0000721371-17-000038.txt : 20170531 0000721371-17-000038.hdr.sgml : 20170531 20170531083826 ACCESSION NUMBER: 0000721371-17-000038 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20161231 1.02 20161231 FILED AS OF DATE: 20170531 DATE AS OF CHANGE: 20170531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CARDINAL HEALTH INC CENTRAL INDEX KEY: 0000721371 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-DRUGS PROPRIETARIES & DRUGGISTS' SUNDRIES [5122] IRS NUMBER: 310958666 STATE OF INCORPORATION: OH FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-11373 FILM NUMBER: 17879602 BUSINESS ADDRESS: STREET 1: 7000 CARDINAL PLACE CITY: DUBLIN STATE: OH ZIP: 43017 BUSINESS PHONE: 6147573033 MAIL ADDRESS: STREET 1: 7000 CARDINAL PLACE CITY: DUBLIN STATE: OH ZIP: 43017 FORMER COMPANY: FORMER CONFORMED NAME: CARDINAL DISTRIBUTION INC DATE OF NAME CHANGE: 19920703 SD 1 a2016formsd.htm FORM SD Document


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

FORM SD
Specialized Disclosure Report
 
Cardinal Health, Inc.
(Exact name of registrant as specified in its charter)
 
 
 
 
 
 
Ohio
 
1-11373
 
31-0958666
(State or other jurisdiction
of incorporation or organization)
 
(Commission
File Number)
 
(IRS Employer
Identification No.)
7000 Cardinal Place, Dublin, Ohio 43017
(Address of principal executive offices) (Zip code)
Craig S. Morford
Chief Legal and Compliance Officer
(614) 757-5000
(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:
þ

Rule 13p-1 under the Securities Exchange Act (17 CFR 204.13p-1) for the reporting period from January 1 to December 31, 2016.







Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02. Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
A copy of Cardinal Health, Inc.'s Conflict Minerals Report for the reporting period from January 1, 2016 to December 31, 2016 is filed as Exhibit 1.01 hereto and is publicly available on the company's website at http://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.

Section 2 - Exhibits
Item 2.01. Exhibits
1.01

 
Conflict Minerals Report for the reporting period from January 1, 2016 to December 31, 2016

2



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 duly authorized undersigned.
 
 
 
 
 
Cardinal Health, Inc.
(Registrant)
 
 
 
 
 
 
By:
/s/ Craig S. Morford
 
Date: May 31, 2017
 
Craig S. Morford
 
 
 
Chief Legal and Compliance Officer
 
 

3



EXHIBIT INDEX
1.01

 
Conflict Minerals Report for the reporting period from January 1, 2016 to December 31, 2016


4
EX-1.01 2 exhibit101-x2016conflictmi.htm CONFLICT MINERALS REPORT Exhibit
Exhibit 1.01

Cardinal Health, Inc.
Conflict Minerals Report
For the 2016 Reporting Period
Introduction
Cardinal Health, Inc. is a globally integrated healthcare services and products company that manages its business in two segments: Pharmaceutical and Medical. As used in this report, "Cardinal Health," "we," "our," "us," and similar pronouns refer to Cardinal Health, Inc. and its consolidated subsidiaries, unless the context requires otherwise.
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the "Rule"), this Conflict Minerals Report describes, for the period from January 1, 2016 to December 31, 2016 (the "2016 reporting period"), the measures we have taken to conduct due diligence on the source and chain of custody of the conflict minerals contained in, and necessary to the functionality or production of, the products in our supply chain that we had reason to believe may have originated in the Democratic Republic of Congo or an adjoining country (collectively, the “covered countries”) and may not have come from recycled or scrap sources. Under the Rule, "conflict minerals" are defined as columbite-tantalite (coltan), cassiterite, gold, and wolframite, including their derivatives, which are limited to tantalum, tin, and tungsten.
Products Subject to this Report and Our Supply Chain
We assessed all product lines manufactured or contracted to be manufactured by us throughout our two segments in the 2016 reporting period to determine whether they potentially contained conflict minerals. Through the screening process, our product teams determined, to the best of their knowledge, that the following product lines manufactured or contracted to be manufactured by our Medical segment (collectively, the "in-scope products") contained conflict minerals and are subject to this report for the 2016 reporting period: radio frequency identification ("RFID") enabled inventory management cabinets and wands; ureteral stone retrieval devices; certain balloon catheters; and certain negative pressure wound therapy devices.
Our supply chains are complex and fragmented. As a “downstream” company, we are many tiers removed in the minerals supply chain from smelters and refiners (collectively, "SORs") that process the metals found in our products, with many intervening third parties between the original sources of conflict minerals and us. We, therefore, must rely on our direct suppliers, with which we have business relationships, to provide information regarding the sourcing of conflict minerals in our in-scope products. Our direct suppliers, in turn, are also downstream in the minerals supply chain and have similar challenges.
Reasonable Country of Origin Inquiry
We conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals in materials, components, and finished goods supplied to us that relate to the in-scope products. The RCOI was designed to determine whether any of the conflict minerals originated in the covered countries and whether any of the conflict minerals may be from recycled or scrap sources.
With the assistance of a third-party vendor (the “Vendor”) with expertise in supply chain due diligence, we engaged 15 suppliers to collect information regarding the presence and sourcing of conflict minerals in our in-scope products. These suppliers were asked to complete the Conflict Minerals Reporting Template (v.4.10 or higher) (the “CMRT”) and return it to the Vendor for assessment and management. The CMRT is an internationally-recognized, standardized reporting form developed by the Conflict-Free Sourcing Initiative (“CFSI”) that requests, among other things, information regarding the country of origin of conflict minerals and the SORs in the conflict minerals supply chain.
The Vendor followed up with all unresponsive suppliers using both automated and personalized emails and offered assistance and further information about the requirements of the Rule and our expectations.
The Vendor identified and followed up on incomplete or contradictory answers in each CMRT submitted and encouraged suppliers to re-submit a valid form.
Where suppliers identified a list of metals processors in their completed CMRTs, the Vendor verified whether the metals processors were actually SORs or recyclers of conflict minerals by comparing the alleged SOR names to CFSI’s Standard Smelter List. If a supplier indicated that a metals processor was certified as conflict-free, the Vendor also confirmed that the processor was listed on the CFSI's list of validated conflict-free SORs. Our suppliers identified a total 310 SORs verified to exist, of which 249 SORs are indicated as conflict-free by CFSI. Many of the CMRTs we received were prepared on a company or division-level basis, which did not allow us to identify which SORs actually processed the conflict minerals contained in our products.





The Vendor researched and reviewed mine information for the verified SORs to determine, to the best of its knowledge, the country of origin of the conflict minerals processed by those SORs. This information was also compared to the country of origin data available to members of CFSI.
Based on our RCOI, we have reason to believe that at least some of the conflict minerals contained in the in-scope products originated in the covered countries, and are not from recycled or scrap sources. Accordingly, we conducted due diligence on the source and chain of custody of these conflict minerals.
Due Diligence
The due diligence measures described below were designed to conform, in all material respects, with the internationally recognized due diligence framework set forth in the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplements on 3T (tin, tantalum, and tungsten) and gold (the "OECD Guidance"). The OECD Guidance identifies five steps for due diligence that should be implemented and provides specific guidance with respect to each step. We developed our due diligence measures to address each of these five steps. These measures took into account the OECD Guidance’s recommendations for companies in the downstream segments of the supply chain, which typically are several tiers removed from, and have no direct relationships with, SORs.
1.
Company Management Systems
The Company has implemented a conflict minerals compliance program (the “Program”) with the following attributes:
Policy Statement
In 2015, we adopted a Conflict Minerals Policy (the "Policy"), which is available on our website at http://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html and which sets forth the expectation that our suppliers source materials from suppliers that also source responsibly, including from conflict-free mines in the covered countries.
Steering Committee
In 2015, we established a conflict minerals steering committee to provide cross-functional oversight for the Program, including representatives from sourcing, legal, quality and regulatory, finance, and internal audit. Our Executive Vice President, Global Sourcing is the executive leader of the steering committee. Steering committee members periodically report on Program developments and progress to our Chief Legal and Compliance Officer and to the Corporate Social Responsibility Subcommittee of our Disclosure Committee.
Control Systems and Supply Chain Transparency
As discussed above, in 2016, we engaged the Vendor to facilitate supplier engagement and assist us in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Program. With the assistance of the Vendor, we contacted and solicited information from our potential direct suppliers of conflict minerals using the CMRT.
To further strengthen the Program, in 2016, we became a member of CFSI, a cross-industry organization that provides resources, tools, and information to help companies source conflict-free minerals, including a list of confirmed SORs and CFSI’s Conflict-Free Smelter Program (the “CFSP”), which validates SORs as conflict-free based on independent third-party audits.
Our Policy encourages suppliers to adopt similar policies and management systems with respect to conflict minerals. It also asks that suppliers take reasonable, good faith steps toward assisting us in reporting on our conflict minerals supply chain and, over time, work to identify and supply materials to us that do not contain conflict minerals that directly or indirectly financed or benefited armed groups in the covered countries.
Our Vendor Code of Conduct, which we adopted in 2016 (the "Vendor Code of Conduct"), requires suppliers to comply with the Policy, including working with their suppliers to identify the source and chain of custody of any conflict minerals contained in their products. Suppliers must agree to cooperate with us in connection with any inquiries or due diligence that we choose to perform with respect to such conflict minerals.
The Vendor maintains records of product and supply chain information collected through the due diligence activities carried out under the Program. Documentation related to the annual CMRTs is retained for at least five years.

