Abbott Laboratories Conflict Minerals Report 2015

Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report

Abbott Laboratories (Abbott) is filing a Conflict Minerals Report as an exhibit to this specialized disclosure report and is providing
that report on Abbott’s publicly available Internet website at http://www.abbott.com/policies/conflict-minerals.html.
Abbott’s determination and related disclosures relating to materials that may come from recycled and scrap sources are included in our
Conflict Minerals Report and are incorporated by reference herein.

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as an exhibit to this Form SD.

Section 2 — Exhibits
Item 2.01 Exhibits

The following exhibit is filed as a part of this report.
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

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.

Abbott Laboratories
(Registrant)

/s/ Brian B. Yoor                                                                                     May 31, 2016
By (Signature and Title)                                                                         (Date)

Brian B. Yoor
Senior Vice President, Finance & Chief Financial Officer

EXHIBIT INDEX

Exhibit 1.01                   Conflict Minerals Report for the Year Ended December 31, 2015

Exhibit 1.01

Abbott Laboratories

Conflict Minerals Report

For the Year Ended December 31, 2015

This report for the year ended December 31, 2015 has been prepared by Abbott Laboratories and its consolidated subsidiaries, as context requires (herein referred to as “Abbott,” “we,” “us,” or “our”) and is submitted in accordance with Rule 13p-1 of the Securities Exchange Act of 1934 (the Rule), and regulations and guidance issued by the Securities and Exchange Commission (SEC) relating to
the Rule. This report is available on our website at http://www.abbott.com/policies/conflict-minerals.html.

1. Overview

Abbott is a broad-based, global health care company. We discover, develop, manufacture and market a wide range of health care products, including nutritional products, diagnostic systems and tests, branded generic pharmaceuticals, and medical devices.

We analyzed the products we manufacture or contract to have manufactured, and found that small quantities of tin, tantalum, tungsten, and gold (3TG) may be present in a number of our products; primarily, in electronic diagnostic and monitoring instruments, in medical and surgical devices and equipment, and in product components containing metal alloys. After requesting information from our suppliers as described below, we are unable to determine whether the limited quantities of 3TG actually present in our products originated from the Democratic Republic of the Congo (DRC) or adjoining countries, and whether such 3TG came from recycled or scrap sources. We similarly have been unable to conclusively identify the specific facilities used to process the 3TG actually present in

our products.

Supply Chain

Abbott manufactures thousands of products. Because of the diversity and complexity of our products, we have thousands of suppliers that supply us with parts, components, or other materials. Each of these suppliers may in turn have large numbers of sub-suppliers. We typically do not have direct relationships with mines, smelters, or refiners. We rely on our suppliers to provide information on the
origin of 3TG contained in the parts, components, and materials supplied to us — including sources of 3TG that are supplied to them from their lower-tier suppliers. Many of our smaller suppliers, as well as those further upstream in the supply chain, are not SEC registrants subject to the Rule.

Our contracts with direct suppliers may be in force for multiple years and historically did not require the supplier to provide Abbott with information regarding the origin of 3TG. As we renew or enter into new contracts with suppliers for parts, components, or other materials that may contain 3TG, we are working to add language requiring those suppliers to provide information about the source and
chain of custody of 3TG present in the parts, components, and materials they supply to Abbott. While these supplier contracts are being updated to contain appropriate flow-down provisions, we rely on the cooperation of our direct suppliers to provide the necessary information on the origin of 3TG and are continuing to work with our suppliers to obtain current 3TG sourcing information, as described in more detail below.

Requesting Information from Suppliers

Abbott’s supplier query program was designed to survey direct suppliers who provide parts, components, or materials likely to contain 3TG. We also surveyed lower-tier, sub-suppliers that were identified by a distributor providing parts, components, or materials to Abbott.

We surveyed suppliers using the Conflict Minerals Reporting Template (CMRT) developed by the Conflict Free Sourcing Initiative (CFSI). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a manufacturer’s supply chain, and forms a basis for our Reasonable Country of Origin Inquiry (RCOI). The CMRT includes questions regarding the supplier’s “conflict-free policy,” its engagement with its direct upstream suppliers, and a listing of smelters used in the supply chain. In addition, the CMRT contains questions about the origin of 3TG included in the supplier’s products, as well as the respondent’s due diligence on their suppliers.

If a supplier response is received early in the reporting year, at the end of the year we ask the supplier to confirm its response is still accurate. We provide suppliers with training materials on Conflict Minerals when we send out the CMRT. CFSI also makes written instructions and recorded training on the CMRT available on its website.

2. Design of Due Diligence Process

Abbott’s due diligence measures have been designed to conform in all material respects with the framework set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. Below is a description of the measures that we implemented and the diligence we performed.

3. Description of Due Diligence Performed

The due diligence measures we performed are presented below according to the five-step framework established by the OECD.

3.1 Company Management Systems

Communication

Abbott’s company statement relating to conflict minerals is available at: http://www.abbott.com/policies/conflict-minerals.html.

Internal Management Structure

We established an internal management structure and processes to support supply chain due diligence related to 3TG. This includes a cross-functional conflict minerals steering committee sponsored by senior management, as well as sub-teams focused on development, implementation, and ongoing enhancements to our compliance processes. The sub-teams include management representatives and
subject matter experts from each of our operating divisions, as well as representatives from Legal, Quality Assurance, Purchasing, Finance, Government Affairs, and Public Affairs. Senior management is briefed on the results of our supplier due diligence efforts.

System of Controls and Transparency

Through our membership in the CFSI we actively follow and support national and international efforts to identify upstream actors in the supply chain and increase traceability.

We have established various supplier controls, including our Supplier Guidelines, which outline expected behaviors and practices for all Abbott suppliers. The Supplier Guidelines instruct suppliers to report on the source and chain of custody of any 3TGs contained in the parts, components, or materials supplied to Abbott, following the guidelines developed by the OECD. This includes providing information on the location of the mine or the country of origin and/or the smelter where the 3TG was processed.

In addition, our Code of Business Conduct outlines Abbott’s core values and expectations for Abbott employees.

Abbott has established procedures and control systems designed to ensure relevant documentation is retained for an appropriate time period.

Supplier Engagement

Abbott has developed model contract language requiring suppliers to provide adequate information regarding the source and chain of custody of 3TGs. We are working to add this language to agreements where the supplier is providing parts, components, assemblies, materials, or other products that may contain any 3TGs. Our Supplier Guidelines also include expectations for suppliers regarding the tracking and reporting of 3TGs in the parts, components, or materials they supply to Abbott. As part of our supplier query process, we also make available training materials on the requirements of the Conflict Minerals Rule and the proper procedure to complete the CMRT.

Grievance Mechanism

We have longstanding grievance mechanisms for employees and suppliers to report potential concerns or violations of Abbott policies. These mechanisms include direct reporting to managers or compliance officers, on-line reporting, and a toll-free Helpline that is available 24 hours a day, seven days a week, with interpreters available in multiple languages.

3.2 Identify and Assess Risk in the Supply Chain

We identified and surveyed suppliers who provide Abbott with parts, components, or materials likely to contain 3TG. We evaluated the responses we received to determine if the response was complete based on internally defined criteria, or if further engagement with the supplier was required. In accordance with our defined procedure, we also attempted to engage suppliers who did not respond,
provided an incomplete response, or provided inconsistent data within the CMRT. We have worked, and will continue to work, with these suppliers to obtain additional information to supplement their responses.

In many cases, suppliers identified facilities that could not be confirmed as known smelters. In such situations we notified CFSI, which has implemented a process to confirm whether such facilities are legitimate smelters. We continue to work with suppliers and CFSI to improve the accuracy of reported processing facility information and to verify the identity of these reported facilities. We also
partner with our suppliers to encourage smelters to engage with CFSI and participate in CFSI’s Conflict-Free Smelter Program.

3.3 Design and Implement a Strategy to Respond to Risks

Abbott’s strategy to respond to identified risks in the supply chain includes the following elements:
􀁸 We identify potential risks or red flags by evaluating the responses provided by our suppliers, and we have developed processes to address incomplete, inconsistent, or otherwise unsatisfactory responses received from our suppliers, including a process to elevate issues to appropriate management for resolution.
􀁸 We maintain a dashboard to regularly monitor and track our supply chain risk assessment process.
􀁸 Management is briefed about our due diligence efforts on a regular basis.

3.4 Carry out Independent Third Party Audit Supply Chain Due Diligence at Identified Points in the Supply Chain

We support audits of 3TG smelters and refiners conducted by third parties through our participation and membership in the CFSI.

3.5 Report on Supply Chain Due Diligence

This Conflict Minerals Report constitutes our annual report on our 3TG due diligence, is filed with the SEC, and is available on our
website at the following link: http://www.abbott.com/policies/conflict-minerals.html

4. Steps to Mitigate Risk

Abbott has taken or intends to take the following steps to continuously improve the due diligence conducted on the source and chain
of custody of 3TG in our products:
a) Participate as a member in the CFSI in efforts to increase the number of smelters and refiners participating in the Conflict-
Free Smelter Program (CFS Program).
b) Engage with suppliers and direct them to training and other resources designed to help them increase the response rate,
improve the content of the supplier survey responses, and ensure that the processing facilities they identify are actual, known
smelters or refiners.
c) For identified known smelters that are not participating in the CFS Program, work with suppliers and CFSI to engage these
smelters to encourage participation in the CFS Program.
d) Work with peer groups and relevant trade associations to define and improve best practices with our supply chain in
accordance with the OECD Guidance.
e) For new or renewed supplier contracts, include a clause requiring the supplier to provide requested information regarding
3TG in the parts, components or materials they supply to Abbott.

