0001477294-16-000200.txt : 20160531 0001477294-16-000200.hdr.sgml : 20160531 20160531164856 ACCESSION NUMBER: 0001477294-16-000200 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20151231 1.02 20151231 FILED AS OF DATE: 20160531 DATE AS OF CHANGE: 20160531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Sensata Technologies Holding N.V. CENTRAL INDEX KEY: 0001477294 STANDARD INDUSTRIAL CLASSIFICATION: INDUSTRIAL INSTRUMENTS FOR MEASUREMENT, DISPLAY, AND CONTROL [3823] IRS NUMBER: 000000000 STATE OF INCORPORATION: P7 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-34652 FILM NUMBER: 161686546 BUSINESS ADDRESS: STREET 1: KOLTHOFSINGEL 8 CITY: ALMEMO STATE: P7 ZIP: 7602 EM BUSINESS PHONE: 31-546-979-450 MAIL ADDRESS: STREET 1: KOLTHOFSINGEL 8 CITY: ALMEMO STATE: P7 ZIP: 7602 EM FORMER COMPANY: FORMER CONFORMED NAME: Sensata Technologies Holding B.V. DATE OF NAME CHANGE: 20091120 SD 1 sensataformsd2016.htm FORM SD Document




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_____________________________________________________________

FORM SD

SPECIALIZED DISCLOSURE REPORT
_____________________________________________________________


SENSATA TECHNOLOGIES HOLDING N.V.
_____________________________________________________________

(Exact name of the registrant as specified in its charter)



THE NETHERLANDS
001-34652
98-0641254
(State or other jurisdiction of
incorporation or organization)
(Commission File Number)
(I.R.S. Employer
Identification No.)
 
 


Kolthofsingel 8, 7602 EM Almelo
The Netherlands
_____________________________________________________________

(Address of principal executive offices, including zip code)


Steven Reynolds
(508) 236-3800
_____________________________________________________________

(Name and telephone number, including area code, of the
person to contact in connection with this 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:
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015



Section 1 – Conflict Minerals Disclosure
Item 1.01    Conflict Minerals Disclosure and Report
Statements in this Specialized Disclosure Report ("Form SD") and the attached Conflict Minerals Report which are not historical facts, such as those that may be identified by the use of words such as "anticipate," "believe," "could," "estimate," "expect," "feel," "forecast," "intend," "may," "plan," "potential," "project," "should," "would," and similar expressions, are forward-looking statements under the provisions of the Private Securities Litigation Reform Act of 1995. By their nature, forward-looking statements involve risks and uncertainties because they relate to events and depend on circumstances that may or may not occur in the future. These risks and uncertainties include, but are not limited to, our ability to successfully implement our Conflict Minerals program and engage suppliers in obtaining more responsive and complete information. Forward-looking statements reflect management's analysis as of the date of this filing. Additional important factors that could cause actual procedures performed to differ materially from our expectations are more fully described in our filings with the Securities and Exchange Commission (the “SEC”). Except as required by applicable law, we do not undertake to publicly update or revise any of these forward-looking statements, whether as a result of new information, future events, or otherwise. Copies of our filings are available from our Investor Relations department or from the SEC website, www.sec.gov.
The Dodd-Frank Wall Street Reform and Consumer Protection Act, which was signed into law in July 2010, mandated that the SEC create rules that assess whether certain materials (Conflict Minerals, as defined below) originating in the Democratic Republic of the Congo (the “DRC”) or adjoining countries (the DRC and adjoining countries are together referred to as the “Covered Countries”) were benefiting armed groups in the area. In August 2012, the SEC issued its final rule, Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"), on the reporting of Conflict Minerals.
Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals, referred to as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite, and wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Covered Countries.
This Form SD is provided in accordance with Rule 13p-1 for the period from January 1, 2015 to December 31, 2015 (the "Reporting Period").
Conflict Minerals Disclosure
We manufacture, or contract to manufacture, products for which Conflict Minerals are necessary to the functionality or production of those products. As a result, in the prior year, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals included in our products, in order to determine whether any of these Conflict Minerals originated in the Covered Countries and were not from recycled or scrap sources. We believe that our RCOI was reasonably designed to determine whether any of the Conflict Minerals that are necessary to the functionality of our products originated in the Covered Countries, and if so, whether they were from recycled or scrap sources.
Pursuant to Rule 13p-1, if, a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in one of the Covered Countries, or if such registrant is unable to determine the country of origin of those Conflict Minerals, then it must file a Conflict Minerals Report with the SEC describing the due

