Form: SD

Specialized Disclosure Report filed pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of conflict minerals (Rule 13p-1)

May 31, 2016

 

Exhibit 1.01

Conflict Minerals Report of Restoration Hardware Holdings, Inc. in Accordance with Rule 13p-1 under the Securities and Exchange Act of 1934

I.

Introduction

 

1.

Overview of our Conflict Minerals Report

This Conflict Minerals Report of Restoration Hardware Holdings, Inc. (the “Company,” “RH,” “us,” “we”) is prepared in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for the reporting period January 1, 2015 to December 31, 2015 (the “reporting period”).

The Rule requires issuers that manufacture or contract to manufacture products that contain conflict minerals that are necessary to the functionality or production of those products to, among other things, disclose annually whether any of those conflict minerals originated in the Covered Countries and if so, to submit a report to the Securities and Exchange Commission (the “SEC”) that includes a description of the measures they took to exercise due diligence on the conflict minerals’ source and chain of custody. Conflict minerals are defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tantalum, tin, tungsten and gold (the “conflict minerals”).   The “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.  

 

2.

Overview of our Supply Chain, Verification Process and Conflict Minerals Policy

During the reporting period, RH did not own or operate any manufacturing facilities but instead contracted and had relationships with third-party suppliers who manufacture our merchandise. The products that the Company “contracts to manufacture,” as such term is referred to by the Rule, are herein referred to as the “Subject Products.”  The Subject Products are manufactured for the Company through such suppliers’ own factories or factories with which such suppliers have commercial relationships.  The Company must therefore rely on its third-party suppliers to provide information regarding the existence of conflict minerals in the Subject Products and their origin.

The Company relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from the smelters or refiners who may provide those minerals to companies in our supply chain. The Company is many steps removed from the mining of conflict minerals. The Company does not purchase raw or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries.  The statements herein are based on the activities performed to date, in good faith, by the Company and on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions in the information provided by suppliers or smelters, ongoing identification of smelters in our supply chain, and incomplete information from industry or other third-party sources, among others.

We adopted a Conflict Minerals Policy that is published on our supplier cloud platforms and is incorporated in our Vendor’s Operation Manual (the “Vendor Manual”).

II.

Description of Products Covered by this Report

RH offers dominant merchandise assortments across a growing number of categories, including furniture, lighting, textiles, bathware, décor, outdoor and garden, tableware and children’s furnishings. The Subject Products included products sold by the Company in the following categories: furniture, bathware, décor, outdoor and garden, and children’s furnishings.  

III.

Reasonable Country of Origin Inquiry

In accordance with the Rule, we conducted in good faith a reasonable country of origin inquiry (the “RCOI”) that was reasonably designed to determine whether any of the necessary conflict minerals in the Subject Products originated in the Covered Countries or were from recycled or scrap sources.

To conduct our RCOI, we used a conflict minerals reporting template developed by the Conflict-Free Sourcing Initiative (the “CFSI”), an initiative founded by members of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI). We requested this information from our direct suppliers who manufacture our Subject Products.

 


 

Based on our RCOI, we have reason to believe that some of the necessary conflict minerals used in our Subject Products originated in the Covered Countries and may not have been from recycled or scrap sources. Accordingly, we conducted due diligence to determine the source and chain of custody of these conflict minerals.

IV.

Due Diligence Process  

We have designed our diligence efforts to generally conform to the Organization for Economic Cooperation and Development’s (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements (the “OECD Guidance”).

The OECD Guidance identifies five due diligence steps: (i) Establish Strong Company Management Systems; (ii) Identify and Assess Risks in the Supply Chain; (iii) Design and Implement a Strategy to Respond to Identified Risks; (iv) Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence, and; (v) Report Annually on Supply Chain Due Diligence.