5. Determination

For 2015, we received responses from a majority of the suppliers we surveyed, improving on the response rates we have experienced in previous years. Many of the responding suppliers provided processing facility data. Using that data, and cross-checking against existing CFSI smelter lists, we were able to confirm 314 of the processing facilities identified by our suppliers as actual known
smelters.

Of the known smelters, 208 are compliant with the Conflict-Free Smelter Program assessment protocols and are considered conflict-free. Another 45 were reported to have committed to undergo a Conflict-Free Smelter Program audit or are participating in another recognized certification program.

Based on information provided by CFSI, 23 of the 208 conflict-free smelters identified by our suppliers were reported as sourcing minerals from the DRC or an adjoining country, 107 were reported as not sourcing from the DRC or an adjoining country and 16 were reported as sourcing solely from recycled or scrap materials. Sourcing was not disclosed for 62 of the conflict-free smelters. Annex I contains a listing of the known smelters and refiners identified by Abbott’s suppliers.

Numerous suppliers reported some use of 3TG produced from recycled or scrap sources in their supply chain during 2015, but did not provide information on whether any of the parts, components, or materials actually supplied to Abbott contained any 3TG from those recycled or scrap sources. In addition, none of the responding suppliers were able to identify the specific facility that processed 3TG in the products actually supplied to Abbott. As a result, we were unable to conclusively identify the specific facilities that were used to process the 3TG contained in the parts, components, or materials actually supplied to Abbott, or whether the 3TG came from recycled or scrap sources.

Similarly, based on our due diligence efforts, we do not have sufficient information to conclusively determine the country of origin of the 3TG contained in the parts, components, or materials actually supplied to Abbott.

We seek reasonable information about 3TG smelters and refiners and the mines or locations of origin of 3TG in our supply chain through the following efforts: supporting industry initiatives like the CFSI through our membership; reviewing best practices established in the Organization for Economic Co-operation and Development (OECD) and other due diligence implementation programs; and requesting our suppliers to complete the CMRT, and evaluating supplier responses as described above.

Forward-looking Statements

Please note that forward-looking statements relating to Abbott’s future plans are based on current expectations and assumptions, and are not intended to be guarantees. Our actual actions may differ from these forward-looking statements.

Smelter List and Country of Origin List

Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)

Gold Advanced Chemical Company **
Gold Aida Chemical Industries Co. Ltd.*
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Almalyk Mining and Metallurgical Complex (AMMC)**
Gold AngloGold Ashanti Córrego do Sítio Minerção*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
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 Caridad Gold CCR Refinery – Glencore Canada Corporation*
Gold Cendres + Métaux SA**
Gold Chimet S.p.A.*
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.**
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Eco-System Recycling Co., Ltd.*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
Gold Fidelity Printers and Refiners Ltd.
Gold FSE Novosibirsk Refinery*
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation**
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Heraeus Precious Metals GmbH & Co. KG*
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Ishifuku Metal Industry Co., Ltd.*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Jiangxi Copper Company Limited*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold JSC Uralectromed*
Gold JX Nippon Mining & Metals Co., Ltd*
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd*
Gold Kennecott Utah Copper LLC*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited 
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Gold Luoyang Zijin Yinhui Gold Refinery 
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies (Hong Kong) Ltd*
Gold Metalor Technologies (Singapore) Pte. Ltd.*
Gold Metalor Technologies (Suzhou) Ltd.**
Gold Metalor Technologies SA*
Gold Metalor USA Refining Corporation*
Gold Mitsubishi Materials Corporation*
Gold Mitsui Mining and Smelting Co., Ltd.*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant*
Gold Gold Navoi Mining and Metallurgical Combinat**
Gold Nihon Material Co. LTD*
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold Ohio Precious Metals, LLC*
Gold Ohura Precious Metal Industry Co., Ltd*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Penglai Penggang Gold Industry Co., Ltd. 
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PT Aneka Tambang (Persero) Tbk*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Republic Metals Corporation*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold SEMPSA Joyería Platería SA*
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold Sichuan Tianze Precious Metals Co., Ltd.*
Gold Singway Technology Co., Ltd.*
Gold So Accurate Group, Inc.
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 Tongling nonferrous Metals Group Co.,Ltd
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Umicore Precious Metals Thailand*
Gold Umicore SA Business Unit Precious Metals Refining*
Gold United Precious Metal Refining, Inc.*
Gold Valcambi SA*
Gold Western Australian Mint trading as The Perth Mint*
Gold WIELAND Edelmetalle GmbH**
Gold YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold Yokohama Metal Co Ltd*
Gold Yunnan Copper Industry Co Ltd
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold Zijin Mining Group Co. Ltd*

Tantalum Changsha South
Tantalum Niobium Co., Ltd.*
Tantalum Conghua Tantalum and Niobium Smeltry*
Tantalum D Block Metals, LLC*
Tantalum Duoluoshan*
Tantalum Exotech Inc.*
Tantalum F&X Electro-Materials Ltd.*
Tantalum FIR Metals & Resource Ltd.*
Tantalum Global Advanced Metals Boyertown*
Tantalum Global Advanced Metals*
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* Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum Jiujiang Tanbre Co., Ltd.*
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum KEMET Blue Metals*
Tantalum Kemet Blue Powder*
Tantalum King-Tan Tantalum Industry Ltd* Tantalum LSM Brasil S.A.* Tantalum Metallurgical Products India (Pvt.) Ltd.*
Tantalum Mineração Taboca S.A.*
Tantalum Mitsui Mining & Smelting*
Tantalum Molycorp Silmet A.S.*
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum Plansee SE Liezen* Tantalum Plansee SE Reutte*
Tantalum QuantumClean* Tantalum Resind Indústria e Comércio Ltda.*
Tantalum RFH Tantalum Smeltry Co., Ltd* Tantalum Solikamsk Metal Works* Tantalum Taki Chemicals* Tantalum Telex*
Tantalum Tranzact, Inc.* Tantalum Ulba*
Tantalum XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum Zhuzhou Cement Carbide* Tin Alpha*

Tin An Vinh Joint Stock Mineral Processing Company**
Tin Chenzhou Yunxiang Mining Smelting Company LTD**
Tin China Tin Group Co., Ltd.*
Tin CNMC (Guangxi) PGMA Co. Ltd. Tin Cooper Santa*
Tin CV Ayi Jaya* Tin CV Gita Pesona* Tin CV JusTindo*
Tin CV Nurjanah*
Tin CV Serumpun Sebalai* 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. (Metallo Group)*
Tin EM Vinto*
Tin Estanho de Rondônia S.A.
Tin Fenix Metals*
Tin Gejiu Jin Ye Mineral Co., Ltd.**
Tin Gejiu Kai Meng Industry and Trade LLC**
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin Gejiu Zi-Li Tin Huichang Jinshunda Tin Co. Ltd
Tin Jiangxi Ketai Advanced Material Co., Ltd.*
Tin Jiangxi Nanshan Tin Linwu Xianggui Ore Smelting 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. (MC)*
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 Phoenix Metal Ltd.**
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 BilliTin Makmur Lestari*
Tin PT Bukit Timah*
Tin PT Cipta Persada Mulia*
Tin PT DS Jaya Abadi*
Tin PT DS Jaya Abadi**
Tin PT Eunindo Usaha Mandiri*
Tin PT Inti Stania Prima*
Tin PT Karimun Mining**
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 Tambang Timah*
Tin PT Timah (Persero) Tbk Mentok*
Tin PT Tinindo Inter Nusa*
Tin PT Tirus Putra Mandiri 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, Ltd.* Tungsten A.L.M.T. Corp.*

Tungsten Asia Tungsten Products Vietnam Ltd.*
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.*
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten Ganzhou Yatai Tungsten 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 Chenzhou Mining Group Co., Ltd.*
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* Tungsten Hydrometallurg, JSC*
Tungsten Japan New Metals Co Ltd*
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals 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 Wolfram Company CJSC Tungsten Xiamen Tungsten (H.C.) Co., Ltd.* Tungsten Xiamen Tungsten Co., Ltd*
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.*

Country of Origin List 3
Angola France Portugal Argentina Germany Republic of Congo Australia Guyana Russia Austria Hungary Rwanda Belgium India Sierra Leone Bolivia Indonesia Singapore Brazil Ireland Slovakia Burundi Israel South Africa Cambodia Japan South Korea Canada Kazakhstan South Sudan Central African Republic Kenya Spain Chile Laos Suriname China Luxembourg Switzerland Colombia Madagascar Taiwan Côte D'Ivoire Malaysia Tanzania Czech Republic Mongolia Thailand Democratic Republic of Congo Mozambique Uganda Djibouti Myanmar United Kingdom Ecuador Namibia United States of America Egypt Netherlands Vietnam Estonia Nigeria Zambia Ethiopia Peru Zimbabwe

3 The CFSI generally does not specify individual countries of origin of the conflict minerals processed by compliant smelters and refiners and thus we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed compliant smelters and refiners. In addition, for some of the listed compliant smelters and refiners, origin information is not disclosed. The list is based on the country of origin data provided to the CFSI for compliant smelters only.

Advanced Semiconductor Engineering, Inc. Conflict Minerals Report 2015

Section 1 — Conflict Minerals Disclosure

Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

Our Form SD and our Conflict Minerals Report for the year ended December 31, 2015 filed as Exhibit 1.01 to this Form SD are available at http://www.aseglobal.com/en/Csr/SupplyChainDevelopment.asp

Section 2 – Exhibits
Item 2.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015

SIGNATURE

Advanced Semiconductor Engineering, Inc.

By:
/s/ Jason C.S. Chang
Jason C.S. Chang
Chief Executive Officer

Date: May 31,2016

EXHIBIT INDEX

Exhibit                                                         Description

Number

1.01              Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015

Exhibit 1.01

Advanced Semiconductor Engineering, Inc.