2


diligence measures it has undertaken or will undertake regarding the source and chain of custody of these Conflict Minerals.
During the course of our RCOI, we received responses from our suppliers that detailed smelters from which Conflict Minerals were sourced. However, we do not have sufficient information based on the results of our RCOI to allow us to make a determination as to which of these smelters provided Conflict Minerals that were used in the production of components that we purchased from these suppliers, or the country of origin of these Conflict Minerals.
As a result, a description of the measures we undertook to exercise due diligence on the source and chain of custody of Conflict Minerals contained in our products manufactured during the Reporting Period is provided in the Conflict Minerals Report attached hereto as Exhibit 1.01. A copy of our Conflict Minerals Report is also publicly available at www.sensata.com.
Item 1.02    Exhibit
We have filed, as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.
Section 2 - Exhibits
Item 2.01    Exhibits
Exhibit No.
 
Description
 
 
1.01
 
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.


3


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 hereunto duly authorized.
 


 
 
 
 
SENSATA TECHNOLOGIES HOLDING N.V.
 
 
 
 
 
 
 
/s/ Paul Vasington
Date: May 31, 2016
 
 
 
Name: Paul Vasington
 
 
 
 
Title: Executive Vice President and Chief Financial Officer


EX-1.01 2 sensatacmr2016.htm CONFLICT MINERALS REPORT Exhibit


Exhibit 1.01

Conflict Minerals Report of Sensata Technologies Holding N.V.
in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1")

The reporting company is Sensata Technologies Holding N.V. and its wholly-owned subsidiaries, collectively referred to as “the Company,” “Sensata,” “we,” “our,” and “us.” Sensata is a global industrial technology company, engaged in the development, manufacture, and sale of sensors and controls. We produce a wide range of customized, innovative sensors and controls for mission-critical applications such as thermal circuit breakers in aircraft, pressure sensors in automotive systems, and bimetal current and temperature control devices in electric motors.
The Dodd-Frank Wall Street Reform and Consumer Protection Act, which was signed into law in July 2010, mandated that the U.S. Securities and Exchange Commission (the “SEC”) create rules that assess whether certain materials (Conflict Minerals, as defined below) originating in the Democratic Republic of the Congo (the “DRC”) or adjoining countries (the DRC and adjoining countries are together referred to as the “Covered Countries”) were benefiting armed groups in the area. In August 2012, the SEC issued its final rule, Rule 13p-1, on the reporting of Conflict Minerals.
Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products, and the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals, referred to as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite, and wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, or any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Covered Countries. Because we manufacture, or contract to manufacture, products for which Conflict Minerals are necessary to the functionality or production of those products, we are subject to the requirements of Rule 13p-1.
Reasonable Country of Origin Inquiry ("RCOI")
In the prior year, we conducted in good faith an RCOI regarding the Conflict Minerals included in our products, in order to determine whether any of these Conflict Minerals originated in the Covered Countries and were not from recycled or scrap sources. We believe that our RCOI was reasonably designed to determine whether any of the Conflict Minerals that are necessary to the functionality of our products originated in the Covered Countries, and if so, whether they were from recycled or scrap sources.
Pursuant to Rule 13p-1, if a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in one of the Covered Countries, or if such registrant is unable to determine the country of origin of those Conflict Minerals, it must file a Conflict Minerals Report with the SEC describing the due diligence measures it has undertaken or will undertake regarding the source and chain of custody of these Conflict Minerals. Because our RCOI from the prior year was not conclusive regarding the country of origin of the Conflict Minerals used in our products, we are providing this Conflict Minerals Report in accordance with Rule 13p-1 for the period from January 1, 2015 to December 31, 2015 (the "Reporting Period").
Most of our products contain at least one of the Conflict Minerals and fall under the scope of the requirements of Rule 13p-1. Therefore, this disclosure includes information on a company level, including general information for all of our products.
Our RCOI was conducted for all significant direct suppliers that we believe may supply components that contain Conflict Minerals. We utilized the Conflict Free Sourcing Initiative ("CFSI") Conflict Minerals Reporting Template ("CMRT") for each supplier surveyed. The CMRT is a standardized reporting template that was developed to facilitate the transfer of information through the supply chain regarding material country of origin and smelters and refiners being utilized. It includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, and a listing of the smelters the direct supplier and its suppliers use. In addition, the CMRT