2



Supplier Engagement
In support of our Policy, we have incorporated conflict mineral provisions into the standard terms of our Medical segment's master distribution agreement template. Since most agreements have multi-year terms, it will take a number of years to integrate these provisions into our various supplier agreements as new supplier relationships are formed and existing suppliers renew their contracts. As discussed above, we also addressed conflict minerals in the Vendor Code of Conduct.
To ensure suppliers understand our expectations, we have, through the Vendor, provided video and written training on conflict minerals and the CMRT to suppliers of in-scope products. This training includes instructions on completing the CMRT and one-on-one email and phone discussions with supplier personnel, as needed. As an improvement for this year's program, we utilized the Vendor's on-line learning management system and provided suppliers of in-scope products with access to on-line conflict minerals training courses. We encouraged all suppliers to complete these courses, and we tracked all training based on completion.
Grievance Mechanism
We have a dedicated email address for reporting questions or concerns relating to our Policy or Program to a Cardinal Health representative. In addition, we have a business conduct line that provides a mechanism for anyone to anonymously report conduct they know or believe is in violation of Cardinal Health guidelines or policies, including any concerns related to the conflict minerals supply chain.
2.
Risk Identification and Assessment
Risks are identified automatically in the Vendor's system based on criteria established for supplier responses, including the submission of a CMRT with incomplete or contradictory answers. These risks are addressed by the Vendor's staff, who contact the supplier, gather pertinent data, and perform an assessment of the supplier’s conflict minerals status. All risks are communicated to our conflict minerals steering committee and Chief Legal and Compliance Officer.
The Vendor attempted to match each verified SOR from the CMRT responses to lists of conflict-free SORs (i.e., SORs validated or certified as conflict-free under internationally-recognized programs such as the CFSP, the London Bullion Market Association Good Delivery program, and the Responsible Jewellery Council Chain-of-Custody Certification program). SORs classified as actively pursuing conflict-free status under the CFSP also were identified.
Each facility that meets the CFSI definition of a SOR of a conflict mineral was assigned a risk rating based on geographic proximity to the covered countries, Conflict-Free Smelter Program ("CFSP") audit status, and any known or plausible evidence of unethical or conflict sourcing. When SORs determined to be of higher risk were reported on a CMRT by one of the suppliers surveyed, we sought to mitigate risk by requesting, through the Vendor, that the supplier to take its own risk mitigation actions, including the submission of a product-specific CMRT to better identify the connection to products that they supply to us.
Additionally, we, through the Vendor, evaluated the strength of our suppliers' conflict minerals due diligence and supply chain control program, further assisting us in identifying supply chain risk. The criteria used to evaluate the program strength of our suppliers included whether the supplier has a conflict minerals policy, whether it has implemented due diligence measures for conflict-free sourcing, whether it verifies due diligence information from its suppliers, and whether its verification process includes corrective active management. If a supplier is determined to have a weak program as a result of this evaluation, it receives a communication from the Vendor informing it of this rating.
3.
Risk Response Strategy
Together with the Vendor, we have developed a strategy to respond to and assess risks identified in our supply chain. As the Program progresses, the Vendor or, if necessary, our supplier relationship managers make escalating contacts with suppliers that have not responded to our CMRT requests, and any suppliers that provided information on the CMRT at the company level are encouraged to re-submit at the product level.
We engage with our suppliers that we may have reason to believe are supplying us with conflict minerals from sources that may support conflict in the covered countries and encourage them to establish an alternative source of conflict minerals that does not support such conflict. We ensure that suppliers are provided with access to the proper training materials to understand the risks and to implement appropriate risk mitigation activities down through their own suppliers.
In addition, under our Vendor Code of Conduct, if we determine or believe at any time that a supplier has failed to comply with the standards set forth in the Vendor Code of Conduct, including those with respect to conflict minerals, we have the right to cease the purchase of the supplier's products and services without notice and without liability or obligation.


