Items 1.01 and 1.02 Conflict Minerals Disclosure and Report; Exhibit
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Avaya Inc. (“Avaya” or 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. The Conflict Minerals Report is publicly available on the Company’s website at: http://www.avaya.com/usa/about-avaya/our-company/corporate-responsibility/products-and-suppliers.
Section 2- Exhibits
Item 2.01 Exhibits
Exhibit 1.01
Avaya Inc. Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015
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.
AVAYA INC.
(Registrant)
/s/ James M. Chirico, Jr. May 25, 2016
By: James M. Chirico, Jr. (Date)
Executive Vice President, Business Operations
Exhibit 1.01
Avaya Inc. Conflict Minerals Report
Reporting period: January 1, 2015 to December 31, 2015
This Conflict Minerals Report is filed with the Securities and Exchange Commission (the “SEC”) by Avaya Inc. in accordance with Section 13(p) of the Securities Exchange Act of 1934 and the instructions to Form SD (together, with the related rules promulgated by the SEC, the “Regulations”) for the reporting period January 1 to December 31, 2015. The Regulations require registrants with conflict minerals that are necessary to the functionality or production of a manufactured product to disclose annually whether any of those minerals originated in the Democratic Republic of the Congo or adjoining countries (the conflict zone) and not from recycled or scrap sources. The conflict minerals are identified as columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, or simply tantalum, tin, tungsten and gold, which are collectively referred to as “conflict minerals” or “3TG”.
Use of the terms “Avaya” or the “Company” in this Report refers to Avaya Inc., a Delaware corporation, and its consolidated subsidiaries taken as a whole, unless the context otherwise indicates.
In accordance with the Regulations, Avaya has conducted a reasonable country of origin inquiry (“RCOI”) and subsequent due diligence according to a nationally or internationally recognized due diligence framework to determine if it knows or has reason to believe that the 3TGs identified in the Company’s products originated from sources in the conflict zone. As a downstream user of minerals, the Company contracts the manufacture of products with electronic manufacturing suppliers (“EMSs”), making it challenging to identify all of its source mines given the extent of the Company’s supply chain and the Company’s lack of direct relationships with the mines and/or smelters providing the minerals. Avaya is wholly reliant on industry initiatives, manufacturing partners and parts vendors with whom the Company has direct supplier relationships to determine the source of the conflict minerals in Avaya’s products. This Conflict Minerals Report (“CMR”) summarizes Avaya’s process to identify and assess products contracted by Avaya for manufacture by EMS partners that were sold during the reporting period and contained 3TG.
Executive Summary of the 2015 Conflict Minerals Program
Avaya performed a RCOI on the portion of its supply chain which provided products and parts containing 3TGs to determine the source of the 3TGs in such products and parts sold during the reporting period. The results identified 318 total smelters or refiners (“SORs”) involved in the Avaya supply chain, of which 267 could be validated against the Conflict Free Smelter Program (“CFSP”) list of SORs and 51 could not be validated against the CFSP list. The CFSP list is confirmed by the Electronic Industry Citizenship Coalition’s (“EICC”) Conflict-Free Sourcing Initiative (“CFSI”) and it identifies SORs who are legitimate processors and who CFSI have audited to ensure that such processors have systems in place to assure that they are sourcing only conflict-free minerals. In addition to these 318 results, the Company received an additional 40 responses which identified entities that were not legitimate SORs. These responses, which are listed at the end of Appendix A to this Report, require additional due diligence with the Company’s direct suppliers to determine the actual SORs that performed the mineral processing and therefore they were not counted in the Company’s analysis of its RCOI results, which is detailed below.
Avaya cannot be certain about the origin of the conflict minerals used by the smelters or entities not listed on the CFSP list. Avaya has partnered with suppliers to obtain more information to determine the status of these smelters and entities. No independent private sector audit was performed of the Avaya due diligence process this year in accordance with SEC guidance promulgated in April 2014 since Avaya is unable to confirm the source of some of the 3TGs used in its products.
Avaya Company Overview
Avaya is a leading provider of contact center, unified communications and networking products and services designed to help enterprise, midmarket and small businesses increase workforce productivity, customer engagement, net promoter score, and customer lifetime value, with the ultimate objective of higher revenue and profitability for our customers. Our products and services portfolio spans software, hardware, professional and support services, and cloud services. These fall under three reporting segments:
• Global Communications Solutions, or GCS, encompass all of our real-time collaboration, contact center and unified communications software and hardware. Unified communications integrates real-time communication services including telephony, e-mail, instant messaging and video. Examples in GCS include audio and video conferencing and collaboration systems; mobile video software, software that runs contact center operations such as multimedia contact routing; software that enables mobile access to the company network for employees; and hardware such as phones, gateways, and servers. We enable these unified communication and real-time collaboration tools to also be embedded inside the applications businesses use every day to keep employees and customers connected, productive and effective. This reporting segment also includes a software development platform, which allows our customers and third parties to adapt our technology by creating custom applications, automated workflows, and engagement environments for their unique needs and allows them to integrate Avaya’s capabilities into their existing infrastructure. GCS also includes cloud-supporting software and hardware products, which make it possible to use all of our contact center and unified communications products via the Cloud.
• Avaya Networking includes our advanced fabric networking technology which offers a unique end to-end virtualized architecture designed to be simple to deploy, agile and resilient. This reporting segment also includes software and hardware products such as Ethernet switches; wireless networking; and access control, and unified management and orchestration solutions, which provides network and device management.
• Avaya Global Services or AGS includes professional and support services designed to help our customers maximize the benefits of using our products and technology. Our services include support for implementation, deployment, monitoring, troubleshooting, optimization, and more. This reporting segment also includes our cloud and managed services, which enable customers to take advantage of our technology in a private, hybrid, or public Cloud environment. The majority of our revenue in this reporting segment is recurring in nature, based on multi-year services contracts.
Avaya’s Conflict Minerals Program Overview
Avaya is an affiliate member of the EICC and Avaya participates in the Coalition’s CFSI program. Therefore, the Avaya Conflict Minerals Program (the “Program”) relies upon guidance published by the CFSI as it relates to downstream companies and incorporates the CFSI Conflict Minerals Reporting Template (“CMRT”), as well as the requirements of the Regulations and the Due Diligence Guidance for Responsible Supply Chains of Minerals From Conflict-Affected and High-Risk Areas of the Organization for Economic Cooperation and Development (“OECD”). As further described below, the elements of the Program are:
I. Determination of Product Applicability
II. The RCOI
III. Due Diligence
I. Determination of Product Applicability
Each year, Avaya creates a list of products and parts which it sold in the reporting calendar year that were contracted to be manufactured for Avaya and that include 3TG. Products purchased off the shelf from Original Equipment Manufacturers (“OEMs”) were excluded as Avaya is not the manufacturer of those products. This list, which was refined by assessing it against the Company’s previous year’s RCOI results, was provided to a third party partner to conduct Avaya’s RCOI.
II. Reasonable Country of Origin Inquiry (RCOI)
Avaya outsources the design of some, and the manufacture of all, of its products and solutions. Therefore, the RCOI included Avaya Electronic Manufacturing Services (“EMS”) providers, Original Design Manufacturers (“ODMs”) and Avaya-controlled suppliers (collectively with the EMS providers and the ODMs, the “Suppliers”) of parts and components used in Avaya-designed hardware products and parts that were sold to customers during calendar year 2015. Finished products and parts obtained from OEMs where the designs were not influenced by Avaya (i.e., products or parts which were purchased and included in Avaya solutions without modification or additional assembly) were excluded from the scope of the RCOI.
Avaya products and parts identified as containing the 3TGs not from recycled or scrap sources, which are in scope pursuant to the Regulations, consist of gateways, routers, servers, network infrastructure equipment and endpoints. As mentioned above, Avaya’s RCOI was conducted using the CMRT, which was provided to Suppliers, along with educational materials and training to facilitate their completion of the CMRT. In addition, Avaya leveraged information resources of the CFSI, publicly available information published by the London Bullion Market Association (“LBMA”) and the Responsible Jewelry Council (“RJC”), and the resources of Avaya’s conflict minerals partner to analyze the Supplier responses. The results of the information review were used to identify those Suppliers for which additional information and due diligence was required. The results of the assessments and the collected CMRTs were electronically stored.
III. Avaya’s Due Diligence Program
The Avaya Due Diligence Program was designed in accordance with the OECD five step framework, which is the international framework currently recognized for compliance with the Regulations.
For its Program, Avaya has adopted a management system similar in nature to the Avaya Quality and Environmental Management systems by implementing a ‘Plan-Do-Check-Act’ mechanism for its conflict minerals processes. Under this Program the Company has undertaken the following actions:
Avaya developed a Conflict Minerals Policy and communicated it to suppliers during the RCOI process and during annual supplier engagement forums. This policy is posted on the Avaya website at http://www.avaya.com/usa/about-avaya/our-company/corporate-responsibility/products-and-suppliers/. Avaya also developed Standard Operating Procedures (“SOPs”) that, with the Conflict Minerals Policy, define Avaya’s process for conducting the Program. A cross-functional team of subject matter experts was assembled from supply chain management, product compliance, product engineering, research and development, and the environmental and legal functions of the Company. Supply chain management leads the team and provides periodic updates to senior management.
Avaya joined the EICC and participates in CFSI, which allowed Avaya to learn from others in the electronics industry regarding their Conflict Minerals plans and processes. This led to Program improvements with greater supply chain and customer transparency.
Avaya continued to implement its document control program to manage and retain from year to year the documentation associated with each RCOI and related Due Diligence activities.
Avaya partnered with Suppliers to identify the sources of conflict minerals in the products and parts that they provide to Avaya as indicated in the RCOI results. Suppliers were also engaged through periodic business reviews and an annual supplier forum to discuss compliance requirements. If significant risks are identified through the RCOI program or other means then it could ultimately cause the Company to suspend trade with, or disengage from, a Supplier.
Step 2: Identify and Assess Risks in the Supply Chain
Avaya used the RCOI analysis results to identify Suppliers using SORs that are not engaged in an approved validation scheme (e.g., the CFSP list, LBMA, etc.) and to assess related supply chain risks.
To address the risks in the Company’s supply chain posed by the use of non-verified smelters, Avaya remains actively involved in the EICC and CFSI and in maintaining and executing the Avaya Conflict Minerals Program. Avaya continues to work with supply chain partners to address reported non-verified smelters. Avaya also works with supply chain partners for resolution when requests for smelters in the supply chain to participate in the CFSP list program are met with resistance or are not executed.
Step 4: Independent third-party audit of our SOR due diligence practices
As a downstream user of 3TG minerals and a member of the EICC, Avaya leverages information from the independent audits of the smelters and refiners facilitated by initiatives such as the CFSI’s CFSP and the LBMA to determine the SORs’ practices. To the extent required by the Regulations, Avaya will conduct an independent private sector audit of the Company’s Program if the RCOI and due diligence conclusively identifies the sources of the 3TG minerals used in our products as either conflict-free or non-conflict-free.
Step 5: Annual Reporting on our Supply Chain Due Diligence
Avaya continues to provide an annual report of its Supply Chain Due Diligence Practice activities in accordance with the Regulations, as evidenced by this Report. The Due Diligence results are summarized below.
Avaya’s RCOI process and due diligence to determine the source of 3TGs in Avaya products is based on data collection and partnership with Suppliers. Avaya queried 260 Suppliers for the 2015 RCOI reporting period with 100% of those surveyed providing an updated CMRT. 318 unique SORs were identified as processing 3TGs used in the parts and/or components contained in Avaya Products. 267 (or 84%) of the SORs identified by the Suppliers were verified as either (i) a conflict-free smelter through CFSP or (ii) participating in a CFSP audit. This represented a 14% increase from the previous year.
