EX-1.01 2 aciacmreport2018.htm EXHIBIT 1.01 Exhibit



Exhibit 1.01

Acacia Communications, Inc.

Conflict Minerals Report

For the Calendar Year Ended December 31, 2018

Introduction and Summary

This Conflict Minerals Report for the year ended December 31, 2018 (this “Report”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements pursuant to Section 13(p) of the Securities Exchange Act of 1934 (“Section 13(p)”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TGs” or “conflict minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries include: Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (collectively, with the DRC, the “Covered Countries”).

In conducting due diligence on our supply chain for purposes of complying with the Rule, we designed our efforts in conformity with the internationally recognized due diligence framework provided by the Organization for Economic Co-Operation and Development (“OECD”). Specifically, our diligence efforts were based on and designed to comply with the 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 tantalum, tin, tungsten and gold (the “OECD Guidance”).

Overview

Company Profile

Acacia Communications, Inc. (“Acacia,” the “Company,” “we,” “us,” or “our”) develops, manufactures and sells high-speed coherent optical interconnect products that are designed to transform communications networks through improvements in performance, capacity and cost. By implementing optical interconnect technology in a silicon-based platform, a process Acacia refers to as the “siliconization of optical interconnects,” Acacia is able to offer products at higher speeds and density with lower power consumption, that meet the needs of cloud and service providers and can be easily integrated in a cost-effective manner with existing network equipment.

The Acacia products covered by this Conflict Minerals Report include (i) embedded modules; (ii) pluggable modules; and (iii) semiconductors. Such products are collectively referred to herein as the “Covered Products.” We have determined that hardware components incorporated into the Covered Products contain one or more conflict minerals and are covered products under the scope of the Rule.

This Report has been prepared by the management of Acacia. The information in this Report includes the activities of all majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Conflict Minerals Program & Policy





The Company has actively engaged with our customers and suppliers for several years with respect to the use of conflict minerals. Our actions are a result of the Company’s responsible and inclusive culture and longstanding leadership in corporate responsibility.

We adopted a Conflict Minerals Policy articulating our conflict minerals supply chain due diligence process and our commitment to our reporting obligations regarding conflict minerals. Our policy is available on our website: https://acacia-inc.com/conflict-minerals-policy-statement/.

Reasonable Country of Origin Inquiry

Based on our determination that during calendar year 2018 (the “Reporting Period”) we manufactured (or contracted to manufacture) Covered Products for which conflict minerals are necessary to the functionality or production, in accordance with the Rule, we conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the required conflict minerals may have originated in the Covered Countries or come from recycled scrap sources.

Our RCOI process utilized the Conflict Minerals Reporting Template (“CMRT”) version 5.11 or higher developed by the Responsible Minerals Initiative (“RMI”) to conduct a survey of all in scope suppliers. We also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process.

Acacia also uses Assent, a third-party service provider, to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we will undertake with suppliers with regard to conflict minerals.

Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of the template. Assent monitored and tracked all communications for future reporting and transparency. Acacia directly contacted suppliers that were unresponsive to Assent’s communications during the diligence process and requested that such suppliers complete the CMRT and submit such CMRT to Assent.

Based on the RCOI conducted, Acacia was unable to exclude the possibility that the 3TGs in some of its Covered Products originated, or may have originated, in the Covered Countries and did not, or may not, have originated from recycled or scrap sources. Therefore, in accordance with the Rule, Acacia performed due diligence on the source and chain of custody of the 3TGs in question.

Design of Due Diligence

We designed our conflict minerals program and due diligence measures to conform, in all material respects, with the OECD Guidance. The OECD Guidance sets out a five-step framework for due diligence and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:

1.
Establishing strong company management systems regarding conflict minerals;
2.
Identifying and assessing risks in our supply chain;
3.
Designing and implementing a strategy to respond to identified risks in our supply chain;
4.
Utilizing independent third-party audits of supply chain due diligence; and
5.
Publicly reporting on our supply chain due diligence.

We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into the Covered Products. Furthermore, Acacia does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.





The OECD Guidance specifies that the implementation of due diligence should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.

