EX-1.01 2 sony-sdex101.htm

Exhibit 1.01

Sony Corporation Conflict Minerals Report

for the Reporting Period from January 1 to December 31, 2016

 

In this document, Sony Corporation and its consolidated subsidiaries are together referred to as “Sony,” “we,” or “our.”

FORWARD-LOOKING STATEMENT DISCLAIMER

 

This document includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995, including (but not limited to) statements about expected future supplier due diligence and engagement efforts and development of company systems supporting those efforts. Many of the forward-looking statements contained in this document may be identified by the use of words such as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimate” and “potential,” among others. These forward-looking statements are based on our expectations and beliefs concerning future events and involve risks and uncertainties that may cause actual results to differ materially from current expectations. These risks and uncertainties are difficult to predict accurately and may be beyond our control, and may include (but are not limited to) the following: regulatory changes and judicial developments relating to the Conflict Minerals Rule (as defined below); changes in or developments related to our products or our supply chain; and industry developments relating to supply chain diligence, disclosure and other practices. Other risks and uncertainties relevant to our forward-looking statements are discussed in greater detail in our reports filed with the Securities and Exchange Commission. Forward-looking statements in this document speak only as of the date made, and we disclaim any obligation to update or revise these statements as a result of new developments or otherwise.

 

I.Introduction

 

This Conflict Minerals Report has been prepared to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”) for the reporting period from January 1 to December 31, 2016. The Conflict Minerals Rule imposes certain investigation and reporting requirements if a company’s manufactured products (including products contracted to be manufactured for the company) contain one or more of the following minerals necessary to the functionality or production of the products: cassiterite, columbite-tantalite (coltan) and wolframite; their derivatives tantalum, tin and tungsten; and gold (these minerals are collectively referred to as in this Report as “3TG”). The Conflict Minerals Rule refers to these minerals as “conflict minerals” regardless of their geographic origin and whether or not they fund armed conflict. Capitalized terms which are not expressly defined in this Report have the meaning set forth in the Conflict Minerals Rule.

 

Sony is committed to responsible sourcing of raw materials globally in support of human rights, labor, health and safety, environment and ethics. This commitment includes our efforts to responsibly source 3TG in the supply chain for our electronics products (as defined below). Our Conflict Minerals Policy is discussed later in this report.

 

This Report documents our efforts relating to responsible sourcing of 3TG and is publicly available on our website at: https://www.sony.net/SonyInfo/IR/library/ConflictMineralsReport2016.pdf

Information contained on our website is not incorporated by reference into this Report or the Form SD of which it is a part.

 

A discussion of our overall efforts relating to responsible sourcing of 3TG is also publicly available on our website at: http://www.sony.net/SonyInfo/csr_report/sourcing/materials/.

 1 
 

 

II.Company and Product Overview

 

Sony is engaged in the development, design, production, manufacture, offer and sale of various kinds of electronic equipment, instruments and devices for consumer, professional and industrial markets such as mobile phones, game hardware and software, network services, still and video cameras, televisions, audio and video recorders and players, and semiconductors. Sony’s primary manufacturing facilities are located in Asia including Japan. Sony also utilizes third-party contract manufacturers for certain products. Sony’s products and services are marketed throughout the world by sales subsidiaries and unaffiliated distributors as well as direct sales and offers via the Internet. Sony is engaged in the production, acquisition and distribution of motion pictures and television programming and the operation of television and digital networks. Sony is also engaged in the development, production, manufacture, and distribution of recorded music and the management and licensing of the words and music of songs as well as production and distribution of animation titles, including game applications based on the animation titles. Further, Sony is also engaged in various financial services businesses, including life and non-life insurance operations through its Japanese insurance subsidiaries and banking operations through a Japanese Internet-based banking subsidiary.

 

III.Product Scoping

 

To help achieve our responsible sourcing goals, we designated as “Responsible Management” the relevant management within Sony who are in charge of each business unit or subsidiary and are primarily responsible for the accuracy and completeness of the 3TG minerals survey results within such business unit or subsidiary. In order to determine the scope of the reasonable country of origin inquiry (“RCOI”) for our products each year, each member of Responsible Management indicated whether 3TG are necessary to the functionality or production of any products manufactured or contracted to be manufactured in the business unit or subsidiary for which he/she is responsible (the “Scoping Process”).

 

Based on the result of the Scoping Process, we determined that 3TG are necessary to the functionality or production of (i) certain electronic equipment, instruments, and devices for consumer, professional and industrial markets, and (ii) game hardware products manufactured by Sony or contracted to be manufactured by Sony (collectively, our “electronics products”). All four 3TG are contained in our in-scope electronics products, although each individual in-scope electronics product does not necessarily contain each 3TG.

 

Following the Scoping Process, we conducted our RCOI for our electronics products in line with the process in Section IV below.