The due diligence steps that we executed included the following:

 

Step

 

OECD Guidance Steps

 

 

 

Due diligence activities performed by RH

 

 

 

 

 

 

 

1

 

Establish Strong Company Management Systems

 

Adopted Conflict Minerals Policy

 

·    We adopted a Conflict Minerals Policy that is published on our supplier cloud platforms and is incorporated in our Vendor Manual

 

 

 

 

 

 

 

 

 

 

 

Created Conflict Minerals Compliance Team

 

·    We created an internal conflict minerals compliance team composed of representatives from sourcing, internal audit and legal departments (the “Conflict Minerals Compliance Team”). The team was structured to ensure critical information reached the relevant employees and suppliers

·    Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the RH executive team, the compliance committee and/or the audit committee

 

 

 

 

 

 

 

 

 

 

 

Internal Engagement

 

·    We educated and continue educating relevant employees on our conflict minerals program and reporting obligations

 

 

 

 

 

 

 

 

 

 

 

Supplier Engagement

 

·    We provided our direct suppliers information on conflict minerals, our disclosure requirements as well as recommendations for developing and implementing a conflict minerals compliance program

 

 

 

 

 

 

 

2

 

Identify and Assess Risks in the Supply Chain

 

Identified  Products in Scope

 

·    Our Conflict Minerals Compliance Team conducted a review of the products contracted to be manufactured during the reporting period to identify product categories and Subject Products that may contain conflict minerals

 

 

 

 

 

 

 

 


 

 

 

 

 

Inquired about Due Diligence Measures Performed by Direct Suppliers

 

·    We used the responses from our direct suppliers to the CFSI reporting template to review their due diligence activities, including whether they had adopted a conflict minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management

·    We analyzed the completed responses received from our direct suppliers to identify incomplete responses, potential errors and/or inaccuracies. As deemed appropriate by us, we followed up by email or phone with the suppliers who did not respond to our request to

complete the CFSI reporting template, or who submitted incomplete responses or responses that we determined may have contained errors or inaccuracies

·    We implemented a conflict minerals data management tool that tracks end-to-end communication with direct suppliers and consolidates suppliers responses to the CFSI template for analysis and reporting

 

 

 

 

 

 

 

 

 

 

 

Identified Smelters

 

·    We collected a list of smelters/processors that are in our supply chain by utilizing the CFSI reporting template.   We determined if the processing facilities adhere to responsible sourcing practices by reconciling that list to the list of smelter facilities designated by the CFSI Conflict-Free Smelter Program and the CFSI list of Active Smelters & Refiners that have committed to undergo the Conflict-Free Smelter Program audit. We have provided lists of smelters/processors that are reported in our supply chain in Appendix A.

 

 

 

 

 

 

 

3

 

Design and Implement a Strategy to Respond to Identified Risks

 

Designed Internal Reporting System

 

·    Our Conflict Minerals Compliance Team periodically reported on its due diligence activities to the RH executive team, the compliance committee and/or the audit committee

 

 

 

 

 

 

 

 

 

 

 

Adopted Conflict Minerals Policy

 

·    We adopted a Conflict Minerals Policy that is published on our supplier cloud platforms and is incorporated in our Vendor Manual

 

 

 

 

 

 

 

 

 

 

 

Verified Smelters

 

·    As part of our risk mitigation process, we determined if the processing facilities identified in our supply chain adhere to responsible sourcing practices by reconciling the list of smelters collected from our direct suppliers to the list of smelter facilities that have been verified as complying with the CFSI Conflict-Free Smelter Program and the CFSI list of Active Smelters & Refiners that have committed to undergo the Conflict-Free Smelter Program audit

 

 

 

 

 

 

 

4

 

Carry out Independent Third-Party Audit of Smelter/Refiner’s Due Diligence

 

 

 

·    We relied on the CFSI’s published lists to verify the CFSI Conflict-Free Smelter Program compliance status of smelters/processors that are reported in our supply chain

 

 

 

 

 

 

 

5

 

Report Annually on Supply Chain Due Diligence

 

 

 

·    This Conflict Minerals Report is filed with the SEC and publicly available on our website at ir.restorationhardware.com, by clicking on “SEC Filings”

 

V.

Review of Due Diligence Results

 

1.

