Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
This Form SD of C. R. Bard, Inc. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2015 through December 31, 2015. The Company has evaluated its product lines and its supply chain to determine whether its products may contain tin, tantalum, tungsten or gold, each defined as a “conflict mineral” pursuant to Section 13(p) of the Exchange Act and Rule 13p-1 and Form SD thereunder, due to the presence of one or more of these minerals in
parts obtained from suppliers or from the utilization of one or more of these minerals in the Company’s or its suppliers’ manufacturing processes in circumstances where the particular mineral or minerals remain in the final product sold by the Company. The Company has determined that certain of the products it manufactures, or contracts with third parties to manufacture, contain gold, tin, tantalum, or tungsten.
The Company further determined that these conflict minerals are necessary to the functionality or production of the products in which they are included (“necessary conflict minerals”) and therefore undertook a good-faith, reasonable country of origin inquiry (“RCOI”) in accordance with its obligations under Section 13(p) of the Exchange Act and Rule 13p-1 and Form SD thereunder, to determine whether any necessary conflict minerals originated in the Democratic Republic of the
Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”) and, if so, whether any such minerals directly or indirectly financed or benefited armed groups in any of the Covered Countries.
The following is a brief summary of our RCOI process, which overlapped substantially with the due diligence measures we undertook after being unable to determine, with respect to at least some of the Company’s products, either: (1) the country or countries of origin of all of our necessary conflict minerals; or (2) that the necessary conflict materials came from scrap or recycled materials.
After concluding that conflict minerals are necessary to the functionality or production of some of its products, the Company conducted a good-faith RCOI to determine whether any of its products, including components or parts thereof, or manufacturing processes contained conflict minerals that originated in a Covered Country. The Company identified approximately 210 known direct suppliers, or Tier 1 suppliers, of products or components that potentially contain the necessary conflict minerals and requested those suppliers disclose whether such products or components contained the necessary conflict minerals and if so, to provide the Company with country of origin, processing facility and/or mine or other extraction point information with respect to such necessary conflict minerals. Our
information request was based on a model supplier inquiry letter created by The Organisation for Economic Co-operation and Development (“OECD”) as part of the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, including the supplements on tin, tantalum, tungsten and gold (the “OECD Due Diligence Guidance”). The Company requested these Tier 1 suppliers provide their responses through a software tool, which included the EICC-GeSI’s Conflict-Free Sourcing Initative reporting template.
The Company’s due diligence process was a continuation of its RCOI process for those Tier 1 suppliers that indicated in their response that they supplied necessary conflict minerals to the Company and the Company went on to exercise due diligence on the source and chain of custody of these conflict minerals, as discussed more fully in the attached Conflict Minerals Report.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and, together with our Form SD, is publicly available at http://www.crbard.com/Social-Responsibility/Conflict-Minerals.html. The content of any website referred to in this Form SD or the attached Conflict Minerals Report is not incorporated by reference into this Form SD or the attached Conflict Minerals Report (Exhibit 1.01 hereto).
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report of C. R. Bard, Inc. as required by Items 1.01 and 1.02 of this Form SD.
SIGNATURES
C. R. BARD, INC.
By: /s/ Christopher S. Holland
Name: Christopher S. Holland
Title: Senior Vice President and
Chief Financial Officer
Date: May 19, 2016
C. R. Bard, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2015 to December 31, 2015
Overview
The Company is engaged in the design, manufacture, packaging, distribution and sale of medical, surgical, diagnostic and patient care devices. Currently, the Company sells a broad range of products to hospitals, individual healthcare professionals, extended care facilities and alternate site facilities on a global basis. In general, the Company’s products are intended to be used once and then discarded or either temporarily or permanently implanted. The Company participates in the markets for vascular, urology, oncology and surgical specialty products. For a more detailed discussion of our products, see our Annual Report on Form 10-K for the fiscal year ended December 31, 2015. The information contained in our Annual Report on Form 10-K is not incorporated by reference into and should not be
considered part of this Conflict Minerals Report or the Form SD with which this Report has been filed as an exhibit.
As a medical device manufacturer, the Company does not engage in the actual mining of conflict minerals, and does not purchase raw ore or unrefined conflict minerals from any source. Nor does the Company directly purchase any product, mineral or any other materials (including but not limited to any conflict mineral) from any source in the Democratic Republic of the Congo (“DRC”), or any of the adjoining countries (collectively, the “Covered Countries”). We do not conduct business, or otherwise have any direct relationship, with any smelter or refiner that processes any necessary conflict minerals contained in our products. Instead, as discussed below, there are typically several tiers of suppliers between the Company and the facilities in which these minerals were smelted or refined.
