Silicon Laboratories Inc.
SILICON LABORATORIES INC (Form: SD, Received: 05/30/2017 16:35:03)

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

 

FORM SD

 

SPECIALIZED DISCLOSURE REPORT

 

SILICON LABORATORIES INC.

(Exact name of registrant as specified in its charter)

 

Delaware

 

000-29823

 

74-2793174

(State or other jurisdiction

 

(Commission File Number)

 

(IRS Employer

of incorporation)

 

 

 

Identification No.)

 

400 West Cesar Chavez , Austin, TX 78701

(Address of principal executive offices) (Zip Code)

 

John C. Hollister  (512) 416-8500

(Name and telephone number, including area code, of the person to contact in connection with this report.)

 

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

 

x           Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.

 

 

 



 

Section 1 - Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

Introduction

 

This Specialized Disclosure Report on Form SD (“Form SD”) of Silicon Laboratories Inc. (“Silicon Laboratories” or “the Company”) 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 related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act. Conflict minerals are defined by the SEC as cassiterite, columbite-tantalite, gold and wolframite, as well as their derivatives (including tantalum, tin and tungsten) and any other mineral or its derivatives determined by the United States Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country (collectively, “Covered Countries”).

 

The Rule imposes certain reporting obligations on SEC registrants that file reports under Section 13(a) or Section 15(d) of the Exchange Act whose products contain conflict minerals that are necessary to the functionality or production of their products. For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Covered Countries.

 

Reasonable Country of Origin Inquiry

 

Description of Reasonable Country of Origin Inquiry Efforts

 

The following is a brief description of the RCOI process the Company undertook in accordance with the Rule:

 

·                   The Company reviewed the components of the products provided by its suppliers to determine if such products contained conflict minerals.

 

·                   The Company conducted a supply chain survey with suppliers to obtain country of origin information for the necessary conflict minerals in the Company’s products using the Electronic Industry Citizenship Coalition (“EICC”) Conflict Minerals Reporting Template (“CMRT”).

 

·                   The Company reviewed the completed CMRT surveys for compliance with the Company’s internal policy.

 

·                   The Company compared the smelters and refiners identified by the CMRT surveys against the list of facilities that have received a “conflict free” designation from the Conflict Free Smelter Program (“CFSP”).

 

·                   The Company assessed whether the smelters and refiners had carried out all elements of reasonable due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

 

Results of the Reasonable Country of Origin Inquiry and Determination of Products

 

Based on the results of the Company’s RCOI, the following was determined:

 

·                   A portion of the necessary conflict minerals contained in the Company’s products originated or may have originated in the Covered Countries and those necessary conflict minerals may not be solely from recycled or scrap sources. The Company performed due diligence measures on these conflict minerals, as discussed further below.

 

·                   A portion of the necessary conflict minerals contained in the Company’s products are from recycled or scrap sources. Conflict minerals obtained from recycled or scrap sources are considered DRC conflict free pursuant to Rule 13p-1.

 

2



 

Conflict Minerals Report

 

On May 30, 2017, Silicon Laboratories issued its Conflict Minerals Report for the calendar year ended December 31, 2016. Such report is filed herewith as Exhibit 1.01 and is also available in the Investor Relations section of Silicon Laboratories’ website under “Corporate Governance” at www.silabs.com. Silicon Laboratories’ website and the information contained therein or connected thereto are not intended to be incorporated into this Report on Form SD.

 

Item 1.02 Exhibit

 

The Conflict Minerals Report for the calendar year ended December 31, 2016 is filed as Exhibit 1.01.

 

Section 2 — Exhibits

 

Item 2.01 Exhibits

 

Exhibit No.

 

Description

1.01

 

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

 

3



 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

 

 

SILICON LABORATORIES INC.

 

 

 

 

 

 

May 30, 2017

 

/s/ John C. Hollister

Date

 

John C. Hollister
Senior Vice President and
Chief Financial Officer

 

4


Exhibit 1.01

 

Silicon Laboratories Inc.

Conflict Minerals Report

Calendar Year Ended December 31, 2016

 

This Conflict Minerals Report of Silicon Laboratories Inc. (“Silicon Laboratories” or “the Company”) 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 related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). Conflict minerals are defined by the SEC as cassiterite, columbite-tantalite, gold and wolframite, as well as their derivatives (including tantalum, tin and tungsten) and any other mineral or its derivatives determined by the United States Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”).

