UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
XEROX CORPORATION
(Exact name of registrant as specified in its charter)
| New York | 001-04471 | 16-0468020 | ||
| (State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
P. O. Box 4505
45 Glover Avenue
Norwalk, Connecticut
06856-4505
Registrant’s telephone number, including area code: (203) 968-3000
Not Applicable
(Former name or former address, if changed since last report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Section 1 – Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available on our website at www.xerox.com and under “Chairman’s Message - Conducting business with integrity” at www.xerox.com/about-xerox/citizenship/miss-enus.html as well as the SEC’s EDGAR database at www.sec.gov. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Section 2 – Exhibits
Item 2.01 – Exhibits
Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2014 to December 31, 2014 as required by Items 1.01 and 1.02 of this Form.
Forward Looking Statements
This Specialized Disclosure Report on Form SD and any exhibits to this Report may contain “forward-looking statements” as defined in the Private Securities Litigation Reform Act of 1995. The words “anticipate,” “believe,” “estimate,” “expect,” “intend,” “will,” “should,” and similar expressions, as they relate to us, are intended to identify forward-looking statements. These statements reflect Management’s current beliefs, assumptions and expectations and are subject to a number of factors that may cause actual results to differ materially. Such factors include but are not limited to: changes in economic conditions, political conditions, trade protection measures, licensing requirements and tax matters in the United States and in the foreign countries in which we do business; changes in foreign currency exchange rates; our ability to successfully develop new products, technologies and service offerings and to protect our intellectual property rights; the risk that multi-year contracts with governmental entities could be terminated prior to the end of the contract term and that civil or criminal penalties and administrative sanctions could be imposed on us if we fail to comply with the terms of such contacts and applicable law; the risk that our bids do not accurately estimate the resources and costs required to implement and service very complex, multi-year governmental and commercial contracts, often in advance of the final determination of the full scope and design of such contracts or as a result of the scope of such contracts being changed during the life of such contracts; the risk that subcontractors, software vendors and utility and network providers will not perform in a timely, quality manner; service interruptions; actions of competitors and our ability to promptly and effectively react to changing technologies and customer expectations; our ability to obtain adequate pricing for our products and services and to maintain and improve cost efficiency of operations, including savings from restructuring actions and the relocation of our service delivery centers; the risk that individually identifiable information of customers, clients and employees could be inadvertently disclosed or disclosed as a result of a breach of our security systems; the risk in the hiring and retention of qualified personnel; the risk that unexpected costs will be incurred; our ability to recover capital investments; the risk that our Services business could be adversely affected if we are unsuccessful in managing the start-up of new contracts; the collectibility of our receivables for unbilled services associated with very large, multi-year contracts; reliance on third parties, including subcontractors, for manufacturing of products and provision of services; our ability to expand equipment placements; interest rates, cost of borrowing and access to credit markets; the risk that our products may not comply with applicable worldwide regulatory requirements, particularly environmental regulations and directives; the outcome of litigation and regulatory proceedings to which we may be a party; and other factors that are set forth in the “Risk Factors” section, the “Legal Proceedings” section, the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” section and other sections of our Quarterly Report on Form 10-Q for the quarter ended March 31, 2015 and our 2014 Annual Report on Form 10-K filed with the Securities and Exchange Commission as well as in our Current Reports on Form 8-K. Xerox assumes no obligation to update any forward-looking statements as a result of new information or future events or developments, except as required by law.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned duly authorized.
Date: May 4, 2015
| XEROX CORPORATION | ||
| By: | /s/ Hervé Tessler | |
| Hervé Tessler | ||
| Senior Vice President | ||
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EXHIBIT INDEX
| Exhibit Number |
Description | |
| 1.01 | Conflict Minerals Report for the reporting period January 1, 2014 to December 31, 2014 | |
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Exhibit 1.01
Conflict Minerals Report
Xerox Corporation
For the Year Ended December 31, 2014
This report for the year ended December 31, 2014 is made by Xerox Corporation and its subsidiaries (Xerox) in compliance with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (3TG). These requirements apply to registrants regardless of the geographic origin of the conflict minerals and whether or not the trading in those minerals benefits armed groups.
