EX-1.01 2 brcd-sdxcy16xex101.htm CONFLICT MINERALS REPORT Exhibit
Exhibit 1.01 - Conflict Minerals Report

Brocade Communications Systems, Inc.
130 Holger Way
San Jose, CA 95134

Calendar Year 2016



1.    Introduction

Background
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd Frank Act”). Section 1502 of the Dodd Frank Act specifically relates to “conflict minerals” (gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten) and added Section 13(p) to the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 (the “Rule”) and Form SD adopted by the Securities and Exchange Commission (“SEC”) require companies subject to the Rule to perform certain procedures to determine the source of conflict minerals that are determined to be necessary to the functionality or production of the products these companies manufacture or contract to manufacture. Specifically, companies are required to conduct a reasonable country-of-origin inquiry (“RCOI”) to determine whether the conflict minerals used in their products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, the “covered countries”) or were from recycled or scrap sources. If, as a result of the RCOI, a company determines that some of the necessary conflict minerals in its supply chain did originate in the covered countries (and are not from recycled or scrap sources) or if the company was unable to determine the countries of origin of all of its necessary conflict minerals, the company is required to perform due diligence on the source and chain of custody of the necessary conflict minerals to determine whether the conflict minerals were used, directly or indirectly, to finance or benefit armed groups in the covered countries, and to disclose information about the due diligence procedures the company performed.
In accordance with the Rule, Brocade Communications Systems, Inc. (“Brocade” or the “Company”) conducted an RCOI and performed due diligence on the source and chain of custody of its conflict minerals. This Conflict Minerals Report (“CMR”) describes the RCOI and due diligence activities performed in good faith for necessary conflict minerals used in Brocade’s products the manufacture of which was completed in calendar year 2016 (“CY 2016”), based on information available at the time of filing. This CMR also describes Brocade’s plans to improve its due diligence activities in calendar year 2017 (“CY 2017”).
Company and Product Overview
Brocade is a leading supplier of networking hardware, software, and services for businesses and organizations of various types and sizes. Its end customers include global enterprises and other organizations that use Brocade products and services as part of their communications infrastructure. In addition, service providers, such as telecommunication firms, cable operators, and mobile carriers, use Brocade products and services as part of their commercial operations. Brocade’s business is focused on two key markets. One is Storage Area Networking (“SAN”), where Brocade offers its SAN products, including modular directors, fixed-configuration and embedded switches, and network management and monitoring capabilities. The second is Internet Protocol (“IP”) Networking, where Brocade offers IP routers, Ethernet switches, wireless access points and controllers, network security, analytics, and monitoring, as well as products used to manage application delivery. Brocade’s IP Networking products are available in modular and fixed hardware-based form factors and can be deployed in both traditional network and next-generation fabric designs. Its IP Networking products also include a wide range of virtualized network software offerings. Brocade also provides product-related customer support and services across all its businesses.

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On May 27, 2016, Brocade completed its acquisition of Ruckus Wireless, Inc. (“Ruckus”). Prior to the closing of the acquisition, Ruckus was a publicly-traded company listed on The NASDAQ Stock Market required to file reports with the SEC under the Exchange Act. Accordingly, this CMR covers products that Ruckus contracted to manufacture that contain conflict minerals necessary to the functionality or production of such products, the manufacture of which was completed during CY 2016, including during the portion of CY 2016 prior to Brocade’s acquisition of Ruckus (the “Ruckus products”). Because of the complexity of the supply chains of the respective organizations, and because Brocade’s planned integration of the businesses and operations of the two companies was expected to continue for the remainder of CY 2016, Brocade elected to manage independent RCOI and due diligence processes with respect to (i) the Ruckus products and (ii) “classic Brocade products” (that is, products manufactured or contracted to be manufactured by Brocade excluding Ruckus products). The RCOI and due diligence inquiries on the source and chain of custody of the necessary conflict minerals (defined below) in the Ruckus products and classic Brocade products were conducted on parallel but separate tracks, each reflected below in the sections entitled “RCOI” and “Due Diligence - Overview of Due Diligence Process”, and the results of these measures for the combined company are included in the section below entitled “Due Diligence - Due Diligence Results.”
This CMR relates to products (i) for which conflict minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during CY 2016. These products are referred to in this CMR as the “in-scope products” and include:
classic Brocade products, consisting of SAN hardware products (fibre channel directors, fixed -configuration and embedded switches and extensions) and IP Networking hardware products (IP routers and Ethernet switches); and
the Ruckus products, consisting of wireless access points and controllers.

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2.
RCOI

Brocade conducted a good faith RCOI regarding the conflict minerals that were necessary to the functionality or production of the in-scope products (the “necessary conflict minerals”). This RCOI was reasonably designed to determine whether any of the necessary conflict minerals originated in the covered countries and whether any of the necessary conflict minerals may be from recycled or scrap sources.
As a downstream purchaser of products that contain conflict minerals, Brocade is many steps removed in the supply chain from the smelters or gold refiners (“SORs”) that process the minerals used in its products and from the mines of origin for the minerals. Brocade does not obtain any conflict minerals directly from mines or SORs where ores are processed; all necessary conflict minerals that may be present in the in-scope products are the result of incorporating various parts and components of products obtained from its suppliers. Therefore, Brocade determined that it was reasonable for the Company to rely on its suppliers to trace these minerals to their sources and provide information regarding the origin of the necessary conflict minerals in the in-scope products. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of conflict minerals, its ability to verify the accuracy of information reported by suppliers is limited.
Brocade utilized certain conflict minerals tools and processes developed by the Conflict-Free Sourcing Initiative (“CFSI”), a consortium of the Electronic Industry Citizenship Coalition (“EICC”), and the Global e-Sustainability Initiative (“GeSI”), specifically:
The industry standard Conflict Minerals Reporting Template (“CMRT”) for surveying in-scope suppliers for critical conflict minerals information; and
The list of known SORs with assigned identification (“ID”) numbers provided as part of the CMRT.

