EX-1.01 2 formsd2014exhibit101.htm CONFLICT MINERALS REPORT FormSD2014Exhibit101




Exhibit 1.01

CONFLICT MINERALS REPORT

OVERVIEW

This report for the reporting period from January 1, 2014 to December 31, 2014 has been prepared by SYNNEX Corporation (the “Company,” “we,” “us” or “our”) pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). As used herein and consistent with the Conflict Minerals Rule, “conflict minerals” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.
We are a business process services company offering a comprehensive range of services to resellers, retailers, original equipment manufacturers, financial and insurance institutions and several other industry verticals worldwide. We operate in two segments: Technology Solutions and Concentrix. Our Technology Solutions segment distributes peripherals, information technology systems (including data center server and storage solutions), system components, software, networking equipment, consumer electronics, and complementary products. Within the Technology Solutions segment, our distribution services are complemented by systems design and integration services. Our Concentrix segment offers a range of global business outsourcing services around process optimization, customer engagement strategy and back office automation to customers in various industry verticals. Our revenues for 2014 largely were from distribution and global business services that were not in-scope for purposes of our compliance with the Conflict Minerals Rule.

REASONABLE COUNTRY OF ORIGIN INQUIRY; DUE DILIGENCE DETERMINATION
A portion of the systems design and integration business within our Technology Solutions segment involved our manufacture, through assembly or integration, of data center servers and storage products. Conflict minerals were necessary to the functionality or production of these manufactured products. Accordingly, these products were in-scope for purposes of our compliance with the Conflict Minerals Rule.


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We purchase only finished components and do not purchase conflict minerals directly from any smelter, refiner or mine. We have relationships with an extensive network of suppliers throughout the world, and we believe that there are generally multiple tiers between the mines, smelters, refiners and our direct suppliers. Therefore, we have requested our direct suppliers to work with their upstream suppliers so that they may provide us with information about the origin of conflict minerals in the components we purchase for inclusion in the products that we manufacture.
To determine whether any of the conflict minerals in the components contained in our data center servers and storage products originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or were from recycled or scrap sources, we conducted a reasonable country of origin inquiry within the meaning of the Conflict Minerals Rule, requesting 2014 suppliers of the components we included in our manufactured products to complete the Conflict-Free Sourcing Initiative (“CFSI”) Conflict Minerals Reporting Template (“CMRT”), which includes questions regarding identified smelters and refiners in the supplier’s supply chain and the supplier’s compliance procedures. We determined that requesting our suppliers to complete the CMRT represented our reasonable best efforts to determine the mines or locations of origin of conflict minerals in our supply chain. We used a third party consultant to assist in our supplier outreach and follow-up.
All of the suppliers that completed CMRTs provided data at the company level, rather than at a level specific to the components that we purchased from them. Some suppliers indicated that conflict minerals contained in their components were not sourced from the Covered Countries, and some suppliers indicated that their products contain minerals sourced from the Covered Countries but from smelters which were certified as compliant by an independent third party. There were also suppliers that indicated they used some recycled or scrap conflict minerals content in the types of components they sell. Because all of the smelter and refiner information provided was at a company level, we were unable to determine which, if any, of the identified smelters and refiners were part of our supply chain.
After conducting a reasonable country of origin inquiry and exercising the due diligence described in this report, as applicable, and in light of the limited information specific to our products provided to us by our suppliers, we concluded for 2014 that each of our data center servers and storage products contained conflict minerals of undetermined origin. Based on the information provided by the suppliers that completed CMRTs, we believe that the facilities that may have been used to process necessary conflict minerals contained in our in-scope products include the smelters and refiners listed in the Annex at the end of this Conflict Minerals Report and we believe that

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the countries of origin of the conflict minerals contained in such products may include the countries listed in the Annex. We endeavored to determine the mine or location of origin of the necessary conflict minerals contained in our in-scope products by requesting that the suppliers provide us with a completed CMRT and through the other procedures followed by us and the third party consultant that are described in this Conflict Minerals Report.



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DUE DILIGENCE

Our due diligence measures have been designed to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing, including the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Our implementation of the OECD Guidance in respect of 2014 is discussed below. These were not all of the discrete measures that we took in furtherance of our conflict minerals policy (which is discussed below) or pursuant to the Conflict Minerals Rule and the OECD Guidance.

