EX-1.01
Published on May 24, 2017
Exhibit 1.01
Conflict Minerals Report
Becton, Dickinson and Company has included this Conflict Minerals Report as an exhibit to its Form SD for 2016, as contemplated 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 24, 2017.
Unless the context indicates otherwise, the term BD, we, us and our refer to Becton, Dickinson and Company and its consolidated subsidiaries for 2016. 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. The company provides innovative solutions that help advance medical research and genomics, enhance the diagnosis of infectious disease and cancer, improve medication management, promote infection prevention, equip surgical and interventional procedures, and support the management of diabetes.
BD is subject to the Conflict Minerals Rule because, for 2016, 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. In October 2016, BD divested its Respiratory Solutions business to a joint venture - Vyaire Medical a standalone, global respiratory solutions company. The closing of the divestiture finalized the sale of 50.1 percent interest in BDs Respiratory Solutions business (including Ventilation, Respiratory Diagnostics, Vital Signs and AirLife) to funds advised by Apax Partners. BD retained a 49.9 percent minority interest in Vyaire. Vyaire Medical is not included in this Report.
We do not directly source 3TG from mines, smelters, or refiners, and we believe that we are many levels removed from these market participants. 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 2016, we conducted a reasonable country of origin inquiry. Our outreach included 2108 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. Suppliers representing 83% of our in-scope spend responded to our reasonable country of origin inquiry.
For 2016, 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 |
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CFSP Compliant1 |
CFSP Active |
Total | CFSP Compliant |
CFSP Active |
Total | |||||||||||||||||||||||||||||||
Gold |
0 | 0 | 0 | 95 | 8 | 103 | 3 | 32 | 138 | |||||||||||||||||||||||||||
Tantalum |
31 | 0 | 31 | 13 | 0 | 13 | 0 | 0 | 44 | |||||||||||||||||||||||||||
Tin |
5 | 0 | 5 | 63 | 5 | 68 | 0 | 11 | 84 | |||||||||||||||||||||||||||
Tungsten |
5 | 0 | 5 | 35 | 0 | 35 | 0 | 5 | 45 | |||||||||||||||||||||||||||
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Total |
41 | 0 | 41 | 206 | 13 | 219 | 3 | 48 | 311 | |||||||||||||||||||||||||||
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Based on the results of our reasonable country of origin inquiry, we conducted due diligence for 2016. 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 did not 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 (Third Edition).
Selected Elements of Design Framework
The OECD Guidance has established a 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 2016 are discussed under Due Diligence Program Execution.
Conflict Minerals Policy
BDs Conflict Minerals Policy, as described in this Conflict Minerals Report is available on our website at https://www.bd.com/_Images/BD-Conflict-Minerals-Policy.pdf.
1 | See Annex for definitions. |
Conflict Minerals Team
We have a centralized Conflict Minerals Team (the Core Team) to provide cross-functional support for the BD Conflict Minerals Program. The Core Team is comprised of representatives from Global Procurement, the Office of Global Sustainability, and BD business units. The Core Team is led by a Program Leader with support and oversight from the Director, Product Stewardship Compliance, the executive leader of the program. Executive leadership of the program resides with Global Sustainability.
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 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 teams.
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 European and U.S. purchase orders include language requiring suppliers to provide information to BD to support BDs compliance efforts under the 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 and the list of known processing facilities on the Commerce Department List. 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.
Smelter and refiner information is also reviewed against the lists of compliant and active (or the equivalent) 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 or the equivalent 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 impacts. The Steering Team reports the findings of its supply chain risk assessment to senior management 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.
In addition, to the extent that identified smelters or refiners are not listed as compliant, we seek to exercise leverage over the smelters and refiners to become certified through our participation in and support of the CFSI. We also utilize information provided by the CFSI to its members to monitor smelter and refiner improvement.
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 and rely on information made available by the CFSI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence and to determine whether the smelter or refiner is compliant. We are a member of the CFSI. We also made a donation to the CFSI Initial Audit Fund to support smelter and refiner audits in the spring of 2016.
Report on Supply Chain Due Diligence
We file a Form SD and 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 2016 compliance period. These are not all of the measures that we took in respect of 2016 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 2108 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 and the list of known processing facilities on the Commerce Department List, and the smelter and refiner database available to members of the CFSI. To the extent that a completed response identified a smelter or refiner not on any of these lists, 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 (or the equivalent) smelters and refiners published by the CFSI, LBMA, and RJC as of April 21, 2017. 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 (or the equivalent) 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 senior management. |
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. | Participated on the CFSIs Smelter Engagement and Due Diligence teams and we made a donation to the CFSI Initial Audit Fund. |
b. | We refined our in-scope commodity categories to better focus our efforts on the highest risk areas; 93% of our in-scope spend for commodities most likely to contain 3TG was covered. |
c. | We refined the country of origin information by mineral. |
Product Information
Our in-scope products for 2016 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.
For 2016, 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 Reasonable Country of Origin Inquiry, Smelter and Refiner and Country of Origin Information and on Annex 1.
Additional Mitigation Efforts
In respect of 2017, 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 2016 that the source of Conflict Minerals was unknown or undeterminable. |
2. | Continue to implement Purchase Order Terms and Conditions changes relating to 3TG in the remaining regions for which implementation has not been completed. |
3. | Donate the amount of the average cost of an audit to the CFSI Initial Audit Fund. |
4. | Continue 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 2016, which we intend to continue to take for 2017 to the extent applicable.
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 2016.
Metal |
Processor |
Country Location |
Status |
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Gold | Advanced Chemical Company | UNITED STATES | Compliant | |||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Compliant | |||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant | |||
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
Gold | Argor-Heraeus SA | SWITZERLAND | Compliant | |||
Gold | Asahi Pretec Corp. | 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 | AU Traders and Refiners | SOUTH AFRICA | 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 | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
Gold | DODUCO GmbH | GERMANY | Compliant | |||
Gold | Dowa | JAPAN | Compliant | |||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | 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 | Geib Refining Corporation | UNITED STATES | 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 | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant | |||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
Gold | Materion | UNITED STATES | Compliant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | 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 | |||
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 | SAFINA A.S. | CZECH REPUBLIC | Compliant | |||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant | |||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | 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 | Torecom | KOREA, REPUBLIC OF | 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 | WIELAND Edelmetalle GmbH | GERMANY | 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 | Active | |||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Active | |||
Gold | Abington Reldan Metals | UNITED STATES | Active | |||
Gold | Bangalore Refinery | INDIA | Active |
Gold | Cendres + Métaux SA | SWITZERLAND | Active | |||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Active | |||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active | |||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active | |||
Gold | SungEel HiTech | KOREA (REPUBLIC OF) | Active | |||
Gold | Tony Goetz NV | BELGIUM | Active | |||
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 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | 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 | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | 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 | HwaSeong 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 | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | 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 | Modeltech Sdn Bhd | MALAYSIA | 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 | SAAMP | FRANCE | On Reference List Only | |||
Gold | Sai Refinery | INDIA | 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 | Sudan Gold Refinery | SUDAN | On Reference List Only | |||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | On Reference List Only | |||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Reference List Only | |||
Gold | Universal Precious Metals Refining | ZAMBIA | 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 Hermsdorf GmbH | GERMANY | Compliant | |||
Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant |
Tantalum | H.C. Starck Ltd. | JAPAN | Compliant | |||
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | 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 Nonferrous Metals Smelting Company Limited | 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 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
Tantalum | NPM Silmet AS | ESTONIA | Compliant | |||
Tantalum | Power Resources Ltd. | MACEDONIA | Compliant | |||
Tantalum | QuantumClean | UNITED STATES | Compliant | |||
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | 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 | Yanling Jincheng Tantalum Co., Ltd. | CHINA | Compliant | |||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant | |||
Tantalum | Zhuzhou Cemented Carbide | CHINA | Compliant | |||
Tin | Alpha | UNITED STATES | Compliant | |||
Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA | 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 Dua Sekawan | INDONESIA | Compliant | |||
Tin | CV Gita Pesona | INDONESIA | Compliant | |||
Tin | CV Serumpun Sebalai | INDONESIA | Compliant | |||
Tin | CV Tiga Sekawan | 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 Fengming Metalurgy Chemical Plant | CHINA | Compliant | |||
Tin | Gejiu Jinye Mineral Company | CHINA | Compliant | |||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant | |||
Tin | HuiChang Hill Tin Industry 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 Philippines, Inc. | PHILIPPINES | Compliant | |||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant | |||
Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant | |||
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 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 Karimun Mining | INDONESIA | Compliant | |||
Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant | |||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant | |||
Tin | PT Menara Cipta Mulia | INDONESIA | Compliant | |||
Tin | PT Mitra Stania Prima | INDONESIA | Compliant | |||
Tin | PT O.M. Indonesia | 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 | 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 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active | |||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active | |||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active | |||
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active | |||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active | |||
Tin | An Thai Minerals Company Limited | VIET NAM | On Reference List Only | |||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Reference List Only | |||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Estanho de Rondônia S.A. | BRAZIL | On Reference List Only | |||
Tin | Gejiu Zili Mining and Metallurgy Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Reference List Only | |||
Tin | Modeltech Sdn Bhd | MALAYSIA | On Reference List Only | |||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Reference List Only |
Tin | PT Justindo | INDONESIA | On Reference List Only | |||
Tin | Super Ligas | BRAZIL | On Reference List Only | |||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | 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 | Global Tungsten & Powders Corp. | UNITED STATES | Compliant | |||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | H.C. Starck Tungsten 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 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Kennametal Fallon | UNITED STATES | Compliant | |||
Tungsten | Kennametal Huntsville | UNITED STATES | Compliant | |||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Compliant | |||
Tungsten | Niagara Refining LLC | UNITED STATES | Compliant | |||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant | |||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant | |||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant | |||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant | |||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant | |||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant | |||
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant | |||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant | |||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant | |||
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Active | |||
Tungsten | ACL Metais Eireli | BRAZIL | On Reference List Only | |||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | On Reference List Only | |||
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | On Reference List Only | |||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | On Reference List Only |
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 2016 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 2016 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 April 18, 2017 |
(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 treated as Active. |
(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 origin information.
Known Countries from which Compliant Gold Smelters Source:
L1 Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Benin, Bolivia, Burkina Faso, Chile, Colombia, Ecuador, Eritrea, Ghana, Guatemala, Guinea, Guyana, Honduras, Mali, Nicaragua, Panama, Peru, Senegal, Togo, United States of America.
L2 Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: South Africa.
Known Countries from which Compliant Tantalum Smelters Source:
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Australia, Bolivia, Brazil, China, Ethiopia, France, Guinea, Guyana, India, Madagascar, Malaysia, Namibia, Nigeria, Russia, Sierra Leone, Thailand, United States of America, Zimbabwe
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Mozambique
L3 The DRC and its nine adjoining countries: Burundi, Rwanda.
DRC The Democratic Republic of the Congo.
Known Countries from which Compliant Tin Smelters Source:
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG:
Australia, Bolivia, Brazil, China, Colombia, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russia, Thailand, Vietnam
L3 The DRC and its nine adjoining countries: Burundi, Rwanda, Uganda.
DRC The Democratic Republic of the Congo.
Known Countries from which Compliant Tungsten Smelters Source:
L1- Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of 3TG: Australia, Austria, Bolivia, Brazil, Cambodia, Canada, China, Colombia, Japan, Mexico, Mongolia, Nigeria, Portugal, Russia, Spain, United States of America, Uzbekistan, Vietnam
L3 - The DRC and its nine adjoining countries: Burundi, Rwanda.
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 2016, we were not able to determine the country of origin of the 3TG processed by 53 smelters or refiners.