Section 1 — Conflict Minerals Disclosure
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
Our Form SD and our Conflict Minerals Report for the year ended December 31, 2015 filed as Exhibit 1.01 to this Form SD are available at http://www.aseglobal.com/en/Csr/SupplyChainDevelopment.asp
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015
SIGNATURE
By:
/s/ Jason C.S. Chang
Jason C.S. Chang
Chief Executive Officer
Date: May 31,2016
EXHIBIT INDEX
Exhibit Description
Number
1.01 Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015
Advanced Semiconductor Engineering, Inc.
Conflict Minerals Report
For the year ended December 31, 2015
Advanced Semiconductor Engineering, Inc. (“ASE”, “we”, “our”, “us”) is among the leading providers of semiconductor packaging and testing services based on 2015 revenues. Our services include semiconductor packaging, production of interconnect materials, front-end engineering testing, wafer probing and final testing services, as well as integrated solutions for electronic manufacturing services in relation to computers, peripherals, communications, industrial, automotive, and storage and server applications. We utilize gold, tantalum, tin and tungsten which are necessary to deliver our packaging, materials and electronic manufacturing services.
We have manufacturing facilities located in Taiwan, China, Malaysia, Japan, Singapore, Korea and the United States that provide packaging, testing and materials services to many semiconductor companies around the world. A typical customer engagement involves receiving consigned silicon wafers from the customer, performing a series of manufacturing services to the wafers, and delivering a completed, packaged integrated circuit back to the customer. In the performance of packaging and materials services, we typically add gold and tin as direct materials in the manufacturing process, and we occasionally add tungsten and tantalum. We do not use gold, tin, tungsten or tantalum in our testing services.
Since our acquisition of a controlling interest in Universal Scientific Industrial Co., Ltd. in February 2010, we provide a broad range of electronic manufacturing services to a global customer base. We have manufacturing facilities located in Taiwan, China and Mexico that provide electronic manufacturing services. In providing these services, we acquire numerous electronic and non-electronic components, and assemble them into sub-assemblies and finished products. Typical materials and components which we utilize include solder (tin based), electrolytic capacitors (tantalum bearing), integrated circuits (gold wire) and high temperature wires (tungsten). Gold, tin, tungsten and tantalum are essential to our electronic manufacturing services.
All packaging and materials services and electronic manufacturing services we provide contain one or more of the conflict minerals: gold, tin, tungsten or tantalum.
Reasonable Country of Origin Inquiry (RCOI)
For our packaging and materials services, we purchase gold, tin, tungsten and tantalum from 116 suppliers. Each of these 116 suppliers has supplied us with the information required in a Conflict Minerals Reporting Template (CMRT) authored by the Electronic Industry Citizenship Coalition, Incorporated & Global e-Sustainability Initiative, or EICC-GeSI, with an accounting of their conflict mineral Smelters or Refiners (SoRs). Each of these 116 suppliers is in receipt of our conflict minerals policy, and each has confirmed their understanding of its principles and their willingness to comply.
For our electronic manufacturing services, we performed an assessment of all 1,316 suppliers who provided us with gold, tin, tungsten or tantalum in 2015 and selected 262 suppliers for our 2015 Conflict Minerals Report based on (1) suppliers from whom we purchased greater than USD $6 million in purchase volume (which collectively accounted for 95% of our total purchase volume) and (2) suppliers whose conflict minerals are used in the services we provide to our top three customers.
Below are the results of our Reasonable Country of Origin Inquiry, or RCOI.
Gold – Packaging and Materials Services
1. During 2015, we purchased gold for our packaging and materials services from a total of 51 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from third parties. Based on data we collected, we identified a total of 122 SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services. All 51 of our gold suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced gold during 2015, representing 100% of our total expenditure for gold during 2015 for our packaging and materials services.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 95 of the SoRs from which we indirectly purchased gold in 2015 for our packaging and materials services are participants in at least one of (i) the Conflict-Free Smelter Program (CFSP) operated by the Conflict-Free Sourcing Initiative (CFSI), (ii) the Gold Industry— London Bullion Market Association (LBMA), or (iii) the Gold Industry— Responsible Jewellery Council (RJC).