1.
Establish Strong Company Management Systems

We have a management system to support supply chain due diligence related to conflict minerals. Our management system included a team of subject matter experts from legal, finance, product management, and sales. The team of subject matter experts was responsible for managing our conflict minerals compliance strategy and was led by our Senior Vice President, General Counsel and Corporate Secretary and our President, Hyve Solutions Corporation. We also retained specialist outside counsel and a conflict minerals consultant to assist us with our compliance efforts.

We used the CMRT to identify smelters and refiners in our supply chain. We maintain business records relating to conflict minerals due diligence in respect of 2014, including records of due diligence processes, findings and resulting decisions, on a computerized database, and relevant materials are preserved for appropriate periods consistent with the OECD Guidance.

We have a conflict minerals policy, which is available on our website at http://ir.synnex.com/corporate-governance-document.cfm?documentid=14085. The conflict minerals policy sets forth our expectation that our supply chain procure conflict minerals responsibly and avoid sourcing that funds armed conflict contributing to the crisis in the Covered Countries. Our conflict minerals policy also sets forth our expectation that our suppliers

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facilitate our efforts at supply chain transparency by providing us with appropriate information when we request and conducting necessary due diligence to identify smelters, refiners, and/or mines from which the conflict minerals in their respective supply chains originate. We have a public email address (conflictmineralsinquiries@synnex.com) available on our website for general inquiries and grievances regarding our conflict minerals program and sources of conflict minerals.

To further our efforts in identifying and assessing conflict minerals sourcing risks in our supply chain, we have included a conflict minerals flow-down clause in new supplier contracts that requires suppliers to provide us with information about the source of conflict minerals.

2.
Identify and Assess Risks in the Supply Chain
To determine whether any of the necessary conflict minerals contained in our data center servers and storage products originated in the Covered Countries, we requested direct suppliers of the components we used in the assembly or integration of the data center servers and storage products to complete the CMRT. We requested our suppliers’ cooperation to gather information from their respective suppliers and ultimately from smelters and refiners in the supply chain. Our consultant assisted us in our supplier outreach, in tracking supplier communications, educating suppliers regarding the CMRT and conflict minerals generally, and assessing risk in and quality of supplier responses. Our consultant followed up with nonresponsive suppliers through its software tool and by direct telephone or e-mail communications by its personnel.
We reviewed the completed responses received from our suppliers. Our consultant followed up with suppliers that submitted a response that contained errors or inaccuracies pertinent to our assessment or that otherwise provided a written response determined to not be suitable to us. To the extent that a completed response identified a smelter or refiner, our consultant reviewed that information against the Standard Smelter Names tab of the CMRT and the list of compliant smelters and refiners published by the CFSI. We also consulted other publicly available information to determine if the listed entity is a smelter or refiner. We obtained countries of origin (when available) by relying on information provided by our direct suppliers. We also used the CMRT responses to review our direct suppliers’ due diligence activities, such as whether they had a conflict minerals policy and required their own suppliers to source from processing facilities validated by an independent audit.


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3.
Design and Implement a Strategy to Respond to Identified Risks

Senior management was briefed about our due diligence efforts.
We address identified risks on a case-by-case basis. This flexible approach enables us to tailor the response to the risks identified.
We intend to take the additional steps discussed under “Additional Risk Mitigation Efforts” to mitigate the risk that the necessary conflict minerals in our in-scope products benefit armed groups.

4.
Carry Out Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

In connection with our due diligence, we utilized information made available by the CFSI concerning independent third-party audits of smelters and refiners.

5.
Report on Supply Chain Due Diligence

This Conflict Minerals Report and our Form SD, which constitute our annual report on our conflict minerals due diligence, are available on our website and are filed with the Securities and Exchange Commission.

ADDITIONAL RISK MITIGATION EFFORTS

We intend to take the following additional steps to improve the due diligence conducted to further mitigate the risk that the necessary conflict minerals in our in-scope products benefit armed groups in the DRC and adjoining countries:
Continue to develop a risk management plan that outlines our responses to identified risks.
Use Revision 4.0 of the CMRT for our 2015 supplier outreach.
Request that suppliers send us for the applicable calendar year or shorter period CMRTs that are completed at the product level.
Engage with suppliers and direct them to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses.
Engage in regular ongoing risk assessment through our suppliers’ submissions of conflict minerals data.


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Caution Concerning Forward-Looking Statements
 
Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” and “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, such as our plans to improve the due diligence conducted to further mitigate the risk that the conflict minerals in our products benefit armed groups in the Covered Countries, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. These risks, uncertainties and changes include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source conflict minerals, and (3) political and regulatory developments, whether in the Covered Countries, the United States or elsewhere. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.


