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TotalEnergies SE (TTE)

Filed: 31 May 19, 7:22am

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

TOTAL S.A.

(Exact name of registrant as specified in its charter)

Republic of France

001-10888

98-0227345

(State or other jurisdiction of incorporation or organization)

(Commission File
Number)

(IRS Employer
Identification No.)

 

2, place Jean Millier

La Défense 6

92400 Courbevoie

France

(Address of principal executive offices) (Zip Code)

 

Patrick de La Chevardière

Chief Financial Officer

Tel: +33 (0)1 47 44 45 46

Fax: +33 (0)1 47 44 49 44

(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:

 

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.

TOTAL S.A. is providing on this Form SD disclosure in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended.


Section 1 - Conflict Minerals Disclosure

Item 1.01(b)

CONFLICT MINERALS DISCLOSURE

TOTAL S.A. (collectively with its subsidiaries and affiliates, "TOTAL" or the "Group") is providing herein disclosure in accordance with Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934, as amended, which implements reporting and disclosure requirements related to certain minerals (referred to as "conflict minerals" under the Rule) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, for the reporting period from January 1, 2018 to December 31, 2018 (the "Reporting Period"). For the Reporting Period, "Conflict Minerals" are defined in the Rule as the following minerals (regardless of their geographic origin): cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, limited to tin, tantalum and tungsten.

I.            Diligence and Reporting Process

TOTAL has established a management system to implement a diligence and reporting process concerning Conflict Minerals in accordance with the Rule, which is coordinated at the Holding level with division coordinators designated at the level of each of the business segments and operational entities (Exploration & Production, Gas, Renewables & Power, Refining & Chemicals, Trading & Shipping, Marketing & Services and Total Global Procurement) who contact the relevant parties (such as business managers and purchasing departments).

For this Reporting Period, Saft Groupe S.A. and its affiliates ("Saft"), a subsidiary in the Gas, Renewables & Power segment and Hutchinson S.A. and its affiliates ("Hutchinson"), a subsidiary in the Refining & Chemicals segment, identified products which each had manufactured, or contracted to have manufactured, that contained Conflict Minerals, namely tin, tantalum, tungsten and/or gold (collectively, "3TG"), that were necessary to the functionality of those products (the "Necessary Conflict Minerals").

In addition, SunPower Corporation, an American company listed on NASDAQ and based in San Jose, California ("SunPower")1, is subject to the Rule and separately publishes information concerning its use of Conflict Minerals in certain of its products that it manufactured or contracted to manufacture (solar panels, balance of systems components). The text of SunPower’s disclosure for this Reporting Period provided on its Form SD is included in Annex A to this document.

A.    SAFT:

Saft is a leading manufacturer of batteries for the industrial infrastructure and processes, transportation, civil and military electronics markets, energy storage, transportation and telecommunication markets. Saft does not make purchases of raw ore or refined 3TG minerals directly from smelters or refiners. For this Reporting Period, Saft focused its diligence efforts on the suppliers of components and parts which were determined by Saft to contain or potentially contain 3TG, i.e. electronics and electric components, and which were incorporated into products manufactured by Saft (the "Relevant Suppliers").

With the assistance of a third party retained by it to assist with supplier outreach and data validation of the responses received from suppliers (the "Service Provider"), Saft conducted in good faith a reasonable country of origin inquiry (the "RCOI") regarding the Necessary Conflict Minerals that was designed to determine whether any of them had originated in the Democratic Republic of the Congo or an adjoining country (each a "Covered Country", as defined in the Rule) or were from recycled or scrap sources. To complete the RCOI, Saft and the Service Provider engaged the Relevant Suppliers using the Conflict Minerals Reporting Template ("CMRT") developed by the Responsible Minerals Initiative. For this Reporting Period, only CMRT’s version 4.0 or higher was accepted. Relevant Suppliers had the ability to share information at a level at which they were most comfortable (i.e. company, product or user-defined) but they had to specify the declaration scope. A limited number of Relevant Suppliers replied by providing their company’s formal policy on Conflict Minerals.

__________________

1 As of December 31, 2018, the Group held 55.66% of the outstanding share capital of SunPower

 

1

Based on the Relevant Suppliers’ responses, a substantial percentage of the Relevant Suppliers (in terms of the number of Relevant Suppliers that responded with a CMRT and acknowledged having one or more 3TG in the products sold to Saft) identified the potential use in their supply chain of smelters in the Covered Countries. However, these smelters were in compliance with the Responsible Minerals Assurance Process Initiative assessment protocol as set forth by the RMI, without independent verification by Saft.

Saft’s contracts with its suppliers require them to source responsibly, and Saft maintains an active dialogue with its suppliers on this topic. As a result, Saft does not has any reason to believe that their Necessary Conflict Minerals sourced in Covered Countries in the Reporting Period directly or indirectly financed or benefitted armed groups.

B.    Hutchinson:

Hutchinson is a global leader in vibration control, fluid management and sealing technologies. Hutchinson reached out to all of its suppliers and identified which products contained Necessary Conflict Minerals for this Reporting Period: automotive fluid transfer lines, anti-vibration and sealing systems, and aerospace industrial applications, found in four business activities of the group (fluid transfer systems, body sealing systems, aerospace & industry and body sealing systems).

