EX-1.01 2 conflictmineralsreportfor1.htm EXHIBIT 1.01 Conflict Minerals Report for 12/31/14


Exhibit 1.01

EMC CORPORATION
Conflict Minerals Report
For the year ended December 31, 2014

Introduction
As part of our global approach to the protection of human rights, EMC is committed to the ethical sourcing of minerals, and in particular of tantalum, tin, tungsten and gold (“3TG”). There is concern that 3TG, often referred to as “conflict minerals,” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.

As stated in our Conflict Minerals Policy, it is our goal not to purchase product materials containing 3TG whose sale finance armed conflict in the DRC. However, we believe being “DRC Conflict-Free” should not mean “DRC-Free”. We intend to source responsibly from the DRC and adjoining countries (collectively, the “Covered Countries”) in order to support peaceful economic activity in the region.

Summary
In 2014, EMC manufactured and contracted to manufacture products in which “conflict minerals” (defined in the U.S. Securities and Exchange Commission Release No. 34-67716 as cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to 3TG) are necessary to the functionality or production of such products. As we do not yet know the source of all the 3TG in these products, we do not have sufficient information to conclude that any of these products are “DRC Conflict-Free.” However, in 2014 we did see an increase in the percentage of smelters and refiners in our supply chain that are compliant with the Conflict-Free Smelter Program (CFSP), as described below. This report describes our approach and our efforts toward responsible sourcing of 3TG.

Our Approach
Researching the origin of minerals through the supply chain is a complex endeavor. As a manufacturer of enterprise storage systems, we consume components and materials containing 3TG and do not purchase 3TG directly from mines, smelters or refiners. Therefore, to meet our goal of being DRC Conflict-Free, we must collaborate with suppliers, industry peers, and other stakeholders. To this end, we seek to advance tools and programs that simplify due diligence processes through the supply chain and increase the supply of verifiably DRC Conflict-Free minerals.

EMC is a member of the Conflict-Free Sourcing Initiative (the “CFSI”), a multi-industry initiative addressing conflict minerals issues in the supply chain. The CFSI’s Conflict Minerals Reporting Template (the “CMRT”) is a widely-used standard form to collect information through the supply chain, including the names of 3TG smelters and refiners. The CFSI’s Conflict-Free Smelter Program (the “CFSP”) uses independent third-party audits to assess whether 3TG smelters and refiners have systems in place to assure sourcing of only conflict-free materials. We use the CMRT to survey our suppliers and identify smelters and refiners in our supply chain, and the CFSP to determine the country of origin and conflict-free status of minerals.

EMC is an active participant in CFSI workgroups and projects. This collaboration helps us advance toward our goal, and it also helps to build a global supply chain system for responsible and ethical mineral sourcing that makes it more widely possible for companies to source DRC Conflict-Free minerals for their products.

Our Strategy
To reach our goal of being DRC Conflict-Free, we set a three-pronged strategy focusing first on supplier-level engagement, where we have the most direct influence, then on the smelter and refiner level, and third on encouraging responsible sourcing from the Covered Countries.
1.
Engage suppliers in due diligence and DRC Conflict-Free sourcing
Survey suppliers using the CMRT





Offer resources and education on the issue of conflict minerals and best practices in due diligence
Influence the supply chain to shift to CFSP-compliant smelters and refiners
2.
Increase the number of Conflict-Free Smelters and Refiners
Identify smelters and refiners in our supply chain
Help advance the CFSP through active participation in CFSI workgroups
Encourage smelters and refiners in our supply chain to undergo an audit to be CFSP-compliant
3.
Encourage responsible sourcing from the Covered Countries:
Promote verifiable conflict-free sourcing from the Covered Countries in order to support peaceful economic activity

Our Products
This report relates to products EMC manufactured or contracted to be manufactured in 2014 that contain 3TG that may be considered necessary to the functionality or production of such products. EMC offers a comprehensive portfolio of storage systems including EMC VMAX, EMC VNX, EMC Isilon, EMC XtremIO, EMC Atmos, EMC ECS, EMC VPEX, and PCIe-based flash cards. Our data protection and availability systems span the backup, archive and availability categories, including EMC Avamar, EMC Data Domain, EMC Recoverpoint, EMC VPLEX, and EMC Disk Library for mainframe products. Federation subsidiary VCE also offers a portfolio of hardware-based converged storage, compute and networking systems known as Vblock. RSA, the Security Division of EMC, manufactures RSA SecureID tokens and offers a number of other security products provided either as Virtual Machines or via an EMC common server-based appliance. These hardware products were in scope for our conflict minerals due diligence efforts in 2014.