 

IV.Reasonable Country of Origin Inquiry

 

Smelters and refiners (“SORs”) are the consolidating points for raw ore and are in the best position in the supply chain to determine the origin of the ores because the origin of ores cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or derivatives. Accordingly, to help drive responsible sourcing by SORs and further enhance traceability and transparency of the sources of 3TG, Sony is actively involved in both upstream-focused and downstream-focused multi-stakeholder initiatives, as described in this Report.

 

Sony does not purchase raw ore or unrefined minerals, or conduct business directly with SORs. We source our products and components from suppliers, which, in turn, source Materials (as defined below) from sub-tier suppliers. Our supply chain is extensive and complex and Sony is “downstream,” typically with many layers of suppliers positioned between ourselves and 3TG SORs and mines. Due to the complexity of our supply chain, we required our in-scope direct suppliers to provide us with information concerning the source of 3TGs in our electronics products as described in this section.

 

We believe that our RCOI was reasonably designed to determine whether any of the 3TG in our

 2 
 

electronics products manufactured in 2016 (i) originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) or (ii) were from recycled or scrap sources. Also, we believe that our RCOI conforms in all material respects to the first and second steps of the “Five-Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” as described in Annex I (the “Five-Step Framework”) of the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition), including its Supplements (the “OECD Guidance”), as it applies to each of the 3TGs and to Sony as a “downstream company.”

 

Sony maintains a procurement database, where all components, parts or materials (collectively, “Materials”) used in our electronics products are registered prior to the time of initial purchase. As the first step of our RCOI, Sony personnel reviewed the Sony procurement database to identify any relevant suppliers of Materials for our in-scope electronics products.

 

Our electronics products manufactured in 2016 may contain Materials whose suppliers were subject to the minerals surveys for 2014 and 2015 (the “Past Minerals Surveys”), as well as Materials that were newly registered on our procurement database after the period covered by the Past Minerals Surveys. Since any subsequent changes in supply chain information of registered Materials require new registration in the database, Sony relied on the results of the Past Minerals Surveys for the Materials whose suppliers were reviewed in the Past Minerals Surveys and which did not have any changes in supply chain information. As a result, Sony’s minerals survey for 2016 (the “2016 Minerals Survey”) focused on suppliers of Materials that were registered in our procurement database after the period covered by the Past Minerals Surveys, which included suppliers of any Materials re-registered due to changes in supply chain information. Our RCOI and due diligence information, as well as results as described in this Report, cover such suppliers and Materials.

 

We conducted our RCOI in line with the processes summarized below and we implemented steps one and two of the Five-Step Framework as part of our RCOI process. The headings below conform to those in the Five-Step Framework.

 

1. Establish and maintain strong company management systems

 

A. We adopted the Sony Group Conflict Minerals Policy, as well as our internal rules and procedures implementing the Policy (collectively, the “Policy”) in 2013 to help achieve responsible sourcing of 3TG in our supply chain.

 

Summary of the Policy:

It is Sony’s policy to refrain from knowingly purchasing any products, components or materials that contain minerals that are found to be financing armed activities, in order to avoid contributing to conflict through our sourcing practices. To ensure compliance with the Policy, Sony requires our suppliers to source materials from smelters determined to be compliant with the conflict-free smelter program protocols established by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative, or other smelters that have been determined to be conflict-free smelters under other trusted traceability projects. We exercise due diligence on the source and chain of custody of the minerals in our supply chain to determine supplier compliance with our Policy and follow the OECD Guidance or other internationally recognized frameworks when conducting such due diligence.

 

The Policy is publicly available on the Sony Corporation website at: http://www.sony.net/SonyInfo/csr_report/sourcing/materials/ and is also attached to this Report as Annex III.

 

The Policy has been communicated to our procurement personnel, to Responsible Management and to our suppliers. The Policy prohibits suppliers from knowingly sourcing 3TG that may be directly or indirectly financing or benefiting armed groups in a Covered Country.

 

 3 
 

We also have incorporated the requirements of our Policy into the Sony Supply Chain Code of Conduct, which is applicable to all our electronics product suppliers and has been incorporated into separate written contracts with many of them. The Sony Supply Chain Code of Conduct is publicly available on the Sony Corporation website at http://www.sony.net/SonyInfo/csr_report/sourcing/supplychain/index.html.

 

B. We established a cross-functional task force to support Sony’s responsible sourcing activities, including our compliance activities associated with the Conflict Minerals Rule (the “Task Force”). Under the Policy and our internal rules and procedures implementing the Policy, the Task Force is responsible for assessing the progress of our compliance program and identifying steps to meet our compliance obligations, as well as for training other internal stakeholders on their roles and responsibilities for implementing and supporting Sony’s responsible sourcing program. Sony’s Corporate Executive Officer in charge of Procurement is also responsible for overall implementation of the Policy and our supply chain processes. The Corporate Executive in charge of Procurement, who reports to the Corporate Executive Officer in charge of Procurement, is also responsible for overseeing compliance with the Policy and our efforts toward conflict-free 3TG sourcing.

