EX-1.01
Published on May 26, 2016
Exhibit 1.01
Conflict Minerals Report
Becton, Dickinson and Company has included this Conflict Minerals Report as an exhibit to its Form SD for 2015, as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the Conflict Minerals Rule). The date of filing of this Conflict Minerals Report is May 26, 2016.
Unless the context indicates otherwise, the term BD, we, us and our refer to Becton, Dickinson and Company and its consolidated subsidiaries for 2015. As used herein and consistent with the Conflict Minerals Rule, Conflict Minerals or 3TG are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin, and tungsten, without regard to the location of origin of the minerals or derivative metals. The Conflict Affected Region is defined as the Democratic Republic of the Congo and its adjacent countries, which include Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
Overview
BD is a global medical technology company that is advancing the world of health by improving medical discovery, diagnostics and the delivery of care. BD leads in patient and health care worker safety and the technologies that enable medical research and clinical laboratories. We provide innovative solutions that help advance cellular studies and genomics, enhance the diagnosis of infectious disease and cancer, improve medication management, promote infection prevention, equip surgical and interventional procedures, optimize respiratory care and support the management of diabetes. In 2015, BD acquired CareFusion Corporation (CareFusion). CareFusion is included in our 3TG compliance and reflected in the Conflict Minerals Report for this reporting period.
BD is subject to the Conflict Minerals Rule because, for 2015, certain of the raw materials and components contained in some of the products that we manufactured or contracted to manufacture contained 3TG that were necessary to the functionality or production of the products. Many of our products do not contain any 3TG or are otherwise not in-scope for purposes of our Conflict Minerals Rule compliance.
We do not directly source 3TG from mines, smelters, or refiners, and we believe that we are many levels removed from these market participants and, therefore, have limited influence over their behavior. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below.
Our Conflict Minerals Policy
BD expects its suppliers and subcontractors to source responsibly, respect human rights, and not contribute to conflict.
Without limiting the foregoing, BD expects that its suppliers and subcontractors will not knowingly source 3TG from sources that directly or indirectly finance or benefit armed groups in the Conflict Affected Region. In furtherance of this expectation and BDs obligations under the Conflict Minerals Rule, applicable BD suppliers and subcontractors (as defined by BD) will be expected to complete a declaration concerning the usage and source of any 3TG in the products supplied to us. As part of gathering the information for the declaration, applicable BD suppliers and subcontractors will be expected to conduct a reasonable country of origin inquiry and/or due diligence, as applicable, in accordance with the Conflict Minerals Rule and the Organisation for Economic Co-operation and Developments Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the OECD Guidance).
In cases where suppliers or subcontractors are found to not be in compliance with our policy, we intend to work with and encourage them to source responsibly. Where these efforts fail or we believe that further engagement with a supplier or subcontractor is inappropriate, we will re-evaluate our business relationship.
We discourage the embargoing of 3TG from the Conflict Affected Regions and advocate the responsible sourcing of 3TG from the region.
Reasonable Country of Origin Inquiry; Smelter and Refiner and Country of Origin Information
As required by the Conflict Minerals Rule, for 2015, we conducted a reasonable country of origin inquiry. Our outreach included 2501 suppliers (the Suppliers) that we identified through our internal scoping process as having provided, or that we believe may have provided, us with raw materials or components that contain Conflict Minerals. The number of suppliers included in our outreach increased by approximately 37% compared to 2014, due to our acquisition of CareFusion. Suppliers representing 80% of our spend responded to our reasonable country of origin inquiry.
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For 2015, our Suppliers identified to us the smelters and refiners described in the table below, sorted by mineral and risk level, as potentially having processed the necessary 3TG contained in our in-scope products. The names of the identified smelters and refiners are listed on Annex 1. We were able to determine the origin of only a portion (if any) of the necessary Conflict Minerals contained in each of our in-scope products.