3. The following table summarizes our RCOI results for gold purchased for our packaging and materials services in 2015.
Gold – Electronic Manufacturing Services
1. During 2015, we purchased gold for our electronic manufacturing services from a total of 182 suppliers. None of these suppliers are SoRs, and all these suppliers purchased gold from SoRs or from other third parties. Based on data we collected, we identified 132 SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services. One-hundred eighty of our gold suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced gold during 2015. Two did not respond.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 97 of the SoRs from which we indirectly purchased gold in 2015 for our electronic manufacturing services are participants in at least one of (i) the CFSP operated by the CFSI, (ii) the LBMA, or (iii) the RJC.
3. The following table summarizes our RCOI results for gold purchased for our electronic manufacturing services in 2015.
Tin – Packaging and Materials Services
1. During 2015, we purchased tin for our packaging and materials services from a total of 63 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified a total of 82 SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services. All 63 of our tin suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tin during 2015, representing 100% of our total expenditure for tin during 2015 for our packaging and materials services.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 66 of the SoRs from which we indirectly purchased tin in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI.
3. The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015.
Tin – Electronic Manufacturing Services
1. During 2015, we purchased tin for our electronic manufacturing services from a total of 212 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tin from SoRs or from other third parties. Based on data we collected, we identified 96 SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015. Two-hundred ten of our tin suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tin during 2015. Two did not respond.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 68 of the SoRs from which we indirectly purchased tin for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI.
3. The following table summarizes our RCOI results for tin purchased for our electronic manufacturing services in 2015.
Tungsten – Packaging and Materials Services
1. During 2015, we purchased tungsten for our packaging and materials services from a total of 4 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from a SoR or another third party. Based on data we collected, we identified 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015. Our 4 tungsten suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tungsten during 2015, representing 100% of our total expenditure for tungsten for our packaging and materials services during 2015.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, the 5 SoRs from which we indirectly purchased tungsten for our packaging and materials services in 2015 are participants in the CFSP operated by CFSI or participants in the Tungsten Industry—Conflict Minerals Council, or TI-CMC.
3. The following table summarizes our RCOI results for tungsten purchased for our packaging and materials services in 2015.
Tungsten – Electronic Manufacturing Services
1. During 2015, we purchased tungsten for our electronic manufacturing services from a total of 119 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tungsten from SoRs or from other third parties. Based on data we collected, we identified 45 SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015. One hundred seventeen of our tungsten suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tungsten during 2015. Two did not reply.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 41 of the SoRs from which we indirectly purchased tungsten for our electronic manufacturing services in 2015 are participants in either the CFSP operated by the CFSI or the TI-CMC program.
3. The following table summarizes our RCOI results for tungsten purchased for our electronic manufacturing services in 2015.
Tantalum – Packaging and Materials Services
1. During 2015, we purchased tantalum for our packaging and materials services from a total of 2 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on data we collected, we identified a total of 2 SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services. All 2 of our tantalum suppliers for our packaging and materials services responded to our request to identify the SoRs from which they sourced tantalum during 2015, representing 100% of our total expenditure for tantalum during 2015 for our packaging and materials services.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 2 of the SoRs from which we indirectly purchased tantalum in 2015 for our packaging and materials services are participants in the CFSP operated by the CFSI.
3. The following table summarizes our RCOI results for tin purchased for our packaging and materials services in 2015.
Tantalum – Electronic Manufacturing Services
1. During 2015, we purchased tantalum for our electronic manufacturing services from a total of 89 suppliers. None of these suppliers are SoRs, and all these suppliers purchased tantalum from SoRs or from other third parties. Based on the data collected, we identified 49 SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015. Eighty-seven of our tantalum suppliers for our electronic manufacturing services responded to our request to identify the SoRs from which they sourced tantalum during 2015. Two did not reply.