If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries), or a registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the source and chain of custody of those conflict minerals. The registrant must annually submit a specialized disclosure (Form SD) and Conflict Minerals Report (CMR) to the SEC that includes a description of those due diligence measures.
| 1. | COMPANY OVERVIEW |
Xerox is the world’s leading enterprise for business process and document management solutions. Its two largest operating segments are Services, which includes business process outsourcing and document outsourcing, and Document Technology, which includes the sale of products and supplies, as well as the associated technical service and financing of those products. Xerox’s Document Technology products include but are not limited to multifunction printers/copiers, scanners, and multifunction/all in one printers, digital printing equipment, production printers & digital presses, continuous feed printers, wide format printers and consumables (e.g., toner cartridges). The Services segment includes the following products: ticket vending machines, parking payment stations, automated coin machines, in-vehicle units and media information displays. These products are more fully described on our Xerox website, which can be accessed at www.xerox.com.
The content of any website referred to in this CMR is included for general information only and is not incorporated by reference in this Report.
| 2. | OUR CONFLICT MINERALS PROGRAM |
2.1 Supply Chain
Xerox is many steps removed from the mining of conflict minerals. The origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The 3TG smelters or refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. Xerox has conducted an analysis of our products and found that, although we do not directly purchase conflict minerals from our suppliers, Xerox purchases products, component parts and materials that contain metals, some of which contain conflict minerals. We rely on our Tier 1 suppliers to provide information on the origin of the conflict minerals contained in components that are included in our products by using the CFSI Conflict Minerals Reporting Template (CMRT), which allows us to perform our Reasonable Country of Origin Inquiry.
2.2 Management Systems
Policy
Xerox has adopted a company policy which is posted on our website under “Chairman’s Message - Conducting business with integrity” at www.xerox.com/about-xerox/citizenship/miss-enus.html.
Internal Team
Xerox has established a management system for conflict minerals. Our management system includes a Senior Management Steering Committee sponsored by the President of Corporate Operations, who reports directly to our CEO and who is responsible for signing the Form SD, as well as senior executives from Global Procurement, Environment Health Safety & Sustainability, Internal Controls and Legal. Our team of functional subject matter experts is responsible for implementing our conflict minerals compliance strategy and the process was led by a Lean Six Sigma Black-belt employee who acted as a facilitator. Senior management is provided with updates on the program and results of our conflict minerals program efforts on a regular basis.
2.3 Control Systems
Controls include, but are not limited to, our Employee Code of Conduct, our Supplier Code of Conduct (adopted from the Electronic Industry Citizenship Coalition (EICC) code of conduct) and a conflict minerals contract clause incorporated in our Multi-National Master Purchasing Agreement for new contracts.
Xerox continues to be a member of the Conflict Free Sourcing Initiative (CFSI), a group assisting in the development of tools and processes to improve conflict minerals due diligence, which is an EICC and Global eSustainability initiative. As outlined in 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 (OECD 2013), the internationally recognized standard on which our company’s system is based, we support an industry initiative, the CFSI, that audits smelters’ and refiners’ due diligence activities. The data on which we relied for certain statements in this declaration was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for member XRXC.
Because of the size of our company, the complexity of our products and the depth and breadth of our supply chain, it is difficult to identify sources upstream from our direct suppliers. As a result, Xerox has developed a supplier risk assessment process, through which the conflict minerals program is implemented, managed and monitored.
2.4 Grievance Mechanism
We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Xerox policies. This is communicated annually in our supplier ethics letter.
| 3. | DUE DILIGENCE PROCESS |
3.1 Design of Due Diligence
Xerox undertook due diligence to seek to determine whether the conflict minerals used in our products were or were not “DRC conflict free.” Xerox designed its due diligence measures to be in conformity, in all material respects, with the nationally or internationally recognized due diligence framework in the OECD 2013. Our design of due diligence measures featured: (1) establishment of strong internal company management systems; (2) identification and assessment of risks in the supply chain; (3) design and implementation of a strategy to respond to risks as they are identified; (4) support of industry organizations to carry out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) preparation of this annual CMR.
