EX-1.01 2 ex1011-fmcmr123117.htm EXHIBIT 1.01.1 Wdesk | Exhibit


EXHIBIT 1.01.1



Icahn Enterprises L.P. and Icahn Enterprises Holdings L.P.
Conflict Minerals Report
(Federal-Mogul LLC)

INTRODUCTION
This Conflict Minerals Report (“CMR”) of Icahn Enterprises L.P. and Icahn Enterprises Holdings L.P. has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”) for the reporting period from January 1, 2017 to December 31, 2017 (“the Reporting Period”). Due to the nature of our business, this CMR was prepared to specifically disclose certain information relating to our operating subsidiary, Federal-Mogul LLC (“Federal-Mogul” or the “Company”).
Rule 13p-1 under the Exchange Act requires the disclosure of certain information when a company manufactures or contracts to manufacture products for which “Conflict Minerals” are necessary to the functionality or production of those products. “Conflict Minerals” for the purposes of Rule 13p-1 are gold, columbite-tantalite (coltan), cassiterite, and wolframite (including their derivatives, tantalum, tin and tungsten, and other minerals or derivatives the U.S. Secretary of State may designate in the future). The “Covered Countries” for the purposes of Rule 13p-1 are the Democratic Republic of the Congo (“the DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.
In accordance with Securities and Exchange Commission (“SEC”) guidance, this CMR is not audited.
As required by Rule 13p-1, this CMR relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are collectively referred to in this report as the “Covered Products”, include railcars and certain railcar components manufactured or sourced by Federal-Mogul's Manufacturing segment. The Company believes that only a small portion of the materials content of the Covered Products constitute Conflict Minerals necessary to their functionality and/or production.

1.    COMPANY OVERVIEW

The Company

Federal-Mogul is a diversified, global supplier of automotive products to a variety of end markets. Federal-Mogul has two business segments that principally focus on discrete markets, each with a chief executive officer reporting to the board of directors. The Federal-Mogul Powertrain segment (“Powertrain”) focuses on original equipment powertrain products for automotive, heavy-duty, and industrial applications. The Federal-Mogul Motorparts segment (“Motorparts”) sells and distributes a broad portfolio of products in the global vehicle aftermarket, while also serving original equipment manufacturers (“OEMs”) with vehicle products including brakes, wipers and, to a limited extent, chassis components.

For more than a century, Federal-Mogul has developed the innovative products its customers need to produce the next generation of vehicles and maintain the present vehicle population. Federal-Mogul is a preferred provider to its customers as a result of its global engineering, manufacturing, distribution and customer service capabilities. The Company continues to develop new technologies that improve fuel economy, reduce emissions, and enhance durability, safety, and vehicle performance. As a result, Federal-Mogul believes that it is uniquely positioned to effectively manage the life cycle of a broad range of original equipment products and original equipment service products (together with OEMs, “OE”) and aftermarket products to a diverse customer base.

Federal-Mogul is a leading technology supplier and, by the Company’s estimates, a market share leader in several product categories. As of December 31, 2017, Federal-Mogul had OE products included on more than 400 global vehicle platforms and more than 1,000 global powertrains used in light, medium, and heavy-duty vehicles. Motorparts is one of the industry’s largest aftermarket-focused suppliers, offering a range of maintenance and repair parts under more than 20 globally recognized brands, as well as numerous private label programs.

Supply Chain






Federal-Mogul’s highly engineered products are manufactured from a variety of raw materials and incorporate subcomponents which are distributed through a global supply chain. The Company has relationships with a considerable network of suppliers throughout the world and has found that the majority of its suppliers are three tiers or more removed from smelter and refiner operations. Therefore, Federal-Mogul must rely on its direct suppliers to work with their upstream suppliers in order to provide information on the origin of 3TG contained in components and materials supplied to Federal-Mogul. Federal-Mogul has incorporated disclosure requirements with respect to conflict minerals in its Restricted Substance Management Standard (the “Restricted Substances Standard”) and North America Terms and Conditions of Purchase (“T&Cs”), and it is Federal-Mogul’s expectation that its suppliers will adopt policies and procedures with respect to conflict minerals.

Because it is not practicable to conduct a survey of all Federal-Mogul suppliers, the Company has developed a risk-based approach to due diligence that focuses on products believed to contain 3TG based on specifications and other documentation (the “product-centric approach”), as well as suppliers thought to potentially provide Federal-Mogul with components and materials incorporating 3TG due to the nature of such components or materials (the “supplier-centric approach”). The Company believes this is a reasonable approach because the combined product-centric and supplier-centric approaches offer a unique level of corroboration in information received from suppliers as compared to information Federal-Mogul maintains on-hand, while also focusing on relevant suppliers.

Conflict Minerals Policy

The Company has adopted a conflict minerals policy which is publicly available on its website at http://www.federalmogul.com/en-US/Suppliers/Pages/ConflictMinerals.aspx.

For additional information about Federal-Mogul’s commitment to responsible sourcing and other human rights, see the Company’s Code of Conduct at http://fedmogul.uberflip.com/i/786648-federal-mogul-code-of-conduct-external and Basic Working Conditions for Suppliers policy at http://www.federalmogul.com/en-US/Suppliers/Pages/Purchasing-Policies.aspx.

2.    REASONABLE COUNTRY OF ORIGIN INQUIRY

For the period from January 1, 2017 through December 31, 2017, Federal-Mogul conducted a good faith reasonable country of origin inquiry of 3TG that are necessary to the functionality or production of the products that Federal-Mogul manufactured or contracted with others to manufacture during this period. Based on this reasonable country of origin inquiry, Federal-Mogul was unable to conclude that these 3TG did not originate from the Democratic Republic of the Congo (the “DRC”) or adjoining countries (collectively, the “Covered Countries”). Accordingly, Federal-Mogul undertook due diligence measures on the source and chain of custody of the identified necessary 3TG.

3.    DUE DILIGENCE PROCESS
 
Design of Due Diligence

Federal-Mogul's due diligence measures conform, in all material respects, with the 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 and the related Supplements for tin, tantalum, and tungsten and for gold.

Due Diligence Measures Performed

Company Management Systems

Federal-Mogul has adopted a conflict minerals policy, which has been communicated to its suppliers and is publicly available on Federal-Mogul’s website.

Federal-Mogul has implemented an internal management structure to manage and oversee Federal-Mogul’s conflict minerals activities, consisting of a dedicated conflict minerals team and executive-level Conflict Minerals Steering Committee.

The Company participated in several industry-wide initiatives in an effort to develop conflict-free supply chains, including: the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict-Free Sourcing Initiative (CFSI), the Automotive Industry Action Group’s (AIAG) Conflict Minerals Work Group, and the National Association of Manufacturers’ (NAM) Conflict Minerals Task Force. Controls included an integrity policy that outlines the expected behaviors of Federal-Mogul’s employees, the Company’s Code of Conduct and the Company’s Basic Working Conditions for Suppliers policy, which provide expected business practices for suppliers, and the disclosure requirements with respect to conflict minerals in Federal-Mogul’s Restricted Substances Standard and T&Cs.






In addition, the Company has established formal requirements for suppliers related to the use and reporting of 3TG, including the implementation of a supplier conflict minerals solicitation process. Suppliers are required to complete the EICC-GeSI Conflict Minerals Reporting Template (the “CMRT”).

Finally, the Company established grievance mechanisms whereby employees, suppliers and other interested parties can report concerns or violations of Federal-Mogul’s policies. Such concerns or violations can be made via the Federal-Mogul helpline (which is described at http://www.federalmogul.com/en-US/Company/Pages/Integrity-Policy.aspx) or through a specific conflict minerals related e-mail address at conflictminerals@federalmogul.com.

Identify and Assess Risks in Federal-Mogul's Supply Chain

As a downstream user of 3TG, Federal-Mogul is many layers removed from the mine or location from which the 3TG originated and the smelters and refiners which processed the 3TG. The Company solicited relevant suppliers using due diligence tools created by the EICC-GeSI, including the CMRT. Federal-Mogul’s solicitation letter included an explanation of the 3TG and the related legal regulations, a request for suppliers to comply with the regulations and respond to Federal-Mogul, and its contact information to direct any questions. Additional solicitations and follow-ups were sent to suppliers that did not respond or provide sufficient information. During 2017, Federal-Mogul solicited approximately 184 identified “high risk” suppliers.

In addition to comparing the results of the above described supplier-centric approach with Federal-Mogul's internal product-centric approach records, the Company further verified the smelter and refiner and country of origin information provided by Federal-Mogul's suppliers by comparing it to the information contained on the CFSI website. Through this process, for suppliers who provided names of smelters and refiners, the Company confirmed the audit status of those supplier-reported smelters and refiners. For those suppliers who provided country of origin information for the 3TG, Federal-Mogul confirmed the listed countries of origin for each smelter and refiner if that information was available on the CFSI website.

Design and Implement a Strategy to Respond to Identified Risks
 
Federal-Mogul has implemented a risk management plan which includes: requiring suppliers to respond to the CMRT; reviewing and verifying responses from suppliers and following-up on any discrepancies; assigning levels of risk to suppliers based on the results of Federal-Mogul’s product-centric and supplier-centric due diligence approaches; and reviewing any identified smelters against the CFSI smelters list to determine audit status. Federal-Mogul monitors the information received from suppliers in response to Federal-Mogul's solicitations, and regularly shares summaries of this information with its Conflict Minerals Steering Committee. Federal-Mogul is a member of CFSI and uses data from CFSI to confirm the validation status of supplier-reported smelters and refiners, as well as reported country of origin information related to the 3TG sourced from such smelters or refiners, if available.

Support the Development and Implementation of Independent Third-Party Audits of Smelter and Refiner Sourcing

As a downstream user of 3TG, Federal-Mogul and its direct supply chain are layers removed from the mine or location from which the 3TG originated and the smelters and refiners that process the 3TG. Through Federal-Mogul's membership and participation in the CFSI, Federal-Mogul collaborates at a cross-industry level, and continues to support the development and implementation of due diligence practices and tools such as the CMRT.

Report on Supply Chain Due Diligence

Federal-Mogul publicly communicates its conflict minerals policy, due diligence activities and related supplier expectations on its website.

4.    DUE DILIGENCE RESULTS

For products manufactured from January 1, 2017 through December 31, 2017, after completing review of its products under Federal-Mogul’s product-centric approach, Federal-Mogul solicited approximately 163 identified “high risk” suppliers, including direct materials suppliers that started supplying to Federal-Mogul in 2017, to gather detailed information regarding the existence of the 3TG in products sold to Federal-Mogul, as well as the origin and chain of custody of the 3TG, using the CMRT. Of the 184 identified “high risk” suppliers solicited under the Company’s supplier-centric approach, 184 responded with a fully completed CMRT. Based on completed information provided by its suppliers, Federal-Mogul believes the smelters and refiners that may have been used to produce 3TG in Federal-Mogul’s products include those listed on Attachment I. Based on completed information provided by Federal-Mogul's suppliers and information available from the CFSI, Federal-Mogul believes that the countries of origin of 3TG processed by these smelters and refiners include the 35 countries listed on Attachment II.






5.    STEPS TAKEN TO MITIGATE RISK

Federal-Mogul intends to continue to evaluate its due diligence program, and, in particular, intends to annually review the criteria used to select suppliers for solicitation. Federal-Mogul intends to continue to engage with its suppliers to identify the 3TG used within its supply chain, as well as the origin and chain of custody of those 3TG. Federal-Mogul intends to continue to engage with third party programs such as the CFSI, and intends to continue to contact smelters and refiners identified in its supply chain survey process that have not yet received a “conflict free” designation and request their participation in the Conflict-Free Smelter Program or other independent third party audit program in order for them to obtain a “conflict free” designation. Finally, to the extent any Federal-Mogul supplier is found to be using not-yet-validated smelters and refiners within its supply chain, Federal-Mogul intends to engage that supplier and re-communicate its requirement for suppliers to commit to be DRC conflict-free, including, working with the concerned supplier to correct the situation; requesting the supplier to develop a corrective action plan to bring its operations into compliance so that supply to Federal-Mogul can continue; and, if a supplier fails to implement a corrective action plan, moving to terminate the business relationship.







Attachment I
to the Conflict Minerals Report of
Federal-Mogul LLC

SMELTER OR REFINER FACILITIES AS IDENTIFIED BY SUPPLIER CMRT RESPONSES

Mineral
Smelter or Refiner
Country
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 Córrego do Sítio Minerção
BRAZIL
Gold
Argor-Heraeus SA
SWITZERLAND
Gold
Asahi Pretec Corporation
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
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
Daejin Indus Co. Ltd
KOREA
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Geib Refining Corporation
UNITED STATES
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Ltd. Hong Kong
HONG KONG
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery
Share Company Limited
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Company Limited
CHINA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc Ltd
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd
JAPAN
Gold
Korea Zinc Co., Ltd
KOREA





Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
LS-NIKKO Copper Inc.
KOREA
Gold
Materion
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Hong Kong) Ltd
HONG KONG
Gold
Metalor Technologies (Singapore) Pte. Ltd.
SINGAPORE
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies SA
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
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
TURKEY
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd
JAPAN
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
PAMP SA
SWITZERLAND
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Précinox SA
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd
SOUTH AFRICA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
Samduck Precious Metals
KOREA
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
Schone Edelmetaal
NETHERLANDS
Gold
SEMPSA Joyería Platería SA
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN
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
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
Torecom
KOREA
Gold
Umicore Brasil Ltda
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore SA Bus Unit Precious Metals Refining
BELGIUM





Gold
United Precious Metal Refining, Inc.
UNITED STATES
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corp.
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES
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 Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
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
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co. Ltd.
CHINA
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 Nonferrous Metals Smelting Company Limited
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
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
QuantumClean
UNITED STATES
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemicals
JAPAN
Tantalum
Telex Metals
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





Tin
Alpha
UNITED STATES
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
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
Electo-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Tin
EM Vinto
BOLIVIA
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
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
Huichang Jinshunda Tin Co. Ltd
CHINA
Tin
Jiangxi Ketai Advanced Materials 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 Belgium N.V.
BELGIUM
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA
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 DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA





Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Menara Cipta Mulia
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
Resind Indústria e Comércio Ltda
BRAZIL
Tin
Rui Da Hung
TAIWAN
Tin
Soft Metais, Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Ltd.
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Tungsten
Chenzhou Diamond Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan 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 &M. Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Tungsten
H.C.Starck Tungsten GmbH
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 Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES





Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd
VIETNAM
Tungsten
Vietnam Youngsun Tungsten Industry Co. Ltd.
VIETNAM
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Rendan Shaguan Tungsten Co., Ltd.
CHINA








Attachment II
to the Conflict Minerals Report of
Federal-Mogul LLC

COUNTRIES OF ORIGIN OF MINERALS
REPORTED BY SUPPLIER CMRT SMELTERS AND REFINERS

Australia, Austria, Belgium, Bolivia, Brazil, Canada, China, Estonia, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Kyrgyzstan, Malaysia, Mexico, Netherlands, Peru, Philippines, Poland, Russian Federation, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan Thailand, Turkey, United Arab Emirates, United States of America, Uzbekistan, and Vietnam.