0001628280-16-016814.txt : 20160527 0001628280-16-016814.hdr.sgml : 20160527 20160527170605 ACCESSION NUMBER: 0001628280-16-016814 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20151231 1.02 20151231 FILED AS OF DATE: 20160527 DATE AS OF CHANGE: 20160527 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Super Micro Computer, Inc. CENTRAL INDEX KEY: 0001375365 STANDARD INDUSTRIAL CLASSIFICATION: ELECTRONIC COMPUTERS [3571] IRS NUMBER: 770353939 STATE OF INCORPORATION: CA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-33383 FILM NUMBER: 161683171 BUSINESS ADDRESS: STREET 1: 980 ROCK AVENUE CITY: SAN JOSE STATE: CA ZIP: 95131 BUSINESS PHONE: 408-503-8000 MAIL ADDRESS: STREET 1: 980 ROCK AVENUE CITY: SAN JOSE STATE: CA ZIP: 95131 SD 1 formsd-2015.htm FORM SD Document





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 

FORM SD
Specialized Disclosure Report
 

SUPER MICRO COMPUTER, INC.
(Exact name of registrant specified in its charter)
 



 
 
 
 
 
Delaware
 
001-33383
 
77-0353939
(State or other jurisdiction
of incorporation)
 
(Commission File Number)
 
(I.R.S. Employer
Identification No.)
980 Rock Avenue, San Jose, California
 
95131
(Address of principal executive offices)
 
(Zip Code)

Howard Hideshima, telephone: (408) 546-8288
(Name and telephone number, including area code, of the person to contact in connection with this report)
 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

x
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.


  







Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Reasonable Country of Origin Inquiry:

Brief description of inquiry:

An analysis of our products was performed on the basis of which we concluded that they each contain one or more of the conflict minerals (defined below), which are necessary to their functionality or production. Therefore, the products that we manufacture or contract to manufacture are subject to the reporting obligations of Rule 13p-1 under the Securities Exchange Act of 1934. To satisfy the reasonable country of origin inquiry ("RCOI") requirement of the Conflict Minerals Rule adopted by the SEC under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), Super Micro Computer, Inc. ("Supermicro" or "we") has, in good faith, surveyed its suppliers using the Conflict-Free Sourcing Initiative ("CFSI") Conflict Minerals Reporting Template. The scope of the survey was to determine whether any of the conflict minerals (defined in Section 1502(e)(4) of the Act to include columbite-tantatlite, cassiterite, wolframite and gold and their derivatives, which are limited to tin, tantalum, tungsten and gold) that are not from recycled or scrap sources originated in the Covered Countries, which include the Democratic Republic of the Congo (the “DRC”) or an adjoining country as defined in Section 1502(e)(1) of the Act. As part of the RCOI process, we performed a scoping exercise to understand our supply chain including the relevant supplier and sub-supplier population and the products or components procured from such suppliers. We adopted a framework for evaluating responses from suppliers and identifying potential red flags in suppliers’ responses. We have also adopted a company level policy on conflict minerals which has been published on our website at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.

Based on the approach described above, we believe that we have conducted a good faith reasonable country of origin inquiry for the calendar year ended December 31, 2015. We have documented the performance of the RCOI and our analysis of the supplier responses and the scoping of our products and suppliers for our internal record keeping purposes.

Results of inquiry:

As of the date of this filing, based on the RCOI responses and an analysis of such responses, as it applies to the calendar year ended December 31, 2015, we cannot ascertain the source mine and country of origin of all of the relevant conflict minerals which are necessary to the functionality or production of our products. Therefore, we proceeded with additional due diligence measures for the purpose of determining the source and chain of custody of such conflict minerals.

Exercise Due Diligence on the Source and Chain of Custody of Our Conflict Minerals:

We are required to exercise due diligence on the conflict minerals' source and chain of custody and to follow a nationally or internationally recognized due diligence framework. Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas (the "OECD Guidance"). We have adopted and communicated our conflict mineral policy to our suppliers and customers and implemented RCOI procedures to collect additional information from our new and existing suppliers. In addition, we have established programs to encourage our suppliers to source their conflict minerals from certified conflict-free smelters.

