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:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
Section 1 – Conflicts Minerals Disclosure
Items 1.01 and 1.02 Conflicts 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 under Supplier Governance—Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance 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.
Xerox (Xerox) is a leading enterprise for document management solutions. In 2016, its two largest operating segments were Business Process Outsourcing and Document Technology. Xerox’s products included but were 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), ticket vending machines, parking payment stations, automated coin machines, in-vehicle units and media information displays. Effective January 1, 2017, Xerox completed the separation of Xerox’s former Business Process Outsourcing business into an independent publicly-traded company (Conduent Inc.). Because Xerox’s former Business Process Outsourcing business operated through subsidiaries of Xerox for the entire 2016 reporting period, this report reflects efforts undertaken by Xerox in 2016, including Xerox’s former Business Process Outsourcing business and Document Technology segment.
Section 2 – Exhibits
Item 2.01 – Exhibits
Exhibit 1.01—Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016 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. These forward-looking statements and other information are based on our beliefs as well as assumptions made by us using information currently available. The words “anticipate,” “believe,” “estimate,” “expect,” “intend,” “will,” “should” and similar expressions, as they relate to us, are intended to identify forward-looking statements. Such forward-looking statements, because they relate to future events, are by their very nature subject to many important factors that could cause actual results to differ materially from those contemplated in this Report and any exhibits to this Report. These factors include, but are not limited to: our ability to address our business challenges in order to reverse revenue declines, reduce costs and increase productivity so that we can invest in and grow our business; changes in economic conditions, political conditions, trade protection measures, licensing requirements and tax laws 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 contracts and applicable law; the risk that partners, subcontractors and software vendors will not perform in a timely, quality manner; 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; 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; reliance on third parties, including subcontractors, for manufacturing of products and provision of services; our ability to manage changes in the printing environment and markets and expand equipment placements; interest rates, cost of borrowing and access to credit markets; funding requirements associated with our employee pension and retiree health benefit plans; the risk that our operations and products may not comply with applicable worldwide regulatory requirements, particularly environmental regulations and directives and anti-corruption laws; the outcome of litigation and regulatory proceedings to which we may be a party; the risk that we do not realize all of the expected strategic and financial benefits from the separation and spin-off of our Business Process Outsourcing business; 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, 2017 and our 2016 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: April 12, 2017
| XEROX CORPORATION | ||
| By: | /s/ Yehia Maaty Omar | |
| Yehia Maaty Omar | ||
| Senior Vice President | ||
3
EXHIBIT INDEX
| Exhibit |
Description | |
| 1.01 | Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016 | |
4
Exhibit 1.01
Conflict Minerals Report
Xerox Corporation
For the Year Ended December 31, 2016
This report for the year ended December 31, 2016 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 (Xerox) is a leading enterprise for document management solutions. In 2016, its two largest operating segments were Business Process Outsourcing and Document Technology. Xerox’s products included but were 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), ticket vending machines, parking payment stations, automated coin machines, in-vehicle units and media information displays. Effective January 1, 2017, Xerox completed the separation of Xerox’s former Business Process Outsourcing business into an independent publicly-traded company (Conduent Inc.). Because Xerox’s former Business Process Outsourcing business operated through subsidiaries of Xerox for the entire 2016 reporting period, this report reflects efforts undertaken by Xerox in 2016, including Xerox’s former Business Process Outsourcing business and Document Technology segment. Xerox 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—Reasonable Country of Origin Inquiry
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 (RCOI).
2.2 Supplier Risk Assessment
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 conducted a product review to determine products in scope and developed a supplier risk assessment process, through which the conflict minerals program is implemented, managed and monitored. With a goal of targeting 3TG minerals, this 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 originated from the DRC or adjoining countries. This supply-chain survey was conducted with our Tier 1 production suppliers using the CMRT, which contains questions about the facilities used to process these minerals, as well as supplier RCOI. 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. Our supplier survey request also included the Conflict Free Sourcing Initiative (CFSI) informational links on available conflict mineral and smelter information. In 2016, Xerox surveyed 380 suppliers with a 53% response rate, estimated to represent more than 65% of our 2016 spend with production suppliers.
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 of the level of risk of the commodities supplied to us.
In 2016, we continued to refine our process of evaluating the CMRTs to assist with our ongoing risk assessment by analyzing supplier responses and providing feedback to suppliers on errors and corrections. We also provide a hot-line for supplier communication. In addition, we provide monthly reports and systematic management reviews to our senior management and elevate non-responsive issues as necessary.
2.3 Company Management Systems
Policy Xerox has adopted a company policy which is posted on our website under Supplier Governance—Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance.
