Exhibit 1.01
CONFLICT MINERALS REPORT
This Conflict Minerals Report (“CMR”) for the reporting period of January 1 to December 31, 2017, is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”).
COMPANY BACKGROUND
Huntington Ingalls Industries, Inc. (“HII” or the “Company,” “we,” “us,” or “our”) is America’s largest military shipbuilding company and a provider of professional services to partners in government and industry. For more than a century, our Ingalls Shipbuilding segment (“Ingalls”) in Mississippi and Newport News Shipbuilding segment (“Newport News”) in Virginia have built more ships in more ship classes than any other U.S. naval shipbuilder. Our Technical Solutions segment, established in the fourth quarter of 2016, provides a wide range of services to the governmental, energy, and oil and gas markets.
We conduct most of our business with the U.S. Government, principally the Department of Defense. As prime contractor, principal subcontractor, team member or partner, we participate in many high-priority U.S. defense technology programs. Ingalls includes our non-nuclear ship design, construction, repair, and maintenance businesses. Newport News includes all of our nuclear ship design, construction, overhaul, refueling, and repair and maintenance businesses. We also provide a wide range of professional services, including fleet support, integrated mission solutions, nuclear and environmental, and oil and gas services through our Technical Solutions segment.
HII procures a large variety of products from many different suppliers. Some of the products HII procures from suppliers contain conflict minerals, which are also referred to as “3TGs” (“conflict minerals” and “3TGs” are tin, tantalum, tungsten and gold, as more specifically described in and covered by the Securities and Exchange Commission’s regulations and guidance). HII is a downstream purchaser and is a number of steps removed in the supply chain from the mining and smelting of 3TGs. As a result, HII relies on its suppliers to represent whether the products they are supplying to HII contain 3TGs. Additionally, HII does not purchase raw ore or unrefined conflict minerals from mines or smelters and does not purchase products directly from any of the Covered Countries (Democratic Republic of Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola), hereinafter referred to collectively as the “DRC.”
This CMR relates to HII products that were manufactured, or contracted to be manufactured, and delivered to customers during calendar year 2017 and that contain 3TGs. This CMR was not subjected to an independent private sector audit. Statements provided below are made in good faith and reflect the Company’s supplier infrastructure and information obtained to address the Rule.
CONFLICT MINERALS POLICY
HII has adopted a conflict minerals policy and related procedures focused on HII’s commitment to sourcing components and materials from suppliers that share its ethical values and that support compliance with the Securities and Exchange Commission’s regulations, as well as HII’s disclosure obligations related to conflict minerals. HII’s policy is summarized on our website at http://www.huntingtoningalls.com/who-we-are/ethics-compliance/conflict-minerals/. HII does support the sourcing of conflict minerals from the Democratic Republic of Congo or its adjoining countries through smelters that have been certified as “conflict-free.” The conflict minerals policy and related procedures have guided HII’s development of internal systems, supply chain due diligence efforts, and Reasonable Country of Origin Inquiry (“RCOI”).
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HII’s efforts related to conflict minerals include: implementing internal policies, procedures, practices, processes and systems designed to obtain information about 3TGs that may be incorporated into HII’s products and their origin; improving transparency through our product supply chain; and, more generally, providing knowledge to and achieving engagement from our suppliers concerning the requisite conflict minerals issues. Additionally, HII belongs to and participates with several professional organizations that devote time and focus to understanding conflict minerals matters and how to appropriately improve and implement processes to better understand and obtain data about the sources of conflict minerals. Through these organizations, HII has supported measures to further educate our supplier base on the Rule and encouraged compliance.
PRODUCTS COVERED AND REPORTING YEAR ACTIVITY
For products completed and delivered by HII in 2017, which included vessels, vessel components, chlorine generator assemblies, and remote operator panels, HII conducted an RCOI as more specifically described below. The results of the RCOI led HII to conduct due diligence with regard to a limited number of suppliers to five of the Company’s business units. The information provided by those suppliers indicated that some 3TGs contained in certain of their products supplied to HII business units may have originated in a Covered Country. As further discussed below in “Information Regarding Country of Origin and Due Diligence Results,” some of these suppliers reported sourcing from smelters that may procure some 3TGs from the DRC, but upon further inquiry HII determined that all such smelters except two have been independently verified by the Responsible Minerals Initiative (“RMI,” which was formerly known as the Conflict Free Sourcing Initiative) to procure 3TGs solely from conflict-free sources that do not support armed conflict in the DRC. Other smelters identified by suppliers are in the process of being audited by RMI to determine if they obtain 3TGs entirely from conflict-free sources, while information about other smelters and the origin of the 3TGs they provide is unknown.