Brocade’s process involved collecting and evaluating completed CMRTs from its suppliers that contracted to manufacture in-scope products or provided parts and components to Brocade that were incorporated into in-scope products and that Brocade determined were likely to contain conflict minerals. Brocade considered these suppliers to be “in-scope” for the purposes of its assessment. This information included declarations regarding the presence of conflict minerals in supplier parts incorporated into the in-scope products and, to the extent such information was available, the SORs where such conflict minerals were processed and the mines of origin for such conflict minerals. Suppliers that were reluctant or unable to provide the required information were escalated to Brocade’s supply base management team or the Ruckus business unit conflict minerals team, as applicable, in order to help maximize supplier responsiveness.
Brocade surveyed a total of 190 in-scope suppliers for classic Brocade products and 240 in-scope suppliers for Ruckus products. In cases of overlap between suppliers for classic Brocade and Ruckus products, these suppliers were surveyed separately and their responses were reviewed independently by Brocade’s supply base management team and the Ruckus business unit conflict minerals team.
For CY 2016 Brocade received responses from 100% of its in-scope suppliers, including from 100% of suppliers for classic Brocade products and 100% of suppliers for Ruckus products. These suppliers identified 359 SORs that may be in Brocade’s supply chain. Based on an analysis of the completed CMRTs and information made available by the CFSI to its members, Brocade also concluded that many of these SORs sourced conflict minerals entirely from outside of the covered countries, including from recycled or scrap sources. In the course of completing its RCOI, the Company determined that some suppliers:
Did not provide complete information regarding the origins of the conflict minerals in their products, i.e., they reported that they collected data from less than 100% of their supply chain;

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Responded that they were unable to determine the origins of certain conflict minerals in their products;
Reported that they are sourcing conflict minerals from SORs that have not undergone an audit by the Conflict-Free Sourcing Program (“CFSP”) developed by the CFSI to be certified as conflict-free or that are not active in the CFSP process; or
Provided company-level responses regarding all conflict minerals used for every product they manufacture instead of more specific product- or component-level information that would be limited to the specific types of components or products supplied to the Company; as a result, there were conflict mineral sources reported to Brocade that may not actually be used in the Company’s products.

As a result, for CY 2016, Brocade was unable to determine the origin of at least a portion of the necessary conflict minerals in its in-scope products. Based on the results of the RCOI, Brocade determined that it was required to conduct due diligence for CY 2016. These due diligence efforts are discussed below.















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3.
Due Diligence


Overview of Due Diligence Process
Brocade designed its due diligence measures to be in conformity in all material respects with the internationally recognized due diligence framework in 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, Third Edition, 2016, including the related supplements on gold, tin, tantalum and tungsten (“OECD Guidance”), consistent with Brocade’s position as a downstream company. Brocade integrated the five-step OECD Guidance into its due diligence measures described below.
OECD Step 1 - Establish strong company management systems

Conflict minerals statement. Brocade adopted a conflict minerals statement that outlines its commitment to responsible sourcing of conflict minerals. The statement sets forth Brocade’s expectation of its suppliers to source minerals responsibly, conduct due diligence on the source and chain of custody of conflict minerals in their products, and provide related information to Brocade on an annual basis. The statement was approved by certain key stakeholders, communicated internally and to in-scope suppliers (including suppliers for Ruckus products) during CY 2016, and is posted on the Company’s external website at: http://www.brocade.com/en/about-us/corporate-responsibility/governance.html.
 
Conflict minerals team. Brocade developed a resource plan identifying both internal and external resources and responsibilities for implementing various aspects of its conflict minerals program. Representatives from Brocade’s environmental compliance and supply chain team (in the case of classic Brocade products) and the Ruckus business unit’s operations team (in the case of Ruckus products) managed the conflict minerals program, with cross-functional support from other departments including corporate affairs, internal audit and compliance, finance and legal. Members of the conflict minerals project teams met regularly over the course of 2016 and into 2017 to review the status of the conflict minerals program. Members of the executive team (including from the Ruckus business unit) had oversight responsibility for the work done by the conflict minerals teams and fully supported their efforts. In addition, the Company retained outside contractors to implement various aspects of its conflict minerals program, including outreach to and data collection from suppliers. Separate contractors were retained to assist with the conflict minerals program with respect to classic Brocade products and Ruckus products.
Systems of controls and transparency. In an effort to enhance its due diligence processes and improve the accuracy and completeness of supplier data, Brocade documented detailed standard operating procedures used in its conflict minerals program for each of the classic Brocade and Ruckus product lines. These documented procedures covered supplier scoping, supplier outreach and follow-up, data collection, review and validation of supplier responses, escalation of issues (e.g., non-responsive suppliers, data quality issues such as incomplete or inconsistent responses, or failure to meet other requirements) and action plans for addressing such issues. As discussed above, Brocade’s primary method for gathering information from suppliers was through the collection and evaluation of CMRTs. Brocade maintained reviewable records of conflict minerals program documents including information tracking and summarizing the status of collecting and validating supplier responses.

