EX-1.01 2 ex-1d01.htm EX-1.01 ecl_Ex1_01

Exhibit 1.01

 

CONFLICT MINERALS REPORT OF 2016

 

TO

 

FORM SD SPECIALIZED DISCLOSURE REPORT

 

OF

 

ECOLAB INC.

 

 

 

Forward-Looking Statements

 

This document contains forward-looking statements within the meaning of the federal securities laws.  Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of the future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG (as such term is defined below) benefit armed groups.

 

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, (3) the accuracy and validity of the audits conducted under the Conflict-Free Smelter Program (“CFSP”) and analogous audit programs with which the Conflict-Free Sourcing Initiative (“CSFI”) has a mutual recognition agreement and (4) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of the filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of the filing of this document or to reflect the occurrence of unanticipated events.

 

I.Introduction

 

Except where the context otherwise requires, references in this Conflict Minerals Report to “Ecolab,” “Company,” “we” and “our” are to Ecolab Inc. and its subsidiaries, collectively.  As used herein and consistent with the Conflict Minerals Rule (as such term is defined below),  (1) “Conflict Minerals” or “3TG” are columbite-tantalite (coltan), cassiterite, gold and wolframite, and their metallic-form derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals, and (2) the “Conflict Minerals Rule” is, collectively, Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD.

 

Applicability of the Conflict Minerals Rule to Our Company

 

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We are the global leader in water, hygiene and energy technologies and services that protect people and vital resources.  We deliver comprehensive solutions, expertise and on-site service to promote safe food, maintain clean environments, optimize water and energy use and improve operational efficiencies for customers in the food, healthcare, energy, hospitality and industrial markets in more than 170 countries.  Our cleaning and sanitizing programs and products, pest elimination services, and equipment maintenance and repair services support customers in the foodservice, food and beverage processing, hospitality, healthcare, government and education, retail, textile care and commercial facilities management sectors.  Our products and technologies are also used in water treatment, pollution control, energy conservation, oil production and refining, steelmaking, papermaking, mining and other industrial processes.

 

We are required to make filings pursuant to the Conflict Minerals Rule because some of the products that we manufacture or contract to manufacture, in particular certain components of our control and dispensing equipment and healthcare product offerings, contain metallic forms of 3TG that are necessary to the functionality or production of the products.  Not all of our products contain 3TG. The 3TG content in our products accounts for only a small percentage of the total materials content and our products with 3TG content accounted for less than 1% of our 2016 total sales. Our in-scope products taken together as a whole include all four 3TG, though each in-scope product does not include all four 3TG.

 

We do not directly source 3TG from mines, smelters or refiners, and we believe that we are in most cases many levels removed from these market participants.  However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy described below.

 

Reasonable Country of Origin Information

 

As required by the Conflict Minerals Rule, for 2016, we conducted a “reasonable country of origin inquiry” (“RCOI”) of the direct suppliers of the components, parts or products believed by us to contain 3TG.  Our RCOI was reasonably designed to determine in good faith whether any of the 3TG in our in-scope products may have originated or did originate in the DRC or an adjoining country or from recycled or scrap sources. For our RCOI, we utilized the processes and procedures contemplated by Steps 1 and 2 of the OECD Guidance (as defined below).  These steps of the OECD Guidance are described under “Design of Due Diligence Measures” and “Due Diligence Measures Performed by Ecolab.”

 

In connection with our RCOI, product-level supplier surveys identified to us 266 smelters and refiners that processed the necessary 3TG contained in our in-scope products. As of May 12, 2017, 225 (approximately 85%) of these smelters and refiners were listed as “compliant” by the CFSI with applicable CFSP assessment protocols, 7 as “active” with respect to progressing to compliance with such protocols,  and 34 were not compliant or active. An additional 46 facilities could not be verified.  The smelters and refiners and their compliance status are listed on Annexes I and II.

 

To help achieve a greater level of specificity in determining the countries of origin of the 3TG processed by the smelters and refiners identified by our suppliers, we continued our practice of enlisting the services of a third-party service provider (the “Reviewer”) to review the smelters and refiners identified to us and provide us with a list of the related countries of origin known to it. The identified countries of origin are listed below under “Product, Smelter and Refiner and Country of Origin Information.”  Our country of origin determinations are derived from the information provided to us by the Reviewer, which is substantially based on mineral origin information in

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reports published by the U.S. Geological Survey.  Certain of the other compliance activities described in this Conflict Minerals Report were performed on our behalf by the Reviewer.