1



contains questions about the origin of Conflict Minerals included in the direct supplier’s products, as well as supplier due diligence. Many companies are using the CMRT in their compliance processes related to conflict minerals.
In the Reporting Period, we identified tools and third party providers that we intend to utilize to perform much of the administrative tasks related to future supplier surveys that will help us perform a more robust RCOI in the future.
OECD due diligence procedures
Because we do not have sufficient information to allow us to make a determination as to the country of origin of the Conflict Minerals in our supply chain, we have performed due diligence on these Conflict Minerals using the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the "OECD Framework"). This due diligence process is described below.
Step 1: Establish company management systems
The purpose of Step 1 of the OECD Framework is to establish strong company management systems by developing a Conflict Minerals strategy and policy, identifying the key stakeholders (the participants who will carry out the initiative), establishing a system of controls and transparency over the supply chain, and establishing a grievance mechanism.
As part of our implementation of this phase of the OECD Framework, we have identified a team (the "Conflict Minerals Team") that includes members from business leadership, legal, finance, and operations. The Conflict Minerals Team functions to periodically review the status of our Conflict Minerals program, ensure that we are making progress towards meeting our compliance goals, and ensure the adequacy of our due diligence process in accordance with the OECD Framework. Certain members of senior management are responsible for overseeing the RCOI, due diligence, and reporting processes.
Our compliance goals include ensuring that we have adequate procedures in place to determine and document which of our products do or may include Conflict Minerals and whether any of our suppliers have sourced Conflict Minerals that have been used in the production of components supplied to us from the Covered Countries.
We utilize best-cost sourcing to the extent possible to keep our costs down. Many of our suppliers are selected in order to maintain quality and performance standards, and many must be qualified based on certain specifications with our customers, in which case customer approval may be required to change suppliers. In addition, in many cases we source our products on a sole-source basis. As a result, in certain circumstances we are limited in our ability to influence our suppliers to modify their sourcing practices or to respond to our RCOI survey requests.
However, the Conflict Minerals Team has developed a policy (the "Conflict Minerals Policy"), which states that: (1) we support the improvement of human rights in the DRC and surrounding areas; (2) we will comply with Rule 13p-1, (3) we will endeavor to direct our business, as much as practical given the constraints noted above, to suppliers who (i) have traceable supply chains, (ii) freely share their data and cooperate with us in identifying whether they have sourced Conflict Minerals from the Covered Countries, and whether any such sourcing has benefited the armed conflict in the region, and (iii) source responsibly; and (4) we will support our customers' inquiries about the source of Conflict Minerals that we use in our manufacturing with responses that are at the supplier (rather than product) level. We periodically monitor our Conflict Minerals Policy to ensure its adequacy. During the Reporting Period, we made changes to the policy and posted the revisions on our website. The most recent Conflict Minerals Policy can be found on the "Investor Relations" page of our website at www.sensata.com.
We have a Code of Business Conduct and Ethics, which outlines expected behaviors for all of our employees. We also have a previously-established grievance mechanism (our ethics hotline), pursuant to which any of our employees may report any concerns involving Conflict Minerals. In February 2014, we added a clause in our

