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, 2015. |
| 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.
Conflict minerals are necessary to the functionality of certain of the Company’s products. As required in the Conflict Regulations, the Company has conducted a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country or are from recycled or scrap sources. Based on its RCOI, the Company has determined that certain of the conflict minerals contained in its products may have originated in the Democratic Republic of the Congo or an adjoining country and may not be from recycled or scrap sources. Therefore, the Company was required to exercise due diligence on the source and chain of custody of its conflict minerals in accordance with the Conflict Regulations and Form SD and to file a Conflict Minerals Report.
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 |
Description | |
| 1.01 | Conflict Minerals Report for the year ended December 31, 2015 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 27, 2016 | ||||
| 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 |
Description | |
| 1.01 | Conflict Minerals Report for the year ended December 31, 2015 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, 2015. This Report is also publicly available on the Company’s website at the following link: http://www.onsemi.com/social-responsibility. The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this 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”), 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.
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.
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.
This Report relates to the process undertaken for products that were manufactured, or contracted to be manufactured, during calendar year 2015 and that contain conflict minerals. This Report is unaudited, as an independent private sector audit is not required pursuant to the guidance provided by the Securities and Exchange Commission in its “Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014.
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.
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
Based on the Company’s reasonable country of origin inquiry (“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, 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 Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition, OECD 2013) and the related Supplements on tantalum, tin, tungsten and gold (collectively, the “OECD Guidance”) and, among other actions, implemented the following:
| • | 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 (“CMRT”), 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 (“CFSP”). 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 CFSI developed an audit protocol for verification of entities as compliant with the 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 were determined to be 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 Guidance. |
| • | OECD: Step 2: Risk Identification and Assessment / |
Identified supply chain risk
| • | The Company believes that it has identified 100% of the suppliers who provide it with tin, tantalum, tungsten and gold (“3TG”) and has, through its supply chain diligence, been able to exclude from this inquiry suppliers who do not provide 3TG to the Company. As of December 31, 2015, the Company received declaration from 100% of its suppliers of conflict minerals using the 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 3TG in their products does not directly or indirectly finance or benefit armed groups in the Covered Countries. |
| • | Identify all 3TG 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
| • | The Company’s 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 (the Company’s 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 its due diligence measures provide reasonable, not absolute, assurance regarding the source and chain of custody of conflict minerals. The Company’s due diligence processes seek data from its direct suppliers and those suppliers seek similar information within their supply chains to identify the original sources of the conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information may produce inaccurate or incomplete information and may be subject to fraud. |
Due Diligence Results
As a result of its continuous due diligence with suppliers and smelters through CFSI’s smelter engagement team, the Company has determined that approximately 98% of our smelters are CFSP compliant or active in the program pursuing compliance as of December 31, 2015, compared to 53% as of December 31, 2014.
Smelters Status:
| 2015 |
CFSP Compliant | CFSI Active List | CFSI Std List | Unknown | Total | |||||||||||||||
| Gold |
59 | 3 | 3 | 0 | 65 | |||||||||||||||
| Tantalum |
38 | 0 | 0 | 0 | 38 | |||||||||||||||
| Tin |
53 | 9 | 1 | 0 | 63 | |||||||||||||||
| Tungsten |
20 | 4 | 0 | 0 | 24 | |||||||||||||||
|
|
|
|
|
|
|
|
|
|
|
|||||||||||
| Total |
170 | 16 | 4 | 0 | 190 | |||||||||||||||
|
|
|
|
|
|
|
|
|
|
|
|||||||||||
| % |
89.5 | % | 8.4 | % | 2.1 | % | 0.0 | % | 100 | % | ||||||||||
Products
As indicated above, the Company has been unable to determine the origins of certain of the conflict minerals contained in its products.