 

Based on the information provided by the Reviewer and our own analysis, we had reason to believe that some of the identified smelters and refiners sourced from the DRC and its adjoining countries.  Based on the results of our RCOI, we conducted due diligence for 2016. These due diligence efforts are discussed below.

 

II.Design of Due Diligence Measures

 

We designed  our 3TG compliance procedures based on, and in conformity in all material respects with, the applicable portions of the five step framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016 Third Edition),  including the supplements on tin, tantalum and tungsten and gold (the “OECD Guidance”).  Selected elements of our program design are discussed below. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2016 are discussed below under “Due Diligence Measures Performed by Ecolab.”    

 

1.Establish strong company management systems

 

a. We have a team of responsible personnel from our regulatory affairs, global supply chain and legal functions for the management and continued implementation of our 3TG compliance strategy. We also utilize specialist outside counsel and other advisors to assist us with our compliance efforts.

 

b. We have adopted and communicate to our suppliers and the public a company policy regarding 3TG (the “Conflict Minerals Policy”) for our supply chain. Among other things, the Conflict Minerals Policy contains our expectations that our suppliers:  (i) supply materials to Ecolab that are “DRC Conflict-Free”;  (ii) adopt policies and management systems with respect to 3TG and require their suppliers to adopt similar policies and systems; (iii) establish their own due diligence program to ensure conflict-free supply chains; and (iv) respond to survey requests in a timely manner, and with full disclosure, following the specific instructions provided. The Conflict Minerals Policy indicates that, in the event Ecolab determines that a supplier’s efforts to comply with the Conflict Minerals Policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Ecolab reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Our policy is available on our website at http://www.ecolab.com/sustainability/commitment-to-sustainability/ethical-sourcing.

 

Through our procurement policies and industry association membership and participation we support responsible sourcing from the DRC region. We do not support embargoes of the region.

 

c. We utilize the Conflict Minerals Reporting Template (the “Conflict Minerals Reporting Template”) developed by the CFSI to identify smelters and refiners in our supply chain. The Conflict Minerals Reporting Template requests suppliers to provide information concerning the usage and source of 3TG in the products they provide Ecolab, as well as information concerning their related compliance efforts.

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d. We are a member of the CFSI. Company personnel on our Conflict Minerals practices team are members of the CFSI due diligence practice team. Additionally, we participate as a member of the Conflict Minerals Task Force in the Twin Cities (Minneapolis-St. Paul) for the purpose of aligning our approach and establishing best practices with other firms with respect to compliance with the Conflict Minerals Rule.

 

e. We have implemented an IT solution to engage our direct suppliers and to maintain responses relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, in an electronic format for at least five years.

 

f. Our procurement terms and conditions contain provisions relating to the sourcing of 3TG to be contained in our products.

 

g. We include as a part of our supplier quality review process inquiries concerning the supplier’s policies and procedures relating to 3TG sourcing.

 

h. In addition to other reporting methods set forth on our web site and in our Code of Conduct and Supplier Code of Conduct, we have a dedicated email address, conflictminerals@ecolab.com, which can be used by interested internal and external parties to contact Ecolab with respect to its supplier surveys, Conflict Minerals Policy and related matters such as grievances, concerns and other possibly relevant information.  This email serves as our grievance mechanism.

 

2.Identify and assess risk in the supply chain

 

a. We request that suppliers provide us with information concerning the usage and source of 3TG in the parts that they sell to us and their related compliance efforts through the completion of a Conflict Minerals Reporting Template. We follow up by email with suppliers that do not respond to the request within a specified time frame. 

 

b. Our IT solution utilizes programming logic to review the Conflict Minerals Reporting Templates that we receive from suppliers and flags responses not conforming to specified criteria.

 

c. Smelter and refiner data is reviewed for us by the Reviewer to verify, to the extent known by the Reviewer based on its research, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG processed by such smelters and refiners, (d) the plausibility of the identified countries of origin having 3TG reserves or mines, and (e) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country.

 

3.Design and implement a strategy to respond to identified risks

 

We have procedures for monitoring and reporting on risk to designated senior management, including our Executive Vice President and General Counsel, on an ongoing

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basis. Pursuant to these procedures, our 3TG compliance team also reports the findings of its compliance efforts to a steering committee comprised of management personnel from our global supply chain, regulatory affairs, legal, research and development and sustainability functions.