Conflict Minerals Report

For the year ended December 31, 2015

Corporate Overview and Product Scope


Advanced Semiconductor Engineering, Inc. (“ASE”, “we”, “our”, “us”) is among the leading providers of semiconductor packaging and testing services based on 2015 revenues. Our services include semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten which are necessary to deliver our packaging, materials and electronic manufacturing services.

We have manufacturing facilities located in Taiwan, China, Malaysia, Japan, Singapore, Korea and the United States that provide packaging, testing and materials services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services to the wafers, and delivering a completed, packaged integrated circuit back to the customer. In the performance of packaging and materials services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten and tantalum. We do not use gold, tin, tungsten or tantalum in our testing services.

Since our acquisition of a controlling interest in Universal Scientific Industrial Co., Ltd. in February 2010, we provide a broad range of electronic manufacturing services to a global customer base. We have manufacturing facilities located in Taiwan, China and Mexico that provide electronic manufacturing services. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products. Typical materials and components which we utilize include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.


All packaging and materials services and electronic manufacturing services we provide contain one or more of the conflict minerals: gold, tin, tungsten or tantalum.

Reasonable Country of Origin Inquiry (RCOI)

For our packaging and materials services, we purchase gold, tin, tungsten and tantalum from 116 suppliers. Each of these 116 suppliers has supplied us with the information required in a Conflict Minerals Reporting Template (CMRT) authored by the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative, or EICC-GeSI, with an accounting of their conflict mineral Smelters or Refiners (SoRs). Each of these 116 suppliers is in receipt of our conflict minerals policy, and each has confirmed their understanding of its principles and their willingness to comply.

For our electronic manufacturing services, we performed an assessment of all 1,316 suppliers who provided us with gold, tin, tungsten or tantalum in 2015 and selected 262 suppliers for our 2015 Conflict Minerals Report based on (1) suppliers from whom we purchased greater than USD $6 million in purchase volume (which collectively accounted for 95% of our total purchase volume) and (2) suppliers whose conflict minerals are used in the services we provide to our top three customers.


Below are the results of our Reasonable Country of Origin Inquiry, or RCOI.

Gold – Packaging and Materials Services

1. During 2015, we purchased gold for our packaging and materials services from a total of 51 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on data we collected, we identified a total of 122 SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services. All 51 of our gold suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced gold during 2015, representing 100% of our total expenditure for gold during 2015 for our packaging and materials services.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 95 of the SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services are participants in at least one of (i) the Conflict-Free Smelter Program (CFSP) operated by the Conflict-Free Sourcing Initiative (CFSI), (ii) the Gold Industry— London Bullion Market Association (LBMA), or (iii) the Gold Industry— Responsible Jewellery Council (RJC).


3. The following table summarizes our RCOI results for gold purchased for our packaging and materials services in 2015.

Gold – Electronic Manufacturing Services

1. During 2015, we purchased gold for our electronic manufacturing services from a total of 182 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on data we collected, we identified 132 SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services. One-hundred eighty of our gold suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced gold during 2015. Two did not respond.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 97 of the SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services are participants in at least one of (i) the CFSP operated by the CFSI, (ii) the LBMA, or (iii) the RJC.

3. The following table summarizes our RCOI results for gold purchased for our electronic manufacturing services in 2015.

Tin – Packaging and Materials Services

1. During 2015, we purchased tin for our packaging and materials services from a total of 63 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified a total of 82 SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services. All 63 of our tin suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tin during 2015, representing 100% of our total expenditure for tin during 2015 for our packaging and materials services.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 66 of the SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI.

3. The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015.

Tin – Electronic Manufacturing Services

1. During 2015, we purchased tin for our electronic manufacturing services from a total of 212 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified 96 SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015. Two-hundred ten of our tin suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tin during 2015. Two did not respond.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 68 of the SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI.

3. The following table summarizes our RCOI results for tin purchased for our electronic manufacturing services in 2015.

Tungsten – Packaging and Materials Services

1. During 2015, we purchased tungsten for our packaging and materials services from a total of 4 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from a SoR or another third party. Based on data we collected, we identified 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015. Our 4 tungsten suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tungsten during 2015, representing 100% of our total expenditure for tungsten for our packaging and materials services during 2015.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, the 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015 are participants in the CFSP operated by CFSI or participants in the Tungsten Industry—Conflict Minerals Council, or TI-CMC.

3. The following table summarizes our RCOI results for tungsten purchased for our packaging and materials services in 2015.

Tungsten – Electronic Manufacturing Services

1. During 2015, we purchased tungsten for our electronic manufacturing services from a total of 119 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from SoRs or from other third parties. Based on data we collected, we identified 45 SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015. One hundred seventeen of our tungsten suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tungsten during 2015. Two did not reply.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 41 of the SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015 are participants in either the CFSP operated by the CFSI or the TI-CMC program.

3. The following table summarizes our RCOI results for tungsten purchased for our electronic manufacturing services in 2015.

Tantalum – Packaging and Materials Services

1. During 2015, we purchased tantalum for our packaging and materials services from a total of 2 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on data we collected, we identified a total of 2 SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services. All 2 of our tantalum suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tantalum during 2015, representing 100% of our total expenditure for tantalum during 2015 for our packaging and materials services.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 2 of the SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI.

3. The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015.

Tantalum – Electronic Manufacturing Services

1. During 2015, we purchased tantalum for our electronic manufacturing services from a total of 89 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the data collected, we identified 49 SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015. Eighty-seven of our tantalum suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tantalum during 2015. Two did not reply.

2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 47 of the SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI.

3. The following table summarizes our RCOI results for tantalum purchased for our electronic manufacturing services in 2015.

Part I. Due Diligence

Design of Due Diligence

ASE designed its due diligence measures to conform to 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: Second Edition, including the related supplements on tantalum, tin, tungsten, and gold.

Due Diligence Measures Performed

OECD Step 1
Establish strong company management systems

A. Adopt and clearly communicate to suppliers and public

The ASE Group Corporate Policy for Sourcing Conflict Minerals is posted on our website (and attached here as Annex A) as well as distributed to each of our suppliers of conflict minerals who must agree in writing that the policy will be complied with.
Additionally, we require each supplier to certify they understand our conflict minerals policy and will comply with its covenants.
Finally, every factory manager must certify they comply with our conflict minerals policy. They are also responsible for communicating the policy throughout their organizations and implementing procedures to ensure compliance.

B. Structure internal management to support due diligence

Our conflict minerals management team is a comprehensive cross-functional team under the direction of our Chief Operating Officer. The team provides planning, analysis, management, tracking, monitoring and communication for the business wide initiative. They hold regular and frequent meetings to ensure progress against requirements.

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

Conflict minerals procedures are documented in our specifications system and managed by our quality control organization. The bills-of-materials required for different customer products across all manufacturing operations are controlled by our manufacturing execution system software.
The primary method for gathering conflict mineral data is through the deployment and gathering of Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Templates (CMRTs). We store this data on a comprehensive filing system and maintain other related records for a minimum of five years.
Aligned with industry practice, we designed a conflict minerals data tool with simple functions that manages large number of supplier CMRTs, auto-validates smelter status with real-time CFSI smelter list and aggregates smelter reporting for our customers.

D. Strengthen company engagement with suppliers

In addition to formal written documentation, ASE is building person-to-person links between employees and suppliers to improve the quality and consistency of vendor communications.
We held an annual supplier seminar to announce new requirements, and provided training to suppliers to enable them to better understand how to set up their conflict minerals monitoring mechanism and to improve smelter data quality.
We amended and added conflict minerals terms to our ASE Group Purchase Order pursuant to which our suppliers agree (i) to use industry standard efforts to ensure that gold, tantalum, tungsten and tin in materials covered by the purchase order and sourced from mines in the Democratic Republic of the Congo or its adjacent regions do not directly or indirectly finance illegal militia in the Democratic Republic of the Congo or its adjacent regions, (ii) to promptly notify us if any materials covered by the purchase order do contain conflict minerals that are not DRC Conflict Free and to provide a report on the mine and/or smelter of origin of the conflict minerals and the related chain of custody and (iii) to only supply us with materials that contain DRC Conflict Free minerals sourced from certified DRC Conflict Free smelter and refinery programs.

E. Establish grievance mechanism

ASE encourages suppliers and employees to have open and honest dialog on issues of mutual interest.
We provide two email addresses (ASE_CM@aseglobal.com and conflictminerals@ms.usi.com.tw) for general surveys, inquiries and grievances regarding our conflict minerals program.

OECD Step 2
Identify and assess risk in the supply chain

A. Identify risks in the supply chain

Our process for identifying conflict minerals risk in the supply chain is as follows:
(a) Identify all direct materials and components in the supply chain that contain conflict minerals.
(b) Identify suppliers of materials and components that contain conflict minerals.
(c) Gather CMRTs from our suppliers of conflict minerals.
(d) Depending on the enormity and complexity of the supply chain:
 Assess the value of the annual purchase volume of all conflict minerals.
 Prioritize conflict mineral sources by dollar volume to leverage impact from available analytical resources.

B. Assess risks of adverse impacts

(a) Assess data gathered on templates to identify potential inconsistencies or “red flags.”
(b) Define annual supplier risk criteria.
(c) Carry out on-site or document audit for suppliers determined as at-risk suppliers according to the risk criteria.
(d) Follow up as appropriate to resolve items of concern.

OECD Step 3
Design and implement a strategy to respond to identified risks

A. Report finding to designated senior management

Periodic reviews are held among team members and with senior management to ensure they are aware of current conflict minerals compliance status.

B. Devise and adopt a risk management plan

In 2015, we compared supplier smelter data to CFSI RCOI data (when available) to identify actual smelter origins.
We used a corporate standard conflict minerals audit checklist and implemented an on-site or document audit process to validate suppliers’ mechanisms related to important aspects of conflict minerals management.