REASONABLE COUNTRY OF ORIGIN INQUIRY
In addition to the efforts described above, HII’s RCOI was designed to determine whether the 3TGs in our relevant products originated in the DRC. In part, HII’s RCOI process included:
| • | maintaining a long-term conflict minerals working group comprised of representatives from HII’s operational, compliance, legal and supply chain functions (at both the corporate and business unit levels), as well as external advisors with conflict minerals subject matter expertise; |
| • | evaluating the Securities and Exchange Commission’s conflict minerals regulations and guidance, adopting policies to support compliance with the regulations, reviewing and updating practices and providing information to suppliers to make them knowledgeable of the Securities and Exchange Commission’s conflict minerals regulations and guidance and, to the extent necessary, developing reasonable interpretations of the regulations and guidance to enable HII to apply the regulations and guidance to our specific operations and industry; |
| • | providing information to HII’s suppliers about, and linked access to, the Securities and Exchange Commission’s conflict minerals regulations and guidance, as well as other supporting publications and access to the extensive conflict minerals resource center of HII’s third party conflict minerals data vendor; |
| • | requiring suppliers, as part of the purchase order process, to represent whether their products contain 3TGs and, if so, further requiring the suppliers to provide a completed RMI Conflict Minerals Reporting Template (“CMRT”) or some other form acceptable to us containing information about the type and origin of 3TGs in their products; |
| • | compiling data from supplier surveys and representations; |
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| • | communicating with, and seeking information from, any major suppliers that did not timely respond to surveys or provided incomplete surveys; and |
| • | conducting periodic reviews with the Company’s conflict minerals working group and supply chain organizations to understand the data and information submitted by suppliers and additional steps that were taken to seek additional information from suppliers. |
In response to HII’s country of origin inquiries, a limited number of HII’s suppliers indicated that, due to a lack of definitive information from their supply chains, certain of their products may contain one or more 3TGs sourced from the DRC. Accordingly, HII believes, based upon the results of its RCOI, that it was appropriate to conduct due diligence measures to obtain additional information, as described below.
DUE DILIGENCE MEASURES
HII has developed due diligence processes that are informed by and track to the Organization for Economic Cooperation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. These due diligence processes include:
Establish Strong Company Management Systems
| • | As noted above, maintaining a conflict minerals working group comprised of representatives from HII’s operational, compliance, legal and supply chain functions (at both the corporate and business unit levels), as well as external advisors with conflict minerals subject matter expertise. |
| • | Publishing and maintaining a conflict minerals policy and related procedures to address HII’s commitment to comply with the Rule. HII’s policy is summarized on our website at http://www.huntingtoningalls.com/who-we-are/ethics-compliance/conflict-minerals/. HII’s policy and procedures include commitments such as: |
| • | To the extent practicable, and consistent with our contractual obligations to our customers, refraining from relationships that could knowingly result in: |
| • | aiding, directly or indirectly, armed groups operating in the DRC through sales of 3TGs; or |
| • | the willful concealment of information related to the transport of 3TGs from the DRC and their use in manufactured products. |
| • | Sourcing components and materials from suppliers that share our ethical values. Our procedures outline the requirements to survey our suppliers and obtain necessary details to support compliance with the Rule. The procedures further identify the functional parties within the Company responsible for supporting the Rule and assessing the presence of any inconsistencies associated with supplier survey responses. |
| • | Educating relevant employees about our conflict minerals program and reporting obligations through a web-based conflict minerals training course or in-person training, as appropriate. |
| • | Establishing conflict minerals as an element in our corporate annual compliance plan, which covers HII’s risk management of conflict minerals compliance. |
| • | Selecting and utilizing a third party conflict minerals data vendor to collect and manage CMRT responses from suppliers and verify the accuracy of the data provided. |
| • | Periodically briefing executive management, including the Chief Financial Officer and the Audit Committee of the Board of Directors, on the conflict minerals requirements and related company activities. |
| • | Maintaining communications with our supply chain through our corporate conflict minerals website at http://www.huntingtoningalls.com/who-we-are/ethics-compliance/conflict-minerals/, which includes Frequently Asked Questions, links to third party information on conflict minerals, and a link to our grievance mechanism, or OpenLine, as discussed further below. |
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| • | Employing mechanisms for interested persons to voice concerns or grievances, including our pre-existing OpenLine as the tool to capture and track concerns or grievances regarding aspects of the Rule either internally or externally. The OpenLine is available 24 hours a day, seven days a week, and can be accessed through either a phone number or website (1-877-631-0020, https://hii-openline.alertline.com/gcs/welcome). |