Due Diligence Performed

1) Establish Strong Company Management Systems

Internal Compliance Team

Acacia’s Conflict Minerals Compliance Team is led by the Export Control and Compliance Manager, with input from representatives from our purchasing, operations and finance teams. The Conflict Minerals Compliance Team is responsible for implementing our conflict minerals compliance strategy and briefing senior management about the results of our due diligence efforts.

Control Systems

The Company expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to Acacia are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. We rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us - including sources of 3TGs that are supplied to them from lower tier suppliers.

Supplier Engagement

Acacia engages with suppliers directly to request that they complete a valid CMRT for the products that they supply to Acacia. With respect to the OECD requirement to strengthen engagement with suppliers, Acacia is committed to supplier engagement escalation such as in-person meetings and corrective actions. Feedback from this engagement has allowed Acacia to oversee improvements in supplier responses and supplier compliance for this initiative.

Conflict Minerals Policy; Grievance Mechanisms

Acacia’s Conflict Minerals Policy is available on our website at: https://acacia-inc.com/conflict-minerals-policy-statement/.

Acacia has appropriate grievance mechanisms whereby employees and suppliers can report violations of Acacia’s policies, including with respect to conflict minerals. Suppliers and others outside of Acacia may contact our Conflict Minerals Compliance Team to communicate with us, including to report grievances, via a dedicated email address that is published in our Conflict Minerals Policy and in other communications with our suppliers.

In addition, our employees may anonymously report suspected violations using our Whistleblower Hotline - 844-403-4965 - which is available 24 hours a day, seven days a week.

Records Maintenance





Acacia has adopted a policy to retain conflict minerals related documents, including supplier responses to CMRTs, and other relevant documentation for a period of five years. Under our direction and guidance, Assent stores all of the information and findings from this process in a database that can be audited by internal or external parties.

2) Identify and Assess Risk in the Supply Chain

Risks are identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. The facilities listed in the CMRT were compared to the list of smelters and refiners maintained by the Responsible Minerals Initiative (“RMI”) to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the Reporting Period.

Identified Direct Suppliers

Due to our downstream position in the supply chain, Acacia relies on our direct suppliers to provide accurate information on the origin of conflict minerals in the materials supplied to us. We reviewed all companies selling materials to Acacia to capture all direct, or first tier, suppliers who have provided materials that contain 3TG in the Covered Products during the Reporting Period.

Conducted RCOI

We relied on the industry wide standard CMRT to poll our direct suppliers for information relevant to our conflict minerals inquiry. Similarly, we require our direct suppliers to incorporate their upstream supplier responses into their CMRT. We reviewed the information contained in the CMRT’s we received from our direct suppliers to determine our reporting obligation based on this RCOI.

Completed Additional Follow-Op

We reviewed the CMRT submissions to validate that they were complete and to identify any contradictions or inconsistencies. We also have worked with suppliers to secure updated responses where necessary.

Identify Smelters/Refiners

We collected a list of smelters/refiners that may have processed conflict minerals in our supply chain by utilizing the responses to the CMRT. We reconciled this list to the list of smelter facilities designated by the RMI Responsible Minerals Assurance Process (formerly the Conflict-Free Smelter Program). We have provided that list in this report.
In order to assess the risk that any particular smelters pose to our supply chain, we determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

We compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs.





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

We developed processes to assess and respond to the risks identified in our supply chain in consultation with our third-party conflict minerals service provider. In response to this risk assessment, Acacia has in place a risk management plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a CMRT response and to outline the required cooperation for compliance with the Rule.
We engage any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict.

4) Carry Out Independent Third-Party Audit of Supply Chain Due Diligence

We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

5) Report on Supply Chain Due Diligence

We have published our Form SD for the year ended December 31, 2018 and this Report in the Investor Relations section of our website at http://ir.acacia-inc.com. Information found on or accessed through our website is not considered part of this Report and is not incorporated by reference herein. We have also publicly filed our Form SD and this Report with the SEC.

Results of RCOI and Due Diligence

Survey Results

For the 2018 reporting period, Acacia received CMRT forms from 80% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. At the end of our program, four suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 158 in scope suppliers and received 127 CMRT submissions by May 21, 2019.

