EX-1.01 2 fy2017_q3xsdxex101xconflic.htm EXHIBIT 1.01 Exhibit

Exhibit 1.01


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Conflict Minerals Report
For Calendar Year 2016

This is The Walt Disney Company’s 2016 (January 1 to December 31, 2016) Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 of the Securities and Exchange Commission (the “Conflict Minerals Rule”).
Background
The Walt Disney Company, together with its subsidiaries, is a diversified worldwide entertainment company with operations in four business segments: Media Networks, Parks and Resorts, Studio Entertainment and Consumer Products and Interactive Media. For convenience, the terms “Company,” “Disney” and “we” are used in this CMR to refer collectively to the parent company and its consolidated subsidiaries through which our various businesses are actually conducted.
The Company derives the vast majority of its revenues from the licensing of intellectual property, the sale of advertising time, and charges for entertainment, lodging and associated food and beverage sales at its theme parks, resorts, and cruise lines. We also derive revenue from the sales of physical products (such as physical copies of films and music) that we have determined do not include columbite-tantalite, cassiterite, gold, wolframite or their derivatives (collectively, the “Subject Minerals”) as necessary to the products’ functionality or production (“necessary Subject Minerals”).
The products we sell that may include necessary Subject Minerals are items such as clothing, accessories, electronic toys, jewelry, and other consumer goods. We classify these items together as retail merchandise, and that is the product category covered by this CMR. We sell many of these items directly through Disney Stores throughout the world and at our entertainment venues, including our parks and resorts. We also sell retail merchandise wholesale to other retailers.
The sale of retail merchandise constituted less than 10% of our revenue in calendar 2016. The number of individual items sold is, however, large. We estimate that we sold retail merchandise with approximately 171,000 stock-keeping units (SKUs) in calendar 2016. Moreover, due to the dynamic nature of our business, the items we sell change rapidly, with many items sold for only a few months, and then replaced by other items sourced from other suppliers.
The Company does not manufacture any of the retail merchandise it sells, sourcing the specific merchandise items that may contain Subject Minerals from over 1,200 suppliers in calendar 2016. Many of our suppliers themselves source components of these items from numerous other suppliers, and our direct suppliers are often many steps removed from the source of the raw materials contained in the items. In addition, in many cases the items we acquire from a supplier represent a small portion of the supplier’s total production.
The number, diversity and frequent turnover of the retail merchandise we sell, the number and turnover of suppliers, and our remote position in the supply chain make it difficult for us to determine and track


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the source of individual items, the nature of the raw materials included in the items, and the source of those raw materials. Nevertheless, our Conflict Minerals Compliance Program is designed to gain relevant information about the sources of raw materials in our products that is as complete as reasonably possible in light of our position in the supply chain.
Our Conflict Minerals Compliance Program (the “Program”) is focused on identifying suppliers of retail merchandise that may contain necessary Subject Minerals and gathering information about the supply chain practices of those suppliers. The Program conforms to the elements of the guidance set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (OECD Guidance) that are required by the Conflict Minerals Rule, and thus includes:
strong company management systems (including a Conflict Minerals Policy and an established internal management structure);
identification and assessment of risk in the supply chain through a reasonable country of origin inquiry;
a strategy to respond to identified risks through due diligence procedures that include follow up with suppliers who either provide insufficient information to identify sources of necessary Subject Minerals or who provide information indicating that they may source necessary Subject Minerals that may have originated in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”); and
reporting on results of the Program.
These elements of the Program, and the results of the Program for 2016, are described below.
Company Management Systems
1.
Conflict Minerals Policy. The Company’s Conflict Minerals Policy sets forth the steps we are taking to comply with the Conflict Minerals Rule. These steps include: the establishment of the internal management structure described below; engagement with suppliers as described in this report; reporting required by the Conflict Minerals Rule; and monitoring developments relating to conflict minerals with an eye to enhancing the Program. Our policy was distributed to suppliers who may supply us with products covered by the rule and is posted on our website at https://ditm-twdc-us.storage.googleapis.com/Conflict-Minerals-Policy.pdf. The policy includes a mechanism for reporting concerns or asking questions regarding the policy.
2.
Internal Management Structure. A Conflict Minerals Steering Committee is comprised of executive-level representatives from Legal, Investor Relations, Controllership, Corporate Communications, Global Public Policy, and Global Product & Labor Standards. The Committee is responsible for providing governance and oversight over the execution of the Program and for monitoring the Program’s compliance with regulatory requirements and satisfaction of enterprise goals. The day-to-day implementation of the Program is conducted by a Conflict Minerals Compliance Program Team within our Global Product & Labor Standards organization, which reports to an executive officer of the Company. The Conflict Minerals Compliance Program Team engages regularly with a third party professional services firm to assist with the progress of the Program.