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Supplier engagement. Brocade developed a supplier engagement process designed to help its suppliers understand the objectives and expectations of its conflict minerals program and strategy, and ultimately strengthen supplier commitment to conflict minerals management and responsible sourcing. Key elements of this process included developing and disseminating an initial communication regarding the information required from in-scope suppliers, distributing and collecting completed CMRTs, communicating Brocade’s publicly available conflict minerals statement to in-scope suppliers (including Ruckus suppliers), developing various additional supplier communication letters and emails (e.g., to follow up with non-responsive suppliers or request additional information or other required action items) and providing or maintaining access to training sessions and other informational materials. Outreach to and engagement of suppliers for classic Brocade and Ruckus products were conducted on separate tracks, each of which involved the key elements described above. In addition, Brocade engaged with suppliers for classic Brocade products that it shared with certain key customers to encourage their adoption of conflict minerals management processes.
Establish a company grievance mechanism. Brocade enabled its employees, suppliers, customers and other stakeholders to report any concerns relating to its corporate responsibility platform or practices (including its conflict minerals program) by contacting CorporateResponsibility@brocade.com, as communicated on its publicly available website at http://www.brocade.com/en/about-us/corporate-responsibility/governance.html. As a proactive measure, on a quarterly basis or more frequently, if needed, Brocade engaged with certain customers to understand their approaches to managing conflict minerals and to help ensure Brocade provided appropriate and responsive information.

OECD Step 2 - Identify and assess risk in the supply chain

Brocade’s efforts to identify and assess risk in its supply chain included the processes and procedures outlined above under the section entitled “RCOI” and, to the extent applicable, the section entitled “Due Diligence - Overview of Due Diligence Process - OECD Step 1 - Establish strong company management systems.”
In addition, through the Company’s membership in the EICC (since July 2015), Brocade became a member of the CFSI and has attended monthly CFSI plenary meetings. Brocade utilized public and members-only conflict minerals tools and processes developed by the CFSI, including specifically:
The CFSP, under which the CFSI conducts third-party audits of SORs utilizing a standard audit protocol to determine whether an SOR is conflict-free (i.e., compliant with CFSP protocols), and the published list of SORs that are compliant under the CFSP, which list is available at: www.conflictfreesourcing.org, and is updated periodically; and
The CFSI’s Compliant Smelter Sourcing Information list, which is available only to CFSI members and provides country-of-origin information for SORs that are certified as conflict-free through the CFSP.

Brocade and its outside contractors reviewed the responses received from in-scope suppliers for plausibility, consistency and gaps in information, followed up with suppliers that submitted responses that triggered specified quality control flags, and monitored and tracked these suppliers’ progress in addressing any identified issues. Responses from suppliers for classic Brocade and Ruckus products were reviewed independently by Brocade’s supply base management team and the Ruckus business unit conflict minerals team with the assistance of their respective outside contractors, and necessary follow-up was conducted on separate tracks. Brocade reviewed the overall results of the combined company, which are reported in the section below entitled “Due Diligence - Due Diligence Results.”
CMRTs were reviewed for completeness, with a focus on whether each supplier provided all of the required information at the level of detail expected and on the correct version of the CMRT. Templates found to be incomplete or on the incorrect version of the CMRT were returned to the suppliers, which were requested to resubmit them with all of the required information.
CMRTs were also reviewed from a consistency and risk perspective to identify:

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Supplier responses for which it was not reasonable to believe the information provided; and
Key issues for which supplier follow-up was needed, including to meet Brocade’s program objectives and, in the case of classic Brocade products, certain customer requirements.
Based on the results of the review, suppliers were asked to clarify their responses, provide additional information or resubmit their CMRTs to address identified issues.
Brocade compared the names of SOR entities listed by in-scope suppliers in completed CMRTs with and without CFSI IDs to the list made available by the CFSI to determine whether the entities were in fact SORs. Brocade then compared the list of SORs identified by its in-scope suppliers to the list of SORs that had received a “conflict-free” designation by the CFSP. For SORs identified by Brocade’s suppliers that had not received a “conflict-free” designation, Brocade, with the assistance of its outside contractors, conducted additional external research to gain more information about the sourcing practices of such SORs, including countries of origin, whether there were any internal due diligence procedures or other processes the SOR may have undertaken to track the chain of custody to the source of their mineral ores, and their plans for complying with CFSP requirements. In addition, Brocade, through its outside contractor, monitored and tracked the improvement in status of such SORs when there was an available update from the CFSI.

OECD Step 3 - Design and implement a strategy to respond to identified risks

The suppliers’ responses to requested follow-up actions and requests for additional information were reviewed by Brocade and its outside contractors and, where necessary, an appropriate response on Brocade’s part was initiated. In the case of suppliers for classic Brocade products, Brocade’s responses were guided by pre-determined action plans triggered by specified risk paths. Where the outcome of these additional actions by certain suppliers did not completely address the identified risks and, as a result, those suppliers did not meet Brocade’s program objectives and requirements, Brocade developed a corrective action plan for these suppliers that Brocade currently expects to implement during its CY 2017 conflict minerals RCOI and due diligence processes. In the case of suppliers for Ruckus products, the Ruckus business unit conflict minerals team determined on a case-by-case basis the appropriate risk strategy for supply chain risks identified in the course of due diligence efforts.
Potential outcomes under Brocade’s risk management plan include continued communication with suppliers to reinforce Brocade’s expectations for its supply chain, preparing internal reports for Brocade’s senior management including recommendations to further mitigate supply chain risk, managing the supply chain risk through suspension or termination of contracts with suppliers, or working with suppliers to actively assist them in developing a conflict-free supply chain (i.e., through use of the CFSP or other means). For example, Brocade used industry-adopted tools and templates provided by the CFSI to reach out to its suppliers for classic Brocade products that identified SORs that have not received a conflict-free designation to request that they engage with such SORs to encourage and assist their participation in the CFSP. In addition, Brocade has directly communicated with the non-compliant tungsten smelters identified by its in-scope suppliers for classic Brocade products to encourage their participation in the CFSP.