 

The Rule imposes certain reporting obligations on SEC registrants that file reports under Section 13(a) or Section 15(d) of the Exchange Act whose products contain conflict minerals that are necessary to the functionality or production of their products, exempting conflict minerals that, prior to January 31, 2013, were located “outside of the supply chain” (as defined in the Rule). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the conflict minerals originated in the Covered Countries.  If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence as to whether the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries.  Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered “DRC conflict free.”

 

Certain of the Company’s products contain conflict minerals, including gold, tantalum, tin and/or tungsten. These minerals are necessary to the functionality of the products contracted by the Company to be manufactured. Pursuant to the Rule, the Company undertook due diligence measures on the source and chain of custody of the conflict minerals in its products that the Company had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources, to determine whether such products were DRC conflict free.

 

The following describes: (a) the design of the Company’s Conflict Minerals Program; (b) the Company’s conclusion based on its RCOI; (c) the measures the Company has taken to exercise due diligence on the source and chain of custody of the conflict minerals contained in its products; and (d) the Company’s products, including information on the facilities used to process the necessary conflict minerals in those products, the country of origin of the necessary conflict minerals in those products and the Company’s efforts to determine the mine or location of origin of those conflict minerals with the greatest possible specificity.

 

Part 1 — Due Diligence

 

Design of Conflict Minerals Program

 

The design of the Company’s conflict minerals program is in conformity with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), as it relates to the Company’s position in the minerals supply chain. Summarized below are the design components of the Company’s conflict minerals program as they relate to the five-step framework set forth in the OECD Guidance:

 

1.               Establish strong company management systems.

 

·                   Adopt and commit to a supply chain policy for minerals originating from conflict-affected and high-risk areas.

 



 

·                   The Company’s supply chain policy requires all suppliers to maintain a conflict-free sourcing policy and to comply with the Company’s internal policy based on the OECD Guidance.

 

·                   Structure internal management systems to support supply chain due diligence.

 

·                   Vendors that supply the Company with products containing conflict minerals are required to complete an Electronic Industry Citizenship Coalition (“EICC”) Conflict Minerals Reporting Template (“CMRT”), a supply chain survey designed to identify the smelters, refiners and countries of origin of the conflict minerals in products the vendors supply to a customer.

 

·                   Establish a system of controls and transparency over the mineral supply chain.

 

·                   The Company maintains a dedicated internal system to track, analyze and approve supplier responses to supply chain surveys. The Company maintains records relating to its conflict minerals program in accordance with its record retention guidelines.

 

·                   Strengthen Company engagement with suppliers.

 

·                   The Company has created an internal system of controls to ensure that both current and new suppliers report information regarding their supply chain.

 

·                   Establish a Company level grievance mechanism.

 

·                   The Company maintains an external reporting system for individuals to report concerns of actions (including compliance with the Company’s conflict minerals program) that may not comply with the Company’s standards, contractual, regulatory or legal requirements.

 

2.               Identify and assess risks in the Company’s supply chain.

 

·                   Identify risks in the supply chain as recommended in the OECD Guidance Supplements.

 

·                   The Company reviews the components of the products provided by its suppliers to determine if such products may contain conflict minerals.

 

·                   The Company requests suppliers that provide products which may contain conflict minerals to complete the CMRT survey. The Company contacts vendors that do not respond to the supply chain survey by a specified date, requesting their responses. If necessary, the Company escalates its requests to management or other appropriate personnel as described in its supply chain policy.

 

·                   Assess risks of adverse impacts in light of the standards of the Company’s supply chain policy consistent with the due diligence recommendations in the OECD Guidance.

 

·                   The Company reviews completed CMRT surveys for compliance with the Company’s internal policy based on the OECD Guidance.

 

·                   The Company compares the smelters and refiners identified by the CMRT surveys against the list of facilities that have received a “conflict free” designation from the Conflict Free Smelter Program (“CFSP”), an initiative organized by the EICC and the Global e-Sustainability Initiative.

 

·                   The Company assesses whether the smelters and refiners have carried out all elements of reasonable due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas.

 

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

 

·                   Devise and adopt a risk management plan.

 

·                   The Company has adopted a risk management plan, which includes measures for risk mitigation for suppliers using smelters and refiners that have not received a conflict free designation from the CFSP.