 

To support our compliance efforts, we also utilize the services of outside specialists, such as an accounting firm consultant and specialist outside counsel.

 

C. We requested our in-scope direct suppliers to fully disclose whether there are any 3TGs in the Materials supplied to us, which may include information obtained from sub-tier suppliers.

 

D. Sony requested all in-scope direct suppliers to comply with the Policy requirements on responsible sourcing, to fully cooperate with our due diligence efforts described in this Report, and to establish and implement their own policy and management structure to help achieve responsible sourcing of 3TG in accordance with the terms of the Policy. We provided training and/or other relevant materials to help such suppliers understand the Policy and to assist such suppliers with our due diligence and related compliance efforts.

 

E. We maintain a hotline to allow any interested party to voice concerns regarding the circumstances of mineral extraction, trade, handling and/or exports from conflict-affected and other high-risk areas and responded to comments we received. We also participated in industry efforts to develop specific grievance mechanisms for conflict minerals-related issues, including the Public-Private Alliance for Responsible Minerals Trade’s (“PPA”) efforts to establish an in-region hotline.

 

2. Identify and assess risk in the supply chain

 

We surveyed all in-scope direct suppliers to determine the status of any 3TGs in Materials supplied to Sony and that were contained in products that we manufactured or contracted to have manufactured during the 2016 reporting cycle. As noted earlier in this Report, for a portion of our RCOI, we utilized the results of the Past Minerals Surveys.

 

We utilized the Conflict Minerals Reporting Template (“CMRT”) survey tool to collect this information and asked these suppliers to respond to the CMRT at their product level, rather than at the company level, so that we could conduct a better RCOI and due diligence on the supply chain of our products. In the CMRT, we requested the supplier to confirm whether its products contained one or more 3TG. If the product contained 3TG, we requested the supplier to identify for each such mineral: (a) the SOR where it was processed, (b) its country of origin, and (c) its mine of origin. We reviewed these CMRTs to determine whether any of the 3TG in our electronic products that were manufactured in 2016 originated in the Covered Countries or were from recycled or scrap sources and to identify the SORs of 3TG in our supply chain. We reviewed all CMRTs to validate that they were complete and to identify any contradictions or inconsistencies, including determining whether an identified entity was actually a SOR and whether the relevant Materials contained the particular minerals reported by the supplier. We worked with suppliers to secure updated responses, as necessary.

 4 
 

 

We compared the SORs identified by in-scope direct suppliers in the CMRT against the list of SOR facilities that have been validated as a “Conflict Free Smelter” (“CFS”) by the Conflict-Free Smelter Program (“CFSP”) for tantalum, tin, tungsten and gold and/or have been validated by London Bullion Market Association and/or the Responsible Jewellery Council for gold, published on the website of the Conflict-Free Sourcing Initiative (“CFSI”), a leading industry program that helps manage risk by improving supply chain transparency on conflict minerals, and also against the more detailed RCOI data provided by the CFSI to its members. The CFSP uses an independent third-party audit to identify SORs that have systems in place to assure sourcing of conflict-free materials. We also screened the named SORs utilizing a third-party screening tool to help assure that none of the named SORs were included on the United States Office of Foreign Asset Control sanctions lists.

 

As a result of the RCOI process described earlier in this Report, we identified some of the locations of origin of the 3TG in Materials used in products that we manufactured or contracted to have manufactured in 2016, as set forth on the attached Annex I. Sony determined it had insufficient information to conclude either (i) that there was no reason to believe that any of its necessary 3TG originated in the Covered Countries, or (ii) that all of its necessary 3TG came from recycled or scrap sources. Therefore, Sony was required to conduct due diligence as described in Section V below pursuant to the Conflict Minerals Rule.

V.Due Diligence Measures

 

We conducted due diligence on the source and chain of custody of 3TG in our electronics products to ascertain whether any of these 3TG originated in the Covered Countries and financed or benefited armed groups in such countries. As a downstream company typically many levels removed from the SORs, our due diligence measures, consistent with the Five-Step Framework, are necessarily based, in part, on multi-industry initiatives that engage with SORs that process the 3TG in our suppliers’ Materials. Sony also relied on its direct suppliers to provide information on the origin of any 3TG contained in the Materials that they sell to us.

 

1.         Design of Due Diligence Measures

 

 

Our 3TG due diligence measures have been designed to conform, in all material respects, with the Five-Step Framework. Steps one and two, which are parts of our RCOI, were addressed in Section IV.