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at http://ir.supermicro.com/sec.cfm.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:
Exhibit 1.01 -- Conflict Minerals Report for the calendar year ended December 31, 2015 as required by Items 1.01 and 1.02 of this Form.






FORWARD LOOKING STATEMENTS

This Specialized Disclosure Report on Form SD and any exhibits hereto contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties. These forward-looking statements and other information are based on our beliefs as well as assumptions made by us using information currently available. In some cases, you can identify forward-looking statements by terminology including “would,” “could,” “may,” “will,” “should,” “expect,” “intend,” “plan,” “anticipate,” “believe,” “estimate,” “predict,” “potential,” or “continue,” the negative of these terms or other comparable terminology. In evaluating these statements, you should specifically consider various factors, including the risks described in our Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2016 and our Annual Report on Form 10-K for the annual period ended June 30, 2015, as well as in our other filings with the SEC. These factors may cause our actual results to differ materially from those anticipated or implied in the forward-looking statements. We undertake no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise. We cannot guarantee future results, levels of activity, performance or achievements.

DOCUMENTS INCORPORATED BY REFERENCE

Unless otherwise stated herein, any documents, third-party materials or references to websites (including Super Micro's) are not incorporated by reference in, or considered to be a part of this Specialized Disclosure Report on Form SD and any exhibits hereto unless expressly incorporated by reference herein.







SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
 
SUPER MICRO COMPUTER, INC.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
By:
 
/s/ Howard Hideshima
 
 
 
Date: May 27, 2016
 
 
Senior VP and Chief Financial Officer
 
 
 
 







EXHIBIT INDEX
 

 
 
 
Exhibit
Number
 
Description
 
 
1.01
 
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.





EX-1.01 2 conflictmineralreport-2015.htm EXHIBIT 1.01 Exhibit

Exhibit 1.01

Super Micro Computer, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2015

I. Introduction
This report for the year ended December 31, 2015 has been prepared pursuant to Rule 13p-1 and the Specialized Disclosure Report on Form SD ("Form SD") under the Securities Exchange Act of 1934 (collectively, the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").
If a registrant determines that conflict minerals are necessary to the functionality or production of products manufactured or contracted by the registrant to be manufactured, the registrant must submit a Form SD which describes the reasonable country of origin inquiry (“RCOI”) that it undertook to determine whether such necessary conflict minerals originated from the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”).
If, on the basis of its RCOI, a registrant knows or has reason to believe that any of the necessary conflict minerals in its supply chain may have originated in any of the Covered Countries, or if it is unable to determine the country of origin of those conflict minerals, the issuer must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
This report has been prepared by Super Micro Computer, Inc. (herein referred to as “Super Micro” the “Company,” “we,” “us,” or “our”). The information contained in this report includes the activities of all of the Company's majority-owned subsidiaries and variable interest entities that are required to be consolidated.
II. Company Overview
We are a global leader in high-performance, high-efficiency server technology and innovation. We develop and provide end-to-end green computing solutions to the cloud computing, data center, enterprise IT, big data, HPC and embedded markets. Our solutions range from complete server, storage, blade and workstations to full racks, networking devices, server management software and technology support and services.
We conduct our operations principally from our headquarters in California and facilities of our subsidiaries in Taiwan, the Netherlands, China and Japan. We sell our server systems and subsystems and accessories through our direct sales force as well as through distributors and Original Equipment Manufacturers ("OEMs").
III. Supply Chain Overview
Our supply chain operations for our server products include sourcing, order management, manufacturing, delivery, and return. We procure server components from the following four major types of suppliers:
Manufacturers or direct suppliers;
Contract manufacturers producing items to match specifications and standards set by us;
Distributors or resellers of manufactured components for other manufacturers; and
Customers providing us certain parts and materials to be used to fulfill their orders.
Logistics and service providers were excluded from the reasonable country of origin inquiry ("RCOI") and due diligence measures discussed below because we have concluded that they do not provide us with any products within the scope of the Rule.
As explained further below, we rely upon our suppliers to provide information on the origin, source and chain of custody of the conflict minerals contained in product components and materials. We commenced conflict minerals due diligence in 2013.
Based on representations from these suppliers, we have determined that they obtain conflict minerals used in our products from the following types of processing facilities:

1


Tin, Tungsten, Tantalum - From smelters which procure the relevant ore and then pass it through smelting and/ or refining, as applicable.
Gold - From smelters/ refiners which either obtain gold from the mines or through recycling.
IV. Conflict Minerals Policy
We are committed to complying with Section 1502 of the Dodd-Frank Act and achieving the goal of confirming that the materials used in our products are procured from conflict-free sources. We have considered the Rule’s requirements and related guidance from the Organisation for Economic Cooperation and Development (the “OECD”), and we expect our suppliers to comply with the Code of Conduct of the Electronics Industry Citizenship Coalition (the “EICC”) and conduct their business in accordance with our supply chain responsibility expectations, as documented in our Conflict Mineral Policy (the "CM Policy") at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.
In support of this policy, we will:
Exercise due diligence with suppliers of products containing or suspected to contain conflict minerals consistent with the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition and the related supplements on gold, tin, tantalum and tungsten, (the “OECD Guidance”) as tailored to include steps appropriate for downstream companies and encourage our suppliers to do likewise with their suppliers;
Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm that the tantalum, tin, tungsten and gold in our supply chain are procured from conflict free sources; and
Collaborate with our suppliers and others on industry-wide solutions through our membership in the Conflict-Free Sourcing Initiative ("CFSI") and participation in industry-wide conflict minerals forums to encourage the manufacture of products that are DRC conflict free.
V. Reasonable Country of Origin Inquiry
Our supply chain due diligence "scope of work" included our existing component suppliers that provide products and components that contain one or more 3TG minerals (collectively referred to as "In Scope Suppliers"). To help establish our supply chain sourcing programs, we have adopted the CFSI’s Conflict Mineral Reporting Template ("CMRT") and launched a due diligence survey using the CMRT for In Scope Suppliers, which suppliers represent 100% of our total 2015 product-related sourcing expenditures. We reviewed our In Scope Suppliers and categorized them into three tiers based on procurement value. We identified our top 22 suppliers by procurement value as the first tier, followed by the next top 47 suppliers as the second tier and the remaining 262 suppliers as the third tier. The suppliers in the first and second tiers accounted 98% of our total 2015 product-related sourcing expenditures. The purpose for this classification was to facilitate a focused follow-up process with our suppliers in securing responses to the CMRT on a timely basis through appropriate allocation of resources. The percentage of CMRT received from our In Scope Suppliers during 2015 has increased to 76% in 2015 compared to 27% in 2014. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for us.
After conducting our RCOI, we were unable to determine the country of origin of the conflict minerals contained in our products that are not from recycled or scrap sources. Given this result, we determined that the Rule requires us to exercise due diligence on the source and chain of custody of the conflict minerals contained in our products, using a framework that conforms to a nationally or internationally recognized due diligence framework.
VI. Due Diligence
a.
Due Diligence Framework
We have exercised due diligence on the source and chain of custody of the necessary conflict minerals used in our products to identify minerals originating from the Covered Countries that are not from scrap or recycled sources. The due diligence processes and efforts have been developed based on the five-step framework proposed by the OECD Guidance and the related supplements for gold, tin, tantalum and tungsten.
Our conflict minerals due diligence process includes:
Establishment of strong company management systems;
Identify and assess risks in the supply chain;