Smelters and Refiners

Our suppliers identified a total of 315 smelters and refiners that appear on the list maintained by RMI. Of these 315 smelters and refiners, 256 are validated as conflict free by RMI, and, based on information provided by RMI, a further 4 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in the Covered Products. All smelters and refiners identified by our suppliers that we believe may source 3TGs from the Covered Countries appear on RMI’s list of validated conflict free smelters and refiners; however, due to the provision of primarily company or division level CMRTs, we cannot definitively determine their connection to the Covered Products.

From the responses that we received, we identified six smelters that potentially posed a risk. We assessed risk based on factors including location of the smelters and publicly available statements that call into question the status of the facilities. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. These suppliers were contacted by Assent and Acacia to evaluate whether or not these smelters could be connected to Acacia products. The suppliers were asked to complete a product-level CMRT, rather than a company or division level CMRT, to better identify the connection to products that they supply to Acacia. Other suppliers




were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.

Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. As noted, since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A actually processed the 3TGs contained in the Covered Products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the conflict minerals contained in the Covered Products.

Countries of Origin

Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. As mentioned above under “Smelters and Refiners,” many responses were provided at the company or division level, therefore, Appendix B may contain more countries than those the Covered Products are being sourced from.

Steps Taken or to be Taken to Mitigate Risk

We have taken or intend to take the following steps to further mitigate the risk that the necessary 3TGs in the Covered Products could benefit armed groups in the Covered Countries:

•
Work closely with our third-party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners actually process 3TGs contained in the Covered Products;
•
Engage with our suppliers and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs, in particular, place a strong emphasis on supplier education and training that can be tracked and evaluated based on completion of training modules. To accomplish this, we utilize Assent’s learning management system, Assent University, and provide all in-scope suppliers with access to Assent’s conflict minerals training course and encourage all suppliers to complete all modules therein;
•
Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers;
•
Include a conflict minerals flow-down clause in new or renewed supplier contracts as well as in the terms and conditions of each purchase order issued;
•
Emphasize clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program; and
•
Incorporate Acacia’s Conflict Minerals Policy by reference into all new supplier contracts and encourage and direct new suppliers to read and accept this policy and to provide information about the source of 3TGs and smelters.

Basis for Information Reported; Forward Looking Statements

The statements included in this Report are based on the RCOI process and due diligence performed in good faith by or on behalf of Acacia. These statements are based on the information available at the time of filing this Form SD and Conflict Minerals Report. A number of factors could introduce errors or otherwise affect our disclosures. These factors include, but are not limited to, gaps in supplier or smelter data, errors or omissions by suppliers or smelters and uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules. Many suppliers and smelters are unfamiliar with the diligence process and information required to be provided under the SEC’s reporting requirements, which could lead to inaccurate responses or failure to timely provide data. Further, information that is in the public domain may not be discovered despite having conducted a reasonable search, there