 

Pursuant to the Policy and our RCOI, we determine which SORs identified in the course of our RCOI have been validated as a CFS by the CFSP. Also, pursuant to the Policy, we review all CMRTs received from suppliers and conduct a risk assessment for each such supplier.

 

 

2.         Due Diligence Performance

 

 

A. Sony requested its suppliers to source minerals from sources not known to support conflict and to exercise due diligence on the source of any 3TG contained in products they provide to Sony. We established these requirements through our Sony Supplier Chain Code of Conduct and our Policy.

 

Responsible Management, by him/herself or through investigators appointed by and under the oversight of Responsible Management, reviewed all CMRTs received from in-scope direct suppliers to identify 3TG sourcing and any conflict minerals risk for each such supplier. In addition to the above review, a member of the Task Force made a random check of CMRTs. The CMRTs were reviewed for specific quality control issues and red flags. Identified risks included a supplier’s failure to adopt a 3TG policy regarding responsible sourcing, failure to properly complete

 5 
 

the CMRT, and/or identification of SORs that were not on the CFSP list.

 

We have implemented a remediation plan that contemplates various actions based on the identified risk. Remediation plans include contacting the supplier to request a response or verify the accuracy of the CMRT, identification of additional SORs from which to source 3TG, increased use of 3TG sourced from SORs participating in the CFSP, adoption of a conflict-free 3TG sourcing policy compatible with the Policy, and/or encouragement of SORs to become conflict-free, through participation in CFSP and equivalent programs. The particular plan depends on the particular risk identified. If a supplier does not cooperate with a request and/or we do not see an improvement by such supplier, we intend to take further actions to achieve conflict-free sourcing over time, including, without limitation, cancelling the contract of a non-compliant supplier or implementing a phased-in termination of the business relationship by stopping new orders, as approved by the Corporate Executive Officer in charge of Procurement.

 

Based on the assessment of risks identified through our due diligence for the Past Minerals Survey, we sent a letter to each potentially non-compliant in-scope direct supplier asking for remediation of the identified risk. As a result of such request, the response rate for 2016 Minerals Survey has improved from the Past Minerals Survey. In light of the improvement, we believe that this approach is effective and we will also send a letter to potentially non-compliant in-scope direct suppliers identified through our due diligence for 2016 Minerals Survey, as we did last year.

 

Risks identified for the 2016 Minerals Survey include:

 

Failure to respond to CMRT;
Identification of additional SORs;
Failure to adopt a conflict-free sourcing policy compatible with the Policy, including a request for review of such supplier’s policy;
Failure to promote the use of 3TG sourced from SORs participating in the CFSP; and
Failure to encourage SORs to participate in the CFSP and become validated as compliant if   not already CFSP-compliant.

As a member of the CFSI Smelter Engagement team, we also directly contacted all uncertified SORs identified by our direct suppliers and asked them to undergo a CFSP audit to become validated as CFS.

 

B. As contemplated by the OECD Guidance, Sony is a member of the CFSI, an industry initiative that sponsors the CFSP, which has developed a process to trace the origin of 3TG and audits the due diligence activities of SORs. Sony obtained country of origin data for SORs through our membership in the CFSI using the Reasonable Country of Origin Inquiry Data made available by the CFSI for its members. In order to encourage all SORs in our supply chain to be validated as a CFS, we also made a donation in 2016 to “The Initial Audit Fund” managed by the CFSI, which encourages smelters to participate in the CFSP by paying for the costs of their initial audit.

 

In addition, Sony participates in industry-driven multi-stakeholder programs and alliances that seek to implement and/or enhance chain of custody transparency and a traceability system, identify upstream actors in the supply chain and identify and prevent or mitigate the adverse impact associated with 3TG mineral extraction in high-risk areas:

 

·Sony is a financial sponsor and active participant in the PPA, an initiative spearheaded by the United States Department of State and the Agency for International Development.

 

·Sony is a longstanding member of EICC, an organization devoted to improving social and environmental conditions in electronic manufacturing supply chains. The EICC has established a Code of Conduct that codifies standard expectations of electronics supply chains regarding conflict minerals. The Sony Supply Chain Code of Conduct is based on
 6 
 

the EICC Code of Conduct.

 

·Sony is a member of the Japan Electronics and Information Technology Industries Association and Trade Association’s Responsible Minerals Trade working group.

 

C. Sony’s Policy and other responsible sourcing information, including Sony Supply Chain Code of Conduct, are available on our external website. As required by the Conflict Minerals Rule, we file this Report, and the Form SD of which it is a part, annually with the SEC. This Report is also publicly available on our website, at https://www.sony.net/SonyInfo/IR/library/ConflictMineralsReport2016.pdf

 

3.         Future Efforts to Mitigate Risks in our Supply Chain and Improve Due Diligence.

 

With respect to suppliers that have not yet responded to our due diligence request, Responsible Management will be taking appropriate actions to secure responsible sourcing, such as visiting such suppliers directly to demand that they respond to our requests and comply with our policy and reminding them to source materials from smelters determined to be compliant with the CFSP protocols.