2



standard terms and conditions that states that suppliers must comply with the requirements of the Conflict Minerals regulations.
Step 2: Identify and assess risks in the supply chain
The purpose of Step 2 of the OECD Framework is to identify risks in the supply chain and evaluate these risks. We did this by creating a list of suppliers of products with Conflict Minerals and by conducting a supplier survey in the prior year.
Our global supply chain is complex and we are many tiers removed from, and have no direct relationships with, the smelters or mining companies that may have direct knowledge of the source of the Conflict Minerals used in our products, and whether these Conflict Minerals are financing the armed conflict in the Covered Countries. As a result, we rely on our direct suppliers to provide us with information regarding the origin of any Conflict Minerals that are included in our products, including, where possible, the smelter's origin. Similarly, our suppliers may depend on their direct suppliers for this information.
In our implementation of this step of the OECD Framework, we (1) identified the Conflict Minerals used in our products, (2) identified the products and components that we believe contain these Conflict Minerals, and (3) identified the suppliers that provide these products and components to us. We surveyed certain of these suppliers (those that represented more than an insignificant amount of spend) in the prior year using the CMRT.
We received and reviewed responses from most of the suppliers we surveyed in the prior year. The responses received indicated either that the supplier was complete with its analysis and had determined that the Conflict Minerals it provides originated from conflict-free sources, or that its analysis was incomplete. We did not receive any responses that indicated that a supplier sourced Conflict Minerals from a Covered Country and that such sourcing benefited the armed conflict in the region. We did not re-perform or update this survey for the Reporting Period.
However, in the Reporting Period, we identified tools and third party providers that we intend to utilize to perform much of the administrative tasks related to supplier surveys that will help us perform a robust survey in the future.
Step 3: Design and implement a risk response strategy
The purpose of Step 3 of the OECD Framework is to respond to identified risks in order to prevent or mitigate potential adverse impacts.
As noted in Step 2 above, we utilized the CMRT for each supplier surveyed in the prior year. One of the risks identified in the process is that our suppliers might not provide us valid or complete information, or might not provide information at all, and as a result, we might not be aware of circumstances in which certain suppliers sourced from the Covered Countries and whether such sourcing benefited the armed conflict in the region.
In order to mitigate this risk, in the prior year we reviewed templates received from surveyed suppliers for completeness and reasonableness. Completeness was assessed based on whether the supplier fully completed the "Declaration" tab of the CMRT. We also assessed responses from our surveyed suppliers to ensure that they were reasonably reliable and did not contain certain defined inconsistencies. We followed up with suppliers that provided an incomplete or inconsistent response by e-mail or phone. We did not re-perform this process for this Reporting Period.
With regard to smelters reported by our suppliers on their CMRT, (1) we cross-referenced each smelter with the CMRT's list of known smelters, and (2) for those smelters that were not identified on the CMRT, we cross-referenced the smelter with the U.S. Department of Commerce's listing of tin, tantalum, tungsten, and gold smelters and refiners published in September 2014 to verify the existence of the smelter. We also reviewed the CFSI website to determine whether each smelter was identified as a "conflict-free smelter," or whether it was in the process of obta