3



4.
Audit of Due Diligence Practices of SORs
We do not have a direct relationship with any SORs of conflict minerals and do not perform or direct audits of these entities within our supply chain. Instead, we support internationally-recognized assessment programs, such as the CFSP, that facilitate and confirm independent third-party audits of SORs’ supply chain due diligence practices, including through our membership in CFSI. Any SOR that has not been validated through such an audit or has been determined to be of higher risk receives a communication from the Vendor and from the CFSI to encourage the SOR to participate in a conflict-free assessment program such as the CFSP.
5.
Annual Reporting on Supply Chain Due Diligence
We report annually on our supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the U.S. Securities and Exchange Commission. We have published our Conflict Minerals Report for the 2016 reporting period our website at http://www.cardinalhealth.com/en/about-us/corporate-citizenship/ethics-and-governance.html.
Due Diligence Results
Survey Results
For the 2016 reporting period, we received responses from approximately 93% of all surveyed suppliers.
Smelters and Refiners
Based on the above-described due diligence efforts, we do not have conclusive information regarding the country of origin of, or facilities used to process, the necessary conflict minerals in our in-scope products for the 2016 reporting period.
Although we requested information about SORs and country of origin from our suppliers at a product level, many of our supplier CMRT responses consisted of information at a company level. As a result, these suppliers provided information about SORs in their supply chains generally, and not just for the products or components supplied specifically to us. Thus, information we received from our suppliers may not be relevant to any of our products and may identify SORs that are not actually in our supply chain.
In addition, some suppliers indicated that they have not received information regarding their supply chains from all of their suppliers and, therefore, could not provide a comprehensive list of all SORs in their supply chains.
Set forth in Annex A is a list of SORs reported in supplier CMRTs for which country of origin sourcing is known or which have conflict-free (or actively seeking conflict-free) status, based on CFSI data as of May 8, 2017. As noted above, we are unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals contained in our in-scope products.
Based on CFSI’s country of origin data as of May 8, 2017, which is organized by risk-based categories, Annex B provides an aggregated list of the countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, in addition to recycled and scrap sources.
Cardinal Health's efforts to determine the mine or location of origin of the necessary conflict minerals in its products with the greatest possible specificity consisted of the implementation of the Program and due diligence measures described above in this Conflict Minerals Report.
Risk Mitigation Steps
We took the following actions to improve our Program following the filing of our Conflict Minerals Report for the period from January 1, 2015 to December 31, 2015:
Improved Supplier Engagement. With the goal of increasing the response rate and quality of CMRT responses, including increasing the number of product-level CMRT responses, we engaged a Vendor, through which we reached out to suppliers, communicated our expectations under the Program, and offered education and training for suppliers. We also adopted a Vendor Code of Conduct that addresses conflict minerals and integrated expectations regarding the Program into new supplier contracts.
Enhanced Due Diligence Processes. Working with a Vendor for the first time, we were able to utilize its expertise in supplier surveys and supply chain due diligence, taking into account improvements in broader industry practice.