Due Diligence Program Design
The Company designed its due diligence measures relating to conflict minerals to conform, in all material respects, with the criteria set forth in the Organisation for Economic Co-Operation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, including the supplements on tin, tantalum, tungsten and gold (the “OECD Due Diligence Guidance”). It is important to note that,
while the OECD Due Diligence Guidance creates a single, five-step framework for due diligence, there are different expectations for manufacturers like the Company, referred to as “downstream companies”, that are far removed in the supply chain not only from the mines or other, original sources of any necessary conflict minerals, but also the processing facilities for these minerals. In the case of “downstream companies”, like the Company, the OECD Due Diligence Guidance seeks to promote constructive engagement with suppliers in order to gradually effect changes in supplier sourcing practices. As explained below, there are typically several tiers of suppliers between the Company and smelters, refiners, mines or other points of origins of the necessary conflict minerals contained in our products.
Due Diligence Program Execution
The Company performed the following due diligence measures for the 2015 reporting period, based on the five-step framework outlined in the OECD Due Diligence Guidance.
1. Establish strong company management systems
The Company has developed a process to comply with the Rule. In connection with this process, the Company designated a conflict minerals steering committee (the “Committee”) comprised of representatives from senior management, global strategic sourcing, finance, internal audit and the law department. The Committee was charged with implementing the Company’s conflict minerals compliance strategy, including the establishment of a policy with respect to sourcing of conflict
minerals from the Covered Countries, making this policy available on the Company’s website at http://www.crbard.com/Social-Responsibility/Conflict-Minerals.html, incorporating a provision in supplier contracts to provide the Company with country of origin information of any necessary conflict minerals, and implementing a supply chain due diligence process focusing on constructive engagement with our Tier 1 suppliers, in part through use of software based tools, which include the EICC-GeSI’s Conflict-Free Sourcing Initiative (“CFSI”) reporting template, to assist in the conflict mineral reporting process.
2. Identify and assess risks in the supply chain
The Company has evaluated its product lines and its supply chain to determine whether its products may contain conflict minerals, due to the presence of such minerals in parts obtained from suppliers or from the utilization of such minerals in the Company’s or its suppliers’ manufacturing processes. To the extent such conflict minerals are contained in its products, the Company has determined that these conflict minerals are necessary to the functionality or production of the products in which they are included (“necessary conflict minerals”).
The Company identified approximately 210 known direct suppliers, or Tier 1 suppliers, of products or components that the Company believed were most likely to contain the necessary conflict minerals and requested those suppliers disclose whether such products or components contained the necessary conflict minerals and if so, to provide the Company with country of origin information with respect to such necessary conflict minerals. Our information request was based on a model supplier inquiry letter created by the OECD as part of the OECD Due Diligence Guidance and the Company requested these Tier 1 suppliers provide their responses through a software tool, which included the EICC-GeSI reporting template.
3. Design and implement a strategy to respond to identified risks
The Company implemented a process to review the responses provided by its Tier 1 suppliers. To the extent supplier responses were incomplete or inconsistent, the Company conducted follow-up inquiries with those suppliers. In addition, the Company engaged further with suppliers that indicated the presence of conflict minerals but were unable to verify the source of such minerals or did not respond to the request for country of origin information. The results of the Company’s findings were reported back to the Committee.
As a “downstream company”, the Company has no direct relationships with mine operators or the smelters or refineries which process minerals that may ultimately be incorporated into the Company’s products. As noted, we are typically several tiers removed in the supply chain from mining, smelting or refining activity. Accordingly, and consistent with the OECD Due Diligence Guidance, the Company worked directly with its Tier 1 suppliers to obtain, where possible, information on the origin and sourcing of the necessary conflict minerals contained in items supplied by such Tier 1 suppliers.
The Company’s relative location within the supply chain, several tiers removed from the extraction, transport and refinement of ore and other sources of necessary conflict minerals, makes it difficult for the Company to trace these minerals back to their country of origin. The Company is dependent on its Tier 1 suppliers for this purpose.
4. Carry out independent third party audit of supply chain due diligence at identified points in the supply chain
Because the Company does not have a direct relationship with smelters or refiners that process conflict minerals, we do not typically perform or direct audits of these entities within our supply chain. The Company utilizes the lists of smelters and refiners produced by the CFSI’s Conflict-Free Smelter Program (“CFSP”) to determine which facilities identified by our Tier 1 suppliers have either undergone an audit conducted by an independent third party, or have agreed to undergo or are undergoing such an audit. (See Appendix A). The Company supports the development and implementation of independent third party audits of smelters and refineries sourcing sponsored by private-sector initiatives, such as the CFSI through its CFSP, that are dedicated to compliance with the OECD Due Diligence Guidance.
5. Report on supply chain due diligence
The Company has filed a Form SD and this Report with the Securities and Exchange Commission (“SEC”) and made copies of the Form SD and this Report available on our website at http://www.crbard.com/Social-Responsibility/Conflict-Minerals.html.