3



ining an audit, as evidenced by it being on the CFSI's "Active" list. Over 71% of the smelters identified were reported by CFSI as either certified or in the process of being certified as of December 31, 2015 (which does not include smelters whose certification expired before December 31, 2015 and that were not in the process of being re-audited).
We used the most recent CMRT template in our responses to our customers, which provides the most up to date list of known smelters with which to cross reference the smelter listings provided by our suppliers.
Based on the results of our due diligence process, we do not have sufficient information to allow us to make a determination as to which of these smelters provided Conflict Minerals that were used in the production of components that we purchased, or which of these Conflict Minerals were sourced from the Covered Countries. Based on information derived from responses obtained from our suppliers and our due diligence efforts, the smelters listed in Appendix I may have been used to process necessary Conflict Minerals that were used in our products.
Step 4: Carry out independent third-party audits of smelter/refiner due diligence process
We are not currently a member of the CFSI. However, we leverage the due diligence conducted on smelters and refiners by the CFSP. The CFSP uses independent private sector auditors to audit the source, including mines of origin and chain of custody, of the Conflict Minerals used by smelters and refiners that agree to participate in the CFSP. The smelters and refiners that are found to be CFSP compliant are those for which the independent auditor has verified that the smelter’s or refiner’s Conflict Minerals either did not originate from the Covered Countries or originated from conflict-free mines in the Covered Countries.
Step 5: Report annually on supply chain due diligence
This Conflict Minerals Report and Form SD are being filed in order to comply with Step 5 of the OECD Framework.
Conclusion
During the Reporting Period, we maintained company management systems over the Conflict Minerals process, including updating our Conflict Minerals Policy, and maintaining our ethics hotline and Code of Business Conduct and Ethics.
We also identified tools and third party providers that we intend to utilize to perform much of the administrative tasks related to supplier surveys that will help us perform a robust survey in the future.
We reported on our Conflict Minerals program to our customers using the most recent CMRT template in order to ensure accuracy of the smelter listing provided.
However, based on our due diligence processes, we are not able to determine the source or country of origin of all of the Conflict Minerals that were used to manufacture our products during the Reporting Period.
Steps to take in the coming year
As our Conflict Minerals program continues into next year, we plan to take additional steps to improve our due diligence processes. Specifically, in the next reporting period, we intend to make good faith efforts to conduct a survey of our supplier base representing a significant portion of our spend and perform additional due diligence procedures based on these survey responses. We intend to utilize the services of a third party provider, thereby reducing the administrative burden of this effort, and improving our ability to identify and respond to related risks.
We intend to continue to develop methods, implement tools, and adopt procedures that are designed to be in accordance with the OECD Framework. We also intend to make reasonable efforts to strengthen company

4



engagement with suppliers and continue structuring internal management systems to support supply chain due diligence.
This Conflict Minerals Report can be found on our website at www.sensata.com. The content on our web site is not incorporated by reference into this Conflict Minerals Report unless expressly noted.

5



Appendix I: Smelter List
Based on information derived from responses obtained from our suppliers and our due diligence efforts, these smelters may have been used to process necessary Conflict Minerals in our products:
Mineral
 
Smelter or Refiner Facility Name
 
Location
Gold
 
Aida Chemical Industries Co. Ltd. *
 
JAPAN
Gold
 
Allgemeine Gold-und Silberscheideanstalt A.G. *
 
GERMANY
Gold
 
Almalyk Mining and Metallurgical Complex (AMMC) **
 
UZBEKISTAN
Gold
 
AngloGold Ashanti Córrego do Sítio Minerção *
 
BRAZIL
Gold
 
Argor-Heraeus SA *
 
SWITZERLAND
Gold
 
Asahi Pretec Corporation *
 
JAPAN
Gold
 
Asaka Riken Co Ltd *
 
JAPAN
Gold
 
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
 
TURKEY
Gold
 
Aurubis AG *
 
GERMANY
Gold
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) ***
 
PHILIPPINES
Gold
 
Bauer Walser AG
 
GERMANY
Gold
 
Boliden AB *
 
SWEDEN
Gold
 
C. Hafner GmbH + Co. KG *
 
GERMANY
Gold
 
Caridad
 
MEXICO
Gold
 
CCR Refinery – Glencore Canada Corporation *
 
CANADA
Gold
 
Cendres & Métaux SA **
 
SWITZERLAND
Gold
 
CHALCO Yunnan Copper Co. Ltd.
 
CHINA
Gold
 
Chimet S.p.A. *
 
ITALY
Gold
 
Chugai Mining
 
JAPAN
Gold
 
Codelco
 
CHILE
Gold
 
Daejin Indus Co. Ltd **
 
KOREA, REPUBLIC OF
Gold
 
Daye Non-Ferrous Metals Mining Ltd.
 
CHINA
Gold
 
Do Sung Corporation **
 
KOREA, REPUBLIC OF
Gold
 
Doduco *
 
GERMANY
Gold
 
Dowa *
 
JAPAN
Gold
 
Eco-System Recycling Co., Ltd. *
 
JAPAN
Gold
 
FSE Novosibirsk Refinery
 
RUSSIAN FEDERATION
Gold
 
Gansu Seemine Material Hi-Tech Co Ltd
 
CHINA
Gold
 
Guangdong Jinding Gold Limited
 
CHINA
Gold
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
 
CHINA
Gold
 
Heimerle + Meule GmbH ***
 
GERMANY
Gold
 
Heraeus Ltd. Hong Kong *
 
China
Gold
 
Heraeus Precious Metals GmbH & Co. KG *
 
GERMANY
Gold
 
Hunan Chenzhou Mining Industry Group
 
CHINA
Gold
 
Hwasung CJ Co., Ltd.
 
KOREA, REPUBLIC OF
Gold
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited *
 
CHINA
Gold
 
Ishifuku Metal Industry Co., Ltd. *
 
JAPAN
Gold
 
Istanbul Gold Refinery *
 
TURKEY
Gold
 
Japan Mint *
 
JAPAN
Gold
 
Jiangxi Copper Company Limited *
 
CHINA
Gold
 
Johnson Matthey Inc
 
UNITED STATES
Gold
 
Johnson Matthey Ltd
 
CANADA
Gold
 
JSC Ekaterinburg Non-Ferrous Metal Processing Plant *
 
RUSSIAN FEDERATION
Gold
 
JSC Uralectromed *
 
RUSSIAN FEDERATION
Gold
 
JX Nippon Mining & Metals Co., Ltd. *
 
JAPAN
Gold
 
Kennecott Utah Copper LLC *
 
UNITED STATES
Gold
 
Kojima Chemicals Co., Ltd *
 
JAPAN
Gold
 
Korea Metal Co. Ltd
 
KOREA, REPUBLIC OF

6



Mineral
 
Smelter or Refiner Facility Name
 
Location
Gold
 
Kyrgyzaltyn JSC
 
KYRGYZSTAN
Gold
 
L' azurde Company For Jewelry
 
SAUDI ARABIA
Gold
 
Lingbao Gold Company Limited
 
CHINA
Gold
 
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
 
CHINA
Gold
 
LS-NIKKO Copper Inc. *
 
KOREA, REPUBLIC OF
Gold
 
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
 
CHINA
Gold
 
Luoyang Zijin Yinhui Metal Smelt Co Ltd
 
CHINA
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
 
Met-Mex Peñoles, S.A.
 
MEXICO
Gold
 
Mitsubishi Materials Corporation *
 
JAPAN
Gold
 
Mitsui Mining and Smelting Co., Ltd. *
 
JAPAN
Gold
 
Moscow Special Alloys Processing Plant *
 
RUSSIAN FEDERATION
Gold
 
Navoi Mining and Metallurgical Combinat **
 
UZBEKISTAN
Gold
 
Nihon Material Co. LTD *
 
JAPAN
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) *
 
RUSSIAN FEDERATION
Gold
 
OJSC Kolyma Refinery *
 
RUSSIAN FEDERATION
Gold
 
PAMP SA *
 
SWITZERLAND
Gold
 
Penglai Penggang Gold Industry Co Ltd
 
CHINA
Gold
 
Prioksky Plant of Non-Ferrous Metals *
 
RUSSIAN FEDERATION
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
 
Sabin Metal Corp.
 
UNITED STATES
Gold
 
SAMWON METALS Corp.
 
KOREA, REPUBLIC OF
Gold
 
SAXONIA Edelmetalle GmbH **
 
GERMANY
Gold
 
Schone Edelmetaal *
 
NETHERLANDS
Gold
 
SEMPSA Joyería Platería SA *
 
SPAIN
Gold
 
Shandong Tarzan Bio-Gold Industry Co., Ltd.
 
CHINA
Gold
 
Shandong Tiancheng Biological Gold Industrial Co. Ltd.
 
CHINA
Gold
 
Shandong Zhaojin Gold & Silver Refinery Co. Ltd ***
 
CHINA
Gold
 
So Accurate Group, Inc.
 
UNITED STATES
Gold
 
SOE Shyolkovsky Factory of Secondary Precious Metals *
 
RUSSIAN FEDERATION
Gold
 
Solar Applied Materials Technology Corp. *
 
TAIWAN
Gold
 
Sumitomo Metal Mining Co., Ltd. *
 
JAPAN
Gold
 
Tanaka Kikinzoku Kogyo K.K. *
 
JAPAN
Gold
 
The Great Wall Gold and Silver Refinery of China
 
CHINA
Gold
 
The Refinery of Shandong Gold Mining Co. Ltd ***
 
CHINA
Gold
 
Tokuriki Honten Co., Ltd *
 
JAPAN
Gold
 
Tongling Nonferrous Metals Group Co., Ltd.
 