4



Supported Efforts to Encourage SOR Participation in Conflict-Free Validation Programs. We continued to participate as a member of CFSI to support programs like the CFSP that facilitate and validate independent third-party audits of SORs’ supply chain due diligence practices.
We will continue to monitor legislative and regulatory developments in this area and may modify our Program in response to these developments.
Forward-Looking Statements
This report includes forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995, that involve risks and uncertainties, such as whether industry organizations and initiatives remain effective as a source of external support to us in the conflict minerals compliance process. Forward-looking statements provide current expectations of future events based on certain assumptions and include any statement that does not directly relate to any historical or current fact. Forward-looking statements can also be identified by words such as “expects,” “plans,” “intends,” “will,” “may,” and similar terms. Forward-looking statements are not guarantees of future performance. We assume no obligation to revise or update any forward-looking statements for any reason, except as required by law. Subsequent events may affect our future determinations under the Rule.

5



ANNEX A
The following is a list of SORs reported in supplier CMRTs for which country of origin sourcing is known or which have conflict-free (or actively seeking conflict-free) status, based on CFSI data as of May 8, 2017. SORs that have been validated by CFSI to have conflict-free sourcing, or are in the process of being validated, are indicated by asterisk.
As explained in our Conflict Minerals Report, we are unable to determine whether any of the facilities listed in Annex A in fact processed conflict minerals in our in-scope products. As a result, the presence of a smelter on the list does not mean that our in-scope products necessarily contained conflict minerals processed by that smelter.
Mineral
Smelter Name
Smelter Location
Gold
Advanced Chemical Company*
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.*
JAPAN
Gold
Al Etihad Gold Refinery DMCC*
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração*
BRAZIL
Gold
Argor-Heraeus S.A.*
SWITZERLAND
Gold
Asahi Pretec Corp.*
JAPAN
Gold
Asahi Refining Canada Ltd.*
CANADA
Gold
Asahi Refining USA Inc.*
UNITED STATES
Gold
Asaka Riken Co., Ltd.*
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners*
SOUTH AFRICA
Gold
AURA-II
UNITED STATES
Gold
Aurubis AG*
GERMANY
Gold
Bangalore Refinery*
INDIA
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 + Métaux S.A.*
SWITZERLAND
Gold
Chimet S.p.A.*
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daejin Indus Co., Ltd.*
REPUBLIC OF KOREA
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
DODUCO GmbH*
GERMANY
Gold
Dowa*
JAPAN
Gold
DSC (Do Sung Corporation)*
REPUBLIC OF KOREA
Gold
Eco-System Recycling Co., Ltd.*
JAPAN
Gold
Elemetal Refining, LLC*
UNITED STATES
Gold
Emirates Gold DMCC*
UNITED ARAB EMIRATES
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Gold
Geib Refining Corporation*
UNITED STATES
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA

A-1



Gold
Guangdong Jinding Gold Limited
CHINA
Gold
Gujarat Gold Centre
INDIA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
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 Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
REPUBLIC OF KOREA
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
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
RUSSIAN FEDERATION
Gold
JSC Uralelectromed*
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.*
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc*
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC*
UNITED STATES
Gold
KGHM Polska Miedź Spółka Akcyjna*
POLAND
Gold
Kojima Chemicals Co., Ltd.*
JAPAN
Gold
Korea Zinc Co., Ltd.*
REPUBLIC OF KOREA
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.*
REPUBLIC OF KOREA
Gold
Luoyang Zijin Yinhui Gold Refinery 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 (Suzhou) Ltd.*
CHINA
Gold
Metalor Technologies S.A.*
SWITZERLAND
Gold
Metalor USA Refining Corporation*
UNITED STATES
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.*
MEXICO
Gold
Mitsubishi Materials Corporation*
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.*
JAPAN
Gold
MMTC-PAMP India Pvt., Ltd.*
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Moscow Special Alloys Processing Plant*
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
TURKEY
Gold
Navoi Mining and Metallurgical Combinat*
UZBEKISTAN