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
(as of December 31, 2015)
| SN | METAL | STANDARD SMELTER NAME | CONFLICT FREE STATUS | |||
| 1 | Gold | Aida Chemical Industries Co., Ltd. | CFSP Validated as conflict-free | |||
| 2 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CFSP Validated as conflict-free | |||
| 3 | Gold | AngloGold Ashanti Córrego do Sítio Mineração | CFSP Validated as conflict-free | |||
| 4 | Gold | Argor-Heraeus SA | CFSP Validated as conflict-free | |||
| 5 | Gold | Asahi Pretec Corporation | CFSP Validated as conflict-free | |||
| 6 | Gold | Asahi Refining Canada Limited | CFSP Validated as conflict-free | |||
| 7 | Gold | Asahi Refining USA Inc. | CFSP Validated as conflict-free | |||
| 8 | Gold | Asaka Riken Co., Ltd. | CFSP Validated as conflict-free | |||
| 9 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CFSP Validated as conflict-free | |||
| 10 | Gold | Aurubis AG | CFSP Validated as conflict-free | |||
| 11 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CFSP Validated as conflict-free | |||
| 12 | Gold | Boliden AB | CFSP Validated as conflict-free | |||
| 13 | Gold | C. Hafner GmbH + Co. KG | CFSP Validated as conflict-free | |||
| 14 | Gold | CCR Refinery – Glencore Canada Corporation | CFSP Validated as conflict-free | |||
| 15 | Gold | Chimet S.p.A. | CFSP Validated as conflict-free | |||
| 16 | Gold | Dowa | CFSP Validated as conflict-free | |||
| 17 | Gold | Eco-System Recycling Co., Ltd. | CFSP Validated as conflict-free | |||
| 18 | Gold | Elemetal Refining, LLC | CFSP Validated as conflict-free | |||
| 19 | Gold | Heimerle + Meule GmbH | CFSP Validated as conflict-free | |||
| 20 | Gold | Heraeus Ltd. Hong Kong | CFSP Validated as conflict-free | |||
| 21 | Gold | Heraeus Precious Metals GmbH & Co. KG | CFSP Validated as conflict-free | |||
| 22 | Gold | Ishifuku Metal Industry Co., Ltd. | CFSP Validated as conflict-free | |||
| 23 | Gold | Istanbul Gold Refinery | CFSP Validated as conflict-free | |||
| 24 | Gold | Jiangxi Copper Company Limited | CFSP Validated as conflict-free | |||
| 25 | Gold | JX Nippon Mining & Metals Co., Ltd. | CFSP Validated as conflict-free | |||
| 26 | Gold | Kennecott Utah Copper LLC | CFSP Validated as conflict-free | |||
| 27 | Gold | Kojima Chemicals Co., Ltd. | CFSP Validated as conflict-free | |||
| 28 | Gold | LS-NIKKO Copper Inc. | CFSP Validated as conflict-free | |||
| 29 | Gold | Materion | CFSP Validated as conflict-free | |||
| 30 | Gold | Matsuda Sangyo Co., Ltd. | CFSP Validated as conflict-free | |||
| 31 | Gold | Metalor Technologies (Hong Kong) Ltd. | CFSP Validated as conflict-free | |||
| 32 | Gold | Metalor Technologies SA | CFSP Validated as conflict-free | |||
| 33 | Gold | Metalor USA Refining Corporation | CFSP Validated as conflict-free | |||
| 34 | Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | CFSP Validated as conflict-free | |||
| 35 | Gold | Mitsubishi Materials Corporation | CFSP Validated as conflict-free | |||
| 36 | Gold | Mitsui Mining and Smelting Co., Ltd. | CFSP Validated as conflict-free | |||
| 37 | Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CFSP Validated as conflict-free | |||
| 38 | Gold | Nihon Material Co., Ltd. | CFSP Validated as conflict-free | |||
| 39 | Gold | Ohura Precious Metal Industry Co., Ltd. | CFSP Validated as conflict-free | |||
| 40 | Gold | PAMP SA | CFSP Validated as conflict-free | |||
| 41 | Gold | PX Précinox SA | CFSP Validated as conflict-free | |||
| 42 | Gold | Rand Refinery (Pty) Ltd. | CFSP Validated as conflict-free | |||
| 43 | Gold | Republic Metals Corporation | CFSP Validated as conflict-free | |||
| 44 | Gold | Royal Canadian Mint | CFSP Validated as conflict-free | |||
| 45 | Gold | SEMPSA Joyería Platería SA | CFSP Validated as conflict-free | |||
| 46 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CFSP Validated as conflict-free | |||
| 47 | Gold | Solar Applied Materials Technology Corp. | CFSP Validated as conflict-free | |||
| 48 | Gold | Sumitomo Metal Mining Co., Ltd. | CFSP Validated as conflict-free | |||
| 49 | Gold | Tanaka Kikinzoku Kogyo K.K. | CFSP Validated as conflict-free | |||