 

We utilize a risk mitigation framework that allows for a flexible response commensurate with the risks identified. Under the framework, actions range from supplier education and follow-up to discontinuing purchases from a supplier.  

 

In addition, to the extent that identified smelters and refiners are not listed as compliant, we seek to exercise leverage over these smelters and refiners to become so through our participation in and support of the CFSI. We also utilize information provided by the CFSI to its members to monitor smelter and refiner improvement.

 

4.Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

 

We support the CFSP through our membership in the CFSI. The CFSP uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate compliance with CFSP protocols and current global standards. The audit employs a risk-based approach to validate smelters’ and refiners’ company level management processes for responsible mineral procurement.

 

In connection with our due diligence, we utilize and rely on information made available by the CFSI concerning CFSP audits to assess smelter and refiner due diligence and to determine whether a smelter or refiner is compliant.

 

The data on which we relied for certain statements in this Conflict Minerals Report was obtained through our membership in the CFSI.

 

5.Report on supply chain due diligence

 

We file a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and make these documents available on our website at http://www.ecolab.com/sustainability/commitment-to-sustainability/ethical-sourcing.

 

III.Due Diligence Measures Performed by Ecolab

 

Ecolab has performed the due diligence and related measures set forth below in respect of 2016. These are not all of the measures that we took in respect of 2016 in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance.    

 

Following the completion of our Conflict Minerals Report for the 2015 reporting year, we conducted a risk assessment of non-responsive suppliers. While we did not suspend or terminate trading with such suppliers, we implemented an enhanced risk mitigation plan, which involved engagement of several of the suppliers representing the highest portion of our equipment expenditures to ensure improved compliance with our Conflict Minerals Policy, including timely responses to survey requests.

 

We sent requests to our in-scope suppliers to provide us with a completed Conflict Minerals

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Reporting Template. We followed up by email with the suppliers that did not provide a response within the specified time frame.

 

We reviewed the completed responses received from the suppliers based on our approved review criteria to identify incomplete responses and specified sourcing risks and sent follow-up emails to suppliers providing incomplete or non-conforming responses.  

 

We enlisted the services of the Reviewer to verify, to the extent known by the Reviewer based on its research, (a) the validity of the smelters and refiners identified to us by the suppliers, (b) the audit status of such smelters and refiners, (c) the country of origin of the 3TG processed by such smelters and refiners, (d) the plausibility of the identified countries of origin having 3TG reserves or mines, and (e) whether such smelters and refiners obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country.

 

Our 3TG compliance team reported the findings of its compliance efforts in respect of 2016 to our management steering committee.

 

We participated in independent third-party audits of smelters and refiners through our membership in the CFSI. In addition, our Conflict Minerals practices team personnel were members of the CFSI due diligence practices team.

 

 

IV.Product, Smelter and Refiner and Country of Origin Information

 

In-Scope Product Categories

 

For 2016, our in-scope products were in the following product categories:

 

A. Equipment used for the control and dispensing of chemical products.

 

B. Healthcare patient management systems and other miscellaneous components related to our Healthcare products.

 

Identified Smelters and Refiners

 

In connection with our due diligence, the suppliers identified to us the verified smelters and refiners listed in Annex I and Annex II below as having processed the necessary 3TG contained in our in-scope products in 2016.  However, not all of the included smelters and refiners may have processed the necessary 3TG contained in our in-scope products.  In some cases, suppliers may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners listed in the Annexes may not be all of the smelters and refiners in our supply chain, since the suppliers may have been unable to identify the smelters and refiners of some of the necessary 3TG content contained in our in-scope products and because not all suppliers responded to our inquiries.     

 

Annex I provides a list of smelters and refiners reported by the CFSI as compliant with applicable CFSP assessment protocols or active with respect to progressing to compliance with such protocols. Annex II provides a list of verified smelters and refiners that were not included on the aforementioned CFSI list. The Reviewer was unable to verify the status of 46 facilities provided to us. Such unverified facilities are not listed on the Annexes. We are continuing to investigate

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these and, if they are determined to be smelters/refiners, we will incorporate them into our due diligence process.