Hutchinson conducted in good faith a RCOI regarding the Necessary Conflict Minerals to determine whether any had originated in a Covered Country or were from recycled or scrap sources. To complete the RCOI, Hutchinson surveyed its suppliers to collect information about the presence and source of the Necessary Conflict Minerals.

Based on the suppliers’ responses (generally provided by means of a CMRT or letter), it was determined that a substantial percentage in terms of absolute numbers and annual turnover of Hutchinson’s suppliers certified that the Necessary Conflict Minerals supplied to it either originated from recycled or scrap sources or did not originate from the Covered Countries. A low percentage of suppliers in absolute numbers and annual turnover sourced Necessary Conflict Minerals during the Reporting Period from one or more of the Covered Countries. A review of these suppliers by Hutchinson revealed them to be reputable, and mainly included major suppliers of the (i) automotive industry involved in the activity of body sealing systems, including publicly listed U.S. car manufacturers or (ii) the aerospace industry.

In some instances, the origin of some of the Necessary Conflict Minerals could be traced to smelters that are compliant with the Responsible Minerals Assurance Process Initiative assessment protocol as set forth by the RMI, without independent verification by Hutchinson.

Hutchinson’s standard agreement with its suppliers require them to fill out the survey questions set forth under the CMRT and Hutchinson maintains an active dialogue with its suppliers on this topic. Hutchinson does not have any reason to believe that their Necessary Conflict Minerals sourced in Covered Countries in the Reporting Period directly or indirectly financed or benefitted armed groups. With respect to non-respondent suppliers, which represent a small percentage of suppliers in absolute numbers and annual turnover for the Reporting Period, diligence performed by Hutchinson revealed no reason to believe such suppliers may have sourced the Necessary Conflict Minerals from a Covered Country.

II.           Group principles

TOTAL is committed to responsible economic and social development in Africa.

TOTAL monitors responsible practices among its suppliers. In its Code of Conduct, TOTAL states that it works with its suppliers to ensure the protection of the interests of both parties in accordance with clear, fairly negotiated contract terms. This relationship is based on three cornerstones: dialogue, professionalism and meeting commitments.

2

TOTAL expects its suppliers to:

        adhere to the Group’s Fundamental Principles of Purchasing (the "FPP") (see below) and ensure that they are adhered to in their activities;

        accept to be audited according to these principles;

        remain attentive to the everyday working conditions of their employee and their suppliers’ employees;

        ensure that their own suppliers and contractors adhere to the FPP;

        refer to the Group Ethics Committee when in doubt or in the event of any malfunction.

The FPP, launched in 2010, specify the commitments that TOTAL expects of its suppliers in the following areas1:

        respect for human rights at work;

        health protection, safety and security;

        preservation of the environment;

        prevention of corruption and conflicts of interest and fraud;

        respect for competition law; and

        the promotion of economic and social development.

A Group directive reaffirms the obligation to annex the FPP or transpose them in the selection process as well as in the contracts concluded with suppliers of goods and services. The FPP are available for consultation by all suppliers in both French and English in the "Suppliers" section on TOTAL’s Internet website at: https://www.total.com/en/suppliers/sustainable-purchasing-day-day-commitment.

In addition, questionnaires focused on environmental and societal issues are used to gather more in-depth information from suppliers about their approach to these subjects, either during pre-qualification or as part of an audit. Supplier relations are also considered from an environmental and societal perspective on occasion as part of ethical assessments of Group subsidiaries and entities.

TOTAL is a member of the United Nations Global Compact platform on Decent Work in Global Supply Chains since 2018, and, in this capacity, takes part in various workshops that aim to help the member companies of the Global Compact to make progress in this area.

This conflict minerals disclosure is also available on TOTAL’s Internet website at: https://www.sustainable-performance.total.com/en/our-challenges/supply-chain.

__________________

1 Saft and SunPower have defined fundamental principles of purchasing specific to their activities.

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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.

 

 

TOTAL S.A.

Date: May 31, 2019

By:

/s/ PATRICK DE LA CHEVARDIERE

Name:

Patrick de LA CHEVARDIERE

Title:

Chief Financial Officer

ANNEX A

SunPower Corporation

Conflict Minerals Disclosure

SunPower Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for 2018 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Exchange Act"1), and Form SD (collectively, the "Conflict Minerals Rule"). The date of filing of this Conflict Minerals Report is May 30, 2019.

Unless the context indicates otherwise, the term "SunPower" refers to SunPower Corporation and its consolidated subsidiaries, and "Service Provider" refers to the third party retained by SunPower to assist with supplier outreach and data validation of the responses received from suppliers. Some of the compliance activities described in this Conflict Minerals Report were performed by the Service Provider in coordination with SunPower. As used herein and consistent with the Conflict Minerals Rule, "Conflict Minerals" or "3TG" are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin of the minerals or derivative metals.

This Conflict Minerals Report can be found on the SunPower website at: http://investors.sunpower.com/sec.cfm.

Forward-Looking Statements

This document contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended (the "Securities Act"), and Section 21E of the Exchange Act. In particular, statements contained in this document that are not historical facts, including, but not limited to, statements concerning the additional steps that SunPower intends to take to mitigate the risk that its necessary 3TG benefit armed groups, constitute forward-looking statements and are made under the safe harbor provisions of Section 27A of the Securities Act and Section 21E of the Exchange Act.