OECD Step 4 - Independent third-party audits of SORs

As a downstream company, Brocade relies on the CFSI to perform independent third-party audits of SORs. Furthermore, as a contributing member of the EICC and a CFSI member, Brocade has demonstrated its support of independent third party audits of SORs by programs such as the CFSP.

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In addition, and based on the outcome of its risk review and any follow-up actions, Brocade selected a group of 21 suppliers for classic Brocade products to participate in “desktop” audits. This group consisted of certain top suppliers that indicated that they sourced conflict minerals from the covered countries, as well as one “control” supplier that indicated that it did not source conflict minerals from the covered countries. The objective of these audits was to verify the information provided in their CMRTs regarding the source and chain of custody of any conflict minerals in their products.
The audits were conducted by an experienced auditor from Brocade’s outside contractor, who was independent of the data collection process, and included: (1) independently verifying information provided by each supplier to the extent possible (e.g., by reviewing each supplier’s company website regarding its conflict minerals policy and other relevant publicly available information, such as information on identified SORs) and (2) contacting each supplier by email to request follow-up information, including additional SOR information, if needed, and completion of a questionnaire regarding its conflict minerals management system, how it derived its information on the CMRT, source of supply, and to ascertain whether the metal(s) could have come from scrap or recycled sources.
Six suppliers did not complete the requested questionnaire; however, sufficient information was provided on the companies’ CMRTs, websites, or via email responses for the auditor to complete the process. In all cases, the suppliers reported that they were collecting information from the supply chains using the CMRT and were conducting due diligence on that information. Only one of the suppliers in the desktop audit reported receiving less than 100% of the data it needed from its suppliers. Additional information regarding conflict minerals policies and reporting was publicly available for all 21 suppliers. After reviewing the results of the desktop audit, Brocade determined that the information provided by the audited suppliers in their CMRTs generally appeared to be verifiable and accurate.

OECD Step 5 - Report on supply chain due diligence

As required under the Rule, Brocade has filed its Form SD, which contains this CMR as an exhibit, with the SEC for CY 2016. Brocade expects to report annually, to the extent required by the Rule, and has posted this CMR on the Company’s website at http://www.brocade.com/en/about-us/corporate-responsibility/governance.html.

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Due Diligence Results

Following the completion of its due diligence process, Brocade determined that at least some of the necessary conflict minerals incorporated in its in-scope products may have originated in the covered countries and may not be solely from recycled or scrap sources. This conclusion is based on information provided by Brocade’s in-scope suppliers for the CY 2016 reporting period and other sources, including information made available by the CFSI and other publicly available information. Given that not all SORs identified by Brocade’s in-scope suppliers have been certified as conflict-free by the CFSP, information provided by suppliers was in some instances unverifiable or incomplete, a number of suppliers responded that information regarding the source and chain of custody of necessary conflict minerals in the in-scope products was uncertain or unknown, and many in-scope suppliers provided company-level responses regarding all conflict minerals used for every product they manufacture rather than responses specific to Brocade’s in-scope products, Brocade was unable to verify with certainty the source and chain of custody of all of the necessary conflict minerals in its in-scope products. Therefore, Brocade is unable at this time to make any specific determinations regarding the status of its in-scope products for CY 2016.
Identified Smelters and Refiners
Based on SOR information provided by Brocade’s in-scope suppliers in completed CMRTs and information published by the CFSI or otherwise made available to its members as of March 6, 2017, Brocade prepared the following lists, which together comprise all of the SORs identified by Brocade’s in-scope suppliers:
Appendix A contains a list of SORs identified by Brocade’s in-scope suppliers that have been certified by the CFSP as conflict-free (i.e., compliant with CFSP protocols).
Appendix B contains a list of SORs identified by Brocade’s in-scope suppliers that have not been certified by the CFSP as conflict-free, but that are “active” in the CFSP process (i.e., they have agreed to participate in the CFSP but the audit process has not yet been completed).
Appendix C contains a list of SORs identified by Brocade’s in-scope suppliers that have not been certified by the CFSP as conflict-free (i.e., “non-compliant”) and are not known to be participating in the CFSP process. This list includes companies identified as SORs by Brocade’s in-scope suppliers that have not been assigned CFSI ID numbers.
Brocade’s due diligence activities for CY 2016 revealed:
Brocade’s in-scope suppliers reported 359 SORs.
73% of the SORs reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP.
100% of the tantalum smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP.
77% of the tungsten smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP.
67% of the gold refiners reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP.
67% of the tin smelters reported by Brocade’s in-scope suppliers have been certified as conflict-free or are designated as active in the CFSP.
3% of the total SORs reported to Brocade by its in-scope suppliers do not have CFSI ID numbers.
As previously discussed, many of Brocade’s in-scope suppliers provided company-level responses regarding all conflict minerals used for every product they manufacture rather than responses specific to Brocade’s in-scope products; as a result, certain conflict mineral sources reported to Brocade and listed on Appendices A, B and C may not actually be used in Brocade’s in-scope products.