Facilities Used to Process Conflict Minerals in Subject Products

Based on our due diligence process and the information received from our direct suppliers, we have identified, in Appendix A, facilities that may have been used to process conflict minerals used in the Subject Products.

 

2.

Country of Origin of Conflict Minerals in Subject Products

Based on the information provided by our direct suppliers, we have reason to believe that some of our necessary conflict minerals may have originated from the Covered Countries. One of our direct suppliers indicated that it purchases tin from a smelter that is compliant with CFSI’s Conflict-Free Smelter Program (“CFSP”), which smelter in turn sources a portion of its tin from the Covered Countries.  In addition, one direct supplier indicated that the county of origin of the conflict minerals it used was “unknown”,

 


 

and two suppliers failed to respond to requests from us.  Accordingly, notwithstanding our due diligence efforts, we were unable to determine the origin of a portion of conflict minerals contained in certain of the Subject Products.

 

3.

Efforts to Identify the Mine or Location of Origin of the Conflict Minerals

Our reasonable country-of-origin inquiry and due diligence process described above represent our best efforts to identify the mine or location of origin for the conflict minerals contained in the Subject Products for this reporting period. We also reviewed publicly available information, including information made publicly available by or through CFSI, to try to identify the mine or location of origin.

VI.

Steps To Be Taken To Mitigate Risk

RH intends to continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of conflict minerals will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. We expect that our direct suppliers will comply with our Conflict Minerals Policy and partner with us to (i) provide appropriate information and conduct necessary due diligence to facilitate our compliance with the Rule, (ii) implement and communicate to their relevant personnel and suppliers policies that are consistent with the Policy, (iii) put in place procedures and contractual provisions for the traceability of Conflict Minerals, working with their suppliers as applicable, (iv) use reasonable efforts to source conflict minerals from smelters and refiners that have been validated by a recognized, independent third party as DRC conflict free, and (v) adopt a risk management strategy with respect to identified risks in the supply chain that is consistent with our Conflict Minerals Policy.

In addition to the due diligence steps that we took during the reporting period, which we intend to continue to take in 2016 to the extent applicable, we intend to (i) engage with our suppliers that provided incomplete responses or failed to respond to requests, to ensure that they provide requested information for 2016, (ii) monitor the progress of traceability measures at suppliers that indicated for this reporting period that the source of conflict minerals was unknown or undeterminable; and (iii) communicate to new suppliers our sourcing expectations, including by disseminating our Conflict Minerals Policy to them.

VII.

Independent Private Sector Audit

Not required for the reporting period.

Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements within the meaning of the federal securities laws including statements related to our business, products and conflict mineral efforts, including steps we intend to take in the future to mitigate the risk that the conflict minerals used in the Subject Products benefit the armed groups on the Covered Countries.  You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. These statements may include words such as “anticipate,” “estimate,” “expect,” “project,” “plan,” “intend,” “believe,” “may,” “will,” “should,” “likely” and other words and terms of similar meaning in connection with any discussion of the timing or nature of future events. We cannot assure you that future developments affecting us will be those that we have anticipated. Important risks and uncertainties that may cause these forward-looking statements to differ materially from our expectations include, among others: failure to carry out our plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers; lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities); internal and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States, as well as those risks and uncertainties disclosed under the sections entitled “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in Restoration Hardware Holdings’ Form 10-K filed with the SEC on March 30, 2016, and similar disclosures in subsequent reports filed with the SEC, which are available on our investor relations website at ir.restorationhardware.com and on the SEC website at www.sec.gov. Any forward-looking statement made by us in this Conflict Minerals Report speaks only as of the date on which we make it. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information, future developments or otherwise, except as may be required by any applicable securities laws.

 

 

 

 


 

Appendix A

Processing Facilities

Table 1. CFSP-compliant processing facilities as listed by CFSI as of May 27, 2016

Processing facilities and their locations reported in our supply chain that are reported by CFSI as compliant with the CFSI Conflict-Free Smelter Program.