A discussion of our overall efforts relating to the responsible sourcing of 3TG is also publicly available on our website at: http://www.sony.net/SonyInfo/csr_report/sourcing/materials/.

 

 7 
 

 

VI.Results of Due Diligence Measures

 

Sony’s RCOI and due diligence on the source and chain of custody of 3TG contained in our electronics products revealed that the SORs identified by our direct suppliers fell into the categories detailed below. We compared the SORs listed below against the list of compliant and active SORs published by the CFSI on its website, as of February 28, 2017 (the “Smelter Reference List”):

 

(i)Our in-scope direct suppliers identified a total of 304 SORs as potential sources of 3TG in Materials supplied to Sony that were reported to be in our supply chain at some point during 2016. The country locations of the SORs that our in-scope direct suppliers identified and reported are listed in Annex II.

 

a.Of those 304 SORs, 259 SORs were validated as CFS by the CFSI or are now under the CFSI audit process. Among these 259 SORs, the number of SORs for each 3TG is as follows:

 

Gold : 135 SORs (of these SORs, 78 SORs are validated as CFS)
Tantalum : 44 SORs (of these SORs, 44 SORs are validated as CFS)
Tin : 81 SORs (of these SORs, 59 SORs are validated as CFS)
Tungsten : 44 SORs (of these SORs, 30 SORs are validated as CFS)

 

b.Among these 259 SORs, our suppliers identified 54 SORs in our supply chain that sourced gold, tantalum and/or tin from three of the Covered Countries, but each of those smelters was listed as CFS on the CFSI website.

 

c.The other 45 SORs identified by our suppliers were not validated as CFS or engaged in the audit process. Due to the limited information from our in-scope direct suppliers, we were unable to verify the location of these SORs, or the country or mine of origin of the 3TG sourced from these SORs, but none of these suppliers identified any SORs that were located in or sourced from a Covered Country.

 

(ii)Some in-scope direct suppliers did not identify the SORs that were the source of 3TG in the Materials they supplied to Sony (or indicate whether the 3TG came from scrap or recycled sources). Such suppliers include (a) those that did not respond or returned incomplete or inconsistent responses to the CMRT and (b) those that responded that they did not have information about the SORs.

 

Sony’s due diligence did not reveal that any 3TG used in our electronics products was sourced from a Covered Country, except for those sourced through SORs validated as CFS, or financed or benefited armed groups in a Covered Country. However, Sony nevertheless concluded in good faith for 2016 that it lacks sufficient information to determine the location or mine of origin of all of the 3TG in our electronics products.

 

Based on the information at a product level provided by our in-scope direct suppliers and our own due diligence efforts, including comparing that information against the above Smelter Reference List, we believe that the SORs that may have been used to process the 3TG minerals in our in-scope products in 2016 include the SORs listed in Annex II.

 

 8 
 

Annex I

Locations of 3TG origin Sony identified based on the information provided by in-scope direct suppliers focused in the 2016 Minerals Survey are as follows:

 

 

Australia, Austria, Belarus, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Democratic Republic of Congo, Ecuador, Ethiopia, France, Germany, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Laos, Madagascar, Malaysia, Myanmar, Mexico, Mongolia, Morocco, Mozambique, Namibia, Nicaragua, Nigeria, Panama, Peru, Philippines, Portugal, Russia, Rwanda, Sierra Leone, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, United States of America, Uzbekistan, Vietnam, Zimbabwe

 

 9 
 

 

 

Annex II

 

The facilities identified by direct suppliers that may have been used to process the 3TG minerals in our electronics products include the following smelters and refiners:

 

Validatedas CFS or under the CFSI audit process

 

Subject

Mineral

Company Country
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA
Gold Advanced Chemical Company UNITED STATES OF AMERICA
Gold Aida Chemical Industries Co., Ltd. JAPAN
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN
Gold AngloGold Ashanti Córrego do Sítio Mineração BRAZIL
Gold Argor-Heraeus S.A. SWITZERLAND
Gold Asahi Pretec Corp. JAPAN
Gold Asahi Refining Canada Ltd. CANADA
Gold Asaka Riken Co., Ltd. JAPAN
Gold AU Traders and Refiners SOUTH AFRICA
Gold Bangalore Refinery INDIA
Gold Boliden AB SWEDEN
Gold C. Hafner GmbH + Co. KG GERMANY
Gold CCR Refinery - Glencore Canada Corporation CANADA
Gold Cendres + Métaux S.A. SWITZERLAND
Gold Central Bank of the Philippines Gold Refinery & Mint PHILIPPINES
Gold Chimet S.p.A. ITALY
Gold Daejin Indus Co., Ltd. REPUBLIC OF KOREA
Gold Do Sung Corporation REPUBLIC OF KOREA
Gold DODUCO GmbH GERMANY
Gold Dowa JAPAN
Gold Eco-System Recycling Co., Ltd. JAPAN
Gold Emirates Gold DMCC UNITED ARAB EMIRATES
Gold FSE Novosibirsk Refinery RUSSIAN FEDERATION
Gold Geib Refining Corporation UNITED STATES OF AMERICA
Gold Heimerle + Meule GmbH GERMANY
Gold Heraeus Ltd. Hong Kong CHINA
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA
 10 
 