Internal Team
Xerox has established a management system for conflict minerals. Our management system includes a Senior Management Steering Committee sponsored by the Chief Delivery Officer, 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, and Legal. Our team of functional subject matter experts is responsible for implementing our conflict minerals compliance strategy. Senior management is provided with updates on the program and results of our conflict minerals program efforts on a regular basis.
2.4 Control Systems
Controls include, but are not limited to, our Code of Business Conduct for our employees, 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 worked with the EICC in the early stages to support the CFSI and continues to be a member of the 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, 3RD Edition, (OECD 2016), 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 CFSI Compliant Smelter Sourcing Information Report created specifically for Xerox.
2
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.
2.5 Grievance Mechanism
We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Xerox policies. This is communicated annually in our employee code of ethics training process and the supplier ethics letter. This mechanism helps us to identify and assess risk.
| 3. | DUE DILIGENCE |
3.1 Design of Due Diligence
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 2016.
3.2 Smelter or Refiner Results*
Our due diligence process includes participation in CFSI and following the OECD implementation framework. We requested that our suppliers complete the CMRT survey in order to obtain information about 3TG smelters or refiners in our supply chain. We have determined that these actions represent 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 survey responses provided smelter and refiner data, although some responses did not completely list all the smelters or refiners used in their supply chain. We analyzed and compared all the 3TG smelter and refiner data we received against information obtained from the CFSI smelter database. For the calendar year 2016, our due diligence identified 437 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 437 smelters and refiners, of which 240 have been certified as conflict-free compliant by the CFSI approved program. An additional 71 are known to be legitimate smelters whom the CFSI outreach program is working to engage in their audit program, but have yet to be certified. Two additional smelters were determined to be “non-compliant” to the CFSI audit protocol. One of these entered into corrective action in September 2016 following a failed CFSI audit, and is currently actively progressing towards CFSP compliance and have committed to complete a CFSP re-validation audit. The second smelter did not undergo their required CFSI re-audit scheduled in 2016, and has therefore been determined to be non-compliant pending re-audit. The remaining 124 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 12/23/2016. |
Smelters or refiners verified as conflict-free or in the audit process**
| ** | Note: CFSI compliance results are as of 12/23/2016 (available at http://www.conflictfreesourcing.org). |
| 2014 | 2015 | 2016 | ||||||||||
| Tantalum |
34 of 45 (75%) | 47 of 55 (85%) | 47 of 53 (89%) | |||||||||
| Tin |
51 of 253 (20%) | 84 of 172 (49%) | 82 of 152 (54%) | |||||||||
| Tungsten |
32 of 51 (63%) | 43 of 60 (72%) | 43 of 49 (88%) | |||||||||
| Gold |
71 of 206 (34%) | 129 of 176 (73%) | 139 of 183 (76%) | |||||||||
|
|
|
|
|
|
|
|||||||
| Total |
188 of 555 (34%) | 303 of 463 (65%) | 311 of 437 (71%) | |||||||||
|
|
|
|
|
|
|
|||||||
3
| 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 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 Supplier Governance—Conflict Minerals at www.xerox.com/en-us/about/supplier-relations/governance.
| 5. | STEPS TO BE TAKEN IN 2017 TO MITIGATE RISK |
Xerox plans to undertake the following steps during 2017 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 related to 3TG minerals under the Rule. |
| • | Review process with distributors submitting CMRT’s and develop best practices in obtaining 3TG mineral data. |
| • | Continue using internal escalation process within our supply chain organization when working 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 provide ongoing feedback to suppliers on errors and corrections required in connection with the CMRT assessment. |