 

Mineral

Facility ID

Processing Facility Name

Country

Tin

CID000292

Alpha United States

UNITED STATES

Tin

CID001070

China Tin Group Co Ltd.

CHINA

Tin

CID000306

CV Gita Pesona

INDONESIA

Tin

CID000313

CV Serumpun Sebalai

INDONESIA

Tin

CID000315

CV United Smelting

INDONESIA

Tin

CID000402

Dowa Japan

JAPAN

Tin

CID000438

EM Vinto (1)

BOLIVIA

Tin

CID000468

Fenix Metals

POLAND

Tin

CID000538

Gejiu Non Ferrous Metal Processing Co Ltd  

CHINA

Tin

CID000244

Jiangxi Ketai Advanced Material Co Ltd

CHINA

Tin

CID002468

Magnu s Minerais Metais e Ligas LTDA

BRAZIL

Tin

CID001105

Malaysia Smelting Corporation (MSC) (1)

MALAYSIA

Tin

CID002500

Melt Metais e Ligas LTDA

BRAZIL

Tin

CID002773

Metallo Chimique N V

BELGIUM

Tin

CID001173

Mineracao Taboca S A

BRAZIL

Tin

CID001182

Minsur Peru

PERU

Tin

CID002517

O M Manufacturing Philippines Inc. (1)

PHILIPPINES

Tin

CID001314

O M Manufacturing Thailand Co. Ltd. (1)

THAILAND

Tin

CID000309

PT Aries Kencana Sejahtera

INDONESIA

Tin

CID001399

PT Artha Cipta Langgeng

INDONESIA

Tin

CID001402

PT Babel Inti Perkasa

INDONESIA

Tin

CID001419

PT Bangka Tin Industry

INDONESIA

Tin

CID001421

PT Belitung Industri Sejahtera (1)

INDONESIA

Tin

CID001424

PT Billi Tin Makmur Lestari

INDONESIA

Tin

CID001428

PT Bukit Timah

INDONESIA

Tin

CID001434

PT DS Jaya Abadi

INDONESIA

Tin

CID001438

PT Eunindo Usaha Mandiri

INDONESIA

Tin

CID002530

PT Inti Stania Prima

INDONESIA

Tin

CID000307

PT Justindo

INDONESIA

Tin

CID001453

PT Mitra Stania Prima (1)

INDONESIA

Tin

CID001457

PT Panca Mega Persada

INDONESIA

Tin

CID001458

PT Prima Timah Utama

INDONESIA

Tin

CID001460

PT Refined Bangka Tin

INDONESIA

Tin

CID001463

PT Sariwiguna Binasentosa

INDONESIA

Tin

CID001468

PT Stanindo Inti Perkasa

INDONESIA

Tin

CID001471

PT Sumber Jaya Indah  

INDONESIA

Tin

CID001482

PT Timah Persero Tbk

INDONESIA

Tin

CID001490

PT Tinindo Inter Nusa

INDONESIA

Tin

CID002479

PT Wahana Perkit Jaya  

INDONESIA

Tin

CID001539

Rui Da Hung Taiwan

TAIWAN

Tin

CID001758

Soft Metais Ltda.

BRAZIL

Tin

CID001898

Thaisarco

THAILAND

Tin

CID002015

VQB Mineral and Trading Group JSC  

VIET NAM

Tin

CID002180

Yunnan Tin Company Ltd China (1)

CHINA

Gold

CID001622

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Gold

CID000019

Aida Chemical Industries Co., Ltd.

JAPAN

Gold

CID000035

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

 


 

Mineral

Facility ID

Processing Facility Name

Country

Gold

CID000058

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

Gold

CID000077

Argor-Heraeus SA

SWITZERLAND

Gold

CID000082

Asahi Pretec Corporation

JAPAN

Gold

CID000924

Asahi Refining Canada Ltd.

CANADA

Gold

CID000920

Asahi Refining USA Inc.

UNITED STATES

Gold

CID000090

Asaka Riken Co., Ltd.