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ANNEX

*The following list may not include all of the smelters and refiners that processed conflict minerals in the products that we manufactured for 2014, as the list contains only smelters and refiners confirmed as smelters and refiners by the CFSI, not all of our suppliers completed CMRTs, and many of the suppliers only identified a portion of the smelters and refiners in their supply chain. Also, the list below may contain smelters and refiners that are not in our supply chain, as our suppliers that did submit CMRTs did so at a “company” level. See “Reasonable Country of Origin Inquiry; Due Diligence Determination” in the Conflict Minerals Report to which this Annex is a part for additional information concerning the information included in the table below.


Mineral
 Standard Smelter Name
 CFSI Compliance Status
Gold
Advanced Chemical Company
Known
Gold
Aida Chemical Industries Co. Ltd.
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Known
Gold
AngloGold Ashanti Córrego do Sítio Minerção
Compliant
Gold
Argor-Heraeus SA
Compliant
Gold
Asahi Pretec Corporation
Compliant
Gold
Asaka Riken Co Ltd
Active
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Compliant
Gold
Aurubis AG
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Known
Gold
Bauer Walser AG
Known
Gold
Boliden AB
Compliant
Gold
C. Hafner GmbH + Co. KG
Compliant
Gold
Caridad
Known
Gold
CCR Refinery – Glencore Canada Corporation
Compliant
Gold
Cendres + Métaux SA
Active
Gold
Chimet S.p.A.
Compliant
Gold
China National Gold Group Corporation
Known
Gold
Chugai Mining
Known
Gold
Colt Refining
Known
Gold
Daejin Indus Co. Ltd
Known
Gold
Daye Non-Ferrous Metals Mining Ltd.
Known
Gold
Do Sung Corporation
Known
Gold
Doduco
Known
Gold
Dowa
Compliant
Gold
Eco-System Recycling Co., Ltd.
Compliant
Gold
FSE Novosibirsk Refinery
Known
Gold
Gansu Seemine Material Hi-Tech Co Ltd
Known
Gold
Guangdong Jinding Gold Limited
Known
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Known
Gold
Heimerle + Meule GmbH
Compliant

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Gold
Heraeus Ltd. Hong Kong
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
Compliant
Gold
Hunan Chenzhou Mining Group Co., Ltd.
Known
Gold
Hwasung CJ Co. Ltd
Known
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
Known
Gold
Ishifuku Metal Industry Co., Ltd.
Compliant
Gold
Istanbul Gold Refinery
Compliant
Gold
Japan Mint
Compliant
Gold
Jiangxi Copper Company Limited
Known
Gold
Johnson Matthey Inc
Compliant
Gold
Johnson Matthey Ltd
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Compliant
Gold
JSC Uralelectromed
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
Compliant
Gold
Kazzinc Ltd
Compliant
Gold
Kennecott Utah Copper LLC
Compliant
Gold
Kojima Chemicals Co., Ltd
Compliant
Gold
Korea Metal Co. Ltd
Known
Gold
Kyrgyzaltyn JSC
Known
Gold
L' azurde Company For Jewelry
Compliant
Gold
Lingbao Gold Company Limited
Known
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
Known
Gold
LS-NIKKO Copper Inc.
Compliant
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
Known
Gold
Materion
Compliant
Gold
Matsuda Sangyo Co., Ltd.
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd
Compliant
Gold
Metalor Technologies (Singapore) Pte. Ltd.
Compliant
Gold
Metalor Technologies SA
Compliant
Gold
Metalor USA Refining Corporation
Compliant
Gold
Met-Mex Peñoles, S.A.
Compliant
Gold
Mitsubishi Materials Corporation
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
Compliant
Gold
Moscow Special Alloys Processing Plant
Known
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Compliant
Gold
Navoi Mining and Metallurgical Combinat
Known
Gold
Nihon Material Co. LTD
Compliant
Gold
Ohio Precious Metals, LLC
Compliant
Gold
Ohura Precious Metal Industry Co., Ltd
Compliant
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
Compliant