 

Gold Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
Gold Japan Mint JAPAN
Gold Jiangxi Copper Co., Ltd. CHINA
Gold Johnson Matthey Inc. UNITED STATES OF AMERICA
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION
Gold JSC Uralelectromed RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
Gold Kazzinc KAZAKHSTAN
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
Gold KGHM Polska Miedź Spółka Akcyjna POLAND
Gold Kojima Chemicals Co., Ltd. JAPAN
Gold Korea Zinc Co., Ltd. REPUBLIC OF KOREA
Gold Kyrgyzaltyn JSC KYRGYZSTAN
Gold LS-NIKKO Copper Inc. REPUBLIC OF KOREA
Gold Materion UNITED STATES OF AMERICA
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold Metalor Technologies (Hong Kong) Ltd. CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
Gold Metalor Technologies (Suzhou) Ltd. CHINA
Gold Metalor Technologies S.A. SWITZERLAND
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO
Gold Mitsubishi Materials Corporation JAPAN
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN
Gold MMTC-PAMP India Pvt., Ltd. INDIA
Gold Modeltech Sdn Bhd MALAYSIA
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN
Gold Nihon Material Co., Ltd. JAPAN
Gold Norddeutsche Affinererie AG GERMANY
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA
Gold Ohio Precious Metals, LLC UNITED STATES OF AMERICA
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION
Gold PAMP S.A. SWITZERLAND
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
 11 
 

 

Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Précinox S.A. SWITZERLAND
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold Republic Metals Corporation UNITED STATES OF AMERICA
Gold Royal Canadian Mint CANADA
Gold Samduck Precious Metals REPUBLIC OF KOREA
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold Schone Edelmetaal B.V. NETHERLANDS
Gold SEMPSA Joyería Platería S.A. SPAIN
Gold Shandong Gold Mine(Laizhou) Smelter 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 RUSSIAN FEDERATION
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 Tokuriki Honten Co., Ltd. JAPAN
Gold Tony Goetz NV BELGIUM
Gold Torecom REPUBLIC OF KOREA
Gold Umicore Brasil Ltda. BRAZIL
Gold Umicore Precious Metals Thailand THAILAND
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA
Gold Valcambi S.A. SWITZERLAND
Gold Western Australian Mint trading as The Perth Mint AUSTRALIA
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Yamamoto Precious Metal Co., Ltd. JAPAN
Gold Yokohama Metal Co., Ltd. JAPAN
Gold Zhaojin Mining Industry Co., Ltd. CHINA
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 OF AMERICA
Tantalum Duoluoshan CHINA
Tantalum Exotech Inc. UNITED STATES OF AMERICA
Tantalum F&X Electro-Materials Ltd. CHINA
Tantalum FIR Metals & Resource Ltd. CHINA
 12 
 

 

Tantalum Global Advanced Metals Aizu JAPAN
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA
Tantalum H.C. Starck Co., Ltd. THAILAND
Tantalum H.C. Starck GmbH Goslar GERMANY
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA
Tantalum H.C. Starck Ltd. JAPAN
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum Hi-Temp UNITED STATES OF AMERICA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
Tantalum Jiangxi Tuohong New Raw Material 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 OF AMERICA
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 Power Resources Ltd. REPUBLIC OF MACEDONIA
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum Resind Indústria e Comércio Ltda. BRAZIL
Tantalum RFH CHINA
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION
Tantalum Taki Chemical Co., Ltd. JAPAN
Tantalum Telex Metals UNITED STATES OF AMERICA
Tantalum Tranzact, Inc. UNITED STATES OF AMERICA
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 Group Co., Ltd. CHINA
 13 
 

 