 

Potential Countries of Origin

 

In addition to sourcing from recycled and scrap sources, based on information received from the Reviewer, Ecolab believes the country of origin of the 3TG sourced by the smelters and refiners in the Annexes may include  the following:  Angola, Argentina, Armenia, Australia, Austria, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Republic of the Congo, Czech Republic, the DRC, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, Germany, Ghana, Guinea, Guyana, India, Indonesia, Ireland, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Kyrgyzstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia and Zimbabwe.

 

For 2016, notwithstanding our compliance efforts, we may not have been able to determine the facilities at which at least a portion of the necessary 3TG contained in each of our in-scope products were processed. We also may not have been able to determine the country of origin for at least a portion of the necessary 3TG contained in each of our in-scope products. None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

 

We endeavored to determine the mine or location of origin of the necessary 3TG contained in our in-scope products by requesting that the suppliers provide us with a completed Conflict Minerals Reporting Template and through the other measures described in this Conflict Minerals Report.  Additionally, the Reviewer assisted us in determining whether the smelters and refiners identified to us by our suppliers obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country to the extent known by the Reviewer from its research.  

 

V.Steps to Improve Due Diligence

 

We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:

 

Implement a new IT solution, which we anticipate will, among other benefits, increase the number of Conflict Mineral Report Templates that we receive and enhance our assessment of non-conforming responses.

 

Continue follow-up with direct suppliers that were unresponsive or provided non-conforming responses to improve response rates and quality of information.

 

Continue our membership in the CFSI.

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ANNEX I

 

List of Facilities Compliant with CFSP Protocols or on CFSI Active List

 

 

 

 

 

Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

Advanced Chemical Company

Gold

Compliant

United States

Aida Chemical Industries Co., Ltd.

Gold

Compliant

Japan

Allgemeine Gold-und Silberscheideanstalt A.G.

Gold

Compliant

Germany

Almalyk Mining and Metallurgical Complex (AMMC)

Gold

Compliant

Uzbekistan

AngloGold Ashanti Córrego do Sítio Mineração

Gold

Compliant

Brazil

Argor-Heraeus SA

Gold

Compliant

Switzerland

Asahi Pretec Corporation

Gold

Compliant

Japan

Asahi Refining Canada Limited

Gold

Compliant

Canada

Asahi Refining USA Inc.

Gold

Compliant

United States

Asaka Riken Co., Ltd.

Gold

Compliant

Japan

Aurubis AG

Gold

Compliant

Germany

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Gold

Compliant

Philippines

Boliden AB

Gold

Compliant

Sweden

C. Hafner GmbH + Co. KG

Gold

Compliant

Germany

CCR Refinery - Glencore Canada Corporation

Gold

Compliant

Canada

Chimet S.p.A.

Gold

Compliant

Italy

Cendres + Métaux SA

Gold

Active

Switzerland

Daeijin Indus Co., Ltd.

Gold

Compliant

South Korea

DODUCO GmbH

Gold

Compliant

Germany

Dowa

Gold

Compliant

Japan

DSC (Do Sung Corporation)

Gold

Compliant

South Korea

Eco-System Recycling Co., Ltd.

Gold

Compliant

Japan

Geib Refining Corporation

Gold

Compliant

United States

Gold Refinery of Zijin Mining Group Co., Ltd.

Gold

Compliant

China

Heimerle + Meule GmbH

Gold

Compliant

Germany

Heraeus Metals Hong Kong Ltd.

Gold

Compliant

China

Heraeus Precious Metals GmbH & Co. KG

Gold

Compliant

Germany

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

Gold

Compliant

China

Ishifuku Metal Industry Co., Ltd.

Gold

Compliant

Japan

Istanbul Gold Refinery

Gold

Compliant

Turkey

Japan Mint

Gold

Compliant

Japan

Jiangxi Copper Company Limited

Gold

Compliant

China

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Gold

Compliant

Russia

JSC Uralelectromed

Gold

Compliant

Russia

JX Nippon Mining & Metals Co., Ltd.

Gold

Compliant

Japan

Kazzinc

Gold

Compliant

Kazakhstan

Kennecott Utah Copper LLC

Gold

Compliant

United States

KGHM Polska Miedź Spόtka Akcyjna

Gold

Active

Poland

Kojima Chemicals Co., Ltd.

Gold

Compliant

Japan

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Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

Kyrgyzaltyn JSC

Gold

Compliant

Kyrgyzstan

LS-NIKKO Copper Inc.