Covered Country Sourced | Non Covered Country Sourced | 100% recycled or scrap |
Source Country Unknown |
Total Smelters |
||||||||||||||||||||||||||||||||||||||||
CFSP Compliant1 |
CFSP Active |
Known | Total | CFSP Compliant |
CFSP Active |
Known | Total | |||||||||||||||||||||||||||||||||||||
Tantalum |
30 | 30 | 16 | 16 | 1 | 47 | ||||||||||||||||||||||||||||||||||||||
Tin |
5 | 1 | 6 | 54 | 5 | 4 | 63 | 4 | 12 | 85 | ||||||||||||||||||||||||||||||||||
Gold |
0 | 80 | 8 | 19 | 107 | 9 | 14 | 130 | ||||||||||||||||||||||||||||||||||||
Tungsten |
5 | 5 | 25 | 11 | 2 | 38 | 2 | 45 | ||||||||||||||||||||||||||||||||||||
Total |
40 | 1 | 0 | 41 | 175 | 24 | 25 | 224 | 13 | 29 | 307 |
Pursuant to the Conflict Minerals Rule, based on the results of our reasonable country of origin inquiry, we were required to conduct due diligence for 2015. These due diligence efforts are discussed later in this Conflict Minerals Report.
Conclusion Statement
Based on our due diligence, none of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the Conflict Affected Region. However, we were unable to conclude that any of our products were DRC conflict free. The terms armed group and DRC conflict free have the meanings contained in the Conflict Minerals Rule.
Due Diligence Program Design
Design Framework
Our due diligence measures relating to 3TG were designed to conform with the criteria set forth in the OECD Guidance, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013).
Selected Elements of Design Framework
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the elements of the program that we have designed to ensure that the 3TG contained in our products are responsibly sourced. Selected due diligence measures that we took in respect of 2015 are discussed under Due Diligence Program Execution.
Conflict Minerals Policy
We have adopted a Conflict Minerals Policy, as described in this Conflict Minerals Report. The Conflict Minerals Policy is posted on our website and distributed to selected employees and suppliers.
Conflict Minerals Team
We have a centralized Conflict Minerals Team (the Core Team) to provide cross-functional oversight for the BD Conflict Minerals Program. The Core Team is comprised of representatives from Global Procurement, the Office of Global Sustainability, and all BD business units. The Core Team is led by a Program Leader with support and oversight from the Director, Global Product Stewardship, the executive leader of the program. Executive leadership of the program resides with Global Sustainability.
1 | See Annex for definitions. |
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We also have a Conflict Minerals Steering Team (the Steering Team) responsible for overseeing the compliance activity while engaging with functional leadership around progress, reviewing and approving internal and external policy language, and collaborating with necessary third-party resources. The Steering Team consists of the Program Leader, Executive Leader, and representatives from Internal Audit, the Law Group, Corporate Quality, and Global Procurement.
Our compliance efforts are supplemented by specialist outside counsel.
Internal and External Communication of BDs Conflict Minerals Program and Training
We communicate to other relevant BD associates our commitment to comply with the Conflict Minerals Rule in writing and through in-person training sessions, and other live communications. In addition, the Core Team, the Steering Team, and other relevant BD associates are educated on the Conflict Minerals Rule and our compliance program.
We provide applicable suppliers and subcontractors with information on the Conflict Minerals Rule and BDs commitment to compliance with the Rule. BD communicates with suppliers in writing, through in-person meetings, and other live communications.
Participation in and Support of Multi-Stakeholder Initiatives
We are a member of the CFSI. BD participates on the Smelter Engagement and Due Diligence CFSI teams. In addition, the BD Conflict Minerals Program Leader, served on the CFSI Steering Team from August 2015 through December 2015. BD is also a member of Responsible Sourcing Networks Multi-Stakeholder Network.
Data Storage and Retention
BD utilizes an internal database for the maintenance of business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions. These records are maintained for 5 years.
Contractual Compliance Requirements
BDs Expectations for Suppliers, which contains our supplier compliance requirements relating to many different subject areas, includes compliance requirements relating to 3TG. BDs US purchase orders include language requiring suppliers to provide information to BD to support BDs compliance efforts under the US Dodd Frank Act Conflict Minerals Rule.
Grievance Mechanism
We have a grievance mechanism for employees, suppliers and other interested parties to report alleged violations of our Conflict Minerals Policy. We publicly communicate our grievance mechanism. Any grievances received are communicated to the Program Leader and Steering Team. BD associates, suppliers, and other interested parties can report actions inconsistent with the Expectations for Suppliers through BDs Global Ethics Help Line, the number of which is 1-800-821-5452. Under our internal procedures, all such calls will be investigated.