Tin Alpha UNITED STATES OF AMERICA
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin Cooperativa Metalurgica de Rondônia Ltda. BRAZIL
Tin CV Ayi Jaya INDONESIA
Tin CV Dua Sekawan INDONESIA
Tin CV Gita Pesona INDONESIA
Tin CV Serumpun Sebalai INDONESIA
Tin CV Tiga Sekawan INDONESIA
Tin CV United Smelting INDONESIA
Tin CV Venus Inti Perkasa INDONESIA
Tin Dowa Metaltech Co., Ltd. JAPAN
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM
Tin Elmet S.L.U. SPAIN
Tin EM Vinto BOLIVIA
Tin Fenix Metals POLAND
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin Gejiu Jinye Mineral Company CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CHINA
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA
Tin Jiangxi Nanshan CHINA
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL
Tin Malaysia Smelting Corporation (MSC) MALAYSIA
Tin Melt Metais e Ligas S.A. BRAZIL
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
Tin Metallo-Chimique N.V. BELGIUM
Tin Mineração Taboca S.A. BRAZIL
Tin Minsur PERU
Tin Mitsubishi Materials Corporation JAPAN
Tin Modeltech Sdn Bhd MALAYSIA
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
Tin OMSA BOLIVIA
Tin PT Aries Kencana Sejahtera INDONESIA
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT ATD Makmur Mandiri Jaya INDONESIA
 14 
 

 

Tin PT Babel Inti Perkasa INDONESIA
Tin PT Bangka Prima Tin INDONESIA
Tin PT Bangka Tin Industry INDONESIA
Tin PT Belitung Industri Sejahtera INDONESIA
Tin PT Bukit Timah INDONESIA
Tin PT Cipta Persada Mulia INDONESIA
Tin PT DS Jaya Abadi INDONESIA
Tin PT Eunindo Usaha Mandiri INDONESIA
Tin PT Inti Stania Prima INDONESIA
Tin PT Karimun Mining INDONESIA
Tin PT Kijang Jaya Mandiri INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT O.M. Indonesia 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 Tambang Timah 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 VIET NAM
Tin White Solder Metalurgia e Mineração Ltda. BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Yunnan Tin Company Limited CHINA
Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
 15 
 

 

Tungsten H.C. Starck GmbH GERMANY
Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
Tungsten Japan New Metals Co., Ltd. JAPAN
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten Kennametal Fallon UNITED STATES OF AMERICA
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Moliren Ltd RUSSIAN FEDERATION
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIET NAM
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIET NAM
Tungsten Wolfram Bergbau und Hütten AG AUSTRIA
Tungsten Woltech Korea Co., Ltd. REPUBLIC OF KOREA
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
Tungsten Xiamen Tungsten Co., Ltd. CHINA
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA

 

 

•    Not designated as CFS by CFSI

 

 

Subject

Mineral

Company Country
Gold ATAkulche TURKEY
Gold Caridad MEXICO
Gold Chugai Mining JAPAN

 

 

 

 

 

 

 

 

 

 16 
 

 

Gold Daye Non-Ferrous Metals Mining Ltd. CHINA
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE
Gold Gansu Seemine Material Hi-Tech Co., Ltd. CHINA
Gold Great Wall Precious Metals Co,. LTD. CHINA
Gold Guangdong Gaoyao Co CHINA
Gold Gujarat Gold Centre INDIA
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA
Gold Hunan Chenzhou Mining Co., Ltd. CHINA
Gold HwaSeong CJ Co., Ltd. REPUBLIC OF KOREA
Gold Kaloti Precious Metals UNITED ARAB EMIRATES
Gold Kazakhmys Smelting LLC KAZAKHSTAN
Gold L'azurde Company For Jewelry SAUDI ARABIA
Gold Lingbao Gold Co., Ltd. CHINA
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA
Gold Morris and Watson NEW ZEALAND
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA
Gold Remondis Argentia B.V. NETHERLANDS
Gold SAAMP FRANCE
Gold Sabin Metal Corp. UNITED STATES OF AMERICA
Gold SAFINA A.S. CZECH REPUBLIC
Gold Sai Refinery INDIA
Gold SAMWON Metals Corp. REPUBLIC OF KOREA
Gold Shandong Tarzan Bio-Gold Industry Co., Ltd. CHINA
Gold So Accurate Group, Inc. UNITED STATES OF AMERICA
Gold Sudan Gold Refinery SUDAN
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA
Gold TOO Tau-Ken-Altyn KAZAKHSTAN
Gold Universal Precious Metals Refining Zambia ZAMBIA
Gold Yunnan Copper Industry Co., Ltd. CHINA
Tin An Thai Minerals Co., Ltd. VIET NAM
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA
Tin Estanho de Rondônia S.A. BRAZIL
Tin Gejiu Zi-Li CHINA
Tin Huichang Jinshunda Tin Co., Ltd. CHINA
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM
Tungsten ACL Metais Eireli BRAZIL
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA
 17 
 

 

Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA

 

 

 

 

 

 

 

 

 

 18 
 

 

 

Annex III

 

Sony Group Conflict Minerals Policy

(effective as of March 22, 2013)

 

Sony's Commitment to Corporate Social Responsibility

Sony is committed to conducting our operations in a socially and environmentally responsible way and to sourcing from suppliers that share our values. Sony and our stakeholders have grown increasingly aware of the importance of companies fulfilling their overall responsibilities to society as corporate citizens, including managing our supply chains in a responsible manner. Sony is working with our suppliers to address issues related to human rights, labor conditions, health and safety, and environmental protection at the production sites of our partners and parts suppliers, as well as in our procurement of minerals and other raw materials.