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

Our packaging and materials services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.
(b) For compliance year 2015, we received CMRTs from 100% of our conflict mineral suppliers.

Our electronic manufacturing services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.
(b) For compliance year 2015, our electronic manufacturing services identified 262 suppliers that accounted for 95% of our total purchase volume and whose conflict minerals are used in the services we provide to our top 3 customers; we received CMRTs from 99.2% of these conflict mineral suppliers.

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

We have begun supplier audits to assess the accuracy of data and statements made by larger suppliers. This program will be broadened over time.
As a member (code: ASEG) of the EICC and CFSI, RCOI data is accessible to use and to manage our supplier smelter data.

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

For CY 2015, ASE has undertaken an Independent Private Sector Audit (IPSA) of our Conflict Minerals Report in compliance with the requirements set forth in the SEC Conflict Minerals Final Rule and subsequent SEC Guidance.
In addition, as a member of CFSI, we leverage the due diligence conducted on smelters by the CFSP which uses independent third-party auditors to audit the source of the conflict minerals used by smelters.

OECD Step 5
Report on supply chain due diligence.

ASE filed a Form SD and Conflict Minerals Report for Compliance Year 2015 with the US Securities and Exchange Commission on or before the May 31, 2016 deadline in compliance with the SEC Conflict Minerals Final Rule and subsequent guidance.

Part II. Due Diligence Determination and Product Declaration

Product Declaration

Our RCOI results did not provide us a sufficient level of confidence to enable us to report that all our products are conflict-free. Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, we therefore conducted additional due diligence on the source and chain of custody of the necessary conflict minerals in our products in order to obtain reasonable and reliable evidence that the gold, tin, tungsten or tantalum used by us in 2015 either (i) did not directly or indirectly benefit violent organizations in the Democratic Republic of the Congo or adjacent regions or (ii) came from recycled or scrap sources.

Based on our RCOI analysis and due diligence measures described in this report, we made the following product determinations.
Packaging and Materials Services:
We reasonably believe that the identified SoRs used in all our packaging and materials services products are DRC Conflict-Free.
Electronic Manufacturing Services:
We reasonably believe that the identified SoRs used in our System in Module and System in Package products are DRC Conflict-Free. And all other products from our electronic manufacturing services are DRC Conflict Undeterminable.

Glossary
A glossary of abbreviations and terms is included in Annex C.

Facilities used to Process Conflict Minerals
A list of Smelters and Refiners that sourced conflict minerals utilized in our services is provided in Annex D.

Conflict Minerals Country of Origin
A list of countries where conflict minerals were mined or extracted is listed in Annex E. These minerals may have been smelted or refined in the country of extraction or in facilities around the world.

Part III – Future Due Diligence Improvements

 Set conflict minerals requirements for new suppliers. Beginning from 2016, we have required new suppliers to first agree to submit a CMRT and a representation letter confirming that they are in compliance with ASE’s conflict minerals policy and requirements.
 Work with tier 1 suppliers to ensure that smelters are actively participating or progressing toward CFSP listing or other Third Party Audit Programs.
 Assess suppliers’ due diligence processes through on-site audits so as to assist suppliers to build up and improve their internal management systems.
 Enhance our conflict minerals data tool with advanced management and analysis functionalities.
 Annually hold supplier seminars to assist suppliers with their conflict minerals programs.

Part IV – Independent Private Sector Audit

We obtained an independent private sector audit by KPMG. This report is set forth in Annex B.

Annex A – ASE Group Corporate Policy for Sourcing Conflict Minerals

The mining and distribution of “conflict minerals”1 originating from the Democratic Republic of the Congo are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Group is dedicated to the elimination of these conflict minerals in our supply chain, and to use only conflict-free minerals2 responsibly sourced around the world. It is also our objective to support the continued use of conflict-free minerals from the DRC and the adjacent regions such that responsible mining is not diminished.

All suppliers to ASE Group must support this policy by:
(a) Being diligent in their assessment and validation of their supply chains to ensure ASE Group’s objectives of a transparent supply chain and conflict-free purchases are inputs to the services and products we produce.
(b) Be in compliance at all times with all regional and international regulations for conflict minerals.
(c) Be in compliance at all times with industry standards for the sourcing and reporting of conflict minerals.
(d) Being diligent and accurate in their formal assurances of conflict-free minerals provided to us.

Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in the Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934.
Conflict-free minerals are conflict minerals that through their distribution directly or indirectly do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions.

Annex B –Independent Accountants’ Report

Independent Accountants’ Report

To the Board of Directors and Shareholders of Advanced Semiconductor Engineering Inc.:

We have examined:

• whether the design of Advanced Semiconductor Engineering Inc. (the “Company”) due diligence framework as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2015 (the “Conflict Minerals Report”), is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”), and

• whether the Company’s description of the due diligence measures it performed, as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook.

Management from the Company is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.

Our examination was not conducted for the purpose of evaluating:
 The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance;
 The completeness of the Company’s description of the due diligence measures performed;
 The suitability of the design or operating effectiveness of the Company’s due diligence process;
 Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance;
 The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or
 The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the section titled “Part I. Due Diligence.”

In our opinion,

• the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2015, as set forth in the Company’s Conflict Minerals Report, is in conformity, in all material respects, with the OECD Due Diligence Guidance, and
• the Company’s description of the due diligence measures it performed for the reporting period from January 1 to December 31, 2015 as set forth in its Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook.

/s/ KPMG

Taipei, Taiwan (the Republic of China)

May 31, 2016

Annex C – Glossary

Smelter List and Country of Origin List

Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)

Gold Advanced Chemical Company **
Gold Aida Chemical Industries Co. Ltd.*
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Almalyk Mining and Metallurgical Complex (AMMC)**
Gold AngloGold Ashanti Córrego do Sítio Minerção*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
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 Caridad Gold CCR Refinery – Glencore Canada Corporation*
Gold Cendres + Métaux SA**
Gold Chimet S.p.A.*
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.**
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Eco-System Recycling Co., Ltd.*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
Gold Fidelity Printers and Refiners Ltd.
Gold FSE Novosibirsk Refinery*
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation**
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Heraeus Precious Metals GmbH & Co. KG*
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Ishifuku Metal Industry Co., Ltd.*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Jiangxi Copper Company Limited*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold JSC Uralectromed*
Gold JX Nippon Mining & Metals Co., Ltd*
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd*
Gold Kennecott Utah Copper LLC*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited 
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Gold Luoyang Zijin Yinhui Gold Refinery 
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies (Hong Kong) Ltd*
Gold Metalor Technologies (Singapore) Pte. Ltd.*
Gold Metalor Technologies (Suzhou) Ltd.**
Gold Metalor Technologies SA*
Gold Metalor USA Refining Corporation*
Gold Mitsubishi Materials Corporation*
Gold Mitsui Mining and Smelting Co., Ltd.*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant*
Gold Gold Navoi Mining and Metallurgical Combinat**
Gold Nihon Material Co. LTD*
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold Ohio Precious Metals, LLC*
Gold Ohura Precious Metal Industry Co., Ltd*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Penglai Penggang Gold Industry Co., Ltd. 
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PT Aneka Tambang (Persero) Tbk*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Republic Metals Corporation*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold SEMPSA Joyería Platería SA*
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold Sichuan Tianze Precious Metals Co., Ltd.*
Gold Singway Technology Co., Ltd.*
Gold So Accurate Group, Inc.
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 Tongling nonferrous Metals Group Co.,Ltd
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Umicore Precious Metals Thailand*
Gold Umicore SA Business Unit Precious Metals Refining*
Gold United Precious Metal Refining, Inc.*
Gold Valcambi SA*
Gold Western Australian Mint trading as The Perth Mint*
Gold WIELAND Edelmetalle GmbH**
Gold YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold Yokohama Metal Co Ltd*
Gold Yunnan Copper Industry Co Ltd
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold Zijin Mining Group Co. Ltd*

Tantalum Changsha South
Tantalum Niobium Co., Ltd.*
Tantalum Conghua Tantalum and Niobium Smeltry*
Tantalum D Block Metals, LLC*
Tantalum Duoluoshan*
Tantalum Exotech Inc.*
Tantalum F&X Electro-Materials Ltd.*
Tantalum FIR Metals & Resource Ltd.*
Tantalum Global Advanced Metals Boyertown*
Tantalum Global Advanced Metals*
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* Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum Jiujiang Tanbre Co., Ltd.*
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum KEMET Blue Metals*
Tantalum Kemet Blue Powder*
Tantalum King-Tan Tantalum Industry Ltd* Tantalum LSM Brasil S.A.* Tantalum Metallurgical Products India (Pvt.) Ltd.*
Tantalum Mineração Taboca S.A.*
Tantalum Mitsui Mining & Smelting*
Tantalum Molycorp Silmet A.S.*
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum Plansee SE Liezen* Tantalum Plansee SE Reutte*
Tantalum QuantumClean* Tantalum Resind Indústria e Comércio Ltda.*
Tantalum RFH Tantalum Smeltry Co., Ltd* Tantalum Solikamsk Metal Works* Tantalum Taki Chemicals* Tantalum Telex*
Tantalum Tranzact, Inc.* Tantalum Ulba*
Tantalum XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum Zhuzhou Cement Carbide* Tin Alpha*

