Thursday 27 October 2016

Exhibit 1.01 - Conflict Minerals Report

Brocade Communications Systems, Inc.
130 Holger Way
San Jose, CA 95134

Calendar Year 2015

Table of Contents

1 Introduction
2 RCOI
3 Due Diligence
3.1 Overview of Brocade’s Due Diligence Process
3.1.1 OECD Step 1 - Establish strong company management systems
3.1.2 OECD Step 2 - Identify and assess risk in the supply chain
3.1.3 OECD Step 3 - Design and implement a strategy to respond to identified risks
3.1.4 OECD Step 4 - Carry out independent third-party audits of supply chain due
diligence at identified points in the supply chain
3.1.5 OECD Step 5 - Report on supply chain due diligence
3.2 Brocade’s Due Diligence Results
3.3 Continuous Improvement and CY 2016 Activities
4 Forward Looking Statements
Appendix A - Smelter List

1 Introduction

In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd Frank Act”). Section 1502 of the Dodd Frank Act specifically relates to “conflict minerals”1 and adds Rule 13p-1 (the “Rule”) to the Securities Exchange Act of 1934, as amended. The Rule and Form SD adopted by the Securities and Exchange Commission (“SEC”) require companies subject to the Rule to perform certain procedures to determine the source of conflict minerals that are determined to be necessary to the functionality of the products such companies manufacture or contract to manufacture. Specifically, companies are required to determine whether
the conflict minerals used in their products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, “covered countries”), to determine whether armed groups directly or indirectly benefitted as a result, and to disclose information about the due diligence procedures the company performed.

In accordance with the Rule, Brocade Communications Systems, Inc. (“Brocade” or the “Company”) exercised due diligence on the source and chain of custody of its conflict minerals and submits this Conflict Minerals Report (“CMR”) which describes the Reasonable Country of Origin Inquiry (“RCOI”) and due diligence activities performed in good faith for calendar year 2015 (“CY 2015”) based on information available from its supply chain at the time of filing. This CMR will also describe Brocade’s commitment to being a socially responsible corporate citizen and its plans to improve its due diligence activities in calendar year 2016 (“CY 2016”) and beyond.

2 RCOI

In accordance with the Rule, Brocade determined that conflict minerals are necessary to the functionality or production of its products for CY 2015, and are incorporated into these products during the manufacturing process. Accordingly, Brocade was required to undertake an RCOI to determine whether any of the conflict minerals originated in the covered countries. As an original equipment manufacturer, Brocade is many steps removed in the supply chain from the smelters or ore refiners (“SORs”) that process the minerals used in its products and from the mines of origin for the minerals. Therefore, Brocade determined that it is reasonable for the Company to expect its suppliers to identify those “upstream” companies, namely, the SORs that represent the sources of conflict minerals in its supply chain.

Brocade aligned with certain conflict minerals tools and processes developed by the Conflict-Free Sourcing Initiative (“CFSI”), a consortium of the Electronic Industry Citizenship Coalition (“EICC”), and the Global e-Sustainability Initiative (“GeSI”), specifically:
• The industry standard Conflict Minerals Reporting Template (“CMRT”) for surveying Tier 1 and Tier 3 suppliers for critical conflict minerals information, including identification of all SORs in their supply chains; and
• The list of “known” SORs with assigned identification (“ID”) numbers provided as part of the CMRT.

Brocade implemented a comprehensive process that involved collecting and evaluating completed CMRTs (version 4.01b was utilized) from its suppliers who were actively engaged in providing products to Brocade during CY 2015 that were likely to contain conflict minerals. This process included retaining an outside contractor to provide the means and methods to implement the data collection from suppliers. Brocade held its suppliers responsible for providing the information needed to support the RCOI process at both the corporate level and the procurement level. For CY 2015 Brocade also established a goal to be conflict-free for tantalum and communicated this requirement to its suppliers. Suppliers who were reluctant to provide the required information were escalated to
Brocade’s supply base management team to achieve the maximum supplier response.

For CY 2015 Brocade received responses from 100% of its in-scope suppliers. These suppliers identified 441 known SORs that may be in its supply chain. Based on the analysis of the CMRTs Brocade also concluded that many of these SORs sourced conflict minerals entirely from outside of the covered countries, including from recycled or scrap sources.

Many of Brocade’s suppliers reported conflict minerals at a “company level”, meaning that they reported the conflict minerals contained in all of their products. Therefore, Brocade received and reviewed information of SORs that were not in the Company’s supply chain. In addition, some suppliers reported that they only collected data for 50% or greater from their supply chain. As a result for CY 2015, Brocade was unable to determine the origin of at least a portion of the necessary conflict minerals in each of its in-scope products. None of the necessary conflict minerals contained in its in-scope products were determined by Brocade to directly or indirectly finance or benefit
armed groups in a covered country. However, Brocade did not conclude that any of its in-scope products were “DRC conflict free.”

Based on the results of the RCOI, Brocade is required to conduct due diligence for CY 2015. These due diligence efforts are discussed below.

3 Due Diligence

3.1 Overview of Brocade’s Due Diligence Process

Brocade’s approach to due diligence was designed in accordance with the framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, 2013 (“OECD Guidance”) and is described below:

3.1.1 OECD Step 1 - Establish strong company management systems

In 2013, Brocade developed an internal management system that supports its compliance with the Rule, addresses its customers’ needs for a conflict-free supply chain, and implements a reasonable approach to understanding the conflict minerals risks in its supply chain. The management system includes the following elements:

• A Brocade Conflict Minerals Statement was developed and approved by key stakeholders, communicated internally, and is posted on the Company’s external website at: http://www.brocade.com/en/about-us/corporateresponsibility/governance.html. The text of Brocade’s statement is presented below:

Brocade recognizes the adverse effects associated with mining columbite-tantalite, cassiterite, gold,
wolframite or their derivatives (collectively referred to as “conflict minerals”) in the Democratic Republic of the Congo ("DRC") and adjoining countries ("covered countries"). Brocade is committed to sourcing minerals for our products in a manner that does not directly finance armed groups perpetrating serious human rights abuses in the covered countries. In addition, Brocade is committed to complying with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act") and with a nationally or internationally recognized framework for conflict minerals due diligence, as applicable. In support of our commitment to responsible sourcing, Brocade has adopted an approach for its products to become DRC conflict free that it believes is reasonable and achievable. The plan requires that Brocade's suppliers source columbite-tantalite (aka "tantalum") from conflict-free smelters by the end of calendar year 2015. This plan has been communicated to our suppliers. Brocade expects our suppliers to exercise due diligence on the source and chain of custody of conflict minerals in the products they manufacture, to make their due diligence measures and conflict minerals sourcing information available to Brocade annually, and to source minerals from responsible sources that do not contribute to human rights abuses in the covered countries. Brocade will comply with the annual reporting requirements of Section 1502 of the Dodd-Frank Act, including making information regarding conflict minerals available to the public.

• A strategy for compliance with the Rule that included establishing roles, responsibilities and updating the internal CY 2015 Conflict Minerals Implementation Plan, and updating the internal Conflict Minerals Standard Operating Procedure (“SOP”). The Conflict Minerals Implementation Plan includes the scope of the program and approach used for compliance with the SEC rule; responsibilities for implementing the plan; a description of the process Brocade followed to collect information about the SORs of conflict minerals used in its products, due diligence, and SEC reporting requirements; a conflict minerals process flow diagram; and an implementation schedule. The SOP describes Brocade’s conflict minerals risk-based due diligence and management system approach to support Brocade’s goal that its supply chain does not contribute to human rights abuses and conflict in the covered countries.

• On a quarterly basis or more frequently, if needed, Brocade engaged with its customers to understand their approaches to managing conflict minerals and to ensure Brocade provided appropriate and responsive information.
• A resource plan was developed that identified both internal and external resources and responsibilities for implementing various aspects of Brocade’s conflict minerals strategy.
• Brocade assigned business functional group responsibilities for conflict minerals to specific Brocade employees, held meetings with those employees to explain what was needed, and developed an internal Plan of Record (“POR”) for CY 2015 that served as a formal re-commitment by the Company to its conflict minerals program and established expectations for accountability.
• Internal and external communications were developed by Brocade that describe its Company statement and conflict minerals strategy and program to employees, suppliers, investors, customers and other interested stakeholders. The communication includes the Conflict Minerals Statement on its publicly available website at: http://www.brocade.com/en/about-us/corporate-responsibility/governance.html, presentations, outbound conflict mineral declarations, supplier communication letters and e-mails, and training programs.

3.1.2 OECD Step 2 - Identify and assess risk in the supply chain

On July 17, 2015, the EICC approved Brocade’s application for membership and Brocade has attended the monthly plenary meetings since then. Brocade aligned with public and members-only conflict minerals tools and processes developed by the CFSI, specifically:
• The Conflict-Free Smelter Program (“CFSP”), under which the CFSI conducts third-party audits of the SORs utilizing a standard audit protocol to determine whether an SOR is conflict-free, and the published list of SORs who are certified under the CFSP, which is available at: www.conflictfreesourcing.org, and is updated periodically; and
• Utilizing the CFSI’s Compliant Smelter Sourcing Information list, as part of the due diligence. This list provides country of origin information for smelting and refining facilities that are validated through the CFSP and only available to EICC members.

Brocade and its outside contractor reviewed the responses received from in-scope suppliers for plausibility, consistency and gaps, and followed up with suppliers that submitted a response that triggered specified quality control flags. This process included comparing the names of entities provided in CMRTs with and without IDs to those set forth on the CFSP to determine whether the entities are in fact SORs, and, if so, whether they are compliant with the CFSP.

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

Brocade conducted a two-part review process on CMRTs received from suppliers: Part 1 was a completeness review and Part 2 was a risk review that included various risk assessment paths and follow-up actions.

The completeness review focused on whether each supplier provided all of the required information at the level of detail expected and on the correct version of the CMRT. Templates found to be incomplete or on the incorrect version of the CMRT were returned to the suppliers who were requested to resubmit them with all of the required information.

The risk review, which included an evaluation of six risk “paths”, was conducted following the completeness review. The primary objective of the risk review was to evaluate whether a supplier’s responses could be considered to be credible such that Brocade could effectively implement its conflict minerals strategy and policy, including meeting the requirements of the SEC final rule.
The six risk “paths” included the following:
• Path A – The supplier’s declared SOR was not on the CMRT drop down list, i.e., the declared SOR is not “valid.”
• Path B – The supplier’s declared SOR was on the drop down list, but is not on the CFSI’s CFSP list.
• Path C – The supplier’s declared SOR is on a Brocade customer watch list.
• Path D – The supplier had not identified all of its SORs.
• Path E – The supplier does not have key management systems in place.
• Path F – The supplier reported conflict minerals from conflict countries.

The risk review was conducted in a manner to identify:
• Supplier responses for which it was not reasonable to believe the information provided
• Key issues for which supplier follow-up was needed to meet Brocade’s program objectives and customer requirements
• Issues which may pose a business risk to Brocade

Based on the results of the risk review, suppliers were asked to provide additional information or resubmit their templates to address identified issues. The suppliers’ responses to requested follow-up actions and requests for additional information were reviewed by Brocade and, where necessary, an appropriate response on Brocade’s part was initiated. In some cases, the outcome of these additional actions by certain suppliers did not completely address the identified risks resulting in identification of suppliers that do not meet Brocade’s expectations with respect to its conflict minerals statement. These suppliers will be subjected to a Corrective Action Plan that will be implemented during Brocade’s CY 2016 conflict minerals RCOI and due diligence processes.

Based on the SOR information provided by the in-scope suppliers on the completed CMRTs, two lists of SORs were compiled. The “known” SOR list included those entities that have been evaluated by CFSI, determined to be SORs, and assigned an ID number. This list of SORs was compared to the CFSI’s Compliant Smelter Sourcing Information list and a notation was made regarding which SORs were determined to be conflict-free and if they sourced from the covered countries or not.

The “unknown” SOR list included those entities identified by suppliers in their CMRTs that did not have ID numbers. This list was subjected to additional review to attempt to determine whether the companies identified were actual SORs. The review included direct contact with the companies, when contact information was provided by a supplier or could otherwise be identified, review of any additional information provided by the SOR, and a search for publicly available information regarding each company via the internet. When the supporting information indicated that an identified company was engaged in smelting operations, it was identified as a SOR. Brocade is aggressively requiring suppliers to investigate “unknown” SORs and require them to participate in the CFSP.

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

As a contributing member of the EICC, Brocade relies on the CFSI to validate that entities listed in supplier CMRTs meet the requirements for being an SOR and then to certify them as conflict-free. This final list of SORs reported to Brocade, including conflict-free designations, is provided in Appendix A.

In addition to the review of CFSI IDs and reviewing each SOR’s compliance status using CFSI’s Compliant Smelter Sourcing Information list, and based on the outcome of the risk review and any follow-up actions, Brocade selected a group of suppliers to participate in “desktop” audits. The objective of these audits was to further evaluate the information provided regarding the source of any conflict minerals from a conflict country reported.

The audits were conducted by an experienced auditor from Brocade’s outside contractor, who was independent of the data collection process, and included the activities described below.
1. Prioritized suppliers based on the information provided in their CMRTs and finalized list for the audits
2. Created “rules” for the audit team
3. Initiated the audit process
4. Contacted suppliers selected for audit
5. Reviewed all information provided by each supplier
6. Independently verified supplier information to the extent possible:
• Reviewed each supplier’s company website regarding its conflict minerals policy and other relevant
information that is publicly available
• Checked for other publicly available information (e.g., information on identified SORs)
• Checked the status of SORs in the CFSP and on the CFSI’s Compliant Smelter Sourcing Information list
7. Requested follow up information from each supplier, including:
• Questionnaire regarding conflict minerals management system, how they derived their information on the CMRT, source of supply, and to ascertain whether the metal(s) could have come from scrap or recycled sources
• Additional SOR information, if needed
8. Evaluated whether each supplier is sourcing materials from a conflict country that is benefitting armed groups
9. Prepared an audit report

The desktop audit was initiated by the auditor sending an email questionnaire to the suppliers. Three suppliers did not respond to the audit request however, sufficient information was provided on the companies’ CMRT, websites, or via electronic mail responses for the auditor to complete the process. In all cases, the suppliers reported that they are collecting information from the supply chains using the CMRT and are conducting due diligence on that information. All of the suppliers in the desktop audit reported receiving 100% of the data they needed from their suppliers except for two that reported greater than 90%. Additional information regarding conflict minerals policies
and reporting was publicly available for all 21 suppliers.

In conclusion, the conflict minerals information provided by a majority of the audited suppliers appeared to be verifiable and accurate. With the exception of two suppliers, the audit results indicate that conflict minerals reported to be sourced from the covered countries are from conflict-free SORs. Information provided by two suppliers demonstrated that their due diligence processes require significant improvement and increased transparency. Brocade intends to put those two suppliers on a Corrective Action Plan for CY 2016.

3.1.5 OECD Step 5 - Report on supply chain due diligence

Brocade publishes a CMR annually and reports are accessible on the Company’s website at http://
www.brocade.com/en/about-us/corporate-responsibility/governance.html.

3.2 Brocade’s Due Diligence Results

Following the completion of its data collection process, Brocade determined that at least some of the conflict minerals in its supply chain may have originated in the covered countries, but the Company has not identified any instances of sourcing that directly or indirectly supported conflict in the covered countries. This conclusion is based on information provided by suppliers for the CY 2015 reporting period. In some instances, information provided by Brocade’s suppliers was unverifiable or incomplete and, as such, the Company was unable to verify with certainty the source and chain of custody of all of the necessary conflict minerals in its products.

The list of SORs identified by Brocade’s in-scope suppliers is provided in Appendix A. The SORs with a “Smelter Status” of “C” were verified against the CFSI’s Compliant Smelter Sourcing Information list and/or the CFSP list as having valid smelting or refining operations for CY 2015 or actively undergoing the CFSP audit (www.conflictfreesourcing.org) up to December 31, 2015.

Brocade’s due diligence activities for CY 2015 revealed:
• Suppliers reported 441 known SORs
• 56% (247/441) of the SORs reported by Brocade’s suppliers are either conflict-free according to the CFSI’s Compliant Smelter Sourcing Information list or are active in the CFSP; in CY 2014, 61% of the SORs were identified as conflict-free or are active in the CFSP
• 100% (48/48) of the reported tantalum smelters were verified against the CFSI’s Compliant Smelter Sourcing Information list and found to be conflict-free or are active in the CFSP; in CY 2014, 93% of the tantalum smelters were verified as conflict-free or active
• 78% (39/50) of the reported tungsten smelters were verified against the CFSI’s Compliant Smelter Sourcing Information list and found to be conflict-free or are active in the CFSP; in CY 2014, 64% were verified as conflict-free or active
• 56% (94/167) of the reported gold refiners were verified against the CFSI’s Compliant Smelter Sourcing Information list and found to be conflict-free or are active in the CFSP; in CY 2014, 57% were verified as conflict-free or active
• 39% (68/176) of the reported tin smelters were verified against the CFSI’s Compliant Smelter Sourcing Information list and found to be conflict-free or are active in the CFSP; in CY 2014, 51% were verified as conflict-free or active
• 30% (131/441) of the total SORs reported to Brocade do not have ID numbers assigned by the CFSI; in CY 2014, 19% of the total SORs reported did not have assigned ID numbers

Brocade attributes these changes to suppliers becoming more successful at collecting more data from their supply chains but they are still working to identify all of the SORs and the sources of their conflict minerals. Brocade believes that the sources of the conflict minerals contained in its products are (i) SORs designated as conflict-free by the CFSI, (ii) SORs that have not been designated as conflict-free by the CFSI, (iii) scrap or recycled sources, and (iv) other indeterminate sources. As these suppliers largely provided the Company with company level information regarding the SORs of all products they manufacture, Brocade is unable at this time to make any specific determinations regarding the status of the Company’s products for CY 2015 or to provide the specific SORs
and country of origin of conflict minerals.

3.3 Continuous Improvement and CY 2016 Activities

Brocade will conduct its CY 2016 data collection process by sourcing conflict minerals data from all of its active suppliers that were included in the CY 2015 process and will expand the scope of the project to include additional suppliers (new suppliers or suppliers that provide new parts) as needed. Brocade will continue to work with its suppliers to refine SOR and country of origin information of conflict minerals and strive to advance the effectiveness of its due diligence efforts of its supply chain. In addition, Brocade is developing and will implement a Corrective Action Plan for those suppliers that did not meet Brocade’s expectations as identified in its conflict minerals statement. The Corrective Action Plan will be designed to reinforce Brocade’s expectations for its suppliers to provide better and more detailed information regarding the source of any conflict minerals in their
products, to source minerals from conflict-free SORs, and to aggressively encourage non-conflict-free SORs to undergo certification as conflict-free. The CFSI’s Compliant Smelter Sourcing Information list will be continuously monitored for SORs that have been removed and the appropriate actions will be taken to ensure that they are removed from the Company’s supply chain. Brocade expects to continue to concentrate on its goal to be conflict free for tantalum, and require suppliers to be conflict-free for tungsten.

4 Forward Looking Statements

This CMR contains forward-looking statements regarding future events and future results. All statements other than statements of historical fact are statements that could be deemed forward-looking statements. Words such as “expects,” “intends,” “plans,” “may,” “will,” and variations of such words and similar expressions are intended to identify such forward-looking statements. Readers are cautioned that these forward-looking statements are only predictions and are subject to risks, uncertainties, and assumptions that are difficult to predict (including, but not limited to whether industry organizations and initiatives such as the EICC and the CFSI remain effective as a source
of external support to us in the conflict minerals compliance process). Therefore, actual results may differ materially and adversely from those expressed in any forward-looking statements. Furthermore, Brocade undertakes no obligation to revise or update any forward-looking statements for any reason.

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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