 

·                   Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management.

 

·                   The Company’s risk mitigation efforts for smelters and refiners that have not received a conflict free designation from the CFSP include: (a) reviewing the mine location; (b) requesting and reviewing Certificate of Origin documents from the supplier; (c) requesting an action plan from the supplier; and (d) performing a risk assessment with an internal management team for further consideration of risk mitigation.

 



 

·                   Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances.

 

·                   The Company’s conflict minerals policy is an on-going program for both current and new suppliers. Any change in the Company’s supply chain may require that certain steps be repeated in order to prevent or mitigate adverse impacts.

 

·                   Report findings of the supply chain risk assessment to the designated senior management of the Company.

 

·                   The Company reports findings from its supply chain risk assessment to its Executive Quality Council, which consists of members of the Company’s executive management.

 

·                   If and when required by the Rule, obtain an independent private sector audit of the Company’s Conflict Minerals Report.

 

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

 

·                   The Company supports development and implementation of due diligence practices and tools, including:

 

·                   The CMRT survey completed by the Company’s suppliers,

 

·                   The Conflict Free Smelter Program used by the Company to determine facilities that have received a conflict free designation.

 

·                   The Company encourages all of its conflict mineral suppliers to use facilities that have received a conflict free designation.

 

5.               Report on supply chain due diligence.

 

·                   The Company publicly reports on its supply chain due diligence policies and practices in the Investor Relations section of its website at www.silabs.com.

 

Conclusion Based on Reasonable Country of Origin Inquiry

 

Step 2 of the Company’s Conflict Minerals Program,  Identify and assess risks in the Company’s supply chain , represents its RCOI. This step is designed to determine whether any of the conflict minerals in the Company’s products originated in the Covered Countries. Based on the results of the Company’s RCOI, the following was determined:

 

·                   A portion of the necessary conflict minerals contained in the Company’s products originated or may have originated in the Covered Countries and those necessary conflict minerals may not be solely from recycled or scrap sources. The Company performed due diligence measures on these conflict minerals.

 

·                   A portion of the necessary conflict minerals contained in the Company’s products are from recycled or scrap sources. Conflict minerals obtained from recycled or scrap sources are considered DRC conflict free pursuant to Rule 13p-1.

 

Description of Due Diligence Measures Performed

 

Steps 3 and 4 of the Company’s Conflict Minerals Program, Design and implement a strategy to respond to identified risks and Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain, respectively, represent the due diligence measures performed by the Company. The purpose of these measures is to determine whether the necessary conflict minerals contained in the Company’s products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries in order to conclude whether such products were DRC conflict free.

 



 

Below is a description of the measures the Company performed to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in its products:

 

·                   Adopted a risk management plan, which included measures for risk mitigation for suppliers using smelters and refiners that have not received a conflict free designation from the CFSP.

 

·                   Requested the Company’s existing and new conflict mineral suppliers to use facilities that have received a conflict free designation. Suppliers that use facilities without such designation may be removed as an approved vendor.

 

·                   Monitored and tracked suppliers to ensure compliance with the Company’s Conflict Minerals Sourcing Policy.

 

·                   Performed risk mitigation efforts with suppliers identified to be in conformity with our Conflict Minerals Sourcing Policy by working with them to bring them into compliance.

 

·                   Reported findings from the Company’s supply chain risk assessment to its Executive Quality Council.

 

Results of Due Diligence Measures and Product Determination

 

The Company received responses from all of its direct suppliers subject to the supply chain survey for 2016. Collectively, their responses listed 206 smelters and refiners within their supply chains. The tables below list the smelters and refiners of conflict minerals within our supply chain for 2016. Our efforts to determine this population are described above under the caption “Description of Due Diligence Measures Performed.” The information presented is derived from information provided by our direct suppliers and the CFSP.

 

Independent Private Sector Audit

 

An independent private sector audit is not required for 2016.

 

Future Due Diligence Measures

 

For the next reporting period, the Company is continuing to engage in the activities described above in “Design of Conflict Minerals Program” to mitigate the risk that its necessary conflict minerals benefit armed groups. The Company will continue to contact suppliers that use smelters and refiners identified in its supply chain survey process that have not received a conflict free designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a conflict free designation.