Tin An Vinh Joint Stock Mineral Processing Company**
Tin Chenzhou Yunxiang Mining Smelting Company LTD**
Tin China Tin Group Co., Ltd.*
Tin CNMC (Guangxi) PGMA Co. Ltd. Tin Cooper Santa*
Tin CV Ayi Jaya* Tin CV Gita Pesona* Tin CV JusTindo*
Tin CV Nurjanah*
Tin CV Serumpun Sebalai* 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. (Metallo Group)*
Tin EM Vinto*
Tin Estanho de Rondônia S.A.
Tin Fenix Metals*
Tin Gejiu Jin Ye Mineral Co., Ltd.**
Tin Gejiu Kai Meng Industry and Trade LLC**
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin Gejiu Zi-Li Tin Huichang Jinshunda Tin Co. Ltd
Tin Jiangxi Ketai Advanced Material Co., Ltd.*
Tin Jiangxi Nanshan Tin Linwu Xianggui Ore Smelting 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. (MC)*
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 Phoenix Metal Ltd.**
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 BilliTin Makmur Lestari*
Tin PT Bukit Timah*
Tin PT Cipta Persada Mulia*
Tin PT DS Jaya Abadi*
Tin PT DS Jaya Abadi**
Tin PT Eunindo Usaha Mandiri*
Tin PT Inti Stania Prima*
Tin PT Karimun Mining**
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 Tambang Timah*
Tin PT Timah (Persero) Tbk Mentok*
Tin PT Tinindo Inter Nusa*
Tin PT Tirus Putra Mandiri 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, Ltd.* Tungsten A.L.M.T. Corp.*

Tungsten Asia Tungsten Products Vietnam Ltd.*
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.*
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten Ganzhou Yatai Tungsten 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 Chenzhou Mining Group Co., Ltd.*
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* Tungsten Hydrometallurg, JSC*
Tungsten Japan New Metals Co Ltd*
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals 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 Wolfram Company CJSC Tungsten Xiamen Tungsten (H.C.) Co., Ltd.* Tungsten Xiamen Tungsten Co., Ltd*
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.*


Annex E – Countries of Origin of Conflict Minerals
It is likely that we used conflict minerals from many of the following sources as well as some that are not identified.

Angola
Argentina
Australia
Austria
Belgium
Bolivia
Brazil
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Côte D'Ivoire
Czech Republic
Democratic Republic of the Congo
Djibouti
Ecuador
Egypt
Estonia
Ethiopia
France
Germany
Guyana
Hungary
India
Indonesia
Ireland
Israel
Japan
Kazakhstan
Kenya
Laos
Luxembourg
Madagascar
Malaysia
Mongolia
Mozambique
Myanmar
Namibia
Netherlands
Nigeria
Peru
Portugal
Republic of Congo
Russia
Rwanda
Sierra Leone
Singapore
Slovakia
South Africa
South Korea
South Sudan
Spain
Suriname
Switzerland
Taiwan
Tanzania
Thailand
Uganda
United Kingdom
United States of America
Vietnam
Zambia
Zimbabwe

MICROSOFT CORPORATION CONFLICT MINERALS REPORT 2015

MICROSOFT CORPORATION

CONFLICT MINERALS REPORT

FOR THE REPORTING PERIOD FROM

JANUARY 1 TO DECEMBER 31, 2015

I. INTRODUCTION

This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1 to December 31, 2015 (“2015 reporting year”). The report covers activities of all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule (“Microsoft”). The Rule imposes certain due diligence and reporting obligations on US Securities and Exchange Commission (“SEC”) registrants whose manufactured products (including products contracted to be made for each registrant) contain “conflict minerals” necessary to the functionality or production of those products. The Rule defines “conflict minerals” to include cassiterite, columbite-tantalite, gold, wolframite and their derivatives limited to tin, tantalum, tungsten, and gold (collectively referred to as “3TGs”).

Microsoft develops and markets software, services, and hardware devices that deliver new opportunities, greater convenience, and enhanced value to people’s lives. Microsoft is committed to the responsible sourcing of raw materials globally in support of human rights, labor, health and safety, environmental protection, and business ethics. Our commitment and strategy are outlined in the Microsoft Responsible Sourcing of Raw Materials policy. Under our policy, Microsoft takes a holistic approach to responsible sourcing while working toward the use of conflict-free minerals in our hardware devices (“devices”). One of our objectives is to ensure that we do not harm communities through an inadvertent de facto embargo of minerals from the Democratic Republic of the Congo (“DRC”) or an adjoining country (defined as a country that shares an internationally recognized border with the DRC) - both considered a “Covered Country” for purposes of the Rule.

This year’s report documents our efforts for the 2015 reporting year, which demonstrate meaningful progress. The number of Conflict-Free Smelter Program1 (“CFSP”)-compliant smelters or refiners (the “SORs”) in our supply chain increased from 148 to 213 due to targeted supplier outreach and maturation of the CFSP - of which Microsoft is a founding partner and strong supporter. Based on Microsoft’s data analysis, we also concluded that 100 percent of tantalum smelters identified in Microsoft’s supply chain were CFSP compliant.

Since the 2014 reporting year (January 1 to December 31, 2014), we have also taken several notable actions to improve our conflict minerals due diligence, including the following:
 Completed implementation of recommendations from third party audit firm covering 2014 reporting year external assessment;

Please note: this CMR contains references and hyper-text links to non-Microsoft, external websites. These links are provided for informational purposes only. Their inclusion in this CMR does not establish Microsoft’s endorsement of or assumption of liability for content posted on these external websites.

 Implemented process improvements to increase supplier response rate, including extensive sourcing manager involvement, supplier resource support, and tailored outreach to both new suppliers and 2014 unresponsive suppliers;

 Developed and refined internal controls and procedures to improve in-scope supplier determination, data collection and validation, and supply chain due diligence, including early engagement with suppliers upon initial on-boarding through Microsoft’s Social and Environmental Accountability (“SEA”) online Audit Management System; and

 Enhanced our supplier data collection process such as addition of automated “red flags” to identify quality control issues and Covered Country sourcing risk early in the surveying process.

Microsoft devices contain one or more 3TGs and are within the Rule’s scope. Devices manufactured during the 2015 reporting year included:

 Surface line of tablet and laptop computers and accessories;
 Xbox gaming/entertainment consoles and accessories;
 Personal computing accessories, including mice and keyboards;
 Mobile devices, including Nokia and Lumia branded mobile phones and devices;
 Surface Hub computing displays; and
 Microsoft Band wellness devices.

On the basis of our performance of the required “Reasonable Country of Origin Inquiry” (“RCOI”) (see Section II), we cannot exclude the possibility that some of the 3TGs contained in our devices may have originated in a Covered Country. Therefore, we are submitting this CMR, which describes the conflict minerals due diligence we performed, as an exhibit to our Form SD.

We are submitting this CMR to the SEC under the reporting requirements of the Rule and have published the CMR externally on our corporate website: see Responsible Sourcing. The manufacture of devices during any specified time period may include raw materials sourced before, as well as during, that time period. In particular, some 3TGs used during the 2015 reporting year may have been smelted and refined prior to January 31, 2013 and are exempt under the Rule because they were outside the supply chain prior to the Rule’s initial reporting period. While such 3TGs are excluded from the Rule’s scope, our RCOI and supply chain due diligence conducted for the 2015 reporting year may have included such minerals.

II. REASONABLE COUNTRY OF ORIGIN INQUIRY

Our RCOI corresponds to the first and second steps of the five-step OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”), as that Guidance (including its Supplements) applies to each of the 3TGs and to Microsoft as a “downstream company.” The OECD Guidance provides a framework for detailed due diligence to support responsible global supply chain management of minerals, including 3TGs, and is currently the only nationally or internationally recognized framework for conflict minerals due diligence.

Microsoft does not contract with raw material providers in preparation for manufacturing our devices and does not source 3TGs directly. We source products from suppliers, which, in turn, source materials, components, and products from their suppliers (“sub-tier suppliers”). Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG SORs. Our contracts require all Microsoft supplier partners to identify, by weight, each and every substance contained in the materials, components, and products supplied to us, including 3TGs. We refer collectively in this CMR to our own manufacturing facilities, contracted manufacturing partners, and our strategic component suppliers as “in-scope suppliers.” Due to our extended supply chain, we leverage our in-scope suppliers, which provide us with information concerning the sources and chains of custody of 3TGs necessary to the functionality or production of our devices. We provide more detail on our supply chain due diligence process in Section III. The graphic below demonstrates Microsoft’s span of influence with its suppliers.

A. Establish Strong Company Management Systems

1. Company Policies

Microsoft’s Responsible Sourcing of Raw Materials policy describes our commitment and strategy to responsibly source raw materials used in our devices. Microsoft is committed to the sourcing of raw materials in a way that supports human rights, labor, health and safety, environment, and ethics. Consistent with this mission, we address the issues associated with the harvesting, extraction, and transportation of raw materials as a global responsibility applicable to all substances used in our devices - unbounded by specific materials or locations. This policy also states that we implement programs that are region-specific, such as working toward the use of conflict-free minerals in our devices. We expect our suppliers to support our commitment to the responsible sourcing of raw materials.

Microsoft’s policies also include Microsoft’s Global Human Rights Statement; our Supplier Code of Conduct, which defines our expectations concerning ethical business, employment, environmental, and worker safety practices; and our internal Standards of Business Conduct, which outlines expected behaviors for all Microsoft employees. Microsoft uses supplier specifications and internal procedures to establish supplier commitments for the responsible sourcing of raw materials, including 3TGs. We incorporate these requirements into our hardware and packaging contracts.

2. Internal Management Team

A cross-functional team (“team”) supports Microsoft’s responsible sourcing activities, including compliance activities associated with the Rule. The Corporate Vice President of Microsoft’s Manufacturing and Supply Chain organization is the executive sponsor of the team. Representatives from various Microsoft corporate groups are involved in the development, review and filing of the CMR. Corporate groups represented on the team include Sourcing, Social and Environmental Accountability, Manufacturing, Accounting/Finance, Internal Audit, Windows and Devices Group, Corporate, External and Legal Affairs, Business and Corporate Responsibility, Information Services, and Product Environmental Compliance.