3.2 Due Diligence Measures Performed
Request information
Our due diligence measures included conducting a supply-chain survey with Tier 1 production suppliers using the CMRT, which contains questions about the facilities used to process these minerals, as well as supplier due diligence. The goal of this activity was to identify, where applicable, the 3TG smelters or refiners who contribute refined conflict minerals to Xerox components, assemblies and Original Equipment Manufacturer (OEM) Products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters or refiners that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters or refiners the company and its suppliers use. In addition, our current standard supplier contracts also require our suppliers to adopt a policy on the responsible sourcing of minerals, implement due diligence processes to support that policy, and complete and return to Xerox the CFSI CMRT.
Our Tier 1 supplier survey request also included the CFSI informational links on available conflict mineral and smelter information.
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Survey Responses
In 2014, with a goal of achieving a greater supplier response rate and targeting of 3TG minerals, a supplier and commodity risk assessment process was developed to identify those suppliers whose products may contain the presence of tin, tantalum, tungsten and gold. We conducted a survey of these suppliers to determine whether the conflict minerals in components contained in our products were or were not DRC conflict free (as defined by the Rule). Suppliers that responded they were not using the 3TG in their products were eliminated after the risk assessment process as well as suppliers with products determined out of scope. Accordingly in 2014, Xerox surveyed 440 suppliers with a 64% response rate.
The responses contained varying degrees of information regarding the names and locations of 3TG smelters or refiners which process necessary conflict minerals used by our suppliers, which are ultimately incorporated into our products. We have designed and adopted a risk management plan that summarizes our risk mitigation efforts. Under our risk-assessment process, we perform due diligence reviews of supplier responses for their use of 3TG and conduct follow-up actions on suppliers, encouraging further requests for accurate, complete or missing template information where responses identified red flags based on our risk assessment. We also provide monthly reports and quarterly management reviews to our senior management and elevate non-responsive issues as necessary.
3.3 Due Diligence Results
Smelter or Refiner Results*
Through our participation in CFSI, the OECD implementation programs and requesting our suppliers to complete the survey, we have determined that seeking information about 3TG smelters or refiners in our supply chain from our suppliers represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
The majority of supplier survey responses did not completely list all the smelters or refiners used in their supply chain. For supplier survey received which listed smelter data, we analyzed and compared the 3TG smelters/refiners against information provided through our membership of the EICC / CFSI program. For the calendar year 2014, our due diligence identified 555 smelters and refiners as potential sources of 3TG minerals that were reported to be in our supply chain.
In order to provide compliance status, we completed further analysis of the 555 smelters and refiners, of which 146 have been certified as conflict-free compliant by the CFSI approved program. An additional 42 are active within the CFSI program and have begun the audit process but have not yet been certified. Of the outstanding 367 reported smelter or refiners, 63 are known to be legitimate smelters whom the CFSI outreach program is working to engage in their audit program. The remaining 304 are alleged smelters which have been allocated a Smelter Identification CID number and are awaiting validation through the CFSI audit program.
*Note: The data above was obtained from the non-public (member only access) CFSI Data Exchange Forum as of 4/23/2015.
Smelters or refiners verified as conflict-free or in the audit process**
| Tantalum | 34 of 45 (75%) | |
| Tin | 51 of 253 (20%) | |
| Tungsten | 32 of 51 (63%) | |
| Gold | 71 of 206 (34%) | |
| Total | 188 of 555 (34 %) |
**Note: CFSI compliance results are as of 04/28/2015 (available at http://www.conflictfreesourcing.org).
| 4. | DETERMINATION |
The information received from our due diligence efforts from suppliers or other sources is not sufficient to determine the origin of all 3TG our products contain, whether the 3TG come from recycled or scrap sources, the facilities used to process
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them, their country of origin, or their mine or location of origin. We have found no reasonable basis for concluding that these refiners, or the other smelters preparing to be audited, sourced 3TG minerals that directly or indirectly finance or benefit armed groups of the conflict region of the Covered Countries.