| 50 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CFSP Validated as conflict-free | |||
| 51 | Gold | Tokuriki Honten Co., Ltd. | CFSP Validated as conflict-free | |||
| 52 | Gold | Umicore Precious Metals Thailand | CFSP Validated as conflict-free | |||
| 53 | Gold | Umicore SA Business Unit Precious Metals Refining | CFSP Validated as conflict-free | |||
| 54 | Gold | United Precious Metal Refining, Inc. | CFSP Validated as conflict-free | |||
| 55 | Gold | Valcambi SA | CFSP Validated as conflict-free | |||
| 56 | Gold | Western Australian Mint trading as The Perth Mint | CFSP Validated as conflict-free | |||
| 57 | Gold | Yamamoto Precious Metal Co., Ltd. | CFSP Validated as conflict-free | |||
| 58 | Gold | Yokohama Metal Co., Ltd. | CFSP Validated as conflict-free | |||
| 59 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CFSP Validated as conflict-free | |||
| 60 | Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CFSP Validated as conflict-free | |||
| 61 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CFSP Validated as conflict-free | |||
| 62 | Tantalum | Conghua Tantalum and Niobium Smeltry | CFSP Validated as conflict-free | |||
| 63 | Tantalum | Duoluoshan | CFSP Validated as conflict-free | |||
| 64 | Tantalum | Exotech Inc. | CFSP Validated as conflict-free | |||
| 65 | Tantalum | F&X Electro-Materials Ltd. | CFSP Validated as conflict-free | |||
| 66 | Tantalum | Global Advanced Metals Aizu | CFSP Validated as conflict-free | |||
| 67 | Tantalum | Global Advanced Metals Boyertown | CFSP Validated as conflict-free | |||
| 68 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CFSP Validated as conflict-free | |||
| 69 | Tantalum | H.C. Starck Co., Ltd. | CFSP Validated as conflict-free | |||
| 70 | Tantalum | H.C. Starck GmbH Goslar | CFSP Validated as conflict-free | |||
| 71 | Tantalum | H.C. Starck GmbH Laufenburg | CFSP Validated as conflict-free | |||
| 72 | Tantalum | H.C. Starck Hermsdorf GmbH | CFSP Validated as conflict-free | |||
| 73 | Tantalum | H.C. Starck Inc. | CFSP Validated as conflict-free | |||
| 74 | Tantalum | H.C. Starck Ltd. | CFSP Validated as conflict-free | |||
| 75 | Tantalum | H.C. Starck Smelting GmbH & Co.KG | CFSP Validated as conflict-free | |||
| 76 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CFSP Validated as conflict-free | |||
| 77 | Tantalum | Hi-Temp Specialty Metals, Inc. | CFSP Validated as conflict-free | |||
| 78 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CFSP Validated as conflict-free | |||
| 79 | Tantalum | Jiujiang Tanbre Co., Ltd. | CFSP Validated as conflict-free | |||
| 80 | Tantalum | KEMET Blue Metals | CFSP Validated as conflict-free | |||
| 81 | Tantalum | KEMET Blue Powder | CFSP Validated as conflict-free | |||
| 82 | Tantalum | King-Tan Tantalum Industry Ltd. | CFSP Validated as conflict-free | |||
| 83 | Tantalum | LSM Brasil S.A. | CFSP Validated as conflict-free | |||
| 84 | Tantalum | Metallurgical Products India Pvt., Ltd. | CFSP Validated as conflict-free | |||
| 85 | Tantalum | Mineração Taboca S.A. | CFSP Validated as conflict-free | |||
| 86 | Tantalum | Mitsui Mining & Smelting | CFSP Validated as conflict-free | |||
| 87 | Tantalum | Molycorp Silmet A.S. | CFSP Validated as conflict-free | |||
| 88 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CFSP Validated as conflict-free | |||
| 89 | Tantalum | Plansee SE Liezen | CFSP Validated as conflict-free | |||
| 90 | Tantalum | Plansee SE Reutte | CFSP Validated as conflict-free | |||
| 91 | Tantalum | QuantumClean | CFSP Validated as conflict-free | |||
| 92 | Tantalum | RFH Tantalum Smeltry Co., Ltd. | CFSP Validated as conflict-free | |||
| 93 | Tantalum | Solikamsk Magnesium Works OAO | CFSP Validated as conflict-free | |||
| 94 | Tantalum | Taki Chemicals | CFSP Validated as conflict-free | |||
| 95 | Tantalum | Telex Metals | CFSP Validated as conflict-free | |||
| 96 | Tantalum | Ulba Metallurgical Plant JSC | CFSP Validated as conflict-free | |||
| 97 | Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CFSP Validated as conflict-free | |||
| 98 | Tantalum | Zhuzhou Cemented Carbide | CFSP Validated as conflict-free | |||