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Identification and Assessment of Risk Through Reasonable Country of Origin Inquiry
Based on lists of historic suppliers of retail merchandise updated through interviews with sourcing executives, we compile a list each year of the suppliers we are able to identify as supplying retail merchandise in the prior calendar year that may contain necessary Subject Minerals.
Each year, we distribute a survey to these suppliers regarding their supply chain practices relating to Subject Minerals. The 2016 survey was based on the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (CMRT), revision 4.20. We supplemented this template with additional multi-language questions designed to provide visibility into our suppliers’ sourcing activities, including the basis for their responses regarding the source of Subject Minerals in the retail merchandise they supplied to us. We also provided suppliers with access to a live technical support specialist via chat during the survey phase, provided multi-language training documents highlighting Frequently Asked Questions on Conflict Minerals and Section 1502 of the Dodd-Frank Wall-Street Reform and Consumer Protection Act, as well as instructions on how to complete the CMRT. Our communications included our expectations for response and noted that the Conflict Minerals Rule was not intended to stop companies and their suppliers from sourcing from the Covered Countries and that such an embargo would be contrary to the intent of the Conflict Minerals Rule.
In 2016, we continued to refine the method of identifying suppliers that are within the scope of the Conflict Minerals Rule and surveyed 1,209 suppliers of retail merchandise that we sell to our customers. We received survey responses from 860, or 71%, compared to a response rate of 54% for calendar 2015. We received survey responses from, or otherwise corresponded with, 100% of our 100 largest suppliers by spend of merchandise for resale and 97% of the suppliers we initially identified as most likely to be supplying us with products that contained Subject Minerals. The improvement in our response rate since the start of our program is shown in Figure 1 below.

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1 For Calendar Year 2014, due to improved systems and processes, we were better able to identify in-scope suppliers thereby resulting in a 46% reduction in the survey population.


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The vast majority of the suppliers who completed the survey responded that the merchandise they supplied to us did not contain any necessary Subject Minerals. Based on survey responses, interviews, and our further review of the retail merchandise supplied, we identified 127 suppliers who manufactured retail merchandise for us that contained necessary Subject Minerals. Of these suppliers:
14 suppliers responded that the Subject Minerals in all the products it supplied to us for resale by us did not originate in Covered Countries, and they provided sufficient information regarding their supply chain program for us to determine that this response was reliable;
Two suppliers responded that the Subject Minerals in at least some of the products it supplied to us for resale by us originated in the Covered Countries. As noted below, we determined that both of these suppliers only sourced Subject Minerals in the Covered Countries from smelters and refiners that are compliant with the CFSI’s Conflict Free Smelters Program (CFSP).
The remaining suppliers could not determine the country of origin of all of the necessary Subject Minerals in products supplied to us for resale by us or could not provide sufficient information regarding the materials used to manufacture our products for us to determine the country of origin.
Due Diligence Measures Performed
Based on our assessment of survey responses in 2016, we implemented due diligence measures with respect to suppliers who (1) may have manufactured retail merchandise for us containing Subject Minerals and (2) had not reliably demonstrated that the Subject Minerals were not sourced from Covered Countries. These measures included:
Performance of targeted follow-up with suppliers who did not initially respond to the survey.
Verification of information regarding smelters and refiners provided by our suppliers with the CFSI’s list of conflict-free smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we determined that the smelters and refiners in the Covered Countries that were identified by nine of our suppliers were all compliant with the CFSI’s CFSP.
Requests for additional information (e.g., certificate of material analysis and bill of materials,) from suppliers whom we determined supplied items containing Subject Minerals and who provided information that was insufficient for us to determine reliably the source of Subject Minerals in retail merchandise manufactured for us. Through this effort, we were able to obtain more reliable information about the presence of Subject Minerals in items supplied to us and obtain additional smelter and refiner information.
Encouragement of suppliers who provided insufficient information regarding their supply chain to develop more robust supply chain information programs and policies.
Encouragement of suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-compliant smelters or refiners to source from smelters and refiners who are compliant with the relevant CFSP assessment protocols of the CFSI, or from another accredited organization.
Support for and engagement with CFSI. The data on which we relied for certain statements in this report was obtained through our membership in CFSI, using the Reasonable Country of Origin Inquiry report for member DISN.


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Smelters, Refiners, and Countries of Origin Information
The suppliers who manufactured retail merchandise for us that we determined contained necessary Subject Minerals identified 189 smelters or refiners that supplied them with Subject Minerals. Although we cannot determine whether retail merchandise manufactured for us contained Subject Minerals from each of these 189 smelters and refiners, we have listed each of them in Attachment A. All but seven of these smelters and refiners are compliant with the relevant CFSP assessment protocols of CFSI and/or another accredited organization. Figure 2 shows compliance by mineral.2 

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Based on the information provided by our suppliers, we have been able to determine that:
of the 189 smelters and refiners identified in Attachment A, twenty are identified by CFSI as sourcing Subject Minerals from Covered Countries;
each of these twenty smelters and refiners were determined by CFSI to be compliant with the relevant CFSP assessment protocols of the CFSI; and
the countries of origin of the Subject Minerals supplied by the smelters and refiners included in Attachment A may include those countries listed in Attachment B.
However, we cannot determine: whether the seven smelters and refiners who are not compliant with the relevant CFSP assessment protocols of the CFSI, or another accredited organization, sourced from Covered Countries; whether gold smelters certified by the RJC or LBMA sourced from the Covered Countries; and whether the suppliers who provided us with insufficient information regarding the source of Subject Minerals sourced Subject Minerals from the Covered Countries. Therefore, we are unable to determine either the facilities used to process or the source (country, mine or other location) of necessary Subject Minerals for all of the retail merchandise we sell.








 
 
2 Of the 71 gold compliant smelters, 59 were also found to be certified by the LBMA and/or RJC


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Further Development of Disney’s Conflict Minerals Compliance Program
Our efforts with respect to 2016 were devoted to increasing the response rate to our supplier survey and improving our conflict minerals survey tool. We achieved both goals by implementing a new third-party conflict minerals solution and enhancing our supplier outreach. We refined internal processes to obtain additional information from those suppliers who provided insufficient information regarding their supply chain programs to evaluate adequately the source of materials they supplied. We continued to encourage suppliers to improve their supply chain policies, source responsibly, and to source Subject Minerals from (or from sub-suppliers who source from) smelters and refiners who are compliant with the relevant CFSP assessment protocols of CFSI or any other accredited organization.
We continue to focus on refining our systems for identifying relevant suppliers and the product categories associated with each supplier, and on obtaining additional and more reliable information on each supplier’s own supply chain. We also continue to evaluate the overall quality of supply chain practices of our suppliers, the impact of encouraging adoption of robust supply chain practices in light of developing supply chain certification programs, the practices of our suppliers, and whether it is helpful and feasible to give them further incentives to strengthen their supply chain programs.




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Attachment A
Smelters and Refiners Identified by
Suppliers

The following table identifies each of the smelters and refiners identified by our suppliers as sources of Subject Minerals in retail merchandise manufactured by the supplier. The table includes the name of the smelter or refiner, the Subject Minerals supplied by the smelter or refiner, and the location of the smelter or refiner. Our suppliers could not confirm whether each smelter or refiner they used supplied Subject Minerals in retail merchandise manufactured for the Company. All but seven of the smelters and refiners identified below are currently compliant with CFSP assessment protocols of the CFSI or other accredited organizations; the seven smelters and refiners that have not been certified as compliant are marked with an asterisk (*) in the table below.
Subject Mineral
Smelter or Refiner Name
Location
Gold
Advanced Chemical Company
United States of America
Gold
Aida Chemical Industries Co., Ltd.
Japan
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp.
Japan
Gold
Asahi Refining Canada Ltd.
Canada
Gold
Asahi Refining USA Inc.
United States of America
Gold
Asaka Riken Co., Ltd.
Japan
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.*
Turkey
Gold
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
DODUCO GmbH
Germany
Gold
Dowa
Japan
Gold
Eco-System Recycling Co., Ltd.
Japan
Gold
Elemetal Refining, LLC*
United States of America
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Ltd. Hong Kong
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
ITALPREZIOSI
Italy
Gold
Jiangxi Copper Co., Ltd.
China
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Kennecott Utah Copper LLC
United States of America
Gold
Kojima Chemicals Co., Ltd
Japan