Identify and Assess Supply Chain Risk
| • | Requiring suppliers as part of the purchase order process to represent whether their products contain 3TGs and, if so, further requiring the suppliers to provide our third party conflict minerals data vendor with a completed CMRT or some other form acceptable to us containing information about the type and origin of 3TGs in their products. |
| • | Including a purchase order clause that requires a supplier to provide an updated survey response to our third party conflict minerals data vendor if the status of any of their product(s) changes prior to final delivery. |
| • | Identifying suppliers of products to HII that may contain 3TGs and asking our third party conflict minerals data vendor to follow up with non-responsive suppliers to request submission of CMRTs or similar information by a specified date. Where a supplier is unable to provide a CMRT, information on its suppliers of products or components that may require 3TG for their production or functionality is requested by our vendor. Those sub-tier suppliers for whom contact information is obtained, and subsequent tiers of suppliers as needed, are then engaged via email or phone in order to build a chain-of-custody back to the smelter or refiner. If major suppliers do not respond to several e-mail reminders and follow-up phone calls from our vendor, we directly contact those suppliers to obtain CMRTs or other acceptable information about the type and origin of 3TGs in their products. |
| • | Conducting a targeted self-assessment to identify items with a higher risk of containing 3TGs if no CMRT was submitted by the supplier. |
| • | Including a purchase order clause that allows HII to either withhold up to 10% of the purchase order price or terminate the purchase order if HII determines that any representation made by the supplier is inaccurate or incomplete in any respect, or if the supplier fails to timely submit the information required by the clause. In 2017, HII found no instances where it was necessary under the purchase order clause to find replacement sources of supply, withhold payments or terminate a supplier relationship. |
| • | Compiling a list of smelters and refiners in our supply chain that have been identified as 3TG providers using our suppliers’ CMRT responses, with assistance from our third party conflict minerals data vendor. This list is reconciled to the list of smelter facilities designated by RMI’s Responsible Minerals Assurance Process (“RMAP”), and is included in this report as Appendix A. |
| • | If a smelter or refiner is not recognized by RMI, then HII’s third party conflict minerals data vendor attempts to contact the smelter or refiner directly to gain more information about its sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes the smelter or refiner takes to track the chain-of-custody on the source of its mineral ores. |
Design and Implement a Strategy to Respond to Supply Chain Risks
| • | Maintaining membership and participation in the National Association of Manufacturers (“NAM”), Aerospace Industries Association (“AIA”) and its conflict minerals working group, and RMI, to stay current on industry “best practices” for conflict minerals due diligence efforts. |
| • | Supporting, through its membership in RMI, the assessment of whether smelters and refiners have carried out the OECD five step due diligence process for responsible supply chains of 3TG from the DRC. |
| • | Analyzing supplier responses and evaluating information in a manner designed to provide the Company with a reasonable basis for conclusions disclosed in the 2018 Form SD and this Conflict Minerals Report, including evaluating the raw number of supplier responses and relative dollar values of purchased products represented by such responses, as well as focusing on suppliers relevant to the reporting period. |
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| • | Supporting information-sharing systems within our industry aimed at improving assessment of supplier due diligence in the supply chain of minerals from conflict-affected and high-risk areas, such as comparing smelters and refiners identified by the HII supply chain with the RMAP information. |
| • | Contacting, through its membership in the AIA and its conflict minerals working group, selected smelters or refiners through a formal letter from the AIA to encourage participation in the RMAP. |
| • | Providing periodic updates to executive management on any actions taken in response to identified risks associated with conflict minerals in HII’s supply chain. |
Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
| • | Due to the downstream nature of our business, HII does not have direct relationships with smelters or refiners and therefore does not perform audits of these entities. HII, however, supports third party audits of supply chain due diligence through its membership in RMI, which assesses whether smelters and refiners carry out due diligence in conformance with the OECD guidance, and also conducts audits to confirm the conflict-free status of impacted smelters and refiners. |
Report on Supply Chain Due Diligence
| • | This Conflict Minerals Report is HII’s public annual report on the due diligence efforts of our supply chain. |
| • | HII posts this report annually at http://www.huntingtoningalls.com/who-we-are/ethics-compliance/conflict-minerals/. |
INFORMATION REGARDING COUNTRY OF ORIGIN AND DUE DILIGENCE RESULTS
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which the Company’s processes are based, we support RMI’s Responsible Minerals Assurance Process, which audits smelters’ and refiners’ due diligence activities. The data on which we relied for certain statements in this report was obtained through our membership in RMI, using the Reasonable Country of Origin Inquiry report for RMI member HUNT.