Collection, Assessment, and Internal Reporting of Supply Chain Information
Suppliers that we determine to be in-scope or potentially in-scope are requested to complete a Conflict Minerals Reporting Template, which contains questions on the inclusion and source of 3TG in the materials they supplied to us and their compliance activities. If a supplier does not respond to our request within a reasonable time frame, or the supplier refuses to respond, this information is forwarded to Global Procurement as part of an escalation process.
Upon receipt of a Conflict Minerals Reporting Template from a supplier, the response is processed through our Supplier Response Analysis process. This process includes reviewing the suppliers responses against a series of identified red flags. Additionally, we review submitted Conflict Minerals Reporting Templates for certain errors and inaccuracies and follow up with these suppliers as well.
Smelter and refiner information provided by suppliers is reviewed against the Smelter Reference List tab of the Conflict Minerals Reporting Template, the list of known processing facilities on the Commerce Department List, and the verified smelters identified by Apple and Intel. To the extent that a smelter or refiner identified by a supplier is not on any of these lists, we take additional steps to attempt to determine whether the listed entity is a smelter or refiner.
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Smelter and refiner information is also reviewed against the lists of compliant and active smelters and refiners and country of origin information published by the CFSI, the Responsible Jewellery Council (the RJC), and the London Bullion Market Association (the LBMA). To the extent that a smelter or refiner identified by a supplier is not listed as compliant by the CFSI, RJC, or LBMA; we consult publicly available information to attempt to determine whether the smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Conflict Affected Region.
Based on the information furnished by suppliers and other information known to us, we assess the risk of adverse impact. The Steering Team reports the findings of its supply chain risk assessment to our Compliance and Ethics Committee on a regular basis.
We determine on a case-by-case basis the appropriate mitigation strategy for any identified non-compliance with our Conflict Minerals Policy and other supplier requirements and expectations relating to our 3TG compliance program. Potential outcomes under our mitigation strategy include continuing to work with the supplier while non-compliances are addressed, or suspending or terminating the relationship with the supplier. Under our mitigation strategy, to the extent that areas of non-compliance that require mitigation are identified, we monitor and track the performance of the mitigation efforts and report back to appropriate senior oversight personnel. Under our procedures, we also will undertake additional fact and risk assessments, as determined by the Steering Team, for non-compliances that require mitigation or after a change of circumstances.
Carry out Independent Third-party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
In connection with our due diligence, we utilize information made available by the CFSI concerning independent third-party audits of smelters and refiners. We are a member of the CFSI.
Report on Supply Chain Due Diligence
We file a Form SD, and to the extent applicable a Conflict Minerals Report, with the Securities and Exchange Commission and make these documents available on our website.
Due Diligence Program Execution
We performed the following due diligence measures in respect of the 2015 compliance period. These are not all of the measures that we took in respect of 2015 in furtherance of our Conflict Minerals Policy and Conflict Minerals compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, please see Due Diligence Program Design.
