UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
 
FORM SD
 
Specialized Disclosure Report
 
3M COMPANY
(Exact Name of Registrant as Specified in Its Charter)
 
Delaware
(State or Other Jurisdiction of Incorporation)

File No. 1-3285	 	41-0417775	
(Commission File Number)	 	(IRS Employer Identification No.)	
 	 	 	
3M Center, St. Paul, Minnesota	 	55144-1000	
(Address of Principal Executive Offices)	 	(Zip Code)	
 
Mark Copman, Vice President
3M Sourcing Operations
(651) 733-1110
(Name and telephone number, including area code, of the person to contact in connection with this report)
 
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
 
x           Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.

 

 
Section 1 — Conflict Minerals Disclosures
 
Item 1.01 Conflict Minerals Disclosure and Report
 
This Specialized Disclosure Report (Form SD) for 3M Company (“3M,” “Company,” “we,” “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2015.
 
Conflict Minerals are defined by the Securities and Exchange Commission (SEC) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively “3TG”).  During calendar year 2015, 3M manufactured and contracted to manufacture products in which 3TG were necessary to the functionality or production of those products.
 
3M therefore conducted a “reasonable country of origin inquiry” (RCOI) to determine whether any of those minerals: (1) originated in the Democratic Republic of Congo (DRC), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (together, the “Covered Countries”); or (2) are from recycled or scrap sources.
 
A.             Introduction:
 
1.               3M’s Business : 3M is a diversified technology company with a global presence in the following five businesses:  Industrial; Safety and Graphics; Electronics and Energy; Health Care; and Consumer.  3M is among the leading manufacturers of products for many of the markets it serves.  These businesses have worldwide responsibility for virtually all 3M product lines.
 
2.               3M Supply Chains :  3M supply chains are complex, including thousands of suppliers spread over different tiers in those chains.  Supplied materials are used in products serving numerous industry sectors.  3M is typically many tiers from smelters or refiners that would have information on mines supplying 3TG.  Moreover, to the extent 3TG are present in 3M products the content may be at trace levels.  Supply chains are improving their capacity to obtain and transmit smelter identities, but there can be long delays, incomplete data and extensive supplier follow-up. Obtaining information regarding smelters, refiners and mine location is therefore challenging.
 
3.               3M’s Conflict Minerals Policy : As disclosed in our Form SD filed on June 1, 2015, 3M adopted a Conflict Minerals Policy (“Policy”) in July, 2011.  The Policy applies to all 3M suppliers.  It was updated in November 2012 following the SEC’s adoption of the final conflict minerals rule (“Final Rule”), and is available on our website along with other information on 3M’s conflict minerals program.  3M expects its suppliers to: (a) supply materials that are “DRC conflict free”; (b) adopt a conflict minerals policy consistent with 3M’s; (c) implement management systems to support compliance with their conflict minerals policy; and (d) require their suppliers to take the same steps.  3M’s Conflict Minerals website states that 3M encourages our suppliers to responsibly source 3TG from the Covered Countries through smelters or refiners (SORs) validated as DRC Conflict Free.
 
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4.               3M’s Commitment to Industry Participation in the Conflict Free Sourcing Initiative (CFSI) : As a downstream company that does not typically contract directly with 3TG smelters or refiners, 3M actively collaborated with others in the industry through participation in the Conflict Free Sourcing Initiative (CFSI).  The CFSI is a broad-based initiative to develop control systems regarding smelters and refiners through independently validated audits under CFSI’s Conflict Free Smelter (CFS) program.  According to the CFSI website, over 300 companies and associations across seven different industries participate in the CFSI.  In furtherance of our commitment to industry collaborative controls and the CFS program in particular, 3M was one of the early donors to the CFSI Initial Audit Fund to provide financial assistance to smelters for their first-year audit.  The Fund is intended to eliminate barriers to smelter participation in the CFS program.  3M has been a member of CFSI since 2011 and was a member of CFSI throughout 2015.  Members of 3M’s Conflict Minerals Steering team participated in the CFSI Due Diligence Practices Team in 2015 as well as the CFSI Smelter Engagement Team. In 2015 we encouraged supplier and other company membership and participation in CFSI.
 
B.             Description of RCOI:
 
1.               RCOI Elements :  The elements of 3M’s RCOI were identification and prioritization of suppliers, supplier data collection and an assessment of supplier data to determine whether further due diligence was required.  These basic elements did not change from the previous year’s inquiry.
 
2.               Prioritized Supplier Inquiry :  In view of 3M’s extensive supply chains, 3M determined that a reasonably designed and good faith inquiry should focus on higher priority suppliers consistent with the Conflict Free Smelter Initiative (CFSI) Reasonable Practices Guidance (subsequently renamed Five Practical Steps to Support SEC Conflict Minerals Disclosure ) .   3M designated over 50 employees globally as “Conflict Minerals Advisors” (CMAs).  The CMAs and many other knowledgeable 3M personnel identified products containing 3TG necessary to the functionality or production of those products (“Necessary 3TG”), including products from covered acquisitions.  This process resulted in many product families and individual products being screened out from further inquiry, as not containing Necessary 3TG.  Through the screening process, the CMAs and other 3M personnel determined to the best of their knowledge that the following product categories may contain Necessary 3TG:
 
·                   Electrical connectors, cables and cords, electronic chargers, controls, monitors and plated circuitry
·                   Products that include these and other electrical or electronic components
·                   Metallized films and tapes
·                   Some orthodontic products
·                   Certain personal protective eyewear and faceshields
 
3M then prioritized its review of these products that may contain Necessary 3TG and the corresponding supply chains taking into account various factors such as estimated content of 3TG, type of mineral, amount of spend, the nature of the supply chain, and supplier location.
 
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3.               Data Collection Via Web-Enabled Supplier Inquiry :  Once the relevant higher priority suppliers (“Supplier Group”) were identified, 3M asked the Supplier Group to provide information about the Necessary 3TG in their products based on responses to the industry standard CFSI Conflict Minerals Reporting Template (CMRT). This request was web-enabled using 3M’s Supplier Regulatory eEnablement (SREE) system.  That system issued three automatic follow-up reminders to those in the Supplier Group who had not responded to the information request.  Additional e-mail reminders were sent to those in the Supplier Group who had not responded, and follow-up phone calls were made with prioritized suppliers.  As part of these phone calls, 3M offers training to the supplier on topics including the importance of the information requested by 3M and how to correctly enter data in the SREE system. In some cases, 3M provided a copy of the CMRT in a language other than English.
 
4.               Data Validation:   3M conducted data validation on all submitted CMRTs, and retained all submitted CMRTs for recordkeeping purposes.  The goal of data validation is to increase the completeness and accuracy of the submissions and to identify any contradictory responses in the CMRT.  3M reviewed the responses to determine where further engagement with suppliers was warranted.  We considered untimely or incomplete responses as well as inconsistencies with the data reported in the CMRT in making this determination.  For any CMRT that was determined invalid based on this review, 3M worked directly with the supplier to clarify the information in the CMRT and/or request that the supplier provide a revised CMRT.  In this direct follow-up with suppliers, we offered training on how to enter CMRT information and/or on 3M’s expectations for CMRT information, as appropriate.
 
For suppliers that responded in their CMRTs that materials or goods they supplied to 3M did not contain Necessary 3TG, 3M CMAs were asked to verify the responses.  3M removed these suppliers from the survey process only after such verification.  If there were discrepancies in expected metal content, 3M CMAs were contacted for additional information and potential follow-up with the supplier to clear the discrepancy.  Where appropriate, 3M asked the supplier to submit a new CMRT or revised documentation after such follow-up.
 
For those suppliers that indicated in their CMRTs that they did not have certain aspects of a conflict minerals program, such as a conflict minerals policy or implementation of due diligence measures for conflict-free sourcing, the CMRTs were still considered valid; however, 3M sent educational bulletins to those suppliers, communicating our conflict minerals policy and 3M’s expectations that the supplier will develop a policy and due diligence management system, and help build capacity in the supply chain through their supplier inquiry so that they assist in the transition to CFS-validated SORs.  The educational bulletin also directed the supplier to 3M’s conflict minerals webpage and guidance on the CFSI website and encouraged the supplier to become a member of CFSI.
 
With respect to data validation on SOR-related information listed in the submitted CMRTs, we compared the SOR names and SOR country locations provided in the suppliers’ submitted CMRTs to the SOR names and SOR country locations that are listed on the “known smelter list” provided in the CFSI-CMRT template form.
 
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We validate whether any 3TG sourced from the Covered Countries is conflict-free based on the information provided by our Supplier Group and on the information available on the CFSI’s website.
 
Based on the responses received from the Company’s RCOI, which included thousands of alleged SOR names, and information on SOR names, locations and associated countries of origin from the CFSI-RCOI data set (to which we have access as a member of CFSI), 3M compiled a list of 316 verified, unique SORs, including information regarding associated countries of origin. 3M performed due diligence on the SORs that were known or reasonably believed to have sourced from the Covered Countries or that had unknown sourcing as described in the attached Conflict Minerals Report.
 
C.  Results of RCOI:
 
Downstream companies such as 3M are not likely to have direct information on the sources of minerals upstream of the SORs in their supply chains.  Instead, downstream companies rely on available information regarding SORs identified through supplier inquiry.  Accordingly, 3M reviewed supplier responses resulting from the inquiry described in Paragraphs B.3 and B.4 above as well as information from capacity-building interactions and efforts with suppliers to elicit responses and encourage development of conflict minerals programs.  These supplier responses and our capacity-building efforts affirmed information on supply chain maturity gathered through participation in the CFSI program and other industry associations. 3M received substantially more SOR names from the Supplier Group for the 2015 reporting year as compared to those received from the Supplier Group for the 2014 reporting year, which indicated significant progress in the multi-tiered supply chains’ capacity to pass 3TG-related inquiries and information on SORs up and down those supply chains.  As a downstream company typically several tiers from SORs, 3M relied on information from direct suppliers, many of them smaller and private companies.  The information 3M received on SOR names from direct suppliers suggested that these direct suppliers had made progress in building their conflict minerals programs and capacities to transmit conflict mineral information during 2015.
 
D.  Conclusion:
 
Based on its RCOI 3M has reason to believe that a portion of its Necessary 3TG may have originated in the Covered Countries and has reason to believe that those Necessary 3TG may not be from recycled or scrap sources.  Accordingly, 3M conducted further due diligence on the source and chain of custody of Necessary 3TG contained in products supplied by the Supplier Group.  After conducting the due diligence described in the attached Conflict Minerals Report, 3M determined that based on SOR information provided by the Supplier Group and information available to 3M as a member of CFSI, the SORs identified as sourcing from those Covered Countries have all been validated as using DRC conflict-free sourcing practices under the Conflict Free Smelter program protocols.
 
In accord with Rule 13p-1 under the Securities Exchange Act of 1934, 3M has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report and both reports are posted to a publicly available Internet site at http://solutions.3m.com/wps/portal/3M/en_US/SD/Supplier/Requirements/SREE/ConflictMinerals/.  The
 
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reference to 3M’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD and Conflict Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.
 
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Item 1.02                                            Exhibit
 
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
 
Section 2 — Exhibits
 
Item                       2.01   Exhibits
 
Exhibit 1.01 — Conflict Minerals Report for the period January 1 to December 31, 2015, as required by Items 1.01 and 1.02 of this Form.
 
SIGNATURES
 
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has caused this report to be signed on its behalf by the duly authorized undersigned.
 
3M COMPANY

/s/ Paul A. Keel	 	May 27, 2016	
 	 	 	
By: Paul A. Keel,	 	(Date)	
 	 	 	
Senior Vice President, Supply Chain	 	 	
 
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Exhibit 1.01
 
CONFLICT MINERALS REPORT OF 3M COMPANY
FOR THE YEAR ENDED DECEMBER 31, 2015
 
INTRODUCTION
 
This Conflict Minerals Report for 3M Company (“3M,” “Company,” “we,” “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2015.
 
Conflict Minerals are defined by the Securities and Exchange Commission (SEC) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively “3TG”).  As a result of the Company’s reasonable country of origin inquiry for the period January 1 to December 31, 2015 described in the attached Form SD, 3M has reason to believe that a portion of the 3TG necessary to the functionality or production of products (“Necessary 3TG”) that we manufactured or contracted to manufacture during the period between January 1, 2015 and December 31, 2015 may have originated in the Democratic Republic of Congo (DRC), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (together, the “Covered Countries”) and has reason to believe that those Necessary 3TG may not be from recycled or scrap sources.
 
The Company therefore conducted due diligence on the source and chain of custody of Necessary 3TG as described below.
 
DUE DILIGENCE MEASURES
 
A.             Design of Our Due Diligence Measures
 
Our CMR Conflict Minerals due diligence process has been designed to conform in all material respects with the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) (the “OECD Guidance”), as applicable for 3TG and downstream companies (as the term ‘downstream companies’ is defined in the OECD Guidance).  Our due diligence measures included:
 
1.               Establish strong Company management systems;
2.               Identify and assess risks in the supply chain;
3.               Design and implement a strategy to respond to identified risks;
4.               Carry out independent third-party audit of the supply chain due diligence at identified points in the supply chain;  and
5.               Report on supply chain due diligence.

 
B.             Due Diligence Performed
 
1.               Establish Strong Company Management Systems
 
Conflict Minerals Policy
 
3M adopted a Conflict Minerals Policy, which is posted on our conflict minerals website at http://solutions.3m.com/wps/portal/3M/en_US/SD/Supplier/Requirements/SREE/ConflictMinerals/.
 
Internal Management System
 
3M’s management system for conflict minerals includes an executive sponsor who is 3M’s Senior Vice President, Supply Chain.  In addition, the Company designated a Conflict Minerals Steering Team, comprised of representatives from Sourcing Operations, Medical Department Regulatory Services, EHS and Sustainability Operations, and 3M Legal Affairs.  The Conflict Minerals Steering Team has responsibility for developing and implementing 3M’s conflict minerals compliance strategy, as well as for reviewing the progress and effectiveness of the program going forward.  The Steering Team is led by a Conflict Minerals Program Manager from 3M Sourcing Operations.  Senior Sourcing, Finance and Audit management were briefed about the results of our due diligence efforts.
 
Control System and Supply Chain Transparency
 
3M gathers information using the Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT) sent to the Supplier Group via our web-enabled Supplier Regulatory eEnablement (SREE) system to determine the chain of custody of the Necessary 3TG included in our products.
 
Supplier Engagement
 
After our supplier inquiry for the previous reporting year, 3M e-mailed those in the Supplier Group that were unresponsive using 3M’s Supplier Corrective Action and Response (SCAR) process.  3M also e-mailed those in the Supplier Group that indicated they did not have key aspects of a conflict minerals program by sending an educational bulletin.
 
3M distributed its expectations for suppliers in connection with our inquiry for the 2015 reporting year in the SREE e-mail that included the CMRT.  The SREE e-mail included links to 3M’s Conflict Minerals website, which includes our Conflict Minerals Policy and 3M training on how to respond to the CMRT.  This website also directs suppliers to training resources available through the CFSI.  3M also sent educational bulletins if suppliers’ CMRT responses indicated a need for additional training.
 
3M’s Sourcing contract templates and U.S. purchase order terms & conditions require suppliers to provide upon request, information on the smelters and refiners in relevant supply chains, and other information 3M might require.
 
3M’s Conflict Minerals website states that 3M encourages our suppliers to responsibly source 3TG from the Covered Countries through smelters or refiners (SORs) validated as DRC Conflict Free.

 
Grievance Mechanism
 
We have a grievance mechanism whereby employees and suppliers can report concerns regarding 3M’s business conduct and other matters, at 3M-ethics.com.  We have procedures in place for follow-up in the event any conflict minerals issues are raised through our grievance mechanism.
 
Maintain Records
 
We have a record retention policy applicable to conflict minerals-related documentation that provides for retention for a minimum of ten years.
 
2.               Identify and Assess Risk in the Supply Chain
 
In 2015, 3M used a web-based system to distribute the Conflict Minerals Reporting Template (CMRT) to the Supplier Group in order to identify SORs and gather information on our supply chain.
 
The SREE system issued three automatic follow-up reminders to those in the Supplier Group who had not responded to the information request.  Additional e-mail reminders were sent to those in the Supplier Group who did not respond, and follow-up phone calls were made with some suppliers.  Supplier responses were reviewed by 3M Sourcing Operations and some responses were also reviewed by employees identified as Conflict Minerals Advisors.  If supplier responses indicated that Necessary 3TG contained in products provided to 3M may have originated from the Covered Countries or may have been processed by SORs that have not been validated as using DRC conflict-free sourcing practices, then such responses were sent to the Conflict Minerals Steering Team for further review and determination of follow-up steps.
 
3.               Design and Implement a Strategy to Respond to Risks
 
3M designed a strategy to respond to risks.  The Conflict Minerals Program Manager will report to the Company’s Conflict Minerals Steering Team and its executive sponsor and provide periodic updates to relevant executives of any findings where a supplier in the Supplier Group identifies a SOR processing Necessary 3TG for 3M products that sources from the Covered Countries. The 3M Conflict Minerals Steering Team and executive sponsor or other relevant executives will determine appropriate follow-up actions, if any, to mitigate risks.  Follow-up actions may include the Company’s Supplier Corrective Action and Response (SCAR) process.  As part of the SCAR process the Company may decide to find alternate sources of supply or terminate existing supplier relationships, as appropriate.  For the year 2015, 3M found no instances where it was necessary to find replacement sources of supply or terminate a supplier relationship.
 
4.               Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
 
3M relies on the CFSI’s Conflict-Free Smelter (CFS) Program and similar gold refining industry auditing programs (Gold Refining Programs) to perform third-party audits of SORs.  We will validate whether any 3TG sourced from the Covered Countries is conflict-free based on the

 
information provided by our Supplier Group and on the information provided by the CFSI and Gold Refining Programs through the CFSI website.
 
5.               Report on Supply Chain Due Diligence
 
This Report and our Form SD will be filed with the SEC and be publicly available at 3M’s conflict minerals website at http://solutions.3m.com/wps/portal/3M/en_US/SD/Supplier/Requirements/SREE/ConflictMinerals/.   The reference to 3M’s website is provided for convenience only, and its contents are not incorporated by reference into this Report and Form SD nor deemed filed with the SEC.
 
RESULTS OF DUE DILIGENCE
 
Based on our Reasonable Country of Origin Inquiry (RCOI) described in our Form SD and the other aspects of our due diligence program described above, 3M evaluated the Supplier Group responses to the CMRT-based supplier inquiry.  Based on its RCOI, 3M has reason to believe that a portion of its Necessary 3TG may have originated in the Covered Countries and has reason to believe that those Necessary 3TG may not be from recycled or scrap sources.
 
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our company’s system is based, we support the CFSI Conflict Free Smelter Program that audits smelters’ and refiners’ due diligence activities. The source of information for certain statements in this declaration was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for member “mmco.”
 
Following our Year 2015 inquiry and identification of SORs, we contacted SORs within our supply chain not yet validated as DRC Conflict Free and not actively pursuing validation, and encouraged them to join the CFS Program and become validated as DRC Conflict Free.  During our Year 2015 inquiry we learned through our membership in CFSI that a SOR (identified as sourcing from locations other than the Covered Countries) had temporarily lost its validated status under the CFS Program.  We contacted the SOR and requested that it re-establish validation under the CFS Program.  The SOR later re-established its validation under the CFS Program.
 
Information on Smelters or Refiners
 
The CMRT requested that the Supplier Group provide 3M with information on the SORs that the Supplier Group and its suppliers use to supply Necessary 3TG to 3M.  Because 3M typically does not have a direct relationship with the facilities used to process 3TG, we must rely on information provided by the Supplier Group. Some responses from the Supplier Group indicated that they were unable to provide SOR information at this time.  Other suppliers in the Supplier Group provided information on all SORs used by the supplier but could not provide information linking specific SORs used to process Necessary 3TG with products provided to 3M.  The CMRT responses provided to us by the Supplier Group resulted in the collective identification of approximately 5,000 SORs.  Based on smelter identification numbers set forth in the Supplier Group responses or provided on the CFSI website, we verified 316 unique SORs from among those SORs identified to us by the Supplier Group that may have been used to process Necessary 3TG in 3M products, and these unique SORs

 
are listed in Annex I below.  Of these unique SORs, 214 were validated as using DRC conflict-free sourcing practices under the CFS program protocols as of March 7, 2016.
 
Efforts to Determine the Country of Origin or Mine of Origin
 
In order to determine country or mine of origin, 3M must: (a) seek information about 3TG SORs in our supply chains through use of the CMRT questions; and (b) rely on the CFS Program and its independent audits of SORs, as well as information from that effort made available by CFSI to its members.  3M’s Supplier Group did not provide information on mines of origin for Necessary 3TG used in 3M products manufactured during 2015.  3M does not have sufficient information to conclusively determine the mines or the countries of origin of the Necessary 3TG in its products or whether the Necessary 3TG are from recycled or scrap sources.  However, based on SOR information provided by the Supplier Group through the CMRT responses, as well as CFSI information available to its members, the countries of origin of 3TG associated with SORs identified to 3M by the Supplier Group are believed to include the countries listed in Annex II below. While some countries listed on Annex II are Covered Countries, the SORs identified as sourcing from those Covered Countries have all been validated as using DRC conflict-free sourcing practices under the Conflict Free Smelter Program protocols.
 
For the identified SORs that are not yet validated, we conducted further review to better understand whether they may be sourcing from the Covered Countries.  We first searched for reasonable evidence (such as SOR location and presence and availability of the mined mineral in proximity to the SOR) that they were not sourcing ore from the Covered Countries.  We found such reasonable evidence for 94 identified SORs.  For the 8 remaining identified SORs where this evidence was not found, we searched for information from public references citing the SOR as financing armed groups in the Covered Countries.  No such information was found as of the end of the reporting period for this Report.  3M will consider taking mitigating action if we learn of credible information that identified SORs are potentially financing armed groups in the Covered Countries.
 
STEPS TO IMPROVE DUE DILIGENCE
 
3M will be alert for facts and circumstances that may require SOR-related risk mitigation.  In addition, 3M also expects that more SORs will become validated as “DRC Conflict Free” through the CFS Program and similar programs which will increase overall transparency and accessibility to information on geographic location of SOR mines of origin.
 
3M expects to improve its due diligence to further mitigate the risk that Necessary 3TG benefit armed groups in the DRC or any of its adjoining countries by taking the following steps:
 
·                   Follow-up with those in the Supplier Group that were unresponsive or did not provide sufficient information in 2015, thereby improving both supplier response rates and the quality of supply chain information available to 3M.
 
·                   Follow-up with those in the Supplier Group that indicated in their response to our 2015 inquiry that they did not have certain key aspects of a conflict minerals program, to obtain updated information.

 
·                   Continue our supplier engagement and capacity building efforts through our supplier inquiry and by directing suppliers to training resources available through industry associations and the CFSI, in order to improve response rates and information quality.
 
·                   Continue our company membership in CFSI.
 
·                   Encourage supplier and other company membership and participation in CFSI, which will strengthen industry collaboration to increase leverage on smelters and refiners to join the CFS program and thereby become validated as DRC Conflict Free.
 
·                   Contact smelters and/or refiners to join the CFS program and become validated or re-establish validation as DRC Conflict Free.
 
·                   Encourage responsible sourcing by suppliers of 3TG in the Covered Countries through use of smelters or refiners validated as DRC Conflict Free.
 
Cautionary Statement about Forward-Looking Statements
 
Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “intends,” “plans,” “projects,” “believes,” and “estimates,” “targets,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.

 
ANNEX I

Mineral	 	Smelter or Refiner Name	 	Country Location of
Smelter or Refiner	
Gold	 	Advanced Chemical Company	 	UNITED STATES	
Gold	 	Aida Chemical Industries Co., Ltd.	 	JAPAN	
Gold	 	Aktyubinsk Copper Company TOO	 	KAZAKHSTAN	
Gold	 	Al Etihad Gold Refinery DMCC	 	UNITED ARAB EMIRATES	
Gold	 	Allgemeine Gold-und Silberscheideanstalt A.G.	 	GERMANY	
Gold	 	Almalyk Mining and Metallurgical Complex (AMMC)	 	UZBEKISTAN	
Gold	 	AngloGold Ashanti Córrego do Sítio Mineração	 	BRAZIL	
Gold	 	Argor-Heraeus SA	 	SWITZERLAND	
Gold	 	Asahi Pretec Corporation	 	JAPAN	
Gold	 	Asahi Refining Canada Limited	 	CANADA	
Gold	 	Asahi Refining USA Inc.	 	UNITED STATES	
Gold	 	Asaka Riken Co., Ltd.	 	JAPAN	
Gold	 	Atasay Kuyumculuk Sanayi Ve Ticaret A.S.	 	TURKEY	
Gold	 	Aurubis AG	 	GERMANY	
Gold	 	Bangko Sentral ng Pilipinas (Central Bank of the Philippines)	 	PHILIPPINES	
Gold	 	Bauer Walser AG	 	GERMANY	
Gold	 	Boliden AB	 	SWEDEN	
Gold	 	C. Hafner GmbH + Co. KG	 	GERMANY	
Gold	 	Caridad	 	MEXICO	
Gold	 	CCR Refinery - Glencore Canada Corporation	 	CANADA	
Gold	 	Cendres + Métaux SA	 	SWITZERLAND	
Gold	 	Chimet S.p.A.	 	ITALY	
Gold	 	Chugai Mining	 	JAPAN	
Gold	 	Daejin Indus Co., Ltd.	 	KOREA, REPUBLIC OF	
Gold	 	Daye Non-Ferrous Metals Mining Ltd.	 	CHINA	
Gold	 	DODUCO GmbH	 	GERMANY	
Gold	 	Dowa	 	JAPAN	
Gold	 	DSC (Do Sung Corporation)	 	KOREA, REPUBLIC OF	
Gold	 	Eco-System Recycling Co., Ltd.	 	JAPAN	
Gold	 	Elemetal Refining, LLC	 	UNITED STATES	
Gold	 	Emirates Gold DMCC	 	UNITED ARAB EMIRATES	
Gold	 	Faggi Enrico S.p.A.	 	ITALY	
Gold	 	Gansu Seemine Material Hi-Tech Co., Ltd.	 	CHINA	
Gold	 	Geib Refining Corporation	 	UNITED STATES	
Gold	 	Great Wall Precious Metals Co., Ltd. of CBPM	 	CHINA	
Gold	 	Guangdong Jinding Gold Limited	 	CHINA	

 

Gold	 	Guoda Safina High-Tech Environmental Refinery Co., Ltd.	 	CHINA	
Gold	 	Hangzhou Fuchunjiang Smelting Co., Ltd.	 	CHINA	
Gold	 	Heimerle + Meule GmbH	 	GERMANY	
Gold	 	Heraeus Ltd. Hong Kong	 	CHINA	
Gold	 	Heraeus Precious Metals GmbH & Co. KG	 	GERMANY	
Gold	 	Hunan Chenzhou Mining Co., Ltd.	 	CHINA	
Gold	 	Hwasung CJ Co., Ltd.	 	KOREA, REPUBLIC OF	
Gold	 	Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited	 	CHINA	
Gold	 	Ishifuku Metal Industry Co., Ltd.	 	JAPAN	
Gold	 	Istanbul Gold Refinery	 	TURKEY	
Gold	 	Japan Mint	 	JAPAN	
Gold	 	Jiangxi Copper Company Limited	 	CHINA	
Gold	 	JSC Ekaterinburg Non-Ferrous Metal Processing Plant	 	RUSSIAN FEDERATION	
Gold	 	JSC Uralelectromed	 	RUSSIAN FEDERATION	
Gold	 	JX Nippon Mining & Metals Co., Ltd.	 	JAPAN	
Gold	 	Kaloti Precious Metals	 	UNITED ARAB EMIRATES	
Gold	 	Kazakhmys Smelting LLC	 	KAZAKHSTAN	
Gold	 	Kazzinc	 	KAZAKHSTAN	
Gold	 	Kennecott Utah Copper LLC	 	UNITED STATES	
Gold	 	KGHM Polska Miedź Spółka Akcyjna	 	POLAND	
Gold	 	Kojima Chemicals Co., Ltd.	 	JAPAN	
Gold	 	Korea Metal Co., Ltd.	 	KOREA, REPUBLIC OF	
Gold	 	Korea Zinc Co. Ltd.	 	KOREA, REPUBLIC OF	
Gold	 	Kyrgyzaltyn JSC	 	KYRGYZSTAN	
Gold	 	L’ azurde Company For Jewelry	 	SAUDI ARABIA	
Gold	 	Lingbao Gold Company Limited	 	CHINA	
Gold	 	Lingbao Jinyuan Tonghui Refinery Co., Ltd.	 	CHINA	
Gold	 	LS-NIKKO Copper Inc.	 	KOREA, REPUBLIC OF	
Gold	 	Luoyang Zijin Yinhui Gold Refinery Co., Ltd.	 	CHINA	
Gold	 	Materion	 	UNITED STATES	
Gold	 	Matsuda Sangyo Co., Ltd.	 	JAPAN	
Gold	 	Metahub Industries Sdn. Bhd.	 	MALAYSIA	
Gold	 	Metalor Technologies (Hong Kong) Ltd.	 	CHINA	
Gold	 	Metalor Technologies (Singapore) Pte., Ltd.	 	SINGAPORE	
Gold	 	Metalor Technologies (Suzhou) Ltd.	 	CHINA	
Gold	 	Metalor Technologies SA	 	SWITZERLAND	
Gold	 	Metalor USA Refining Corporation	 	UNITED STATES	
Gold	 	METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V	 	MEXICO	

 

Gold	 	Mitsubishi Materials Corporation	 	JAPAN	
Gold	 	Mitsui Mining and Smelting Co., Ltd.	 	JAPAN	
Gold	 	MMTC-PAMP India Pvt., Ltd.	 	INDIA	
Gold	 	Morris and Watson	 	New Zealand	
Gold	 	Moscow Special Alloys Processing Plant	 	RUSSIAN FEDERATION	
Gold	 	Nadir Metal Rafineri San. Ve Tic. A.Ş.	 	TURKEY	
Gold	 	Navoi Mining and Metallurgical Combinat	 	UZBEKISTAN	
Gold	 	Nihon Material Co., Ltd.	 	JAPAN	
Gold	 	Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH	 	AUSTRIA	
Gold	 	Ohura Precious Metal Industry Co., Ltd.	 	JAPAN	
Gold	 	OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)	 	RUSSIAN FEDERATION	
Gold	 	OJSC Kolyma Refinery	 	RUSSIAN FEDERATION	
Gold	 	OJSC Novosibirsk Refinery	 	RUSSIAN FEDERATION	
Gold	 	PAMP SA	 	SWITZERLAND	
Gold	 	Penglai Penggang Gold Industry Co., Ltd.	 	CHINA	
Gold	 	Prioksky Plant of Non-Ferrous Metals	 	RUSSIAN FEDERATION	
Gold	 	PT Aneka Tambang (Persero) Tbk	 	INDONESIA	
Gold	 	PX Précinox SA	 	SWITZERLAND	
Gold	 	Rand Refinery (Pty) Ltd.	 	SOUTH AFRICA	
Gold	 	Republic Metals Corporation	 	UNITED STATES	
Gold	 	Royal Canadian Mint	 	CANADA	
Gold	 	SAAMP	 	FRANCE	
Gold	 	Sabin Metal Corp.	 	UNITED STATES	
Gold	 	Samduck Precious Metals	 	KOREA, REPUBLIC OF	
Gold	 	SAMWON Metals Corp.	 	KOREA, REPUBLIC OF	
Gold	 	SAXONIA Edelmetalle GmbH	 	GERMANY	
Gold	 	Schone Edelmetaal B.V.	 	NETHERLANDS	
Gold	 	SEMPSA Joyería Platería SA	 	SPAIN	
Gold	 	Shandong Tiancheng Biological Gold Industrial Co., Ltd.	 	CHINA	
Gold	 	Shandong Zhaojin Gold & Silver Refinery Co., Ltd.	 	CHINA	
Gold	 	Sichuan Tianze Precious Metals Co., Ltd.	 	CHINA	
Gold	 	Singway Technology Co., Ltd.	 	TAIWAN	
Gold	 	So Accurate Group, Inc.	 	UNITED STATES	
Gold	 	SOE Shyolkovsky Factory of Secondary Precious Metals	 	RUSSIAN FEDERATION	
Gold	 	Solar Applied Materials Technology Corp.	 	TAIWAN	
Gold	 	Sumitomo Metal Mining Co., Ltd.	 	JAPAN	

 

Gold	 	T.C.A S.p.A	 	ITALY	
Gold	 	Tanaka Kikinzoku Kogyo K.K.	 	JAPAN	
Gold	 	The Refinery of Shandong Gold Mining Co., Ltd.	 	CHINA	
Gold	 	Tokuriki Honten Co., Ltd.	 	JAPAN	
Gold	 	Tongling Nonferrous Metals Group Co., Ltd.	 	CHINA	
Gold	 	Tony Goetz NV	 	BELGIUM	
Gold	 	Torecom	 	KOREA, REPUBLIC OF	
Gold	 	Umicore Brasil Ltda.	 	BRAZIL	
Gold	 	Umicore Precious Metals Thailand	 	THAILAND	
Gold	 	Umicore SA Business Unit Precious Metals Refining	 	BELGIUM	
Gold	 	United Precious Metal Refining, Inc.	 	UNITED STATES	
Gold	 	Valcambi SA	 	SWITZERLAND	
Gold	 	Western Australian Mint trading as The Perth Mint	 	AUSTRALIA	
Gold	 	WIELAND Edelmetalle GmbH	 	GERMANY	
Gold	 	Yamamoto Precious Metal Co., Ltd.	 	JAPAN	
Gold	 	Yokohama Metal Co., Ltd.	 	JAPAN	
Gold	 	Yunnan Copper Industry Co., Ltd.	 	CHINA	
Gold	 	Zhongyuan Gold Smelter of Zhongjin Gold Corporation	 	CHINA	
Gold	 	Zijin Mining Group Co., Ltd. Gold Refinery	 	CHINA	
Tantalum	 	Avon Specialty Metals Ltd	 	UNITED KINGDOM	
Tantalum	 	Changsha South Tantalum Niobium Co., Ltd.	 	CHINA	
Tantalum	 	Conghua Tantalum and Niobium Smeltry	 	CHINA	
Tantalum	 	D Block Metals, LLC	 	UNITED STATES	
Tantalum	 	Duoluoshan	 	CHINA	
Tantalum	 	E.S.R. Electronics	 	UNITED STATES	
Tantalum	 	Exotech Inc.	 	UNITED STATES	
Tantalum	 	F&X Electro-Materials Ltd.	 	CHINA	
Tantalum	 	FIR Metals & Resource Ltd.	 	CHINA	
Tantalum	 	Global Advanced Metals Aizu	 	JAPAN	
Tantalum	 	Global Advanced Metals Boyertown	 	UNITED STATES	
Tantalum	 	Guangdong Zhiyuan New Material Co., Ltd.	 	CHINA	
Tantalum	 	H.C. Starck Co., Ltd.	 	THAILAND	
Tantalum	 	H.C. Starck GmbH Goslar	 	GERMANY	
Tantalum	 	H.C. Starck GmbH Laufenburg	 	GERMANY	
Tantalum	 	H.C. Starck Hermsdorf GmbH	 	GERMANY	
Tantalum	 	H.C. Starck Inc.	 	UNITED STATES	
Tantalum	 	H.C. Starck Ltd.	 	JAPAN	
Tantalum	 	H.C. Starck Smelting GmbH & Co.KG	 	GERMANY	
Tantalum	 	Hengyang King Xing Lifeng New Materials Co., Ltd.	 	CHINA	
Tantalum	 	Hi-Temp Specialty Metals, Inc.	 	UNITED STATES	
Tantalum	 	Jiangxi Dinghai Tantalum & Niobium Co., Ltd.	 	CHINA	

 

Tantalum	 	Jiangxi Tuohong New Raw Material	 	CHINA	
Tantalum	 	JiuJiang JinXin Nonferrous Metals Co., Ltd.	 	CHINA	
Tantalum	 	Jiujiang Tanbre Co., Ltd.	 	CHINA	
Tantalum	 	Jiujiang Zhongao Tantalum & Niobium Co., Ltd.	 	CHINA	
Tantalum	 	KEMET Blue Metals	 	MEXICO	
Tantalum	 	KEMET Blue Powder	 	UNITED STATES	
Tantalum	 	King-Tan Tantalum Industry Ltd.	 	CHINA	
Tantalum	 	LSM Brasil S.A.	 	BRAZIL	
Tantalum	 	Metallurgical Products India Pvt., Ltd.	 	INDIA	
Tantalum	 	Mineração Taboca S.A.	 	BRAZIL	
Tantalum	 	Mitsui Mining & Smelting	 	JAPAN	
Tantalum	 	Molycorp Silmet A.S.	 	ESTONIA	
Tantalum	 	Ningxia Orient Tantalum Industry Co., Ltd.	 	CHINA	
Tantalum	 	Plansee SE Liezen	 	AUSTRIA	
Tantalum	 	Plansee SE Reutte	 	AUSTRIA	
Tantalum	 	QuantumClean	 	UNITED STATES	
Tantalum	 	Resind Indústria e Comércio Ltda.	 	BRAZIL	
Tantalum	 	RFH Tantalum Smeltry Co., Ltd.	 	CHINA	
Tantalum	 	Solikamsk Magnesium Works OAO	 	RUSSIAN FEDERATION	
Tantalum	 	Taki Chemicals	 	JAPAN	
Tantalum	 	Telex Metals	 	UNITED STATES	
Tantalum	 	Tranzact, Inc.	 	UNITED STATES	
Tantalum	 	Ulba Metallurgical Plant JSC	 	KAZAKHSTAN	
Tantalum	 	XinXing HaoRong Electronic Material Co., Ltd.	 	CHINA	
Tantalum	 	Yichun Jin Yang Rare Metal Co., Ltd.	 	CHINA	
Tantalum	 	Zhuzhou Cemented Carbide	 	CHINA	
Tin	 	Alpha	 	UNITED STATES	
Tin	 	An Thai Minerals Company Limited	 	VIET NAM	
Tin	 	An Vinh Joint Stock Mineral Processing Company	 	VIET NAM	
Tin	 	Chenzhou Yunxiang Mining and Metallurgy Company Limited	 	CHINA	
Tin	 	China Tin Group Co., Ltd.	 	CHINA	
Tin	 	CNMC (Guangxi) PGMA Co., Ltd.	 	CHINA	
Tin	 	Cooperativa Metalurgica de Rondônia Ltda.	 	BRAZIL	
Tin	 	CV Ayi Jaya	 	INDONESIA	
Tin	 	CV Dua Sekawan	 	INDONESIA	
Tin	 	CV Gita Pesona	 	INDONESIA	
Tin	 	CV Serumpun Sebalai	 	INDONESIA	
Tin	 	CV Tiga Sekawan	 	INDONESIA	
Tin	 	CV United Smelting	 	INDONESIA	
Tin	 	CV Venus Inti Perkasa	 	INDONESIA	

 

Tin	 	Dowa	 	JAPAN	
Tin	 	Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company	 	VIET NAM	
Tin	 	Elmet S.L.U. (Metallo Group)	 	SPAIN	
Tin	 	EM Vinto	 	BOLIVIA	
Tin	 	Estanho de Rondônia S.A.	 	BRAZIL	
Tin	 	Feinhütte Halsbrücke GmbH	 	GERMANY	
Tin	 	Fenix Metals	 	POLAND	
Tin	 	Gejiu Fengming Metalurgy Chemical Plant	 	CHINA	
Tin	 	Gejiu Kai Meng Industry and Trade LLC	 	CHINA	
Tin	 	Gejiu Non-Ferrous Metal Processing Co., Ltd.	 	CHINA	
Tin	 	Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.	 	CHINA	
Tin	 	Gejiu Zili Mining And Metallurgy Co., Ltd.	 	CHINA	
Tin	 	Guanyang Guida Nonferrous Metal Smelting Plant	 	CHINA	
Tin	 	HuiChang Hill Tin Industry Co., Ltd.	 	CHINA	
Tin	 	Huichang Jinshunda Tin Co., Ltd.	 	CHINA	
Tin	 	Jiangxi Ketai Advanced Material Co., Ltd.	 	CHINA	
Tin	 	Linwu Xianggui Ore Smelting Co., Ltd.	 	CHINA	
Tin	 	Magnu’s Minerais Metais e Ligas Ltda.	 	BRAZIL	
Tin	 	Malaysia Smelting Corporation (MSC)	 	MALAYSIA	
Tin	 	Melt Metais e Ligas S/A	 	BRAZIL	
Tin	 	Metahub Industries Sdn. Bhd.	 	MALAYSIA	
Tin	 	Metallic Resources, Inc.	 	UNITED STATES	
Tin	 	Metallo-Chimique N.V.	 	BELGIUM	
Tin	 	Mineração Taboca S.A.	 	BRAZIL	
Tin	 	Minsur	 	PERU	
Tin	 	Mitsubishi Materials Corporation	 	JAPAN	
Tin	 	Nankang Nanshan Tin Manufactory Co., Ltd.	 	CHINA	
Tin	 	Nghe Tinh Non-Ferrous Metals Joint Stock Company	 	VIET NAM	
Tin	 	O.M. Manufacturing (Thailand) Co., Ltd.	 	THAILAND	
Tin	 	O.M. Manufacturing Philippines, Inc.	 	PHILIPPINES	
Tin	 	Operaciones Metalurgical S.A.	 	BOLIVIA	
Tin	 	Phoenix Metal Ltd.	 	RWANDA	
Tin	 	PT Alam Lestari Kencana	 	INDONESIA	
Tin	 	PT Aries Kencana Sejahtera	 	INDONESIA	
Tin	 	PT Artha Cipta Langgeng	 	INDONESIA	
Tin	 	PT ATD Makmur Mandiri Jaya	 	INDONESIA	
Tin	 	PT Babel Inti Perkasa	 	INDONESIA	
Tin	 	PT Bangka Kudai Tin	 	INDONESIA	
Tin	 	PT Bangka Prima Tin	 	INDONESIA	
Tin	 	PT Bangka Timah Utama Sejahtera	 	INDONESIA	

 

Tin	 	PT Bangka Tin Industry	 	INDONESIA	
Tin	 	PT Belitung Industri Sejahtera	 	INDONESIA	
Tin	 	PT BilliTin Makmur Lestari	 	INDONESIA	
Tin	 	PT Bukit Timah	 	INDONESIA	
Tin	 	PT Cipta Persada Mulia	 	INDONESIA	
Tin	 	PT DS Jaya Abadi	 	INDONESIA	
Tin	 	PT Eunindo Usaha Mandiri	 	INDONESIA	
Tin	 	PT Fang Di MulTindo	 	INDONESIA	
Tin	 	PT Inti Stania Prima	 	INDONESIA	
Tin	 	PT Justindo	 	INDONESIA	
Tin	 	PT Karimun Mining	 	INDONESIA	
Tin	 	PT Kijang Jaya Mandiri	 	INDONESIA	
Tin	 	PT Mitra Stania Prima	 	INDONESIA	
Tin	 	PT Panca Mega Persada	 	INDONESIA	
Tin	 	PT Pelat Timah Nusantara Tbk	 	INDONESIA	
Tin	 	PT Prima Timah Utama	 	INDONESIA	
Tin	 	PT Refined Bangka Tin	 	INDONESIA	
Tin	 	PT Sariwiguna Binasentosa	 	INDONESIA	
Tin	 	PT Seirama Tin Investment	 	INDONESIA	
Tin	 	PT Stanindo Inti Perkasa	 	INDONESIA	
Tin	 	PT Sukses Inti Makmur	 	INDONESIA	
Tin	 	PT Sumber Jaya Indah	 	INDONESIA	
Tin	 	PT Timah (Persero) Tbk Kundur	 	INDONESIA	
Tin	 	PT Timah (Persero) Tbk Mentok	 	INDONESIA	
Tin	 	PT Tinindo Inter Nusa	 	INDONESIA	
Tin	 	PT Tirus Putra Mandiri	 	INDONESIA	
Tin	 	PT Tommy Utama	 	INDONESIA	
Tin	 	PT Wahana Perkit Jaya	 	INDONESIA	
Tin	 	Resind Indústria e Comércio Ltda.	 	BRAZIL	
Tin	 	Rui Da Hung	 	TAIWAN	
Tin	 	Soft Metais Ltda.	 	BRAZIL	
Tin	 	Thaisarco	 	THAILAND	
Tin	 	Tuyen Quang Non-Ferrous Metals Joint Stock Company	 	VIET NAM	
Tin	 	VQB Mineral and Trading Group JSC	 	VIET NAM	
Tin	 	White Solder Metalurgia e Mineração Ltda.	 	BRAZIL	
Tin	 	Yunnan Chengfeng Non-ferrous Metals Co., Ltd.	 	CHINA	
Tin	 	Yunnan Tin Group (Holding) Company Limited	 	CHINA	
Tungsten	 	A.L.M.T. TUNGSTEN Corp.	 	JAPAN	
Tungsten	 	ACL Metais Eireli	 	BRAZIL	
Tungsten	 	Asia Tungsten Products Vietnam Ltd.	 	VIET NAM	
Tungsten	 	Chenzhou Diamond Tungsten Products Co., Ltd.	 	CHINA	

 

Tungsten	 	Chongyi Zhangyuan Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Dayu Jincheng Tungsten Industry Co., Ltd.	 	CHINA	
Tungsten	 	Dayu Weiliang Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Fujian Jinxin Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Ganxian Shirui New Material Co., Ltd.	 	CHINA	
Tungsten	 	Ganzhou Huaxing Tungsten Products Co., Ltd.	 	CHINA	
Tungsten	 	Ganzhou Jiangwu Ferrotungsten Co., Ltd.	 	CHINA	
Tungsten	 	Ganzhou Non-ferrous Metals Smelting Co., Ltd.	 	CHINA	
Tungsten	 	Ganzhou Seadragon W & Mo Co., Ltd.	 	CHINA	
Tungsten	 	Ganzhou Yatai Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Global Tungsten & Powders Corp.	 	UNITED STATES	
Tungsten	 	Guangdong Xianglu Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	H.C. Starck GmbH	 	GERMANY	
Tungsten	 	H.C. Starck Smelting GmbH & Co.KG	 	GERMANY	
Tungsten	 	Hunan Chenzhou Mining Co., Ltd.	 	CHINA	
Tungsten	 	Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji	 	CHINA	
Tungsten	 	Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin	 	CHINA	
Tungsten	 	Hunan Chunchang Nonferrous Metals Co., Ltd.	 	CHINA	
Tungsten	 	Hydrometallurg, JSC	 	RUSSIAN FEDERATION	
Tungsten	 	Japan New Metals Co., Ltd.	 	JAPAN	
Tungsten	 	Jiangwu H.C. Starck Tungsten Products Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Dayu Longxintai Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Gan Bei Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Xinsheng Tungsten Industry Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.	 	CHINA	
Tungsten	 	Jiangxi Yaosheng Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Kennametal Fallon	 	UNITED STATES	
Tungsten	 	Kennametal Huntsville	 	UNITED STATES	
Tungsten	 	Malipo Haiyu Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Moliren Ltd	 	RUSSIAN FEDERATION	
Tungsten	 	Niagara Refining LLC	 	UNITED STATES	
Tungsten	 	Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC	 	VIET NAM	
Tungsten	 	Philippine Chuangin Industrial Co., Inc.	 	PHILIPPINES	
Tungsten	 	Pobedit, JSC	 	RUSSIAN FEDERATION	
Tungsten	 	Sanher Tungsten Vietnam Co., Ltd.	 	VIET NAM	
Tungsten	 	Tejing (Vietnam) Tungsten Co., Ltd.	 	VIET NAM	
Tungsten	 	Vietnam Youngsun Tungsten Industry Co., Ltd.	 	VIET NAM	

 

Tungsten	 	Wolfram Bergbau und Hütten AG	 	AUSTRIA	
Tungsten	 	Woltech Korea Co., Ltd.	 	KOREA, REPUBLIC OF	
Tungsten	 	Xiamen Tungsten (H.C.) Co., Ltd.	 	CHINA	
Tungsten	 	Xiamen Tungsten Co., Ltd.	 	CHINA	
Tungsten	 	Xinhai Rendan Shaoguan Tungsten Co., Ltd.	 	CHINA	

 
ANNEX II

Countries (A-K)	 	Countries (L-Z)	
Angola*	 	Laos	
Argentina	 	Luxembourg	
Australia	 	Madagascar	
Austria	 	Malaysia	
Belgium	 	Mongolia	
Bolivia	 	Mozambique	
Brazil	 	Myanmar	
Burundi*	 	Namibia	
Cambodia	 	Netherlands	
Canada	 	Nigeria	
Central African Republic*	 	Peru	
Chile	 	Portugal	
China	 	Republic of Congo*	
Colombia	 	Russia	
Côte D’Ivoire	 	Rwanda*	
Czech Republic	 	Sierra Leone	
Democratic Republic of the Congo*	 	Singapore	
Djibouti	 	Slovakia	
Ecuador	 	South Africa	
Egypt	 	South Korea	
Estonia	 	South Sudan*	
Ethiopia	 	Spain	
France	 	Suriname	
Germany	 	Switzerland	
Guyana	 	Taiwan	
Hungary	 	Tanzania*	
India	 	Thailand	
Indonesia	 	Uganda*	
Ireland	 	United Kingdom	
Israel	 	United States	
Japan	 	Vietnam	
Kazakhstan	 	Zambia*	
Kenya	 	Zimbabwe	

*Covered Countries