Section 1- Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
A copy of Kornit's (the "Company") Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at:
http://www.kornit.com/?catid=%7BD01663BB-DA36-4DFF-AEA3-B082E5A1DE35%7D#oht:lang=en-us
Section 2- Exhibits
Exhibit 1.01 - Conflict Minerals Report is attached per Section 1.
Signature
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.
Guy Avidan
(Registrant)
By: Guy Avidan
Chief Financial Officer
*Source: Securities and Exchange Commission 17 CFR Parts 240 and 249b (SEC final rule)
www.sec.gov/rules/final/2012/34-67716.pdf
Pages 344-348
**Print name and title of the registrant’s signing executive officer1 under his or her signature.
GENERAL INSTRUCTIONS as per the SEC rule provisions
Appendix B – Conflict Minerals Report (CMR) Template
Conflict Minerals Report of COMPANY
Introduction
Kornit Digital develops, manufactures and markets industrial and commercial printing solutions for the garment, apparel and textile industries. Leading the digital textile printing industry with our revolutionary NeoPigmentTM process including an integrated pretreatment solution, Kornit Digital caters directly to the needs of both designers and manufacturers.
Founded in 2002 by seasoned professionals with extensive experience in the digital printing industry, we are the only company to provide our customers with a complete digital printing solution, from start to finish. We insist that customers should enjoy the best of the best – software, support and high-end technology, all in an environmentally sustainable way.
Based on our proprietary ground-breaking technology and our in-house chemistry development, Kornit Digital introduces the Kornit line of high-speed DTG printers, known to be the first industrial digital printers offering direct to garment printing. With our immense experience in the direct to garment market, we are revolutionizing the roll fabric industry with our single step solution that enables printing with one ink set on all types of fabric and with no additional finishing process.
Our product portfolio consists of two series of systems and the consumables used in those systems. These series are the DTG printers and the Roll to Roll printer. Collectively, this portfolio offers a variety of performance options for our customers, depending on their desired application, as well as on the nature and size of the designs. Our wide range of systems allows us to offer our customers systems at a number of different price points, depending on the features that our customers desire.
As an issuer that offers products that include tin, tungsten, tantalum and gold (“Conflict Minerals”) necessary in our manufactured products, we are subject to Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Section 1502 reporting requirements associated with Conflict Minerals, and the SEC’s Rule 13p-1.
Rule overview and scope:
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict minerals” are defined as cassiterite, columbite- tantalite, gold,wolframite, and their derivatives, which are limited to tin, tantalum, tungsten and gold for the purpose of this assessment.
If a registrant can establish that the conflict minerals in its products originated from sources other than the Democratic Republic of the Congo (DRC) or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, the registrant must submit a specialized disclosure report under Form SD that describes the steps that the registrant took to determine the origin of the conflict minerals in its products.
If a registrant has reason to believe that any of the conflict minerals in its supply chain may have originated in a Covered Country, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures
Reasonable Country of Origin Inquiry (RCOI)
Kornit is committed to ethical practices and compliance with all applicable laws and regulations. We are committed to working with our customers and suppliers to responsibly source the materials and components we use in manufacturing our customers’ products which may contain these minerals.
In accordance with our Conflict Minerals Policy, which can be download from: http://www.kornit.com/?catid={115F7A29-8FE5-4071-A6CC-ADE1CC448C7F}#oht:lang=en-us , Kornit has concluded in good faith that during the 2015 calendar year, we have manufactured and contracted to manufacture products containing all four Conflict Minerals and have determined that the use of these minerals is necessary to the functionality or production of these products.
We performed a reasonable country of origin inquiry (“RCOI”) simultaneously with the due diligence phase in which we engaged to determine whether the Conflict Minerals necessary to the functionality or production of our products were or were not “DRC conflict free.” This was done simultaneously due to the large number of applicable suppliers from which we source materials that we surveyed and the time frame in which we needed to complete both the RCOI and due diligence. Our RCOI employed several methods to assess whether the necessary Conflict Minerals in our products originated from the Democratic Republic of the Congo or a country that shares an internationally recognized border with the Democratic Republic of the Congo (collectively, “Covered Countries”). These measures consisted primarily of the following actions:
Internal assessments of our products to determine which contain or may contain necessary Conflict Minerals.
The following steps were performed to determine the applicable suppliers list:
a) A suppliers list, which Kornit Digital Ltd purchased from during the calendar year 2015, was issued using the ERP Priority system by the purchasing department manager. As part of our risk based approach we identified suppliers from which we purchased goods directly (“Tier 1 Suppliers”), as well as electronic manufacturers with whom our Tier 1 Suppliers contracted for in order to supply us the goods. In order to reduce the risk of not getting full information we have decided not to rely solely on our Tier 1 Suppliers to provide information on their entire supply chain, and to approach directly also the electronic manufacturers, even though we have not purchased from them directly. The total number of the suppliers and manufacturers in the list was 303. The list was then segmented according to the type of material the supplier provides. Some of the categories were excluded since they were not necessary to the functionality or production of the products. The final list included 137 suppliers and manufacturers related to the "Electronics" category. The CFSI reporting template was sent to the suppliers in this list in order to investigate the source of the conflict minerals in the products they provide. Currently Kornit's response rate is 60.6%
Since our supply chain include multiple tiers between our company and the relevant smelters and refineries, we rely on our direct suppliers and manufacturers to provide information on the origin of the conflict minerals contained in components which are included in our products.