Our Conflict Minerals Policy and Program
EMC’s Conflict Minerals Policy states our goal to be DRC Conflict-Free, our expectations of our suppliers, and our approach of broad collaboration with suppliers, industry peers, and other stakeholders. EMC’s program is overseen by a Conflict Minerals Governance Committee that provides strategic direction and input to EMC’s conflict minerals policy, supplier requirements, communications, and risk management. This committee includes executives from Global Supply Chain Management, Global Supply Chain Engineering, and the Office of Sustainability, as well as representatives from Finance, Legal, Global Product Operations Sustainability, Government Affairs and Internal Audit. This committee reports to the Audit Committee of the Board of Directors.

Supplier requirements for conflict minerals due diligence are embedded in EMC’s supply chain management. Our Supplier Code of Conduct requires direct materials suppliers to have a conflict minerals policy and conduct due diligence on the source and chain of custody of the 3TG in their products. These same requirements are included in our standard contracts and purchase agreements.

Our Supply Chain

Reasonable Country of Origin Inquiry
The first step in our compliance process was to identify where 3TG are used in our products and by which suppliers. We searched our Full Material Disclosure database, which catalogues the substances used in EMC products, to generate a list of suppliers from whom we would need information. We included Tier 1 suppliers who sell directly to EMC, and other suppliers from whom we instruct Tier 1 suppliers to purchase parts for the components they sell to us (“Tier 2+”). We asked these suppliers to survey their own supply chain, report to us using the CMRT, and publish a conflict minerals policy. Suppliers representing 99% of our Tier 1 and 93% of our Tier 2+ 2014 spend submitted CMRTs.

EMC compared the list of smelters and refiners reported by suppliers against the CFSI’s list of verified 3TG smelters and refiners. As of April 30, 2015, of the 256 verified 3TG smelter and refiner facilities in our supply chain, 155 are compliant with CFSP and have been found to be DRC Conflict-Free. The list of these verified smelters and refiners that our suppliers reported as being in their supply chains is set forth in Appendix A. The list of countries from which we believe the 3TG in our products may have originated is set forth in Appendix B. Some 3TG also originated from recycled or scrap sources. This information was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report dated April 30, 2015 that is available to EMC as a





member of CFSI. This report provides information on smelters and refiners that are compliant with CFSP, including smelter facility name, location, and countries from which minerals were sourced.

We then mapped our suppliers against our covered products and reviewed the smelter lists for those suppliers. We found that for each covered product category:
Some 3TG is sourced through verified smelters or refiners that are not yet CFSP-compliant and therefore we have not yet determined the country of origin of those minerals; and
Some 3TG is sourced from CFSP-compliant smelters or refiners, including smelters or refiners that source responsibly from the Covered Countries.

This supplier survey and smelter review process constituted our Reasonable Country of Origin Inquiry (RCOI). This RCOI combined with our risk assessment and mitigation efforts described below represent EMC’s best efforts to trace the source of the 3TG in our supply chain to the mine or location of origin as necessary.

Supply Chain Risk Assessment
In keeping with our strategy, we focus our risk assessment and mitigation where we expect to have the most impact: evaluating supplier responses to our conflict minerals survey and the CFSP-compliant status of the smelters and refiners in our supply chain. As a downstream company, EMC utilizes the CFSP for smelter and refiner audits and assessment of risks in the mineral supply chain from the mine to the smelter or refiner.

Assessing supplier responses
We depend on supplier reporting to conduct our due diligence. Therefore, complete and correct supplier reporting, as well as supplier cooperation with our commitment to DRC conflict-free sourcing, reduces the risk that EMC will purchase products and/or materials containing minerals whose sale financed armed conflict in the DRC.

Each supplier’s CMRT was reviewed against an internally-developed framework for reasonableness and risk. We sought to understand our suppliers’ progress on due diligence, confirm whether they had published a conflict minerals policy, and obtain a list of 3TG smelters and refiners in their supply chain. In analyzing supplier responses to our survey, we found three areas of concern: inaccurate smelter and refiner lists, inconsistent approaches to determining whether 3TG was sourced from the Covered Countries, and absence of conflict minerals policies.

Smelter and Refiner Lists: Obtaining a complete and accurate list of smelters and refiners in our supply chain is an essential step in the RCOI process. We have experienced some challenges in collecting this information. For example, we found that many of the smelter and refiner names reported through the supply chain either are not 3TG smelters or refiners, or that more research is required to make that determination. While we believe our suppliers are providing information in good faith, this challenge underscores the need for supplier education and improved information on smelter and refiner facilities worldwide.

Determining Whether 3TG Was Sourced from the Covered Countries: EMC is committed to being DRC conflict-free and to sourcing responsibly from the Covered Countries through CFSP-compliant smelters and refiners. However, we found that many suppliers are still learning how to determine the country of origin of 3TG. For example, some of our suppliers reported that none of the 3TG in their products originated from the Covered Countries when, in fact, CFSP-compliant smelters in their supply chain publicly disclose that they do source from the Covered Countries. Other suppliers reported that they were sourcing 3TG from the Covered Countries, but did not specify how they had come to this conclusion, or whether that 3TG was sourced through CFSP-compliant smelters. In both situations, when we contacted these suppliers to discuss their responses, we found that many had either misunderstood how to use CFSP to determine country of origin, or they had based their responses solely on what their suppliers had reported to them.