Gold

Compliant

South Korea

Materion

Gold

Compliant

United States

Matsuda Sangyo Co., Ltd.

Gold

Compliant

Japan

Metalor Technologies (Hong Kong) Ltd.

Gold

Compliant

China

Metalor Technologies (Singapore) Pte., Ltd.

Gold

Compliant

Singapore

Metalor Technologies (Suzhou) Co Ltd

Gold

Compliant

China

Metalor Technologies SA

Gold

Compliant

Switzerland

Metalor USA Refining Corporation

Gold

Compliant

United States

Metalúrgica Met-Mex Peñoles S.A. de C.V

Gold

Compliant

Mexico

Mitsubishi Materials Corporation

Gold

Compliant

Japan

Mitsui Mining & Smelting Co., Ltd.

Gold

Compliant

Japan

Moscow Special Alloys Processing Plant

Gold

Compliant

Russia

Nadir Metal Rafineri San. Ve Tic. A.Ş

Gold

Compliant

Turkey

Navoi Mining and Metallurgical Combinat

Gold

Active

Uzbekistan

Nihon Material Co., Ltd.

Gold

Compliant

Japan

Ohura Precious Metal Industry Co., Ltd.

Gold

Compliant

Japan

OJSC Krastsvetmet

Gold

Compliant

Russia

OJSC Novosibirsk Refinery

Gold

Compliant

Russia

PAMP SA

Gold

Compliant

Switzerland

Prioksky Plant of Non-Ferrous Metals

Gold

Compliant

Russia

PT Aneka Tambang (Persero) Tbk

Gold

Compliant

Indonesia

PX Précinox S.A.

Gold

Compliant

Switzerland

Rand Refinery (Pty) Ltd.

Gold

Compliant

South Africa

Republic Metals Corporation

Gold

Compliant

United States

Royal Canadian Mint

Gold

Compliant

Canada

Samduck Precious Metals

Gold

Compliant

South Korea

Saxonia Edelmetalle GmbH

Gold

Compliant

Germany

Schöne Edelmetaal B.V.

Gold

Compliant

Netherlands

SEMPSA Joyería Platería SA

Gold

Compliant

Spain

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

Gold

Compliant

China

Sichuan Tianze Precious Metals Co., Ltd.

Gold

Compliant

China

Singway Technology Co., Ltd.

Gold

Compliant

Taiwan

SOE Shyolkovsky Factory of Secondary Precious Metals

Gold

Compliant

Russia

Solar Applied Materials Technology Corp.

Gold

Compliant

Taiwan

Sumitomo Metal Mining Co., Ltd.

Gold

Compliant

Japan

Tanaka Kikinzoku Kogyo K.K.

Gold

Compliant

Japan

The Refinery of Shandong Gold Mining Co., Ltd.

Gold

Compliant

China

Tokuriki Honten Co., Ltd.

Gold

Compliant

Japan

Torecom

Gold

Compliant

South Korea

Umicore Brasil Ltda.

Gold

Compliant

Brazil

Umicore Precious Metals Thailand

Gold

Compliant

Thailand

Umicore SA Business Unit Precious Metals Refining

Gold

Compliant

Belgium

United Precious Metal Refining, Inc.

Gold

Compliant

United States

Valcambi SA

Gold

Compliant

Switzerland

Western Australian Mint trading as The Perth Mint

Gold

Compliant

Australia

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Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

WIELAND Edelmetalle GmbH

Gold

Compliant

Germany

Yamamoto Precious Metal Co., Ltd.

Gold

Compliant

Japan

Yokohama Metal Co., Ltd.

Gold

Compliant

Japan

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Gold

Compliant

China

 

 

 

 

Changsha South Tantalum Niobium Co., Ltd.

Tantalum

Compliant

China

Conghua Tantalum and Niobium Smeltry

Tantalum

Compliant

China

D Block Metals, LLC

Tantalum

Compliant

United States

Duoluoshan

Tantalum

Compliant

China

Exotech Inc.

Tantalum

Compliant

United States

F&X Electro-Materials Ltd.

Tantalum

Compliant

China

FIR Metals & Resource Ltd.

Tantalum

Compliant

China

Global Advanced Metals Aizu

Tantalum

Compliant

Japan

Global Advanced Metals Boyertown

Tantalum

Compliant

United States

Guangdong Zhiyuan New Material Co., Ltd.