 

Part 2 — Product Description

 

Description of the Company’s products

 

Silicon Laboratories is a provider of silicon, software and solutions for the Internet of Things (IoT), Internet infrastructure, industrial, consumer and automotive markets. Mixed-signal integrated circuits (ICs) are electronic components that convert real-world analog signals, such as sound and radio waves, into digital signals that electronic products can process. Therefore, mixed-signal ICs are critical components in products addressing a variety of markets, including industrial, communications, consumer and automotive.

 

As a fabless semiconductor company, Silicon Laboratories relies on third-party semiconductor fabricators to manufacture the silicon wafers that reflect its IC designs. Each wafer contains numerous die, which are cut from the wafer to create a chip for an IC. The Company relies on third parties to assemble, package, and, in most cases, test these devices and ship these units to its customers.

 



 

The following facilities, to the extent known, are used to process the necessary conflict minerals in the Company’s products:

 

Metal

 

Facility Name

Gold

 

Aida Chemical Industries Co., Ltd.

Gold

 

Allgemeine Gold-und Silberscheideanstalt A.G.

Gold

 

Almalyk Mining and Metallurgical Complex (AMMC)

Gold

 

AngloGold Ashanti Córrego do Sítio Mineração

Gold

 

Argor-Heraeus S.A.

Gold

 

Asahi Pretec Corp.

Gold

 

Asahi Refining Canada Ltd.

Gold

 

Asahi Refining USA Inc.

Gold

 

Asaka Riken Co., Ltd.

Gold

 

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Gold

 

Aurubis AG

Gold

 

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Gold

 

Boliden AB

Gold

 

C. Hafner GmbH + Co. KG

Gold

 

CCR Refinery - Glencore Canada Corporation

Gold

 

Cendres + Métaux S.A.

Gold

 

Chimet S.p.A.

Gold

 

Dowa

Gold

 

Eco-System Recycling Co., Ltd.

Gold

 

Elemetal Refining, LLC

Gold

 

Heimerle + Meule GmbH

Gold

 

Heraeus Ltd. Hong Kong

Gold

 

Heraeus Precious Metals GmbH & Co. KG

Gold

 

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

Gold

 

Ishifuku Metal Industry Co., Ltd.

Gold

 

Istanbul Gold Refinery

Gold

 

Japan Mint

Gold

 

Jiangxi Copper Co., Ltd.

Gold

 

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Gold

 

JSC Uralelectromed

Gold

 

JX Nippon Mining & Metals Co., Ltd.

Gold

 

Kazzinc

Gold

 

Kennecott Utah Copper LLC

Gold

 

Kojima Chemicals Co., Ltd.

Gold

 

Kyrgyzaltyn JSC

Gold

 

LS-NIKKO Copper Inc.

Gold

 

Materion

Gold

 

Matsuda Sangyo Co., Ltd.

Gold

 

Metalor Technologies (Hong Kong) Ltd.

Gold

 

Metalor Technologies (Singapore) Pte., Ltd.

Gold

 

Metalor Technologies S.A.

Gold

 

Metalor USA Refining Corporation

Gold

 

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

Gold

 

Mitsubishi Materials Corporation

Gold

 

Mitsui Mining and Smelting Co., Ltd.

Gold

 

MMTC-PAMP India Pvt., Ltd.

Gold

 

Nadir Metal Rafineri San. Ve Tic. A.Ş.

Gold

 

Navoi Mining and Metallurgical Combinat

Gold

 

Nihon Material Co., Ltd.

Gold

 

Ohura Precious Metal Industry Co., Ltd.

Gold

 

OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)

Gold

 

PAMP S.A.

 



 

Gold

 

PT Aneka Tambang (Persero) Tbk

Gold

 

PX Précinox S.A.

Gold

 

Rand Refinery (Pty) Ltd.

Gold

 

Republic Metals Corporation

Gold

 

Royal Canadian Mint

Gold

 

Samduck Precious Metals

Gold

 

SEMPSA Joyería Platería S.A.

Gold

 

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

Gold

 

Sichuan Tianze Precious Metals Co., Ltd.

Gold

 

Singway Technology Co., Ltd.

Gold

 

SOE Shyolkovsky Factory of Secondary Precious Metals

Gold

 

Solar Applied Materials Technology Corp.

Gold

 

Sumitomo Metal Mining Co., Ltd.

Gold

 

T.C.A S.p.A

Gold

 

Tanaka Kikinzoku Kogyo K.K.

Gold

 

The Refinery of Shandong Gold Mining Co., Ltd.

Gold

 

Tokuriki Honten Co., Ltd.

Gold

 

Torecom

Gold

 

Umicore Brasil Ltda.

Gold

 

Umicore Precious Metals Thailand

Gold

 

Umicore S.A. Business Unit Precious Metals Refining

Gold

 

United Precious Metal Refining, Inc.

Gold

 

Valcambi S.A.

Gold

 

Western Australian Mint trading as The Perth Mint

Gold

 

Yamamoto Precious Metal Co., Ltd.

Gold

 

Yokohama Metal Co., Ltd.

Gold

 

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Gold

 

Zijin Mining Group Co., Ltd. Gold Refinery

Tantalum

 

Changsha South Tantalum Niobium Co., Ltd.

Tantalum

 

Conghua Tantalum and Niobium Smeltry

Tantalum

 

Duoluoshan

Tantalum

 

Exotech Inc.

Tantalum

 

F&X Electro-Materials Ltd.

Tantalum

 

Global Advanced Metals Aizu

Tantalum

 

Global Advanced Metals Boyertown

Tantalum

 

Guangdong Zhiyuan New Material Co., Ltd.

Tantalum

 

H.C. Starck Co., Ltd.

Tantalum

 

H.C. Starck GmbH Goslar

Tantalum

 

H.C. Starck GmbH Laufenburg

Tantalum

 

H.C. Starck Hermsdorf GmbH

Tantalum

 

H.C. Starck Inc.

Tantalum

 

H.C. Starck Ltd.

Tantalum

 

H.C. Starck Smelting GmbH & Co. KG

Tantalum

 

Hengyang King Xing Lifeng New Materials Co., Ltd.

Tantalum

 

Hi-Temp Specialty Metals, Inc.

Tantalum

 

JiuJiang JinXin Nonferrous Metals Co., Ltd.

Tantalum

 

Jiujiang Tanbre Co., Ltd.

Tantalum

 

LSM Brasil S.A.

Tantalum

 

Mineração Taboca S.A.

Tantalum

 

Mitsui Mining and Smelting Co., Ltd.

Tantalum

 

Molycorp Silmet A.S.

Tantalum

 

Ningxia Orient Tantalum Industry Co., Ltd.

Tantalum

 

Plansee SE Liezen

Tantalum

 

Plansee SE Reutte

Tantalum

 

Solikamsk Magnesium Works OAO

Tantalum

 

Taki Chemical Co., Ltd.

 



 

Tantalum

 

Telex Metals

Tantalum

 

Ulba Metallurgical Plant JSC

Tantalum

 

Yichun Jin Yang Rare Metal Co., Ltd.

Tantalum

 

Zhuzhou Cemented Carbide Group Co., Ltd.

Tin

 

Alpha

Tin

 

An Vinh Joint Stock Mineral Processing Company

Tin

 

China Tin Group Co., Ltd.

Tin

 

Cooperativa Metalurgica de Rondônia Ltda.

Tin

 

CV Ayi Jaya

Tin

 

CV Gita Pesona

Tin

 

CV Serumpun Sebalai

Tin

 

CV United Smelting

Tin

 

CV United Smelting

Tin

 

CV Venus Inti Perkasa

Tin

 

Dowa

Tin

 

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

Tin

 

Elmet S.L.U.

Tin

 

EM Vinto

Tin

 

Fenix Metals

Tin

 

Gejiu Kai Meng Industry and Trade LLC

Tin

 

Gejiu Non-Ferrous Metal Processing Co., Ltd.

Tin

 

Jiangxi Ketai Advanced Material Co., Ltd.

Tin

 

Magnu’s Minerais Metais e Ligas Ltda.

Tin

 

Malaysia Smelting Corporation (MSC)

Tin

 

Melt Metais e Ligas S.A.

Tin

 

Metallic Resources, Inc.

Tin

 

Metallo-Chimique N.V.

Tin

 

Mineração Taboca S.A.

Tin

 

Minsur

Tin

 

Mitsubishi Materials Corporation

Tin

 

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Tin

 

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

Tin

 

O.M. Manufacturing Philippines, Inc.

Tin

 

Operaciones Metalurgical S.A.