CHINA
Gold
 
Torecom **
 
KOREA, REPUBLIC OF
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

7



Mineral
 
Smelter or Refiner Facility Name
 
Location
Gold
 
Western Australian Mint trading as The Perth Mint *
 
AUSTRALIA
Gold
 
WIELAND Edelmetalle GmbH **
 
GERMANY
Gold
 
Wieland-Werke AG
 
GERMANY
Gold
 
YAMAMOTO PRECIOUS METAL CO., LTD. *
 
JAPAN
Gold
 
Yokohama Metal Co., Ltd. *
 
JAPAN
Gold
 
Yunnan Copper Industry Co Ltd
 
CHINA
Gold
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation *
 
CHINA
Gold
 
Zijin Mining Group Co., Ltd. Gold Refinery ***
 
CHINA
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
 
Global Advanced Metals *
 
UNITED STATES
Tantalum
 
Guangdong Zhiyuan New Material Co., Ltd. *
 
CHINA
Tantalum
 
H.C Starck GmbH Goslar *
 
GERMANY
Tantalum
 
Hengyang King Xing Lifeng New Materials Co., Ltd. *
 
CHINA
Tantalum
 
Hi-Temp *
 
UNITED STATES
Tantalum
 
JiuJiang JinXin Nonferrous Metals Co., Ltd. *
 
CHINA
Tantalum
 
Jiujiang Tanbre Co., Ltd. *
 
CHINA
Tantalum
 
Kemet Blue Powder *
 
UNITED STATES
Tantalum
 
King-Tan Tantalum Industry Ltd. *
 
CHINA
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 Liezen *
 
AUSTRIA
Tantalum
 
QuantumClean *
 
UNITED STATES
Tantalum
 
RFH Tantalum Smeltry Co., Ltd *
 
CHINA
Tantalum
 
Solikamsk Metal Works *
 
RUSSIAN FEDERATION
Tantalum
 
Taki Chemicals *
 
JAPAN
Tantalum
 
Telex Metals *
 
UNITED STATES
Tantalum
 
Ulba *
 
KAZAKHSTAN
Tantalum
 
Yichun Jin Yang Rare Metal Co., Ltd *
 
CHINA
Tantalum
 
Zhuzhou Cemented Carbide *
 
CHINA
Tin
 
Alpha *
 
UNITED STATES
Tin
 
China Rare Metal Materials Company
 
CHINA
Tin
 
China Tin Group Co., Ltd. *
 
CHINA
Tin
 
CNMC (Guangxi) PGMA Co. Ltd.
 
CHINA
Tin
 
CV Serumpun Sebalai *
 
INDONESIA
Tin
 
CV United Smelting *
 
INDONESIA
Tin
 
EM Vinto *
 
BOLIVIA
Tin
 
Estanho de Rondônia S.A.
 