2. Based on an inspection of the list available at www.conflictfreesourcinginitiative.org conducted on December 31, 2015, 47 of the SoRs from which we indirectly purchased tantalum for our electronic manufacturing services in 2015 are participants in the CFSP operated by the CFSI.
3. The following table summarizes our RCOI results for tantalum purchased for our electronic manufacturing services in 2015.
Part I. Due Diligence
Design of Due Diligence
ASE designed its due diligence measures to conform to the Organization 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, including the related supplements on tantalum, tin, tungsten, and gold.
Due Diligence Measures Performed
OECD Step 1
Establish strong company management systems
A. Adopt and clearly communicate to suppliers and public
The ASE Group Corporate Policy for Sourcing Conflict Minerals is posted on our website (and attached here as Annex A) as well as distributed to each of our suppliers of conflict minerals who must agree in writing that the policy will be complied with.
Additionally, we require each supplier to certify they understand our conflict minerals policy and will comply with its covenants.
Finally, every factory manager must certify they comply with our conflict minerals policy. They are also responsible for communicating the policy throughout their organizations and implementing procedures to ensure compliance.
B. Structure internal management to support due diligence
Our conflict minerals management team is a comprehensive cross-functional team under the direction of our Chief Operating Officer. The team provides planning, analysis, management, tracking, monitoring and communication for the business wide initiative. They hold regular and frequent meetings to ensure progress against requirements.
C. Establish a system of controls and transparency over the mineral supply chain
Conflict minerals procedures are documented in our specifications system and managed by our quality control organization. The bills-of-materials required for different customer products across all manufacturing operations are controlled by our manufacturing execution system software.
The primary method for gathering conflict mineral data is through the deployment and gathering of Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Templates (CMRTs). We store this data on a comprehensive filing system and maintain other related records for a minimum of five years.
Aligned with industry practice, we designed a conflict minerals data tool with simple functions that manages large number of supplier CMRTs, auto-validates smelter status with real-time CFSI smelter list and aggregates smelter reporting for our customers.
D. Strengthen company engagement with suppliers
In addition to formal written documentation, ASE is building person-to-person links between employees and suppliers to improve the quality and consistency of vendor communications.
We held an annual supplier seminar to announce new requirements, and provided training to suppliers to enable them to better understand how to set up their conflict minerals monitoring mechanism and to improve smelter data quality.
We amended and added conflict minerals terms to our ASE Group Purchase Order pursuant to which our suppliers agree (i) to use industry standard efforts to ensure that gold, tantalum, tungsten and tin in materials covered by the purchase order and sourced from mines in the Democratic Republic of the Congo or its adjacent regions do not directly or indirectly finance illegal militia in the Democratic Republic of the Congo or its adjacent regions, (ii) to promptly notify us if any materials covered by the purchase order do contain conflict minerals that are not DRC Conflict Free and to provide a report on the mine and/or smelter of origin of the conflict minerals and the related chain of custody and (iii) to only supply us with materials that contain DRC Conflict Free minerals sourced from certified DRC Conflict Free smelter and refinery programs.
E. Establish grievance mechanism
ASE encourages suppliers and employees to have open and honest dialog on issues of mutual interest.
We provide two email addresses (ASE_CM@aseglobal.com and conflictminerals@ms.usi.com.tw) for general surveys, inquiries and grievances regarding our conflict minerals program.
OECD Step 2
Identify and assess risk in the supply chain
A. Identify risks in the supply chain
Our process for identifying conflict minerals risk in the supply chain is as follows:
(a) Identify all direct materials and components in the supply chain that contain conflict minerals.
(b) Identify suppliers of materials and components that contain conflict minerals.
(c) Gather CMRTs from our suppliers of conflict minerals.
(d) Depending on the enormity and complexity of the supply chain:
Assess the value of the annual purchase volume of all conflict minerals.
Prioritize conflict mineral sources by dollar volume to leverage impact from available analytical resources.
B. Assess risks of adverse impacts
(a) Assess data gathered on templates to identify potential inconsistencies or “red flags.”
(b) Define annual supplier risk criteria.
(c) Carry out on-site or document audit for suppliers determined as at-risk suppliers according to the risk criteria.
(d) Follow up as appropriate to resolve items of concern.
OECD Step 3
Design and implement a strategy to respond to identified risks
A. Report finding to designated senior management
Periodic reviews are held among team members and with senior management to ensure they are aware of current conflict minerals compliance status.
B. Devise and adopt a risk management plan
In 2015, we compared supplier smelter data to CFSI RCOI data (when available) to identify actual smelter origins.
We used a corporate standard conflict minerals audit checklist and implemented an on-site or document audit process to validate suppliers’ mechanisms related to important aspects of conflict minerals management.
C. Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management
Our packaging and materials services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.
(b) For compliance year 2015, we received CMRTs from 100% of our conflict mineral suppliers.
Our electronic manufacturing services mitigate supply chain risk to conflict minerals in two ways:
(a) We work with non-compliant suppliers to obtain CFSP certification, or an equivalent. Suppliers unwilling or incapable of achieving such certification are replaced with compliant suppliers.
(b) For compliance year 2015, our electronic manufacturing services identified 262 suppliers that accounted for 95% of our total purchase volume and whose conflict minerals are used in the services we provide to our top 3 customers; we received CMRTs from 99.2% of these conflict mineral suppliers.
D. Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances
We have begun supplier audits to assess the accuracy of data and statements made by larger suppliers. This program will be broadened over time.
As a member (code: ASEG) of the EICC and CFSI, RCOI data is accessible to use and to manage our supplier smelter data.
OECD Step 4
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
For CY 2015, ASE has undertaken an Independent Private Sector Audit (IPSA) of our Conflict Minerals Report in compliance with the requirements set forth in the SEC Conflict Minerals Final Rule and subsequent SEC Guidance.
In addition, as a member of CFSI, we leverage the due diligence conducted on smelters by the CFSP which uses independent third-party auditors to audit the source of the conflict minerals used by smelters.
OECD Step 5
Report on supply chain due diligence.
ASE filed a Form SD and Conflict Minerals Report for Compliance Year 2015 with the US Securities and Exchange Commission on or before the May 31, 2016 deadline in compliance with the SEC Conflict Minerals Final Rule and subsequent guidance.
Part II. Due Diligence Determination and Product Declaration
Product Declaration
Our RCOI results did not provide us a sufficient level of confidence to enable us to report that all our products are conflict-free. Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, we therefore conducted additional due diligence on the source and chain of custody of the necessary conflict minerals in our products in order to obtain reasonable and reliable evidence that the gold, tin, tungsten or tantalum used by us in 2015 either (i) did not directly or indirectly benefit violent organizations in the Democratic Republic of the Congo or adjacent regions or (ii) came from recycled or scrap sources.
Based on our RCOI analysis and due diligence measures described in this report, we made the following product determinations.
Packaging and Materials Services:
We reasonably believe that the identified SoRs used in all our packaging and materials services products are DRC Conflict-Free.
Electronic Manufacturing Services:
We reasonably believe that the identified SoRs used in our System in Module and System in Package products are DRC Conflict-Free. And all other products from our electronic manufacturing services are DRC Conflict Undeterminable.
Glossary
A glossary of abbreviations and terms is included in Annex C.
Facilities used to Process Conflict Minerals
A list of Smelters and Refiners that sourced conflict minerals utilized in our services is provided in Annex D.
Conflict Minerals Country of Origin
A list of countries where conflict minerals were mined or extracted is listed in Annex E. These minerals may have been smelted or refined in the country of extraction or in facilities around the world.
Part III – Future Due Diligence Improvements
Set conflict minerals requirements for new suppliers. Beginning from 2016, we have required new suppliers to first agree to submit a CMRT and a representation letter confirming that they are in compliance with ASE’s conflict minerals policy and requirements.
Work with tier 1 suppliers to ensure that smelters are actively participating or progressing toward CFSP listing or other Third Party Audit Programs.