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 may include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by SunPower’s direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (the "DRC") or an adjoining country (collectively, the "Covered Countries"), the United States or elsewhere. SunPower cautions readers not to place undue reliance on any forward-looking statements, which only speak as of the date made. SunPower undertakes no obligation to update any forward-looking statement to reflect events or circumstances after the date on which such statement is made.

Overview; SunPower's Products and Applicability of the Conflict Minerals Rule

SunPower is a leading global energy company dedicated to changing the way our world is powered. We deliver complete solar solutions to residential, commercial, and power plant customers worldwide by offering cutting-edge solar module technology and solar power systems, integrated storage and software

____________________________

1 Definitions provided in this Annex are exclusive to this section.

 

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solutions that enable customers to effectively manage and optimize their CCOE energy usage and expenses as well as additional services and financial solutions. SunPower products include solar panels and balance of systems components that can include inverters, combiner boxes, racking systems, mechanical and motorized systems, and electrical tracking, monitoring and controller systems. Each of the product areas that SunPower manufactures and contracts to manufacture contains 3TG which is necessary to the functionality or production of such products. However, 3TG content continues to represent a small portion of the materials content of SunPower’s products. For 2018, SunPower was unable to determine the origin of at least a portion of the necessary 3TG in each of its products.

For a further discussion of SunPower’s products, see its Annual Report on Form 10-K for the fiscal year ended December 30, 2018. The information contained in the Form 10-K is not incorporated by reference into this Conflict Minerals Report or SunPower's Form SD for 2018 and should not be considered part of this Conflict Minerals Report or the Form SD.

SunPower is committed to human rights. As a result of this commitment, SunPower commenced its 3TG diligence activities in 2011, well before the adoption of the Conflict Minerals Rule.

SunPower is multiple levels removed from the mining of minerals (3TG or otherwise). SunPower does not make purchases of raw ore or refined minerals directly from smelters or refiners and makes no purchases in the Covered Countries. However, through the efforts described in this Conflict Minerals Report, SunPower seeks to ensure its suppliers are sourcing responsibly.

SunPower does not seek to embargo sourcing of 3TG from the Covered Countries and encourages its suppliers to continue to source 3TG responsibly from the region.

Reasonable Country of Origin Inquiry

To complete the "reasonable country of origin inquiry" (the "RCOI") required by the Conflict Minerals Rule, SunPower and its Service Provider engaged with suppliers to collect information about the presence and source of 3TG used in products and components supplied to SunPower. For its RCOI, to the extent applicable, SunPower utilized the same processes and procedures as for its due diligence, in particular Steps 1 and 2 of the OECD Guidance (as defined below), which are discussed later in this Conflict Minerals Report.

The results of SunPower’s RCOI are discussed under "Findings Covering Smelters, Refiners and Country of Origin Information."

Due Diligence Measures

Design Framework

SunPower utilizes due diligence measures for 3TG that are intended 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 (Third Edition) (the "OECD Guidance"). The OECD Guidance established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected

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and high-risk areas. Application of the framework constitutes a part of the program that SunPower has put in place to help ensure that the 3TG contained in its products are responsibly sourced.

Diligence Program

In furtherance of SunPower’s 3TG due diligence, it performed the due diligence measures discussed below for 2018.

Compliance Team

In support of its compliance efforts, SunPower has a compliance team that is charged with overseeing, implementing and providing feedback on its 3TG compliance strategy. The team consists of staff from SunPower’s legal and operations groups, under executive leadership of our Chief Executive Officer, SunPower Technologies. The members of the team and selected other internal personnel are trained on the Conflict Minerals Rule, the OECD Guidance, SunPower’s compliance plan, and the procedures for reviewing and validating supplier responses to its inquiries.

SunPower also utilized the Service Provider and specialist outside counsel to assist with and/or to advise it on certain aspects of its compliance.

Conflict Minerals Policy; Training Resources; Grievance Mechanism

SunPower maintains a Conflict Minerals Policy. Under the Conflict Minerals Policy, SunPower suppliers are required to acknowledge SunPower’s Supplier Sustainability Guidelines, which includes the Conflict Minerals Policy.

The Conflict Minerals Policy indicates that SunPower will evaluate its relationships with its suppliers on an ongoing basis to ensure continued compliance with the policy. Under the Conflict Minerals Policy, SunPower reserves the right to request additional documentation from its suppliers regarding the source of any 3TG included in their products. In addition, SunPower reserves the right to ask for suppliers to maintain traceability data for a minimum of five years.

The Conflict Minerals Policy is communicated internally to SunPower’s supply chain employees and to suppliers. In addition, the Conflict Minerals Policy is posted on SunPower’s website at https://us.sunpower.com/conflict-minerals.

In an effort to increase supplier awareness about Conflict Minerals and related regulatory requirements, provide answers to frequently asked questions concerning 3TG mineral tracing, and ultimately improve the accuracy and completeness of supplier responses, suppliers that were part of SunPower’s outreach received access to the Service Provider’s online resources.

SunPower has a grievance mechanism for reporting violations of its Conflict Minerals Policy. The grievance mechanism is indicated in the Conflict Minerals Policy. Violations may be reported by calling SunPower’s Compliance and Ethics Helpline at 1-866-307-5679 within the United States, or at toll-free numbers provided for twenty additional countries/regions in SunPower’s Code of Business Conduct and Ethics available on its investor relations website at investors.sunpower.com, or by going to SunPower’s reporting website at https://sunpower.alertline.com, https://sunpowereu.alertline.com (for employees in Europe, except Spain) or https://sunpowersp.alertline.com (for employees in Spain).

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Data Collection; Records Storage and Retention

In 2018, SunPower carried out due diligence on parts selected by SunPower within the bills of materials of products that were contracted to be manufactured. The contract manufacturer carried out due diligence for general use parts of products that were contracted to be manufactured, the results of which were reflected in their Conflict Minerals Reporting Templates (collectively, the "CMRTs" and individually, a "CMRT") developed by the Responsible Minerals Initiative (the "RMI"). SunPower’s outreach included 123 suppliers (the "Suppliers") that (1) contracted to manufacture products for SunPower which were determined by SunPower to contain or potentially contain 3TG which is necessary to the functionality or production of the products, or (2) provided components, parts, or products which were determined by SunPower to contain or potentially contain necessary 3TG, and which were incorporated into products contracted to be manufactured by SunPower.

SunPower sent the Suppliers a request to submit a CMRT to gather information on the use of 3TG by the Suppliers, the source of the 3TG and the Suppliers’ related compliance procedures. SunPower gave the Suppliers the ability to provide information at a level at which they could most readily assemble the information (i.e. company, product, or user-defined), but required the Suppliers to declare the level of information provided. Following the initial introductions to the program and information request, up to four reminder emails were sent to each non-responsive Supplier requesting survey completion.

SunPower and the Service Provider reviewed CMRT responses received from the Suppliers for incomplete responses, potential errors or inaccuracies, lack of consistency, and other flags. If any "quality control" flags were raised, Suppliers were contacted to clarify the concern. If a smelter or refiner was not on the CMRT Smelter Look-up tab list, the Service Provider (a) requested that the Supplier confirm that the listed entity was a smelter or refiner, (b) consulted publicly-available information to attempt to determine whether the identified entity was a smelter or refiner, or (c) attempted to contact the listed entity. If the smelter or refiner was not identified as Conformant (as later defined) or the equivalent by the RMI, the London Bullion Market Association (the "LMBA") or the Responsible Jewelry Council (the "RJC"), SunPower or the Service Provider attempted to contact the smelter or refiner to gain more information about its sourcing practices, including countries of origin and transfer, and due diligence procedures.

To the extent that no contact was made with a smelter or refiner identified by a Supplier, SunPower or the Service Provider searched public information to attempt to determine the mine or location of origin of the 3TG processed by the smelter or refiner and whether it obtains 3TG from sources that directly or indirectly finance or benefit armed groups in a Covered Country.

SunPower has an internal electronic file for the maintenance of business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions. SunPower stores all supplier CMRTs and documents evidence of identified supplier 3TG sourcing risk. As contemplated by the OECD Guidance, SunPower will maintain these records for at least five years. The Service Provider also is requested to maintain records in its possession for at least five years.

Supplier Acknowledgements

SunPower required the Suppliers to provide the acknowledgements contemplated by its Conflict Minerals Policy, as described above. Suppliers were also requested to provide an electronic signature before submitting their data to SunPower to verify that all answers submitted were accurate to the best of each Supplier’s knowledge.

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3TG Risk Management

SunPower obtained information on 3TG sourcing risk from a variety of sources, including the Service Provider. SunPower further used the CMRT to identify 3TG sourcing risk. As an additional measure, SunPower asked a large cross section of its suppliers to respond to 3TG scoping questions. Given SunPower’s position in the 3TG supply chain, it believes that these are the most efficient means for identifying 3TG sourcing risk.

Supply chain managers within SunPower worked with the compliance team to identify 3TG sourcing concerns and determine risk mitigation efforts. The compliance team reported aggregated risk findings to and the contents of this Conflict Minerals Report are shared with SunPower’s executive management.

SunPower determines on a case-by-case basis the appropriate risk mitigation strategy for any identified risks. Potential outcomes under SunPower’s risk mitigation strategy include continuing to work with the supplier while risks are addressed or reassessing the relationship with the supplier. Under SunPower’s risk management framework, to the extent that risks require mitigation, SunPower monitors and tracks the performance of the risk mitigation efforts and reports these efforts to appropriate senior oversight personnel.

Utilization of Independent Third-Party Audits

To the extent that smelters or refiners are identified, SunPower primarily utilizes information made available by the RMI concerning independent third-party audits and Conformant status. SunPower also relies on audits performed by the LBMA’s Good Delivery Program and the RJC’s Chain-of-Custody Certification.

Report on Supply Chain Due Diligence

SunPower files a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission and makes these filings available on its investor relations website.

Findings Covering Smelters, Refiners and Country of Origin Information

For 2018, SunPower received 77 Supplier responses to its outreach. The CMRT declarations received identified 315 smelters and refiners that processed or may have processed 3TG contained in SunPower’s products. Of these 77 CMRT declarations, 49 were company-level, 23 were product-level, and 5 were at a level defined by the Supplier. Due to the number of Suppliers providing company-level declarations, the list of processing facilities disclosed below may over-represent the number of 3TG processing facilities in SunPower’s supply chain.

In brief, as indicated in the table below:

 

     315 smelters and refiners were identified by the Suppliers.

     249 smelters and refiners, or 79%, were listed as Conformant by the RMI.

     3 smelters or refiners, or less than 1%, were listed as Active.

     63 smelters or refiners, or 20%, were listed on the Smelter Look-up tab only.

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In connection with SunPower’s RCOI or due diligence, as applicable, the Suppliers identified to SunPower the facilities listed below as potentially having processed the necessary 3TG contained in SunPower’s in-scope products in 2018 (table information is as of May 14, 2019; see the notes following the table for additional information concerning the information presented in the table).

 

Metal

Smelter Name

Smelter Country

Status

Gold

8853 S.p.A.

Italy

Conformant

Gold

Abington Reldan Metals, LLC

United States

On Smelter Look-Up Tab Only

Gold

Advanced Chemical Company

United States

Conformant

Gold

African Gold Refinery

Uganda

On Smelter Look-Up Tab Only

Gold

Aida Chemical Industries Co., Ltd.

Japan

Conformant

Gold

Al Etihad Gold Refinery DMCC

United Arab Emirates

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

Germany

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

Uzbekistan

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

Brazil

Conformant

Gold

Argor-Heraeus S.A.

Switzerland

Conformant

Gold

Asahi Pretec Corp.

Japan

Conformant

Gold

Asahi Refining Canada Ltd.

Canada

Conformant

Gold

Asahi Refining USA Inc.

United States

Conformant

Gold

Asaka Riken Co., Ltd.

Japan

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Turkey

On Smelter Look-Up Tab Only

Gold

AU Traders and Refiners

South Africa

Conformant

Gold

Aurubis AG

Germany

Conformant


6

Gold

Bangalore Refinery

India

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Philippines

Conformant

Gold

Boliden AB

Sweden

Conformant

Gold

C. Hafner GmbH + Co. KG

Germany

Conformant

Gold

Caridad

Mexico

On Smelter Look-Up Tab Only

Gold

CCR Refinery - Glencore Canada Corporation

Canada

Conformant

Gold

Cendres + Metaux S.A.

Switzerland

Conformant

Gold

Chimet S.p.A.

Italy

Conformant

Gold

Chugai Mining

Japan

Active

Gold

Daejin Indus Co., Ltd.

Korea, Republic of

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

China

On Smelter Look-Up Tab Only

Gold

Degussa Sonne / Mond Goldhandel GmbH

Germany

On Smelter Look-Up Tab Only

Gold

Dijllah Gold Refinery FZC

United Arab Emirates

On Smelter Look-Up Tab Only

Gold

DODUCO Contacts and Refining GmbH

Germany

Conformant

Gold

Dowa

Japan

Conformant

Gold

DS PRETECH Co., Ltd.

Korea, Republic of

Conformant

Gold

DSC (Do Sung Corporation)

Korea, Republic of

Conformant

Gold

Eco-System Recycling Co., Ltd.

Japan

Conformant

Gold

Emirates Gold DMCC

United Arab Emirates

Conformant

Gold

Fidelity Printers and Refiners Ltd.

Zimbabwe

On Smelter Look-Up Tab Only


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Gold

Fujairah Gold FZC

United Arab Emirates

On Smelter Look-Up Tab Only

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

India

On Smelter Look-Up Tab Only

Gold

Geib Refining Corporation

United States

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

China

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

China

On Smelter Look-Up Tab Only

Gold

Guangdong Jinding Gold Limited

China

On Smelter Look-Up Tab Only

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

HeeSung Metal Ltd.

Korea, Republic of

Conformant

Gold

Heimerle + Meule GmbH

Germany

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

China

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

Germany

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

HwaSeong CJ CO., LTD.

Korea, Republic of

On Smelter Look-Up Tab Only

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

China

Conformant

Gold

International Precious Metal Refiners

United Arab Emirates

On Smelter Look-Up Tab Only

Gold

Ishifuku Metal Industry Co., Ltd.

Japan

Conformant


8

Gold

Istanbul Gold Refinery

Turkey

Conformant

Gold

Italpreziosi

Italy

Conformant

Gold

Japan Mint

Japan

Conformant

Gold

Jiangxi Copper Co., Ltd.

China

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Russian Federation

On Smelter Look-Up Tab Only

Gold

JSC Uralelectromed

Russian Federation

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

Japan

Conformant

Gold

Kaloti Precious Metals

United Arab Emirates

On Smelter Look-Up Tab Only

Gold

Kazakhmys Smelting LLC

Kazakhstan

On Smelter Look-Up Tab Only

Gold

Kazzinc

Kazakhstan

Conformant

Gold

Kennecott Utah Copper LLC

United States

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

Poland

Active

Gold

Kojima Chemicals Co., Ltd.

Japan

Conformant

Gold

Korea Zinc Co., Ltd.

Korea, Republic of

Conformant

Gold

Kyrgyzaltyn JSC

Kyrgyzstan

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

Russian Federation

On Smelter Look-Up Tab Only

Gold

L'azurde Company For Jewelry

Saudi Arabia

On Smelter Look-Up Tab Only

Gold

Lingbao Gold Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

L'Orfebre S.A.

Andorra

Conformant


9

Gold

LS-NIKKO Copper Inc.

Korea, Republic of

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Marsam Metals

Brazil

Conformant

Gold

Materion

United States

Conformant

Gold

Matsuda Sangyo Co., Ltd.

Japan

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

China

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

Singapore

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

China

Conformant

Gold

Metalor Technologies S.A.

Switzerland

Conformant

Gold

Metalor USA Refining Corporation

United States

Conformant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

Mexico

Conformant

Gold

Mitsubishi Materials Corporation

Japan

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

Japan

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

India

Conformant

Gold

Modeltech Sdn Bhd

Malaysia

On Smelter Look-Up Tab Only

Gold

Morris and Watson

New Zealand

On Smelter Look-Up Tab Only

Gold

Morris and Watson Gold Coast

Australia

On Smelter Look-Up Tab Only

Gold

Moscow Special Alloys Processing Plant

Russian Federation

Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

Turkey

Conformant

Gold

Navoi Mining and Metallurgical Combinat

Uzbekistan

On Smelter Look-Up Tab Only

Gold

NH Recytech Company

Korea, Republic of

Active


10

Gold

Nihon Material Co., Ltd.

Japan

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

Austria

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

Japan

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

Russian Federation

Conformant

Gold

OJSC Novosibirsk Refinery

Russian Federation

Conformant

Gold

PAMP S.A.

Switzerland

Conformant

Gold

Pease & Curren

United States

On Smelter Look-Up Tab Only

Gold

Penglai Penggang Gold Industry Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Planta Recuperadora de Metales SpA

Chile

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

Russian Federation

Conformant

Gold

PT Aneka Tambang (Persero) Tbk

Indonesia

Conformant

Gold

PX Precinox S.A.

Switzerland

Conformant

Gold

QG Refining, LLC

United States

On Smelter Look-Up Tab Only

Gold

Rand Refinery (Pty) Ltd.

South Africa

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

REMONDIS PMR B.V.

Netherlands

Conformant

Gold

Royal Canadian Mint

Canada

Conformant

Gold

SAAMP

France

Conformant

Gold

Sabin Metal Corp.

United States

On Smelter Look-Up Tab Only

Gold

Safimet S.p.A

Italy

Conformant


11

Gold

SAFINA A.S.

Czech Republic

On Smelter Look-Up Tab Only

Gold

Sai Refinery

India

On Smelter Look-Up Tab Only

Gold

Samduck Precious Metals

Korea, Republic of

On Smelter Look-Up Tab Only

Gold

SAMWON METALS Corp.

Korea, Republic of

On Smelter Look-Up Tab Only

Gold

SAXONIA Edelmetalle GmbH

Germany

Conformant

Gold

SEMPSA Joyeria Plateria S.A.

Spain

Conformant

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

China

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

China

Conformant

Gold

Singway Technology Co., Ltd.

Taiwan

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

Russian Federation

Conformant

Gold

Solar Applied Materials Technology Corp.

Taiwan

Conformant

Gold

State Research Institute Center for Physical Sciences and Technology

Lithuania

On Smelter Look-Up Tab Only

Gold

Sudan Gold Refinery

Sudan

On Smelter Look-Up Tab Only

Gold

Sumitomo Metal Mining Co., Ltd.

Japan

Conformant

Gold

SungEel HiMetal Co., Ltd.

Korea, Republic of

Conformant

Gold

T.C.A S.p.A

Italy

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

Japan

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

China

Conformant


12

Gold

Tokuriki Honten Co., Ltd.

Japan

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Tony Goetz NV

Belgium

On Smelter Look-Up Tab Only

Gold

TOO Tau-Ken-Altyn

Kazakhstan

On Smelter Look-Up Tab Only

Gold

Torecom

Korea, Republic of

Conformant

Gold

Umicore Brasil Ltda.

Brazil

Conformant

Gold

Umicore Precious Metals Thailand

Thailand

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

Belgium

Conformant

Gold

United Precious Metal Refining, Inc.

United States

Conformant

Gold

Universal Precious Metals Refining Zambia

Zambia

On Smelter Look-Up Tab Only

Gold

Valcambi S.A.

Switzerland

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

Australia

Conformant

Gold

WIELAND Edelmetalle GmbH

Germany

Conformant

Gold

Yamakin Co., Ltd.

Japan

Conformant

Gold

Yokohama Metal Co., Ltd.

Japan

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

China

On Smelter Look-Up Tab Only

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

China

Conformant

Tantalum

Asaka Riken Co., Ltd.

Japan

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

China

Conformant


13

Tantalum

D Block Metals, LLC

United States

Conformant

Tantalum

Exotech Inc.

United States

Conformant

Tantalum

F&X Electro-Materials Ltd.

China

Conformant

Tantalum

FIR Metals & Resource Ltd.

China

Conformant

Tantalum

Global Advanced Metals Aizu

Japan

Conformant

Tantalum

Global Advanced Metals Boyertown

United States

Conformant

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

China

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

China

Conformant

Tantalum

H.C. Starck Co., Ltd.

Thailand

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

Germany

Conformant

Tantalum

H.C. Starck Inc.

United States

Conformant

Tantalum

H.C. Starck Ltd.

Japan

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

Germany

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

Germany

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

China

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

China

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

China

Conformant

Tantalum

Jiujiang Janny New Material Co., Ltd.

China

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

China

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

China

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

China

Conformant

Tantalum

KEMET Blue Metals

Mexico

Conformant


14

Tantalum

Kemet Blue Powder

United States

Conformant

Tantalum

LSM Brasil S.A.

Brazil

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

India

Conformant

Tantalum

Mineracao Taboca S.A.

Brazil

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

Japan

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

China

Conformant

Tantalum

NPM Silmet AS

Estonia

Conformant

Tantalum

Power Resources Ltd.

Macedonia, The Former Yugoslav Republic Of

Conformant

Tantalum

QuantumClean

United States

Conformant

Tantalum

Resind Industria e Comercio Ltda.

Brazil

Conformant

Tantalum

Solikamsk Magnesium Works OAO

Russian Federation

Conformant

Tantalum

Taki Chemical Co., Ltd.

Japan

Conformant

Tantalum

Telex Metals

United States

Conformant

Tantalum

Ulba Metallurgical Plant JSC

Kazakhstan

Conformant

Tantalum

XinXing Haorong Electronic Material Co., Ltd.

China

Conformant

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

China

Conformant

Tin

Alpha

United States

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

Viet Nam

On Smelter Look-Up Tab Only

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

China

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

China

Conformant

Tin

China Tin Group Co., Ltd.

China

On Smelter Look-Up Tab Only


15

Tin

CV Ayi Jaya

Indonesia

Conformant

Tin

CV Dua Sekawan

Indonesia

Conformant

Tin

CV Gita Pesona

Indonesia

Conformant

Tin

CV United Smelting

Indonesia

Conformant

Tin

CV Venus Inti Perkasa

Indonesia

Conformant

Tin

Dowa

Japan

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

Viet Nam

On Smelter Look-Up Tab Only

Tin

EM Vinto

Bolivia

Conformant

Tin

Estanho de Rondonia S.A.

Brazil

On Smelter Look-Up Tab Only

Tin

Fenix Metals

Poland

On Smelter Look-Up Tab Only

Tin

Gejiu Fengming Metallurgy Chemical Plant

China

Conformant

Tin

Gejiu Jinye Mineral Company

China

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

China

On Smelter Look-Up Tab Only

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

China

On Smelter Look-Up Tab Only

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

China

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

China

On Smelter Look-Up Tab Only

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

China

Conformant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

China

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

China

Conformant


16

Tin

Huichang Jinshunda Tin Co., Ltd.

China

On Smelter Look-Up Tab Only

Tin

Jiangxi New Nanshan Technology Ltd.

China

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

Brazil

Conformant

Tin

Malaysia Smelting Corporation (MSC)

Malaysia

Conformant

Tin

Melt Metais e Ligas S.A.

Brazil

Conformant

Tin

Metallic Resources, Inc.

United States

Conformant

Tin

Metallo Belgium N.V.

Belgium

Conformant

Tin

Metallo Spain S.L.U.

Spain

Conformant

Tin

Mineracao Taboca S.A.

Brazil

Conformant

Tin

Minsur

Peru

Conformant

Tin

Mitsubishi Materials Corporation

Japan

Conformant

Tin

Modeltech Sdn Bhd

Malaysia

Conformant

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

Viet Nam

On Smelter Look-Up Tab Only

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

Thailand

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

Philippines

Conformant

Tin

Operaciones Metalurgical S.A.

Bolivia

Conformant

Tin

Pongpipat Company Limited

Myanmar

On Smelter Look-Up Tab Only

Tin

PT Aries Kencana Sejahtera

Indonesia

Conformant

Tin

PT Artha Cipta Langgeng

Indonesia

Conformant

Tin

PT ATD Makmur Mandiri Jaya

Indonesia

Conformant

Tin

PT Babel Inti Perkasa

Indonesia

Conformant

Tin

PT Babel Surya Alam Lestari

Indonesia

Conformant

Tin

PT Bangka Prima Tin

Indonesia

Conformant


17

Tin

PT Bangka Serumpun

Indonesia

Conformant

Tin

PT Bangka Tin Industry

Indonesia

Conformant

Tin

PT Belitung Industri Sejahtera

Indonesia

Conformant

Tin

PT Bukit Timah

Indonesia

Conformant

Tin

PT DS Jaya Abadi

Indonesia

Conformant

Tin

PT Inti Stania Prima

Indonesia

Conformant

Tin

PT Karimun Mining

Indonesia

Conformant

Tin

PT Kijang Jaya Mandiri

Indonesia

Conformant

Tin

PT Menara Cipta Mulia

Indonesia

Conformant

Tin

PT Mitra Stania Prima

Indonesia

Conformant

Tin

PT Panca Mega Persada

Indonesia

Conformant

Tin

PT Premium Tin Indonesia

Indonesia

Conformant

Tin

PT Prima Timah Utama

Indonesia

Conformant

Tin

PT Rajehan Ariq

Indonesia

Conformant

Tin

PT Refined Bangka Tin

Indonesia

Conformant

Tin

PT Sariwiguna Binasentosa

Indonesia

Conformant

Tin

PT Stanindo Inti Perkasa

Indonesia

Conformant

Tin

PT Sukses Inti Makmur

Indonesia

Conformant

Tin

PT Sumber Jaya Indah

Indonesia

Conformant

Tin

PT Timah (Persero) Tbk Kundur

Indonesia

Conformant

Tin

PT Timah (Persero) Tbk Mentok

Indonesia

Conformant

Tin

PT Tinindo Inter Nusa

Indonesia

Conformant

Tin

PT Tirus Putra Mandiri

Indonesia

Conformant

Tin

PT Tommy Utama

Indonesia

Conformant


18

Tin

Resind Industria e Comercio Ltda.

Brazil

Conformant

Tin

Rui Da Hung

Taiwan

Conformant

Tin

Soft Metais Ltda.

Brazil

Conformant

Tin

Super Ligas

Brazil

On Smelter Look-Up Tab Only

Tin

Thaisarco

Thailand

Conformant

Tin

Tin Technology & Refining

United States

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

Viet Nam

On Smelter Look-Up Tab Only

Tin

White Solder Metalurgia e Mineracao Ltda.

Brazil

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

China

Conformant

Tin

Yunnan Tin Company Limited

China

Conformant

Tungsten

A.L.M.T. TUNGSTEN Corp.

Japan

Conformant

Tungsten

ACL Metais Eireli

Brazil

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

China

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

China

Conformant

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

China

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

China

Conformant

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

China

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

China

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

China

Conformant

Tungsten

Global Tungsten & Powders Corp.

United States

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

China

Conformant


19

Tungsten

H.C. Starck Smelting GmbH & Co. KG

Germany

Conformant

Tungsten

H.C. Starck Tungsten GmbH

Germany

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

China

Conformant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

China

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

China

Conformant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

China

On Smelter Look-Up Tab Only

Tungsten

Hydrometallurg, JSC

Russian Federation

Conformant

Tungsten

Japan New Metals Co., Ltd.

Japan

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

China

Conformant

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

China

On Smelter Look-Up Tab Only

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

China

Conformant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

China

On Smelter Look-Up Tab Only

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

China

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

China

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

China

Conformant

Tungsten

Kennametal Fallon

United States

Conformant

Tungsten

Kennametal Huntsville

United States

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

China

Conformant

Tungsten

Masan Tungsten Chemical LLC (MTC)

Viet Nam

Conformant

Tungsten

Moliren Ltd.

Russian Federation

Conformant


20

Tungsten

Niagara Refining LLC

United States

Conformant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

Philippines

Conformant

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

China

Conformant

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

Viet Nam

Conformant

Tungsten

Unecha Refractory Metals Plant

Russian Federation

Conformant

Tungsten

Wolfram Bergbau und Hutten AG

Austria

Conformant

Tungsten

Woltech Korea Co., Ltd.

Korea, Republic of

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

China

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

China

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

China

Conformant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

China

Conformant

 

a)           "Conformant" means that a smelter or refiner was listed as Conformant with the Responsible Minerals Assurance Process ("RMAP") assessment protocols. Smelters and refiners listed as "re-audit in progress" are still considered to be Conformant. Included smelters and refiners were not necessarily Conformant for all or part of 2018 and may not continue to be Conformant for any future period.

 

b)          "Active" means that the smelter or refiner is a participant in the RMAP and has committed to undergo an RMAP assessment. Smelters and refiners are identified as Active in the RMAP once they have scheduled the assessment date.

 

c)           "On Smelter Look-Up Tab Only" means that a smelter or refiner is listed on the Smelter Look-up tab list of the CMRT, but is not listed as "Conformant" or "Active."

 

d)          Smelter or refiner status reflected in the table is based solely on information made publicly available by the RMI, without independent verification by SunPower.

 

e)           Country location is the location of the smelter or refiner and is based solely on information made publicly available by the RMI, without independent verification by SunPower.

 

21

Country of Origin Information

SunPower has endeavored to determine the mine or location of origin of the necessary 3TG contained in its in-scope products by requiring that the Suppliers provide it with completed CMRTs and through the other measures described in this Conflict Minerals Report. Where a smelter or refiner has been identified that is not Conformant, SunPower or the Service Provider also has reviewed public information, to the extent available, to try to determine the mine or location of origin of the 3TG processed by the smelter or refiner.

The countries of origin of the 3TG processed by smelters and refiners listed above may have included countries listed below (as well as possibly other countries). The countries below are sorted by risk level.

L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the Covered Countries: Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic of Korea, Russian Federation, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Turkey, United Kingdom, United States of America, Uzbekistan, Vietnam and Zimbabwe.

 

L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique, South Africa and United Arab Emirates.

 

L3 - The DRC and its adjoining countries: Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

 

DRC - Democratic Republic of the Congo.

The 3TG processed by the identified smelters and refiners also may have originated in whole or in part from recycled or scrap sources.

Due Diligence Improvement Measures

 

SunPower intends to further improve its due diligence measures for 2019 in order to mitigate the risk that the necessary 3TG in its in-scope products benefit armed groups by taking the following steps, among others:

 

     Continue to alert suppliers when SunPower obtains information that a 3TG smelter or refiner is believed to be irresponsibly sourcing 3TG.

 

     Request that suppliers who have identified non-Conformant or high-risk smelters require their upstream suppliers to find alternative sources of 3TG or require certification of the smelters and refiners in their supply chains.

22

     Include 3TG compliance in quarterly business reviews with suppliers.

 

     Review our 3TG compliance program for potential additional enhancements, in particular ways to enhance supplier engagement.

The foregoing steps are in addition to the steps that SunPower took for 2018.

23