Tantalum

Compliant

China

H.C. Starck Co., Ltd.

Tantalum

Compliant

Thailand

H.C. Starck Hermsdorf GmbH

Tantalum

Compliant

Germany

H.C. Starck Inc.

Tantalum

Compliant

United States

H.C. Starck Ltd.

Tantalum

Compliant

Japan

H.C. Starck Smelting GmbH & Co.KG

Tantalum

Compliant

Germany

H.C. Starck Tantalum and Niobium GmbH

Tantalum

Compliant

Germany

Hengyang King Xing Lifeng New Materials Co., Ltd.

Tantalum

Compliant

China

Hi-Temp Specialty Metals, Inc.

Tantalum

Compliant

United States

Jiangxi Dinghai Tantalum & Niobium Co., Ltd

Tantalum

Compliant

China

JiuJiang JinXin Nonferrous Metals Co., Ltd.

Tantalum

Compliant

China

Jiujiang Nonferrous Metals Smelting Company Limited

Tantalum

Compliant

China

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

Tantalum

Compliant

China

KEMET Blue Metals

Tantalum

Compliant

Mexico

Kemet Blue Powder

Tantalum

Compliant

United States

King-Tan Tantalum Industry Ltd.

Tantalum

Compliant

China

LSM Brasil S.A.

Tantalum

Compliant

Brazil

Metallurgical Products India Pvt., Ltd.

Tantalum

Compliant

India

Mineração Taboca S.A.

Tantalum

Compliant

Brazil

Mitsui Mining & Smelting

Tantalum

Compliant

Japan

Ningxia Orient Tantalum Industry Co., Ltd.

Tantalum

Compliant

China

NPM Silmet AS

Tantalum

Compliant

Estonia

QuantumClean

Tantalum

Compliant

United States

RFH Tantalum Smeltry Co., Ltd.

Tantalum

Compliant

China

Solikamsk Magnesium Works OAO

Tantalum

Compliant

Russia

Taki Chemicals Co., Ltd.

Tantalum

Compliant

Japan

Telex Metals

Tantalum

Compliant

United States

Ulba Metallurgical Plant JSC

Tantalum

Compliant

Kazakhstan

XinXing Haorong Electronic Material Co., Ltd.

Tantalum

Compliant

China

Yichun Jin Yang Rare Metal Co., Ltd.

Tantalum

Compliant

China

Zhuzhou Cemented Carbide

Tantalum

Compliant

China

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Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

Alpha

Tin

Compliant

United States

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

Tin

Compliant

China

China Tin Group Co., Ltd.

Tin

Compliant

China

Cooperativa Metalurgica de Rondônia Ltda.

Tin

Compliant

Brazil

CV Ayi Jaya

Tin

Compliant

Indonesia

CV Dua Sekawan

Tin

Compliant

Indonesia

CV Gita Pesona

Tin

Compliant

Indonesia

CV Serumpun Sebalai

Tin

Compliant

Indonesia

CV Tiga Sekawan

Tin

Compliant

Indonesia

CV United Smelting

Tin

Compliant

Indonesia

CV Venus Inti Perkasa

Tin

Compliant

Indonesia

Dowa

Tin

Compliant

Japan

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Tin

Active

Vietnam

Elmet S.L.U. (Metallo Group)

Tin

Compliant

Spain

EM Vinto

Tin

Compliant

Bolivia

Fenix Metals

Tin

Compliant

Poland

Gejiu Fengming Metallurgy Chemical Plant

Tin

Compliant

China

Gejiu Jinye Mineral Company

Tin

Compliant

China

Gejiu Kai Meng Industry and Trade LLC

Tin

Active

China

Gejiu Non-Ferrous Metal Processing Co., Ltd.

Tin

Compliant

China

Geiju Yunxin Nonferrous Electrolysis Co., Ltd.

Tin

Compliant

China

Guanyang Guida Nonferrous Metal Smelting Plant

Tin

Compliant

China

HuiChang Hill Tin Industry Co., Ltd.

Tin

Compliant

China

Huichang Jinshunda Tin Co., Ltd.

Tin

Active

China

Jiangxi Ketai Advanced Material Co., Ltd.

Tin

Compliant

China

Magnu's Minerais Metais e Ligas Ltda.

Tin

Compliant

Brazil

Malaysia Smelting Corporation (MSC)

Tin

Compliant

Malaysia

Melt Metais e Ligas S/A

Tin

Compliant

Brazil

Metallic Resources, Inc.