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Country-of-Origin Information and Efforts to Determine Mine or Location of Origin
Brocade endeavored to determine the mine or location of origin of the necessary conflict minerals contained in its in-scope products by conducting a supply chain survey with its in-scope suppliers using the CMRT and through the information made available by the CFSI to its members, as well as the other measures described in this CMR.
For country-of-origin information, the Company relied primarily on the CFSI’s Compliant Smelter Sourcing Information list, which the CFSI makes available only to its members and updates periodically, and supplemented that list with information derived from the CMRTs provided by its in-scope suppliers. The CFSI list indicates country-of-origin information for many of the SORs that have been certified to be conflict-free through the CFSP (i.e., compliant SORs).  However, the list does not include any country-of-origin information for (i) SORs designated as “active” in the CFSP process that have not been certified as conflict-free (such as those identified by Brocade’s suppliers and listed on Appendix B) or (ii) SORs that are non-compliant and not known to be participating in the CFSP process (such as those identified by Brocade’s suppliers and listed on Appendix C).  Moreover, this list does not indicate individual countries of origin of the conflict minerals (with the exception of the DRC); instead, it indicates countries of origin by category based on defined levels of sourcing risk.
Based on the CFSI’s Compliant Smelter Sourcing Information List as of March 3, 2017, and subject to the limitations of such list described above, the compliant SORs listed on Appendix A are identified by the CFSI as sourcing conflict minerals from each of the categories of countries defined by the CFSI (L1, L2, L3 and DRC) as set forth Appendix D under the section entitled “CFSI Compliant Smelter Sourcing Information List.” The list also indicates that some of the compliant SORs listed on Appendix A process conflict minerals originating solely from recycled or scrap sources.
In addition, based solely on information reported by Brocade’s in-scope suppliers for CY 2016 in completed CMRTs (which information Brocade has not verified as being accurate or complete), the additional countries listed on Appendix D under the section entitled “Additional Reported Countries of Origin” were identified by such suppliers as countries of origin for conflict minerals in their products.
Continuous Improvement and CY 2017 Activities

For its CY 2017 data collection process, Brocade currently expects to work with its suppliers that are determined to be in-scope for CY 2017 to refine SOR and country-of-origin information for its necessary conflict minerals and to strive to advance the effectiveness of its due diligence on the source and chain of custody for the necessary conflict minerals in its supply chain. In addition, Brocade is developing and expects to implement a corrective action plan for those suppliers for classic Brocade products that did not meet Brocade’s expectations as identified in its conflict minerals statement. Brocade plans to design the corrective action plan to reinforce Brocade’s expectations for its suppliers to provide better and more detailed information regarding the source of any conflict minerals in their products, to source minerals from conflict-free SORs, and to aggressively encourage non-compliant SORs to undergo certification as conflict-free. Brocade also intends to continuously monitor the CFSI’s list of SORs that have been certified as conflict-free by the CFSP for SORs that have been removed and to take the appropriate actions consistent with its risk mitigation strategy described in the section above entitled “Due Diligence -Overview of Due Diligence Process - OECD Step 3 - Design and implement a strategy to respond to identified risks.” In addition to continued engagement with suppliers, Brocade plans to follow up with the SORs to whom it has reached out directly in order to encourage their participation in the CFSP and to assess their progress.


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4.
Forward Looking Statements

This CMR contains forward-looking statements regarding future events and future results. All statements other than statements of historical fact are statements that could be deemed forward-looking statements that involve risks and uncertainties, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts, strategy and future reporting. Words such as “expects,” “intends,” “plans,” “may,” “will,” and variations of such words and similar expressions are intended to identify such forward-looking statements. Readers are cautioned that these forward-looking statements are only predictions and are subject to risks, uncertainties, and assumptions that are difficult to predict (including, but not limited to, whether industry organizations and initiatives such as the EICC and the CFSI and other supply chain transparency efforts remain effective as a source of external support in the conflict minerals compliance process, risks and uncertainties associated with the possibility of inaccurate information, fraud and other irregularities, inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information, and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, as well as the possibility of future regulatory changes). Therefore, actual results may differ materially and adversely from those expressed or implied in any forward-looking statements. Furthermore, Brocade undertakes no obligation to revise or update any forward-looking statements for any reason.

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APPENDIX A
List of Certified “Conflict-Free” (i.e., CFSP-compliant) SORs
Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Advanced Chemical Company
CID000015
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
CID000019
JAPAN
Gold
Al Etihad Gold Refinery DMCC
CID002560
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
BRAZIL
Gold
Argor-Heraeus S.A.
CID000077
SWITZERLAND
Gold
Asahi Pretec Corp.
CID000082
JAPAN
Gold
Asahi Refining Canada Limited
CID000924
CANADA
Gold
Asahi Refining USA Inc.
CID000920
UNITED STATES
Gold
Asaka Riken Co., Ltd.
CID000090
JAPAN
Gold
AU Traders and Refiners
CID002850
SOUTH AFRICA
Gold
Aurubis AG
CID000113
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
PHILIPPINES
Gold
Boliden AB
CID000157
SWEDEN
Gold
C. Hafner GmbH + Co. KG
CID000176
GERMANY
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
CANADA
Gold
Chimet S.p.A.
CID000233
ITALY
Gold
Daejin Indus Co., Ltd.
CID000328
KOREA (REPUBLIC OF)
Gold
DODUCO GmbH
CID000362
GERMANY
Gold
Dowa
CID000401
JAPAN
Gold
DSC (Do Sung Corporation)
CID000359
KOREA (REPUBLIC OF)
Gold
Eco-System Recycling Co., Ltd.
CID000425
JAPAN
Gold
Emirates Gold DMCC
CID002561
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
CID002459
UNITED STATES
Gold
Heimerle + Meule GmbH
CID000694
GERMANY
Gold
Heraeus Ltd. Hong Kong
CID000707
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
JAPAN
Gold
Istanbul Gold Refinery
CID000814
TURKEY
Gold
Japan Mint
CID000823
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CID000855
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
CID000929
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
JAPAN
Gold
Kazzinc
CID000957
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
CID000969
UNITED STATES
Gold
Kojima Chemicals Co., Ltd.
CID000981
JAPAN