 

Conflict Minerals and Sony’s Policy

The Democratic Republic of the Congo in Central Africa (“DRC”) and certain adjacent countries are currently mired in conflict with armed groups perpetrating human rights abuses in that region. These armed groups are trading certain minerals found in that region to finance their activities. These four minerals -- columbite-tantalite also known as coltan (tantalum), cassiterite (tin), gold, wolframite (tungsten) -- are commonly found in many products, ranging from jewelry to electronics to airplane components. To the extent that they are found to be financing armed activities, these four minerals are commonly referred to as “conflict minerals”.

 

It is Sony’s policy to refrain from knowingly purchasing any products, components or materials that contain conflict minerals, in order to avoid contributing to conflict through our sourcing practices. To ensure compliance with this policy, Sony requires our suppliers to source materials from smelters determined to be compliant with the conflict-free smelter program protocols established by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSi), or other smelters that have been determined to be conflict-free smelters under other trusted traceability projects. We will exercise due diligence on the source and chain of custody of these minerals in our supply chain to determine supplier compliance with our policy and will follow the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas or other internationally recognized framework when conducting such due diligence.

 

Sony’s Activities

- Sony participation in industry groups and the Public-Private Alliance

Sony actively participates and supports industry groups and alliances that seek to identify and prevent or mitigate the adverse impacts associated with mineral extraction in high risk areas. We are actively involved with the EICC, an organization devoted to improving social and environmental conditions in electronics supply chains, in developing a process that companies can use to trace the origin of these minerals. In 2011, the EICC launched the conflict-free smelter program, which is the leading industry practice. Sony utilizes the framework established by the EICC and other industry groups and alliances to aid in our efforts to responsibly source the four identified minerals.

Sony is also helping to fund, and is an active participant in, the Public-Private Alliance for Responsible Minerals Trade (PPA), an initiative spearheaded by the United States Department of State and Agency for International Development. The objectives of the PPA are: (1) to assist with the development of pilot supply-chain systems that will allow businesses to source minerals from mines that have been audited and certified to be ‘conflict-free;’ (2) to provide a platform for coordination amongst government, industry, and civil society actors seeking to support conflict-free sourcing and a self-sustaining trade from the DRC and the Great Lakes Region; and (3) to establish a website designed to serve as a resource for companies seeking information regarding how to responsibly source.

 19 
 

 

Moreover, as part of our overall effort to achieve conflict-free supply chains, Sony promotes active, on-going dialogue with civil society organizations, industry groups, and other external stakeholders for the further improvement of conflict-free sourcing practices.

 

- Assessment of Sony’s businesses

Sony assesses each of its businesses to determine if any of the four identified minerals are found in our products. To the extent such assessment determines that any such minerals are used to manufacture such products, all relevant suppliers are required to adhere to the following guidelines:

 

-Expectations for Sony Suppliers of Four Identified Minerals

Sony requires such suppliers to commit to this policy against conflict minerals and respond to our due diligence survey regarding sourcing of these four minerals. Such suppliers are also expected to have a policy, due diligence framework, and management systems consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas to ensure that any products, components, or materials delivered to Sony do not contain any conflict minerals.

 

-Risk mitigation plan

In the event that Sony confirms that any of our products, components, or materials may contain conflict minerals, Sony, in collaboration with our relevant suppliers, shall take all actions reasonably necessary to eliminate such minerals from such products, components or materials and shall request that the supplier of such products, components or materials makes necessary improvements to its sourcing practices. Further, in the event that Sony confirms that a supplier has failed to cooperate sufficiently with a due-diligence investigation, fails to follow Sony requests for remediation or has otherwise violated this policy, Sony shall take necessary actions, including, without limitation, termination of business with such supplier by stopping new orders.

 

Sony has established a hotline to allow any interested party (affected persons or whistle-blowers) to voice concerns regarding the circumstances of mineral extraction, trade, handling and/or export in conflict-affected and other high-risk areas. In addition to our internal risk assessments, the hotline will help to allow us to be alerted to risks in our supply chain.

 

-Disclosure

Sony will disclose a description of the measures we took to determine the source and chain of custody of any of the four minerals found in any of our products as well as the results of our due diligence to our stakeholders through our website and other appropriate mechanisms.

 

 

 

 

 20