Conflict Minerals Policy: Suppliers who publish their conflict minerals policy show commitment to responsible sourcing. We found that some suppliers declared that they use 3TG, but either did not have, or had not published, a conflict minerals policy.






Assessing smelter and refiner data
In analyzing our smelter and refiner data, we identified two major areas of concern: smelter verification and the limited supply of CFSP-compliant smelters and refiners.

Smelter and Refiner Verification: While we expect that our suppliers will continue to improve their reporting, there is a need for additional research on reported smelter names to verify whether they actually are 3TG smelters or refiners. Without an accurate list of 3TG smelters and refiners in our supply chain, we will not be able to target the smelters and refiners that would benefit from participation in the CFSP audits, or fully understand the progress toward our goal to be DRC Conflict-Free.

Supply of CFSP-compliant Smelters and Refiners: In order for our products to be verified as DRC Conflict-Free, there must be a sufficient number of confirmed conflict-free smelters and refiners to allow a viable supply of minerals. There is still a need for more smelters and refiners to participate in the program. Table 1 shows the percentage of CFSP-compliant smelters and refiners for 3TG in our supply chain, broken out by metal.

Table 1
3TG Smelters and Refiners in EMC’s Supply Chain
Mineral
Total # smelters and
refiners in our supply chain
Total # CFSP-compliant smelters and refiners in our supply chain
% of CFSP-compliant smelters and refiners in our supply chain
Tantalum
2013: 24
2014: 39
2013: 21
2014: 39
2013: 88%
2014: 100%
Tin
2013: 47
2014: 71
2013: 11
2014: 36
2013: 23%
2014: 51%
Tungsten
2013: 21
2014: 35
2013: 1
2014: 14
2013: 5%
2014: 40%
Gold
2013: 90
2014: 111
2013: 40
2014: 66
2013: 44%
2014: 59%
Based on EMC supplier data as of April 1, 2015 and CFSI’s Reasonable Country of Origin Inquiry report dated April 30, 2015. Numbers only include facilities reported by suppliers that are on the CFSI standard smelter list as of April 30, 2015.

Addressing Identified Risks: Our Approach

EMC is taking steps to improve our due diligence process and further mitigate the risk of purchasing 3TG whose sale finance armed conflict in the DRC. In keeping with our conflict minerals strategy, we focus our risk mitigation efforts in three areas: supplier engagement; increasing the number of conflict-free smelters and refiners; and encouraging responsible sourcing from the Covered Countries.

Engage suppliers in due diligence and DRC Conflict-Free sourcing
EMC issues targeted communications to help our suppliers improve their reporting, informed by the risks identified in our supplier surveys. At the launch of the 2014 survey, we distributed information to help suppliers return more complete and accurate smelter and refiner lists, and better understand the role of CFSP audits in determining the country of origin and the DRC Conflict-Free status of the minerals in their products. As suppliers returned CMRTs, we reviewed their responses against our internally-developed framework for reasonableness and risk. We contacted those whose answers did not seem reasonable, or indicated potential risk, in order to obtain additional information and request corrective actions. Unresponsive suppliers were escalated through supply chain management staff responsible for managing the commercial relationships. We also set a 2014 goal for 100% of Tier 1 direct material suppliers that sell us products containing 3TG to have a conflict minerals policy published on their website. More than 99% (by spend) of our Tier 1 suppliers in scope have done so.

Conflict minerals requirements and incentives are embedded in EMC’s supply chain management business processes. These activities target the Tier 1 and Tier 2 suppliers with whom we have the strongest business





relationship and therefore the greatest influence. For example, suppliers’ conflict minerals risk scores, based on their response to the survey, are incorporated into the supplier scorecard. This scorecard also includes other metrics such as quality, cost and availability, and provides a key input into business decisions. Suppliers’ risk scores and corrective actions are also made available in EMC’s supplier portal, and are included in suppliers’ Quarterly and Executive Business Reviews. Going forward, we will continue to raise our expectations of suppliers to improve due diligence and source from CFSP-compliant smelters.

Increase the number of Conflict-Free Smelters and Refiners
EMC is working to develop a more accurate list of 3TG smelters and refiners in our supply chain, and to encourage verified 3TG smelters and refiners to undergo CFSP audits if they have not already done so. We participate in the CFSI workgroup that conducts research to verify alleged 3TG smelters and refiners, and outreach to engage them in the CFSP audit program. We also contributed to CFSP’s Initial Audit Fund, which pays the costs of a smelter or refiner’s first CFSP audit, a major incentive for smelters to participate. As the number of CFSP-compliant smelters and refiners grows, we can more effectively engage our suppliers to shift purchasing to CFSP-compliant smelters and refiners. There has been measurable improvement from 2013 in the percentage of CFSP-compliant smelters in our supply chain, as shown in Table 1 above.

Encourage responsible sourcing from the Covered Countries
EMC desires to be DRC Conflict-Free, but not at the expense of supporting responsible mining operations in the Covered Countries. In 2014, we educated suppliers who mistakenly believed that CFSP-compliant smelters are, by definition, not sourcing from the Covered Countries, or whose conflict minerals policies indicated that they intend not to source from the Covered Countries at all. In addition, EMC has applied to join the Public-Private Alliance for Responsible Minerals Trade (the PPA), a multi-sector and multi-stakeholder initiative to support supply chain solutions to conflict minerals challenges in the DRC and the Great Lakes Region of Central Africa.


Due Diligence Design

EMC’s due diligence framework conforms in all material respects with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and supplements (Second Edition, 2014).

Due Diligence Performed

Step 1: Establish strong company management systems
Published our company’s conflict minerals policy on EMC.com
Convened a Conflict Minerals Governance Committee to oversee program
Maintained an Implementation Team for program execution
Updated the Standard Operating Procedure
Improved the tools, processes and materials for supplier communications
Engaged EMC supply chain staff to support the conflict minerals program through existing business communications and processes
Maintained conflict minerals program data
Identified the EMC hotline, email address, and secure web report, which are publicly available on EMC.com, as the mechanism through which any interested party can voice concerns

Step 2: Identify and assess risks in the supply chainIdentified products and suppliers in scope
Surveyed suppliers in scope with the CMRT
Reviewed suppliers’ completed CMRTs to determine if they met internally-developed standards of reasonableness and risk
Reviewed smelters and refiners identified by suppliers
Confirmed 256 CFSI-verified 3TG smelters and refiners in our supply chain
155 of those smelters and refiners were CFSP-compliant as of April 30, 2015






Step 3: Design and implement a strategy to respond to identified risks
Convened the Conflict Minerals Governance Committee regularly to report metrics and discuss identified risks
Implemented a risk mitigation plan including:
Providing supplier education on conflict-free sourcing and how to improve reporting
Requiring Tier 1 suppliers to publish conflict minerals policies on their corporate websites
Adding supplier conflict mineral risk scores as an indicator in the supplier scorecard
Including conflict minerals risk scores and corrective actions in suppliers’ Executive and Quarterly Business Reviews
Participating in the CFSI’s Smelter Engagement Team to:
Perform research and outreach to verify smelters and refiners that were reported by suppliers but were not on CFSI’s smelter reference list
Communicate with verified smelters and refiners to ask them to become CFSP-compliant
Contributing to CFSI’s Initial Audit Fund, which pays the cost of a smelter or refiner’s first CFSP audit

Step 4: Plan an independent third-party audit of the smelter or refiner’s due diligence
Relied on the independent third-party audits managed by the CFSP
Supported the CFSP through active participation in CFSI workgroups

Step 5: Report annually on supply chain due diligence
Submitted Form SD for the calendar year ended December 31, 2014 to the U.S. Securities and Exchange Commission and published this report on EMC.com.

To Voice Concerns about EMC’s Conflict Minerals Program
EMC actively encourages its employees and other parties to report concerns either directly to the company or through EMC’s hotline, which is maintained by a third-party provider. The different ways through which reports can be made are included in EMC’s Business Conduct Guidelines, corporate compliance training materials, and elsewhere. Specifically, questions and guidance regarding a potential violation of law, regulation, the Business Conduct Guidelines, or other EMC policies can be reported in any of the following ways:
Contact the Office of the General Counsel by telephone (508-435-1000, extension 77267), facsimile (508-497-8079), or email (General_Counsel@emc.com).
Contact the Audit Committee of the EMC Board of Directors by email (AuditCommitteeChairman@emc.com) or by mail (Alertline, PMB 3767, 13950 Ballantyne Corporate Place, Charlotte, NC 28277).
If you are located within the United States, contact the EMC hotline, which is monitored by an independent third-party provider, by telephone (877-764-0557), or via a secure web report to https://emccorporation.alertline.com.

This report contains forward‑looking statements, within the meaning of the Federal securities laws, about our business and prospects. The forward-looking statements do not include the potential impact of any mergers, acquisitions, divestitures, securities offerings or business combinations that may be announced or closed after the date hereof. Any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “believes,” “plans,” “intends,” “expects,” “goals” and similar expressions are intended to identify forward-looking statements, although not all forward-looking statements contain these words. Our future results may differ materially from our past results and from those projected in the forward-looking statements due to various uncertainties and risks, including, but not limited to, those described in this report. The forward-looking statements speak only as of the date of this report and undue reliance should not be placed on these statements. We disclaim any obligation to update any forward-looking statements contained herein after the date of this report. Websites referred to in this report are not incorporated by reference unless specifically indicated.





Appendix A
3TG Smelters and Refiners in EMC’s Supply Chain
This list is based on EMC supplier data as of April 1, 2015. In many cases, suppliers provided information encompassing their entire supply chain; this information was not limited to facilities that contributed 3TG used only in EMC products. As a result, we are unable to validate whether our products in fact contain 3TG from all of these sources. Smelters listed as “Active” have committed to undergo a CFSP audit. This list only includes facilities reported by suppliers that are on the CFSI standard smelter list as of April 30, 2015.
Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
GOLD
 
 
 
Advanced Chemical Company
CID000015
UNITED STATES
 
Aida Chemical Industries Co., Ltd.
CID000019
JAPAN
Compliant
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
GERMANY
Compliant
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
UZBEKISTAN
 
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
BRAZIL
Compliant
Argor-Heraeus SA
CID000077
SWITZERLAND
Compliant
Asahi Pretec Corporation
CID000082
JAPAN
Compliant
Asaka Riken Co., Ltd.
CID000090
JAPAN
Active
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
TURKEY
Compliant
Aurubis AG
CID000113
GERMANY
Compliant
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
PHILIPPINES
 
Bauer Walser AG
CID000141
GERMANY
 
Boliden AB
CID000157
SWEDEN
Compliant
C. Hafner GmbH + Co. KG
CID000176
GERMANY
Compliant
Caridad
CID000180
MEXICO
 
CCR Refinery - Glencore Canada Corporation
CID000185
CANADA
Compliant
Cendres + Métaux SA
CID000189
SWITZERLAND
Active
Chimet S.p.A.
CID000233
ITALY
Compliant
Chugai Mining
CID000264
JAPAN
 
Daejin Indus Co., Ltd.
CID000328
KOREA, REPUBLIC OF
 
Daye Non-Ferrous Metals Mining Ltd.
CID000343
CHINA
 
Do Sung Corporation
CID000359
KOREA, REPUBLIC OF
 
Doduco
CID000362
GERMANY
Active
Dowa
CID000401
JAPAN
Compliant
Eco-System Recycling Co., Ltd.
CID000425
JAPAN
Compliant
Faggi Enrico S.p.A.
CID002355
ITALY
 
Gansu Seemine Material Hi-Tech Co., Ltd.
CID000522
CHINA
 
Geib Refining Corporation
CID002459
UNITED STATES
 
Guangdong Jinding Gold Limited
CID002312
CHINA
 
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
CHINA
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
CHINA
 
Heimerle + Meule GmbH
CID000694
GERMANY
Compliant
Heraeus Ltd. Hong Kong
CID000707
HONG KONG
Compliant
Heraeus Precious Metals GmbH & Co. KG
CID000711
GERMANY
Compliant
Hunan Chenzhou Mining Group Co., Ltd.
CID000767
CHINA
 
Hwasung CJ Co., Ltd.
CID000778
KOREA, REPUBLIC OF
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CID000801
CHINA
 
Ishifuku Metal Industry Co., Ltd.
CID000807
JAPAN
Compliant
Istanbul Gold Refinery
CID000814
TURKEY
Compliant
Japan Mint
CID000823
JAPAN
Compliant
Jiangxi Copper Company Limited
CID000855
CHINA
 





Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
Johnson Matthey Inc.
CID000920
UNITED STATES
Compliant
Johnson Matthey Limited
CID000924
CANADA
Compliant
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
RUSSIAN FEDERATION
Compliant
JSC Uralelectromed
CID000929
RUSSIAN FEDERATION
Compliant
JX Nippon Mining & Metals Co., Ltd.
CID000937
JAPAN
Compliant
Kazzinc
CID000957
KAZAKHSTAN
Compliant
Kennecott Utah Copper LLC
CID000969
UNITED STATES
Compliant
Kojima Chemicals Co., Ltd.
CID000981
JAPAN
Compliant
Korea Metal Co., Ltd.
CID000988
KOREA, REPUBLIC OF
 
Kyrgyzaltyn JSC
CID001029
KYRGYZSTAN
 
L' azurde Company For Jewelry
CID001032
SAUDI ARABIA
Compliant
Lingbao Gold Company Limited
CID001056
CHINA
 
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
CHINA
 
LS-NIKKO Copper Inc.
CID001078
KOREA, REPUBLIC OF
Compliant
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
CHINA
 
Materion
CID001113
UNITED STATES
Compliant
Matsuda Sangyo Co., Ltd.
CID001119
JAPAN
Compliant
Metalor Technologies (Hong Kong) Ltd.
CID001149
HONG KONG
Compliant
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
SINGAPORE
Compliant
Metalor Technologies (Suzhou) Ltd.
CID001147
CHINA
 
Metalor Technologies SA
CID001153
SWITZERLAND
Compliant
Metalor USA Refining Corporation
CID001157
UNITED STATES
Compliant
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
CID001161
MEXICO
Compliant
Mitsubishi Materials Corporation
CID001188
JAPAN
Compliant
Mitsui Mining and Smelting Co., Ltd.
CID001193
JAPAN
Compliant
Moscow Special Alloys Processing Plant
CID001204
RUSSIAN FEDERATION
 
Nadir Metal Rafineri San. Ve Tic. A.Ş.
CID001220
TURKEY
Compliant
Navoi Mining and Metallurgical Combinat
CID001236
UZBEKISTAN
 
Nihon Material Co., Ltd.
CID001259
JAPAN
Compliant
Ohio Precious Metals, LLC
CID001322
UNITED STATES
Compliant
Ohura Precious Metal Industry Co., Ltd.
CID001325
JAPAN
Compliant
OJSC Krastvetmet
CID001326
RUSSIAN FEDERATION
Compliant
OJSC Kolyma Refinery
CID001328
RUSSIAN FEDERATION
 
OJSC Novosibirsk Refinery
CID000493
RUSSIAN FEDERATION
 
PAMP SA
CID001352
SWITZERLAND
Compliant
Penglai Penggang Gold Industry Co., Ltd.
CID001362
CHINA
 
Prioksky Plant of Non-Ferrous Metals
CID001386
RUSSIAN FEDERATION
 
PT Aneka Tambang (Persero) Tbk
CID001397
INDONESIA
Compliant
Rand Refinery (Pty) Ltd.
CID001512
SOUTH AFRICA
Compliant
Republic Metals Corporation
CID002510
UNITED STATES
Compliant
Royal Canadian Mint
CID001534
CANADA
Compliant
Sabin Metal Corp.
CID001546
UNITED STATES
 
Samduck Precious Metals
CID001555
KOREA, REPUBLIC OF
 
SAMWON Metals Corp.
CID001562
KOREA, REPUBLIC OF
 
Schone Edelmetaal
CID001573
NETHERLANDS
Compliant
SEMPSA Joyería Platería SA
CID001585
SPAIN
Compliant
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
CHINA
 
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CHINA
Compliant
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
CHINA
Compliant
So Accurate Group, Inc.
CID001754
UNITED STATES
 
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
RUSSIAN FEDERATION
Active





Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
Solar Applied Materials Technology Corp.
CID001761
TAIWAN
Compliant
Sumitomo Metal Mining Co., Ltd.
CID001798
JAPAN
Compliant
Tanaka Kikinzoku Kogyo K.K.
CID001875
JAPAN
Compliant
The Great Wall Gold and Silver Refinery of China
CID001909
CHINA
 
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CHINA
Compliant
Tokuriki Honten Co., Ltd.
CID001938
JAPAN
Compliant
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
CHINA
 
Torecom
CID001955
KOREA, REPUBLIC OF
Active
Umicore Brasil Ltda.
CID001977
BRAZIL
Compliant
Umicore Precious Metals Thailand
CID002314
THAILAND
Compliant
Umicore SA Business Unit Precious Metals Refining
CID001980
BELGIUM
Compliant
United Precious Metal Refining, Inc.
CID001993
UNITED STATES
Compliant
Valcambi SA
CID002003
SWITZERLAND
Compliant
Western Australian Mint trading as The Perth Mint
CID002030
AUSTRALIA
Compliant
Yamamoto Precious Metal Co., Ltd.
CID002100
JAPAN
Compliant
Yokohama Metal Co., Ltd.
CID002129
JAPAN
Active
Yunnan Copper Industry Co., Ltd.
CID000197
CHINA
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CHINA
Compliant
Zijin Mining Group Co., Ltd. Gold Refinery
CID002243
CHINA
Compliant
TANTALUM
 
 
 
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CHINA
Compliant
Conghua Tantalum and Niobium Smeltry
CID000291
CHINA
Compliant
Duoluoshan
CID000410
CHINA
Compliant
Exotech Inc.
CID000456
UNITED STATES
Compliant
F&X Electro-Materials Ltd.
CID000460
CHINA
Compliant
Global Advanced Metals Aizu
CID002558
UNITED STATES
Compliant
Global Advanced Metals Boyertown
CID002557
UNITED STATES
Compliant
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
CHINA
Compliant
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
CID002501
CHINA
Compliant
H.C. Starck Co., Ltd.
CID002544
THAILAND
Compliant
H.C. Starck GmbH Goslar
CID002545
GERMANY
Compliant
H.C. Starck GmbH Laufenburg
CID002546
GERMANY
Compliant
H.C. Starck Hermsdorf GmbH
CID002547
GERMANY
Compliant
H.C. Starck Inc.
CID002548
UNITED STATES
Compliant
H.C. Starck Ltd.
CID002549
JAPAN
Compliant
H.C. Starck Smelting GmbH & Co.KG
CID002550
GERMANY
Compliant
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
CHINA
Compliant
Hi-Temp Specialty Metals, Inc.
CID000731
UNITED STATES
Compliant
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
CHINA
Compliant
Jiujiang Tanbre Co., Ltd.
CID000917
CHINA
Compliant
KEMET Blue Metals
CID002539
MEXICO
Compliant
KEMET Blue Powder
CID002568
UNITED STATES
Compliant
King-Tan Tantalum Industry Ltd.
CID000973
CHINA
Compliant
LSM Brasil S.A.
CID001076
BRAZIL
Compliant
Metallurgical Products India Pvt., Ltd.
CID001163
INDIA
Compliant
Mineração Taboca S.A.
CID001175
BRAZIL
Compliant
Mitsui Mining & Smelting
CID001192
JAPAN
Compliant
Molycorp Silmet A.S.
CID001200
ESTONIA
Compliant
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CHINA
Compliant
Plansee SE Liezen
CID002540
AUSTRIA
Compliant
Plansee SE Reutte
CID002556
AUSTRIA
Compliant





Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
QuantumClean
CID001508
UNITED STATES
Compliant
RFH Tantalum Smeltry Co., Ltd.
CID001522
CHINA
Compliant
Solikamsk Magnesium Works OAO
CID001769
RUSSIAN FEDERATION
Compliant
Taki Chemicals
CID001869
JAPAN
Compliant
Telex Metals
CID001891
UNITED STATES
Compliant
Ulba Metallurgical Plant JSC
CID001969
KAZAKHSTAN
Compliant
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
CHINA
Compliant
Zhuzhou Cemented Carbide
CID002232
CHINA
Compliant
TIN
 
 
 
Alpha
CID000292
UNITED STATES
Compliant
China Tin Group Co., Ltd.
CID001070
CHINA
Active
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
CHINA
 
Cooperativa Metalurgica de Rondônia Ltda.
CID000295
BRAZIL
Compliant
CV Gita Pesona
CID000306
INDONESIA
 
CV Serumpun Sebalai
CID000313
INDONESIA
 
CV United Smelting
CID000315
INDONESIA
Compliant
Dowa
CID000402
JAPAN
Compliant
EM Vinto
CID000438
BOLIVIA
Compliant
Estanho de Rondônia S.A.
CID000448
BRAZIL
 
Feinhütte Halsbrücke GmbH
CID000466
GERMANY
 
Fenix Metals
CID000468
POLAND
Active
Gejiu Kai Meng Industry and Trade LLC
CID000942
CHINA
 
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CHINA
Compliant
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
CHINA
 
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
CHINA
 
Huichang Jinshunda Tin Co., Ltd.
CID000760
CHINA
 
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
CHINA
Compliant
Linwu Xianggui Ore Smelting Co., Ltd.
CID001063
CHINA
 
Magnu's Minerais Metais e Ligas Ltda.
CID002468
BRAZIL
Compliant
Malaysia Smelting Corporation (MSC)
CID001105
MALAYSIA
Compliant
Melt Metais e Ligas S/A
CID002500
BRAZIL
Compliant
Metallic Resources, Inc.
CID001142
UNITED STATES
 
Metallo-Chimique N.V.
CID002773
BELGIUM
Compliant
Mineração Taboca S.A.
CID001173
BRAZIL
Compliant
Minsur
CID001182
PERU
Compliant
Mitsubishi Materials Corporation
CID001191
JAPAN
Compliant
Nankang Nanshan Tin Manufactory Co., Ltd.
CID001231
CHINA
 
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
VIET NAM
Active
Novosibirsk Processing Plant Ltd.
CID001305
RUSSIAN FEDERATION
 
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
THAILAND
Active
O.M. Manufacturing Philippines, Inc.
CID002517
Philippines
Active
Operaciones Metalurgical S.A.
CID001337
BOLIVIA
Compliant
PT Alam Lestari Kencana
CID001393
INDONESIA
 
PT Aries Kencana Sejahtera
CID000309
INDONESIA
Active
PT Artha Cipta Langgeng
CID001399
INDONESIA
Compliant
PT ATD Makmur Mandiri Jaya
CID002503
INDONESIA
Compliant
PT Babel Inti Perkasa
CID001402
INDONESIA
Compliant
PT Bangka Kudai Tin
CID001409
INDONESIA
 
PT Bangka Putra Karya
CID001412
INDONESIA
Compliant
PT Bangka Timah Utama Sejahtera
CID001416
INDONESIA
 
PT Bangka Tin Industry
CID001419
INDONESIA
Compliant





Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
PT Belitung Industri Sejahtera
CID001421
INDONESIA
Compliant
PT BilliTin Makmur Lestari
CID001424
INDONESIA
Active
PT Bukit Timah
CID001428
INDONESIA
Compliant
PT DS Jaya Abadi
CID001434
INDONESIA
Compliant
PT Eunindo Usaha Mandiri
CID001438
INDONESIA
Compliant
PT Fang Di MulTindo
CID001442
INDONESIA
 