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the 3TG minerals in our products include the CFSI compliant smelters listed in Appendix I below. Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG minerals in our products or whether the 3TG minerals in our products are from recycled or scrap sources. However, based on the information provided by our suppliers, as well as from the CFSI and other sources, we believe that the countries of origin of the 3TG minerals contained in our products include the countries listed in Appendix II below as well as recycled and scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.
Through our participation in the CFSI, we continue to support independent third party audits through the CFSI or other third party certification schemes.
In accordance with the OECD Guidance and the Rule, this CMR is available on our website under “Chairman’s Message - Conducting business with integrity” at http://www.xerox.com/about-xerox/citizenship/miss-enus.html.
| 5. | STEPS TO BE TAKEN IN 2015 TO MITIGATE RISK |
Xerox plans to undertake the following steps during 2015 to improve the due diligence conducted in order to further mitigate the risk that the necessary conflict minerals in our products do not benefit armed groups in the DRC or adjoining countries, including:
| • | Continue to strengthen engagement with relevant suppliers and to provide training, as appropriate, to help them understand and satisfy Xerox requirements on the 3TG mineral Rule. |
| • | Continue using internal elevation process within our supply chain organization in working (or requiring) with suppliers to obtain required information. |
| • | Review third party programs to further improve our conflict mineral process in obtaining accurate and complete information about smelters/refiners. |
| • | Continue to participate as a member in the EICC and the CFSI including Conflict Free Smelter Program smelter validation and supplier outreach. |
| • | Continue to work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. |
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APPENDIX I
| Mineral |
Smelter or Refiner Name* |
Country Location of Smelter or Refiner | ||
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | ||
| Gold | Argor-Heraeus SA | SWITZERLAND | ||
| Gold | Asahi Pretec Corporation | JAPAN | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
| Gold | Aurubis AG | GERMANY | ||
| Gold | Boliden AB | SWEDEN | ||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA | ||
| Gold | Chimet S.p.A. | ITALY | ||
| Gold | Dowa | JAPAN | ||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | ||
| Gold | Heimerle + Meule GmbH | GERMANY | ||
| Gold | Heraeus Ltd. Hong Kong | HONG KONG | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
| Gold | Istanbul Gold Refinery | TURKEY | ||
| Gold | Japan Mint | JAPAN | ||
| Gold | Johnson Matthey Inc. | UNITED STATES | ||
| Gold | Johnson Matthey Ltd. | CANADA | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIA | ||
| Gold | JSC Uralelectromed | RUSSIA | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
| Gold | Kazzinc Inc. | KAZAKHSTAN | ||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | ||
| Gold | Kojima Chemicals Co., Ltd | JAPAN | ||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | ||
| Gold | LS-NIKKO Copper Inc. | REPUBLIC OF KOREA | ||
| Gold | Materion | UNITED STATES | ||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE | ||
| Gold | Metalor Technologies SA | SWITZERLAND | ||
| Gold | Metalor USA Refining Corporation | UNITED STATES | ||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | ||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | ||
| Gold | Nihon Material Co. Ltd. | JAPAN |
A-1
| Mineral |
Smelter or Refiner Name* |
Country Location of Smelter or Refiner | ||
| Gold | Ohio Precious Metals, LLC | UNITED STATES | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIA | ||
| Gold | PAMP SA | SWITZERLAND | ||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
| Gold | PX Précinox SA | SWITZERLAND | ||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
| Gold | Royal Canadian Mint | CANADA | ||
| Gold | Schone Edelmetaal | NETHERLANDS | ||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd. | CHINA | ||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd. | CHINA | ||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