JAPAN

Gold

CID000113

Aurubis AG

GERMANY

Gold

CID000128

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Gold

CID000157

Boliden AB

SWEDEN

Gold

CID000176

C. Hafner GmbH + Co. KG

GERMANY

Gold

CID000233

Chimet S.p.A.

ITALY

Gold

CID000401

Dowa

JAPAN

Gold

CID000425

Eco-System Recycling Co., Ltd.

JAPAN

Gold

CID000493

FSE Novosibirsk Refinery

RUSSIAN FEDERATION

Gold

CID000694

Heimerle + Meule GmbH

GERMANY

Gold

CID000707

Heraeus Ltd. Hong Kong

CHINA

Gold

CID000711

Heraeus Precious Metals GmbH & Co. KG

GERMANY

Gold

CID000801

Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited(1)

CHINA

Gold

CID000807

Ishifuku Metal Industry Co., Ltd.

JAPAN

Gold

CID000814

Istanbul Gold Refinery

TURKEY

Gold

CID000823

Japan Mint

JAPAN

Gold

CID000855

Jiangxi Copper Company Limited(1)

CHINA

Gold

CID000927

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Gold

CID000929

JSC Uralelectromed

RUSSIAN FEDERATION

Gold

CID000937

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Gold

CID000957

Kazzinc

KAZAKHSTAN

Gold

CID000969

Kennecott Utah Copper LLC

UNITED STATES

Gold

CID000981

Kojima Chemicals Co., Ltd.

JAPAN

Gold

CID001078

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

Gold

CID001113

Materion

UNITED STATES

Gold

CID001119

Matsuda Sangyo Co., Ltd.

JAPAN

Gold

CID001153

Metalor Switzerland

SWITZERLAND

Gold

CID001149

Metalor Technologies (Hong Kong) Ltd.

CHINA

Gold

CID001152

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Gold

CID001157

Metalor USA Refining Corporation

UNITED STATES

Gold

CID001161

Met-Mex Penoles, S.A.

MEXICO

Gold

CID001188

Mitsubishi Materials Corporation

JAPAN

Gold

CID001193

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Gold

CID001204

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Gold

CID001220

Nadir Metal Rafineri San. Ve Tic. A.Ş.

Turkey

Gold

CID001259

Nihon Material Co., Ltd.

JAPAN

Gold

CID001322

Ohio Precious Metals, LLC

UNITED STATES

Gold

CID001325

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Gold

CID001352

PAMP SA

SWITZERLAND

Gold

CID001386

Prioksky Plant of Non-Ferrous Metals (1)

RUSSIAN FEDERATION

Gold

CID001397

PT Aneka Tambang (Persero) Tbk

INDONESIA

Gold

CID001498

PX Précinox SA

SWITZERLAND

Gold

CID001512

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Gold

CID001534

Royal Canadian Mint

CANADA

Gold

CID001573

Schone Edelmetaal B.V.

NETHERLANDS

Gold

CID001585

Sempsa JP (Cookson Sempsa)

SPAIN

Gold

CID001622

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Gold

CID001756

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Gold

CID001761

Solar Applied Materials Technology Corp.

TAIWAN

Gold

CID001798

Sumitomo Metal Mining Co., Ltd.

JAPAN

 


 

Mineral

Facility ID

Processing Facility Name

Country

Gold

CID001875

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Gold

CID001916

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

Gold

CID001938

Tokuriki Honten Co., Ltd.

JAPAN

Gold

CID001977

Umicore Brasil Ltda.

BRAZIL

Gold

CID002314

Umicore Precious Metals Thailand

THAILAND

Gold

CID001980

Umicore SA Business Unit Precious Metals Refining

BELGIUM

Gold

CID001993

United Precious Metal Refining, Inc. (1)

UNITED STATES

Gold

CID002003

Valcambi SA

SWITZERLAND

Gold

CID002030

Western Australian Mint trading as The Perth Mint

AUSTRALIA

Gold

CID002100

Yamamoto Precious Metal Co., Ltd. (1)

JAPAN

Gold

CID002129

Yokohama Metal Co., Ltd.