This team meets according to Microsoft’s internal Responsible Sourcing Program Manual and, at a minimum, quarterly to assess the progress of our program and identify steps that are necessary to meet our compliance obligations. The team also trains other internal stakeholders on their roles and responsibilities for implementing and supporting Microsoft’s responsible sourcing program.

3. System of Supply Chain Controls and Transparency

We require our in-scope suppliers to fully disclose all substances and materials that are present in the devices or components they supply to us by component and weight. These material disclosure requirements explicitly cover 3TGs. Our in-scope suppliers are responsible for communicating these 3TG sourcing requirements and specifications to their sub-tier suppliers. Data obtained from our in-scope suppliers, therefore, includes 3TG information obtained from their sub-tier suppliers.

In addition, we require all in-scope suppliers to submit a Conflict Minerals Reporting Template (“CMRT”) annually. These CMRTs are evaluated for completeness, data integrity, due diligence thoroughness, and sourcing risk. Potential risks may include, but are not limited to, failure to fully complete the CMRT, inconsistencies in the CMRT, and possible sourcing from a Covered Country. If data gaps or risks are identified, Microsoft investigates each issue and engages with those suppliers to address all concerns in conformance to Microsoft policies, procedures and specifications..

In cases where the supplier still poses risk, Microsoft initiates supplier corrective action calibrated to the severity of the identified risk. H02050 - Microsoft Supplier Social and Environmental Accountability Manual and Microsoft internal operating procedures establish controls for documenting supplier engagement, supplier response, and corrective action for any non-conformance findings.

If we confirm that a supplier’s upstream SOR is using raw materials that do not comply with Microsoft’s Responsible Sourcing of Raw Materials policy or the specifications referenced in this CMR, Microsoft initiates actions to address the non-conformance. These actions may include supplier engagement, training, and/or additional audits. Microsoft works with impacted suppliers to find alternate sources for non-compliant minerals. If a supplier does not commit to an alternate source within a reasonable time period, Microsoft places the supplier on restricted status with no new Microsoft business awarded until any non-conformance is resolved. Termination of Microsoft’s business relationship with the supplier may also occur.

Microsoft is a longstanding member of the Global e-Sustainability Initiative (“GeSI”) and the Electronics Industry Citizenship Coalition (“EICC”) - two organizations that initiated the Conflict-Free Sourcing Initiative (“CFSI”). Founded in 2008 by GeSI and EICC members, the CFSI is one of the most utilized and respected resources for addressing supply chain conflict minerals issues. The CFSI, through its CFSP, uses an independent third-party audit to verify SORs that demonstrate that the 3TGs, which they process, do not originate from sources that may be directly or indirectly financing or benefitting armed groups in a Covered Country. Microsoft funded an early adopters program that provided initial audit funds, enabling more SORs to be CFSP audited. Microsoft also provides financial support to the Industrial Technology Research Institute’s Tin Supply Chain Initiative (“iTSCi”) that has established a system of traceability and due diligence in Covered Countries and we support the efforts of organizations, including the Public-Private Alliance for Minerals Trade (“PPA”), that promote responsible mining and raw material sourcing. Microsoft is a sponsor of the Multi-Stakeholder Group, hosted by the Responsible Sourcing Network, which coordinates efforts to promote security and stability in the DRC region by engaging governments to bring an end to the conflict in the DRC.

Microsoft works to positively impact end-to-end mining sustainability, from artisanal mines to larger mining enterprises. Through this work, we aspire to improve conditions directly at the source across a broad scope of issues in partnership with the electronics industry, the mining industry, and other not-for-profit partners. In particular, Microsoft believes that it can improve practices associated with the mining of metal ores at their source through participation in collaborative initiatives related to the upstream mining industry. Microsoft supports and participates in numerous additional partnerships that work to establish responsible mining standards and the responsible sourcing of minerals, including the following:
 Initiative for Responsible Mining Assurance ("IRMA"): established a multi-stakeholder and independently verifiable responsible mining assurance system that improves social and environmental performance;
 Pact: empowers small and medium sized miners to achieve legal, safe and secure livelihoods; and
 Alliance for Responsible Mining ("ARM"): sets standards for responsible artisanal and small scale mining and supports and creates opportunities for gold miners and provides them incentives to become responsible economic, technological and environmental enterprises.

4. Supplier Engagement

In light of our corporate size, the complexity of our devices, and the depth, breadth, and constant evolution of our supply chain; we rely on our in-scope suppliers to provide us with information concerning the source and chain of custody of 3TGs contained in the products and components they supply to us. Many of our in-scope suppliers are also subject to the Rule, and they rely on information provided by their upstream suppliers to meet their compliance obligations. We drive responsible sourcing through our extended supply chain by surveying our in-scope suppliers’ sourcing of raw materials in their upstream supply chains. We also use tools that include supplier and smelter capability building and support broader industry efforts to promote responsible mining and sourcing. Finally, we conduct audits of our contracted suppliers to verify conformance to Microsoft requirements. More information is set forth below.

 Supplier Requirements: We require our in-scope suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications that we communicate, monitor, and track electronically to ensure conformance. These policies and procedures are outlined in Section III. We also train our directly contracted suppliers to meet our requirements through training sessions, educational forums, and direct communications.

 Capability Building and Partnerships: We work closely with our supply chain partners to build the raw material supplier capabilities for achieving our responsible sourcing goals. We invest in industry programs, such as the CFSP, to increase suppliers’ capabilities and provide them with platforms to share best practices with each other.

 Supplier Audits: Microsoft conducts audits of its contracted suppliers to assess their conformance to Microsoft requirements, including supply chain transparency. All new contracted hardware and packaging suppliers undergo an initial capability assessment to verify conformance to Microsoft requirements. Microsoft requires that suppliers have a policy and effective procedures to establish and monitor their responsible sourcing of raw materials. Microsoft selects and retains only those business partners that commit to meeting these requirements. A failure by a supplier or any sub-tier supplier to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft. During the 2015 reporting year, Microsoft-engaged auditors conducted onsite audits of 129 contracted hardware and packaging suppliers to assess areas of SEA conformance, including whether the suppliers had an established conflict minerals policy, systems in place to implement that policy, and documentation to verify conformance to Microsoft responsible sourcing requirements.

CFSI’s “Practical Guidance for Downstream Companies” document states that “all of the [OECD Guidance’s] red flag triggers are contained in the upstream portion of the supply chain.” Because these conflict mineral supply chain “triggers” are directed to upstream companies, rather than downstream manufacturers, such as Microsoft, we mitigate risks associated with the sourcing of 3TGs by working with our in-scope suppliers to identify 3TG SORs and encourage those facilities to become CFSP compliant or, failing to do so, use an alternate facility that is CFSP compliant. We also participate in industry-wide initiatives, such as the CFSP, that assess SOR compliance with the OECD Guidance as recommended by CFSI guidance documents. We require our in-scope suppliers to actively work with their upstream suppliers to mitigate risks associated with their sourcing of 3TGs.

5. Grievance Mechanism

Microsoft’s Global Human Rights Statement expresses our commitment to provide an anonymous grievance reporting mechanism for our employees and other stakeholders who may be impacted by our operations. Microsoft’s Business Conduct Hotline provides that mechanism, which allows employees and others to ask compliance questions or report concerns regarding Microsoft’s business operations, including its mineral sourcing policies or those of its suppliers. We investigate and, where appropriate, take remedial action to address reported incidents. We also participate in industry efforts to develop specific grievance mechanisms for conflict minerals-related issues, including PPA’s efforts to establish an in-region hotline.

B. Identify and Assess Risk in the Supply Chain

We took the following steps to identify and assess supplier conflict mineral sourcing risk in connection with 2015 reporting year data:
 Using the Rule and SEC guidance, we generated a list of potential in-scope suppliers to receive Microsoft’s annual CMRT survey.
 We surveyed all potential in-scope suppliers to determine the status of any 3TGs contained in devices manufactured during the 2015 reporting year by utilizing the CFSI-standard CMRT and the services of a third party solution provider. The survey included questions regarding a supplier’s responsible sourcing policies, its practices for engaging with its upstream suppliers, a request to list all SORs from which its 3TGs were sourced, and other detailed questions concerning the origins of 3TGs contained in the supplier’s products as well as its 3TG due diligence policies and procedures.
 The survey followed the OECD Guidance as tailored for Microsoft’s role as a downstream company. We reviewed all supplier CMRT submissions to validate that they were complete and to identify any contradictions or inconsistencies. We worked with our third-party solution provider to secure updated responses from suppliers, as needed.
 We identified 276 active and in-scope suppliers for reporting year 2015. Of the 276 active and in-scope suppliers surveyed, we received responses from 267. This resulted in a 97% response rate - an improvement from the 2014 reporting year rate of 82% and the 2013 reporting year rate of 71% as shown in Figure 1.

III. DUE DILIGENCE DESIGN AND PERFORMANCE

On the basis of our RCOI, we determined that 3TGs contained in our devices may have originated in one or more Covered Country. Accordingly, we designed and performed due diligence on the source and chain-of-custody of those 3TGs.

A. Due Diligence Design

Our 3TG due diligence process conforms to the third and fourth steps of the five-step OECD Guidance. The first and second steps of the five-step OECD Guidance were addressed in Section II.