| • | 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 | ||
|
Gold |
Western Australian Mint trading as The Perth Mint | Australia | ||
| Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Austria | ||
| Gold |
Umicore S A Business Unit Precious Metals Refining | Belgium | ||
| Gold |
AngloGold Ashanti Córrego do Sitio Mineração | Brazil | ||
| Gold |
Umicore Brasil Ltda. | Brazil | ||
| Gold |
Asahi Refining Canada Ltd. | Canada | ||
| Gold |
CCR Refinery—Glencore Canada Corp. | Canada | ||
| Gold |
Royal Canadian Mint | Canada | ||
| Gold |
Heraeus Metals Hong Kong Ltd. | China | ||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | ||
| Gold |
Jiangxi Copper Co., Ltd. | China | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd. | China | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. | China | ||
| Gold |
The Refinery of Shandong Gold Mining Co., Ltd. | China | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corp. | China | ||
| Gold |
Zijin Mining Group Co., Ltd. Gold Refinery | China | ||
| Gold |
Allgemeine Gold-und Silberscheideanstalt AG | Germany | ||
| Gold |
Aurubis AG | Germany | ||
| Gold |
C Hafner GmbH + Co. KG | Germany | ||
| Gold |
Doduco GmbH | Germany | ||
| Gold |
Heimerle + Meule GmbH | Germany | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG | Germany | ||
| Gold |
SAXONIA Edelmetalle GmbH | Germany | ||
| Gold |
Wieland Edelmetalle GmbH | Germany | ||
| Gold |
MMTC-PAMP India Pvt., Ltd. | India | ||
| Gold |
PT Aneka Tambang (Persero) Tbk | Indonesia | ||
| Gold |
Chimet S.p.A. | Italy | ||
| Gold |
T.C.A. S.p.A. | Italy | ||
| Gold |
Aida Chemical Industries Co., Ltd. | Japan | ||
| Gold |
Asahi Pretec Corp. | Japan | ||
| Gold |
Asaka Riken Co., Ltd. | Japan | ||
| Gold |
Dowa | Japan | ||
| Gold |
Eco-System Recycling Co., Ltd. | Japan | ||
| Gold |
Ishifuku Metal Industry Co., Ltd. | Japan | ||
| Gold |
Japan Mint | Japan | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. | Japan |
A-1
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Gold |
Kojima Chemicals Co., Ltd. | Japan | ||
| Gold |
Matsuda Sangyo Co., Ltd. | Japan | ||
| Gold |
Mitsubishi Materials Corp. | Japan | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold |
Nihon Material Co., Ltd. | Japan | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd. | Japan | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K. | Japan | ||
| Gold |
Tokuriki Honten Co., Ltd. | Japan | ||
| Gold |
Yamamoto Precious Metal Co., Ltd. | Japan | ||
| Gold |
Yokohama Metal Co., Ltd. | Japan | ||
| Gold |
Kazzinc | Kazakhstan | ||
| Gold |
LS-NIKKO Copper Inc. | Korea | ||
| Gold |
Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold |
Metalúrgica Met-Mex Peñoles S. A. de C.V. | Mexico | ||
| Gold |
Moscow Special Alloys Processing Plant | Moscow | ||
| Gold |
Schone Edelmetaal B.V. | Netherlands | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold |
DSC (Do Sung Corp.) | Republic of Korea | ||
| Gold |
Korea Zinc Co Ltd | Republic of Korea | ||
| Gold |
Samduck Precious Metals | Republic of Korea | ||
| Gold |
Torecom | Republic of Korea | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russia | ||
| Gold |
OJSC Novosibirsk Refinery | Russia | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russia | ||
| Gold |
JSC UralElectromed | Russia | ||
| Gold |
Prioksky Plant of Non-Ferrous Metals | Russia | ||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | Russia | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||
| Gold |
AU Traders and Refiners | South Africa | ||
| Gold |
Rand Refinery (Pty) Ltd. | South Africa | ||
| Gold |
SEMPSA Joyería Platería S.A. | Spain | ||
| Gold |
Boliden AB | Sweden | ||
| Gold |
Argor-Heraeus S.A. | Switzerland | ||
| Gold |
Metalor Technologies S.A. | Switzerland | ||
| Gold |
PAMP S.A. | Switzerland | ||
| Gold |
PX Précinox S.A. | Switzerland | ||
| Gold |
Valcambi S.A. | Switzerland |
A-2
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Gold |
Singway Technology Co., Ltd. | Taiwan | ||
| Gold |
Solar Applied Materials Technology Corp. | Taiwan | ||
| Gold |
Umicore Precious Metals Thailand | Thailand | ||
| Gold |
Istanbul Gold Refinery | Turkey | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic A. Ş. | Turkey | ||
| Gold |
