Document





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
 

FORM SD
Specialized Disclosure Report
 

SUPER MICRO COMPUTER, INC.
(Exact name of registrant specified in its charter)
 



 
 
 
 
 
Delaware
 
001-33383
 
77-0353939
(State or other jurisdiction
of incorporation)
 
(Commission File Number)
 
(I.R.S. Employer
Identification No.)
980 Rock Avenue, San Jose, California
 
95131
(Address of principal executive offices)
 
(Zip Code)

Kevin Bauer, Senior Vice President, Chief Financial Officer, telephone: (408) 503-8000
(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, 2018.


  







Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report

Reasonable Country of Origin Inquiry:

Brief description of inquiry:

An analysis of our products was performed, on the basis of which we concluded that certain products contain one or more of the conflict minerals (defined below), which are necessary to their functionality or production. Therefore, the products that we manufacture or contract to manufacture are subject to the reporting obligations of Rule 13p-1 under the Securities Exchange Act of 1934. To satisfy the reasonable country of origin inquiry ("RCOI") requirement of the Conflict Minerals Rule adopted by the SEC under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”), Super Micro Computer, Inc. ("Supermicro" or "we") has, in good faith, surveyed our suppliers using the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template. The scope of the survey was to determine whether any of the conflict minerals (defined in Section 1502(e)(4) of the Act to include columbite-tantalite, cassiterite, wolframite and gold and their derivatives, which are limited to tin, tantalum, tungsten and gold) that are not from recycled or scrap sources originated in the Covered Countries, which include the Democratic Republic of the Congo (the “DRC”) or an adjoining country as defined in Section 1502(e)(1) of the Act. As part of the RCOI process, we have performed a scoping exercise to understand our supply chain including the relevant supplier and sub-supplier population and the products or components procured from such suppliers. We adopted a framework for evaluating responses from suppliers and identifying potential red flags in suppliers’ responses. We have also adopted a company level policy on conflict minerals which has been published on our website at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.

Based on the approach described above, we believe that we have conducted a good faith reasonable country of origin inquiry for the calendar year ended December 31, 2018. We have documented the performance of the RCOI and our analysis of the supplier responses and the scoping of our products and suppliers for our internal record keeping purposes.

Results of inquiry:

As of the date of this filing, based on the Conflict Minerals Reporting Template responses and an analysis of such responses, as it applies to the calendar year ended December 31, 2018, we cannot ascertain the source mine and country of origin of all of the relevant conflict minerals which are necessary to the functionality or production of our products.
Therefore, we proceeded to exercise due diligence on the source and chain of custody of conflict minerals, as described in the Conflict Minerals Report included as Exhibit 1.01 to this Form SD.

Due Diligence on the Source and Chain of Custody of Our Conflict Minerals:

We exercised due diligence on the conflict minerals' source and chain of custody following a nationally or internationally recognized due diligence framework. Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas (the "OECD Guidance"). We have adopted and communicated our conflict mineral policy to our suppliers and customers and implemented RCOI and Due Diligence procedures to collect additional information from our new and existing suppliers. In addition, we have established programs to encourage our suppliers to source their conflict minerals from certified conflict-free smelters.

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at https://ir.supermicro.com/financial-information/sec-filings.

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

The following exhibit is filed as part of this report:

Exhibit 1.01 -- Conflict Minerals Report for the calendar year ended December 31, 2018 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 duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
 
SUPER MICRO COMPUTER, INC.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
By:
 
/s/ Kevin Bauer
 
 
 
Date: May 31, 2019
 
 
Senior Vice President, CFO
 
 
 
 







EXHIBIT INDEX
 

 
 
 
Exhibit
Number
 
Description
 
 
1.01
 





Exhibit

Exhibit 1.01

Super Micro Computer, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2018

I. Introduction
This report for the year ended December 31, 2018 has been prepared pursuant to Rule 13p-1 and the Specialized Disclosure Report on Form SD ("Form SD") under the Securities Exchange Act of 1934 (collectively, the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").

If a registrant determines that conflict minerals are necessary to the functionality or production of products manufactured or contracted by the registrant to be manufactured, the registrant must submit a Form SD which describes the reasonable country of origin inquiry (“RCOI”) that it undertook to determine whether such necessary conflict minerals originated from the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”).

If, on the basis of its RCOI, a registrant knows or has reason to believe that any of the necessary conflict minerals in its supply chain may have originated in any of the Covered Countries and knows they are not, or has reason to believe that they may not be, from recycled or scrap sources, the issuer must exercise due diligence on the conflict minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.

This report has been prepared by Super Micro Computer, Inc. (herein referred to as “Super Micro” the “Company,” “we,” “us,” or “our”). The information contained in this report includes the activities of all of the Company's majority-owned subsidiaries and variable interest entities that are required to be consolidated. This Report has not been subject to an independent private sector audit.
II. Company Overview
We are a global leader in high-performance, high-efficiency server technology and innovation. We develop and provide end-to-end green computing solutions to the cloud computing, data center, enterprise IT, big data, HPC and embedded markets. Our solutions range from complete server, storage, blade and workstations to full racks, networking devices, server management software and technology support and services.

We conduct our operations principally from our headquarters in California and facilities of our subsidiaries in Taiwan, the Netherlands, China and Japan. We sell our server systems and subsystems and accessories through our direct sales force as well as through distributors and Original Equipment Manufacturers ("OEMs").
III. Supply Chain Overview
Our supply chain operations for our server products include sourcing, order management, manufacturing, delivery, and return. We procure server components from the following four major types of suppliers:
Manufacturers or direct suppliers;

Contract manufacturers producing items to match specifications and standards set by us;

Distributors or resellers of manufactured components for other manufacturers; and

Customers providing us certain parts and materials to be used to fulfill their orders.

Logistics and service providers were excluded from the reasonable country of origin inquiry ("RCOI") and due diligence measures discussed below because we have concluded that they do not provide us with any products within the scope of the Rule.

As explained further below, we rely upon our suppliers and third parties to provide information on the origin, source and chain of

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custody of the conflict minerals contained in product components and materials. We commenced conflict minerals due diligence in 2013.

Based on representations from these suppliers, we have determined that they obtain conflict minerals used in our products from the following types of processing facilities:

Tin, Tungsten, Tantalum - From smelters which procure the relevant ore and then pass it through smelting, as applicable.

Gold - From smelters/ refiners which either obtain gold from the mines or through recycling.
IV. Conflict Minerals Policy
We are committed to complying with Section 1502 of the Dodd-Frank Act and achieving the goal of confirming that the materials used in our products are procured from conflict-free sources. We have considered the Rule’s requirements and related guidance from the Organization for Economic Cooperation and Development (the “OECD”), and we expect our suppliers to comply with the Code of Conduct of the Responsible Business Electro Alliance (“RBA”) and conduct their business in accordance with our supply chain responsibility expectations, as documented in our Conflict Mineral Policy (the "CM Policy") at http://www.supermicro.com/about/policies/Supermicro_Conflict_Minerals_Statement.pdf.

In support of this policy, we expect to:

a.
Exercise due diligence about suppliers for products containing or suspected to contain conflict minerals, consistent with the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 3rd Edition and the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), as tailored to include steps appropriate for downstream companies, and encourage our suppliers to do likewise with their suppliers;
b.
Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm that the tantalum, tin, tungsten and gold in our supply chain are procured from conflict-free sources;
c.
Collaborate with our suppliers and others on industry-wide solutions through our membership in the Responsible Minerals Initiative (“RMI”) and participation in industry-wide conflict minerals forums to encourage the manufacture of products that do not directly or indirectly finance or benefit armed groups in the Covered Countries; and
d.
Require our suppliers to subscribe to and follow the RBA Code of Conduct.
V. Reasonable Country of Origin Inquiry
Our supply chain due diligence "scope of work" included our existing component suppliers that provide products and components that contain one or more 3TG minerals (collectively referred to as "In Scope Suppliers"). To help establish our supply chain sourcing programs, we have adopted the RMI’s Conflict Mineral Reporting Template ("CMRT") and launched a Reasonable Country of Origin (RCOI) survey using the CMRT for In Scope Suppliers, which suppliers represent 100% of our total 2018 product-related sourcing expenditures. We reviewed our In Scope Suppliers and categorized them into three tiers based on procurement value. We identified our top 17 suppliers by procurement value as the first tier, followed by the next top 66 suppliers as the second tier and the remaining 211 suppliers as the third tier. The suppliers in the first and second tiers accounted for 99% of our total 2018 product-related sourcing expenditures. The purpose for this classification was to facilitate a focused follow-up process with our suppliers in securing responses to the CMRT on a timely basis through appropriate allocation of resources. The percentage of CMRT received from our In Scope Suppliers during 2018 was 99% compared to 82% in 2017. We noted a 17% improvement in the response rate from our first two tiers of suppliers, and there was an increase of approximately 22% in responses from our third tier of suppliers. The data on which we relied to determine the country of origin of the minerals was obtained through our membership in the RMI.

After conducting our RCOI, we were unable to determine the country of origin for all of the conflict minerals contained in our products that are not from recycled or scrap sources. Given this result, we determined that the Rule requires us to exercise due diligence on the source and chain of custody of the conflict minerals contained in our products, using a framework that conforms to a nationally or internationally recognized due diligence framework.
VI. Due Diligence
a.
Due Diligence Framework
We have exercised due diligence on the source and chain of custody of the necessary conflict minerals used in our products to identify minerals originating from the Covered Countries that are not from scrap or recycled sources. The design of our due

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diligence processes has been developed to conform to the five-step framework proposed by the OECD Guidance and the related supplements for gold, tin, tantalum and tungsten. Given that we do not have a direct relationship with the smelters and refiners that process the conflict minerals that are present in our products, we rely on the RMI and other organizations to conduct third-party audits of smelters and refiners.

Our conflict minerals due diligence process includes:

Establishment of strong company management systems;

Identify and assess risks in the supply chain;

Design and implement a strategy to respond to identified risks;

Independent 3rd Party Audit of Smelter/Refiners Due Diligence Practices

Report annually on supply chain due diligence.
b.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of conflict minerals, we do not have direct relationships with smelters or refiners that produce the conflict minerals within our supply chain and the complexity of that supply chain limits our ability to directly obtain information about those producers of conflict minerals. Accordingly, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information, as well as our smelters, may yield inaccurate or incomplete information.
c.
Brief Description of Due Diligence Measures Taken
(i)
Establishment of Strong Company Management Systems:
We have established a management system for complying with applicable conflict minerals reporting and disclosure rules. Our management system includes the development of a Conflict Minerals Oversight Committee led by our Senior VP of Operations, Senior VP and Chief Financial Officer and Chief Compliance Officer, and a team of subject matter experts (Conflict Minerals Committee) is responsible for implementing our conflict minerals compliance policy and strategy. The Conflict Minerals Oversight Committee is briefed periodically about the results of our due diligence efforts and reports periodically to the Audit Committee of our Board of Directors.

We maintain our Conflict Minerals Policy that states our position on the use of conflict minerals. Our Conflict Minerals Policy has been communicated to all existing suppliers and was provided to new suppliers as part of our supplier "onboarding" process. We have provided training to our conflict mineral related team members. Additionally, our policy is prominently posted on our public facing website.

(ii)
Identification and Assessment of Risks in the Supply Chain:
We have made reasonable efforts to identify all In Scope Suppliers that supply products that may potentially contain conflict minerals by conducting a supply chain survey using the RMI CMRT; requesting our In Scope Suppliers to identify smelters and refiners and countries of origin of the conflict minerals in products they supply to us; following up with In Scope Suppliers that do not respond to the CMRT by requesting their responses; comparing smelters and refiners identified by our supply chain survey against the list of facilities that are identified by RMI as conformant with the Responsible Minerals Assurance Process (“RMAP”) assessment protocols, which list provides country of origin; and maintaining documentation of reasonable efforts we have made to identify and assess supply chain risks. We have also reviewed the responses to identify potential red flags for further follow-up.

(iii)
Strategic Response to Identified Risks:
We have implemented a risk mitigation response to monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Policy or contractual requirements to determine their progress in meeting those requirements. We will continuously make reasonable efforts to encourage suppliers who are sourcing from non-conflict-free smelters to move towards the use of conflict-free smelters. If a supplier fails to remedy the risks identified by our compliance risk assessment, we will escalate the matter to the Conflict Minerals Oversight Committee to determine whether to approve or reject the supplier based on the following factors: a cost and benefit analysis; evaluation of potential risk factors; any existing

3


competitive bids; and whether the supplier is a single source supplier to the Company. If the Oversight Committee decides to continue a business relationship with a non-compliant supplier due to inherent limitations of our supply chain, we will use reasonable efforts to follow up with the supplier for its correction plan, and encourage the supplier to work with smelters that are conformant with the RMAP assessment protocols. We also provide periodic compliance updates or reports to our Conflict Minerals Oversight Committee summarizing our risk mitigation efforts. Additionally, we have made updates to our policy to minimize the potential of onboarding any new suppliers who are not conformant with the RMAP assessment protocols, and thus not in alignment with our objective of sourcing from conflict-free suppliers.

(iv) Independent 3rd Party Audit of Smelter/Refiner’s Due Diligence Practices:
We do not have direct relationships with 3TG smelters and refiners, nor do we independently perform direct audits of these entities that provide the 3TG in our supply chain. As an alternative, we consider information collected and provided by independent third-party audit programs, such as RMAP and we rely upon industry efforts, including RMI’s, to influence smelters and refiners to voluntarily undergo the validation process under the RMAP. Additionally, we engaged a third party consultant with expertise in conflict minerals compliance to conduct an analysis of our conflict minerals program and activities. The consultant performed a gap analysis to identify areas for potential improvement in our program. We have updated our conflict minerals compliance plan based on the results of this analysis.

(v) Report Annually on Supply Chain Due Diligence
A Form SD and a Conflict Minerals Report as an exhibit thereto are filed annually with the SEC. The Form SD and Conflict Minerals Report are also available on our website at https://ir.supermicro.com/financial-information/sec-filings.

VII. Efforts to Determine the Mine or Location of Origin of the Conflict Minerals in Our Products and Facilities Used to Process the Conflict Minerals
The results of our RCOI and due diligence on the source and chain of custody of our necessary conflict minerals are the product of our iterative and escalating data collection and dialogue process with our In Scope Suppliers. This process is designed to obtain information regarding the smelters and refineries from which suppliers source such 3TG minerals and to confirm the status of such smelters or refineries as verified by the RMI as a method of assessing the mine and location of origin of such conflict minerals.

Based on the responses that we received from our suppliers, we identified 323 smelters and refineries as potential sources of 3TG minerals that were reported to be in our supply chain, of which 253 have been verified by the RMI to be conformant with the RMAP assessment protocols, and 9 are active (meaning they are in the process of being audited or have committed to the audit process). Table 1 below presents, by mineral, the total number of smelters and refineries identified and the percentage verified to be RMAP-conformant or in the RMI Verification Process. Year over year, the percentage of verified or in-process smelters has decreased from 87% to 81%. See Appendix I for a list, by name, of smelters and refiners verified as conformant with the RMAP assessment protocols.
Table 1 - Smelters and Refiners Verified as RMAP-Conformant or in the RMI Verification Process by Mineral.
 
Total Smelters and Refiners by Mineral
 
Number Verified or In Process
 
Percentage Verified or In Process
Gold
151

 
106

 
70
%
Tantalum
42

 
40

 
95
%
Tin
84

 
75

 
89
%
Tungsten
46

 
41

 
89
%
As to the remainder of the smelters and refineries that are not verified by the RMI, we were unable to determine the mines of origin or the minerals sourced from such smelters and refineries.

VIII. Due Diligence Process Improvement Efforts

Due to the level of complexity of our products and the respective supply chains and our position in these supply chains as a downstream company, it will take additional time and resources for a number of our suppliers to verify the source mines and country of origin of all of the minerals used by their smelters and refiners. We intend to take the following steps to continue to improve our due diligence measures and to further mitigate the risk that trade in the conflict minerals contained in our products could benefit armed groups in Covered Countries:

a.
Continuing to focus our efforts on collaborating with industry peers through our membership in the RMI to improve the systems of transparency and control in our supply chain, including through our use of the latest revision of the CMRT in connection with our RCOI of our supply chain.

b.
Continuing to partner with our In-Scope Suppliers and others on industry-wide solutions through our membership in RMI in an effort to collaboratively increase the number of verified smelters.

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c.
Enhancing our engagement with our relevant first-tier suppliers in order to further build their knowledge and capacity so they are able to provide more complete and accurate information on the source and chain of custody of conflict minerals in our supply chain. Selected suppliers who have demonstrated insufficient knowledge and sophistication related to CM compliance will be provided with CM training.
d.
Encouraging our supply chain to source conflict minerals from smelters that are conformant to the RMAP. Updates to the terms and conditions of our vendor/supplier documents and our supply chain policy will emphasize further to our supply chain (both existing and new suppliers), our goal of achieving a conflict-free supply chain.
e.
Continuing our work to refine the process for conducting follow-up with our surveyed suppliers to more effectively resolve unreasonable or illogical responses in their surveys. Additionally, we continue to refine the use of a specialized software tool to distribute the CMRT, receive responses, follow-up as needed, aggregate and analyze the data and product meaningful and actionable reports on our supply chain.

FORWARD LOOKING STATEMENTS
This Specialized Disclosure Report on Form SD and any exhibits hereto contain “forward-looking statements” about our plans, intentions, forecasts and other expectations concerning the Company's future actions to engage contract manufacturers, to identify to the extent possible the source of conflicts minerals in its products and to take other actions regarding its product sourcing The Company's actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties .. These forward-looking statements and other information are based on our beliefs as well as assumptions made by us using information currently available. In some cases, you can identify forward-looking statements by terminology including “would,” “could,” “may,” “will,” “should,” “expect,” “intend,” “plan,” “anticipate,” “believe,” “estimate,” “predict,” “potential,” or “continue,” the negative of these terms or other comparable terminology. Risks and uncertainties that could cause actual actions or results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for conflict minerals, the possibility of inaccurate information, fraud and other irregularities, inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers, third-party audit programs or others In addition, you should specifically consider various factors contained in our filings with the SEC, including those factors discussed under the caption “Risk Factors” in such filings. These factors may cause our actual results to differ materially from those anticipated or implied in the forward-looking statements. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report. We undertake no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.

DOCUMENTS INCORPORATED BY REFERENCE
Unless otherwise expressly stated herein, no documents, third-party materials or references to websites (including Super Micro's) are incorporated by reference in, or to be considered to be a part of, this Conflict Minerals Report.



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Appendix I
Smelters and Refineries
RMAP-Conformant
Metal
Smelter Name as Provided by Supplier
Country Location
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Aurubis AG
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY

A-1


Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION

A-2


Gold
PAMP S.A.
SWITZERLAND
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Royal Canadian Mint
CANADA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA

A-3


Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
T.C.A S.p.A
ITALY
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Marsam Metals
BRAZIL
Gold
SAAMP
FRANCE
Gold
Italpreziosi
ITALY
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Safimet S.p.A
ITALY
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
NPM Silmet AS
ESTONIA

A-4


Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA

A-5


Tin
Alpha
UNITED STATES OF AMERICA
Tin
CV Gita Pesona
INDONESIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
Dowa
JAPAN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Fenix Metals
POLAND
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Karimun Mining
INDONESIA

A-6


Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
PT Inti Stania Prima
INDONESIA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Tiga Sekawan
INDONESIA
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Metallo Belgium N.V.
BELGIUM

A-7


Tin
Metallo Spain S.L.U.
SPAIN
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Gejiu Jinye Mineral Company
CHINA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
PT Bangka Serumpun
INDONESIA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA

A-8


Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION

A-9


RMAP-Active (In the Verification Process)
Metal
Smelter Name as Provided by Supplier
Country Location
Gold
Chugai Mining
JAPAN
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
L'Orfebre S.A.
ANDORRA
Gold
Bangalore Refinery
INDIA
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA


Countries of origin of the conflict minerals these facilities process are believed to include: AUSTRALIA, AUSTRIA, BELGIUM, BOLIVIA (PLURINATIONAL STATE OF), BRAZIL, CANADA, CHILE, CHINA, ESTONIA, FRANCE, GERMANY, INDIA, INDONESIA, ITALY, JAPAN, KAZAKHSTAN, KOREA, REPUBLIC OF YRGYZSTAN, MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF, MALAYSIA, MEXICO, PERU,
PHILIPPINES, POLAND, RUSSIAN FEDERATION, SINGAPORE, SOUTH AFRICA, SPAIN, SWEDEN, SWITZERLAND, TAIWAN, PROVINCE OF CHINA, THAILAND, TURKEY, UNITED ARAB EMIRATES, UNITED STATES OF AMERICA, UZBEKISTAN, VIETNAM


A-10