BRAZIL
Tin
 
Feinhütte Halsbrücke GmbH
 
GERMANY
Tin
 
Gebr. Kemper GmbH & Co.KG
 
GERMANY
Tin
 
Gejiu Non-Ferrous Metal Processing Co. Ltd. *
 
CHINA
Tin
 
Gejiu Zi-Li
 
CHINA
Tin
 
Huichang Jinshunda Tin Co. Ltd
 
CHINA
Tin
 
Jiangxi Nanshan
 
CHINA
Tin
 
Kai Unita Trade Limited Liability Company
 
CHINA
Tin
 
Linwu Xianggui Smelter Co
 
CHINA
Tin
 
Magnu's Minerais Metais e Ligas LTDA *
 
BRAZIL

8



Mineral
 
Smelter or Refiner Facility Name
 
Location
Tin
 
Malaysia Smelting Corporation (MSC) *
 
MALAYSIA
Tin
 
Melt Metais e Ligas S/A *
 
BRAZIL
Tin
 
Metallo-Chimique N.V. *
 
BELGIUM
Tin
 
Mineração Taboca S.A. *
 
BRAZIL
Tin
 
Minsur *
 
PERU
Tin
 
Mitsubishi Materials Corporation *
 
JAPAN
Tin
 
Nghe Tinh Non-Ferrous Metal **
 
VIET NAM
Tin
 
Novosibirsk Integrated Tin Works
 
RUSSIAN FEDERATION
Tin
 
O.M. Manufacturing (Thailand) Co., Ltd. *
 
THAILAND
Tin
 
OMSA *
 
BOLIVIA
Tin
 
PT Artha Cipta Langgeng *
 
INDONESIA
Tin
 
PT Babel Inti Perkasa *
 
INDONESIA
Tin
 
PT Bangka Kudai Tin
 
INDONESIA
Tin
 
PT Belitung Industri Sejahtera *
 
INDONESIA
Tin
 
PT Bukit Timah *
 
INDONESIA
Tin
 
PT Eunindo Usaha Mandiri *
 
INDONESIA
Tin
 
PT Karimun Mining **
 
INDONESIA
Tin
 
PT Mitra Stania Prima *
 
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 Tambang Timah
 
INDONESIA
Tin
 
PT Timah (Persero), Tbk *
 
INDONESIA
Tin
 
PT Tinindo Inter Nusa *
 
INDONESIA
Tin
 
Soft Metais, Ltda. *
 
BRAZIL
Tin
 
Thaisarco *
 
THAILAND
Tin
 
VQB Mineral and Trading Group JSC *
 
VIET NAM
Tin
 
White Solder Metalurgia e Mineração Ltda. *
 
BRAZIL
Tin
 
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. **
 
CHINA
Tin
 
Yunnan Tin Company, Ltd. *
 
CHINA
Tungsten
 
A.L.M.T. Corp. *
 
JAPAN
Tungsten
 
Chongyi Zhangyuan Tungsten Co Ltd *
 
CHINA
Tungsten
 
Dayu Weiliang Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Fujian Jinxin Tungsten Co., Ltd. *
 
CHINA
Tungsten
 
Ganzhou Grand Sea W & Mo Group Co Ltd
 
CHINA
Tungsten
 
Ganzhou Huaxing Tungsten Products Co., Ltd. *
 
CHINA
Tungsten
 
Ganzhou Jiangwu Ferrotungsten Co., Ltd. *
 
CHINA
Tungsten
 
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
 
CHINA
Tungsten
 
Global Tungsten & Powders Corp. *
 
UNITED STATES
Tungsten
 
Guangdong Xianglu Tungsten Industry Co., Ltd. *
 
CHINA
Tungsten
 
HC Starck GmbH *
 
GERMANY
Tungsten
 
Hunan Chenzhou Mining Group Co *
 
CHINA
Tungsten
 
Japan New Metals Co Ltd *
 
JAPAN
Tungsten
 
Jiangxi Gan Bei Tungsten Co., Ltd. *
 
CHINA
Tungsten
 
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Yaosheng Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Kennametal Fallon
 
UNITED STATES
Tungsten
 
Kennametal Huntsville *
 
UNITED STATES
Tungsten
 
Malipo Haiyu Tungsten Co., Ltd. *
 
CHINA
Tungsten
 
Tejing (Vietnam) Tungsten Co., Ltd. *
 
VIET NAM

9



Mineral
 
Smelter or Refiner Facility Name
 
Location
Tungsten
 
Vietnam Youngsun Tungsten Industry Co., Ltd *
 
VIET NAM
Tungsten
 
Wolfram Bergbau und Hütten AG *
 
AUSTRIA
Tungsten
 
Xiamen Tungsten (H.C.) Co., Ltd. *
 
CHINA
Tungsten
 
Xiamen Tungsten Co., Ltd *
 
CHINA
Tungsten
 
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
 
CHINA
*
Smelter is on the Conflict Free Sourcing Initiative's list of "conflict-free smelters"
**
Smelter is on the Conflict Free Sourcing Initiative's list of "Active" smelters, indicating that an audit is in process.
***
Smelter's certification as a "conflict-free smelter" expired prior to December 31, 2015

10