HII or its third party conflict minerals data vendor engaged with each supplier that suggested possible sourcing of 3TGs from the DRC to obtain further supporting documentation for their statements. These suppliers responded with either (i) conflict minerals disclosure on a company-wide basis in which they were unable to verify whether the specific products sold to HII contained 3TGs sourced from the DRC, or (ii) additional information that indicated the names and locations of known smelters from which their 3TGs may have originated, but without additional information to verify whether the 3TGs in their products sold to HII originated from the DRC, or an indication that their RCOI was ongoing and not yet complete. Appendix A lists the smelters named by those suppliers, but the inclusion of a smelter in Appendix A does not necessarily mean that HII products contain 3TGs processed by that smelter. Comparing the list of those smelters named in Appendix A to the smelter database information maintained by RMI as of May 11, 2018, as well as other publicly-available information, indicated the following:
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| • | 255 of the listed smelters had been audited as part of the RMI initiative and were determined to source their 3TGs solely from either countries other than the DRC or conflict-free sources (“Conformant”); |
| • | 10 of the listed smelters are in the process of arranging for or are being audited to determine if they source their 3TGs solely from either countries other than the DRC or otherwise from conflict-free sources (“Active”); |
| • | Seven of the listed smelters are designated by RMI as non-conformant to the RMAP audit standard (“Non-conformant”), two of which were identified as sourcing from the DRC prior to ceasing operations; |
| • | 48 of the listed smelters are designated by RMI as not yet participating in the RMAP (“Non-participating”). HII has insufficient information from or about these smelters to understand their sources for 3TGs. |
Based on smelter and refiner information provided by suppliers through the CMRT responses, as well as RMI information available to its members, the countries of origin of 3TG associated with smelters and refiners identified in Appendix A are believed to include the countries listed in Appendix B below. While some countries listed in Appendix B are DRC countries, 58 out of the 60 smelters or refiners positively identified as sourcing from those DRC countries have been validated as using DRC conflict-free sourcing practices under the RMAP protocols.
ONGOING EFFORTS
HII is continuing its efforts to:
| • | Determine which supplier-provided products contain 3TGs; |
| • | Obtain additional information from direct suppliers, as well as others in or with knowledge of the supply chain, as to whether their products contain 3TGs and, if so, the origin of those 3TGs, as additional conflict minerals and smelter information becomes available to the supply chain; |
| • | Communicate knowledge and our expectations to suppliers about the type and level of detailed information needed by HII to understand the origin and source of 3TGs; |
| • | Remain actively involved in and participate with industry and other groups, including AIA, NAM and RMI, to ascertain best and leading practices and to obtain and share information that may assist in determining whether purchased products contain 3TGs and, if so, the origin of those 3TGs and whether the 3TGs were sourced from conflict-free sources; |
| • | Support industry efforts to expand participation of smelters and refiners in conflict-free certification programs; and |
| • | Provide resources and information to non-issuer suppliers about the Securities and Exchange Commission’s conflict minerals reporting requirements, as well as information about RMI and other informative measures designed to educate about the importance of conflict-free sourcing. |
APPENDIX A
Listed below are the smelters to which we previously referred in this report.
| Mineral |
Official Smelter Name |
Smelter Location | ||
| Gold |
Advanced Chemical Company* | United States | ||
| 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 Corrego do Sitio Mineracao* | Brazil | ||
| Gold |
Argor-Heraeus S.A.* | Switzerland |
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| Mineral |
Official Smelter Name |
Smelter Location | ||
| Gold |
Asahi Pretec Corp.* | 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 |
Boliden AB* | Sweden | ||
| Gold |
C. Hafner GmbH + Co. KG* | Germany | ||
| Gold |
Caridad*** | Mexico | ||
| Gold |
CCR Refinery—Glencore Canada Corporation* | Canada | ||
| Gold |
Cendres + Metaux S.A.* | Switzerland | ||
| Gold |
Yunnan Copper Industry Co., Ltd.*** | China | ||
| Gold |
Chimet S.p.A.* | Italy | ||
| Gold |
Chugai Mining*** | Japan | ||
| Gold |
Daejin Indus Co., Ltd.* | Korea, Republic of | ||
| Gold |
Daye Non-Ferrous Metals Mining Ltd.*** | China | ||
| Gold |
DSC (Do Sung Corporation)* | Korea, Republic of | ||
| Gold |
DODUCO Contacts and Refining GmbH* | Germany | ||
| Gold |
Dowa* | Japan | ||
| Gold |
Eco-System Recycling Co., Ltd.* | Japan | ||
| Gold |
OJSC Novosibirsk Refinery* | Russian Federation | ||
| Gold |
Refinery of Seemine Gold Co., Ltd.*** | China | ||
| Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd.*** | China | ||
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd.*** | China | ||
| Gold |
HeeSung Metal Ltd.* | Korea, Republic of | ||
| Gold |
Heimerle + Meule GmbH* | Germany | ||
| Gold |
Heraeus Metals Hong Kong Ltd.* | China | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG* | Germany | ||
| Gold |
Hunan Chenzhou Mining Co., Ltd.*** | China | ||
| Gold |
HwaSeong CJ CO., LTD.*** | Korea, Republic of | ||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | China | ||
| Gold |
Ishifuku Metal Industry Co., Ltd.* | Japan | ||
| Gold |
Istanbul Gold Refinery* | Turkey | ||
| Gold |
Japan Mint* | Japan | ||
| Gold |
Jiangxi Copper Co., Ltd.* | China | ||
| Gold |
Asahi Refining USA Inc.* | United States | ||
| Gold |
Asahi Refining Canada Ltd.* | Canada | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant* | Russian Federation | ||
| Gold |
JSC Uralelectromed* | Russian Federation | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd.* | Japan | ||
| Gold |
Kazakhmys Smelting LLC*** | Kazakhstan |
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| Mineral |
Official Smelter Name |
Smelter Location | ||
| Gold |
Kazzinc* | Kazakhstan | ||
| Gold |
Kennecott Utah Copper LLC* | United States | ||
| Gold |
Kojima Chemicals Co., Ltd.* | Japan | ||
| Gold |
Kyrgyzaltyn JSC* | Kyrgyzstan | ||
| Gold |
L’azurde Company For Jewelry*** | Saudi Arabia | ||
| Gold |
Lingbao Gold Co., Ltd.*** | 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 |
Materion* | United States | ||
| Gold |
Matsuda Sangyo Co., Ltd.* | Japan | ||
| Gold |
Metalor Technologies (Suzhou) Ltd.* | China | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd.* | China | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd.* | Singapore | ||
| Gold |
Metalor Technologies S.A.* | Switzerland | ||
| Gold |
Metalor USA Refining Corporation* | United States | ||
| Gold |
Metalurgica Met-Mex Penoles S.A. De C.V.* | Mexico | ||
| Gold |
Mitsubishi Materials Corporation* | Japan | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd.* | Japan | ||
| Gold |
Moscow Special Alloys Processing Plant* | Russian Federation | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey | ||
| Gold |
Navoi Mining and Metallurgical Combinat*** | Uzbekistan | ||
| Gold |
Nihon Material Co., Ltd.* | Japan | ||
| Gold |
Elemetal Refining, LLC***** | United States | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd.* | Japan | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)* | Russian Federation | ||
| Gold |
PAMP S.A.* | 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 Precinox S.A.* | Switzerland | ||
| Gold |
Rand Refinery (Pty) Ltd.* | South Africa | ||
| Gold |
Royal Canadian Mint* | Canada | ||
| Gold |
Sabin Metal Corp.*** | United States | ||
| Gold |
Samduck Precious Metals* | Korea, Republic of | ||
| Gold |
SAMWON METALS Corp.*** | Korea, Republic of | ||
| Gold |
Schone Edelmetaal B.V.*** | Netherlands | ||
| Gold |
SEMPSA Joyeria Plateria S.A.* | Spain | ||
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd.*** | China | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | China |
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| Mineral |
Official Smelter Name |
Smelter Location | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd.* | China | ||