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Gold
OJSC Kolyma Refinery
Known
Gold
PAMP SA
Compliant
Gold
Penglai Penggang Gold Industry Co Ltd
Known
Gold
Prioksky Plant of Non-Ferrous Metals
Known
Gold
PT Aneka Tambang (Persero) Tbk
Compliant
Gold
PX Précinox SA
Compliant
Gold
Rand Refinery (Pty) Ltd
Compliant
Gold
Republic Metals Corporation
Compliant
Gold
Royal Canadian Mint
Compliant
Gold
Sabin Metal Corp.
Active
Gold
Samduck Precious Metals
Known
Gold
Samwon Metals Corp.
Known
Gold
Schone Edelmetaal
Compliant
Gold
SEMPSA Joyería Platería SA
Compliant
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
Compliant
Gold
So Accurate Group, Inc.
Known
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Active
Gold
Solar Applied Materials Technology Corp.
Compliant
Gold
Sumitomo Metal Mining Co., Ltd.
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
Compliant
Gold
The Great Wall Gold and Silver Refinery of China
Known
Gold
The Refinery of Shandong Gold Mining Co. Ltd
Compliant
Gold
Tokuriki Honten Co., Ltd
Compliant
Gold
Tongling nonferrous Metals Group Co.,Ltd
Known
Gold
Torecom
Active
Gold
Umicore Brasil Ltda
Compliant
Gold
Umicore Precious Metals Thailand
Compliant
Gold
Umicore SA Business Unit Precious Metals Refining
Compliant
Gold
United Precious Metal Refining, Inc.
Compliant
Gold
Valcambi SA
Compliant
Gold
Western Australian Mint trading as The Perth Mint
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
Compliant
Gold
Yokohama Metal Co Ltd
Active
Gold
Yunnan Copper Industry Co Ltd
Known
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Compliant
Gold
Zijin Mining Group Co. Ltd
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
Compliant
Tantalum
Duoluoshan
Compliant
Tantalum
Exotech Inc.
Compliant
Tantalum
F&X Electro-Materials Ltd.
Compliant
Tantalum
Global Advanced Metals Aizu
Compliant

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Tantalum
Global Advanced Metals Boyertown
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Compliant
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
Compliant
Tantalum
H.C. Starck Co., Ltd.
Compliant
Tantalum
H.C. Starck GmbH Goslar
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH
Compliant
Tantalum
H.C. Starck Inc.
Compliant
Tantalum
H.C. Starck Ltd.
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co.KG
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
Compliant
Tantalum
Hi-Temp
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., LTD
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
Compliant
Tantalum
KEMET Blue Metals
Compliant
Tantalum
KEMET Blue Powder
Compliant
Tantalum
King-Tan Tantalum Industry Ltd
Compliant
Tantalum
LSM Brasil S.A.
Compliant
Tantalum
Metallurgical Products India (Pvt.) Ltd.
Compliant
Tantalum
Mineração Taboca S.A.
Compliant
Tantalum
Mitsui Mining & Smelting
Compliant
Tantalum
Molycorp Silmet A.S.
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Compliant
Tantalum
Plansee SE Liezen
Compliant
Tantalum
Plansee SE Reutte
Compliant
Tantalum
QuantumClean
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd
Compliant
Tantalum
Shanghai Jiangxi Metals Co. Ltd
Known
Tantalum
Solikamsk Magnesium Works OAO
Compliant
Tantalum
Taki Chemicals
Compliant
Tantalum
Telex
Compliant
Tantalum
Ulba
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd
Compliant
Tantalum
Zhuzhou Cement Carbide
Compliant
Tin
Alpha
Compliant
Tin
China Rare Metal Materials Company
Compliant
Tin
China Tin Group Co., Ltd.
Active
Tin
CNMC (Guangxi) PGMA Co. Ltd.
Known
Tin
Cooper Santa
Active
Tin
CV Gita Pesona
Active
Tin
CV JusTindo
Active

