||
| Tantalum | H.C. Starck Inc. | CFSP Validated | ||
| Tantalum | H.C. Starck Ltd. | CFSP Validated | ||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | CFSP Validated | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CFSP Validated | ||
| Tantalum | Hi-Temp | CFSP Validated | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CFSP Validated | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CFSP Validated | ||
| Tantalum | KEMET Blue Powder | CFSP Validated | ||
| Tantalum | King-Tan Tantalum Industry Ltd | CFSP Validated | ||
| Tantalum | LSM Brasil S.A. | CFSP Validated | ||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | CFSP Validated | ||
| Tantalum | Mineração Taboca S.A. | CFSP Validated | ||
| Tantalum | Mitsui Mining & Smelting | CFSP Validated | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CFSP Validated | ||
| Tantalum | Plansee SE Reutte | CFSP Validated | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CFSP Validated | ||
| Tantalum | Solikamsk Magnesium Works OAO | CFSP Validated | ||
| Tantalum | Taki Chemicals | CFSP Validated | ||
| Tantalum | Telex | CFSP Validated | ||
| Tantalum | Ulba | CFSP Validated | ||
| Tantalum | Zhuzhou Cement Carbide | CFSP Validated | ||
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | Unknown | ||
| Tantalum | Tantalite Resources | Unknown | ||
| Tin | Alpha | CFSP Validated | ||
| Tin | China Rare Metal Materials Company | CFSP Validated | ||
| Tin | China Tin Group Co., Ltd. | CFSP Validated | ||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | CFSP Validated | ||
| Tin | Cooper Santa | CFSP Validated | ||
| Tin | CV JusTindo | CFSP Validated | ||
| Tin | CV Nurjanah | CFSP Validated | ||
| Tin | CV Serumpun Sebalai | CFSP Validated | ||
| Tin | CV United Smelting | CFSP Validated | ||
| Tin | Dowa | CFSP Validated | ||
| Tin | EM Vinto | CFSP Validated | ||
| Tin | Feinhütte Halsbrücke GmbH | CFSP Validated | ||
| Tin | Fenix Metals | CFSP Validated | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CFSP Validated | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CFSP Validated | ||
| Tin | Gejiu Zi-Li | CFSP Validated | ||
| Tin | Huichang Jinshunda Tin Co. Ltd | CFSP Validated | ||
| Tin | Jiangxi Nanshan | CFSP Validated | ||
| Tin | Linwu Xianggui Smelter Co | CFSP Validated | ||
| Tin | Magnu’s Minerais Metais e Ligas LTDA | CFSP Validated | ||
| Tin | Malaysia Smelting Corporation (MSC) | CFSP Validated | ||
| Tin | Metallic Resources Inc | CFSP Validated | ||
| Tin | Mineração Taboca S.A. | CFSP Validated | ||
| Tin | Minsur | CFSP Validated | ||
| Tin | Mitsubishi Materials Corporation | CFSP Validated | ||
| Tin | NGHE TIN NON-FERROUS METAL | CFSP Validated | ||
| Tin | Novosibirsk Integrated Tin Works | CFSP Validated | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CFSP Validated | ||
| Tin | O.M. Manufacturing Philippines, Inc. | CFSP Validated | ||
| Tin | OMSA | CFSP Validated | ||
| Tin | PT Alam Lestari Kencana | CFSP Validated | ||
| Tin | PT Artha Cipta Langgeng | CFSP Validated | ||
| Tin | PT Babel Inti Perkasa | CFSP Validated | ||
| Tin | PT Bangka Kudai Tin | CFSP Validated | ||
| Tin | PT Bangka Putra Karya | CFSP Validated | ||
| Tin | PT Bangka Timah Utama Sejahtera | CFSP Validated | ||
| Tin | PT Bangka Tin Industry | CFSP Validated | ||
| Tin | PT Belitung Industri Sejahtera | CFSP Validated | ||
| Tin | PT BilliTin Makmur Lestari | CFSP Validated | ||
| Tin | PT Bukit Timah | CFSP Validated | ||
| Tin | PT Eunindo Usaha Mandiri | CFSP Validated | ||
| Tin | PT Fang Di MulTindo | CFSP Validated | ||
| Tin | PT Karimun Mining | CFSP Validated | ||
| Tin | PT Mitra Stania Prima | CFSP Validated | ||
| Tin | PT Pelat Timah Nusantara Tbk | CFSP Validated | ||
| Tin | PT Prima Timah Utama | CFSP Validated | ||
| Tin | PT REFINED BANGKA TIN | CFSP Validated | ||
| Tin | PT Sariwiguna Binasentosa | CFSP Validated | ||
| Tin | PT Stanindo Inti Perkasa | CFSP Validated | ||
| Tin | PT Sumber Jaya Indah | CFSP Validated | ||
| Tin | PT Tambang Timah | CFSP Validated | ||
| Tin | PT Timah (Persero), Tbk | CFSP Validated | ||
| Tin | PT Tinindo Inter Nusa | CFSP Validated | ||
| Tin | Rui Da Hung | CFSP Validated | ||
| Tin | Soft Metais, Ltda. | CFSP Validated | ||
| Tin | Thaisarco | CFSP Validated | ||
| Tin | White Solder Metalurgia e Mineração Ltda. | CFSP Validated | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CFSP Validated | ||