1. | We sent requests to 2501 Suppliers to provide us with a completed Conflict Minerals Reporting Template. We followed up by email or phone with the Suppliers that did not provide a response within the specified time frame. |
2. | We reviewed the completed responses received from the Suppliers based on our red flags review criteria and for errors and inaccuracies. |
3. | We reviewed the smelters and refiners identified to us by the Suppliers against those contained on the Smelter Reference List tab of the Conflict Minerals Reporting Template, the Commerce Department List, and the verified smelters identified by Apple and Intel. To the extent that a completed response identified a smelter or refiner not on that list, we (a) requested that the Supplier confirm that the listed entity is a smelter or refiner or (b) consulted publicly available information to attempt to determine whether the identified entity is a smelter or refiner. |
4. | To the extent that a completed response identified a smelter or refiner, we also reviewed that information against the list of compliant and active smelters and refiners published by the CFSI, LBMA, and RJC as of May 16, 2016. See Reasonable Country of Origin Inquiry: Smelter and Refiner and Country of Origin Information and Annex 1 for further information on the smelters and refiners identified by the Suppliers. |
5. | To the extent that a smelter or refiner identified by a Supplier was not listed as compliant by the CFSI, LBMA, or RJC, we consulted publicly available information to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Conflict Affected Region. |
6. | The Steering Team reported the findings of its supply chain assessment to our Compliance and Ethics Committee. |
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7. | In addition, to mitigate the risk that the necessary 3TG contained in our in-scope products directly or indirectly finance or benefit armed groups in the Conflict Affected Region, we: |
a. | Adopted a requirement that business records relating to 3TG due diligence, including records of due diligence processes, findings, and resulting decisions, be maintained for 5 years. |
b. | Implemented enhancements to our red flags process. |
c. | Participated on the CFSIs Smelter Engagement and Due Diligence teams, our Conflict Minerals Program Leader served on the CFSI Steering Team, and we became a member of the Responsible Sourcing Networks Multi-stakeholder Group. |
Product Information
Our in-scope products for 2015 included a broad range of electrical or electronic medical devices, laboratory equipment and diagnostic products we manufacture or contract to be manufactured. Not all of our products in each of these categories were in-scope for purposes of our compliance, i.e. not all of our products contain necessary 3TG or were manufactured or contracted to be manufactured by us.
Due to the challenges of tracing a multi-tier supply chain, for 2015, we were unable to determine at least a portion of the smelters and refiners, and countries of origin, of the necessary 3TG contained in each of our in-scope products. Identified smelters and refiners and country of origin information are described under Smelter and Refiner Information.
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Additional Mitigation Efforts
In respect of 2016, we have taken or intend to take the following additional steps to mitigate the risk that the necessary 3TG contained in our in-scope products finance or benefit armed groups:
1. | Monitor and encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2015 that the source of Conflict Minerals was unknown or undeterminable. |
2. | Implement Purchase Order Terms and Conditions changes relating to 3TG in the remaining regions for which implementation has not been completed. |
3. | We made a donation for the average cost of an audit to the CFSI Initial Audit Fund in the spring of 2016. |
4. | We are continuing to refine our in scope commodity categories to focus our efforts on the highest risk areas. |
The foregoing steps are in addition to the steps that we took for 2015, which we intend to continue to take for 2016 to the extent applicable.
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Annex 1
Capitalized terms used and not otherwise defined in this Annex have the meanings indicated in our Conflict Minerals Report.
Smelters and Refiners
In connection with our reasonable country of origin inquiry and due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below, sorted by mineral and risk level, as potentially having processed the necessary 3TG contained in our in-scope products in 2015.
Metal |
Processor |
Country Location |
Status |
|||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
Gold | Argor-Heraeus SA | SWITZERLAND | Compliant | |||
Gold | Asahi Pretec Corporation | JAPAN | Compliant | |||
Gold | Asahi Refining Canada Limited | CANADA | Compliant | |||
Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant | |||
Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
Gold | Aurubis AG | GERMANY | Compliant | |||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
Gold | Boliden AB | SWEDEN | Compliant | |||
Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant | |||
Gold | Chimet S.p.A. | ITALY | Compliant | |||
Gold | DODUCO GmbH | GERMANY | Compliant | |||
Gold | Dowa | JAPAN | Compliant | |||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant | |||
Gold | Elemetal Refining, LLC | UNITED STATES | Compliant | |||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant | |||
Gold | Heimerle + Meule GmbH | GERMANY | Compliant | |||
Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant | |||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Compliant | |||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
Gold | Istanbul Gold Refinery | TURKEY | Compliant | |||
Gold | Japan Mint | JAPAN | Compliant | |||
Gold | Jiangxi Copper Company Limited | CHINA | Compliant | |||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant | |||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant | |||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
Gold | Kazzinc | KAZAKHSTAN | Compliant | |||
Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant | |||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant | |||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
Gold | Materion | UNITED STATES | Compliant | |||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
Gold | Metalor Technologies SA | SWITZERLAND | Compliant | |||
Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant | |||
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Compliant | |||
Gold | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant | |||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
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Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant | |||
Gold | Nihon Material Co., Ltd. | JAPAN | Compliant | |||
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant | |||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant | |||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant | |||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant | |||
Gold | PAMP SA | SWITZERLAND | Compliant | |||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant | |||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
Gold | PX Précinox SA | SWITZERLAND | Compliant | |||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant | |||
Gold | Republic Metals Corporation | UNITED STATES | Compliant | |||
Gold | Royal Canadian Mint | CANADA | Compliant | |||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant | |||
Gold | SEMPSA Joyería Platería SA | SPAIN | Compliant | |||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant | |||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant | |||
Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant | |||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant | |||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
Gold | T.C.A S.p.A | ITALY | Compliant | |||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant | |||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant | |||
Gold | Umicore Brasil Ltda. | BRAZIL | Compliant | |||
Gold | Umicore Precious Metals Thailand | THAILAND | Compliant | |||
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant | |||
Gold | Valcambi SA | SWITZERLAND | Compliant | |||
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant | |||
Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN | Compliant | |||
Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant | |||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant | |||
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant | |||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | LBMA Good Delivery | |||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | LBMA Good Delivery | |||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | LBMA Good Delivery | |||
Gold | Advanced Chemical Company | UNITED STATES | CFSP Active | |||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CFSP Active | |||
Gold | Cendres + Métaux SA | SWITZERLAND | CFSP Active | |||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CFSP Active | |||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CFSP Active | |||
Gold | Faggi Enrico S.p.A. | ITALY | CFSP Active | |||
Gold | Geib Refining Corporation | UNITED STATES | CFSP Active | |||
Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | CFSP Active | |||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CFSP Active | |||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CFSP Active | |||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CFSP Active | |||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CFSP Active (recycler) | |||
Gold | Torecom | KOREA, REPUBLIC OF | CFSP Active | |||
Gold | WIELAND Edelmetalle GmbH | GERMANY | CFSP Active | |||
Gold | Abington Reldan Metals, LLC. | UNITED STATES | 100% from recycled or scrap sources |
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Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | 100% from recycled or scrap sources | |||
Gold | AURA-II | UNITED STATES | 100% from recycled or scrap sources | |||
Gold | Bauer Walser AG | GERMANY | 100% from recycled or scrap sources | |||
Gold | Chugai Mining | JAPAN | 100% from recycled or scrap sources | |||
Gold | Remondis Argentia B.V. | NETHERLANDS | 100% from recycled or scrap sources | |||
Gold | Sabin Metal Corp. | UNITED STATES | 100% from recycled or scrap sources | |||
Gold | Safina a.s. | CZECH REPUBLIC | 100% from recycled or scrap sources | |||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | On Reference List Only | |||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Reference List Only | |||
Gold | Bangalore Refinery Pnt Ltd | INDIA | On Reference List Only | |||
Gold | Caridad | MEXICO | On Reference List Only | |||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | On Reference List Only | |||
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Guangdong Jinding Gold Limited | CHINA | On Reference List Only | |||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | On Reference List Only | |||
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Reference List Only | |||
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Reference List Only | |||
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | On Reference List Only | |||
Gold | L azurde Company For Jewelry | SAUDI ARABIA | On Reference List Only | |||
Gold | Lingbao Gold Company Limited | CHINA | On Reference List Only | |||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Morris and Watson | NEW ZEALAND | On Reference List Only | |||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Reference List Only | |||
Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | On Reference List Only | |||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Reference List Only | |||
Gold | So Accurate Group, Inc. | UNITED STATES | On Reference List Only | |||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Reference List Only | |||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant | |||
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant | |||
Tantalum | D Block Metals, LLC | UNITED STATES | Compliant | |||
Tantalum | Duoluoshan | CHINA | Compliant | |||
Tantalum | Exotech Inc. | UNITED STATES | Compliant | |||
Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant | |||
Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant | |||
Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant | |||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant | |||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant | |||
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Compliant | |||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant | |||
Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant | |||
Tantalum | H.C. Starck Ltd. | JAPAN | Compliant |
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Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant | |||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant | |||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
Tantalum | KEMET Blue Metals | MEXICO | Compliant | |||
Tantalum | KEMET Blue Powder | UNITED STATES | Compliant | |||
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant | |||
Tantalum | LSM Brasil S.A. | BRAZIL | Compliant | |||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant | |||
Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant | |||
Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant | |||
Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant | |||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
Tantalum | Plansee SE Liezen | AUSTRIA | Compliant | |||
Tantalum | Plansee SE Reutte | AUSTRIA | Compliant | |||
Tantalum | QuantumClean | UNITED STATES | Compliant | |||
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant | |||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant | |||
Tantalum | Taki Chemicals | JAPAN | Compliant | |||
Tantalum | Telex Metals | UNITED STATES | Compliant | |||
Tantalum | Tranzact, Inc. | UNITED STATES | Compliant | |||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant | |||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant | |||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant | |||
Tantalum | Zhuzhou Cemented Carbide | CHINA | Compliant | |||
Tantalum | E.S.R. Electronics | UNITED STATES | CFSP Active | |||
Tin | Alpha | UNITED STATES | Compliant | |||
Tin | China Tin Group Co., Ltd. | CHINA | Compliant | |||
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant | |||
Tin | CV Ayi Jaya | INDONESIA | Compliant | |||
Tin | CV Gita Pesona | INDONESIA | Compliant | |||
Tin | CV Serumpun Sebalai | INDONESIA | Compliant | |||
Tin | CV United Smelting | INDONESIA | Compliant | |||
Tin | CV Venus Inti Perkasa | INDONESIA | Compliant | |||
Tin | Dowa | JAPAN | Compliant | |||
Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Compliant | |||
Tin | EM Vinto | BOLIVIA | Compliant | |||
Tin | Fenix Metals | POLAND | Compliant | |||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant | |||
Tin | Magnus Minerais Metais e Ligas Ltda. | BRAZIL | Compliant | |||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
Tin | Melt Metais e Ligas S/A | BRAZIL | Compliant | |||
Tin | Metallic Resources, Inc. | UNITED STATES | Compliant | |||
Tin | Metallo-Chimique N.V. | BELGIUM | Compliant | |||
Tin | Mineração Taboca S.A. | BRAZIL | Compliant | |||
Tin | Minsur | PERU | Compliant | |||
Tin | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant | |||
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant | |||
Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
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Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant | |||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
Tin | PT Babel Inti Perkasa | INDONESIA | Compliant | |||
Tin | PT Bangka Prima Tin | INDONESIA | Compliant | |||
Tin | PT Bangka Tin Industry | INDONESIA | Compliant | |||
Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant | |||
Tin | PT BilliTin Makmur Lestari | INDONESIA | Compliant | |||
Tin | PT Bukit Timah | INDONESIA | Compliant | |||
Tin | PT Cipta Persada Mulia | INDONESIA | Compliant | |||
Tin | PT DS Jaya Abadi | INDONESIA | Compliant | |||
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant | |||
Tin | PT Inti Stania Prima | INDONESIA | Compliant | |||
Tin | PT Justindo | INDONESIA | Compliant | |||
Tin | PT Mitra Stania Prima | INDONESIA | Compliant | |||
Tin | PT Panca Mega Persada | INDONESIA | Compliant | |||
Tin | PT Prima Timah Utama | INDONESIA | Compliant | |||
Tin | PT REFINED BANGKA TIN | INDONESIA | Compliant | |||
Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant | |||
Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant | |||
Tin | PT Sukses Inti Makmur | INDONESIA | Compliant | |||
Tin | PT Sumber Jaya Indah | INDONESIA | Compliant | |||
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant | |||
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant | |||
Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant | |||
Tin | PT Tommy Utama | INDONESIA | Compliant | |||
Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant | |||
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
Tin | Rui Da Hung | TAIWAN | Compliant | |||
Tin | Soft Metais Ltda. | BRAZIL | Compliant | |||
Tin | Thaisarco | THAILAND | Compliant | |||
Tin | VQB Mineral and Trading Group JSC | VIET NAM | Compliant | |||
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant | |||
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Compliant | |||
Tin | An Thai Minerals Company Limited | VIET NAM | CFSP Active | |||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CFSP Active | |||
Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA | CFSP Active | |||
Tin | CV Dua Sekawan | INDONESIA | CFSP Active | |||
Tin | CV Tiga Sekawan | INDONESIA | CFSP Active | |||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CFSP Active | |||
Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | CFSP Active | |||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CFSP Active | |||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CFSP Active | |||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CFSP Active | |||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CFSP Active | |||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CFSP Active | |||
Tin | Phoenix Metal Ltd. | RWANDA | CFSP Active | |||
Tin | PT Karimun Mining | INDONESIA | CFSP Active | |||
Tin | PT Kijang Jaya Mandiri | INDONESIA | CFSP Active | |||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CFSP Active | |||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CFSP Active (recycler) | |||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | 100% from recycled or scrap sources | |||
Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | 100% from recycled or scrap sources |
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Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | 100% from recycled or scrap sources | |||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Estanho de Rondônia S.A. | BRAZIL | On Reference List Only | |||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | On Reference List Only | |||
Tin | PT Tirus Putra Mandiri | INDONESIA | On Reference List Only | |||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant | |||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant | |||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant | |||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant | |||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant | |||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant | |||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | H.C. Starck GmbH | GERMANY | Compliant | |||
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant | |||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant | |||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant | |||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tungsten | Kennametal Huntsville | UNITED STATES | Compliant | |||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Niagara Refining LLC | UNITED STATES | Compliant | |||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant | |||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant | |||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant | |||
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant | |||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | ACL Metais Eireli | BRAZIL | CFSP Active | |||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CFSP Active | |||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CFSP Active | |||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CFSP Active | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CFSP Active | |||
Tungsten | Kennametal Fallon | UNITED STATES | CFSP Active | |||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CFSP Active | |||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CFSP Active | |||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CFSP Active | |||
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | TI-CMC Category A | |||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | TI-CMC Category A | |||
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | TI-CMC Category A | |||
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | TI-CMC Category A | |||
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | On Reference List Only | |||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | On Reference List Only |
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We note the following in connection with the information in the table:
(a) | The smelters and refiners listed in the table were identified by the Suppliers as being part of our 2015 supply chain. Some of the Suppliers may have reported to us smelters and refiners that were not in our supply chain (i) since they reported at a company level, meaning that they reported to us the 3TG contained in all of their products, not just the products that they sold to us, or (ii) due to over-inclusiveness in the information received from their suppliers. In addition, the smelters and refiners reflected above may not be all of the smelters and refiners in our 2015 supply chain, since many of the Suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products and because not all of the Suppliers responded to our inquiries. |
(b) | All information in the table is as of May 17, 2016. |
(c) | Compliant means that the smelter or refiner was compliant with the CFSIs Conflict-Free Smelter Programs (CFSP) assessment protocols, including through mutual recognition and those indicated as Re-audit in process. Included smelters or refiners were not necessarily Compliant for all or part of 2015 and may not continue to be Compliant for any future period. |
(d) | Active means that the smelter or refiner is listed by the CFSI as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or, according to information published by the CFSI, the smelter has agreed to complete a CFSP validation audit within two years of membership issuance by the Tungsten Industry Conflict Minerals Council (the TI-CMC). Refiners listed only on the LBMAs Good Delivery List were counted in the Active column of the summary table. |
(e) | On Reference List Only means the smelter or refiner is not listed as Compliant or Active. The table only includes entities that were listed as smelters or refiners by the CFSI, the LBMA, the RJC or the TI-CMC. |
(f) | The compliance status reflected in the table is based solely on information made publicly available by the CFSI, without independent verification by us. |
(g) | Country location is the location of the smelter or refiner. |
Country of Origin Information
The countries of origin of the 3TG processed by the Compliant smelters and refiners listed above may have included countries in each of the categories listed below. The countries below are sorted by risk level. See Reasonable Country of Origin Inquiry; Smelter and Refiner and Country of Origin Information for additional country of origin information.
L1 Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote dIvoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam and Zimbabwe.
L2 Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique and South Africa.
L3 The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC The Democratic Republic of the Congo.
In addition, some of the listed Compliant smelters and refiners may have processed 3TG originating from recycled or scrap sources.
For 2015, we were not able to determine the country of origin of the 3TG processed by 29 smelters or refiners.
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