Page 12


Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Korea Zinc Co., Ltd.
CID002605
KOREA (REPUBLIC OF)
Gold
Kyrgyzaltyn JSC
CID001029
KYRGYZSTAN
Gold
LS-NIKKO Copper Inc.
CID001078
KOREA (REPUBLIC OF)
Gold
Materion
CID001113
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
CID001119
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
CHINA
Gold
Metalor Technologies S.A.
CID001153
SWITZERLAND
Gold
Metalor USA Refining Corporation
CID001157
UNITED STATES
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
MEXICO
Gold
Mitsubishi Materials Corporation
CID001188
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
,INDIA
Gold
Moscow Special Alloys Processing Plant
CID001204
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
CID001220
TURKEY
Gold
Nihon Material Co., Ltd.
CID001259
JAPAN
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
CID000493
RUSSIAN FEDERATION
Gold
PAMP S.A.
CID001352
SWITZERLAND
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
INDONESIA
Gold
PX Précinox S.A.
CID001498
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
CID001512
SOUTH AFRICA
Gold
Republic Metals Corporation
CID002510
UNITED STATES
Gold
Royal Canadian Mint
CID001534
CANADA
Gold
Samduck Precious Metals
CID001555
KOREA (REPUBLIC OF)
Gold
SAXONIA Edelmetalle GmbH
CID002777
GERMANY
Gold
Schone Edelmetaal B.V.
CID001573
NETHERLANDS
Gold
SEMPSA Joyería Platería S.A.
CID001585
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
CHINA
Gold
Singway Technology Co., Ltd.
CID002516
TAIWAN
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
CID001761
TAIWAN
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
JAPAN
Gold
T.C.A S.p.A
CID002580
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CHINA
Gold
Tokuriki Honten Co., Ltd.
CID001938
JAPAN
Gold
Torecom
CID001955
KOREA (REPUBLIC OF)





Page 13


Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Umicore Brasil Ltda.
CID001977
BRAZIL
Gold
Umicore Precious Metals Thailand
CID002314
THAILAND
Gold
Umicore SA Business Unit Precious Metals Refining
CID001980
BELGIUM
Gold
United Precious Metal Refining, Inc.
CID001993
UNITED STATES
Gold
Valcambi S.A.
CID002003
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
CID002030
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
CID002778
GERMANY
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
JAPAN
Gold
Yokohama Metal Co., Ltd.
CID002129
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CHINA
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CID002243
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CID000291
CHINA
Tantalum
D Block Metals, LLC
CID002504
UNITED STATES
Tantalum
Duoluoshan
CID000410
CHINA
Tantalum
Exotech Inc.
CID000456
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.
CID000460
CHINA
Tantalum
FIR Metals & Resource Ltd.
CID002505
CHINA
Tantalum
Global Advanced Metals Aizu
CID002558
JAPAN
Tantalum
Global Advanced Metals Boyertown
CID002557
UNITED STATES
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
CHINA
Tantalum
H.C. Starck Co., Ltd.
CID002544
THAILAND
Tantalum
H.C. Starck GmbH Goslar
CID002545
GERMANY
Tantalum
H.C. Starck GmbH Laufenburg
CID002546
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
GERMANY
Tantalum
H.C. Starck Inc.
CID002548
UNITED STATES
Tantalum
H.C. Starck Ltd.
CID002549
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.
CID000731
UNITED STATES
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
CHINA
Tantalum
KEMET Blue Metals
CID002539
MEXICO
Tantalum
KEMET Blue Powder
CID002568
UNITED STATES
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
CHINA
Tantalum
LSM Brasil S.A.
CID001076
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
INDIA
Tantalum
Mineração Taboca S.A.
CID001175
BRAZIL
Tantalum
Mitsu Mining and Smelting Co., Ltd
CID001192
JAPAN
Tantalum
Molycorp Silmet A.S.
CID001200
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CHINA





Page 14


Metal
Smelter Name
Smelter Identification
Smelter Location
Tantalum
Plansee SE Liezen
CID002540
AUSTRIA
Tantalum
Plansee SE Reutte
CID002556
AUSTRIA
Tantalum
Power Resources Ltd.
CID002847
MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF)
Tantalum
QuantumClean
CID001508
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.
CID002707
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
CHINA
Tantalum
Solikamsk Magnesium Works OAO
CID001769
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co. Ltd
CID001869
JAPAN
Tantalum
Telex Metals
CID001891
UNITED STATES
Tantalum
Tranzact, Inc.
CID002571
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
CID001969
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
CHINA
Tantalum
Zhuzhou Cemented Carbide
CID002232
CHINA
Tin
Alpha
CID000292
UNITED STATES
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
CHINA
Tin
China Tin Group Co., Ltd.
CID001070
CHINA
Tin
Cooperativa Metalurgica de Rondônia Ltda.
CID000295
BRAZIL
Tin
CV Ayi Jaya
CID002570
INDONESIA
Tin
CV Dua Sekawan
CID002592
INDONESIA
Tin
CV Gita Pesona
CID000306
INDONESIA
Tin
CV Serumpun Sebalai
CID000313
INDONESIA
Tin
CV Tiga Sekawan
CID002593
INDONESIA
Tin
CV United Smelting
CID000315
INDONESIA
Tin
CV Venus Inti Perkasa
CID002455
INDONESIA
Tin
Dowa
CID000402
JAPAN
Tin
Elmet S.L.U.
CID002774
SPAIN
Tin
EM Vinto
CID000438
BOLIVIA
Tin
Fenix Metals
CID000468
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
CHINA
Tin
Gejiu Jinye Mineral Company
CID002859
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
CID001105
MALAYSIA
Tin
Melt Metais e Ligas S.A.
CID002500
BRAZIL
Tin
Metallic Resources, Inc.
CID001142
UNITED STATES
Tin
Metallo-Chimique N.V.
CID002773
BELGIUM
Tin
Mineração Taboca S.A.
CID001173
BRAZIL
Tin
Minsur
CID001182
PERU
Tin
Mitsubishi Materials Corporation
CID001191
JAPAN