| 99 | Tin | Alpha | CFSP Validated as conflict-free | |||
| 100 | Tin | China Tin Group Co., Ltd. | CFSP Validated as conflict-free | |||
| 101 | Tin | Cooperativa Metalurgica de Rondônia Ltda. | CFSP Validated as conflict-free | |||
| 102 | Tin | CV Ayi Jaya | CFSP Validated as conflict-free | |||
| 103 | Tin | CV Gita Pesona | CFSP Validated as conflict-free | |||
| 104 | Tin | CV Serumpun Sebalai | CFSP Validated as conflict-free | |||
| 105 | Tin | CV United Smelting | CFSP Validated as conflict-free | |||
| 106 | Tin | Dowa | CFSP Validated as conflict-free | |||
| 107 | Tin | Elmet S.L.U. (Metallo Group) | CFSP Validated as conflict-free | |||
| 108 | Tin | EM Vinto | CFSP Validated as conflict-free | |||
| 109 | Tin | Fenix Metals | CFSP Validated as conflict-free | |||
| 110 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CFSP Validated as conflict-free | |||
| 111 | Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CFSP Validated as conflict-free | |||
| 112 | Tin | Magnu’s Minerais Metais e Ligas Ltda. | CFSP Validated as conflict-free | |||
| 113 | Tin | Malaysia Smelting Corporation (MSC) | CFSP Validated as conflict-free | |||
| 114 | Tin | Melt Metais e Ligas S/A | CFSP Validated as conflict-free | |||
| 115 | Tin | Metallic Resources, Inc. | CFSP Validated as conflict-free | |||
| 116 | Tin | Metallo-Chimique N.V. | CFSP Validated as conflict-free | |||
| 117 | Tin | Mineração Taboca S.A. | CFSP Validated as conflict-free | |||
| 118 | Tin | Minsur | CFSP Validated as conflict-free | |||
| 119 | Tin | Mitsubishi Materials Corporation | CFSP Validated as conflict-free | |||
| 120 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CFSP Validated as conflict-free | |||
| 121 | Tin | O.M. Manufacturing Philippines, Inc. | CFSP Validated as conflict-free | |||
| 122 | Tin | Operaciones Metalurgical S.A. | CFSP Validated as conflict-free | |||
| 123 | Tin | PT Aries Kencana Sejahtera | CFSP Validated as conflict-free | |||
| 124 | Tin | PT Artha Cipta Langgeng | CFSP Validated as conflict-free | |||
| 125 | Tin | PT ATD Makmur Mandiri Jaya | CFSP Validated as conflict-free | |||
| 126 | Tin | PT Babel Inti Perkasa | CFSP Validated as conflict-free | |||
| 127 | Tin | PT Bangka Prima Tin | CFSP Validated as conflict-free | |||
| 128 | Tin | PT Bangka Tin Industry | CFSP Validated as conflict-free | |||
| 129 | Tin | PT Belitung Industri Sejahtera | CFSP Validated as conflict-free | |||
| 130 | Tin | PT BilliTin Makmur Lestari | CFSP Validated as conflict-free | |||
| 131 | Tin | PT Bukit Timah | CFSP Validated as conflict-free | |||
| 132 | Tin | PT Cipta Persada Mulia | CFSP Validated as conflict-free | |||
| 133 | Tin | PT DS Jaya Abadi | CFSP Validated as conflict-free | |||
| 134 | Tin | PT Eunindo Usaha Mandiri | CFSP Validated as conflict-free | |||
| 135 | Tin | PT Inti Stania Prima | CFSP Validated as conflict-free | |||
| 136 | Tin | PT Justindo | CFSP Validated as conflict-free | |||
| 137 | Tin | PT Mitra Stania Prima | CFSP Validated as conflict-free | |||
| 138 | Tin | PT Panca Mega Persada | CFSP Validated as conflict-free | |||
| 139 | Tin | PT Prima Timah Utama | CFSP Validated as conflict-free | |||
| 140 | Tin | PT Refined Bangka Tin | CFSP Validated as conflict-free | |||
| 141 | Tin | PT Sariwiguna Binasentosa | CFSP Validated as conflict-free | |||
| 142 | Tin | PT Stanindo Inti Perkasa | CFSP Validated as conflict-free | |||
| 143 | Tin | PT Timah (Persero) Tbk Kundur | CFSP Validated as conflict-free | |||
| 144 | Tin | PT Timah (Persero) Tbk Mentok | CFSP Validated as conflict-free | |||
| 145 | Tin | PT Tinindo Inter Nusa | CFSP Validated as conflict-free | |||
| 146 | Tin | PT Wahana Perkit Jaya | CFSP Validated as conflict-free | |||
| 147 | Tin | Resind Indústria e Comércio Ltda. | CFSP Validated as conflict-free | |||
| 148 | Tin | Rui Da Hung | CFSP Validated as conflict-free | |||
| 149 | Tin | Soft Metais Ltda. | CFSP Validated as conflict-free | |||
| 150 | Tin | Thaisarco | CFSP Validated as conflict-free | |||
| 151 | Tin | VQB Mineral and Trading Group JSC | CFSP Validated as conflict-free | |||
| 152 | Tin | White Solder Metalurgia e Mineração Ltda. | CFSP Validated as conflict-free | |||
