EXHIBIT 1.01
Conflict Minerals Report of First Solar, Inc.
For the Reporting Period from January 1 to December 31, 2017
Introduction
First Solar, Inc., together with its consolidated subsidiaries (“First Solar,” “the Company,” “we,” “us,” and “our”), has prepared this Conflict Minerals Report pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and the requirements of Form SD (collectively, “the Rules”).
We are a leading global provider of comprehensive photovoltaic (“PV”) solar energy solutions. We design, manufacture, and sell PV solar modules with an advanced thin film semiconductor technology and also develop, design, construct, and sell PV solar power systems that primarily use the modules we manufacture. Additionally, we provide operations and maintenance (“O&M”) services to system owners. We have substantial, ongoing research and development efforts focused on module and system-level innovations. We are the world’s largest thin film PV solar module manufacturer and one of the world’s largest PV solar module manufacturers. Our mission is to provide cost-advantaged solar technology through innovation, customer engagement, industry leadership, and operational excellence.
We operate our business in two segments:
• | Modules Segment – Our modules segment involves the design, manufacture, and sale of cadmium telluride solar modules, which convert sunlight into electricity. Third-party customers of our modules segment include integrators and operators of PV solar power systems. |
• | Systems Segment – Our fully integrated systems segment provides complete turn-key PV solar power systems, or solar solutions, that draw upon our capabilities, which include (i) project development, (ii) engineering, procurement, and construction (“EPC”) services, and (iii) O&M services. We may provide our full EPC services or any combination of individual products and services within our EPC capabilities depending upon the customer and market opportunity. All of our systems segment products and services are for PV solar power systems, which primarily use our solar modules, and we sell such products and services to utilities, independent power producers, commercial and industrial companies, and other system owners. Additionally, within our systems segment, we may temporarily own and operate certain of our systems for a period of time based on strategic opportunities or market factors. |
Minerals including tantalum, tin, tungsten, and gold (“3TG”) are classified as “conflict minerals” and are necessary to the functionality or production of certain products that we manufacture or contract to manufacture. As such, we are subject to the Rules with respect to those necessary conflict minerals. The Rules require us to conduct in good faith a reasonable country of origin inquiry (“RCOI”) into those necessary conflict minerals to determine whether they originated in the Democratic Republic of Congo (“DRC”) or an adjoining country (“a covered country” and together, the “covered countries”) or are from recycled or scrap sources. If, as a result of our RCOI procedures, we know or have reason to believe that any of our necessary conflict minerals originated in a covered country and are not from recycled or scrap materials, then we are required to exercise due diligence to determine the source and chain of custody of such conflict minerals.
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First Solar Conflict Minerals Policy
To the extent we source minerals from the covered countries, we are dedicated to protecting and respecting human rights by responsibly sourcing such minerals. We have a long-standing commitment to conducting our business in compliance with applicable laws and regulations. First Solar condemns human rights abuses associated with the extraction, transport, or trade of minerals. Similarly, First Solar has a no tolerance policy with respect to corruption, money-laundering, or bribery. We require all direct suppliers to agree to follow such principles.
At the same time, First Solar supports sourcing from the covered countries when performed in accordance with accepted international standards, specifically within the guidance from the Organisation for Economic Co-operation and Development (“OECD”). Suppliers with minerals not found to be DRC conflict free in their sourcing will be given a reasonable amount of time to begin sourcing minerals responsibly and in a manner consistent with the principles of responsible sourcing from conflict-affected areas.
Description of Product Identification and RCOI Processes
We have concluded that, during 2017, we manufactured and contracted to manufacture products containing certain conflict minerals. As such, we conducted a RCOI process to determine whether any of the conflict minerals originated, or may have originated, in the covered countries and whether such conflict minerals originated from recycled or scrap sources.
We conducted an assessment to determine which of our direct suppliers may be providing components of our products that are likely to contain conflict minerals. We employed a collaborative process to identify the applicable list of components and suppliers to focus our efforts, consulting with members of our supply chain department, including commodity managers, suppliers, senior management, and other individuals familiar with our manufacturing, solar plant sourcing, and construction processes. We verified with such personnel that the population of components and suppliers was complete and comprehensive for our 2017 procedures. We then identified the list of suppliers that we directly procured materials from (“tier one” or “direct” suppliers) to survey. These tier one suppliers were confirmed to have supplied products or components to us that contained conflict minerals between January 1, 2017 and December 31, 2017.
Accordingly, we reached the following conclusions for our business segments:
• | Modules Segment – We consider the majority of the parts and components that go into the manufacturing of our thin film solar modules to be subject to the Rules, and such items are included in our RCOI procedures. |
• | Systems Segment – We consider our systems segment to be primarily a service, and not a “product” under the Rules. With the exception of solar modules, we do not manufacture the majority of the parts or components used in the balance of our systems. For those parts and components that we purchase, we generally do not exert design or material specification influence over such items, nor are the items engineered to our specifications. As such, the majority of our balance of system parts and components used within our systems segment are not subject to the Rules. However, there are a limited number of parts and components in our systems segment that we have determined to be subject to the Rules, and such items are included in our RCOI procedures. |
Results
Leveraging the Responsible Minerals Initiative’s (“RMI”) (previously known as the Conflict-Free Sourcing Initiative) Conflict Minerals Reporting Template (“CMRT”), our RCOI consisted of surveying tier one suppliers confirmed to have supplied products that contained conflict minerals that were either used to manufacture solar modules or contracted for the manufacturing of our balance of system components. This template includes information regarding the smelters,
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origins of conflict minerals, supplier due diligence programs, and whether the materials originate from recycled or scrap sources.
As part of reviewing the completed CMRT surveys, we assessed the responses for reasonableness by comparing them to prior year information and reviewing the completeness of current year surveys provided. Incomplete CMRT surveys were rejected back to the suppliers. For non-responsive suppliers, we have internal escalation procedures, which escalate to more senior members of our global supply chain organization depending on certain milestones within our RCOI timeline. For the suppliers that we considered to be applicable to the Rules, we received a 100% response rate after following our internal procedures.
Our tier one suppliers performed similar RCOI procedures to identify the chain of custody from their suppliers back to the smelter and country of origin. We relied on the good faith efforts of our tier one suppliers to provide us with reasonable information and representations relating to the smelter and country of origin. The smelter or refiner facilities that were used to process our necessary conflict minerals are contained in Appendix A. See “Smelter and Refiner Facilities” below for more detail regarding the information contained in Appendix A.
We received completed surveys from all suppliers included in the procedures outlined above and reached the following conclusions:
• | Modules Segment – 83% of our applicable suppliers support our modules segment. The applicable survey results showed that tin is the only conflict mineral included in our solar module materials. |
• | Systems Segment – 17% of our applicable suppliers support our systems segment. The applicable survey results showed that tin is the primary conflict mineral included in our balance of systems parts. Additionally, tungsten, tantalum, and gold are contained in our tracker systems, which contain an electrical gateway, controller, and other parts that support the functionality to follow the sun’s irradiance throughout the day. |
Based on the RCOI conducted for both business segments, we have reason to believe that a portion of our necessary conflict minerals originated or may have originated in the covered countries and such necessary conflict minerals may not be from recycled or scrap sources. Based on this result, we exercised due diligence to determine the source and chain of custody of such conflict minerals as described below.
Framework Used to Develop Due Diligence Measures
In accordance with the Rules, we undertook due diligence efforts to determine the country, mine, or location of origin and facilities used to produce the conflict minerals used in our products. We have designed our due diligence measures to conform in all material respects with the internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”) and related supplements for 3TG.
Due Diligence Undertaken to Comply with the OECD Framework
Our due diligence process for 2017 included the following steps:
OECD Step 1: Establish a Company Management System
• | We have adopted and communicated our conflict minerals policy both publicly and to relevant internal and external parties. |
• | Our conflict minerals policy is available at www.firstsolar.com/-/media/First-Solar/Sustainability-Documents/FS-Mineral-Policy.ashx. Our conflict minerals policy is not incorporated herein by reference. |
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• | Beginning in September 2013, we adopted conflict minerals compliance language in any new supplier agreements and purchase order terms and conditions. |
• | We have an operating cross-functional internal governance team with representatives from our supply chain, legal, sustainability, and finance departments to ensure policy statements and control processes are followed. |
• | We have an existing records retention process and grievance mechanism for reporting policy violations via our Ethics Hotline. |
OECD Step 2: Identify and Assess Risks in Supply Chain
• | We conducted our surveys leveraging the CMRT, which was sent to all suppliers considered to be subject to the Rules. We used the CMRT to identify smelter or refiner facilities and countries of origin of our necessary conflict minerals. |
• | We relied on RMI information and other information provided by our suppliers to identify countries of origin for Responsible Minerals Assurance Program (“RMAP”) (previously known as Conflict-Free Smelter Program) compliant smelter or refiner facilities. |
• | We reviewed the responses from the CMRT questionnaires with our supply chain department cross-checking the list of RMAP facilities found at www.responsiblemineralsinitiative.org, which website is not incorporated by reference herein. |
OECD Step 3: Design and Implement a Strategy to Respond to Risk
• | We reported information on the source and chain of custody of our necessary conflict minerals to our conflict minerals steering committee, executive management, and the audit committee of our board of directors on a periodic basis. |
• | As part of our internal conflict minerals policy, we have a conflict minerals risk mitigation plan that defines supplier-risk management strategies, including (i) continued procurement, (ii) assistance in identifying alternate sources of supply, and (iii) disengagement, the severity of which is at the discretion of our conflict minerals steering committee and executive management. |
OECD Step 4: Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
• | As we do not source directly from smelter or refiner processing facilities, we rely on the RMAP to oversee and coordinate third-party audits of these facilities. The RMAP audit protocols and procedures were designed by the RMI. These audit protocols and procedures require the smelters or refiners to engage specially trained third-party auditors to independently verify that these smelters and refiners can be considered conflict free. |
• | We rely on the publicly available audit results of the RMAP third-party audits to validate the sourcing practices of processing facilities in our supply chain. |
OECD Step 5: Report Annually on Supply Chain Due Diligence
• | We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission on an annual basis, as necessary. Our Form SD and Conflict Minerals Report are also available on our website at investor.firstsolar.com/financial-information/sec-filings. |
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Smelter and Refiner Facilities
In connection with our RCOI and due diligence efforts, our suppliers provided us with lists of facilities that may have processed the necessary conflict minerals used in our products during 2017. Such facility information is included in Appendix A and summarized in the following tables.
i) Overall results breakdown by business unit:
Business Unit | Number of Suppliers | Percentage | ||||
Modules | 10 | 83 | % | |||
Systems | 2 | 17 | % | |||
Total | 12 | 100 | % |
ii) Facilities breakdown by minerals:
Minerals | Number of Smelters or Refiners | Percentage | ||||
Gold | 136 | 52 | % | |||
Tantalum | 20 | 8 | % | |||
Tin | 85 | 33 | % | |||
Tungsten | 18 | 7 | % | |||
Total | 259 | 100 | % |
iii) Facilities breakdown by RMAP status:
RMAP Status (as of April 24, 2018) | Number of Smelters or Refiners | Percentage | ||||
RMAP conformant | 201 | 78 | % | |||
Active smelters and refiners | 6 | 2 | % | |||
Known | 52 | 20 | % | |||
Total | 259 | 100 | % |
The total number of facilities identified excluded the following entities, because each has been determined by the RMAP to be a downstream processing facility of a smelter or refiner and is therefore ineligible to participate in the RMAP.
Conflict Mineral | Smelter or Refiner Name | Smelter Location | Suppliers | Covered Products | ||||
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China | Amphenol Corporation | Modules | ||||
Tin | VQB Mineral and Trading Group JSC | Vietnam | General Cable Corporation | Modules | ||||
Tin | VQB Mineral and Trading Group JSC | Vietnam | Amphenol Corporation | Modules |
Due Diligence Efforts to Identify Country, Location, and Mine of Origin of Conflict Minerals in Products
After obtaining CMRT forms and related documentation through our RCOI and due diligence processes as described above, we compared the smelters and refiners used by relevant suppliers against the list of smelters and refiners from the RMAP (www.responsiblemineralsinitiative.org), which website is not incorporated by reference herein, as well as responses in the CMRT to gather the country, location, and mine of origin information. In addition, for smelters not certified under the RMAP (referred to as “known”), we obtained written representations regarding the chain of custody and origin of such minerals smelted in order to identify the mine or location of origin with the greatest amount of specificity possible.
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We endeavored to determine the mine or location of origin of the necessary conflict minerals contained in our products through our CMRT responses. Where a smelter or refiner was identified, we reviewed public information, to the extent available, in an attempt to determine the mine or location of origin. Some of our suppliers reported such location of origin information within their CMRT responses. The majority of our smelters reported to be sourcing from L1 countries or from recycled or scrap sources.
The countries of origin of the conflict minerals processed by the RMAP compliant and active smelters or refiners identified to us by our suppliers may have included the countries identified below:
L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export from these regions of conflict minerals:
• | Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, the United Kingdom, the United States, Vietnam, 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. |
DRC – The smelter is sourcing from the Democratic Republic of the Congo.
Some of the conflict minerals processed by our RMAP compliant and active smelters or refiners may have originated in whole or in part from recycled or scrap sources.
Continuous Improvement Efforts to Mitigate Risk
We intend to advance the effectiveness of our due diligence efforts, further enhance our compliance processes, and mitigate any risk that the necessary conflict materials used in our products may benefit armed groups by taking the following steps:
1) | Engage further with direct suppliers and processing facilities to: |
• | Improve the quality of processing facility data provided by our direct suppliers via the CMRT, including country of origin and mine or location of origin, and |
• | Encourage non-RMAP validated processing facilities to become validated either through the RMAP or a RMAP-recognized third-party audit program. |
2) | Continue to require conflict minerals compliance language in our supplier agreements and refine our internal operating procedures to continue to move towards a “DRC conflict free” supply chain across all business segments. |
3) | Continue to monitor and track the RCOI and due diligence progress of our non-RMAP suppliers, including the usage of smelters and refiners that have been certified by the RMAP. |
4) | Require periodic supplier re-certifications to confirm that their previously reported sourcing information has not changed. |
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Appendix A
Table of Our Conflict Minerals Processing Facilities*
(As of April 24, 2018)
Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Gold | Abington Reldan Metals, LLC | United States of America | Known | X | ||||||
Gold | Accurate Refining Group | United States of America | Known | X | ||||||
Gold | Advanced Chemical Company | United States of America | RMAP conformant | X | ||||||
Gold | Aida Chemical Industries Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates | RMAP conformant | X | ||||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | RMAP conformant | X | X | |||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | RMAP conformant | X | ||||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | RMAP conformant | X | ||||||
Gold | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | China | Known | X | ||||||
Gold | Argor-Heraeus S.A. | Switzerland | RMAP conformant | X | X | |||||
Gold | Asahi Pretec Corp. | Japan | RMAP conformant | X | ||||||
Gold | Asahi Refining Canada Ltd. | Canada | RMAP conformant | X | X | |||||
Gold | Asahi Refining USA Inc. | United States of America | RMAP conformant | X | ||||||
Gold | Asaka Riken Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | ATAkulche | Turkey | Known | X | ||||||
Gold | AU Traders and Refiners | South Africa | RMAP conformant | X | ||||||
Gold | AURA-II | United States of America | Known | X | ||||||
Gold | Aurubis AG | Germany | RMAP conformant | X | ||||||
Gold | Bangalore Refinery | India | Active smelters and refiners | X | ||||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | RMAP conformant | X | ||||||
Gold | Boliden AB | Sweden | RMAP conformant | X | ||||||
Gold | C. Hafner GmbH + Co. KG | Germany | RMAP conformant | X | X | |||||
Gold | Caridad | Mexico | Known | X | ||||||
Gold | CCR Refinery - Glencore Canada Corporation | Canada | RMAP conformant | X | ||||||
Gold | Cendres + Metaux S.A. | Switzerland | RMAP conformant | X | ||||||
Gold | CHALCO Yunnan Copper Co. Ltd. | China | Known | X | ||||||
Gold | Chimet S.p.A. | Italy | RMAP conformant | X | ||||||
Gold | Chugai Mining | Japan | Known | X | ||||||
Gold | Daejin Indus Co., Ltd. | Korea (Republic of) | RMAP conformant | X | ||||||
Gold | Daye Non-Ferrous Metals Mining Ltd. | China | Known | X | ||||||
Gold | DODUCO Contacts and Refining GmbH | Germany | RMAP conformant | X | X | |||||
Gold | Dowa | Japan | RMAP conformant | X | ||||||
Gold | DSC (Do Sung Corporation) | Korea (Republic of) | RMAP conformant | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Gold | Eco-System Recycling Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Elemetal Refining, LLC | United States of America | Known | X | ||||||
Gold | Emirates Gold DMCC | United Arab Emirates | RMAP conformant | X | ||||||
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | Known | X | ||||||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | Known | X | ||||||
Gold | Geib Refining Corporation | United States of America | RMAP conformant | X | ||||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China | RMAP conformant | X | ||||||
Gold | Great Wall Precious Metals Co,. LTD. | China | Known | X | ||||||
Gold | Guangdong Gaoyao Co | China | Known | X | ||||||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Known | X | ||||||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Known | X | ||||||
Gold | Heimerle + Meule GmbH | Germany | RMAP conformant | X | X | |||||
Gold | Heraeus Metals Hong Kong Ltd. | China | RMAP conformant | X | X | |||||
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | RMAP conformant | X | X | |||||
Gold | Hunan Chenzhou Mining Co., Ltd. | China | Known | X | ||||||
Gold | HwaSeong CJ CO., LTD. | Korea (Republic of) | Known | X | ||||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | RMAP conformant | X | ||||||
Gold | Ishifuku Metal Industry Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Istanbul Gold Refinery | Turkey | RMAP conformant | X | ||||||
Gold | Japan Mint | Japan | RMAP conformant | X | ||||||
Gold | Jiangxi Copper Co., Ltd. | China | RMAP conformant | X | ||||||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | RMAP conformant | X | ||||||
Gold | JSC Uralelectromed | Russian Federation | RMAP conformant | X | ||||||
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Kaloti Precious Metals | United Arab Emirates | Known | X | ||||||
Gold | Kazakhmys Smelting LLC | Kazakhstan | Known | X | ||||||
Gold | Kazzinc | Kazakhstan | RMAP conformant | X | ||||||
Gold | Kennecott Utah Copper LLC | United States of America | RMAP conformant | X | ||||||
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | Active smelters and refiners | X | ||||||
Gold | Kojima Chemicals Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Korea Zinc Co., Ltd. | Korea (Republic of) | RMAP conformant | X | ||||||
Gold | Kyrgyzaltyn JSC | Kyrgyzstan | RMAP conformant | X | ||||||
Gold | L'azurde Company For Jewelry | Saudi Arabia | Known | X | ||||||
Gold | LinBao Gold Mining | China | Known | X | ||||||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Known | X | ||||||
Gold | LS-NIKKO Copper Inc. | Korea (Republic of) | RMAP conformant | X | X | |||||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Known | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Gold | Materion | United States of America | RMAP conformant | X | ||||||
Gold | Matsuda Sangyo Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Metalor Technologies (Hong Kong) Ltd. | China | RMAP conformant | X | ||||||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | RMAP conformant | X | ||||||
Gold | Metalor Technologies (Suzhou) Ltd. | China | RMAP conformant | X | ||||||
Gold | Metalor Technologies S.A. | Switzerland | RMAP conformant | X | X | |||||
Gold | Metalor USA Refining Corporation | United States of America | RMAP conformant | X | X | |||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | RMAP conformant | X | ||||||
Gold | Mitsubishi Materials Corporation | Japan | RMAP conformant | X | ||||||
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | MMTC-PAMP India Pvt., Ltd. | India | RMAP conformant | X | ||||||
Gold | Modeltech Sdn Bhd | Malaysia | Active smelters and refiners | X | ||||||
Gold | Morris and Watson | New Zealand | Known | X | ||||||
Gold | Moscow Special Alloys Processing Plant | Russian Federation | RMAP conformant | X | ||||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | RMAP conformant | X | ||||||
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | Known | X | ||||||
Gold | Nihon Material Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | RMAP conformant | X | ||||||
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | RMAP conformant | X | ||||||
Gold | OJSC Novosibirsk Refinery | Russian Federation | RMAP conformant | X | ||||||
Gold | PAMP S.A. | Switzerland | RMAP conformant | X | ||||||
Gold | Penglai Penggang Gold Industry Co., Ltd. | China | Known | X | ||||||
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | RMAP conformant | X | ||||||
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | RMAP conformant | X | ||||||
Gold | PX Precinox S.A. | Switzerland | RMAP conformant | X | ||||||
Gold | Rand Refinery (Pty) Ltd. | South Africa | RMAP conformant | X | ||||||
Gold | Refinery of Seemine Gold Co., Ltd. | China | Known | X | ||||||
Gold | Remondis Argentia B.V. | Netherlands | Active smelters and refiners | X | ||||||
Gold | Republic Metals Corporation | United States of America | RMAP conformant | X | ||||||
Gold | Royal Canadian Mint | Canada | RMAP conformant | X | X | |||||
Gold | SAAMP | France | RMAP conformant | X | ||||||
Gold | Sabin Metal Corp. | United States of America | Known | X | ||||||
Gold | SAFINA A.S. | Czech Republic | Active smelters and refiners | X | ||||||
Gold | Sai Refinery | India | Known | X | ||||||
Gold | Samduck Precious Metals | Korea (Republic of) | RMAP conformant | X | ||||||
Gold | Samwon Metals Corp. | Korea (Republic of) | Known | X | ||||||
Gold | SAXONIA Edelmetalle GmbH | Germany | RMAP conformant | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Gold | Schone Edelmetaal B.V. | Netherlands | Known | X | ||||||
Gold | SEMPSA Joyeria Plateria S.A. | Spain | RMAP conformant | X | ||||||
Gold | Shandong Tarzan Bio-Gold Industry Co., Ltd. | China | Known | X | ||||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | RMAP conformant | X | ||||||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | RMAP conformant | X | ||||||
Gold | Singway Technology Co., Ltd. | Taiwan, Province of China | RMAP conformant | X | ||||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | RMAP conformant | X | ||||||
Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China | RMAP conformant | X | X | |||||
Gold | Sudan Gold Refinery | Sudan | Known | X | ||||||
Gold | Sumitomo Metal Mining Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | T.C.A S.p.A | Italy | RMAP conformant | X | ||||||
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | RMAP conformant | X | ||||||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | RMAP conformant | X | X | |||||
Gold | Tokuriki Honten Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Tony Goetz NV | Belgium | Known | X | ||||||
Gold | TOO Tau-Ken-Altyn | Kazakhstan | Known | X | ||||||
Gold | Torecom | Korea (Republic of) | RMAP conformant | X | ||||||
Gold | Umicore Brasil Ltda. | Brazil | RMAP conformant | X | ||||||
Gold | Umicore Precious Metals Thailand | Thailand | RMAP conformant | X | X | |||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium | RMAP conformant | X | ||||||
Gold | United Precious Metal Refining, Inc. | United States of America | RMAP conformant | X | X | |||||
Gold | Universal Precious Metals Refining Zambia | Zambia | Known | X | ||||||
Gold | Valcambi S.A. | Switzerland | RMAP conformant | X | ||||||
Gold | Western Australian Mint (T/a The Perth Mint) | Australia | RMAP conformant | X | X | |||||
Gold | WIELAND Edelmetalle GmbH | Germany | RMAP conformant | X | X | |||||
Gold | Yamakin Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Yokohama Metal Co., Ltd. | Japan | RMAP conformant | X | ||||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | RMAP conformant | X | ||||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | RMAP conformant | X | ||||||
Tantalum | D Block Metals, LLC | United States of America | RMAP conformant | X | ||||||
Tantalum | Douluoshan Sapphire Rare Metal Co Ltd | China | Known | X | ||||||
Tantalum | Exotech Inc. | United States of America | RMAP conformant | X | ||||||
Tantalum | F&X Electro-Materials Ltd. | China | RMAP conformant | X | ||||||
Tantalum | Global Advanced Metals Aizu | Japan | RMAP conformant | X | ||||||
Tantalum | Global Advanced Metals Boyertown | United States of America | RMAP conformant | X | ||||||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China | RMAP conformant | X | ||||||
Tantalum | H.C. Starck Co., Ltd. | Thailand | RMAP conformant | X | ||||||
Tantalum | H.C. Starck Hermsdorf GmbH | Germany | RMAP conformant | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Tantalum | H.C. Starck Inc. | United States of America | RMAP conformant | X | ||||||
Tantalum | H.C. Starck Ltd. | Japan | RMAP conformant | X | ||||||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany | RMAP conformant | X | ||||||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany | RMAP conformant | X | ||||||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | RMAP conformant | X | ||||||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | RMAP conformant | X | ||||||
Tantalum | LSM Brasil S.A. | Brazil | RMAP conformant | X | ||||||
Tantalum | Mineracao Taboca S.A. | Brazil | RMAP conformant | X | ||||||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | RMAP conformant | X | ||||||
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | RMAP conformant | X | ||||||
Tin | Alpha | United States of America | RMAP conformant | X | X | |||||
Tin | An Thai Minerals Co., Ltd. | Vietnam | Known | X | ||||||
Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam | Known | X | ||||||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | China Tin Group Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | China | Known | X | ||||||
Tin | Cooper Santa | Brazil | Known | X | X | |||||
Tin | CV Ayi Jaya | Indonesia | RMAP conformant | X | ||||||
Tin | CV Dua Sekawan | Indonesia | RMAP conformant | X | ||||||
Tin | CV Gita Pesona | Indonesia | RMAP conformant | X | ||||||
Tin | CV JusTindo | Indonesia | Known | X | ||||||
Tin | CV United Smelting | Indonesia | RMAP conformant | X | X | |||||
Tin | CV Venus Inti Perkasa | Indonesia | RMAP conformant | X | ||||||
Tin | Dowa | Japan | RMAP conformant | X | ||||||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam | Known | X | ||||||
Tin | EM Vinto | Bolivia (Plurinational State of) | RMAP conformant | X | X | |||||
Tin | Estanho de Rondonia S.A. | Brazil | Known | X | ||||||
Tin | Fenix Metals | Poland | RMAP conformant | X | X | |||||
Tin | Gejiu Fengming Metallurgy Chemical Plant | China | RMAP conformant | X | ||||||
Tin | Gejiu Jinye Mineral Company | China | RMAP conformant | X | ||||||
Tin | Gejiu Kai Meng Industry and Trade LLC | China | RMAP conformant | X | ||||||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | RMAP conformant | X | X | |||||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | Gejiu Zi-Li | China | Known | X | ||||||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China | RMAP conformant | X | ||||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | Huichang Jinshunda Tin Co., Ltd. | China | RMAP conformant | X | ||||||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | RMAP conformant | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Tin | Jiangxi New Nanshan Technology Ltd. | China | RMAP conformant | X | ||||||
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil | RMAP conformant | X | ||||||
Tin | Malaysia Smelting Corporation (MSC) | Malaysia | RMAP conformant | X | X | |||||
Tin | Melt Metais e Ligas S.A. | Brazil | RMAP conformant | X | ||||||
Tin | Metallic Resources, Inc. | United States of America | RMAP conformant | X | ||||||
Tin | Metallo Belgium N.V. | Belgium | RMAP conformant | X | X | |||||
Tin | Metallo Spain S.L.U. | Spain | RMAP conformant | X | ||||||
Tin | Mineracao Taboca S.A. | Brazil | RMAP conformant | X | X | |||||
Tin | Minsur | Peru | RMAP conformant | X | X | |||||
Tin | Mitsubishi Materials Corporation | Japan | RMAP conformant | X | X | |||||
Tin | Modeltech Sdn Bhd | Malaysia | Active smelters and refiners | X | ||||||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam | Known | X | ||||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | RMAP conformant | X | ||||||
Tin | O.M. Manufacturing Philippines, Inc. | Philippines | RMAP conformant | X | ||||||
Tin | Operaciones Metalurgical S.A. | Bolivia (Plurinational State of) | RMAP conformant | X | X | |||||
Tin | Phoenix Metal Ltd. | Rwanda | Known | X | ||||||
Tin | PT Aries Kencana Sejahtera | Indonesia | RMAP conformant | X | ||||||
Tin | PT Artha Cipta Langgeng | Indonesia | RMAP conformant | X | X | |||||
Tin | PT ATD Makmur Mandiri Jaya | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Babel Inti Perkasa | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Bangka Prima Tin | Indonesia | RMAP conformant | X | ||||||
Tin | PT Bangka Tin Industry | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Belitung Industri Sejahtera | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Bukit Timah | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Cipta Persada Mulia | Indonesia | Known | X | ||||||
Tin | PT DS Jaya Abadi | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Eunindo Usaha Mandiri | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Inti Stania Prima | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Karimun Mining | Indonesia | RMAP conformant | X | ||||||
Tin | PT Kijang Jaya Mandiri | Indonesia | RMAP conformant | X | ||||||
Tin | PT Lautan Harmonis Sejahtera | Indonesia | RMAP conformant | X | ||||||
Tin | PT Menara Cipta Mulia | Indonesia | RMAP conformant | X | ||||||
Tin | PT Mitra Stania Prima | Indonesia | RMAP conformant | X | X | |||||
Tin | PT O.M. Indonesia | Indonesia | Known | X | ||||||
Tin | PT Panca Mega Persada | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Premium Tin Indonesia | Indonesia | RMAP conformant | X | ||||||
Tin | PT Prima Timah Utama | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Rajehan Ariq | Indonesia | RMAP conformant | X | ||||||
Tin | PT Refined Bangka Tin | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Sariwiguna Binasentosa | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Stanindo Inti Perkasa | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Sukses Inti Makmur | Indonesia | RMAP conformant | X |
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Covered Products | ||||||||||
Conflict Mineral | Smelter or Refiner Name | Smelter Location | RMAP Status | Systems Segment | Modules Segment | |||||
Tin | PT Sumber Jaya Indah | Indonesia | RMAP conformant | X | ||||||
Tin | PT Timah (Persero) Tbk Kundur | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Timah (Persero) Tbk Mentok | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Tinindo Inter Nusa | Indonesia | RMAP conformant | X | X | |||||
Tin | PT Tommy Utama | Indonesia | RMAP conformant | X | ||||||
Tin | PT Wahana Perkit Jaya | Indonesia | Known | X | ||||||
Tin | Resind Industria e Comercio Ltda. | Brazil | RMAP conformant | X | ||||||
Tin | Rui Da Hung | Taiwan, Province of China | RMAP conformant | X | X | |||||
Tin | Soft Metais Ltda. | Brazil | RMAP conformant | X | ||||||
Tin | Thaisarco | Thailand | RMAP conformant | X | X | |||||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam | Known | X | ||||||
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil | RMAP conformant | X | X | |||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | RMAP conformant | X | X | |||||
Tin | Yunnan Tin Company Limited | China | RMAP conformant | X | X | |||||
Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | RMAP conformant | X | ||||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Global Tungsten & Powders Corp. | United States of America | RMAP conformant | X | ||||||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany | RMAP conformant | X | ||||||
Tungsten | H.C. Starck Tungsten GmbH | Germany | RMAP conformant | X | ||||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Japan New Metals Co., Ltd. | Japan | RMAP conformant | X | ||||||
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Kennametal Huntsville | United States of America | RMAP conformant | X | ||||||
Tungsten | Niagara Refining LLC | United States of America | RMAP conformant | X | ||||||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | RMAP conformant | X | ||||||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | RMAP conformant | X | ||||||
Tungsten | Wolfram Bergbau und Hutten AG | Austria | RMAP conformant | X | ||||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | RMAP conformant | X | ||||||
Tungsten | Xiamen Tungsten Co., Ltd. | China | RMAP conformant | X |
——————————
*We note the following in connection with the table above:
a. | Active smelters and refiners have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs. Smelters or refiners are identified as active in the RMAP once they submit a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts, which is one of the first steps of the audit process. Smelters or refiners on the active list are at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. |
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b. | Though we request that our tier one suppliers provide responses at the product-level, some of our suppliers provided responses at the company-level, meaning that they reported smelter and refiner information for all of their products, not just for the products sold to us. Accordingly, our list of processing facilities disclosed in this appendix contains more facilities than those that actually process or refine the conflict minerals contained in our products. |
c. | Known smelters and refiners include those reported entities that were listed on the Smelter Reference List tab of the CMRT because those are the only reported entities that we were able to determine were smelters or refiners. |
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