b) Solicited survey responses using the Conflict Minerals Reporting Template (CMRT) version 4.01 designed by the Conflict Free Sourcing Initiative (CFSI). We engaged our supply chain to respond to the Conflict Minerals Reporting Template by referring suppliers to training materials that included an overview of the law and instructions on how to complete the Conflict Minerals Reporting Template.
c) Assessment of responses received for information that would identify as inconsistent, incomplete, or inaccurate responses. Responses that failed any of the “red flag” review tests were identified for additional follow up.
d) To non-responsive suppliers, we sent periodic reminders to provide surveys or updated responses.
Based on the RCOI conducted, Kornit has reason to believe that a portion of the Conflict Minerals necessary to the functionality of its products originated in the Democratic Republic of the Congo or an adjoining country and knows, or has reason to believe, that those necessary Conflict Minerals may not be from recycled or scrap sources. Based on this result, Kornit conducted due diligence activities and details these efforts in this Conflict Minerals Report.
Due Diligence
Design of Due Diligence
In accordance with Rule 13p-1 and Form SD, we undertook due diligence We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2013) (“OECD Framework”) and related supplements for Conflict Minerals.
The 5 steps defined in the OECD Due Diligence Guidance are: (1) establishment of strong internal company management systems; (2) identification and assessment of risks in the supply chain; (3) design and implementation of a strategy to respond to risks as they are identified; (4) carry out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) report annually on supply chain due diligence.
Due Diligence Performed
The due diligence measures we undertook consisted primarily of:
a. Established strong company management systems.
We reviewed and maintained the company management systems previously established through the following actions:
• Reviewed Kornit Conflict Minerals Policy, in order to assess whether any updates were required. As part of our policy Kornit strives to only use 3TG minerals from smelters that have been audited and verified as conflict free by the CFS Program and requires its suppliers to only source 3TG minerals from conflict-free smelters. The policy is available at: http://www.kornit.com/?catid={115F7A29-8FE5-4071-A6CC-ADE1CC448C7F}#oht:lang=en-us
• Established Conflict Minerals Governance Charter to set the Conflict Minerals annual work plan including: Kornit steps for compliance, objectives, time lines, internal management and cross functional team with identified roles and responsibilities, all to support supply chain due diligence.
• Established periodic meetings of the cross functional team, for the purpose of sharing best practices and monitoring our progress regarding the various steps required for compliance.
• Established a process whereby we engage with suppliers and refer them to training materials on line, which materials include an overview of relevant Conflict Minerals regulation and provide instructions on how to respond to the due diligence survey (which was based on the Conflict Minerals Reporting Template).
• Added a Conflict Minerals provision to our standard Terms and Conditions of Purchase to require suppliers to comply with our Conflict Minerals Policy and requirements.
• Established a process whereby we communicate the due diligence efforts to customers, suppliers and other relevant functions in our organization, as applicable.
• Established a grievance mechanism whereby concerns and violations of the Conflict Minerals Policy should be reported to Kornits’ Chief Financial Officer and/or Engineering Manager (at kornit@kornit.com).
• Established a records retention method in which all the relevant records are kept for a minimum of five years.
b. Identified and assessed risks in the supply chain
As part of our risk-based approach we have decided to focus on suppliers and electronics manufactures. We assessed two primary risks in our supply chain: (1) the risk of not receiving on time and accurate information from the supplier; and (2) the risk of not being able to replace a supplier while trying to move towards the goal of being a conflict free company.
As a result of this assessment, we segmented our suppliers into three risk levels (high, medium and low) In order to allow us to invest our risk management efforts according to the supplier level of risk, we have refered to Conflict Minerals-related risks based on suppliers characteristics, such as: the geographical location of the supplier or manufacturer, whether or not the supplier is a SEC registrant, volume of spending during 2015 and the extent to which the company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers.
As part of the risk assessment phase, we have identified that form the responses received, 88.0% of Kornit's level 1 suppliers and manufacturers list have policy in place which addresses the conflict minerals sourcing and 7.2% don’t contain conflict minerals in the products provided to Kornit.
We have identified, to the best of our efforts, the smelters/refiners in the supply chain by conducting a supply chain survey using the CMRT, requesting suppliers and manufactures to identify smelters and refiners and country of origin of the conflict minerals in products they supply to Kornit. In addition, Kornit compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict free" designation from the Conflict Free Smelter Program ("CFSP") or other independent third party audit program
c. Designed and implemented a strategy to respond to identified risks
The findings of the supply chain risk assessment are reported to designated members of our senior management. As part of our risk management strategy we are continuing the trade with the suppliers while Kornit continues with its efforts to investigate its supply chain.
Kornit contacts suppliers whose responses are identified as incomplete, inconsistent or inaccurate. Kornit also reviews supplier responses to track smelters and refiners in our supply chain that supply us with Conflict Minerals and have not received a conflict-free designation based on the Conflict Free Sourcing Initiative Conflict-Free Smelter Program or other independent third party validation program.