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Tin
CV Makmur Jaya
Known
Tin
CV Nurjanah
Active
Tin
CV Serumpun Sebalai
Known
Tin
CV United Smelting
Compliant
Tin
Dowa
Compliant
Tin
EM Vinto
Compliant
Tin
Estanho de Rondônia S.A.
Known
Tin
Fenix Metals
Active
Tin
Gejiu Kai Meng Industry and Trade LLC
Known
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.
Compliant
Tin
Gejiu Zi-Li
Known
Tin
Huichang Jinshunda Tin Co. Ltd
Known
Tin
Jiangxi Nanshan
Known
Tin
Linwu Xianggui Smelter Co
Known
Tin
Magnu's Minerais Metais e Ligas LTDA
Compliant
Tin
Malaysia Smelting Corporation (MSC)
Compliant
Tin
Melt Metais e Ligas S/A
Compliant
Tin
Metallo Chimique
Compliant
Tin
Mineração Taboca S.A.
Compliant
Tin
Minsur
Compliant
Tin
Mitsubishi Materials Corporation
Compliant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Active
Tin
Novosibirsk Integrated Tin Works
Known
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Active
Tin
O.M. Manufacturing Philippines, Inc.
Active
Tin
OMSA
Compliant
Tin
PT Alam Lestari Kencana
Known
Tin
PT Artha Cipta Langgeng
Active
Tin
PT ATD Makmur Mandiri Jaya
Compliant
Tin
PT Babel Inti Perkasa
Compliant
Tin
PT Babel Surya Alam Lestari
Known
Tin
PT Bangka Kudai Tin
Known
Tin
PT Bangka Putra Karya
Compliant
Tin
PT Bangka Timah Utama Sejahtera
Known
Tin
PT Bangka Tin Industry
Compliant
Tin
PT Belitung Industri Sejahtera
Compliant
Tin
PT BilliTin Makmur Lestari
Active
Tin
PT Bukit Timah
Compliant
Tin
PT DS Jaya Abadi
Compliant
Tin
PT Eunindo Usaha Mandiri
Compliant
Tin
PT Fang Di MulTindo
Known
Tin
PT Hanjaya Perkasa Metals
Known

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Tin
PT HP Metals Indonesia
Known
Tin
PT Inti Stania Prima
Active
Tin
PT Karimun Mining
Active
Tin
PT Koba Tin
Known
Tin
PT Mitra Stania Prima
Compliant
Tin
PT Panca Mega Persada
Compliant
Tin
PT Pelat Timah Nusantara Tbk
Known
Tin
PT Prima Timah Utama
Compliant
Tin
PT Refined Bangka Tin
Compliant
Tin
PT Sariwiguna Binasentosa
Compliant
Tin
PT Seirama Tin investment
Known
Tin
PT Singkep Times Utama
Known
Tin
PT Stanindo Inti Perkasa
Compliant
Tin
PT Sumber Jaya Indah
Active
Tin
PT Supra Sukses Trinusa
Known
Tin
PT Tambang Timah
Compliant
Tin
PT Timah (Persero), Tbk
Compliant
Tin
PT Tinindo Inter Nusa
Compliant
Tin
PT Tommy Utama
Known
Tin
PT Wahana Perkit Jaya
Compliant
Tin
PT Yinchendo Mining Industry
Known
Tin
Rui Da Hung
Active
Tin
Soft Metais, Ltda.
Active
Tin
Thaisarco
Compliant
Tin
VQB Mineral and Trading Group JSC
Active
Tin
White Solder Metalurgia e Mineração Ltda.
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
Active
Tin
Yunnan Tin Company, Ltd.
Compliant
Tungsten
A.L.M.T. Corp.
Active
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Active
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Active
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
Active
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Active
Tungsten
Ganxian Shirui New Material Co., Ltd.
Known
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Compliant
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Active
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
Compliant
Tungsten
Global Tungsten & Powders Corp.
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
Active
Tungsten
H.C. Starck GmbH
Active
Tungsten
H.C. Starck Smelting GmbH & Co.KG
Active

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Mineral
 Standard Smelter Name
 CFSI Compliance Status
Tungsten
Hunan Chenzhou Mining Group Co., Ltd.
Active
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Compliant
Tungsten
Japan New Metals Co., Ltd.
Compliant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Active
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Known
Tungsten
Jiangxi Richsea New Materials Co., Ltd.
Known
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Active
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Active
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Active
Tungsten
Kennametal Fallon
Active
Tungsten
Kennametal Huntsville
Active
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Active
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
Active
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Active
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd
Compliant
Tungsten
Wolfram Bergbau und Hütten AG
Compliant
Tungsten
Wolfram Company CJSC
Active
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
Active

The suppliers disclosed the following countries of origin of the conflict minerals processed by these facilities:

Argentina, Australia, Austria, Bolivia, Botswana, Brazil, Bulgaria, Burkina Faso, Canada, Central African Republic, Chile, China, Cote d’Ivoire, Democratic Republic of the Congo, Egypt, Ethiopia, Finland, Ghana, Guinea, Indonesia, Kazakhstan, Kenya, Malaysia, Mali, Mexico, Mozambique, Namibia, Peru, Russia, Rwanda, South Africa, Thailand, Taiwan, Tanzania, Turkey, United Arab Emirates, United States, Vietnam, Zambia, Zimbabwe

The foregoing list of countries is not exhaustive and contains only the information provided by the suppliers. Countries of origin were not indicated by the suppliers for all of the disclosed smelters and refiners.


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