Tin

Compliant

United States

Metallo-Chimique N.V.

Tin

Compliant

Belgium

Mineração Taboca S.A.

Tin

Compliant

Brazil

Minsur

Tin

Compliant

Peru

Mitsubishi Materials Corporation

Tin

Compliant

Japan

Nankang Nanshan Tin Manufactory Co., Ltd.

Tin

Active

China

O.M. Manufacturing (Thailand) Co., Ltd.

Tin

Compliant

Thailand

O.M. Manufacturing Philippines, Inc.

Tin

Compliant

Philippines

Operaciones Metalurgical S.A.

Tin

Compliant

Bolivia

PT Aries Kencana Sejahtera

Tin

Compliant

Indonesia

PT Artha Cipta Langgeng

Tin

Compliant

Indonesia

PT ATD Makmur Mandiri Jaya

Tin

Compliant

Indonesia

PT Babel Inti Perkasa

Tin

Compliant

Indonesia

PT Bangka Prima Tin

Tin

Compliant

Indonesia

PT Bangka Tin Industry

Tin

Compliant

Indonesia

PT Belitung Industri Sejahtera

Tin

Compliant

Indonesia

PT Bukit Timah

Tin

Compliant

Indonesia

11


 

 

 

 

 

Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

PT DS Jaya Abadi

Tin

Compliant

Indonesia

PT Eunindo Usaha Mandiri

Tin

Compliant

Indonesia

PT Inti Stania Prima

Tin

Compliant

Indonesia

PT Karimun Mining

Tin

Compliant

Indonesia

PT Kijang Jaya Mandiri

Tin

Compliant

Indonesia

PT Mitra Stania Prima

Tin

Compliant

Indonesia

PT Panca Mega Persada

Tin

Compliant

Indonesia

PT Prima Timah Utama

Tin

Compliant

Indonesia

PT Refined Bangka Tin

Tin

Compliant

Indonesia

PT Sariwiguna Binasentosa

Tin

Compliant

Indonesia

PT Stanindo Inti Perkasa

Tin

Compliant

Indonesia

PT Sukses Inti Makmur

Tin

Compliant

Indonesia

PT Sumber Jaya Indah

Tin

Compliant

Indonesia

PT Timah (Persero) Tbk Kundur

Tin

Compliant

Indonesia

PT Timah (Persero) Tbk Mentok

Tin

Compliant

Indonesia

PT Tinindo Inter Nusa

Tin

Compliant

Indonesia

PT Tommy Utama

Tin

Compliant

Indonesia

Resind Indústria e Comércio Ltda.

Tin

Compliant

Brazil

Rui Da Hung

Tin

Compliant

Taiwan

Soft Metais Ltda.

Tin

Compliant

Brazil

Thaisarco

Tin

Compliant

Thailand

VQB Mineral and Trading Group JSC

Tin

Compliant

Vietnam

White Solder Metalurgia e Mineração Ltda.

Tin

Compliant

Brazil

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

Tin

Compliant

China

Yunnan Tin Group (Holding) Company Limited

Tin

Compliant

China

 

 

 

 

A.L.M.T. TUNGSTEN Corp.

Tungsten

Compliant

Japan

Asia Tungsten Products Vietnam Ltd.

Tungsten

Compliant

Vietnam

Chenzhou Diamond Tungsten Products Co., Ltd.

Tungsten

Compliant

China

Chongyi Zhangyuan Tungsten Co., Ltd.

Tungsten

Compliant

China

Fujian Jinxin Tungsten Co., Ltd.

Tungsten

Compliant

China

Ganzhou Huaxing Tungsten Products Co., Ltd.

Tungsten

Compliant

China

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

Tungsten

Compliant

China

Ganzhou Seadragon W & Mo Co., Ltd.

Tungsten

Compliant

China

Global Tungsten & Powders Corp.

Tungsten

Compliant

United States

Guangdong Xianglu Tungsten Co., Ltd.

Tungsten

Compliant

China

H.C. Starck Smelting GmbH & Co.KG

Tungsten

Compliant

Germany

H.C. Starck Tungsten GmbH

Tungsten

Compliant

Germany

Hunan Chenzhou Mining Co., Ltd.

Tungsten

Compliant

China

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

Tungsten

Compliant

China

Hunan Chunchang Nonferrous Metals Co., Ltd.