Page 15


Metal
Smelter Name
Smelter Identification
Smelter Location
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
CID001337
BOLIVIA
Tin
PT Aries Kencana Sejahtera
CID000309
INDONESIA
Tin
PT Artha Cipta Langgeng
CID001399
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
CID002503
INDONESIA
Tin
PT Babel Inti Perkasa
CID001402
INDONESIA
Tin
PT Bangka Prima Tin
CID002776
INDONESIA
Tin
PT Bangka Tin Industry
CID001419
INDONESIA
Tin
PT Belitung Industri Sejahtera
CID001421
INDONESIA
Tin
PT Bukit Timah
CID001428
INDONESIA
Tin
PT DS Jaya Abadi
CID001434
INDONESIA
Tin
PT Eunindo Usaha Mandiri
CID001438
INDONESIA
Tin
PT Inti Stania Prima
CID002530
INDONESIA
Tin
PT Karimun Mining
CID001448
INDONESIA
Tin
PT Kijang Jaya Mandiri
CID002829
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
CID002870
INDONESIA
Tin
PT Menara Cipta Mulia
CID002835
INDONESIA
Tin
PT Mitra Stania Prima
CID001453
INDONESIA
Tin
PT O.M. Indonesia
CID002757
INDONESIA
Tin
PT Panca Mega Persada
CID001457
INDONESIA
Tin
PT Prima Timah Utama
CID001458
INDONESIA
Tin
PT Refined Bangka Tin
CID001460
INDONESIA
Tin
PT Sariwiguna Binasentosa
CID001463
INDONESIA
Tin
PT Stanindo Inti Perkasa
CID001468
INDONESIA
Tin
PT Sukses Inti Makmur
CID002816
INDONESIA
Tin
PT Sumber Jaya Indah
CID001471
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
CID001477
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
CID001482
INDONESIA
Tin
PT Tinindo Inter Nusa
CID001490
INDONESIA
Tin
PT Tommy Utama
CID001493
INDONESIA
Tin
Resind Indústria e Comércio Ltda.
CID002706
BRAZIL
Tin
Rui Da Hung
CID001539
TAIWAN
Tin
Soft Metais Ltda.
CID001758
BRAZIL
Tin
Thaisarco
CID001898
THAILAND
Tin
VQB Mineral and Trading Group JSC
CID002015
VIET NAM
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
BRAZIL
Tin
Yunnan Tin Company Limited
CID002180
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
CHINA






Page 16


Metal
Smelter Name
Smelter Identification
Smelter Location
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CHINA
Tungsten
Global Tungsten & Powders Corp.
CID000568
UNITED
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CHINA
Tungsten
H.C. Starck GmbH
CID002541
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
CHINA
Tungsten
Hydrometallurg, JSC
CID002649
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
CID000825
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
CHINA
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
CHINA
Tungsten
Kennametal Fallon
CID000966
UNITED STATES
Tungsten
Kennametal Huntsville
CID000105
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
CHINA
Tungsten
Moliren Ltd
CID002845
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
CID002589
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
VIET NAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
VIET NAM
Tungsten
Unecha Refractory metals plant
CID002724
RUSSIAN FEDERATION
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
CID002843
KOREA (REPUBLIC OF)
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
CHINA













Page 17


APPENDIX B
List of SORs “Active” in the CSFP Process
Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Abington Reldan Metals, LLC
CID002708
UNITED STATES
Gold
Bangalore Refinery
CID002863
INDIA
Gold
Cendres + Métaux S.A.
CID000189
SWITZERLAND
Gold
KGHM Polska Miedź Spółka Akcyjna
CID002511
POLAND
Gold
Modeltech Sdn Bhd
CID002857
MALAYSIA
Gold
Navoi Mining and Metallurgical Combinat
CID001236
UZBEKISTAN
Gold
Tony Goetz NV
CID002587
BELGIUM
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
VIET NAM
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
CHINA
Tin
Modeltech Sdn Bhd
CID002858
MALAYSIA
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CID001231
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
CHINA





















Page 18


APPENDIX C
List of SORs that are Non-Compliant and with No Known Participation in the CFSP
Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Johnson Matthey Chemicals Ltd.
 
UNITED STATES
Gold
Suichang County Garden ridge Gold factory
 
 
Gold
Zhongkuang Group Co,.Ltd.
 
 
Tin
Novosibirsk Integrated Tin Works
 
 
Tin
Shenzhen Xinhongtai Tin Co., Ltd
 
 
Tin
Super Ligas
 
BRAZIL
Tin
Xianghualing Tin Industry Co., Ltd.
 