A-2



Gold
Nihon Material Co., Ltd.*
JAPAN
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.*
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery*
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 Précinox S.A.*
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.*
SOUTH AFRICA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Republic Metals Corporation*
UNITED STATES
Gold
Royal Canadian Mint*
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES
Gold
SAFINA A.S.
CZECH REPUBLIC
Gold
Sai Refinery
INDIA
Gold
Samduck Precious Metals*
REPUBLIC OF KOREA
Gold
SAMWON Metals Corp.
REPUBLIC OF KOREA
Gold
SAXONIA Edelmetalle GmbH*
GERMANY
Gold
Schone Edelmetaal B.V.*
NETHERLANDS
Gold
SEMPSA Joyería Platería S.A.*
SPAIN
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
CHINA
Gold
Singway Technology Co., Ltd.*
TAIWAN
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
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.*
JAPAN
Gold
T.C.A S.p.A*
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.*
JAPAN
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
Tony Goetz NV*
BELGIUM
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom*
REPUBLIC OF KOREA
Gold
Umicore Brasil Ltda.*
BRAZIL
Gold
Umicore Precious Metals Thailand*
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining*
BELGIUM
Gold
United Precious Metal Refining, Inc.*
UNITED STATES
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
Valcambi S.A.*
SWITZERLAND

A-3



Gold
Western Australian Mint trading as The Perth Mint*
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH*
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
D Block Metals, LLC*
UNITED STATES
Tantalum
Duoluoshan*
CHINA
Tantalum
Exotech Inc.*
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.*
CHINA
Tantalum
FIR Metals & Resource Ltd.*
CHINA
Tantalum
Global Advanced Metals Aizu*
JAPAN
Tantalum
Global Advanced Metals Boyertown*
UNITED STATES
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
CHINA
Tantalum
H.C. Starck Co., Ltd.*
THAILAND
Tantalum
H.C. Starck GmbH Goslar*
GERMANY
Tantalum
H.C. Starck GmbH Laufenburg
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
Hengyang King Xing Lifeng New Materials Co., Ltd.*
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.*
UNITED STATES
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
Jiangxi Tuohong New Raw Material*
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.*
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
CHINA
Tantalum
KEMET Blue Metals*
MEXICO
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
Plansee SE Reutte*
AUSTRIA
Tantalum
QuantumClean*
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.*
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.*
CHINA
Tantalum
Solikamsk Magnesium Works OAO*
RUSSIAN FEDERATION

A-4



Tantalum
Taki Chemicals*
JAPAN
Tantalum
Telex Metals*
UNITED STATES
Tantalum
Tranzact, Inc.*
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC*
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.*
CHINA
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.*
CHINA
Tin
Alpha*
UNITED STATES
Tin
An Thai Minerals Co., Ltd.
VIETNAM
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
CHINA
Tin
China Tin Group Co., Ltd.*
CHINA
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tin
Cooperativa Metalurgica de Rondônia Ltda.*
BRAZIL
Tin
CV Ayi Jaya*
INDONESIA
Tin
CV Dua Sekawan*
INDONESIA
Tin
CV Gita Pesona*
INDONESIA
Tin
CV Serumpun Sebalai*
INDONESIA
Tin
CV Tiga Sekawan*
INDONESIA
Tin
CV United Smelting*
INDONESIA
Tin
CV Venus Inti Perkasa*
INDONESIA
Tin
Dowa*
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company*
VIETNAM
Tin
Elmet S.L.U.*
SPAIN
Tin
EM Vinto*
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Fenix Metals*
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant*
CHINA
Tin
Gejiu Jinye Mineral Company*
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC*
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.*
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.*
CHINA
Tin
Magnu's Minerais Metais e Ligas Ltda.*
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA
Tin
Melt Metais e Ligas S.A.*
BRAZIL
Tin
Metallic Resources, Inc.*
UNITED STATES
Tin
Metallo-Chimique N.V.*
BELGIUM
Tin
Mineração Taboca S.A.*
BRAZIL
Tin
Minsur*
PERU
Tin
Mitsubishi Materials Corporation*
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA

A-5



Tin
Nankang Nanshan Tin Manufactory Co., Ltd.*
CHINA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.*
PHILIPPINES
Tin
Operaciones Metalurgical S.A.*
BOLIVIA
Tin
Phoenix Metal Ltd.
RWANDA
Tin
PT Aries Kencana Sejahtera*
INDONESIA
Tin
PT Artha Cipta Langgeng*
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya*
INDONESIA
Tin
PT Babel Inti Perkasa*
INDONESIA
Tin
PT Bangka Prima Tin*
INDONESIA
Tin
PT Bangka Tin Industry*
INDONESIA
Tin
PT Belitung Industri Sejahtera*
INDONESIA
Tin
PT Bukit Timah*
INDONESIA
Tin
PT Cipta Persada Mulia*
INDONESIA
Tin
PT DS Jaya Abadi*
INDONESIA
Tin
PT Eunindo Usaha Mandiri*
INDONESIA
Tin
PT Inti Stania Prima*
INDONESIA
Tin
PT Justindo
INDONESIA
Tin
PT Karimun Mining*
INDONESIA
Tin
PT Kijang Jaya Mandiri*
INDONESIA
Tin
PT Lautan Harmonis Sejahtera*
INDONESIA
Tin
PT Mitra Stania Prima*
INDONESIA
Tin
PT O.M. Indonesia*
INDONESIA
Tin
PT Panca Mega Persada*
INDONESIA
Tin
PT Prima Timah Utama*
INDONESIA
Tin
PT Refined Bangka Tin*
INDONESIA
Tin
PT Sariwiguna Binasentosa*
INDONESIA
Tin
PT Stanindo Inti Perkasa*
INDONESIA
Tin
PT Sukses Inti Makmur*
INDONESIA
Tin
PT Sumber Jaya Indah*
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur*
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok*
INDONESIA
Tin
PT Tinindo Inter Nusa*
INDONESIA
Tin
PT Tommy Utama*
INDONESIA
Tin
PT Wahana Perkit Jaya*
INDONESIA
Tin
Resind Indústria e Comércio Ltda.*
BRAZIL
Tin
Rui Da Hung*
TAIWAN
Tin
Soft Metais Ltda.*
BRAZIL
Tin
Thaisarco*
THAILAND
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
VQB Mineral and Trading Group JSC*
VIETNAM
Tin
White Solder Metalurgia e Mineração Ltda.*
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
CHINA
Tin
Yunnan Tin Company Limited*
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.*
JAPAN

A-6



Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.*
VIETNAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.*
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
CHINA
Tungsten
H.C. Starck GmbH*
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co. KG*
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
CHINA
Tungsten
Hydrometallurg, JSC*
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.*
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
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 Xiushui Xianggan Nonferrous Metals 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
Moliren Ltd*
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC*
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
VIETNAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City*
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
VIETNAM
Tungsten
Unecha Refractory metals plant*
RUSSIAN FEDERATION
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.*
VIETNAM
Tungsten
Wolfram Bergbau und Hütten AG*
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.*
REPUBLIC OF KOREA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.*
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
CHINA


A-7



ANNEX B
Countries of Origin
Below is an aggregated list of countries of origin, to the extent known, from which the SORs listed in Annex A are believed to have sourced conflict minerals, based on data available from CFSI as of May 8, 2017.
Angola
Laos
 
Argentina
Luxembourg
 
Australia
Madagascar
 
Austria
Malaysia
 
Belgium
Mongolia
 
Bolivia
Mozambique
 
Brazil
Myanmar
 
Burundi
Namibia
 
Cambodia
Netherlands
 
Canada
Nigeria
 
Central African Republic
Peru
 
Chile
Portugal
 
China
Russia
 
Colombia
Republic of Congo
 
Côte D'Ivoire
Rwanda
 
Czech Republic
Sierra Leone
 
Democratic Republic of Congo
Singapore
 
Djibouti
Slovakia
 
Ecuador
South Africa
 
Egypt
South Korea
 
Estonia
South Sudan
 
Ethiopia
Spain
 
France
Suriname
 
Germany
Switzerland
 
Guyana
Taiwan
 
Hungary
Thailand
 
India
Tanzania
 
Indonesia
Uganda
 
Ireland
United Kingdom
 
Israel
United States
 
Japan
Vietnam
 
Kazakhstan
Zambia
 
Kenya
Zimbabwe
 


B-1