JAPAN

Gold

CID002224

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Gold

CID002243

Zijin Mining Group Co., Ltd. Gold Refinery

CHINA

Tantalum

CID000211

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Tantalum

CID000291

Conghua Tantalum and Niobium Smeltry

CHINA

Tantalum

CID002504

D Block Metals, LLC

UNITED STATES

Tantalum

CID000410

Duoluoshan (1)

CHINA

Tantalum

CID000456

Exotech Inc.

UNITED STATES

Tantalum

CID000460

F&X Electro-Materials Ltd.

CHINA

Tantalum

CID002558

Global Advanced Metals Aizu

JAPAN

Tantalum

CID002557

Global Advanced Metals Boyertown

UNITED STATES

Tantalum

CID000616

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

Tantalum

CID002544

H.C. Starck Co., Ltd.

THAILAND

Tantalum

CID002545

H.C. Starck GmbH Goslar

GERMANY

Tantalum

CID002546

H.C. Starck GmbH Laufenburg

GERMANY

Tantalum

CID002547

H.C. Starck Hermsdorf GmbH

GERMANY

Tantalum

CID002548

H.C. Starck Inc.

UNITED STATES

Tantalum

CID002549

H.C. Starck Ltd.

JAPAN

Tantalum

CID002550

H.C. Starck Smelting GmbH & Co.KG

GERMANY

Tantalum

CID002492

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Tantalum

CID000731

Hi-Temp

UNITED STATES

Tantalum

CID000914

JiuJiang JinXin Nonferrous Metals Co., Ltd. (1)

CHINA

Tantalum

CID000917

Jiujiang Tanbre Co., Ltd.

CHINA

Tantalum

CID002539

KEMET Blue Metals

MEXICO

Tantalum

CID002568

KEMET Blue Powder

UNITED STATES

Tantalum

CID000973

King-Tan Tantalum Industry Ltd.

CHINA

Tantalum

CID001076

LSM Brasil S.A.

BRAZIL

Tantalum

CID001163

Metallurgical Products India Pvt., Ltd.

INDIA

Tantalum

CID001175

Mineração Taboca S.A.

BRAZIL

Tantalum

CID001192

Mitsui Mining & Smelting

JAPAN

Tantalum

CID001200

Molycorp Silmet A.S.

ESTONIA

Tantalum

CID001277

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Tantalum

CID002540

Plansee SE Liezen

AUSTRIA

Tantalum

CID002556

Plansee SE Reutte

AUSTRIA

Tantalum

CID001508

QuantumClean

UNITED STATES

Tantalum

CID001522

RFH

CHINA

Tantalum

CID001769

Solikamsk Metal Works

RUSSIAN FEDERATION

Tantalum

CID001869

Taki Chemicals

JAPAN

Tantalum

CID001891

Telex Metals

UNITED STATES

Tantalum

CID001969

Ulba

KAZAKHSTAN

Tantalum

CID002307

Yichun Jin Yang Rare Metal Co., Ltd.

CHINA

Tantalum

CID002232

Zhuzhou Cemented Carbide

CHINA

Tungsten

CID000004

A.L.M.T. TUNGSTEN Corp.

JAPAN

Tungsten

CID002513

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Tungsten

CID000258

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Tungsten

CID000499

Fujian Jinxin Tungsten Co., Ltd.

CHINA

 


 

Mineral

Facility ID

Processing Facility Name

Country

Tungsten

CID000875

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Tungsten

CID002315

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Tungsten

CID002494

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Tungsten

CID000568

Global Tungsten & Powders Corp.

UNITED STATES

Tungsten

CID000218

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Tungsten

CID002541

H.C. Starck GmbH

GERMANY

Tungsten

CID002542

H.C. Starck Smelting GmbH & Co.KG

GERMANY

Tungsten

CID000766

Hunan Chenzhou Mining Group Co., Ltd.

CHINA

Tungsten

CID000769

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Tungsten

CID000825

Japan New Metals Co., Ltd.