Due Diligence Results, Product Information and Additional Risk Mitigation Efforts
Reasonable Country of Origin Inquiry and Due Diligence Results
After making the threshold determination that necessary conflict minerals were contained in some of its products, the Company conducted a good-faith, reasonable country of origin inquiry (“RCOI”) to determine whether its products or manufacturing processes do, in fact, contain or use conflict minerals that originated in a Covered Country. The Company contacted approximately 210 of its Tier 1 suppliers requesting that such suppliers disclose the presence of necessary conflict minerals and if present, to provide us with country of origin, processing facility and/or mine or other extraction point information with respect to such necessary conflict minerals. As discussed further below, one Tier 1 supplier disclosed that some of the necessary conflict minerals supplied to the Company was obtained
from one or more of its own suppliers, some of whom stated that such conflict minerals originated from one or more of the Covered Countries and did not derive from recycled or scrap sources. All but approximately 12 of the Company’s remaining Tier 1 suppliers confirmed that the conflict minerals in question were derived from recycled or scrap sources or from countries other than the Covered Countries.
The Company’s due diligence process was a continuation of its RCOI process for those Tier 1 suppliers that indicated in their responses that they supplied necessary conflict minerals to the Company. The Company reviewed additional documentation from those suppliers for data verification and consistency. Based on the responses and the documentation reviewed, where applicable, the Company contacted suppliers to obtain additional information regarding the necessary
conflict minerals supplied. As stated above, approximately 12 suppliers were unable to provide information regarding the country of origin of the conflict minerals, the facilities where these minerals may have been refined or smelted, or the mines from which they may have been extracted. In most cases, this was due to the fact that these Tier 1 suppliers had not completed their own supply chain due diligence or were otherwise unable to obtain the necessary information from their suppliers. Based on its engagement with these suppliers, the Company believes such suppliers are working to enhance their own supply chain due diligence in order to provide improved reporting in future periods.
As stated above, one of the Company’s Tier 1 suppliers advised the Company that some of the necessary conflict minerals supplied by one or more of its own suppliers originated in one or more of the Covered Countries, and did not derive from recycled or scrap sources. However, this supplier did not provide the Company with any additional information enabling the Company to pinpoint the identity or location of the specific processing facility or facilities corresponding to any of the relevant products it supplied to the Company. Due to the lack of detail provided by the supplier, the Company was unable to confirm that the necessary conflict minerals in its products were processed by any particular smelter or refiner and its, therefore, unable to identify the processing facilities or the origin for such conflict minerals.
The Company’s process described above reflects its efforts to determine the mines or country of origin of the necessary conflict minerals, as well as the relevant processing facilities. The statements above are based on the RCOI process and due diligence performed in good faith by the Company and on the information available at the time the RCOI process was implemented and due diligence performed. A number of factors could introduce errors in this report including, but not limited to: gaps in product or product content information, gaps in supplier data, errors or omissions by or of suppliers, incomplete due diligence by Tier 1 suppliers, gaps in supplier education and knowledge, lack of timeliness of data, language barriers and translation, and smuggling of conflict minerals to countries beyond the Covered Countries.
Product Description and Processing Facilities
Products – The products subject to disclosure under the Rule include vascular products, urology products, oncology products and surgical specialty products.
Processing Facilities – As a “downstream company”, the Company has no direct relationships with mine operators or the smelters or refineries which process minerals that may ultimately be incorporated into the Company’s products. Due to the Company’s relative location within the supply chain, it makes it difficult for the Company to trace these minerals back to the facilities in which they were processed. Therefore, the Company is dependent on its Tier 1 suppliers for providing the list of processing facilities and is unable to verify this list beyond what is provided to it by its Tier 1 suppliers. Based on the responses received from the Company’s Tier 1 suppliers, the Company believes the facilities listed in Appendix A may have been used in the processing of necessary conflict minerals used in its products.
Risk Mitigation – Improvement Program
For the 2016 reporting cycle, the Company plans to take certain measures to mitigate the risk that conflict minerals will benefit or finance armed groups in the Covered Countries, including the following:
• Continue to follow a due diligence process that conforms, in all martial respects, with the OECD Due Diligence Guidance, expanding and otherwise improving upon our supply chain inquiry process as necessary and appropriate in light of our experience under the conflict minerals disclosure regime, as well as refining our software solution to further automate the RCOI and due diligence processes
• Continue to work with suppliers who provided incomplete or insufficient information
• Continue to educate our suppliers about our reporting obligations related to conflict minerals
• Encourage the continuing development and progress of traceability measures at suppliers that indicated the source of conflict minerals was uncertain or unknown
• Communicate our sourcing expectations to suppliers, including dissemination of our Conflict Minerals Policy to them
• Continue to compare the list of smelters identified through our good faith RCOI and related due diligence process to the evolving lists of smelters and/or refiners that have been designated as “compliant” or “conflict free” through independent “conflict free” smelter/refiner designation programs (e.g., the CFSI’s CFSP) requiring independent third party audits (among other eligibility requirements), and encourage our suppliers to implement measures in their supply chains to use smelters and refiners that participate in such programs.
In accordance with the SEC’s current guidance, this report has not been subject to an independent private sector audit.
Appendix A
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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