Emirates Gold DMCC | United Arab Emirates | ||
| Gold |
Advanced Chemical Co. | United States | ||
| Gold |
Asahi Refining USA Inc. | United States | ||
| Gold |
Elemetal Refining LLC | United States | ||
| Gold |
Kennecott Utah Copper LLC | United States | ||
| Gold |
Materion | United States | ||
| Gold |
Metalor United States Refining Corporation | United States | ||
| Gold |
Republic Metals Corporation | United States | ||
| Gold |
United Precious Metal Refining Inc | United States | ||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Tantalum |
Plansee SE Liezen | Austria | ||
| Tantalum |
Plansee SE Reutte | Austria | ||
| Tantalum |
LSM Brasil S.A. | Brazil | ||
| Tantalum |
Mineração Taboca S.A. | Brazil | ||
| Tantalum |
Resind Indústria e Comércio Ltda. | Brazil | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | China | ||
| Tantalum |
Conghua Tantalum and Niobium Smeltry | China | ||
| Tantalum |
Duoluoshan | China | ||
| Tantalum |
F&X Electro-Materials Ltd. | China | ||
| Tantalum |
FIR Metals & Resource Ltd. | China | ||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. | China | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum |
Jiangxi Tuohong New Raw Material | China | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||
| Tantalum |
Jiujiang Tanbre Co., Ltd. | China | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | ||
| Tantalum |
King-Tan Tantalum Industry Ltd. | China | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. | China | ||
| Tantalum |
Yanling Jincheng Tantalum Co., Ltd. | China | ||
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. | China | ||
| Tantalum |
Zhuzhou Cemented Carbide Group Co., Ltd. | China |
A-3
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Tantalum |
NPM Silmet AS | Estonia | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH | Germany | ||
| Tantalum |
H.C. Starck Smelting GmbH & Co KG | Germany | ||
| Tantalum |
H.C. Starck Tantalum and Niobium GmbH Goslar | Germany | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd. | India | ||
| Tantalum |
Global Advanced Metals Aizu | Japan | ||
| Tantalum |
H.C. Starck Ltd. | Japan | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Tantalum |
Taki Chemical Co., Ltd. | Japan | ||
| Tantalum |
Ulba Metallurgical Plant JSC | Kazakhstan | ||
| Tantalum |
Power Resources Ltd. | Macedonia | ||
| Tantalum |
Kemet Blue Metals | Mexico | ||
| Tantalum |
Solikamsk Magnesium Works OAO | Russia | ||
| Tantalum |
H.C. Starck Co., Ltd. | Thailand | ||
| Tantalum |
D Block Metals LLC | United States | ||
| Tantalum |
Exotech Inc. | United States | ||
| Tantalum |
Global Advanced Metals Boyertown | United States | ||
| Tantalum |
H.C. Starck Inc. | United States | ||
| Tantalum |
Hi-Temp Specialty Metals Inc. | United States | ||
| Tantalum |
Kemet Blue Powder | United States | ||
| Tantalum |
QuantumClean | United States | ||
| Tantalum |
Telex Metals | United States | ||
| Tantalum |
Tranzact Inc. | United States | ||
| Tin |
Metallo-Chimique N.V. | Belgium | ||
| Tin |
EM Vinto | Bolivia | ||
| Tin |
Operaciones Metalurgical S.A. | Bolivia | ||
| Tin |
Cooperativa Metalurgica de Rondônia Ltda. | Brazil | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin |
Melt Metais e Ligas S.A. | Brazil | ||
| Tin |
Mineração Taboca S.A. | Brazil | ||
| Tin |
Resind Indústria e Comércio Ltda. | Brazil | ||
| Tin |
Soft Metais Ltda. | Brazil | ||
| Tin |
White Solder Metalurgia e Mineração Ltda. | Brazil | ||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | ||
| Tin |
China Tin Group Co., Ltd. | China | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant | China | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. | China |
A-4
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd. | China | ||
| Tin |
Yunnan Tin Company Limited | China | ||
| Tin |
CV Ayi Jaya | Indonesia | ||
| Tin |
CV Dua Sekawan | Indonesia | ||
| Tin |
CV Gita Pesona | Indonesia | ||
| Tin |
CV Serumpun Sebalai | Indonesia | ||
| Tin |
CV Tiga Sekawan | Indonesia | ||
| Tin |
CV United Smelting | Indonesia | ||
| Tin |
CV Venus Inti Perkasa | Indonesia | ||
| Tin |
PT Aries Kencana Sejahtera | Indonesia | ||
| Tin |
PT Artha Cipta Langgeng | Indonesia | ||
| Tin |
PT ATD Makmur Mandiri Jaya | Indonesia | ||
| Tin |
PT Babel Inti Perkasa | Indonesia | ||
| Tin |
PT Bangka Prima Tin | Indonesia | ||
| Tin |