| 153 | Tin | Yunnan Tin Group (Holding) Company Limited | CFSP Validated as conflict-free | |||
| 154 | Tungsten | A.L.M.T. TUNGSTEN Corp. | CFSP Validated as conflict-free | |||
| 155 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CFSP Validated as conflict-free | |||
| 156 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 157 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 158 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CFSP Validated as conflict-free | |||
| 159 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 160 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CFSP Validated as conflict-free | |||
| 161 | Tungsten | Global Tungsten & Powders Corp. | CFSP Validated as conflict-free | |||
| 162 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 163 | Tungsten | H.C. Starck GmbH | CFSP Validated as conflict-free | |||
| 164 | Tungsten | H.C. Starck Smelting GmbH & Co.KG | CFSP Validated as conflict-free | |||
| 165 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CFSP Validated as conflict-free | |||
| 166 | Tungsten | Hydrometallurg, JSC | CFSP Validated as conflict-free | |||
| 167 | Tungsten | Japan New Metals Co., Ltd. | CFSP Validated as conflict-free | |||
| 168 | Tungsten | Kennametal Huntsville | CFSP Validated as conflict-free | |||
| 169 | Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CFSP Validated as conflict-free | |||
| 170 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 171 | Tungsten | Wolfram Bergbau und Hütten AG | CFSP Validated as conflict-free | |||
| 172 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CFSP Validated as conflict-free | |||
| 173 | Tungsten | Xiamen Tungsten Co., Ltd. | CFSP Validated as conflict-free | |||
| 174 | Gold | Metalor Technologies (Suzhou) Ltd. | CFSP Validated as active | |||
| 175 | Gold | Samduck Precious Metals | CFSP Validated as active | |||
| 176 | Tin | An Vinh Joint Stock Mineral Processing Company | CFSP Validated as active | |||
| 177 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CFSP Validated as active | |||
| 178 | Tin | Gejiu Kai Meng Industry and Trade LLC | CFSP Validated as active | |||
| 179 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CFSP Validated as active | |||
| 180 | Tin | Phoenix Metal Ltd. | CFSP Validated as active | |||
| 181 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CFSP Validated as active | |||
| 182 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CFSP Validated as active | |||
| 183 | Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CFSP Validated as active | |||
| 184 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CFSP Validated as active | |||
| 185 | Tungsten | Kennametal Fallon | CFSP Validated as active | |||
| 186 | Tungsten | Pobedit, JSC | CFSP Validated as active | |||
| 187 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CFSP Validated as eligible smelter | |||
| 188 | Gold | Chugai Mining | CFSP Validated as eligible smelter | |||
| 189 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CFSP Validated as eligible smelter | |||
| 190 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CFSP Validated as eligible smelter | |||
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, R/S, Australia; Belgium; Brazil; Canada; China; Germany; Italy; Japan; Korea, Republic of; Mexico; Philippines; South Africa; Spain; Sweden; Switzerland; Taiwan; Thailand; Turkey; UNITED STATES; Uzbekistan | |
| TANTALUM | L1, L2, L3, DRC, R/S, Austria; Brazil; China; Estonia; Germany; India; Japan; Kazakhstan; Mexico; Russian Federation; Thailand; UNITED STATES | |
| TIN | L1, L2, L3, DRC, R/S, Belgium; Bolivia; Brazil; China; Indonesia; Japan; Malaysia; Peru; Philippines; Poland; Rwanda; Spain; Taiwan; Thailand; UNITED STATES, Vietnam | |
| TUNGSTEN | L1, L3, R/S, Austria; China; Columbia; Germany; Japan; Russian Federation; UNITED STATES; Vietnam | |
| MINERAL SOURCING | COUNTRIES OF ORIGIN including the following: | |
| L1 | Argentina, Australia, Austria; Belgium; Bolivia; Brazil; Cambodia; Canada; Chile; China; Colombia; Côte D’Ivoire; Czech Republic; Djibouti; Ecuador; 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 | |