| Gold | Umicore Brasil Ltda | BRAZIL | ||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | ||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | ||
| Gold | Valcambi SA | SWITZERLAND | ||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
| Gold | Zijin Mining Group Co., Ltd. | CHINA | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | ||
| Tantalum | Duoluoshan | CHINA | ||
| Tantalum | Exotech Inc. | UNITED STATES | ||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | ||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | ||
| Tantalum | H.C. Starck Inc. | UNITED STATES | ||
| Tantalum | H.C. Starck Ltd. | JAPAN | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||
| Tantalum | KEMET Blue Metals | MEXICO | ||
| Tantalum | KEMET Blue Powder | UNITED STATES | ||
| Tantalum | King-Tan Tantalum Industry Ltd | CHINA |
A-2
| Mineral |
Smelter or Refiner Name* |
Country Location of Smelter or Refiner | ||
| Tantalum | LSM Brasil S.A. | BRAZIL | ||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | INDIA | ||
| Tantalum | Mineração Taboca S.A. | BRAZIL | ||
| Tantalum | Mitsui Mining & Smelting | JAPAN | ||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
| Tantalum | Plansee SE Reutte | AUSTRIA | ||
| Tantalum | QuantumClean | UNITED STATES | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA | ||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIA | ||
| Tantalum | Taki Chemicals | JAPAN | ||
| Tantalum | Telex Metals | UNITED STATES | ||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | CHINA | ||
| Tantalum | Zhuzhou Cement Carbide | CHINA | ||
| Tin | Alpha | UNITED STATES | ||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | ||
| Tin | CV United Smelting | INDONESIA | ||
| Tin | Dowa | JAPAN | ||
| Tin | EM Vinto | BOLIVIA | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA | ||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | ||
| Tin | Magnu’s Minerais Metais e Ligas LTDA | BRAZIL | ||
| Tin | Malaysia Smelting Corporation | MALAYSIA | ||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
| Tin | Metallo Chimique | BELGIUM | ||
| Tin | Mineração Taboca S.A. | BRAZIL | ||
| Tin | Minsur S.A. | PERU | ||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA | ||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||
| Tin | PT Bangka Putra Karya | INDONESIA | ||
| Tin | PT Bangka Tin Industry | INDONESIA | ||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | ||
| Tin | PT Bukit Timah | INDONESIA | ||
| Tin | PT DS Jaya Abadi | INDONESIA | ||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | ||
| Tin | PT Mitra Stania Prima | INDONESIA | ||
| Tin | PT Panca Mega Persada | INDONESIA | ||
| Tin | PT Prima Timah Utama | INDONESIA | ||
| Tin | PT REFINED BANGKA TIN | INDONESIA |
A-3
| Mineral |
Smelter or Refiner Name* |
Country Location of Smelter or Refiner | ||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | ||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | ||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | ||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | ||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||
| Tin | Thaisarco | THAILAND | ||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | ||
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | ||
| Tungsten | Xiamen Tungsten (HC) Co., Ltd. | CHINA | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
*Smelter or refiner names as reported by the CFSI as of 04/23/2015.
A-4
APPENDIX II
Countries of origin of Smelters or Refiners are believed to include:
| Angola | Peru | |
| Argentina | Portugal | |
| Australia | Republic of Congo | |
| Austria | Russia | |
| Belgium | Rwanda | |
| Bolivia | Sierra Leone | |
| Brazil | Singapore | |
| Burundi | Slovakia | |
| Canada | South Africa | |
| Central African Republic | South Korea | |
| Chile | South Sudan | |
| China | Spain | |
| Colombia | Suriname | |
| Côte D’Ivoire | Switzerland | |
| Czech Republic | Taiwan | |
| Djibouti | Tanzania | |
| Egypt | Thailand | |
| Estonia | Uganda | |
| Ethiopia | United Kingdom | |
| France | United States of America | |
| Germany | Vietnam | |
| Guyana | Zambia | |
| Hungary | Zimbabwe | |
| India | ||
| Indonesia | ||
| Ireland | ||
| Israel | ||
| Japan | ||
| Kazakhstan | ||
| Kenya | ||
| Laos | ||
| Luxembourg | ||
| Madagascar | ||
| Malaysia | ||
| Mongolia | ||
| Mozambique | ||
| Myanmar | ||
| Namibia | ||
| Netherlands | ||
| Nigeria | ||
A-5