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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 S.A.
Switzerland
Gold
Metalor USA Refining Corporation
United States of America
Gold
Metalúrgica Met-Mex Peñoles, S.A. De C.V
Mexico
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Turkey
Gold
Nihon Material Co., Ltd.
Japan
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Gold
Ohura Precious Metal Industry Co., Ltd
Japan
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant"
(OJSC Krastsvetmet)
Russian Federation
Gold
PAMP S.A.
Switzerland
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Gold
PX Précinox S.A.
Switzerland
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
Republic Metals Corporation
United States of America
Gold
Royal Canadian Mint
Canada
Gold
Schone Edelmetaal B.V.
Netherlands
Gold
SEMPSA Joyería Platería S.A.
Spain
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd
China
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Gold
So Accurate Group Inc.*
United States of America
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
Umicore Brasil Ltda.
Brazil
Gold
Umicore Precious Metals Thailand
Thailand
Gold
Umicore SA Business Unit Precious Metals Refining
Belgium
Gold
United Precious Metal Refining, Inc.
United States of America
Gold
mbi S.A.
Switzerland
Gold
Western Australian Mint trading as The Perth Mint
Ausralia
Gold
Yamamoto Precious Metal Co., Ltd.
Japan
Gold
Yokohama Metal Co., Ltd.
Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
China


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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
Duoluoshan
China
Tantalum
Exotech Inc.
United States of America
Tantalum
F&X Electro-Materials 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 GmbH Goslar
Germany
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
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Tantalum
Hi-Temp Specialty Metals, Inc.
United States of America
Tantalum
Jiujiang JinXin Nonferrous Metals Co., Ltd.
China
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
LSM Brasil S.A.
Brazil
Tantalum
Mineração Taboca S.A.
Brazil
Tantalum
Mitsui Mining & Smelting
Japan
Tantalum
Molycorp Silmet A.S.
Estonia
Tantalum
ngxia Orient Tantalum Industry 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
Yichun Jin Yang Rare Metal Co., Ltd.
China
Tantalum
Zhuzhou Cement Carbide Group Co., Ltd.
China
Tin
Alpha
United States of America
Tin
An Vinh Joint Stock Mineral Processing Company*
Vietnam
Tin
China Tin Group Co., Ltd.
China
Tin
Cooperativa Metalurgica de Rondônia Ltda.
Brazil
Tin
CV Ayi Jaya
Indonesia
Tin
CV Gita Pesona
Indonesia
Tin
CV Serumpun Sebalai
Indonesia
Tin
CV United Smelting
Indonesia
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Dowa
Japan
Tin
Elmet S.L.U.
Spain
Tin
EM Vinto
Bolivia
Tin
Fenix Metals
Poland


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Tin
Gejiu Non-Ferrous Metal Processing 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-Chimique N.V.
Belgium
Tin
Mineração Taboca S.A.
Brazil
Tin
Minsur
Peru
Tin
Mitsubishi Materials Corporation
Japan
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
Operaciones Metalurgical S.A.
Bolivia
Tin
PT Alam Lestari Kencana*
Indonesia
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 Cipta Persada Mulia*
Indonesia
Tin
PT DS Jaya Abadi
Indonesia
Tin
PT Eunindo Usaha Mandiri
Indonesia
Tin
PT Inti Stania Prima
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 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
Resind Indústria e Comércio Ltda.
Brazil
Tin
Rui Da Hung
Taiwan, Province of China
Tin
Soft Metais Ltda.
Brazil
Tin
Thaisarco
Thailand
Tin
VQB Mineral and Trading Group JSC
Vietnam
Tin
White Solder Metalurgia e Mineração Ltda.
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
China


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Tin
Yunnan Tin Company Limited
China
Tungsten
A.L.M.T. TUNGSTEN Corp.
Japan
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 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 GmbH
Germany
Tungsten
H.C. Starck Smelting GmbH & Co.KG
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
Niagara Refining LLC
United States of America
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Vietnam
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Vietnam
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Xiamen Tungsten Co., Ltd.
China




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Attachment B
Countries of Origin

The following table identifies the countries of origin of the smelters and refiners identified in Attachment A and is based on the smelters and refiners provided by our suppliers and the CFSI’s reasonable country of origin data, which provides country of origin data for those smelters and refiners.
Australia
Madagascar
Austria
Malaysia
Benin
Mali
Bolivia (Plurinational State of)
Mexico
Brazil
Mongolia
Burkina Faso
Mozambique
Burundi
Myanmar
Cambodia
Namibia
Canada
Nicaragua
Chile
Nigeria
China
Panama
Colombia
Peru
Democratic Republic of the Congo
Portugal
Ecuador
Russia
Eritrea
Rwanda
Ethiopia
Senegal
France
Sierra Leone
Ghana
South Africa
Guatemala
Spain
Guinea
Thailand
Guyana
Togo
Honduras
Uganda
India
United States of America
Indonesia
Uzbekistan
Japan
Vietnam
Laos
Zimbabwe




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