CHINA
Tin
Yunnan Gejiu Jinye Minerals
OTH173
CHINA
Tin
Zhongshan Jinye Smelting Co., Ltd
 
 
Gold
Aktyubinsk Copper Company TOO
CID000028
KAZAKHSTAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
TURKEY
Gold
AURA-II
CID002851
UNITED STATES
Gold
Caridad
CID000180
MEXICO
Gold
Chugai Mining
CID000264
JAPAN
Gold
Colt Refining
CID000288
UNITED STATES
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
CHINA
Gold
Elemetal Refining, LLC
CID001322
UNITED STATES
Gold
Faggi Enrico S.p.A.
CID002355
ITALY
Gold
Fidelity Printers and Refiners Ltd.
CID002515
ZIMBABWE
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CID000522
CHINA
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
CHINA
Gold
Guangdong Jinding Gold Limited
CID002312
CHINA
Gold
Gujarat Gold Centre
CID002852
INDIA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
CHINA
Gold
Henan Yuguang Gold & Lead Co., Ltd.
CID002519
CHINA
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
CHINA
Gold
HwaSeong CJ Co., Ltd.
CID000778
KOREA (REPUBLIC OF)
Gold
Kaloti Precious Metals
CID002563
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
CID000956
KAZAKHSTAN
Gold
Korea Metal Co., Ltd.
CID000988
KOREA, REPUBLIC OF
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
CID001032
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CID001056
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
CHINA
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
CHINA
Gold
Materials Eco-Refining CO.,LTD
CID003085
 
Gold
Metahub Industries Sdn. Bhd.
CID002821
MALAYSIA
Gold
Morris and Watson
CID002282
NEW ZEALAND
Gold
OJSC Kolyma Refinery
CID001328
RUSSIAN FEDERATION


Page 19


Metal
Smelter Name
Smelter Identification
Smelter Location
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
CHINA
Gold
Remondis Argentia B.V.
CID002582
NETHERLANDS
Gold
SAAMP
CID002761
FRANCE
Gold
Sabin Metal Corp.
CID001546
UNITED STATES
Gold
SAFINA A.S.
CID002290
CZECH REPUBLIC
Gold
Sai Refinery
CID002853
INDIA
Gold
Samwon Metals Corp.
CID001562
KOREA (REPUBLIC OF)
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
CHINA
Gold
Shenzhen Lianfeng Hardware Plastic Products Co., Ltd.
CID002406
 
Gold
So Accurate Group, Inc.
CID001754
UNITED STATES
Gold
Sudan Gold Refinery
CID002567
SUDAN
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
CHINA
Gold
TOO Tau-Ken-Altyn
CID002615
KAZAKHSTAN
Gold
Universal Precious Metals Refining Zambia
CID002854
ZAMBIA
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
CHINA
Tin
An Thai Minerals Co., Ltd.
CID002825
VIET NAM
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
VIET NAM
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
CHINA
Tin
Estanho de Rondônia S.A.
CID000448
BRAZIL
Tin
Feinhütte Halsbrücke GmbH
CID000466
GERMANY
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
CHINA
Tin
Global Advanced Metals
CID000566
UNITED STATES
Tin
Hezhou Jinwei Tin Co., Ltd
CID000720
CHINA
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CID001063
CHINA
Tin
Metahub Industries Sdn. Bhd.
CID001136
MALAYSIA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
VIET NAM
Tin
Novosibirsk Processing Plant Ltd.
CID001305
RUSSIAN FEDERATION
Tin
Phoenix Metal Ltd.
CID002507
RWANDA
Tin
PT Alam Lestari Kencana
CID001393
INDONESIA
Tin
PT Babel Surya Alam Lestari
CID001406
INDONESIA
Tin
PT Bangka Kudai Tin
CID001409
INDONESIA
Tin
PT Bangka Putra Karya
CID001412
INDONESIA
Tin
PT Bangka Timah Utama Sejahtera
CID001416
INDONESIA
Tin
PT BilliTin Makmur Lestari
CID001424
INDONESIA
Tin
PT Cipta Persada Mulia
CID002696
INDONESIA
Tin
PT Fang Di MulTindo
CID001442
INDONESIA
Tin
PT Justindo
CID000307
INDONESIA
Tin
PT Koba Tin
CID001449
INDONESIA
Tin
PT Pelat Timah Nusantara Tbk
CID001486
INDONESIA
Tin
PT Seirama Tin investment
CID001466
INDONESIA
Tin
PT Tirus Putra Mandiri
CID002478
INDONESIA
Tin
PT Wahana Perkit Jaya
CID002479
INDONESIA
Tin
PT Yinchendo Mining Industry
CID001494
INDONESIA
Tin
Shanghai Yueqiang Metal Products Co., Ltd
CID001642
CHINA





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Metal
Smelter Name
Smelter Identification
Smelter Location
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
VIET NAM
Tungsten
ACL Metais Eireli
CID002833
BRAZIL
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CID002518
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CID000345
CHINA
Tungsten
Ganxian Shirui New Material Co., Ltd.
CID002531
CHINA
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CID000868
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CID002578
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
CHINA
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
CHINA
Tungsten
Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd.
CID001091
CHINA
Tungsten
Pobedit, JSC
CID002532
RUSSIAN FEDERATION
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
CID002538
VIET NAM
























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APPENDIX D

Country of Origin Information

CFSI Compliant Smelter Sourcing Information List

L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries: Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russia, Senegal, Sierra Leone, Spain, Thailand, Togo, United States of America, Uzbekistan, Vietnam and Zimbabwe
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing conflict minerals: Mozambique and South Africa.
L3 - Countries adjoining the DRC: Burundi, Rwanda and Uganda
DRC - The Democratic Republic of the Congo.

Additional Reported Countries of Origin
Argentina
Azerbaijan
Belgium
Estonia
Germany
Hong Kong
Italy
Kazakhstan
Korea (Republic of)
Liberia
Mauritania
Morocco
Papa New Guinea
Philippines
Poland
Singapore
Suriname
Sweden
Switzerland
Taiwan
Tanzania



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