| Tin | Yunnan Tin Company, Ltd. | CFSP Validated | ||
| Tin | American Iron and Metal | Unknown | ||
| Tin | CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda. | Unknown | ||
| Tin | CV Duta Putra Bangka | Unknown | ||
| Tin | CV Makmur Jaya | Unknown | ||
| Tin | Gold Bell Group | Unknown | ||
| Tin | Guangxi Huaxi Group Co.,Ltd | Unknown | ||
| Tin | IBF IND BRASILEIRA DE FERROLIGAS LTDA | Unknown | ||
| Tin | Jia Tian | Unknown | ||
| Tin | MCP Metal Specialist Inc. | Unknown | ||
| Tin | Metallo Chimique | Unknown | ||
| Tin | Minmetals Ganzhou Tin Co. Ltd. | Unknown | ||
| Tin | Nathan Trotter & Co.,Inc. | Unknown | ||
| Tin | PT Babel Surya Alam Lestari | Unknown | ||
| Tin | PT HP Metals Indonesia | Unknown | ||
| Tin | PT Koba Tin | Unknown | ||
| Tin | PT Yinchendo Mining Industry | Unknown | ||
| Tin | Poongsan Corporation | Unknown | ||
| Tin | Samhwa Non-Ferrous Metal. Inc Co.,Ltd | Unknown | ||
| Tin | Tongding Metal Material Co.,Ltd. | Unknown | ||
| Tin | Traxys | Unknown | ||
| Tin | WC Heraeus Hanau | Unknown | ||
| Tin | Westfalenzinn | Unknown | ||
| Tin | Wilhelm Westmetall | Unknown | ||
| Tungsten | A.L.M.T. Corp. | CFSP Validated | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CFSP Validated | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CFSP Validated | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CFSP Validated | ||
| Tungsten | Global Tungsten & Powders Corp. | CFSP Validated | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | H.C. Starck GmbH | CFSP Validated | ||
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CFSP Validated | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CFSP Validated | ||
| Tungsten | Japan New Metals Co., Ltd. | CFSP Validated | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CFSP Validated | ||
| Tungsten | Kennametal Fallon | CFSP Validated | ||
| Tungsten | Kennametal Huntsville | CFSP Validated | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | CFSP Validated | ||
| Tungsten | Wolfram Bergbau und Hütten AG | CFSP Validated | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CFSP Validated | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CFSP Validated | ||
| Tungsten | Nanchang Cemented Carbide Limited Liability Company | Unknown | ||
| Tungsten | North American Tungsten | Unknown | ||
| Tungsten | Voss Metals Company, Inc. | Unknown | ||
| Tungsten | Wolfram Company CJSC | Unknown | ||
| Tungsten | Xiamen Golden Egret Special Alloy Co. Ltd. | Unknown | ||
| Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | Unknown | ||
APPENDIX B
Below is a summary of the minerals and country of origin information, collected as a result of the Company’s RCOI and due diligence:
| CONFLICT MINERAL | Countries of Origin and other sources may include the following: | |
| GOLD | L1, L2, L3, DRC, Argentina; Australia; Brazil; Canada; Chile; China; Germany; Hong Kong; Indonesia; Italy; Japan; Korea; Papua New Guinea; Peru; Philippines; South America; SOUTH AFRICA; Switzerland; Taiwan; UNITED STATES | |
| TANTALUM | L1, L3, Australia; Austria; Belarus; Bolivia; Brazil; Canada; China; DRC; Ethiopia; India; Mozambique; Namibia; Russia; Rwanda; Sierra Leone; UNITED STATES; Zimbabwe | |
| TIN | L1, L3, Australia; Bolivia; Brazil; Canada; China; DRC; Germany; Indonesia; Japan; Nigeria; Peru; Rwanda; South East Asia Countries; UNITED STATES | |
| TUNGSTEN | Australia; Bolivia; Brazil; Canada; China; Columbia; Japan; Mexico; Nigeria; Portugal; Russia; Rwanda; Spain; Thailand; UNITED STATES; Vietnam | |
| MINERAL SOURCING | Countries of Origin including the following: | |
| L1 | Argentina; Australia; Austria; Belgium; Bolivia; Brazil; Canada; Chile; China; Colombia; Côte D’Ivoire; Czech Republic; Djibouti; Egypt; Estonia; Ethiopia; France; Germany; Guyana; Hungary; India; Indonesia; Ireland; Israel; Japan; Kazakhstan; Laos; Luxembourg; Madagascar; Malaysia; Mongolia; Myanmar; Namibia; Netherlands; Nigeria; Peru; Portugal; Russia; Sierra Leone; Singapore; Slovakia; South Korea; Spain; Suriname; Switzerland; Taiwan; Thailand; United Kingdom; United States of America; Vietnam; Zimbabwe | |
| L2 | Kenya; Mozambique; South Africa | |
| L3 | Angola; Burundi; Central African Republic; Republic of Congo; Rwanda; South Sudan; Tanzania; Uganda; Zambia | |
| DRC | Democratic Republic of Congo | |