JAPAN

Tungsten

CID002321

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

Tungsten

CID000105

Kennametal Huntsville

UNITED STATES

Tungsten

CID002319

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Tungsten

CID002543

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

Tungsten

CID001889

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Tungsten

CID002011

Vietnam Youngsun Tungsten Industry Co., Ltd.

VIET NAM

Tungsten

CID002044

Wolfram Bergbau und Hütten AG

AUSTRIA

Tungsten

CID002320

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

Tungsten

CID002082

Xiamen Tungsten Co., Ltd.

CHINA

Tungsten

CID002095

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

 

(1) Re-audit in progress; smelters and refiners with a “re-audit in progress” are still considered to be CFSP-compliant.

Table 2. CFSP-participating processing facilities as listed by CFSI as of May 27, 2016

Processing facilities and their locations reported in our supply chain that are reported by CFSI to have agreed to participate in the CFSI Conflict-Free Smelter Program but have not yet completed the program.

 

Mineral

Facility ID

Processing Facility Name

Country

Tin

CID000942

Gejiu Kai Meng Industry and Trade LLC China 2CHN053 CID000942

CHINA

Tin

CID002158

Yunnan Chengfeng Non ferrous Metals Co Ltd China 2CHN047 CID002158

CHINA

Gold

CID000015

Advanced Chemical Company

UNITED STATES

Gold

CID000041

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Gold

CID000189

Cendres + Métaux SA

SWITZERLAND

Gold

CID000328

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

Gold

CID001236

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Gold

CID001555

Samduck Precious Metals

KOREA, REPUBLIC OF

Gold

CID001955

Torecom

KOREA, REPUBLIC OF

Tungsten

CID002318

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

Tungsten

CID002317

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Tungsten

CID002316

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Tungsten

CID000966

Kennametal Fallon

UNITED STATES

 

Table 3. CFSP-non-participating processing facilities as of May 27, 2016

Processing facilities and their locations reported in our supply chain that are not reported as either compliant with or participating in the CFSI Conflict-Free Smelter Program.

 

Mineral

Facility ID

Processing Facility Name

Country

Gold

CID000103

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

Gold

CID000141

Bauer Walser AG

GERMANY

Gold

CID000180

Caridad

MEXICO

Gold

CID000264

Chugai Mining

JAPAN

Gold

CID000343

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Gold

CID000522

Gansu Seemine Material Hi-Tech Co., Ltd.

CHINA

 


 

Mineral

Facility ID

Processing Facility Name

Country

Gold

CID002312

Guangdong Jinding Gold Limited

CHINA

Gold

CID000767

Hunan Chenzhou Mining Industry Co. Ltd.

CHINA

Gold

CID000778

Hwasung CJ Co., Ltd.

KOREA, REPUBLIC OF

Gold

CID000988

Korea Metal Co., Ltd.

KOREA, REPUBLIC OF

Gold

CID001029

Kyrgyzaltyn JSC

KYRGYZSTAN

Gold

CID001032

L' azurde Company For Jewelry

SAUDI ARABIA

Gold

CID001056

Lingbao Gold Company Limited

CHINA

Gold

CID001058

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

Gold

CID001093

Luoyang Zijin Yinhui Metal Smelt Co Ltd

CHINA

Gold

CID001328

OJSC Kolyma Refinery

RUSSIAN FEDERATION

Gold

CID001362

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Gold

CID001546

Sabin Metal Corp.

UNITED STATES

Gold

CID001562

SAMWON Metals Corp.

KOREA, REPUBLIC OF

Gold

CID001754

So Accurate Group, Inc.

UNITED STATES

Gold

CID001947

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Gold

CID000197

Yunnan Copper Industry Co., Ltd.

CHINA

Tantalum

CID002501

Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch

CHINA

Tungsten

CID000345

Dayu Weiliang Tungsten Co., Ltd.

CHINA

Tungsten

CID000868

Ganzhou Non-ferrous Metals Smelting Co., Ltd.

CHINA

Tungsten

CID002313

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA