EX-1.01 2 ex1012018.htm EXHIBIT 1.01 Exhibit


Lumentum Holdings Inc.

Conflict Minerals Report

For the Calendar Year Ended December 31, 2017

Introduction

Lumentum Holdings Inc. (“Lumentum”, also referred to as “we”, “our” and “us”) (NASDAQ: LITE) is an industry leading provider of optical and photonic products addressing a range of end market applications including data communications (“Datacom”) and telecommunications networking and commercial lasers (“commercial lasers”) for manufacturing, inspection and life-science applications, as defined by revenue and market share. In addition, Lumentum is using its core optical and photonic technology and its volume manufacturing capability to expand into emerging markets that benefit from advantages that optical or photonics-based solutions provide, including 3D sensing for consumer electronics and diode light sources for a variety of consumer and industrial applications. The majority of Lumentum’s customers are original equipment manufacturers that incorporate Lumentum’s products into their products which address end-market applications. For example, Lumentum sells fiber optic components that its network equipment manufacturer customers assemble into communications networking systems, which they sell to network service providers or enterprises with their own networks. Increasingly, Lumentum is also selling Datacom products to owners and operators of large data centers, which Lumentum refers to as hyperscale datacenters. Similarly, many of the customers for Lumentum’s Lasers products incorporate Lumentum’s products into tools they produce, which are used for manufacturing processes by their customers. Lumentum has a global marketing and sales footprint that enables it to address global market opportunities for its products. Lumentum has manufacturing capabilities and facilities in North America, Asia-Pacific and Europe, the Middle East and Africa with employees engaged in R&D, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum’s Amendment No. 1 to Annual Report on Form 10-K/A for the fiscal year ended July 1, 2017, filed with the U.S. Securities and Exchange Commission (“SEC”) on March 29, 2018.

This Report has been prepared in accordance with the requirements of Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”) contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2017. Third-party products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report. This Report can be found on our website at www.lumentum.com/investors.

Executive Summary
Lumentum reviewed its entire affected supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2017 and contained Conflict Minerals. We then contacted these suppliers, each of which provided us with a list of smelter or refiner names (collectively, “smelters”). We identified 319 unique smelter entities in Lumentum’s supply chain. Of these 319 smelters, 42 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the “DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 37 of the 42 smelters were Responsible Minerals Assurance Process (“RMAP”) conformant in 2017. The remaining five smelters sourcing from the Covered Countries were subject to Lumentum’s risk mitigation process.


Design of Due Diligence
Lumentum designed its due diligence measures to conform to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the “OECD Guidance”). The OECD Guidance sets forth five steps for supply chain due diligence. There is significant overlap between our reasonable country of origin inquiry (“RCOI”) efforts and our due diligence measures performed, both of which are described below.


Management Systems





Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies, and maintain an e-mail address conflictminerals@lumentum.com for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the RCOI and due diligence procedures described below. All relevant Conflict Minerals data is kept in our internal database system.

Reasonable Country of Origin Inquiry
Lumentum conducted a RCOI that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2017. We retained a third-party consulting firm to assist with the RCOI and due diligence processes. As part of our RCOI, we contacted approximately 427 suppliers and original manufacturers. Each direct supplier was provided with Lumentum’s Conflict Minerals Policy and asked to provide Conflict Minerals data in the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this review, 319 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After directly contacting all 319 smelters and performing a risk assessment regarding responses, 42 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the smelters as well as other public information available at the time. In accordance with the Rule, Lumentum is required to exercise due diligence on the Conflict Minerals’ source and chain of custody and to follow a nationally or internationally recognized due diligence framework.


Conflict Minerals Policy
Lumentum’s Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/corporate-responsibility/partner-responsibility-ethics-and-labor.


Risk Assessment and Response
Lumentum’s risk assessment plan was designed to define, identify, mitigate, and manage risks. Should a risk arise, it would be reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply chain and directly contacted all 319 smelters and performed a risk assessment regarding responses. 42 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the smelters as well as other public information available at the time. Lumentum then compared this list to the list provided by the RMAP and for smelters that were not identified by the RMAP as conflict free, Lumentum conducted risk mitigation. These smelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.

Due Diligence Results and Ongoing Risk Mitigation Efforts

Smelters
Of the 42 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 37 smelters were recognized as RMAP Conformant at the end of 2017. Lumentum has conducted and continues to conduct risk mitigation on the remaining five smelters that are not RMAP Conformant. Lumentum has contacted all of its suppliers who have these five smelters in their supply chain and has either (i) requested confirmation that the identified smelter is not in the supply chain for products the supplier sells to Lumentum or (ii) demanded removal of the smelter from its supply chain. Lumentum’s risk mitigation efforts are ongoing. A list of the identified smelters is listed on Annex A hereto.

Because Lumentum’s suppliers source from smelters that source from the Covered Countries and some of these smelters were not yet conflict free certified at the end of our 2017 due diligence process, Lumentum has been unable to reach a definitive conclusion regarding its products manufactured during calendar year 2017.

Steps to be Taken to Mitigate Risk
Lumentum is committed to continuous improvement in our due diligence process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their Conflict





Minerals status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.

Additional Risk Factors
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our determinations regarding the status of our supply chain with respect to Conflict Minerals. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in conflict free smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to Conflict Minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.





Annex A

Smelters and Refineries

Below is a list of the smelters reported to Lumentum as likely in Lumentum’s supply chain as of December 31, 2017.

Metal
Smelter
Gold
Abington Reldan Metals, LLC
Gold
Advanced Chemical Company
Gold
Aida Chemical Industries Co., Ltd.
Gold
Al Etihad Gold Refinery DMCC
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Gold
Argor-Heraeus S.A.
Gold
Asahi Pretec Corp.
Gold
Asahi Refining Canada Ltd.
Gold
Asahi Refining USA Inc.
Gold
Asaka Riken Co., Ltd.
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
AU Traders and Refiners
Gold
Aurubis AG
Gold
Bangalore Refinery
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
Boliden AB
Gold
C. Hafner GmbH + Co. KG
Gold
Caridad
Gold
CCR Refinery - Glencore Canada Corporation
Gold
Cendres + Métaux S.A.
Gold
Chimet S.p.A.
Gold
Chugai Mining
Gold
Daejin Indus Co., Ltd.
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Degussa Sonne / Mond Goldhandel GmbH
Gold
DODUCO Contacts and Refining GmbH
Gold
Dowa
Gold
DSC (Do Sung Corporation)
Gold
Eco-System Recycling Co., Ltd.
 
 
Gold
Emirates Gold DMCC
Gold
Fidelity Printers and Refiners Ltd.
 
 
Gold
Geib Refining Corporation
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Gold
Guangdong Jinding Gold Limited
Gold
Gujarat Gold Centre
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
HeeSung Metal Ltd.
Gold
Heimerle + Meule GmbH





Gold
Henan Yuguang Gold & Lead Co., Ltd.
Gold
Heraeus Metals Hong Kong Ltd.
Gold
Heraeus Precious Metals GmbH & Co. KG
Gold
Hunan Chenzhou Mining Co., Ltd.
Gold
HwaSeong CJ Co., Ltd.
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold
Ishifuku Metal Industry Co., Ltd.
Gold
Istanbul Gold Refinery
Gold
Italpreziosi
Gold
Japan Mint
Gold
Jiangxi Copper Co., Ltd.
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold
JSC Uralelectromed
Gold
JX Nippon Mining & Metals Co., Ltd.
Gold
Kaloti Precious Metals
Gold
Kazakhmys Smelting LLC
Gold
Kazzinc
Gold
Kennecott Utah Copper LLC
Gold
KGHM Polska Miedź Spółka Akcyjna
Gold
Kojima Chemicals Co., Ltd.
Gold
Korea Zinc Co., Ltd.
Gold
Kyrgyzaltyn JSC
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Gold
L'azurde Company For Jewelry
Gold
L'Orfebre S.A.
Gold
Lingbao Gold Co., Ltd.
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
LS-NIKKO Copper Inc.
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold
Marsam Metals
Gold
Materion
Gold
Matsuda Sangyo Co., Ltd.
Gold
Metalor Technologies (Hong Kong) Ltd.
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Gold
Metalor Technologies (Suzhou) Ltd.
Gold
Metalor Technologies S.A.
Gold
Metalor USA Refining Corporation
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
Gold
Mitsubishi Materials Corporation
Gold
Mitsui Mining and Smelting Co., Ltd.
Gold
MMTC-PAMP India Pvt., Ltd.
Gold
Modeltech Sdn Bhd
Gold
Morris and Watson
Gold
Morris and Watson Gold Coast
Gold
Moscow Special Alloys Processing Plant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold
Navoi Mining and Metallurgical Combinat
Gold
Nihon Material Co., Ltd.
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold
Ohura Precious Metal Industry Co., Ltd.





Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
OJSC Novosibirsk Refinery
Gold
PAMP S.A.
Gold
Pease & Curren
Gold
Penglai Penggang Gold Industry Co., Ltd.
Gold
Planta Recuperadora de Metales SpA
Gold
Prioksky Plant of Non-Ferrous Metals
Gold
PT Aneka Tambang (Persero) Tbk
Gold
PX Précinox S.A.
Gold
Rand Refinery (Pty) Ltd.
Gold
Refinery of Seemine Gold Co., Ltd.
Gold
Remondis Argentia B.V.
Gold
Republic Metals Corporation
Gold
Royal Canadian Mint
Gold
SAAMP
Gold
Sabin Metal Corp.
Gold
Safiment S.p.A
Gold
SAFINA A.S.
Gold
Sai Refinery
Gold
Samduck Precious Metals
Gold
SAMWON Metals Corp.
Gold
SAXONIA Edelmetalle GmbH
Gold
Schone Edelmetaal B.V.
Gold
SEMPSA Joyería Platería S.A.
Gold
Shandong Humon Smelting Co., Ltd.
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold
Sichuan Tianze Precious Metals Co., Ltd.
Gold
Singway Technology Co., Ltd.
 
 
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
Solar Applied Materials Technology Corp.
Gold
State Research Institute Center for Physical Sciences and Technology
Gold
Sudan Gold Refinery
Gold
Sumitomo Metal Mining Co., Ltd.
Gold
SungEel HiMetal Co., Ltd.
Gold
Super Dragon Technology Co., Ltd.
Gold
T.C.A S.p.A
Gold
Tanaka Kikinzoku Kogyo K.K.
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
Tokuriki Honten Co., Ltd.
Gold
Tongling Nonferrous Metals Group Co., Ltd.
Gold
Tony Goetz NV
Gold
TOO Tau-Ken-Altyn
Gold
Torecom
Gold
Umicore Brasil Ltda.
Gold
Umicore Precious Metals Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
Gold
United Precious Metal Refining, Inc.





Gold
Universal Precious Metals Refining Zambia
Gold
Valcambi S.A.
Gold
Western Australian Mint trading as The Perth Mint
Gold
WIELAND Edelmetalle GmbH
Gold
Yamakin Co., Ltd.
 
 
Gold
Yokohama Metal Co., Ltd.
Gold
Yunnan Copper Industry Co., Ltd.
Gold
Zhongkuang Gold Industry Co., Ltd.
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum
Asaka Riken Co., Ltd.
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
 
 
Tantalum
D Block Metals, LLC
 
 
Tantalum
Exotech Inc.
Tantalum
F&X Electro-Materials Ltd.
Tantalum
FIR Metals & Resource Ltd.
Tantalum
Global Advanced Metals Aizu
Tantalum
Global Advanced Metals Boyertown
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
Tantalum
H.C. Starck Co., Ltd.
 
 
 
 
Tantalum
H.C. Starck Hermsdorf GmbH
Tantalum
H.C. Starck Inc.
Tantalum
H.C. Starck Ltd.
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
 
 
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum
Jiangxi Tuohong New Raw Material
Tantalum
Jiujiang Janny New Material Co., Ltd.
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited.
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum
KEMET Blue Metals
Tantalum
KEMET Blue Powder
 
 
Tantalum
LSM Brasil S.A.
Tantalum
Metallurgical Products India Pvt., Ltd.
Tantalum
Mineração Taboca S.A.
Tantalum
Mitsui Mining & Smelting
 
 
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
NPM Silmet AS
 
 
Tantalum
Power Resources Ltd.
Tantalum
QuantumClean
Tantalum
Resind Indústria e Comércio Ltda.





Tantalum
RFH Tantalum Smeltry Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tantalum
Solikamsk Magnesium Works OAO
Tantalum
Taki Chemicals
Tantalum
Telex Metals
 
 
Tantalum
Ulba Metallurgical Plant JSC
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
 
 
Tin
Alpha
 
 
Tin
An Vinh Joint Stock Mineral Processing Company
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
Tin
China Tin Group Co., Ltd.
 
 
 
 
Tin
CV Ayi Jaya
Tin
CV Dua Sekawan
Tin
CV Gita Pesona
Tin
CV Serumpun Sebalai
Tin
CV Tiga Sekawan
Tin
CV United Smelting
Tin
CV Venus Inti Perkasa
Tin
Dowa
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
 
 
Tin
EM Vinto
Tin
Estanho de Rondônia S.A.
Tin
Fenix Metals
Tin
Gejiu Fengming Metallurgy Chemical Plant
Tin
Gejiu Jinye Mineral Company
Tin
Gejiu Kai Meng Industry and Trade LLC
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin
Guangdong Hanhe Non-Ferrous Metal Co. Ltd.
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
Tin
HuiChang Hill Tin Industry Co., Ltd.
Tin
Huichang Jinshunda Tin Co., Ltd.
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
Tin
Magnu's Minerais Metais e Ligas Ltda.
Tin
Malaysia Smelting Corporation (MSC)
Tin
Melt Metais e Ligas S.A.
Tin
Metallic Resources, Inc.
Tin
Metallo-Belgium N.V.
Tin
Metallo-Spain S.L.U.
Tin
Mineração Taboca S.A.
Tin
Minsur
Tin
Mitsubishi Materials Corporation
Tin
Modeltech Sdn Bhd





Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
O.M. Manufacturing Philippines, Inc.
Tin
Operaciones Metalurgical S.A.
Tin
Pongpipat Company Limited
Tin
PT Aries Kencana Sejahtera
Tin
PT Artha Cipta Langgeng
Tin
PT ATD Makmur Mandiri Jaya
Tin
PT Babel Inti Perkasa
Tin
PT Bangka Prima Tin
Tin
PT Bangka Serumpun
Tin
PT Bangka Tin Industry
Tin
PT Belitung Industri Sejahtera
Tin
PT Bukit Timah
 
 
Tin
PT DS Jaya Abadi
Tin
PT Eunindo Usaha Mandiri
Tin
PT Inti Stania Prima
 
 
Tin
PT Karimun Mining
Tin
PT Kijang Jaya Mandiri
Tin
PT Lautan Harmonis Sejahtera
Tine
PT Menara Cipta Mulia
Tin
PT Mitra Stania Prima
 
 
Tin
PT Panca Mega Persada
Tin
PT Premium Tin Indonesia
Tin
PT Prima Timah Utama
Tin
PT Refined Bangka Tin
Tin
PT Sariwiguna Binasentosa
Tin
PT Stanindo Inti Perkasa
Tin
PT Sukses Inti Makmur
Tin
PT Sumber Jaya Indah
Tin
PT Timah (Persero) Tbk Kundur
Tin
PT Timah (Persero) Tbk Mentok
Tin
PT Tinindo Inter Nusa
Tin
PT Tommy Utama
 
 
Tin
Resind Indústria e Comércio Ltda.
Tin
Rui Da Hung
Tin
Soft Metais Ltda.
Tin
Super Ligas
Tin
Thaisarco
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
 
 
Tin
White Solder Metalurgia e Mineração Ltda.
 
 
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin
Yunnan Tin Company Limited
Tungsten
A.L.M.T. TUNGSTEN Corp.





Tungsten
ACL Metais Eireli
Tungsten
Asia Tungsten Products Vietnam Ltd.
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
Ganzhou Haichuang Tungsten Industry Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
Tungsten
Global Tungsten & Powders Corp.
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
Tungsten
H.C. Starck Smelting GmbH & Co.KG
Tungsten
H.C. Starck Tungsten GmbH
Tungsten
Hunan Chenzhou Mining Co., Ltd.
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
Hunan Litian Tungsten Industry Co., Ltd
Tungsten
Hydrometallurg, JSC
Tungsten
Japan New Metals Co., Ltd.
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten
Kennametal Fallon
Tungsten
Kennametal Huntsville
Tungsten
Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
Tungsten
Moliren Ltd
Tungsten
Niagara Refining LLC
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten
Philippine Chuangxin Industrial Co., Inc.
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
Unecha Refractory Metals Plant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten
Wolfram Bergbau und Hütten AG
Tungsten
Woltech Korea Co., Ltd.
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
Xiamen Tungsten Co., Ltd.
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.

42 of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. Under the Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries and





there is no requirement to identify the specific Covered Country by the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are the DRC, Rwanda, Burundi, and Tanzania.