Kornit referred suppliers to training materials on line that included an overview of the law and instructions on how to complete the Conflict Minerals Reporting Template. We also sent follow up letters to high risk non-responsive suppliers, and to suppliers who declared the existence of Conflict Minerals in their supply chain from the DRC or adjoining countries from non-certified smelters.
Kornit's supply chain Due Diligence is a dynamic process and requires on-going risk monitoring. Therefore, after implementing our risk mitigation strategy, then Kornit goes back to Step 2 of the OECD guidelines to ensure effective management of risks.
d. Reviewed independent third-party audit of smelter/refiner due diligence practices
Kornit is a downstream company of necessary Conflict Minerals and is many steps removed from smelters and refiners who provide minerals and ores. Therefore, Kornit does not perform audits of smelters and refiners within the supply chain. As a result, Kornit’s due diligence efforts relied on reviewing cross-industry initiatives such as those led by the CFSI. to conduct smelter and refiner due diligence.
e. Prepared this annual report on supply chain due diligence
Kornit’ Conflict Mineral Policy states that we will comply with Section 1502 of the Dodd Frank Act which includes filing a Form SD and this Conflict Minerals report with the SEC and posting publicly on the Internet at:
http://www.kornit.com/?catid=%7BD01663BB-DA36-4DFF-AEA3-B082E5A1DE35%7D#oht:lang=en-us
Results of Assessment
We conducted a supply-chain survey of the 137 direct suppliers and manufacturers that we identified which may contribute necessary conflict minerals to our products. The overall response rate to this survey was approximately 60.6% containing the names and locations of smelters and refiners (see Annex 1) and country of origin see (Annex 2) which process Conflict Minerals.
Of this response rate:
X% suppliers delivered completed CMRT - 60.6% (83 from 137 suppliers)
X% suppliers were classified as “DRC conflict free” - 10.8% (9 from 83 suppliers)
X% suppliers were classified as “Free no 3TG” - 8.4% (7 from 83 suppliers)
X% suppliers were classified as “Undetermined not from DRC” - 6.1% (5 from 83 suppliers)
X% suppliers were classified as “Undetermined from DRC” - 69.9% (58 from 83 suppliers)
X% suppliers were classified as “Not from DRC” – 4.8% (4 from 83 suppliers)
We cannot be certain about our conclusions regarding the source and chain of custody of the necessary Conflict Minerals, as the information comes from direct and secondary suppliers and independent third party audit programs.
Despite suppliers indicating that they source from the Covered Countries, these suppliers were unable to accurately report which specific smelters/refiners were part of the supply chain of the components that were sold to Kornit in 2015. As a result of this lack of information, Kornit is unable to determine the full list of facilities used to process those necessary Conflict Minerals or their country of origin and to conclude whether or not the Conflict Minerals used in its products may have directly or indirectly financed armed groups in the Covered Countries. Kornit’ efforts to determine the mine(s) or location of origin included the use of the due diligence measures described above.
Smelters and refiners verified as conflict free or in the audit process:
Tin
72 of 93 (77.4%) – (59 compliant and 13 active smelters)
Tantalum
45 of 51(88.2%) – (45 compliant and 0 active smelters)
Tungstan
31 of 49 (63.3%) – (31 compliant and 0 active smelters)
Gold
96 of 133 (72.2%) – (81 compliant and 15 active smelters)
Total
244 of 326 (74.9%) – (216 compliant and 28 active smelters)
Status of identified smelters and refiners: 2015
Verified Conflict Free
216 (66.3%)
Participating in an audit process
28 (8.5%)
Not Participating
82 (25.2%)
Total
326 (100%)
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Kornit. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our conclusions.
These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, errors or omissions by or of suppliers, confusion over requirements of SEC final rules, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier unfamiliarity with the protocol, conflict area sourced materials being declared secondary materials, companies going out of business in 2015, and smuggling of conflict area Conflict Minerals to countries beyond the Covered Countries.
Information gathered from our suppliers is not on a continuous, real-time basis, but rather information gathered from suppliers’ information provided on the Conflict Mineral Reporting Template at that time. We cannot be certain about our conclusions regarding the source and chain of custody of the necessary Conflict Minerals, as the information comes from direct and secondary suppliers and independent third party audit programs.
Continuous improvement efforts to mitigate risk
Kornit continues to take, as applicable, the following steps to improve the due diligence process and mitigate the possibility that we are utilizing Conflict Minerals that benefit armed groups contributing to human rights violations:
• Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals, as required by Rule 13p-1.
• Work with suppliers that did not respond to Kornit’ 2015 survey to help them understand the importance of this initiative to Kornit and to encourage their participation in 2016.
• Attempt to validate supplier responses using information collected via independent, conflict-free smelter validation programs such as the Conflict Free Sourcing Initiative (CFSI) Conflict Free Smelter program to which we will provide financial support.
• Send follow up letters to high risk non-responsive suppliers, and to suppliers with Conflict Minerals from the Covered Countries from non-certified smelters.
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.
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