Assess suppliers’ due diligence processes through on-site audits so as to assist suppliers to build up and improve their internal management systems.
Enhance our conflict minerals data tool with advanced management and analysis functionalities.
Annually hold supplier seminars to assist suppliers with their conflict minerals programs.
Part IV – Independent Private Sector Audit
We obtained an independent private sector audit by KPMG. This report is set forth in Annex B.
Annex A – ASE Group Corporate Policy for Sourcing Conflict Minerals
The mining and distribution of “conflict minerals”1 originating from the Democratic Republic of the Congo are sometimes controlled by violent organizations in order to fund conflict in that country and adjacent regions. Our industry supply chains are inadvertently subject to metals derived from these conflict minerals which can be introduced through the metals we use such as gold, tin, tantalum and tungsten. ASE Group is dedicated to the elimination of these conflict minerals in our supply chain, and to use only conflict-free minerals2 responsibly sourced around the world. It is also our objective to support the continued use of conflict-free minerals from the DRC and the adjacent regions such that responsible mining is not diminished.
All suppliers to ASE Group must support this policy by:
(a) Being diligent in their assessment and validation of their supply chains to ensure ASE Group’s objectives of a transparent supply chain and conflict-free purchases are inputs to the services and products we produce.
(b) Be in compliance at all times with all regional and international regulations for conflict minerals.
(c) Be in compliance at all times with industry standards for the sourcing and reporting of conflict minerals.
(d) Being diligent and accurate in their formal assurances of conflict-free minerals provided to us.
Conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives as defined in the Dodd-Frank Act section 1502 and SEC Rule 13p-1 under the Securities Exchange Act of 1934.
Conflict-free minerals are conflict minerals that through their distribution directly or indirectly do not benefit violent organizations in the Democratic Republic of the Congo and its adjacent regions.
Annex B –Independent Accountants’ Report
Independent Accountants’ Report
To the Board of Directors and Shareholders of Advanced Semiconductor Engineering Inc.:
We have examined:
• whether the design of Advanced Semiconductor Engineering Inc. (the “Company”) due diligence framework as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2015 (the “Conflict Minerals Report”), is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”), and
• whether the Company’s description of the due diligence measures it performed, as set forth in the section titled “Part I. Due Diligence” of the Company’s Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook.
Management from the Company is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination.
Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.
Our examination was not conducted for the purpose of evaluating:
The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance;
The completeness of the Company’s description of the due diligence measures performed;
The suitability of the design or operating effectiveness of the Company’s due diligence process;
Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance;
The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or
The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the section titled “Part I. Due Diligence.”
In our opinion,
• the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2015, as set forth in the Company’s Conflict Minerals Report, is in conformity, in all material respects, with the OECD Due Diligence Guidance, and
• the Company’s description of the due diligence measures it performed for the reporting period from January 1 to December 31, 2015 as set forth in its Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook.
/s/ KPMG
Taipei, Taiwan (the Republic of China)
May 31, 2016
Annex C – Glossary
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.*
Annex E – Countries of Origin of Conflict Minerals
It is likely that we used conflict minerals from many of the following sources as well as some that are not identified.
Angola
Argentina
Australia
Austria
Belgium
Bolivia
Brazil
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Côte D'Ivoire
Czech Republic
Democratic Republic of the Congo
Djibouti
Ecuador
Egypt
Estonia
Ethiopia
France
Germany
Guyana
Hungary
India
Indonesia
Ireland
Israel
Japan
Kazakhstan
Kenya
Laos
Luxembourg
Madagascar
Malaysia
Mongolia
Mozambique
Myanmar
Namibia
Netherlands
Nigeria
Peru
Portugal
Republic of Congo
Russia
Rwanda
Sierra Leone
Singapore
Slovakia
South Africa
South Korea
South Sudan
Spain
Suriname
Switzerland
Taiwan
Tanzania
Thailand
Uganda
United Kingdom
United States of America
Vietnam
Zambia
Zimbabwe
No comments:
Post a Comment