B. Due Diligence Performed
1. Design and Implement a Strategy to Respond to Risks

Microsoft requires its suppliers to take affirmative actions to minimize the possible sourcing of 3TGs from conflict-affected and high-risk areas. This is required through contracts with our suppliers and supplier specifications.

a. Microsoft Supplier Specifications - H00594 and HO0642

Microsoft’s supplier specification H00594, Restricted Substances for Hardware Products (“H00594”), requires 100 percent identification of all materials, including 3TG, used in all packaging and hardware products and parts supplied to Microsoft on a component-by-component level. Specifically, H00594 requires contracted suppliers to do the following:
 Post a responsible sourcing policy, conforming to the OECD Guidance, on their website;
 Exercise due diligence on the source and chain of custody of any 3TG contained in materials, components, or products they supply to Microsoft;
 Identify, by name, each SOR that has processed or otherwise handled 3TGs contained in those materials, components, or products;
 Encourage those SORs to participate in the CFSP or an equivalent third-party conflict-free audit scheme, when available;
 Confirm that 3TGs in their supply chain are sourced from SORs that are compliant with the CFSP or an equivalent independent private sector audit firm, when available; and
 Notify Microsoft immediately if they obtain information or knowledge that the minerals used in the materials, components, or products that they supply to Microsoft may contain 3TGs sourced from a Covered Country.

H00594 requires Microsoft suppliers to impose these same requirements on their sub-tier suppliers and to provide appropriate training and support to help their sub-tier suppliers meet Microsoft responsible sourcing requirements. To facilitate this process, H00642, Restricted Substances Control System for Hardware Products. requires Microsoft suppliers to utilize the common CMRT provided by the CFSI and found at www.conflictfreesourcing.org. Suppliers are responsible for submitting the annual CMRT as well as updating the CMRT upon request or when changes occur.

b. Responsible Sourcing Program Manual Processes to Implement OECD Guidance

To respond to possible conflict mineral risks that were identified during our due diligence process, Microsoft implemented responsible sourcing practices, to communicate with suppliers that may be sourcing 3TGs under conditions that may be directly or indirectly financing or benefitting armed groups in a Covered Country. Under our Responsible Sourcing of Raw Materials Program, we use the OECD Guidance to review supplier CMRT data and identify potential red flags for the sourcing of 3TGs, including the following:
 The minerals originated from or were transported via a conflict-affected or high-risk area;
 The minerals were claimed to originate from a country that has limited known reserves for the mineral in question;
 The minerals were claimed to originate from a country in which minerals from conflict-affected and high-risk areas are known to transit;
 The company’s suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals or operate in one of the red flag locations of mineral origin and transit; and
 The company’s suppliers’ or other known upstream companies were known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months.

Microsoft’s program includes an escalation process that may require an in-scope supplier to find an alternative to a non-CFSP compliant source of 3TGs for use in materials, components, or products supplied to Microsoft or risk termination as a Microsoft supplier. To date, we have not encountered a responsible sourcing issue with a supplier that has warranted contract termination.

Also, as required by Microsoft’s internal Responsible Sourcing Program Manual, our team assessed the progress of our conflict minerals program and identified steps necessary to meet our compliance obligations. The team also provided monthly program status updates, including metrics and audit results, to Microsoft’s Corporate Vice President of Manufacturing and Supply Chain organization. We utilized supplier survey updates, supplier communications, supplier social and environmental accountability audits, and new supplier briefings to prevent the introduction of any new 3TG sourcing risk to our supply chain. We also leveraged meetings with executives to report findings and receive program guidance.

c. Industry and NGO Partner Engagement

Microsoft participated in, or has been a member of, several industry-wide responsible mining and smelting initiatives, including CFSI, PPA, ITRI’s iTSCi program, IRMA, Pact, and ARM. As part of our due diligence, we also conducted smelter outreach on behalf of the CFSI Smelter Engagement Team.

2. Carried Out Independent Third-Party Audit of Supply Chain Due Diligence

As contemplated by the OECD Guidance, our due diligence program leveraged independent SOR audits, which were undertaken in accordance with the CFSP and other similar programs. Microsoft obtained SOR data from the CFSP Compliant Smelter List through our membership in the CFSI using the Reasonable Country of Origin Inquiry Data for member MSFT. This data was used to support certain statements contained in this CMR. The CFSP Compliant Smelter List is a published list of SORs that have undergone assessment through the CFSP or industry equivalent program (such as Responsible Jewellery Council or London Bullion Market Association (“LBMA”)). Microsoft also participated in CFSI’s Smelter Engagement Team during the 2015 reporting year and we engaged a third party to assist smelters prepare for CFSP audits.

3. Reported on Supply Chain Due Diligence

Microsoft’s Responsible Sourcing of Raw Materials policy and other responsible sourcing documents are available on our external website. We have filed our CMR, required by the Rule, with the SEC and we have posted it on our external Responsible Sourcing website. These disclosures meet the fifth step of the five-step OECD Guidance.

IV. SOR INFORMATION

A. 3TG Processing Facilities

Microsoft has made a reasonable good faith effort to collect and evaluate information concerning 3TG SORs based on data provided by our in-scope suppliers. The vast majority of our in-scope suppliers provided data at a company or divisional level or otherwise were unable to identify specific entities that had processed 3TGs contained in the materials, components, or products supplied to us. This was expected given the multiple tiers of supply chain actors that are positioned between our in-scope suppliers and 3TG SORs.

Our supplier survey data revealed 19,568 potential 3TG SORs in the Microsoft supply chain. We validated the data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and eliminating otherwise invalid SOR names. This process reduced the list to 688 entities. Of this list, 226 SORs were unknown to CFSI (but are being investigated by CFSI members) and another 160 SORs were confirmed as misidentified and/or were not actual SORs. After removing those entities, 302 SORs remained.

The Figures below provide a visual depiction of the SORs identified in Microsoft’s supply chain by CFSP audit status. Figure 2 categorizes the SORs by audit status and reporting year. Figure 3 categorizes the SORs by 3TG mineral and audit status.

Appendix A to this CMR lists the 302 SORs which, to the extent known, processed 3TGs in Microsoft devices during the 2015 reporting year. Appendix A provides each SOR’s country location, 3TG processed, and CFSP audit status. Appendix A includes several gold SORs which have received the LBMA Responsible Gold Certificate - these are marked with an asterisk.

Table 1 (below) summarizes the conflict mineral status of the 302 SORs that were identified in the Microsoft supply chain.

CFSI defines each audit stage in the following manner:
 Compliant: SOR has been audited and found to be compliant with the relevant audit protocols;
 Active: SOR has been engaged but is not yet compliant;
 In Communication: SOR is not yet active but is in communication with CFSP and/or member company;
 Outreach Required: SOR is not yet active and outreach is needed by CFSI member companies to encourage SOR participation in CFSP; and
 TI-CMC Member Company: SOR is a member of the Tungsten Industry – Conflict Mineral Council (“TI-CMC”) and has agreed to undergo an audit within 2 years of joining TI-CMC.

B. 3TG Countries of Origin

Countries of origin for the 3TGs that were identified by our CFSP-compliant SORs include: Argentina, Angola, Australia, Austria, Belgium, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe. Other countries of origin identified through additional due diligence included: Armenia, Belarus, Ghana, Guinea, Hong Kong, Italy, Jersey, Kyrgyzstan, Mali, Mexico, Morocco, Niger, Papua New Guinea, Philippines, Poland, Saudi Arabia, Sweden, Tajikistan, Turkey, United Arab Emirates, and Uzbekistan.

Figure 8 provides a graphical presentation of the countries of origin for 3TGs that were identified as being used in the Microsoft supply chain during the 2015 reporting year. Although Covered Countries are listed in Microsoft’s countries of origin list, the SORs located in those countries are CFSP-compliant, verifying that they have been determined by CFSP to source 3TGs in a manner that does not directly or indirectly finance or benefit armed groups in a Covered Country. At this time, we have country-of-origin information for CFSP-compliant SORs and countries identified through additional due diligence.

For the identified conflict-free SORs for which minerals sourcing information is available from CFSI4:
 55% process recycled or scrap material.
 75% are not sourcing from Covered Countries.
 38 SORs are sourcing from Covered Countries but are CFSP compliant.

C. 3TG Mines or Locations of Origin

Microsoft obtained Reasonable Country of Origin data through our membership in the CFSI using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin of SORs identified in Microsoft’s supply chain. Microsoft supports the continued refinement and expansion of the list of participating SORs in the CFSP audit program through our membership in CFSI, which oversees the CFSP. We encourage SORs to participate in the CFSP by contacting all non-compliant SORs identified in our supply chain each reporting year. We also require all of our suppliers that reported non-compliant SORs to conduct outreach to those SORs and encourage them to join the CFSP. In addition, we have encouraged other SORs to participate in the CFSP by contacting SORs directly and by engaging in outreach events to encourage greater CFSP participation. We funded a third party to help educate SORs and prepare the SORs for the audit process. We have also offered to visit SORs to facilitate their participation in the CFSP.

These numbers include metrics on indirect sourcing that were not included in the 2014 reporting year report as they were made available for the first time this year by CFSI.

V. IMPROVEMENTS

Microsoft’s key 2015 reporting year accomplishments and improvements are detailed below. Although comparisons to the 2014 reporting year data are of limited utility due to supply chain year-to-year variances in the data pool, this year’s report, which documents our efforts to expand the number of verified conflict-free SORs in our supply chain, demonstrates meaningful progress, including the following improvements:
 Increased the number of CFSP-compliant SORs identified through our due diligence from 148 to 213 due to enhanced supplier outreach, and maturation of CFSI’s CFSP;
 Increased supplier response rate from 71% in 2013 and 82% in 2014 to 97% in the 2015 reporting year;
 Developed early risk identification mechanisms with third party solution provider;
 Strengthened supplier corrective action process to drive and improve supplier due diligence;
 Developed new internal operational controls to standardize responsible sourcing, scoping determination, data collection, data validation and reporting;
 Initiated external review of Microsoft’s conflict minerals program by a third-party audit firm to assess alignment with OECD Guidance and implemented audit recommendations; and
 Enhanced engagement with external organizations, such as Pact, ARM and IRMA that are committed to advancing responsible sourcing on a global basis by developing mining standards and addressing issues such as child labor in the mining industry.