PT Inti Stania Prima
CID002530
INDONESIA
Active
PT Justindo
CID000307
INDONESIA
Active
PT Karimun Mining
CID001448
INDONESIA
Active
PT Mitra Stania Prima
CID001453
INDONESIA
Compliant
PT Panca Mega Persada
CID001457
INDONESIA
Compliant
PT Pelat Timah Nusantara Tbk
CID001486
INDONESIA
 
PT Prima Timah Utama
CID001458
INDONESIA
Compliant
PT Refined Bangka Tin
CID001460
INDONESIA
Compliant
PT Sariwiguna Binasentosa
CID001463
INDONESIA
Compliant
PT Seirama Tin Investment
CID001466
INDONESIA
 
PT Stanindo Inti Perkasa
CID001468
INDONESIA
Compliant
PT Sumber Jaya Indah
CID001471
INDONESIA
Active
PT Supra Sukses Trinusa
CID001476
INDONESIA
 
PT Timah (Persero) Tbk Kundur
CID001477
INDONESIA
Compliant
PT Timah (Persero) Tbk Mentok
CID001482
INDONESIA
Compliant
PT Tinindo Inter Nusa
CID001490
INDONESIA
Compliant
Rui Da Hung
CID001539
TAIWAN
Active
Soft Metais Ltda.
CID001758
BRAZIL
Active
Thaisarco
CID001898
THAILAND
Compliant
VQB Mineral and Trading Group JSC
CID002015
VIET NAM
Active
White Solder Metalurgia e Mineração Ltda.
CID002036
BRAZIL
Compliant
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
CHINA
Active
Yunnan Tin Group (Holding) Company Limited
CID002180
CHINA
Compliant
TUNGSTEN
 
 
 
A.L.M.T. TUNGSTEN Corp.
CID000004
JAPAN
Active
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
China
Compliant
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
CHINA
Active
Dayu Weiliang Tungsten Co., Ltd.
CID000345
CHINA
 
Fujian Jinxin Tungsten Co., Ltd.
CID000499
CHINA
Compliant
Ganxian Shirui New Material Co., Ltd.
CID002531
CHINA
 
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
CHINA
Compliant
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
CHINA
Compliant
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CID000868
CHINA
Active
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CHINA
Compliant
Global Tungsten & Powders Corp.
CID000568
UNITED STATES
Compliant
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CHINA
Active
H.C. Starck GmbH
CID002541
GERMANY
Active
H.C. Starck Smelting GmbH & Co.KG
CID002542
GERMANY
Active
Hunan Chenzhou Mining Group Co., Ltd.
CID000766
CHINA
Active
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
CHINA
Compliant
Japan New Metals Co., Ltd.
CID000825
JAPAN
Compliant
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
CHINA
 
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
CHINA
Compliant
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
CHINA
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
CHINA
 





Smelter or Refiner Name
Smelter Identification Number
Smelter or Refiner
Location
CFSP-Compliant status as of 4/30/15
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
CHINA
 
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
CHINA
 
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
CHINA
Active
Kennametal Fallon
CID000966
UNITED STATES
 
Kennametal Huntsville
CID000105
UNITED STATES
 
Malipo Haiyu Tungsten Co., Ltd.
CID002319
CHINA
Compliant
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
VIET NAM
Active
Pobedit, JSC
CID002532
RUSSIAN FEDERATION
 
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
VIET NAM
 
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
VIET NAM
Compliant
Wolfram Bergbau und Hütten AG
CID002044
AUSTRIA
Compliant
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CHINA
Compliant
Xiamen Tungsten Co., Ltd.
CID002082
CHINA
Compliant
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
CHINA
Active






Appendix B
Countries from which the minerals in EMC’s products may have originated
Based on CFSI’s Reasonable Country of Origin Inquiry report dated April 30, 2015, the countries of origin of the 3TG processed by facilities listed in Appendix A are believed to include the following:

 
Angola
Luxembourg
Argentina
Madagascar
Australia
Malaysia
Austria
Mongolia
Belgium
Mozambique
Bolivia
Myanmar
Brazil
Namibia
Burundi
Netherlands
Canada
Nigeria
Central African Republic
Peru
Chile
Portugal
China
Republic of Congo
Colombia
Russia
Cote D’Ivoire
Rwanda
Czech Republic
Sierra Leone
Democratic Republic of the Congo
Singapore
Djibouti
Slovakia
Egypt
South Africa
Estonia
South Korea
Ethiopia
South Sudan
France
Spain
Germany
Suriname
Guyana
Switzerland
Hungary
Taiwan
India
Tanzania
Indonesia
Thailand
Ireland
Uganda
Israel
United Kingdom
Japan
United States of America
Kazakhstan
Vietnam
Kenya
Zambia
Laos
Zimbabwe