United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Western Digital Corporation
(Exact name of registrant as specified in its charter)
| Delaware | 1-8703 | 33-0956711 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 3355 Michelson Drive, Suite 100 Irvine, California |
92612 | |
| (Address of principal executive offices) | (Zip Code) |
Michael C. Ray
Senior Vice President, General Counsel and Secretary
(949) 672-7000
(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, 2013. |
Section 1—Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Overview
Unless the context indicates otherwise, the terms “we,” “its,” “us” and “our” refer to Western Digital Corporation and its consolidated subsidiaries.
Our Conflict Minerals Policy
We strongly disapprove of the violence in the Democratic Republic of the Congo (the “DRC”) and adjoining countries and are committed to supporting responsible sourcing of Conflict Minerals (as defined below). We also take seriously our compliance obligations under Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). To these ends, we have adopted and communicated to our suppliers and the public a company policy regarding Conflict Minerals (the “Conflict Minerals Policy”) for our supply chain. As used herein, in the Conflict Minerals Policy and consistent with the Conflict Minerals Rule, “Conflict Minerals” are columbite-tantalite (coltan), cassiterite, gold and wolframite, and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals. The Conflict Minerals Policy contains our expectations that our suppliers:
| 1. | Supply materials to us that are “DRC conflict free;” the Conflict Minerals Policy indicates that this means (a) any Conflict Minerals necessary to the functionality and production of supplied materials do not directly or indirectly finance armed groups through mining or mineral trading in the DRC or an adjoining country, or (b) any Conflict Minerals in supplied materials are from recycled or scrap sources; and |
| 2. | Adopt policies with respect to Conflict Minerals in support of our Conflict Minerals Policy and, throughout the supply chain, to require their suppliers to adopt similar policies. |
Our focus on the responsible sourcing of Conflict Minerals began well in advance of the adoption of the Conflict Minerals Rule. We have been a member of the Electronic Industry Citizenship Coalition (“EICC”) since 2007. The EICC is an industry collaboration with a focus on improving working conditions and environmental stewardship throughout the electronics supply chain. Through EICC, we have worked with other companies in our industry to focus on the responsible sourcing of Conflict Minerals. In addition, we started communicating with suppliers on this subject in 2010.
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Applicability of the Conflict Minerals Rule to Our Company
We are a leading developer and manufacturer of data storage solutions that enable consumers, businesses, governments and other organizations to create, manage, experience and preserve digital content. Our principal products are hard disk drives that use one or more rotating magnetic disks to store and allow fast access to data. Our other products include solid-state drives, home entertainment products, personal cloud storage devices and software applications for smart phones and tablets.
We are subject to the Conflict Minerals Rule because products in the foregoing categories that we manufacture contain Conflict Minerals that are necessary to the functionality or production of the products. However, we do not directly source Conflict Minerals from mines, smelters or refiners, and we believe that we are in most cases many levels removed from these market participants. We therefore have limited influence over these upstream participants. Furthermore, because of the depth, geographic diversity and constant evolution of our supply chain, and due to competitive factors, we often have significant difficultly identifying participants upstream from our direct suppliers. Through the efforts described in this Form SD and the Conflict Minerals Report for the calendar year ended December 31, 2013 included as an exhibit hereto (the “Conflict Minerals Report”), we seek to ensure that our sourcing practices are consistent with the expectations provided in our Conflict Minerals Policy.
Reasonable Country of Origin Inquiry Information
In connection with the reasonable country of origin inquiry required by the Conflict Minerals Rule, our direct suppliers identified to us three smelters that processed necessary Conflict Minerals in our supply chain that we reasonably believe sourced only recycled or scrap content for at least part of 2013. The products that contained Conflict Minerals that we reasonably believe came from recycled or scrap sources also contained other Conflict Minerals for which we were not able to determine the origin.
For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures that we established for our due diligence. We designed our due diligence measures relating to Conflict Minerals to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013). For a discussion of the due diligence measures that we performed in respect of 2013, see the Conflict Minerals Report filed as an Exhibit to this Form SD.
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Website Disclosure
As required by the Conflict Minerals Rule, the foregoing information is available on our website at the following Internet address: http://investor.wdc.com/sec.cfm. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or our Conflict Minerals Report.
Conflict Minerals Report
As required by the Conflict Minerals Rule, a Conflict Minerals Report is provided as an Exhibit to this Form SD and is available at the following Internet address: http://investor.wdc.com/sec.cfm.
As indicated in the Conflict Minerals Report, for 2013, we were unable to determine the origin of at least a portion of the Conflict Minerals in each of our in-scope products. However, we have not found for 2013 that any of the necessary Conflict Minerals contained in our in-scope products directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. The terms “armed group” and “adjoining country” have the meanings contained in the Conflict Minerals Rule.
Item 1.02
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.02 to this Form SD.
Section 2—Exhibits
Item 2.01 Exhibits
| Exhibit 1.02 | – | Conflict Minerals Report for the calendar year ended December 31, 2013. | ||
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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 duly authorized undersigned.
| WESTERN DIGITAL CORPORATION | ||||||
| (Registrant) | ||||||
| By: | /s/ Michael C. Ray |
June 2, 2014 | ||||
| Name: | Michael C. Ray | |||||
| Title: | Senior Vice President, General Counsel and Secretary | |||||
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EXHIBIT INDEX
| Exhibit |
Description | |
| 1.02 | Conflict Minerals Report for the calendar year ended December 31, 2013. | |
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Exhibit 1.02
Conflict Minerals Report
Western Digital Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for 2013 as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is June 2, 2014.
Unless the context indicates otherwise, the terms “we,” “its,” “us” and “our” refer to Western Digital Corporation (“WDC”) and its consolidated subsidiaries. WDC is the parent company of our storage business, which operates under two independent subsidiaries – HGST and WD. As used herein and consistent with the Conflict Minerals Rule, “Conflict Minerals” 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.
For 2013, each of our in-scope products contained at least some Conflict Minerals content for which we were unable to determine the origin. Product, smelter and refiner information in respect of 2013 is described under “Product Information; Additional Risk Mitigation Efforts “ below and on Annex A. However, we have not found for 2013 that any of the necessary Conflict Minerals contained in our in-scope products directly or indirectly financed or benefitted armed groups in the Democratic Republic of the Congo (the “DRC”) or an adjoining country. The terms “armed group” and “adjoining country” have the meanings contained in the Conflict Minerals Rule.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary Conflict Minerals benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source Conflict Minerals, (3) internal and external resource constraints and (4) political and regulatory developments, whether in the DRC region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
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Due Diligence Program Design
Overview
We have designed our due diligence measures relating to Conflict Minerals to conform with, in all material respects, the criteria set forth in the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013) (the “OECD Guidance”).
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. This framework consists of the following elements:
| 1. | Establish strong company management systems (“Step One”); |
| 2. | Identify and assess risk in the supply chain (“Step Two”); |
| 3. | Design and implement a strategy to respond to identified risks (“Step Three”); |
| 4. | Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain (“Step Four”); and |
| 5. | Report on supply chain due diligence (“Step Five”). |
Our implementation of the OECD Guidance in respect of 2013 and thereafter is discussed separately in the sections below.
Due Diligence Program Execution
In furtherance of our Conflict Minerals due diligence, we performed the following due diligence measures in respect of the 2013 compliance period. This summary does not describe all of the measures that we took in furtherance of our Conflict Minerals Policy (as defined below) and Conflict Minerals compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. In addition, not all of the due diligence measures discussed below are expressly provided for in the OECD Guidance.
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| 1. | OECD Guidance Step One: “Establish strong company management systems” |
| a. | A team of senior staff under (i) the Senior Vice President, Chief Procurement Officer of WD, in respect of that subsidiary, and (ii) the Senior Vice President of Quality Assurance/CTS of HGST, in respect of that subsidiary, was responsible for the management and continued implementation of our Conflict Minerals compliance strategy. WD and HGST are operated as independent subsidiaries due to regulatory requirements. Procurement and Quality were represented on the working groups at each of WD and HGST. At the WDC level, the following functional areas were represented on the working group or otherwise involved with our compliance process: corporate compliance; financial reporting; internal audit; investor relations; and legal. |
| b. | Selected personnel at WD and HGST were educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. We also prepared an internal procedure document addressing certain aspects of our compliance program. This procedure document was communicated to the members of the working group. |
| c. | We utilized specialist outside counsel and other consultants to assist us with our compliance efforts. |
| d. | We had in place a policy regarding the responsible sourcing of Conflict Minerals (the “Conflict Minerals Policy”). The Conflict Minerals Policy continued to be posted on our website and distributed electronically to selected employees and suppliers. Our Conflict Minerals Policy is further described in the Form SD to which this Conflict Minerals Report is an exhibit. |
| e. | We determined to use the Conflict Minerals Reporting Template (the “Conflict Minerals Reporting Template”) developed by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“EICC/GeSI”) to identify smelters and refiners in our supply chain. The Conflict Minerals Reporting Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the Conflict Minerals Reporting Template contains questions about the origin of Conflict Minerals included in a company’s products, as well as its supplier due diligence. |
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| f. | We were, and continue to be, a member of the EICC and the Conflict-Free Sourcing Initiative (the “CFSI”). |
| g. | We established procedures to maintain business records relating to Conflict Minerals due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database. As part of these procedures, we began implementing a third-party information technology solution for managing supplier responses submitted on the Conflict Minerals Reporting Template. |
| h. | Certain of our forms of purchase order terms and conditions contained a requirement to comply with environmental specifications for materials, components and products, which specifically referenced Conflict Minerals compliance, and the EICC Code of Conduct, which references the responsible sourcing of minerals generally. |
| i. | We sent suppliers communications indicating our Conflict Minerals sourcing policy and third-party resources for additional information. With the communication, we also sent suppliers the Conflict Minerals Reporting Template. In addition, we reminded certain suppliers of our compliance expectations during supplier quarterly business reviews. |
| j. | We designated our third-party managed Ethics Hotline as the mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. |
| 2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” |
| a. | Inquiries were made of all direct suppliers that we believed were in-scope for 2013. These suppliers are referred to herein as the “Suppliers.” |
| b. | We requested by email that the Suppliers provide us with information concerning the usage and source of Conflict Minerals in our products and their related compliance efforts through the completion of a Conflict Minerals Reporting Template. We followed up by email or phone with all Suppliers that did not respond to the request within the specified time frame. At some of our business units, as part of the supplier on-boarding process, we required the completion of a Conflict Minerals Reporting Template or otherwise made inquiries concerning Conflict Minerals usage. |
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| c. | We reviewed the completed responses received from Suppliers based on an internally-approved written review criteria to identify incomplete responses, potential errors and inaccuracies. We followed up by email or phone with the Suppliers that submitted an incomplete response or a response that we concluded contained errors or inaccuracies or that otherwise provided a written response determined not to be suitable by us. We followed up with other Suppliers where deemed appropriate by us. |
| d. | To the extent that a completed response identified a smelter or refiner, we reviewed this information against the lists of conflict free and “active” smelters and refiners and country of origin information published by the CFSI, the London Bullion Market Association (“LBMA”), the Responsible Jewellery Council (“RJC”) and the Tungsten Industry – Conflict Minerals Council (“TI-CMC”). |
| e. | To the extent that a smelter or refiner identified by a Supplier was not certified as conflict free by an independent third-party, we consulted publicly available information to attempt to determine whether that smelter or refiner obtained Conflict Minerals from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. |
| 3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” |
| a. | Our Conflict Minerals compliance team reported the findings of its compliance efforts in respect of 2013 to (i) the Senior Vice President, Chief Procurement Officer of WD, in respect of that subsidiary, (ii) the Senior Vice President of Quality Assurance/CTS of HGST, in respect of that subsidiary, and (iii) for our Company as a whole, the General Counsel and the Audit Committee of the Board of Directors. |
| b. | To mitigate the risk that our necessary Conflict Minerals benefit armed groups, we intend to engage in the additional measures discussed under “Product Information; Additional Risk Mitigation Efforts” below. |
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| 4. | OECD Guidance Step Four: “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 utilized information made available by the CFSI, the LBMA and the RJC concerning independent third-party audits of smelters and refiners in order to determine whether the smelter or refiner was certified as conflict free. We also supported independent third-party audits by being a member of the CFSI.
| 5. | OECD Guidance Step 5: “Report on supply chain due diligence” |
We have filed a Form SD and this Conflict Minerals Report with the Securities and Exchange Commission and made available on our website the Form SD and this Conflict Minerals Report.
Product Information; Additional Risk Mitigation Efforts
We do not directly source Conflict Minerals from mines, smelters or refiners, and we believe that we are in most cases many levels removed from these market participants. We therefore have limited influence over these upstream participants. Furthermore, because of the depth, geographic diversity and constant evolution of our supply chain, and due to competitive factors, we often have significant difficultly identifying participants upstream from our direct suppliers. Due to these challenges of tracing a multi-tier supply chain, for 2013, we were unable to determine the origin of at least a portion of the Conflict Minerals in each of our in-scope products.
For 2013, our in-scope product categories were: (1) hard disk drives; (2) solid-state drives; (3) home entertainment products, which include media players; and (4) personal cloud storage devices. For a further discussion of our products, see our Annual Report on Form 10-K for the fiscal year ended June 28, 2013. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report and should not be considered part of this Conflict Minerals Report.
We have not found for 2013 that any of our in-scope products supported conflict (i.e., contained necessary Conflict Minerals that directly or indirectly financed or benefitted an armed group in the DRC or an adjoining country). An “armed group” under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to the DRC or an adjoining country.
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In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the facilities listed on Annex A as having processed the necessary Conflict Minerals contained in our in-scope products in 2013. Due to our position in the supply chain, which is discussed above, we rely on our Suppliers for accurate smelter and refiner information and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary Conflict Minerals contained in our in-scope products.
The countries of origin of the Conflict Minerals processed by the certified smelters and refiners listed on Annex A may have included the countries listed below. The listed countries of origin are derived from information made available by the CFSI to its members. Except for the DRC, the CFSI does not indicate individual countries of origin of the Conflict Minerals processed by certified smelters and refiners. Instead, the CFSI indicates country of origin by category. Certified smelters and refiners listed on Annex A were in each of the categories below:
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of from these regions of tin/tantalum/tungsten containing minerals: Argentina, Australia, Austria, Belgium, Brazil, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, India, Indonesia, Ireland, Israel, Japan, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Russian Federation, Sierra Leone, Singapore, Suriname, Switzerland, Thailand, United Kingdom, United States and Zimbabwe.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing Conflict Minerals: Kenya, Mozambique and South Africa.
L3 – The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC – The Democratic Republic of the Congo.
Because the CFSI generally does not indicate individual countries of origin of the Conflict Minerals processed by certified smelters and refiners, we were not able to determine the countries of origin of the Conflict Minerals processed by the listed certified smelters and refiners with greater specificity. In addition, for some of the listed certified smelters and refiners, origin information is not disclosed. We did not determine the countries of origin of the Conflict Minerals processed by other smelters and refiners listed on Annex A.
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Conflict Minerals from recycled or scrap sources are discussed separately in the Form SD to which this Conflict Minerals Report is an exhibit.
We endeavored to determine the mine or location of origin of the Conflict Minerals contained in our in-scope products by requesting that the Suppliers provide us with a completed Conflict Minerals Reporting Template. Where a smelter or refiner was identified, we also reviewed publicly available information and information made available by the CFSI, the LBMA, the RJC and the TI-CMC, to the extent available, to try to determine the mine or location of origin.
Risk Mitigation Efforts After December 31, 2013
Since the end of 2013, we have taken the following additional steps to mitigate the risk that the necessary Conflict Minerals in our in-scope products benefit armed groups:
| 1. | With assistance from outside consultants, we prepared written procedures to support our 2014 reasonable country of origin inquiry and due diligence processes. |
| 2. | In certain cases, we engaged with certain suppliers and directed them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
We intend to take the following additional steps in 2014 to mitigate the risk that the necessary Conflict Minerals in our in-scope products benefit armed groups:
| 1. | Train relevant personnel on our newly-adopted written procedures that were prepared to support our 2014 reasonable country of origin and due diligence inquiries. |
| 2. | Continue to implement at the business unit level procedures to maintain business records relating to Conflict Minerals due diligence, including records of due diligence processes, findings and resulting decisions, on a computerized database. |
| 3. | Develop procedures for monitoring and reporting on risk to designated senior management on an ongoing basis. |
| 4. | Encourage Suppliers that provided company, division or product category level information for 2013 to provide product level information for 2014 through ongoing outreach with these Suppliers. |
| 5. | Engage with Suppliers that provided incomplete responses or that did not provide responses for 2013 to help ensure that they provide requested information for 2014. |
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| 6. | Monitor and encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2013 that the source of Conflict Minerals was unknown or undeterminable. |
| 7. | Communicate to new potentially in-scope suppliers our sourcing expectations, including through the dissemination of our Conflict Minerals Policy to them. In addition, as new in-scope suppliers are added, work with these suppliers to help ensure that they understand the requirements of the Conflict Minerals Rule and the OECD Guidance. |
| 8. | Communicate to stakeholders the availability of our Ethics Hotline for reporting violations of the Conflict Minerals Policy. |
All of the foregoing steps are in addition to the steps that we took in respect of 2013, which we intend to continue to take in respect of our 2014 compliance to the extent applicable.
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Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
In connection with our due diligence, the Suppliers identified to us the smelters and refiners listed below as having processed the necessary Conflict Minerals contained in our in-scope products in 2013. Please see the notes that accompany the table for important information concerning the data in the table.
Smelter and Refiner Information(1)
| Metal |
Name of Smelter or Refiner |
Smelter or Refiner Status | ||
| Gold |
Allgemeine Gold- und Silberscheideanstalt A.G. | Certified | ||
| Gold |
Argor-Heraeus SA | Certified | ||
| Gold |
Asahi Pretec Corporation | Certified | ||
| Gold |
CCR Refinery – Glencore Canada Corporation / Xstrata Canada Corporation | Certified | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Certified | ||
| Gold |
Dowa | Certified | ||
| Gold |
Eco-System Recycling Co., Ltd. | Certified | ||
| Gold |
Heimerle + Meule GmbH | Certified | ||
| Gold |
Heraeus Ltd. Hong Kong | Certified | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG | Certified | ||
| Gold |
Ishifuku Metal Industry Co., Ltd | Certified | ||
| Gold |
Japan Mint | Certified | ||
| Gold |
Jiangxi Copper Company Limited | Certified | ||
| Gold |
Johnson Matthey Inc | Certified | ||
| Gold |
Johnson Matthey Ltd | Certified | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. | Certified | ||
| Gold |
Kennecott Utah Copper LLC | Certified | ||
| Gold |
Kojima Chemicals Co., Ltd | Certified | ||
| Gold |
LS-Nikko Copper Inc. | Certified | ||
| Gold |
Materion | Certified | ||
| Gold |
Matsuda Sangyo Co., Ltd. | Certified | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd | Certified | ||
| Gold |
Metalor Technologies SA | Certified | ||
| Gold |
Metalor USA Refining Corporation | Certified | ||
| Gold |
Mitsubishi Materials Corporation | Certified | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | Certified |
A-1
| Gold |
Navoi Mining and Metallurgical Combinat | Certified | ||
| Gold |
Nihon Material Co. LTD | Certified | ||
| Gold |
Ohio Precious Metals, LLC | Certified | ||
| Gold |
Rand Refinery (Pty) Ltd | Certified | ||
| Gold |
Royal Canadian Mint | Certified | ||
| Gold |
SEMPSA Joyería Platería SA | Certified | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co. Ltd | Certified | ||
| Gold |
Solar Applied Materials Technology Corp. | Certified | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. | Certified | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K. | Certified | ||
| Gold |
The Refinery of Shandong Gold Mining Co. Ltd | Certified | ||
| Gold |
Tokuriki Honten Co., Ltd | Certified | ||
| Gold |
Umicore SA Business Unit Precious Metals Refining | Certified | ||
| Gold |
United Precious Metal Refining, Inc. | Certified | ||
| Gold |
Valcambi SA | Certified | ||
| Gold |
Western Australian Mint trading as The Perth Mint | Certified | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Certified | ||
| Gold |
Aida Chemical Industries Co. Ltd. | On Standard List | ||
| Gold |
Asaka Riken Co Ltd | On Standard List | ||
| Gold |
Caridad | On Standard List | ||
| Gold |
Chugai Mining | On Standard List | ||
| Gold |
Daejin Indus Co. Ltd | On Standard List | ||
| Gold |
DaeryongENC | On Standard List | ||
| Gold |
Do Sung Corporation | On Standard List | ||
| Gold |
FSE Novosibirsk Refinery | On Standard List | ||
| Gold |
Hwasung CJ Co. Ltd | On Standard List | ||
| Gold |
Korea Metal Co. Ltd | On Standard List | ||
| Gold |
Sabin Metal Corp. | On Standard List | ||
| Gold |
SAMWON METALS Corp. | On Standard List | ||
| Gold |
So Accurate Group, Inc. | On Standard List | ||
| Gold |
The Great Wall Gold and Silver Refinery of China | On Standard List | ||
| Gold |
Tongling nonferrous Metals Group Co.,Ltd | On Standard List | ||
| Gold |
Torecom | On Standard List | ||
| Gold |
YAMAMOTO PRECIOUS METAL CO., LTD. | On Standard List | ||
| Gold |
Yokohama Metal Co Ltd | On Standard List | ||
| Tantalum |
Exotech Inc. | Certified | ||
| Tantalum |
F&X Electro-Materials Ltd. | Certified | ||
| Tantalum |
Global Advanced Metals | Certified | ||
| Tantalum |
H.C. Starck GmbH | Certified |
A-2
| Tantalum |
Hi-Temp | Certified | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. / JiuJiang Tanbre Co.Ltd. | Certified | ||
| Tantalum |
Kemet Blue Powder | Certified | ||
| Tantalum |
Mitsui Mining & Smelting | Certified | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | Certified | ||
| Tantalum |
Plansee | Certified | ||
| Tantalum |
Solikamsk Magnesium Works OAO | Certified | ||
| Tantalum |
Taki Chemicals | Certified | ||
| Tantalum |
Ulba | Certified | ||
| Tantalum |
Zhuzhou Cement Carbide | Certified | ||
| Tin |
Alpha | Certified | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co. Ltd. | Certified | ||
| Tin |
Malaysia Smelting Corporation (MSC) | Certified | ||
| Tin |
Mineração Taboca S.A. | Certified | ||
| Tin |
Minsur | Certified | ||
| Tin |
Mitsubishi Materials Corporation | Certified | ||
| Tin |
OMSA | Certified | ||
| Tin |
PT Bukit Timah | Certified | ||
| Tin |
PT Tambang Timah | Certified | ||
| Tin |
PT Timah | Certified | ||
| Tin |
Thaisarco | Certified | ||
| Tin |
White Solder Metalurgia e Mineração Ltda. | Certified | ||
| Tin |
Yunnan Tin Company, Ltd. | Certified | ||
| Tin |
China Tin Group Co., Ltd. | Active | ||
| Tin |
Cooper Santa | Active | ||
| Tin |
CV United Smelting | Active | ||
| Tin |
PT Bangka Putra Karya | Active | ||
| Tin |
PT Eunindo Usaha Mandiri | Active | ||
| Tin |
PT REFINED BANGKA TIN | Active | ||
| Tin |
PT Stanindo Inti Perkasa | Active | ||
| Tin |
Rui Da Hung | Active | ||
| Tin |
Soft Metais, Ltda. | Active | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | Active | ||
| Tin |
CNMC (Guangxi) PGMA Co. Ltd. | On Standard List | ||
| Tin |
CV Serumpun Sebalai | On Standard List | ||
| Tin |
EM Vinto | On Standard List | ||
| Tin |
Fenix Metals | On Standard List | ||
| Tin |
Gejiu Zi-Li | On Standard List | ||
| Tin |
Huichang Jinshunda Tin Co. Ltd | On Standard List | ||
| Tin |
Jiangxi Nanshan | On Standard List |
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| Tin |
Metallo Chimique | On Standard List | ||
| Tin |
Minmetals Ganzhou Tin Co. Ltd. | On Standard List | ||
| Tin |
Novosibirsk Integrated Tin Works | On Standard List | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | On Standard List | ||
| Tin |
PT Artha Cipta Langgeng | On Standard List | ||
| Tin |
PT Babel Inti Perkasa | On Standard List | ||
| Tin |
PT Belitung Industri Sejahtera | On Standard List | ||
| Tin |
PT DS Jaya Abadi | On Standard List | ||
| Tin |
PT Mitra Stania Prima | On Standard List | ||
| Tin |
PT Sariwiguna Binasentosa | On Standard List | ||
| Tin |
PT Tinindo Inter Nusa | On Standard List | ||
| Tungsten |
A.L.M.T. Corp. | Certified | ||
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd. | Certified | ||
| Tungsten |
Ganzhou Grand Sea W & Mo Group Co Ltd | Certified | ||
| Tungsten |
Global Tungsten & Powders Corp | Certified | ||
| Tungsten |
H.C. Starck Group | Certified | ||
| Tungsten |
Hunan Chenzhou Mining Group Co., Ltd. | Certified | ||
| Tungsten |
Kennametal Huntsville | Certified | ||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. | Certified | ||
| Tungsten |
Wolfram Bergbau und Hütten AG | Certified | ||
| Tungsten |
Wolfram Company CJSC | Certified | ||
| Tungsten |
Xiamen Tungsten Co., Ltd | Certified | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co. Ltd. | Active | ||
| Tungsten |
Guangdong Xianglu Tungsten Industry Co., Ltd. | Active | ||
| Tungsten |
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | Active | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | On Standard List | ||
| Tungsten |
Ganzhou Nonferrous Metals Smelting Co Ltd. | On Standard List | ||
| Tungsten |
Japan New Metals Co., Ltd. | On Standard List | ||
| Tungsten |
Zhuzhou Cemented Carbide Group Co Ltd | On Standard List |
| (1) | We note the following in connection with the information contained in the foregoing table: |
| (a) | The smelters and refiners listed in the table were identified by the Suppliers to us as part of our 2013 supply chain. However, not all of the included smelters and refiners may have processed the necessary Conflict Minerals contained in our in-scope products, since, in some cases, Suppliers may have reported to us smelters and refiners that were not in our supply chain, due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners reflected above may not be all of the smelters and refiners in our supply chain, since the Suppliers were unable to identify the smelters and refiners of some of the necessary Conflict Minerals content contained in our in-scope products and because not all Suppliers responded to our inquiries. |
| (b) | The table only includes entities that were listed as smelters or refiners by an independent third-party. |
| (c) | Smelter or refiner status information in the table is as of May 20, 2014. |
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| (d) | “Certified” means that a smelter or refiner is listed as compliant with the Conflict-Free Smelter Program’s (“CFSP”) assessment protocols, including through mutual recognition, or is classified as “Re-audit in process” by the CFSP. Included smelters and refiners were not necessarily Certified for all or part of 2013 and may not continue to be Certified for any future period. We do not have information on the origin of the Conflict Minerals processed by any of the Certified smelters and refiners prior to their respective certification dates. |
| (e) | “Active” is a CFSI designation that means that the smelter or refiner is listed 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 CFSP, the smelter has agreed to complete a CFSP validation within two years of membership issuance by the TI – CMC. |
| (f) | Smelter or refiner status reflected in the table is based solely on information made publicly available by the CFSI, LBMA, RJC and/or TI-CMC, without independent verification by us. |
| (g) | “On Standard List” means that a smelter or refiner is listed on the CFSI Dashboard, but is not listed as “Certified” or “Active.” |
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