Tungsten

Compliant

China

Hydrometallurg, JSC

Tungsten

Compliant

Russia

Japan New Metals Co., Ltd.

Tungsten

Compliant

Japan

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

Tungsten

Compliant

China

Jiangxi Gan Bei Tungsten Co., Ltd.

Tungsten

Compliant

China

12


 

 

 

 

 

Smelter or Refiner Name

Mineral

Smelter or
Refiner
Status

Smelter or
Refiner
Location

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

Tungsten

Compliant

China

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

Tungsten

Compliant

China

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

Tungsten

Compliant

China

Jiangxi Yaosheng Tungsten Co., Ltd.

Tungsten

Compliant

China

Kennametal Fallon

Tungsten

Compliant

United States

Kennametal Huntsville

Tungsten

Compliant

United States

Malipo Haiyu Tungsten Co., Ltd.

Tungsten

Compliant

China

Niagara Refining LLC

Tungsten

Compliant

United States

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

Tungsten

Compliant

Vietnam

Tejing (Vietnam) Tungsten Co., Ltd.

Tungsten

Compliant

Vietnam

Vietnam Youngsun Tungsten Industry Co., Ltd.

Tungsten

Compliant

Vietnam

Wolfram Bergbau und Hütten AG

Tungsten

Compliant

Austria

Xiamen Tungsten (H.C.) Co., Ltd.

Tungsten

Compliant

China

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

Tungsten

Compliant

China

 

The following notes apply to Annex I above:


(1)

“Compliant” means that a smelter or refiner was compliant with the applicable Conflict-Free Smelter Program (“CFSP”) assessment protocols.

 

(2)

“Active” means that the smelter or refiner (a) has submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or has agreed to complete a CFSP compliance audit conducted by an independent third party auditor or (b) is listed as undertaking a corrective action plan, in which it is actively progressing towards CFSP compliance or has committed to a CFSP validation audit. 

 

(3)

The designations of Compliant and Active and the smelter or refiner location reflected in the table are based solely on information made publicly available by the CFSI, without independent verification by us.

 

13


 

ANNEX II

 

List of Verified Facilities Not Otherwise Listed as Compliant or Active

 

 

 

 

 

 

 

 

Smelter or Refiner Name

Mineral

Smelter or
Refiner 
Location

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Gold

Turkey

Caridad

Gold

Mexico

Chugai Mining

Gold

Japan

Daye Non-Ferrous Metals Mining Ltd.

Gold

China

Gansu Seemine Material Hi-Tech Co Ltd

Gold

China

Guangdong Jinding Gold Limited

Gold

China

Great Wall Precious Metals Co., Ltd. of CBPM

Gold

China

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

Gold

China

Hangzhou Fuchunjiang Smelting Co., Ltd.

Gold

China

Hunan Chenzhou Mining Co., Ltd.

Gold

China

HwaSeong CJ Co. Ltd

Gold

South Korea

Lingbao Jinyuan Tonghui Refinery Co. Ltd.

Gold

China

Luo yang Zijin Yinhui Metal Smelt Co Ltd

Gold

China

Morris and Watson

Gold

New Zealand

Penglai Penggang Gold Industry Co Ltd

Gold

China

Sabin Metal Corp.

Gold

United States

SAMWON METALS Corp.

Gold

South Korea

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

Gold

China

So Accurate Group, Inc.

Gold

United States

TongLing Nonferrous Metals Group Holdings Co., Ltd.

Gold

China

Yunnan Copper Industry Co Ltd

Gold

China

 

 

 

An Thai Minerals Company Limited

Tin

Vietnam

An Vinh Joint Stock Mineral Processing Company

Tin

Vietnam

CNMC (Guangxi) PGMA Co. Ltd.

Tin

China

Estanho de Rondônia S.A.

Tin

Brazil

Gejiu Zili Mining and Metallurgy Co., Ltd.

Tin

China

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Tin

Vietnam

PT Cipta Persada Mulia

Tin

Indonesia

PT Justindo

Tin

Indonesia

PT Tirus Putra Mandiri

Tin

Indonesia

PT WAHANA PERKIT JAYA

Tin

Indonesia

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Tin

Vietnam

 

 

 

Ganzhou Yatai Tungsten Co., Ltd.

Tungsten

China

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

Tungsten

China

 

14