PT Bangka Tin Industry | Indonesia | ||
| Tin |
PT Belitung Industri Sejahtera | Indonesia | ||
| Tin |
PT Bukit Timah | Indonesia | ||
| Tin |
PT Cipta Persada Mulia | Indonesia | ||
| Tin |
PT DS Jaya Abadi | Indonesia | ||
| Tin |
PT Eunindo Usaha Mandiri | Indonesia | ||
| Tin |
PT Inti Stania Prima | Indonesia | ||
| Tin |
PT Karimun Mining | Indonesia | ||
| Tin |
PT Kijang Jaya 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 | ||
| Tin |
PT Sariwiguna Binasentosa | Indonesia | ||
| Tin |
PT Stanindo Inti Perkasa | Indonesia | ||
| Tin |
PT Sukses Inti Makmur | Indonesia | ||
| Tin |
PT Sumber Jaya Indah | Indonesia | ||
| Tin |
PT Timah (Persero) Tbk Kundur | Indonesia | ||
| Tin |
PT Timah (Persero) Tbk Mentok | Indonesia | ||
| Tin |
PT Tinindo Inter Nusa | Indonesia | ||
| Tin |
PT Tommy Utama | Indonesia | ||
| Tin |
PT Wahana Perkit Jaya | Indonesia | ||
| Tin |
Dowa | Japan | ||
| Tin |
Mitsubishi Materials Corp. | Japan |
A-5
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Tin |
Malaysia Smelting Corp. (MSC) | Malaysia | ||
| Tin |
Minsur | Perú | ||
| Tin |
O.M. Manufacturing Philippines Inc. | Philippines | ||
| Tin |
Fenix Metals | Poland | ||
| Tin |
Elmet S.L.U. | Spain | ||
| Tin |
Rui Da Hung | Taiwan | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin |
Thaisarco | Thailand | ||
| Tin |
Alpha | United States | ||
| Tin |
Metallic Resources Inc. | United States | ||
| Tin |
VQB Mineral and Trading Group JSC | Vietnam | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||
| Tungsten |
Fujian Jinxin Tungsten 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 |
Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||
| Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City | China | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | China | ||
| Tungsten |
Xiamen Tungsten Co., Ltd. | China | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | ||
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | ||
| Tungsten |
H.C. Starck Smelting GmbH & Co. KG | Germany | ||
| Tungsten |
A.L.M.T. Tungsten Corp. | Japan | ||
| Tungsten |
Japan New Metals Co., Ltd. | Japan | ||
| Tungsten |
Woltech Korea Co., Ltd. | Korea | ||
| Tungsten |
Philippine Chuangxin Industrial Co Inc. | Philippines |
A-6
| Mineral |
Smelter or Refiner Name* |
Country Location of | ||
| Tungsten |
Wolfram Bergbau und Hütten AG | Republic of Korea | ||
| Tungsten |
Hydrometallurg JSC | Russia | ||
| Tungsten |
Moliren Ltd. | Russian Federation | ||
| Tungsten |
Unecha Refractory Metals Plant | Russian Federation | ||
| Tungsten |
Global Tungsten & Powders Corp. | United States | ||
| Tungsten |
Kennametal Fallon | United States | ||
| Tungsten |
Kennametal Huntsville | United States | ||
| Tungsten |
Niagara Refining LLC | United States | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. | Vietnam | ||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | ||
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | ||
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| * | Smelter or refiner names as reported by the CFSI as of 12/23/2016. |
A-7
APPENDIX II
Countries of origin of the 3TG minerals contained in our products **
| Gold |
Tantalum |
Tin |
Tungsten | |||
| Bolivia |
Australia | Australia | Australia | |||
| Chile |
Bolivia | Bolivia | Austria | |||
| Colombia |
Brazil | Brazil | Bolivia | |||
| Ecuador |
Burundi | Burundi | Brazil | |||
| Guatemala |
China | China | Burundi | |||
| Guyana |
Democratic Republic of Congo |
Colombia | Cambodia | |||
| Honduras |
Ethiopia | Democratic Republic of Congo |
Canada | |||
| Nicaragua |
France | Indonesia | China | |||
| Panama |
Guinea | Laos | Colombia | |||
| Peru |
Guyana | Malaysia | Democratic Republic of Congo | |||
| United States |
India | Mongolia | Japan | |||
| Madagascar | Myanmar | Mexico | ||||
| Malaysia | Nigeria | Mongolia | ||||
| Mozambique | Peru | Nigeria | ||||
| Namibia | Portugal | Portugal | ||||
| Nigeria | Russia | Russia | ||||
| Russia | Rwanda | Rwanda | ||||
| Rwanda | Thailand | Spain | ||||
| Sierra Leone | Uganda | United States | ||||
| Thailand | Vietnam | Uzbekistan | ||||
| United States | Vietnam | |||||
| Zimbabwe | Zimbabwe |
| ** | As per CFSI Compliant Smelter Sourcing RCOI information as of 12/23/2016. |
Note: CFSI approved smelters certified via the LBMA and RJC have not disclosed country of origin details.
A-8