| 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 |
Great Wall Precious Metals Co., Ltd. of CBPM*** | 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 S.A. Business Unit Precious Metals Refining* | Belgium | ||
| Gold |
United Precious Metal Refining, Inc.* | United States | ||
| Gold |
Valcambi S.A.* | Switzerland | ||
| Gold |
Western Australian Mint (T/a The Perth Mint)* | Australia | ||
| Gold |
Yamakin Co., Ltd.* | Japan | ||
| Gold |
Yokohama Metal Co., Ltd.* | Japan | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China | ||
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd.* | China | ||
| Gold |
Morris and Watson*** | New Zealand | ||
| Gold |
SAFINA A.S.* | Czech Republic | ||
| Gold |
Guangdong Jinding Gold Limited*** | China | ||
| Gold |
Umicore Precious Metals Thailand* | Thailand | ||
| Gold |
Geib Refining Corporation* | United States | ||
| Gold |
MMTC-PAMP India Pvt., Ltd.* | India | ||
| Gold |
Republic Metals Corporation* | United States | ||
| Gold |
KGHM Polska Miedz Spolka Akcyjna** | Poland | ||
| Gold |
Fidelity Printers and Refiners Ltd.*** | Zimbabwe | ||
| Gold |
Singway Technology Co., Ltd.* | Taiwan | ||
| Gold |
Al Etihad Gold LLC* | United Arab Emirates | ||
| Gold |
Emirates Gold DMCC* | United Arab Emirates | ||
| Gold |
Kaloti Precious Metals*** | United Arab Emirates | ||
| Gold |
Sudan Gold Refinery*** | Sudan | ||
| Gold |
T.C.A S.p.A* | Italy | ||
| Gold |
Remondis Argentia B.V.** | Netherlands | ||
| Gold |
Tony Goetz NV**** | Belgium | ||
| Gold |
Korea Zinc Co., Ltd.* | Korea, Republic of | ||
| Gold |
Marsam Metals* | Brazil | ||
| Gold |
TOO Tau-Ken-Altyn*** | Kazakhstan |
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| Mineral |
Official Smelter Name |
Smelter Location | ||
| Gold |
Abington Reldan Metals, LLC**** | United States | ||
| Gold |
SAAMP* | France | ||
| Gold |
L’Orfebre S.A.** | Andorra | ||
| Gold |
Italpreziosi* | Italy | ||
| Gold |
SAXONIA Edelmetalle GmbH* | Germany | ||
| Gold |
WIELAND Edelmetalle GmbH* | Germany | ||
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria | ||
| Gold |
AU Traders and Refiners* | South Africa | ||
| Gold |
GCC Gujrat Gold Centre Pvt. Ltd.*** | India | ||
| Gold |
Sai Refinery*** | India | ||
| Gold |
Universal Precious Metals Refining Zambia*** | Zambia | ||
| Gold |
Modeltech Sdn Bhd** | Malaysia | ||
| Gold |
Bangalore Refinery** | India | ||
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO*** | Russian Federation | ||
| Gold |
Morris and Watson Gold Coast*** | Australia | ||
| Gold |
Degussa Sonne / Mond Goldhandel GmbH*** | Germany | ||
| Gold |
Pease & Curren*** | United States | ||
| Gold |
SungEel HiMetal Co., Ltd.* | Korea, Republic of | ||
| Gold |
Planta Recuperadora de Metales SpA* | Chile | ||
| Gold |
Safimet S.p.A* | Italy | ||
| Gold |
State Research Institute Center for Physical Sciences and Technology*** | Lithuania | ||
| Gold |
African Gold Refinery*** | Uganda | ||
| Gold |
NH Recytech Company** | Korea, Republic of | ||
| Gold |
DS PRETECH Co., Ltd.** | Korea, Republic of | ||
| Tantalum |
Asaka Riken Co., Ltd.* | Japan | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd.* | China | ||
| Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd.* | China | ||
| Tantalum |
Duoluoshan***** | China | ||
| Tantalum |
Exotech Inc.* | United States | ||
| Tantalum |
F&X Electro-Materials Ltd.* | China | ||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd.* | China | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China | ||
| Tantalum |
Jiujiang Nonferrous Metals Smelting Company Limited* | China | ||
| Tantalum |
LSM Brasil S.A.* | Brazil | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd.* | India | ||
| Tantalum |
Mineracao Taboca S.A.* | Brazil | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd.* | Japan | ||
| Tantalum |
NPM Silmet AS* | Estonia | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd.* | China | ||
| Tantalum |
QuantumClean* | United States |
10
| Mineral |
Official Smelter Name |
Smelter Location | ||
| Tantalum |
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum |
Solikamsk Magnesium Works OAO* | Russian Federation | ||
| Tantalum |
Taki Chemical Co., Ltd.* | Japan | ||
| Tantalum |
Telex Metals* | United States | ||
| Tantalum |
Ulba Metallurgical Plant JSC* | Kazakhstan | ||
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd.* | China | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd.* | China | ||
| Tantalum |
D Block Metals, LLC* | United States | ||
| Tantalum |
FIR Metals & Resource Ltd.* | China | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum |
XinXing Haorong Electronic Material Co., Ltd.* | China | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | China | ||
| Tantalum |
KEMET Blue Metals* | Mexico | ||
| Tantalum |
H.C. Starck Co., Ltd.* | Thailand | ||
| Tantalum |
H.C. Starck Tantalum and Niobium GmbH* | Germany | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH* | Germany | ||
| Tantalum |
H.C. Starck Inc.* | United States | ||
| Tantalum |
H.C. Starck Ltd.* | Japan | ||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG* | Germany | ||
| Tantalum |
Global Advanced Metals Boyertown* | United States | ||
| Tantalum |
Global Advanced Metals Aizu* | Japan | ||
| Tantalum |
Kemet Blue Powder* | United States | ||
| Tantalum |
Resind Industria e Comercio Ltda.* | Brazil | ||
| Tantalum |
Jiangxi Tuohong New Raw Material* | China | ||
| Tantalum |
Power Resources Ltd.* | Macedonia, The Former Yugoslav Republic Of | ||
| Tantalum |
Jiujiang Janny New Material Co., Ltd.* | China | ||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China | ||
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd.* | China | ||
| Tin |
CNMC (Guangxi) PGMA Co., Ltd.*** | China | ||
| Tin |
Alpha* | United States | ||
| Tin |
CV Gita Pesona* | Indonesia | ||
| Tin |
PT Aries Kencana Sejahtera* | Indonesia | ||
| Tin |
PT Premium Tin Indonesia* | Indonesia | ||
| Tin |
CV United Smelting* | Indonesia | ||
| Tin |
Dowa* | Japan | ||
| Tin |
EM Vinto* | Bolivia | ||
| Tin |
Estanho de Rondonia S.A.*** | Brazil | ||
| Tin |
Fenix Metals* | Poland |
11
| Mineral |
Official Smelter Name |
Smelter Location | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd.* | China | ||
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd.*** | China | ||
| Tin |
Huichang Jinshunda Tin Co., Ltd.* | China | ||
| Tin |
Gejiu Kai Meng Industry and Trade LLC* | China | ||
| Tin |
China Tin Group Co., Ltd.* | China | ||
| Tin |
Malaysia Smelting Corporation (MSC)* | Malaysia | ||
| Tin |
Metallic Resources, Inc.* | United States | ||
| Tin |
Mineracao Taboca S.A.* | Brazil | ||
| Tin |
Minsur* | Peru | ||
| Tin |
Mitsubishi Materials Corporation* | Japan | ||
| Tin |
Jiangxi New Nanshan Technology Ltd.* | China | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand | ||
| Tin |
Operaciones Metalurgical S.A.* | Bolivia | ||
| Tin |
PT Artha Cipta Langgeng* | Indonesia | ||
| Tin |
PT Babel Inti Perkasa* | Indonesia | ||
| Tin |
PT Babel Surya Alam Lestari** | Indonesia | ||
| Tin |
PT Bangka Tin Industry* | Indonesia | ||
| Tin |
PT Belitung Industri Sejahtera* | Indonesia | ||
| Tin |
PT Bukit Timah* | Indonesia | ||
| Tin |
PT DS Jaya Abadi* | Indonesia | ||
| Tin |
PT Eunindo Usaha Mandiri* | Indonesia | ||
| Tin |
PT Karimun Mining* | 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 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 |
Rui Da Hung* | Taiwan | ||
| Tin |
Soft Metais Ltda.* | Brazil | ||
| Tin |
Thaisarco* | Thailand | ||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | China | ||
| Tin |
White Solder Metalurgia e Mineracao Ltda.* | Brazil | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | China | ||
| Tin |
Yunnan Tin Company Limited* | China |
12
| Mineral |
Official Smelter Name |
Smelter Location | ||
| Tin |
CV Venus Inti Perkasa* | Indonesia | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda.* | Brazil | ||
| Tin |
Melt Metais e Ligas S.A.* | Brazil | ||
| Tin |
PT ATD Makmur Mandiri Jaya* | Indonesia | ||
| Tin |
O.M. Manufacturing Philippines, Inc.* | Philippines | ||
| Tin |
PT Inti Stania Prima* | Indonesia | ||
| Tin |
CV Ayi Jaya* | Indonesia | ||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company**** | Viet Nam | ||
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company*** | Viet Nam | ||
| Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company*** | Viet Nam | ||
| Tin |
CV Dua Sekawan* | Indonesia | ||
| Tin |
CV Tiga Sekawan* | Indonesia | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company*** | Viet Nam | ||
| Tin |
Resind Industria e Comercio Ltda.* | Brazil | ||
| Tin |
Super Ligas*** | Brazil | ||
| Tin |
Metallo Belgium N.V.* | Belgium | ||
| Tin |
Metallo Spain S.L.U.* | Spain | ||
| Tin |
PT Bangka Prima Tin* | Indonesia | ||
| Tin |
PT Sukses Inti Makmur* | Indonesia | ||
| Tin |
PT Kijang Jaya Mandiri* | Indonesia | ||
| Tin |
PT Menara Cipta Mulia* | Indonesia | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd.* | China | ||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant* | China | ||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant* | China | ||
| Tin |
Modeltech Sdn Bhd** | Malaysia | ||
| Tin |
Gejiu Jinye Mineral Company* | China | ||
| Tin |
PT Lautan Harmonis Sejahtera* | Indonesia | ||
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | China | ||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd.* | China | ||
| Tin |
PT Bangka Serumpun* | Indonesia | ||
| Tin |
Pongpipat Company Limited*** | Myanmar | ||
| Tungsten |
A.L.M.T. TUNGSTEN Corp.* | Japan | ||
| Tungsten |
Kennametal Huntsville* | United States | ||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd.* | China | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd.* | China | ||
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd.* | China | ||
| Tungsten |
Global Tungsten & Powders Corp.* | United States | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd.* | China | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd.* | China | ||
| Tungsten |
Japan New Metals Co., Ltd.* | Japan |
13
| Mineral |
Official Smelter Name |
Smelter Location | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd.* | China | ||
| Tungsten |
Kennametal Fallon* | United States | ||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd.* | Viet Nam | ||
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd.* | Viet Nam | ||
| Tungsten |
Wolfram Bergbau und Hutten AG* | Austria | ||
| Tungsten |
Xiamen Tungsten Co., Ltd.* | China | ||
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.*** | China | ||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | China | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd.* | China | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd.* | China | ||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd.* | China | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd.* | Viet Nam | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd.* | China | ||
| Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | China | ||
| Tungsten |
Ganzhou Yatai Tungsten Co., Ltd.**** | China | ||
| Tungsten |
H.C. Starck Tungsten GmbH* | Germany | ||
| Tungsten |
H.C. Starck Smelting GmbH & Co. KG* | Germany | ||
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | Viet Nam | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | China | ||
| Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | China | ||
| Tungsten |
Niagara Refining LLC* | United States | ||
| Tungsten |
Ganzhou Haichuang Tungsten Industry Co., Ltd.** | China | ||
| Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd.*** | China | ||
| Tungsten |
Hydrometallurg, JSC* | Russian Federation | ||
| Tungsten |
Unecha Refractory Metals Plant* | Russian Federation | ||
| Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City* | China | ||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc.* | Philippines | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | China | ||
| Tungsten |
ACL Metais Eireli* | Brazil | ||
| Tungsten |
Woltech Korea Co., Ltd.* | Korea, Republic of | ||
| Tungsten |
Moliren Ltd.* | Russian Federation | ||
| Tungsten |
Hunan Litian Tungsten Industry Co., Ltd.**** | China |
| * | Denotes Conformant smelters |
| ** | Denotes Active smelters |
| *** | Denotes Non-participating smelters |
| **** | Denotes Non-conformant smelters |
| ***** | Denotes a Non-conformant smelter that may have sourced 3TGs from the DRC, but has ceased operations for at least a year |
14
APPENDIX B
Listed below are the countries of origin to which we previously referred in this report:
| Mineral |
Country | |
| Gold |
Benin, Bolivia (Plurinational State of), Burkina Faso, Canada, Chile, Colombia, Ecuador, Eritrea, Ghana, Guatemala, Guinea, Guyana, Honduras, Mali, Nicaragua, Panama, Peru, Russian Federation, Senegal, Togo, United States of America, South Africa | |
| Tantalum |
Australia, Bolivia (Plurinational State of), Brazil, Burundi, China, Columbia, DRC, Ethiopia, France, Guinea, Guyana, India, Kazakhstan, Madagascar, Malaysia, Mozambique, Namibia, Nigeria, Russian Federation, Rwanda, Sierra Leone, Thailand, United States of America, Zimbabwe | |
| Tin |
Argentina, Australia, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, DRC, Germany, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Thailand, United Kingdom of Great Britain and Northern Ireland, Uganda, Vietnam, Zimbabwe | |
| Tungsten |
Australia, Austria, Bolivia (Plurinational State of), Brazil, Burundi, Cambodia, Canada, China, Colombia, DRC, Japan, Mexico, Mongolia, Nigeria, Portugal, Russian Federation, Rwanda, Spain, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam | |
15