may be errors in publicly available information, language barriers or errors in translation could lead to inaccurate information, there could be oversights or errors in conflict free smelter audits, materials sourced from the Covered Countries could be inaccurately categorized as out of scope, illegally tagged conflict minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, we may face difficulties obtaining information from companies that are no longer in business and smuggling of conflict minerals outside the Covered Countries may make identification of their origin more difficult. Additionally, this Report includes statements concerning Acacia Communications and its future expectations, plans and prospects that constitute “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. For this purpose, any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “may,” “should,” “expects,” “plans,” “anticipates,” “could,” “intends,” “target,” “projects,” “contemplates,” “believes,” “estimates,” “predicts,” “potential,” “will” or “continue” or the negative of these terms or other similar expressions are intended to help you identify forward-looking statements. The forward-looking statements in this press release are only predictions. Acacia Communications has based these forward-looking statements largely on its current expectations and projections about future events and financial trends that the Company believes may affect its business, financial condition and results of operations. These forward-looking statements speak only as of the date of this Report and are subject to a number of risks, uncertainties and assumptions including, without limitation, the Company’s ability to sustain or increase revenue from its larger customers, generate revenues from new customers, or offset the discontinuation of concentrated purchases by its larger customers with purchases by new or existing customers, the Company’s ability to anticipate the timing and scale of demand for our products, including from its largest customers, the Company’s expectations regarding expenses and revenue, its ability to maintain and expand gross profit, the sufficiency of the Company’s cash resources and needs for additional financing, the Company’s ability to produce products free of problems, defects, errors and vulnerabilities, the Company’s anticipated growth strategies, its expectations regarding competition, the anticipated trends and challenges in its business and the market in which it operates, the Company’s expectations regarding, and the capacity and stability of, its supply chain and manufacturing, the size and growth of the potential markets for its products and the ability to serve those markets, the scope, progress, expansion and costs of developing and commercializing its products, the timing, rate and degree of introducing any of its products into the market and the market acceptance of any of its products, the Company’s ability to establish and maintain development partnerships, its ability to attract or retain key personnel, the Company’s expectations regarding federal, state and foreign regulatory requirements, including export controls, tax law changes and interpretations, economic sanctions and anti-corruption regulations, regulatory or legislative developments in the United States and foreign countries, including trade policy and tariffs and export control laws or regulations that could impede its ability to sell its products to its customer ZTE Kangxun Telecom Co. Ltd. or any of its affiliates or that could impede its ability to sell products to other customers in certain foreign jurisdictions, particularly in China, the Company’s ability to obtain and maintain intellectual property protection for its products, and other risks set forth under the caption “Risk Factors” in the Company’s public reports filed with the SEC, including the Company’s Annual Report on Form 10-K for the year ended December 31, 2018, its Quarterly Report on Form 10-Q for the fiscal quarter ended March 31, 2019 to be filed with the SEC and in other filings that the Company may make with the SEC in the future. Because forward-looking statements are inherently subject to risks and uncertainties, some of which cannot be predicted or quantified, you should not rely on these forward-looking statements as indicative of future events. Acacia Communications assumes no obligation to publicly update or revise any forward-looking statements contained in this Report press release as a result of new information, future events or otherwise.





Appendix A - Smelter List
 

Metal
Standard Smelter Name
Smelter Facility Location
RMI Status
Gold
8853 S.p.A.
ITALY
Conformant
Gold
Abington Reldan Metals, LLC
UNITED STATES
Non Conformant
Gold
Advanced Chemical Company
UNITED STATES
Conformant
Gold
African Gold Refinery
UGANDA
Not Enrolled
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Conformant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Conformant
Gold
Argor-Heraeus S.A.
SWITZERLAND
Conformant
Gold
Asahi Pretec Corp.
JAPAN
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
Conformant
Gold
Aurubis AG
GERMANY
Conformant
Gold
Bangalore Refinery
INDIA
Conformant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
Gold
Boliden AB
SWEDEN
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Conformant
Gold
Caridad
MEXICO
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
Gold
Cendres + Métaux S.A.
SWITZERLAND
Conformant
Gold
Chimet S.p.A.
ITALY
Conformant
Gold
Chugai Mining
JAPAN
Active
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Conformant
Gold
Dowa
JAPAN
Conformant
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Conformant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Conformant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Not Enrolled




Gold
Geib Refining Corporation
UNITED STATES
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
HeeSung
KOREA, REPUBLIC OF
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not Enrolled
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
Istanbul Gold Refinery
TURKEY
Conformant
Gold
Italpreziosi
ITALY
Conformant
Gold
Japan Mint
JAPAN
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Not Enrolled
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Not Enrolled
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
Conformant
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Marsam Metals
BRAZIL
Conformant
Gold
Materion
UNITED STATES
Conformant




Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES
Conformant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
Gold
Modeltech Sdn Bhd
MALAYSIA
Non Conformant
Gold
Morris and Watson
NEW ZEALAND
Not Enrolled
Gold
Morris and Watson Gold Coast
AUSTRALIA
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Conformant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Not Enrolled
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Active
Gold
Nihon Material Co., Ltd.
JAPAN
Conformant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
Gold
PAMP S.A.
SWITZERLAND
Conformant
Gold
Pease & Curren
UNITED STATES
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Planta Recuperadora de Metales SpA
CHILE
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
Gold
PX Précinox S.A.
SWITZERLAND
Conformant
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Not Enrolled
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Not Enrolled
Gold
Remondis Argentia B.V.
NETHERLANDS
Conformant
Gold
Republic Metals Corporation
UNITED STATES
Conformant
Gold
Royal Canadian Mint
CANADA
Conformant
Gold
SAAMP
FRANCE
Conformant
Gold
Sabin Metal Corp.
UNITED STATES
Not Enrolled
Gold
Safimet S.p.A
Italy
Conformant
Gold
SAFINA A.S.
CZECH REPUBLIC
Not Enrolled
Gold
Sai Refinery
INDIA
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Non Conformant




Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Conformant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
Gold
Shangdong Humon Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Not Enrolled
Gold
Sudan Gold Refinery
SUDAN
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
Gold
SungEel HiTech
KOREA, REPUBLIC OF
Conformant
Gold
T.C.A S.p.A
ITALY
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
Non Conformant
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
Conformant
Gold
Umicore Brasil Ltda.
BRAZIL
Conformant
Gold
Umicore Precious Metals Thailand
THAILAND
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Conformant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
Conformant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES
Conformant
Tantalum
Exotech Inc.
UNITED STATES
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Conformant
Tantalum
Global Advanced Metals Aizu
JAPAN
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Conformant




Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Conformant
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Conformant
Tantalum
KEMET Blue Metals
MEXICO
Conformant
Tantalum
KEMET Blue Powder
UNITED STATES
Conformant
Tantalum
LSM Brasil S.A.
BRAZIL
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
Tantalum
NPM Silmet AS
ESTONIA
Conformant
Tantalum
Power Resources Ltd.
MACEDONIA
Conformant
Tantalum
QuantumClean
UNITED STATES
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Conformant
Tantalum
Taki Chemicals
JAPAN
Conformant
Tantalum
Telex Metals
UNITED STATES
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Conformant
Tin
Alpha
UNITED STATES
Conformant
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Conformant
Tin
China Tin Group Co., Ltd.
CHINA
Conformant
Tin
CV Ayi Jaya
INDONESIA
Conformant
Tin
CV Dua Sekawan
INDONESIA
Conformant
Tin
CV Gita Pesona
INDONESIA
Conformant
Tin
CV Tiga Sekawan
INDONESIA
Conformant
Tin
CV United Smelting
INDONESIA
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
Conformant
Tin
Dowa
JAPAN
Conformant




Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Non Conformant
Tin
EM Vinto
BOLIVIA
Conformant
Tin
Estanho de Rondônia S.A.
BRAZIL
Not Enrolled
Tin
Fenix Metals
POLAND
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Conformant
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
Conformant
Tin
Minsur
PERU
Conformant
Tin
Mitsubishi Materials Corporation
JAPAN
Conformant
Tin
Modeltech Sdn Bhd
MALAYSIA
Conformant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Conformant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Conformant
Tin
Pongpipat Company Limited
MYANMAR
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
Conformant
Tin
PT Babel Surya Alam Lestari
INDONESIA
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
Conformant
Tin
PT Bangka Serumpun
INDONESIA
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Conformant
Tin
PT Bukit Timah
INDONESIA
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
Conformant
Tin
PT Inti Stania Prima
INDONESIA
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
Conformant
Tin
PT Panca Mega Persada
INDONESIA
Conformant




Tin
PT Premium Tin Indonesia
INDONESIA
Conformant
Tin
PT Prima Timah Utama
INDONESIA
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
Conformant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Conformant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
Conformant
Tin
PT Tirus Putra Mandiri
INDONESIA
Conformant
Tin
PT Tommy Utama
INDONESIA
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Conformant
Tin
Rui Da Hung
TAIWAN
Conformant
Tin
Soft Metais Ltda.
BRAZIL
Conformant
Tin
Super Ligas
Brazil
Not Enrolled
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Conformant
Tin
Thaisarco
THAILAND
Conformant
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Conformant
Tin
Yunnan Tin Company Limited
CHINA
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Non Conformant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Conformant




Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not Enrolled
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Kennametal Fallon
UNITED STATES
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Conformant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Conformant







Appendix B - Countries of Origin

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe