UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
SCHLUMBERGER N.V.
(SCHLUMBERGER LIMITED)
(Exact name of registrant as specified in its charter)
Saul R. Laureles
Deputy General Counsel
(713) 513-2000
(Name and telephone number, including area code, of the person to contact in connection with this report.)
SCHLUMBERGER LIMITED
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2015
Curaçao 1-4601 52-0684746 (State or other jurisdiction of (Commission (IRS Employer
incorporation or organization) File Number) Identification No.)
42, rue Saint-Dominique 75007
Paris, France
5599 San Felipe, 17th Floor 77056
Houston, Texas United States of America
62 Buckingham Gate SW1E 6AJ
London, United Kingdom
Parkstraat 83, The Hague, 2514 JG
The Netherlands (Zip Codes)
(Addresses of principal executive offices)
Deputy General Counsel
(713) 513-2000
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2015 to December 31, 2015.
Section 1 — Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
Conflict Minerals Disclosure
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Schlumberger Limited (the “Company”) has filed this Specialized Disclosure Report and the Conflict Minerals Report attached hereto as Exhibit 1.01 for the year ended December 31, 2015. Both of these documents are publicly available on the Company’s website at: http://www.slb.com/about/global_citizenship/conflict_minerals.aspx.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report.
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.
SCHLUMBERGER LIMITED
/s/ Alexander C. Juden
Alexander C. Juden
Secretary and General Counsel
Date: May 11, 2016
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2015
This Conflict Minerals Report (the “Report”) of Schlumberger Limited has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2015 to December 31, 2015.
All references in this Report to “Schlumberger,” “Company,” “we,” “us” or “our” are to Schlumberger Limited (Schlumberger N.V., incorporated in Curaçao) and its consolidated subsidiaries as of December 31, 2015.
Schlumberger is the world’s leading provider of technology for reservoir characterization, drilling, production, and processing to the oil and gas industry, and supplies the industry’s most comprehensive range of products and services, from exploration through production, and integrated pore-to-pipeline solutions that optimize hydrocarbon recovery to deliver reservoir performance.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which specified minerals are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“conflict minerals”).
Description of Products Covered by this Report
This Report relates to products sold: (a) that contain conflict minerals necessary to their functionality or production (“necessary conflict minerals”); (b) that we had reason to believe may have originated in the Democratic Republic of the Congo or an adjoining country (the “covered countries”) and may not have come from recycled or scrap sources; and (c) that we manufactured, or contracted to be manufactured, in 2015 (the “covered products”). The covered products, organized by Group, are as follows: Reservoir Characterization — permanent multiphase meters; subsea safety valves; oil, gas and core analysis laboratory equipment; seismic land acquisition systems; perforating hardware and accessories; Drilling — downhole drilling tools; solids and pressure control equipment for drilling fluids systems; data acquisition equipment for drilling operations; Production — surface and downhole completions tools; artificial lift pumps; stimulation pumping and cementing equipment; and groundwater monitoring products.
Due Diligence Design and Process
Our due diligence efforts were designed to conform in all material respects to the framework in the Organisation for Economic Co-operation and Development’s “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and related Supplements on Gold and on Tin, Tantalum and Tungsten (collectively, the “OECD Guidance”).
The following is a description of the measures that we took to exercise due diligence on the source and chain of custody of necessary conflict minerals contained in our covered products.
Step 1: Company Management Systems
Conflict Minerals Policy
We have adopted a policy relating to conflict minerals in our products (the “Conflict Minerals Policy”), incorporating relevant standards contained in the OECD Guidance, which is available at http://www.slb.com/about/global_citizenship/conflict_minerals.aspx. The Conflict Minerals Policy iterates our commitment to responsibly source materials from suppliers that share our values. It reflects our expectation that our immediate (“Tier 1”) suppliers will perform due diligence similar to ours on the sources of conflict minerals in their supply chains, and our expectation that they will require their own suppliers to do the same. It further provides generally that when a robust and validated conflict-free supply chain is established or a robust mineral tracing program is developed, we will expect our direct suppliers to procure only minerals using that validated supply chain, so as to avoid the use of minerals that have financed conflict in the covered countries.
Internal Management Teams
Members of our business, legal, engineering, procurement and sourcing, and information technology functions comprised a core team that was involved in various phases of compliance with the Rule. Members of this core team have put in place processes and controls reasonably designed to increase transparency in our conflict minerals supply chain. The core team formally reports to senior management on the progress of its compliance efforts throughout the Company and promotes consistency in interpretation of the Rule and industry practice and in implementation of our compliance efforts.
In 2013, we established a steering committee comprised of executive-level representatives of our procurement and sourcing, engineering, manufacturing and sustaining, and legal functions. The steering committee is responsible for implementing our conflict minerals compliance strategy; setting the general direction of our conflict minerals compliance efforts; and allocating sufficient resources in the cross-functional core team efforts. Senior management is briefed on the progress of our due diligence efforts on a periodic basis throughout the year. In addition, members of the core team presented to their respective business unit Presidents a final, formal review of: (a) their findings as to the source and status of the necessary conflict minerals contained in the covered products sold by their business unit; and (b) their unit’s due diligence efforts.
Control Systems
We have (a) adopted various processes related to our conflict minerals compliance efforts and determinations; (b) adopted standardized data templates for all business units to ensure consistency across various information technology systems, (c) adopted a procedure in our engineering design and manufacturing systems that requires the recording of necessary conflict mineral contents of newly-developed parts included in our products; (d) improved our electronic repository to retain relevant documentation concerning our conflict minerals compliance efforts and determinations; and (e) adopted written summaries, reviewed by the President of each relevant business unit, describing how each such business unit complied with the Rule and which of its products were subject to the Rule. In addition, certain employees from our legal, engineering, manufacturing, sustaining, procurement and sourcing, sales, finance and compliance functions are targeted for annual training and certification.
As we do not, except in very rare instances, have direct relationships with conflict mineral smelters and refiners (“SORs”), we engaged with others in our industry to compare and assess due diligence practices, identify SORs in our supply chains and formulate potential improvements in our ongoing due diligence efforts. We implemented a supply chain transparency system through the use of due diligence tools developed by the Conflict-Free Sourcing Initiative (“CFSI”), including the CFSI’s Conflict Minerals Reporting Template (the “Template”), which is designed to identify the SORs that process the conflict minerals in a company’s supply chain. We also support our suppliers’ use of validation, certification and audit programs on SORs upstream in our supply chain, such as those developed by CFSI; the ITRI Tin Supply Chain Initiative (“iTSCi”); Tungsten Industry – Conflict Mineral Council Framework (“ti-cmc”); the London Bullion Market Association (“LBMA”); and the Responsible Jewellery Council (“RJC”).
We also maintain a company-level grievance mechanism, as described in our Code of Conduct, that enables employees and others to anonymously report concerns, including any concerns regarding our conflict minerals supply chain. Throughout the year, we communicated this mechanism to our employees.
Step 2: Identification and Assessment of Supply Chain Risks
In order to identify and assess the risks in our supply chain, we first identified products for sale that we manufactured or contracted to manufacture in 2015 that contained, or that may contain, necessary conflict minerals. As stated above, we have adopted a procedure in our engineering design and manufacturing system that is reasonably designed to identify each necessary conflict mineral included in our products. We conducted extensive research on our existing parts, particularly those that we had not confirmed in 2014. In cases where we determined that a necessary conflict mineral was contained in one of our parts, we identified that specific mineral and flagged both the part and finished product containing that part in our system. If, after our initial research, we were unable to determine whether a necessary conflict mineral was included in a part, we considered that part to be in scope of the Rule and it was internally flagged for additional research. For new parts developed or manufactured in 2015, the engineers and métiers in charge of providing materials for such part were required to indicate any necessary conflict minerals included in the part. Where we determined that a newly-developed part contained a necessary conflict mineral and that the finished product was in scope of the Rule, we included that part in our further information gathering efforts. We then identified our Tier 1 suppliers that supplied us with the parts and products considered to be in scope of the Rule.
As a downstream company typically several tiers removed from mining operations and SORs, we must rely on our suppliers to provide information regarding the source and presence of necessary conflict minerals in our covered products. To that end, we engaged a third-party data collection and aggregation provider to assist us in conducting due diligence on our supply chain. Information was collected using the Template, which requested our Tier 1 suppliers to identify the SORs and countries of origin of the necessary conflict minerals they supplied to us and contained in our covered products, and to determine whether any such necessary conflict minerals came from recycled or scrap sources. In conducting due diligence, we prioritized responses from certain of our suppliers, as determined based on their strategic importance to us and our annual spend with such suppliers; we communicated this priority to our third-party data collection and aggregation provider in an effort to increase the response rate of these higher-risk suppliers.
Our supplier engagement began with introductory emails to relevant Tier 1 suppliers, notifying them that we would be conducting appropriate due diligence regarding the presence, source and chain of custody for any necessary conflict minerals that may be contained in parts or products that we purchased from them. The emails also described our conflict minerals compliance program and the Rule. In an effort to increase awareness of our conflict minerals program, we provided suppliers with background materials describing the conflict minerals rule, including frequently asked questions (FAQs) regarding, among other things, conflict minerals tracing. We requested product-level information from our Tier 1 suppliers on the parts and products we purchased from them. Suppliers were allowed to submit multiple responses as necessary to address all such parts and products. We analyzed all responses to determine their scope. As described further in the “Results of Supply Chain Due Diligence” section below, we received significantly more product-level responses for 2015 from our Tier 1 suppliers year-over-year. For 2014, a majority of our suppliers responded at the company level, whereas for 2015 a majority of our suppliers responded at the product level.
We pursued subsequent engagement with non-responsive suppliers, which included the following:
• we sent multiple email reminders requesting survey completion;
• suppliers who remained non-responsive after these email reminders were contacted by phone and offered assistance, including further information about the Rule, our conflict minerals program and clarification regarding how they could provide the required information; and
• if, following the above efforts, a supplier still did not provide the information requested, we further escalated the matter internally on a supplier risk priority basis and followed up directly with certain of these suppliers.
We reviewed and evaluated all supplier responses for consistency and completeness, both in terms of which products were said to contain or not contain necessary conflict minerals, as well as the origin of those materials. When necessary, we followed up with suppliers on responses to their reporting templates to seek clarifying or corrective information.
In instances where a supplier identified a SOR and the source of its conflict minerals, we sought to verify this information with third-party databases, internet searches, and reviews of government databases and industry/trade organization lists, including the list of known conflict minerals processing facilities worldwide published by the U.S. Department of Commerce. We also compared the SORs identified by suppliers in their responses to us against the list of compliant SORs published by CFSI’s Conflict-Free Smelter Program (the “CFSP”), the LBMA and the RJC. In some cases, a supplier identified a SOR and stated that its conflict minerals were not sourced from any of the covered countries. However, we were sometimes able to confirm, based on available information concerning the SOR identified, that the SOR was reported to source from one or more of the covered countries. In such cases, we communicated our findings to the supplier for further investigation. As a general matter, we requested that suppliers update their responses to us as more information became available to them.
Based on our review, we flagged certain responses when:
• SOR information was provided for a conflict mineral that was not used in the relevant part or product;
• SOR information was not provided for a conflict mineral that was used in a relevant part or product;
• SOR information provided could not be verified using the methods described above;
• a supplier indicated that it sourced conflict minerals from the covered countries, but none of the SORs listed were known to source from the region;
• a supplier indicated that it had not received conflict minerals data from all relevant suppliers;
• a supplier indicated that it had not identified all SORs from which it sourced conflict minerals for the relevant parts and products;
• a supplier indicated that it had not provided all applicable SOR information it received from its suppliers; or
• a supplier indicated that all of the conflict minerals for the relevant parts and products originated from scrap/recycled sources, but one or more of the SORs listed were not known to be exclusive recyclers.
We followed up on all flagged responses to clarify and address inconsistencies, incompleteness, invalid responses, uncertainties and responses indicating that relevant conflict minerals were or may have been sourced from one or more of the covered countries.
During 2015, we also led an energy industry effort to communicate directly with eight SORs that were not part of any certification program but that we confirmed were used by all members of our industry group. Because these SORs were not part of any certification program, it was not clear where the SORs sourced their minerals. All of the industry group participants signed a letter that was sent to these eight SORs requesting that they engage with a recognized certification body.
Step 3: Strategy to Respond to Identified Risks
For any SORs that were known to source necessary conflict minerals from any of the covered countries, we attempted to confirm that such SORs were listed in the various lists of compliant SORs described above. In addition, we sent a communication to our suppliers who sourced from such SORs, asking that they acknowledge the source of the relevant conflict minerals. We also included a copy of our Conflict Minerals Policy. Additionally, we reached out to our Tier 1 suppliers that we determined to have sourced from any of the covered countries, wherein we recommend such supplier join a group such as CFSI in order to obtain more up to date and accurate information regarding SORs and further to support the industry effort to achieve transparency.
As described in our Conflict Minerals Policy, in the event that we have reason to believe a supplier is supplying us with conflict minerals from sources that may support conflict in any of the covered countries, we will encourage that supplier to establish an alternative source of conflict minerals that does not support such conflict, or we may consider reevaluating the supplier relationship. If a Tier 1 supplier has been unresponsive or otherwise uncooperative in our due diligence efforts, we will also reevaluate that relationship. If a Tier 1 supplier is not compliant with our Conflict Minerals Policy and is unwilling to expect its own suppliers to use conflict-free sources, we may then also reassess the supplier relationship. As described above, we support the use of validation, certification and audit programs for SORs in our supply chain.
Our supplier engagement efforts described above in “Step 2: Identification and Assessment of Supply Chain Risks” also support our risk mitigation efforts.
Step 4: Independent Third-Party Audit of SORs’ Due Diligence Practices
As stated above, we are typically several tiers removed from mining operations and SORs, rendering transparency of our supply chain very difficult. Furthermore, except in rare instances, we do not have direct relationships with SORs and do not perform direct audits of the entities within our supply chain. Accordingly, we rely on our suppliers to provide the information necessary to assess compliance with our conflict minerals program and support the development and implementation of independent third party audits of SORs’ sourcing, such as the CFSP. For a Tier 1 supplier that we determined to have sourced from any of the covered countries, we recommend such supplier join a group such as the CFSI in order to obtain more up-to-date and accurate information regarding SORs and further to support the industry efforts to achieve transparency. In addition, as discussed above, during 2015, we led an energy industry effort to communicate directly with eight SORs that were not part of any certification program and requested that they engage with a recognized certification body.
We use a third party to aid in verifying the information supplied by our suppliers with respect to the SORs that they source from, and to review and confirm the validity of the CFSI, RJC and LBMA certifications of those SORs. In some cases, our third party reaches out directly to SORs as necessary to confirm the information either publicly available or made available in reporting template responses that may be contradictory or incomplete.
Step 5: Report on Supply Chain Due Diligence
As indicated in the Specialized Disclosure Report on Form SD, this Report is publicly available on our website at http://www.slb.com/about/global_citizenship/conflict_minerals.aspx. Our Conflict Minerals Policy also is available at http://www.slb.com/about/global_citizenship/conflict_minerals.aspx.
Results of Supply Chain Due Diligence
We sent the Template to 1,146 suppliers and received completed responses from approximately 58% of these suppliers. As part of our risk identification and mitigation efforts, we focused on obtaining responses from our top suppliers, based on strategic importance and annual spend. The following table lists the response rate and certain other information for our suppliers.
Many of the respondents indicated that they had not finished the due diligence on their supply chains and were still completing the Template. We requested a response at the product level; 69% of the completed declarations were at the product level, compared to only 2% in the previous year.
For the responses we received at the company level, we do not know whether the SORs listed actually supplied conflict minerals that we used in our covered products. Therefore, such SORs are not included in the tables below of the SORs that we know have processed the necessary conflict minerals contained in our covered products.
For responses at the product level, 367 SORs are included in the tables below. Based on our due diligence, we identified 30 verified SORs that source conflict minerals from one or more of the covered countries. Twenty eight of these SORs are certified with a recognized certification body. One tin SOR has a CFSI smelter identification number but is not, as of March 31, 2016, certified. One remaining tungsten SOR is not CFSP certified for tungsten, but is certified for tantalum.
Smelter List and Country of Origin List
Metal Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)
Gold Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold Argor-Heraeus SA*
Gold Asahi Pretec Corp*
Gold Asaka Riken Co Ltd*
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 Do Sung Corporation**
Gold Doduco*
Gold Dowa*
Gold Emirates Gold DMCC*
Gold Faggi Enrico S.p.A.**
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 Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold Heimerle + Meule GmbH*
Gold Heraeus Ltd. Hong Kong*
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold Istanbul Gold Refinery*
Gold Japan Mint*
Gold Johnson Matthey Inc*
Gold Johnson Matthey Ltd*
Gold JSC Uralectromed*
Gold Kazzinc Ltd*
Gold Gold Kojima Chemicals Co., Ltd*
Gold Korea Zinc Co. Ltd.**
Gold Kyrgyzaltyn JSC
Gold L' azurde Company For Jewelry
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold LS-NIKKO Copper Inc.*
Co., Ltd. Gold Materion*
Gold Matsuda Sangyo Co., Ltd.*
Gold Met-Mex Peñoles, S.A.*
Gold Metalor Technologies SA*
Gold MMTC-PAMP India Pvt., Ltd.*
Gold Morris and Watson
Gold Nihon Material Co. LTD*
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold PAMP SA*
Gold Prioksky Plant of Non-Ferrous Metals*
Gold PX Précinox SA*
Gold Rand Refinery (Pty) Ltd*
Gold Royal Canadian Mint*
Gold Sabin Metal Corp.
Gold Samduck Precious Metals**
Gold SAMWON METALS Corp.
Gold SAXONIA Edelmetalle GmbH**
Gold Schone Edelmetaal*
Gold Shandong Tiancheng Biological Gold Industrial 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 T.C.A S.p.A*
Gold Tokuriki Honten Co. Ltd*
Gold Torecom**
Gold Umicore Brasil Ltda*
Gold Valcambi SA*
Gold WIELAND Edelmetalle GmbH**
Gold Yokohama Metal Co Ltd*
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
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.*
Future Process Improvements
Integrate Cameron products and practices — On April 1, 2016, we acquired Cameron International Corporation (“Cameron”), a provider of flow equipment products, systems and services. We will integrate the Cameron products subject to the Rule into our conflict minerals program and systems and will review and evaluate Cameron’s processes and procedures to identify and implement synergies. We will flag the Cameron products in our various systems and incorporate them into our third-party data collection and reporting tool.
Supplier engagement — We received a response rate of 63% from our Tier 1 suppliers for 2015, as opposed to 46% for 2014. We will continue to engage with our Tier 1 suppliers to attempt to increase supply chain transparency, including follow up with unresponsive suppliers. In addition, we will work with our Tier 1 suppliers to obtain even more product-level responses. As stated previously, 69% of our supplier responses were at the product level, as opposed to 2% for 2014. Finally, we will encourage improvement from those Tier 1 suppliers who provided a response at the product level but stated that 25% or less of their supply chain had provided a response. We will engage with these suppliers to remind them of the expectations set forth in our Conflict Minerals Policy and provide assistance where practicable.
Educational certification — More than 80% of our employees targeted for training on the Rule completed their annual training in 2015. These employees are members of the legal, engineering, manufacturing, sustaining, procurement and sourcing, sales, finance and compliance functions. We will continue targeted annual training and seek to improve the completion percentage, while also targeting new employees, including those from the Cameron acquisition. We will also develop additional training materials for enhanced understanding of various procedures for targeted employees who are integral to our reporting requirements under the Rule.
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