2


Design and implement a strategy to respond to identified risks;
Carry out independent third-party audit of smelter/refiner’s due diligence practices; and
Report annually on supply chain due diligence.
b.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of conflict minerals, we do not have direct relationship with smelters or refiners that produce the conflict minerals within our supply chain. Accordingly, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information, as well as our smelters, may yield inaccurate or incomplete information.
c.
Brief Description of Due Diligence Measures Taken
(i)
Establishment of Strong Company Management Systems:
We have established a management system for complying with applicable conflict minerals reporting and disclosure rules. Our management system includes the development of a Conflict Minerals Oversight Committee led by our Senior VP of Operations, Senior VP and Chief Financial Officer and General Counsel, and a team of subject matter experts from relevant functions such as purchasing, quality compliance, finance, and legal. The team of subject matter experts is responsible for implementing our conflict mineral compliance policy and strategy. The Oversight Committee is briefed periodically about the results of our due diligence efforts and reports periodically to the Audit Committee of our Board of Directors.
We maintained our CM Policy that states our position on the use of conflict minerals. Our CM Policy has been communicated to all existing suppliers and was provided to new suppliers as part of our supplier "onboarding" process. We have provided training to our conflict mineral related team members.
(ii)
Identification and Assessment of Risks in the Supply Chain:
We have made reasonable efforts to identify all In Scope Suppliers that supply products that may potentially contain conflict minerals by conducting a supply chain survey using the CFSI CMRT; requesting our In Scope Suppliers to identify smelters and refiners and countries of origin of the conflict minerals in products they supply to us; following up with In Scope Suppliers that do not respond to the CMRT by requesting their responses; comparing smelters and refiners identified by our supply chain survey against the list of facilities that have received a “conflict-free” designation from the CFS Program, which designations provide country of origin; and maintaining documentation of reasonable efforts we have made to identify and assess supply chain risks. We have also reviewed the responses to identify potential red flags for further follow-up.
(iii)
Strategic Response to Identified Risks:
We have implemented a risk mitigation response to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. We will continuously make reasonable efforts to encourage suppliers who are sourcing from non-conflict-free smelters to move towards the use of conflict-free smelters. If a supplier fails to remedy the risks identified by our compliance risk assessment, we will escalate the matter to the Conflict Minerals Oversight Committee to determine whether to approve or reject the supplier based on the following factors: a cost and benefit analysis; evaluation of potential risk factors; any existing competitive bids; and whether the supplier is a single source supplier to the Company. If the Oversight Committee decides to continue a business relationship with a non-compliant supplier due to inherent limitations of our supply chain, we will use reasonable efforts to follow up with the supplier for its correction plan, and encourage the supplier to work with smelters that are certified through CFSI's CFS program. We also provide periodic compliance updates or reports to our Conflict Minerals Oversight Committee summarizing our risk mitigation efforts.

3



(iv)
Independent 3rd Party Audit of Smelter/Refiner’s Due Diligence Practices:
We do not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain the 3TG. However, we do rely upon industry efforts, including CFSI, to influence smelters and refiners to get audited and certified through CFSI’s CFS program. Pursuant to the Rule, this report is not subject to an independent private sector audit.
VII. Efforts to Determine the Mine or Location of Origin of the Conflict Minerals in Our Products and Facilities Used to Process the Conflict Minerals
The results of our RCOI and due diligence on the source and chain of custody of our necessary conflict minerals are the product of our iterative and escalating data collection and dialogue process with our In Scope Suppliers. This process is designed to obtain information regarding the smelters and refineries from which suppliers source such 3TG minerals and to confirm the status of such smelters or refineries as verified by the CFSI as a method of assessing the mine and location of origin of such conflict minerals.
Based on the responses that we received from our suppliers, we identified 358 smelters and refineries as potential sources of 3TG minerals that were reported to be in our supply chain, of which 213 have been verified by the CFSI to be conflict free and 34 are in the process of being verified. Table 1 below presents, by mineral, the total number of smelters and refineries identified and the percentage verified to be conflict free or in the CFSI Verification Process. See Appendix I for a list of smelters and refiners by name verified as conflict-free.
Table 1 - Smelters and Refiners Verified as Conflict-Free or in the CFSI Verification Process by Mineral.
 
Total Smelters and Refiners by Mineral
 
Number Verified or In Process
 
Percentage Verified or In Process
Gold
138

 
94

 
68
%
Tantalum
55

 
46

 
84
%
Tin
108

 
77

 
71
%
Tungsten
57

 
30

 
53
%
As to the remainder of the smelters and refineries that are not verified by the CFSI, we were unable to determine the mines of origin or the minerals sourced from such smelters and refineries.