Tin

 

PT Aries Kencana Sejahtera

Tin

 

PT Artha Cipta Langgeng

Tin

 

PT ATD Makmur Mandiri Jaya

Tin

 

PT Babel Inti Perkasa

Tin

 

PT Bangka Prima Tin

Tin

 

PT Bangka Tin Industry

Tin

 

PT Belitung Industri Sejahtera

Tin

 

PT Bukit Timah

Tin

 

PT Cipta Persada Mulia

Tin

 

PT DS Jaya Abadi

Tin

 

PT Eunindo Usaha Mandiri

Tin

 

PT Inti Stania Prima

Tin

 

PT Justindo

Tin

 

PT Menara Cipta Mulia

Tin

 

PT Mitra Stania Prima

Tin

 

PT Panca Mega Persada

Tin

 

PT Prima Timah Utama

Tin

 

PT Refined Bangka Tin

Tin

 

PT Sariwiguna Binasentosa

Tin

 

PT Stanindo Inti Perkasa

Tin

 

PT Sukses Inti Makmur

Tin

 

PT Sumber Jaya Indah

 



 

Tin

 

PT Timah (Persero) Tbk Kundur

Tin

 

PT Timah (Persero) Tbk Mentok

Tin

 

PT Tinindo Inter Nusa

Tin

 

PT Tommy Utama

Tin

 

PT Wahana Perkit Jaya

Tin

 

Resind Indústria e Comércio Ltda.

Tin

 

Rui Da Hung

Tin

 

Soft Metais Ltda.

Tin

 

Thaisarco

Tin

 

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Tin

 

VQB Mineral and Trading Group JSC

Tin

 

White Solder Metalurgia e Mineração Ltda.

Tin

 

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

Tin

 

Yunnan Tin Company Limited

Tungsten

 

A.L.M.T. TUNGSTEN Corp.

Tungsten

 

Chenzhou Diamond Tungsten Products Co., Ltd.

Tungsten

 

Chongyi Zhangyuan Tungsten Co., Ltd.

Tungsten

 

Fujian Jinxin Tungsten Co., Ltd.

Tungsten

 

Ganzhou Huaxing Tungsten Products Co., Ltd.

Tungsten

 

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

Tungsten

 

Ganzhou Seadragon W & Mo Co., Ltd.

Tungsten

 

Global Tungsten & Powders Corp.

Tungsten

 

Guangdong Xianglu Tungsten Co., Ltd.

Tungsten

 

H.C. Starck GmbH

Tungsten

 

H.C. Starck Smelting GmbH & Co.KG

Tungsten

 

Hunan Chunchang Nonferrous Metals Co., Ltd.

Tungsten

 

Hydrometallurg, JSC

Tungsten

 

Japan New Metals Co., Ltd.

Tungsten

 

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

Tungsten

 

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

Tungsten

 

Jiangxi Yaosheng Tungsten Co., Ltd.

Tungsten

 

Kennametal Fallon

Tungsten

 

Kennametal Huntsville

Tungsten

 

Malipo Haiyu Tungsten Co., Ltd.

Tungsten

 

Niagara Refining LLC

Tungsten

 

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

Tungsten

 

Tejing (Vietnam) Tungsten Co., Ltd.

Tungsten

 

Vietnam Youngsun Tungsten Industry Co., Ltd.

Tungsten

 

Wolfram Bergbau und Hütten AG

Tungsten

 

Xiamen Tungsten (H.C.) Co., Ltd.

Tungsten

 

Xiamen Tungsten Co., Ltd.

Tungsten

 

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

 

The countries of origin of the necessary conflict minerals in the Company’s products are believed to include:

 

Australia, Austria, Belgium, Bolivia, Brazil, Canada, China, Democratic Republic of the Congo, Estonia, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Peru, Philippines, Mozambique, Poland, Portugal, Russian Federation, Rwanda, Singapore, South Korea, South Africa, Spain, Sweden, Switzerland, Taiwan, Thailand, Turkey, United States, Uzbekistan, Vietnam and Zimbabwe.

 

Efforts to determine the mine or location of origin with the greatest possible specificity of the necessary conflict minerals in the Company’s products:

 

In an effort to determine the mine or location of origin of the necessary conflict minerals in its products that are DRC conflict free with the greatest possible specificity, the Company developed and conducted the due diligence measures described in Part 1 of this Conflict Minerals Report.