Introduction:
Motorola Solutions, Inc. (which may be referred to as “Motorola Solutions,” the “Company,” “we,” “us,” or “our”) designs, manufactures, and sells communications infrastructure, devices, system software and applications, and provides services associated with their use. Our products and
services are designed to help our government and enterprise customers improve their operations through increased effectiveness and efficiency of their mobile workforce and can be found in a wide range of workplaces, from the retail floor to the warehouse floor, and from the small town police
station to the most secure government offices.
We conduct our business globally and manage it through two segments: Products and Services. Within these segments we are reporting on the following product categories: (i) two-way portable radios and vehicle-mounted radios, (ii) accessories such as speaker microphones, batteries, earpieces, headsets, carry cases and cables, (iii) software features and upgrades, (iv) radio network core and central processing software, (v) base stations, (vi) consoles, and (vii) repeaters.
We were incorporated under the laws of the State of Delaware as the successor to an Illinois corporation, Motorola, Inc., organized in 1928. We changed our name from Motorola, Inc. to Motorola Solutions, Inc. on January 4, 2011. Our principal executive offices are located at 1303 East
Algonquin Road, Schaumburg, Illinois 60196.
Section 1 – Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
The Company is concerned about the social and environmental conditions that have been observed in some mines that supply metals to the electronics industry known as “conflict minerals” which currently consist of the following metals: columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives. The longstanding civil war in the eastern provinces of the Democratic Republic of Congo (“DRC”) has impacted many mines that supply conflict minerals. Together with our peers, we are working to support the development and implementation of a tracking and validation system to ensure conflict minerals that originate in the DRC come from responsible sources free from association with armed conflict. For more information on our program and to view our Supplier Code of Conduct you can visit the “About Us” tab on our web site at www.motorolasolutions.com. The information contained on Motorola Solutions’ website is not a part of this Form SD and is not deemed incorporated by reference into this Form SD or any other public filing made with the Securities and Exchange Commission (the “SEC”).
In accordance with the requirements of our Supplier Code of Conduct, Motorola Solutions has concluded in good faith that during 2015:
a) Motorola Solutions manufactured and contracted to manufacture products as to which conflict minerals are necessary to the functionality or production of such products; and
b) Based on a “reasonable country of origin inquiry” Motorola Solutions knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, sometimes referred to as the “Covered Countries”) and knows or has reason to believe that those necessary conflict minerals may not be from recycle or scrap sources.
Motorola Solutions’ reasonable country of origin inquiry (“RCOI”) employed a combination of measures to determine whether the necessary conflict minerals in Motorola Solutions products originated from the Covered Countries. Motorola Solutions’ primary means of determining country of origin of necessary conflict minerals was by conducting a supply-chain survey with direct suppliers using the Conflict Free Sourcing Initiative’s Conflict Minerals Reporting Template (CMRT). Motorola Solutions used the smelter information from the CMRT and the various smelter’s Country of Origin information provided through our membership to the Conflict Free Sourcing Initiative to determine the Country of Origin of material that may be in our products. Additionally, Motorola Solutions’ participation with in-region sourcing programs such as Solutions for Hope (http://solutions-network.org/site-solutionsforhope/ ) and Conflict Free Tin Initiative (http://solutions-network.org/site-cfti/ )provided additional country of origin information.
As a result of the reasonable country of origin inquiry conducted as described above, Motorola Solutions concluded that material in our products may have originated from all three of the country levels as described below:
Level 1 Country: Countries with known active ore production for tin, tungsten, tantalum or gold that are not identified as conflict regions or plausible countries of smuggling or export of tin, tungsten, tantalum or gold containing materials.
Level 2 Country: Known or plausible countries for smuggling, export out of level 3 countries, or transit of materials containing tin, tungsten, tantalum or gold. This currently includes Kenya, Mozambique, and South Africa.
Level 3 Country: The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act. These include Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
These are also commonly referred to as “covered countries” in the Dodd Frank Act Section 1502.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (‘Rule 13p-1”), Motorola Solutions has filed this Specialized Disclosure Form (Form SD) and the associated Exhibit 101 Conflict Minerals Report and is available on the Company’s website at www.MotorolaSolutions.com/investor.
Item 1.02 – Exhibits
The Motorola Solutions Conflict Minerals Report is attached to this report as Exhibit 1.01.
Forward-Looking Statements
This Specialized Disclosure Report on Form SD, including the Conflict Minerals Report exhibit, contains forward-looking statements that are based upon management’s expectations and beliefs concerning future events impacting Motorola Solutions. Certain matters contained herein concerning
the future, including risk mitigation steps, constitute forward-looking statements and are based upon management’s expectations and beliefs. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. For a description of certain factors that could cause our future results to differ materially from those expressed in any forward-looking statement, see Item 1A of our Annual Report on Form 10-K for the year ended December 31, 2015, entitled “Risk Factors.”
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report of Motorola Solutions, Inc. for the period January 1 to December 31, 2015, as required by Items 1.01 and 1.02 of this Form.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
MOTOROLA SOLUTIONS, INC.
(Registrant)
Name: Gino A. Bonanotte
Title: Executive Vice President and
Chief Financial Officer
Exhibit 1.01 – Conflict Minerals Report of Motorola Solutions, Inc. for the period January 1 to December 31, 2015.
Section 2: EX-1.01 (EX-1.01)
Exhibit 1.01
CONFLICT MINERALS REPORT OF
MOTOROLA SOLUTIONS, INC.
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2015
This is the Conflict Minerals1 Report of Motorola Solutions, Inc. (may be referred to as “Motorola Solutions”, the “Company,” “we,” “us,” or “our”) for calendar year 2015 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accordance in all material respects with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
In accordance in all material respects with Rule 13p-1, we undertook efforts to determine the content and source of the minerals within our products. The Company designed its efforts in conformity, in all material respects, with the internationally recognized due diligence framework in the 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 each of the conflict minerals.
The statements below are based on the due diligence activities performed to date and in good faith by Motorola Solutions and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
II. Design of Due Diligence Measures
The Company designed its overall conflict minerals policies and procedures based on the five step framework developed by OECD (2013), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition (OECD Due
Diligence Guidance) OECD Publishing (http://dx.doi.org/10.1787/9789264185050-en ) and the supplements on tin, tantalum, tungsten and gold.
Our implementation of the five step framework consists of the following activities which are discussed in further detail in Section III (RCOI) and Section IV (Due Diligence).
[The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country]
1. Development of Conflict Mineral Policies and Procedures
2. Risk Assessment of Potential Sources of Conflict Minerals in Our Supply Chain
3. Mitigation of Sourcing from Conflict Smelters / Refiners
4. Auditing of Smelters/Refiners to Ensure Conflict Free Status
5. Reporting of Results of the above Activities
Our efforts utilized multi-industry initiatives with the smelters and refiners of minerals who may provide those minerals to companies in our supply chain. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals; the Company does not purchase raw ore or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries.
III. Management Systems and Reasonable Country of Origin Inquiry
The following outlines the measures taken to determine country of origin.
Step 1. Policy and Management System
a. Conflict Minerals Policy – As required by the OECD Framework, Motorola Solutions developed a policy which establishes the expectations of our suppliers to responsibly source products on a conflict free basis. The policy resides in our Supplier Code of Conduct and can be found at http://responsibility.motorolasolutions.com/index.php/downloads/. It is periodically reviewed and updated, if necessary.
b. Company level grievance mechanism – As required by the OECD Framework, Motorola Solutions utilizes our internal Ethics Line to provide a grievance mechanism. All Motorola Solutions employees as well as those outside the Company can communicate directly and confidentially (via
phone/fax/email) with the Office of Ethics without fear of retaliation.
Step 2. Conduct Risk Assessment
The MSI process relied on the Conflict Minerals Reporting Template and Conflict-Free Smelter Program developed by the Conflict Free Sourcing Initiative. The following steps were taken as part of our risk assessment process.
a. Identify products in scope – Our internal cross-functional group of employees assigned to our conflict-free minerals team reviewed the categories of products that we sell to determine the products that are in scope as described in the Adopting Release. As part of this process, the Company identified direct suppliers that provide products potentially containing conflict minerals, and set a goal to collect CMRT data from suppliers representing 93% of the in-scope direct material spend for this report, an improvement of 3% over the previous year’s survey.
b. Conduct Reasonable Country of Origin Inquiry (“RCOI”) – As part of the RCOI, the Company used the industry-developed Conflict Minerals Reporting Template (“CMRT”). We evaluated the responses in the template to determine the reporting obligations based on the RCOI. We surveyed tier 1 direct suppliers that provide material and components for products that are within scope and, as needed, performed due diligence steps to identify the smelters and refiners who contribute refined conflict minerals to the Company.
c. Identify smelters/processors – The Company compared the smelters and refiners identified by direct suppliers via the supply-chain survey against the list of smelter facilities designated as “conflict free” by the Conflict Free Sourcing Initiative’s (CFSI) independent third-party smelter audit program.
IV. Due Diligence Measures Performed by Company
The following outlines the measures taken to exercise due diligence in conformance with the OECD Due Diligence guidance.
Step 3. Mitigate Risk
As part of the risk mitigation process we compared the list of smelters/processors collected from suppliers and compared it to the Conflict Free Smelter list developed by the Conflict Free Sourcing Initiative (CFSI). After completing this review, the Company communicated to suppliers who
have smelters and/or processors that are not on the CFS list to migrate their supply chain to those that are on the CFS list. The communication also includes a recommendation for a supplier to recommend that the smelter and/or refiner in their supply chain participate in the CFS program. In addition, suppliers who reported all smelters and/or processors in their supply chain are identified by CFSI as “conflict-free” were sent letters acknowledging their efforts to establish a conflict-free supply chain, and encouraging them to continue to maintain it as such.
Step 4. Audit of Smelters/Refiners
Step 4 of the OECD due diligence process recommends that downstream companies implement audits by cooperating through their industry organizations, and that downstream companies participate in and contribute to such organizations. The Company is a member of the Conflict Free
Sourcing Initiative (CFSI) of the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (EICC/GeSI). As a member, the Company has supported the execution of the Conflict Free Smelter Program (CFSP) and has relied on the CFSP to develop information on the
country and mine or location of origin of conflict minerals in the Company’s products. The efforts to determine mine or location of origin through CFSI are described on the CFSI website at http://www.conflictfreesourcing.org/.
Step 5. Results of Due Diligence
In our 2015 survey, we requested CMRT data from 176 suppliers. We received data from suppliers representing over 93% of our in-scope direct material spend, exceeding our internal goal. A review of this data showed that 211 of the smelters identified in our supply chain are certified as “conflict-free” by the CFSI. A further 85 smelters are identified by CFSI as having agreed to participate in the CFSP program but are not yet certified as conflict-free. See Appendix I for a list of countries of origin identified through the RCOI process.
The Company has determined that materials in products were derived from Covered Countries. Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website at www.motorolasolutions.com/investor.
V. Product Description
On the basis of the measures described above, the Company has determined that as of December 31, 2015, a portion of its necessary conflict minerals originated or may have originated in the Democratic Republic of Congo or an adjoining country.
1. Description of products – The products subject to this disclosure include: (i) two-way portable radios and vehicle-mounted radios, (ii) accessories such as speaker microphones, batteries, earpieces, headsets, carry cases and cables, (iii) software features and upgrades, (iv) the radio network core and central processing software, (v) base stations, (vi) consoles, and (vii) repeaters.
2. Processing Facilities – Based on the input received from our suppliers, the facilities listed in Table 1 may have been used in the processing of conflict minerals used in our products.
VI. Steps to Improve Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. We will also continue to monitor changes in circumstances that may impact the facts or our determination. Over time, we anticipate that the amount of information globally on the traceability
and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional fact and risk assessments where potentially relevant changes in facts or circumstances are identified. New suppliers will be reviewed for conflict minerals conformance during initial business reviews. If we become aware of a supplier whose due diligence needs improvement, we intend to continue the trade relationship while that supplier improves its performance. However, if we identify an upstream supplier is sourcing from or linked to any party providing direct or indirect support to non-state armed groups we will work with our supply chain to suspend or discontinue engagement with that upstream supplier. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In 2015, we implemented a data management system that allows us to store data collected from suppliers via the CMRT. This system has data analysis capabilities that allow us to efficiently review the quality of supplier responses and will allow us to measure improvements over time.
In addition to those above, the Company will undertake the following steps during the next compliance period to improve the due diligence conducted to further mitigate the risk that its necessary conflict minerals do not benefit armed groups, including:
• Continue to collect responses from suppliers using tools such as the Conflict Minerals Reporting Template.
• Continue to direct suppliers to information and training resources that will improve the quality of the data in the supplier responses.
• Compare and validate RCOI results to information collected via independent conflict free smelter validation programs such as the Conflict Free Sourcing Initiative.
• Inform and encourage suppliers to transition to smelters identified by the due diligence process as “conflict free” by an independent audit program such as the Conflict Free Sourcing Initiative.
• Continue support of key in-region conflict-free sourcing initiatives like the Public-Private Alliance for Responsible Minerals Trade (“PPA”), the ITRI Tin Supply Chain Initiative (iTSCi) and the Conflict Free Sourcing Initiative (“CFSI”).
• Continue to support implementation of closed pipe systems, through our support of organizations such as the Solutions for Hope Platform.
• Continue to allow verified conflict-free material from the region to enter our supply chain.
VII. Independent Private Sector Audit
Not required for calendar year 2015.
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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