4



VIII. Due Diligence Process Improvement Efforts

Due to the level of complexity of our products and the respective supply chains and our position in these supply chains as a downstream company, it will take additional time and resources for a number of our suppliers to verify the source mines and country of origin of all of the minerals used by their smelters. We intend to take the following steps to continue to improve our due diligence measures and to further mitigate the risk that trade in the conflict minerals contained in our products could benefit armed groups in Covered Countries:

Continuing to focus our efforts on collaborating with industry peers through our membership in the CFSI to improve the systems of transparency and control in our supply chain, including through our use of the latest revision of the CMRT in connection with our diligence of our supply chain.

Continuing to partner with our In-Scope Suppliers and others on industry-wide solutions through our membership in CFSI in an effort to collaboratively increase the number of verified smelters.

Enhancing our engagement with our relevant first-tier suppliers in order to further build their knowledge and capacity so they are able to provide more complete and accurate information on the source and chain of custody of conflict minerals in our supply chain.
Encouraging our supply chain to source conflict minerals from certified Conflict Free Smelters or source 3TG minerals from smelters located outside the DRC and participate in third-party audits that use the CFSI Conflict-Free Smelter Program assessment protocols.
Continuing our work to refine the process for conducting follow-up with our surveyed suppliers to more effectively resolve unreasonable or illogical responses in their surveys.    

5


Appendix I
Smelters and Refineries
Verified as Conflict Free by the CFSI
Subject Mineral
Smelter/Refiner Name
Smelter/Refiner Location
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 SA
SWITZERLAND
Gold
Asahi Pretec Corporation
JAPAN
Gold
Asahi Refining Canada Limited
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES
Gold
Asaka Riken Co., Ltd.
JAPAN
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
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Company Limited
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIA
Gold
JSC Uralelectromed
RUSSIA
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
LS-NIKKO Copper Inc.
REPUBLIC OF KOREA
Gold
Materion
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies SA
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES
Gold
Metalurgica Met-Mex Penoles, S.A. DE C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA

A-1


Gold
Moscow Special Alloys Processing Plant
RUSSIA
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 Krastvetmet
RUSSIA
Gold
OJSC Novosibirsk Refinery
RUSSIA
Gold
PAMP SA
SWITZERLAND
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIA
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Précinox SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
Schöne Edelmetaal B.V. 
NETHERLANDS
Gold
SEMPSA Joyería Platería SA
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIA
Gold
Solar Applied Materials Technology Corp.
TAIWAN
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
Gold
Valcambi SA
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
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
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Tantalum
D-Block Metals, LLC
UNITED STATES
Tantalum
Duoluoshan
CHINA
Tantalum
Exotech Inc.
UNITED STATES
Tantalum
F & X Electro-Materials Limited
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Tantalum
Guandong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck GmbH Goslar
GERMANY

A-2


Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES
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
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineração Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining & Smelting
JAPAN
Tantalum
Molycorp Silmet A.S.
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Plansee SE Liezen
AUSTRIA
Tantalum
Plansee SE Reutte
AUSTRIA
Tantalum
QuantumClean
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIA
Tantalum
Taki Chemical
JAPAN
Tantalum
Telex Metals
UNITED STATES
Tantalum
Tranzact, Inc.
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tantalum
Zhuzhou Cemented Carbide
CHINA
Tin
Alpha
UNITED STATES
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 (Metallo Group)
SPAIN
Tin
EM Vinto
BOLIVIA
Tin
Fenix Metals
POLAND
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

A-3


Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Melt Metais e Ligas S/A
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES
Tin
Metallo-Chemique 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 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 BilliTin Makmur Lestari
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 Justindo
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 Sukses Inti Makmur
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
PT Tommy Utama
INDONESIA
Tin
PT Wahana Perkit Jaya
INDONESIA
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN
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 Tin Company Limited
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA

A-4


Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
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
RUSSIA
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIETNAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Countries of origin of the conflict minerals these facilities process are believed to include: Angola, Argentina, Australia, Austria, Belgium, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Democratic Republic of Congo, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Congo, Republic of Korea, Republic of Namibia, Russian Federation, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom of Great Britain and Northern Ireland, Tanzania, Uganda, United States of America, Vietnam, Zambia and Zimbabwe.

A-5