The majority of responses received from Avaya’s Suppliers during the RCOI were provided at the company level, with less than 10% of the responses specific to the product that such Supplier sells to Avaya. Two top tier Suppliers indicated their inability to obtain more than a 50% and 75% response rate, respectively, from their supply chain, making it impossible to determine the complete list of smelters in the Avaya supply chain. In addition, some SORs identified by the Suppliers were not listed on any certified smelter or refiners lists by the CFSI, the LBMA, or the RJC and could not be confirmed through Company due diligence as actual SORs. As a result, Avaya cannot determine its conflict-free status at either a product or company level because it cannot confirm that the SORs identified provide a complete picture of conflict minerals sourcing.
The 318 SORs identified by the Company’s in-scope Suppliers, the minerals processed, and their classification in regard to the CFSP list are provided in the list included as Appendix A of this Report. A graphical depiction of the 2015 RCOI and due diligence results is provided in Figure 1.0 (next page).
The validation classifications of the SORs reported in Appendix A and in the graphs are defined as follows:
CFSP Compliant (CFS) - These are certified conflict-free smelters
Participating in CFSP (CFSP) - These are smelters participating/progressing toward CFSP certification as a CFS
Not Listed on CFSP List (Not CFSP) - These are smelters that are neither CFSP Compliant nor Participating in the CFSP
Not a Legitimate SOR - These are non-CFSI verified smelters, or “unknown”
Figure 2 below presents a graphical depiction of the 2014 RCOI and due diligence results. Comparing the two results, the amount of SORs identified by the Company’s in-scope suppliers that are not a Conflict Free Smelter, (“CFS”, as verified by the CFSP), or part of the CFSP audit have reduced almost by half, from 30% to 16% over the past year.
Avaya plans to implement the following actions with its supply chain to help mitigate the risk of potentially sourcing conflict minerals:
Perform the RCOI process earlier in the calendar year to allow additional time for Supplier engagement and due diligence.
Continue to require completion of the CMRT in applicable Requests For Quote (“RFQ”) and from applicable new Suppliers upon award of contract (if not part of an RFQ).
Identify Suppliers with possible deficiencies in their responses or their management systems for additional monitoring and suggest resources such as the training available from the CFSI.
Identify Suppliers that based on past performance may need additional due diligence in the future.
Develop corrective action plans for Suppliers with identified deficiencies and track deficiency resolution.
This Conflict Minerals Report Exhibit 1.01 contains “forward-looking statements" about the Company’s future supply chain risk mitigation plans, diligence programs and conflict mineral management processes. All statements other than statements of historical fact are “forward-looking” statements for purposes of the U.S. federal and state securities laws. These statements may be identified by the use of forward looking terminology such as “anticipate,” “believe,” “continue,” “could,” “estimate,” “expect,” “intend,” “may,” “might,” “plan,” “potential,” “predict,” “should” or “will” or the negative thereof or other variations thereon or comparable terminology. The Company has based these forward-looking statements on its current expectations, assumptions, estimates and projections. While the Company believes these expectations, assumptions, estimates and projections are reasonable, such forward-looking statements are only predictions and involve known and unknown risks and uncertainties, many of which are beyond its control. These factors, including those discussed in Item 1A of the Company’s Annual Report on Form 10-K for the fiscal year ended September 30, 2015 under the heading "Risk Factors," may cause its actual risk mitigation plans, diligence programs, conflict mineral management processes, results, performance or achievements to differ materially from any future risk mitigation plans, diligence programs, conflict mineral management processes, results, performance or achievements expressed or implied by these forward-looking statements. For a further list and description of such risks and uncertainties, please refer to the Company’s filings with the SEC that are available at www.sec.gov. The Company cautions you that the list of important factors included in the Company’s SEC filings may not contain all of the material factors that are important to you. In addition, the matters referred to in the forward-looking statements contained in this report may not in fact occur. The Company undertakes no obligation to publicly update or revise any forward-looking statement as a result of new information, future events or otherwise, except as otherwise required by law.
List of Reported Smelters/Refiners Facilities Processing Minerals Used in Avaya Products as
Confirmed by the Conflict Free Smelter Initiative (CFSI) Lists
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.*
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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