VI. FUTURE ACTIONS

Microsoft is committed to the sourcing of raw materials in ways that fundamentally support human rights, labor, health and safety, environmental protection, and business ethics in our supply chain. We will continue to improve our ability to identify, assess, and mitigate risks associated with our raw materials sourcing. We will continue to implement our Responsible Sourcing of Raw Materials policy that includes a combination of building cross-industry sector capability, supporting electronics industry efforts, implementing region-specific programs such as working toward the use of conflict-free minerals in our devices and working with in-region expert NGOs that are able to implement community programs that are linguistically and culturally effective. Encouraging SORs to participate in the CFSP will improve our knowledge about the 3TGs in our raw material supply chain and we will continue to encourage CFSP participation.

Microsoft is aware of concerns that have been raised regarding the Rule’s possible unintended negative consequences for local communities. Microsoft is committed to complying with the OECD Guidance and the Rule in such a way that mitigates such concerns through implementation of our Responsible Sourcing of Raw Materials program, which is a holistic program that extends beyond the geographic limitations and the scope of the Rule. Consistent with our commitments, we intend to take the following steps to continuously improve our responsible sourcing of raw materials due diligence efforts:
 Continue to refine and improve internal procedures and processes to enhance alignment with the OECD Guidance, including Microsoft’s supplier escalation process and supplier audit procedures;
 Increase Microsoft’s level of engagement with suppliers by holding supplier forums, webinars, and providing resources;
 Continue to refine supplier data by conducting outreach where reported data is incomplete or uncertain;
 Enhance our usage of software tools and technology for improved tracking, evaluating and storing of supplier 3TG due diligence data;
 Strengthen engagement with relevant industry groups and external stakeholders to define and improve best practices and build supplier and SOR capabilities (including encouraging SORs to become CSFP compliant);
 Continue active participation in the CFSI Smelter Engagement Team, which seeks to bring non-compliant SORs into the CFSP; and
 Continue our engagement with organizations like IRMA, ARM, and Pact to establish global responsible sourcing standards and programs in the mineral supply chain

APPENDIX A

Conflict Mineral Status of Identified SORs1

This Appendix lists the 302 SORs which, to the extent known, processed 3TGs that were used to manufacture Microsoft devices during the 2015 reporting year. The SORs are listed by their audit status, 3TG processed, and country location. Appendix A includes several gold SORs which have received the LBMA Responsible Gold Certificate - these are marked with an asterisk.

Smelter List and Country of Origin List

Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)

Gold Advanced Chemical Company **
Gold Aida Chemical Industries Co. Ltd.*
Gold Al Etihad Gold Refinery DMCC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Almalyk Mining and Metallurgical Complex (AMMC)**
Gold AngloGold Ashanti Córrego do Sítio Minerção*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
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 Caridad Gold CCR Refinery – Glencore Canada Corporation*
Gold Cendres + Métaux SA**
Gold Chimet S.p.A.*
Gold Chugai Mining
Gold Daejin Indus Co., Ltd.**
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Eco-System Recycling Co., Ltd.*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
Gold Fidelity Printers and Refiners Ltd.
Gold FSE Novosibirsk Refinery*
Gold Gansu Seemine Material Hi-Tech Co., Ltd.
Gold Geib Refining Corporation**
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Heraeus Precious Metals GmbH & Co. KG*
Gold Hunan Chenzhou Mining Group Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Ishifuku Metal Industry Co., Ltd.*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Jiangxi Copper Company Limited*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold JSC Uralectromed*
Gold JX Nippon Mining & Metals Co., Ltd*
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd*
Gold Kennecott Utah Copper LLC*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Gold Company Limited 
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Gold Luoyang Zijin Yinhui Gold Refinery 
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies (Hong Kong) Ltd*
Gold Metalor Technologies (Singapore) Pte. Ltd.*
Gold Metalor Technologies (Suzhou) Ltd.**
Gold Metalor Technologies SA*
Gold Metalor USA Refining Corporation*
Gold Mitsubishi Materials Corporation*
Gold Mitsui Mining and Smelting Co., Ltd.*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Moscow Special Alloys Processing Plant*
Gold Gold Navoi Mining and Metallurgical Combinat**
Gold Nihon Material Co. LTD*
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold Ohio Precious Metals, LLC*
Gold Ohura Precious Metal Industry Co., Ltd*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Penglai Penggang Gold Industry Co., Ltd. 
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PT Aneka Tambang (Persero) Tbk*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Republic Metals Corporation*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold SEMPSA Joyería Platería SA*
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold Sichuan Tianze Precious Metals Co., Ltd.*
Gold Singway Technology Co., Ltd.*
Gold So Accurate Group, Inc.
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 Tongling nonferrous Metals Group Co.,Ltd
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Umicore Precious Metals Thailand*
Gold Umicore SA Business Unit Precious Metals Refining*
Gold United Precious Metal Refining, Inc.*
Gold Valcambi SA*
Gold Western Australian Mint trading as The Perth Mint*
Gold WIELAND Edelmetalle GmbH**
Gold YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold Yokohama Metal Co Ltd*
Gold Yunnan Copper Industry Co Ltd
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold Zijin Mining Group Co. Ltd*

Tantalum Changsha South
Tantalum Niobium Co., Ltd.*
Tantalum Conghua Tantalum and Niobium Smeltry*
Tantalum D Block Metals, LLC*
Tantalum Duoluoshan*
Tantalum Exotech Inc.*
Tantalum F&X Electro-Materials Ltd.*
Tantalum FIR Metals & Resource Ltd.*
Tantalum Global Advanced Metals Boyertown*
Tantalum Global Advanced Metals*
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* Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum Jiujiang Tanbre Co., Ltd.*
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum KEMET Blue Metals*
Tantalum Kemet Blue Powder*
Tantalum King-Tan Tantalum Industry Ltd* Tantalum LSM Brasil S.A.* Tantalum Metallurgical Products India (Pvt.) Ltd.*
Tantalum Mineração Taboca S.A.*
Tantalum Mitsui Mining & Smelting*
Tantalum Molycorp Silmet A.S.*
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum Plansee SE Liezen* Tantalum Plansee SE Reutte*
Tantalum QuantumClean* Tantalum Resind Indústria e Comércio Ltda.*
Tantalum RFH Tantalum Smeltry Co., Ltd* Tantalum Solikamsk Metal Works* Tantalum Taki Chemicals* Tantalum Telex*
Tantalum Tranzact, Inc.* Tantalum Ulba*
Tantalum XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum Zhuzhou Cement Carbide* Tin Alpha*

Tin An Vinh Joint Stock Mineral Processing Company**
Tin Chenzhou Yunxiang Mining Smelting Company LTD**
Tin China Tin Group Co., Ltd.*
Tin CNMC (Guangxi) PGMA Co. Ltd. Tin Cooper Santa*
Tin CV Ayi Jaya* Tin CV Gita Pesona* Tin CV JusTindo*
Tin CV Nurjanah*
Tin CV Serumpun Sebalai* 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. (Metallo Group)*
Tin EM Vinto*
Tin Estanho de Rondônia S.A.
Tin Fenix Metals*
Tin Gejiu Jin Ye Mineral Co., Ltd.**
Tin Gejiu Kai Meng Industry and Trade LLC**
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin Gejiu Zi-Li Tin Huichang Jinshunda Tin Co. Ltd
Tin Jiangxi Ketai Advanced Material Co., Ltd.*
Tin Jiangxi Nanshan Tin Linwu Xianggui Ore Smelting 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. (MC)*
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 Phoenix Metal Ltd.**
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 BilliTin Makmur Lestari*
Tin PT Bukit Timah*
Tin PT Cipta Persada Mulia*
Tin PT DS Jaya Abadi*
Tin PT DS Jaya Abadi**
Tin PT Eunindo Usaha Mandiri*
Tin PT Inti Stania Prima*
Tin PT Karimun Mining**
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 Tambang Timah*
Tin PT Timah (Persero) Tbk Mentok*
Tin PT Tinindo Inter Nusa*
Tin PT Tirus Putra Mandiri 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, Ltd.* Tungsten A.L.M.T. Corp.*

Tungsten Asia Tungsten Products Vietnam Ltd.*
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten Dayu Weiliang Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.*
Tungsten Ganxian Shirui New Material Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten Ganzhou Yatai Tungsten 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 Chenzhou Mining Group Co., Ltd.*
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.* Tungsten Hydrometallurg, JSC*
Tungsten Japan New Metals Co Ltd*
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals 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 Wolfram Company CJSC Tungsten Xiamen Tungsten (H.C.) Co., Ltd.* Tungsten Xiamen Tungsten Co., Ltd*
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.*

Country of Origin List 3
Angola France Portugal Argentina Germany Republic of Congo Australia Guyana Russia Austria Hungary Rwanda Belgium India Sierra Leone Bolivia Indonesia Singapore Brazil Ireland Slovakia Burundi Israel South Africa Cambodia Japan South Korea Canada Kazakhstan South Sudan Central African Republic Kenya Spain Chile Laos Suriname China Luxembourg Switzerland Colombia Madagascar Taiwan Côte D'Ivoire Malaysia Tanzania Czech Republic Mongolia Thailand Democratic Republic of Congo Mozambique Uganda Djibouti Myanmar United Kingdom Ecuador Namibia United States of America Egypt Netherlands Vietnam Estonia Nigeria Zambia Ethiopia Peru Zimbabwe

3 The CFSI generally does not specify individual countries of origin of the conflict minerals processed by compliant smelters and refiners and thus we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed compliant smelters and refiners. In addition, for some of the listed compliant smelters and refiners, origin information is not disclosed. The list is based on the country of origin data provided to the CFSI for compliant smelters only.