Form SD Colfax CORP

 

 

United States

Securities and Exchange Commission

Washington, D.C. 20549

 

 

FORM SD

SPECIALIZED DISCLOSURE REPORT

 

 

Colfax Corporation

(Exact name of registrant as specified in its charter)

 

 

 

Delaware		001-34045		54-1887631
(State or other jurisdiction of incorporation or organization)		(Commission File Number)		(IRS Employer Identification No.)

 

420 National Business Parkway, 5th Floor Annapolis Junction, Maryland		20701
(Address of principal executive offices)		(Zip Code)

A. Lynne Puckett, Senior Vice President, General Counsel & Secretary

(301) 323-9000

(Name and telephone number, including area code, of the person to contact in connection with this report.)

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

x	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.

 

 

 

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Section 1—Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following Internet website: http://ir.colfaxcorp.com/governance.cfm. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.

Item 1.02 Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Section 2—Exhibits

Item 2.01 Exhibits

 

Exhibit 1.01		–		Conflict Minerals Report for the calendar year ended December 31, 2015

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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.

 

COLFAX CORPORATION
								Date: May 31, 2016
By:		/s/ Stephen Wittig
		Name:		Stephen Wittig
		Title:		Senior Vice President, CBS and Supply Chain

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EXHIBIT INDEX

 

Exhibit		Description
1.01		Conflict Minerals Report for the calendar year ended December 31, 2015

Exhibit 1.01

Conflict Minerals Report

Colfax Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for January 1^st 2015 to December 31^st 2015 as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 31, 2016.

Unless the context indicates otherwise, the terms “Colfax,” “we,” “its,” “us,” and “our” refer to Colfax Corporation and its consolidated subsidiaries. As used herein, “Conflict Minerals” or “3TG” are, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten.

Forward-Looking Statements

This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups.

Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.

Company and Product Information

Colfax Corporation is a diversified global industrial manufacturing and engineering company that provides gas- and fluid-handling and fabrication technology products and services to commercial and governmental customers around the world under the Howden, ESAB and Colfax Fluid Handling brand names.

Our in-scope product categories for 2015 were: (1) gas- and fluid-handling products, consisting of pumps, fluid-handling systems and controls, specialty valves, heavy-duty centrifugal and axial fans, rotary heat exchangers and gas compressors; and (2) welding equipment, cutting equipment and automated welding and cutting systems. For a further discussion of our products, see our Annual Report on Form 10-K for the year ended December 31, 2015. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or the Form SD.

Applicability of the Conflict Minerals Rule to Our Company

We are subject to the Conflict Minerals Rule because products that we manufacture contain 3TG that are necessary to their functionality or production. Our in-scope products contain tin, tantalum, tungsten and gold, although each in-scope product does not contain all four 3TG.

We generally do not source 3TG from smelters or refiners and have no direct relationships with mines, and we believe that we are in most cases many levels removed from all of these market participants. We therefore have limited influence over these upstream actors. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below, and encourage conflict free sourcing in our supply chain.

Product, smelter and refiner information in respect of 2015 is described under “Product Information” below and on Annex A. For 2015, each of our in-scope products contained 3TG content for which we were unable to determine the origin. None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.

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Our Conflict Minerals Policy

We are committed to being a responsible corporate citizen and are opposed to human rights abuses such as are occurring in the DRC. To this end, we have adopted and communicated to our suppliers and the public a company policy (the “Conflict Minerals Policy”) for the supply chain of 3TG.

The Conflict Minerals Policy includes, but is not limited to, our expectations that:

 

1.

The components, parts and products supplied to us are DRC conflict free within the meaning of the Conflict Minerals Rule;

 

2.

Our suppliers define, implement and communicate to sub-suppliers their own 3TG policy consistent with our Conflict Minerals Policy and 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 (the “OECD Guidance”); and

 

3.

Our suppliers implement policies, procedures and frameworks that are consistent with the OECD Guidance and require their direct and indirect sub-suppliers to do the same, and that our suppliers otherwise work with sub-suppliers to ensure traceability of 3TG.

We do not embargo sourcing of 3TG from the DRC region and encourage our suppliers to continue to source responsibly from the region, from sources that do not support conflict.

Reasonable Country of Origin Inquiry Information

As required by the Conflict Minerals Rule, for 2015, we conducted a “reasonable country of origin inquiry.” For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the OECD Guidance, which are discussed below.

Our inquiry included approximately 9,950 suppliers (the “Suppliers”) that we identified as having provided us with components, parts or products that contain 3TG or that we believe may have provided us with components, parts or products that contain 3TG. For 2015, the Suppliers identified to us 320 smelters and refiners that processed or may have processed the necessary 3TG contained in our in-scope products, as shown and described under Annex A below. These smelters and refiners include 216 smelters and refiners identified as “Compliant” and 47 identified as “Active,” each as defined in Annex A. This information is based primarily on company-level declarations from Suppliers. Accordingly, many of these smelters and refiners may not be part of our supply chain, as we generally were not able to collect data at the product-level.

Pursuant to the Conflict Minerals Rule, based on the results of our reasonable country of origin inquiry, we were required to conduct due diligence for 2015. These due diligence efforts are discussed below.

Due Diligence Program Design

Design Framework

We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the OECD Guidance, Second Edition 2013, including the related Supplements for tin, tantalum and tungsten and for gold (hereinafter referred to as the “OECD Guidance”).

Selected Elements of Design Framework

The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the elements of the program that we have put in place to help ensure that the 3TG contained in our in-scope products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2015 are discussed under “Due Diligence Program Execution.”

 

1.

OECD Guidance Step One: “Establish strong company management systems”

 

a.

We have a Conflict Minerals Policy. We communicate the policy internally to our sourcing teams and to selected suppliers. The Conflict Minerals Policy also is posted on our website.

 

b.

We have a team of senior staff under the Senior Vice President, Colfax Business System (“CBS”) and Supply Chain and General Counsel charged with managing our 3TG compliance strategy. The working group also includes representatives from each business platform. We supplement our compliance efforts with specialist outside counsel.

 

c.

Selected internal personnel are educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries.

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d.

We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict-Free Sourcing Initiative (the “CFSI”) to identify smelters and refiners in our supply chain. The CMRT requests suppliers to provide information concerning the usage and source of 3TG in their products, as well as information concerning their related compliance efforts. We utilize a third-party service provider (the “Service Provider”) to conduct our supplier outreach and follow-up, as well as for the review and validation of supplier responses.

 

e.

We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, for at least five years.

 

f.

The Service Provider provides training and educational materials to suppliers to enhance the quality of responses. During 2015 we also conducted supplier webcasts to further inform our supply base of our expectations and program goals, which were attended by a board range of suppliers.

 

g.

We have contractual terms relating to 3TG, which are incorporated into selected supplier contracts.

 

h.

We have a mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. The contact information for our grievance mechanism is www.colfaxcorp.ethicspoint.com.

 

2.

OECD Guidance Step Two: “Identify and assess risk in the supply chain”

 

a.

We request in writing, through the Service Provider, that suppliers provide us with a completed CMRT. The Service Provider follows up by email or phone on our behalf with suppliers that do not respond to the request within the specified time frame.

 

b.

The Service Provider on our behalf reviews supplier responses against its written review criteria to identify incomplete responses, potential errors and inaccuracies in the CMRTs that are received from suppliers. The Service Provider follows up by email or phone with suppliers that submit an incomplete response or a response that it concludes contains errors or inaccuracies.

 

c.

Smelter and refiner information provided by suppliers is reviewed by the Service Provider against the smelters and refiners listed on the Smelter Reference List tab of the CMRT and the list of known processing facilities published by the U.S. Department of Commerce (the “Commerce Department List”). To the extent that a smelter or refiner identified by a supplier is not on either of these lists, the Service Provider may take additional steps to attempt to determine whether the listed entity is a smelter or refiner.

 

d.

Smelter and refiner information also is reviewed against the lists of Compliant and Active smelters and refiners and country of origin information published by the CFSI. To the extent that a smelter or refiner identified by a supplier is not listed as Compliant by the CFSI, the Service Provider undertakes an additional review to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. The Service Provider attempts to reach out to the smelter or refiner directly and conducts research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of its 3TG.

 

e.

The Service Provider evaluates suppliers’ due diligence processes and policies based on the suppliers’ responses to certain of the questions in the CMRT. These questions ask suppliers about their internal processes regarding 3TG.

 

3.

OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks”

 

a.

Our 3TG compliance team reviews the reports and evaluations prepared by the Service Provider and liaises with appropriate members of senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence.

 

b.

We undertake additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries, and respond via supplier follow-up, commercial escalation or other commensurate means to the risks identified via these reviews.

 

4.

OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain”

In connection with our due diligence, we utilize information made available by the CFSI concerning independent third-party audits of smelters and refiners.

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5.

OECD Guidance Step 5 : “Report on supply chain due diligence”

We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission and make these filings available on our website.

Due Diligence Program Execution

We performed the following due diligence measures in respect of 2015. These are not all of the measures that we took in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, see “Due Diligence Program Design.”

 

1.

The Service Provider requested that the Suppliers provide us with a completed CMRT. Requests were sent to approximately 9,950 Suppliers. The Service Provider followed up by email or phone with Suppliers that did not respond to the request within a specified time frame. All non-responsive Suppliers were followed up with at least three times with a request to complete the CMRT.

 

2.

The Service Provider reviewed the responses received from the Suppliers based on its written review criteria for completeness, errors and inaccuracies. The Service Provider generally followed up by email or phone with the Suppliers that submitted a response that triggered specified quality issues relating to completeness and accuracy.

 

3.

To the extent that a completed response identified a smelter or refiner, the Service Provider reviewed that information against the lists of Compliant and Active smelters published by the CFSI. 216 of the identified smelters and refiners were listed as Compliant by the CFSI and 47 were listed as Active, as of May 31, 2016. Please see Annex A below for further information regarding the smelters and refiners identified to us through our reasonable county of origin inquiry and due diligence.

 

4.

To the extent that a smelter or refiner identified by a Supplier was not listed as Compliant by the CFSI, the Service Provider attempted to reach out to the smelter or refiner directly and conducted research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of the sources of its 3TG.

 

5.

Our 3TG compliance team reviewed the reports and evaluations prepared by the Service Provider and liaised with members of our senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence

 

6.

We undertook additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries.

Identified Smelters and Refiners

In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the facilities listed on Annex A below either as part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2015. Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products.

Please see Annex A below for further information regarding the smelters and refiners identified to us by the Suppliers.

We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us or our Service Provider with a completed CMRT, and through the other activities described herein that were taken by us or the Service Provider.

Future Risk Mitigation Efforts

We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups in the DRC and its adjoining countries. These steps are in addition to the steps that we took in respect of 2015, which we intend to continue to take in respect of 2016 to the extent applicable.

 

1.

Engage with applicable Suppliers that provided incomplete responses or that did not provide responses for 2015 to help ensure that they provide requested information for 2016.

 

Ø

Provide additional outreach to suppliers with non-compliant responses

 

Ø

Conduct further training for suppliers

 

Ø

Work to identify improved supplier contacts for non-respondents

 

2.

Encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2015 that the source of 3TG was unknown or undeterminable.

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3.

Continue communicating to suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them and required adherence to contractual sourcing requirements.

 

4.

Continue to focus risk mitigation efforts on relevant suppliers

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Annex A

Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.

Smelters and Refiners

In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below as either being part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2015. Please see the notes that accompany the tables for additional information concerning the information in the tables.

Summary Smelter and Refiner Information

 

Metal		Compliant		Active		On Reference List Only		Total
Tantalum		46		1		2		49
Tin		59		17		15		91
Tungsten		31		14		4		49
Gold		80		15		36		131
Totals		216		47		57		320

Smelter and Refiner Names and Status

 

Metal		Standard Smelter Name		Facility Location		CFSI Audit Status
Gold		Advanced Chemical Company		UNITED STATES		Active
Gold		Aida Chemical Industries Co., Ltd.		JAPAN		Compliant
Gold		Aktyubinsk Copper Company TOO		KAZAKHSTAN		On Reference List Only
Gold		Al Etihad Gold Refinery DMCC		UNITED ARAB EMIRATES		On Reference List Only
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY		Compliant
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN		Active
Gold		AngloGold Ashanti Córrego do Sítio Mineração		BRAZIL		Compliant
Gold		Argor-Heraeus SA		SWITZERLAND		Compliant
Gold		Asahi Pretec Corporation		JAPAN		Compliant
Gold		Asahi Refining Canada Limited		CANADA		Compliant
Gold		Asahi Refining USA Inc.		UNITED STATES		Compliant
Gold		Asaka Riken Co., Ltd.		JAPAN		Compliant
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY		On Reference List Only
Gold		Aurubis AG		GERMANY		Compliant
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES		Compliant
Gold		Bauer Walser AG		GERMANY		On Reference List Only
Gold		Boliden AB		SWEDEN		Compliant
Gold		C. Hafner GmbH + Co. KG		GERMANY		Compliant
Gold		Caridad		MEXICO		On Reference List Only
Gold		CCR Refinery – Glencore Canada Corporation		CANADA		Compliant

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Gold		Cendres + Métaux SA		SWITZERLAND		Active
Gold		Chimet S.p.A.		ITALY		Compliant
Gold		Chugai Mining		JAPAN		On Reference List Only
Gold		Daejin Indus Co., Ltd.		KOREA, REPUBLIC OF		Active
Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA		On Reference List Only
Gold		Do Sung Corporation		KOREA, REPUBLIC OF		Active
Gold		DODUCO GmbH		GERMANY		Compliant
Gold		Dowa		JAPAN		Compliant
Gold		Eco-System Recycling Co., Ltd.		JAPAN		Compliant
Gold		Elemetal Refining, LLC		UNITED STATES		Compliant
Gold		Emirates Gold DMCC		UNITED ARAB EMIRATES		Compliant
Gold		Faggi Enrico S.p.A.		ITALY		Active
Gold		Gansu Seemine Material Hi-Tech Co., Ltd.		CHINA		On Reference List Only
Gold		Geib Refining Corporation		UNITED STATES		Active
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA		On Reference List Only
Gold		Guangdong Jinding Gold Limited		CHINA		On Reference List Only
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA		On Reference List Only
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA		On Reference List Only
Gold		Heimerle + Meule GmbH		GERMANY		Compliant
Gold		Heraeus Ltd. Hong Kong		CHINA		Compliant
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY		Compliant
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA		On Reference List Only
Gold		Hwasung CJ Co., Ltd.		KOREA, REPUBLIC OF		On Reference List Only
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited		CHINA		Compliant
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN		Compliant
Gold		Istanbul Gold Refinery		TURKEY		Compliant
Gold		Japan Mint		JAPAN		Compliant
Gold		Jiangxi Copper Company Limited		CHINA		Compliant
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION		Compliant
Gold		JSC Uralelectromed		RUSSIAN FEDERATION		Compliant
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN		Compliant
Gold		Kaloti Precious Metals		UNITED ARAB EMIRATES		On Reference List Only
Gold		Kazakhmys Smelting LLC		KAZAKHSTAN		On Reference List Only
Gold		Kazzinc		KAZAKHSTAN		Compliant
Gold		Kennecott Utah Copper LLC		UNITED STATES		Compliant
Gold		KGHM Polska Miedź Spółka Akcyjna		POLAND		Active
Gold		Kojima Chemicals Co., Ltd.		JAPAN		Compliant
Gold		Korea Metal Co., Ltd.		KOREA, REPUBLIC OF		On Reference List Only
Gold		Korea Zinc Co. Ltd.		KOREA, REPUBLIC OF		Active
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN		On Reference List Only
Gold		L’ azurde Company For Jewelry		SAUDI ARABIA		On Reference List Only
Gold		Lingbao Gold Company Limited		CHINA		On Reference List Only
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA		On Reference List Only
Gold		LS-NIKKO Copper Inc.		KOREA, REPUBLIC OF		Compliant
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA		On Reference List Only
Gold		Materion		UNITED STATES		Compliant

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Gold		Matsuda Sangyo Co., Ltd.		JAPAN		Compliant
Gold		Metahub Industries Sdn. Bhd.		MALAYSIA		On Reference List Only
Gold		Metalor Technologies (Hong Kong) Ltd.		CHINA		Compliant
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE		Compliant
Gold		Metalor Technologies (Suzhou) Ltd.		CHINA		Active
Gold		Metalor Technologies SA		SWITZERLAND		Compliant
Gold		Metalor USA Refining Corporation		UNITED STATES		Compliant
Gold		METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V		MEXICO		Compliant
Gold		Mitsubishi Materials Corporation		JAPAN		Compliant
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN		Compliant
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA		Compliant
Gold		Morris and Watson		NEW ZEALAND		On Reference List Only
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION		Compliant
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		TURKEY		Compliant
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN		Active
Gold		Nihon Material Co., Ltd.		JAPAN		Compliant
Gold		Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH		AUSTRIA		Compliant
Gold		Ohura Precious Metal Industry Co., Ltd.		JAPAN		Compliant
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		RUSSIAN FEDERATION		Compliant
Gold		OJSC Kolyma Refinery		RUSSIAN FEDERATION		On Reference List Only
Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION		Compliant
Gold		PAMP SA		SWITZERLAND		Compliant
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA		On Reference List Only
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION		Compliant
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA		Compliant
Gold		PX Précinox SA		SWITZERLAND		Compliant
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA		Compliant
Gold		Republic Metals Corporation		UNITED STATES		Compliant
Gold		Royal Canadian Mint		CANADA		Compliant
Gold		SAAMP		FRANCE		On Reference List Only
Gold		Sabin Metal Corp.		UNITED STATES		On Reference List Only
Gold		Samduck Precious Metals		KOREA, REPUBLIC OF		Active
Gold		SAMWON Metals Corp.		KOREA, REPUBLIC OF		On Reference List Only
Gold		SAXONIA Edelmetalle GmbH		GERMANY		Active
Gold		Schone Edelmetaal B.V.		NETHERLANDS		Compliant
Gold		SEMPSA Joyería Platería SA		SPAIN		Compliant
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		CHINA		On Reference List Only
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA		Compliant
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA		Compliant
Gold		Singway Technology Co., Ltd.		TAIWAN		Compliant
Gold		So Accurate Group, Inc.		UNITED STATES		On Reference List Only
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION		Compliant
Gold		Solar Applied Materials Technology Corp.		TAIWAN		Compliant
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN		Compliant
Gold		T.C.A S.p.A		ITALY		Compliant
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN		Compliant

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Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA		Compliant
Gold		Tokuriki Honten Co., Ltd.		JAPAN		Compliant
Gold		Tongling Nonferrous Metals Group Co., Ltd.		CHINA		On Reference List Only
Gold		Tony Goetz NV		BELGIUM		On Reference List Only
Gold		Torecom		KOREA, REPUBLIC OF		Active
Gold		Umicore Brasil Ltda.		BRAZIL		Compliant
Gold		Umicore Precious Metals Thailand		THAILAND		Compliant
Gold		Umicore SA Business Unit Precious Metals Refining		BELGIUM		Compliant
Gold		United Precious Metal Refining, Inc.		UNITED STATES		Compliant
Gold		Valcambi SA		SWITZERLAND		Compliant
Gold		Western Australian Mint trading as The Perth Mint		AUSTRALIA		Compliant
Gold		WIELAND Edelmetalle GmbH		GERMANY		Active
Gold		Yamamoto Precious Metal Co., Ltd.		JAPAN		Compliant
Gold		Yokohama Metal Co., Ltd.		JAPAN		Compliant
Gold		Yunnan Copper Industry Co., Ltd.		CHINA		On Reference List Only
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA		Compliant
Gold		Zijin Mining Group Co., Ltd. Gold Refinery		CHINA		Compliant
Tantalum		Avon Specialty Metals Ltd		UNITED KINGDOM		On Reference List Only
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA		Compliant
Tantalum		Conghua Tantalum and Niobium Smeltry		CHINA		Compliant
Tantalum		D Block Metals, LLC		UNITED STATES		Compliant
Tantalum		Duoluoshan		CHINA		Compliant
Tantalum		E.S.R. Electronics		UNITED STATES		Active
Tantalum		Exotech Inc.		UNITED STATES		Compliant
Tantalum		F&X Electro-Materials Ltd.		CHINA		Compliant
Tantalum		FIR Metals & Resource Ltd.		CHINA		Compliant
Tantalum		Global Advanced Metals Aizu		JAPAN		Compliant
Tantalum		Global Advanced Metals Boyertown		UNITED STATES		Compliant
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA		Compliant
Tantalum		Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch		CHINA		On Reference List Only
Tantalum		H.C. Starck Co., Ltd.		THAILAND		Compliant
Tantalum		H.C. Starck GmbH Goslar		GERMANY		Compliant
Tantalum		H.C. Starck GmbH Laufenburg		GERMANY		Compliant
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY		Compliant
Tantalum		H.C. Starck Inc.		UNITED STATES		Compliant
Tantalum		H.C. Starck Ltd.		JAPAN		Compliant
Tantalum		H.C. Starck Smelting GmbH & Co.KG		GERMANY		Compliant
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA		Compliant
Tantalum		Hi-Temp Specialty Metals, Inc.		UNITED STATES		Compliant
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA		Compliant
Tantalum		Jiangxi Tuohong New Raw Material		CHINA		Compliant
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA		Compliant
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA		Compliant
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA		Compliant
Tantalum		KEMET Blue Metals		MEXICO		Compliant
Tantalum		KEMET Blue Powder		UNITED STATES		Compliant
Tantalum		King-Tan Tantalum Industry Ltd.		CHINA		Compliant

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Tantalum		LSM Brasil S.A.		BRAZIL		Compliant
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA		Compliant
Tantalum		Mineração Taboca S.A.		BRAZIL		Compliant
Tantalum		Mitsui Mining & Smelting		JAPAN		Compliant
Tantalum		Molycorp Silmet A.S.		ESTONIA		Compliant
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA		Compliant
Tantalum		Plansee SE Liezen		AUSTRIA		Compliant
Tantalum		Plansee SE Reutte		AUSTRIA		Compliant
Tantalum		QuantumClean		UNITED STATES		Compliant
Tantalum		Resind Indústria e Comércio Ltda.		BRAZIL		Compliant
Tantalum		RFH Tantalum Smeltry Co., Ltd.		CHINA		Compliant
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION		Compliant
Tantalum		Taki Chemicals		JAPAN		Compliant
Tantalum		Telex Metals		UNITED STATES		Compliant
Tantalum		Tranzact, Inc.		UNITED STATES		Compliant
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN		Compliant
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA		Compliant
Tantalum		Yichun Jin Yang Rare Metal Co., Ltd.		CHINA		Compliant
Tantalum		Zhuzhou Cemented Carbide		CHINA		Compliant
Tin		Alpha		UNITED STATES		Compliant
Tin		An Thai Minerals Company Limited		VIET NAM		Active
Tin		An Vinh Joint Stock Mineral Processing Company		VIET NAM		Active
Tin		Chenzhou Yun Xiang mining limited liability company		CHINA		Active
Tin		China Tin Group Co., Ltd.		CHINA		Compliant
Tin		CNMC (Guangxi) PGMA Co., Ltd.		CHINA		On Reference List Only
Tin		Cooperativa Metalurgica de Rondônia Ltda.		BRAZIL		Compliant
Tin		CV Ayi Jaya		INDONESIA		Compliant
Tin		CV Dua Sekawan		INDONESIA		Active
Tin		CV Gita Pesona		INDONESIA		Compliant
Tin		CV Serumpun Sebalai		INDONESIA		Compliant
Tin		CV Tiga Sekawan		INDONESIA		Active
Tin		CV United Smelting		INDONESIA		Compliant
Tin		CV Venus Inti Perkasa		INDONESIA		Compliant
Tin		Dowa		JAPAN		Compliant
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIET NAM		Active
Tin		Elmet S.L.U. (Metallo Group)		SPAIN		Compliant
Tin		EM Vinto		BOLIVIA		Compliant
Tin		Estanho de Rondônia S.A.		BRAZIL		On Reference List Only
Tin		Feinhütte Halsbrücke GmbH		GERMANY		On Reference List Only
Tin		Fenix Metals		POLAND		Compliant
Tin		Gejiu Fengming Metalurgy Chemical Plant		CHINA		Active
Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA		Active
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA		Compliant
Tin		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		CHINA		Active
Tin		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA		On Reference List Only
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA		Active

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Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA		Active
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA		On Reference List Only
Tin		Jiangxi Ketai Advanced Material Co., Ltd.		CHINA		Compliant
Tin		Linwu Xianggui Ore Smelting Co., Ltd.		CHINA		On Reference List Only
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL		Compliant
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA		Compliant
Tin		Melt Metais e Ligas S/A		BRAZIL		Compliant
Tin		Metahub Industries Sdn. Bhd.		MALAYSIA		On Reference List Only
Tin		Metallic Resources, Inc.		UNITED STATES		Compliant
Tin		Metallo-Chimique N.V.		BELGIUM		Compliant
Tin		Mineração Taboca S.A.		BRAZIL		Compliant
Tin		Minsur		PERU		Compliant
Tin		Mitsubishi Materials Corporation		JAPAN		Compliant
Tin		Nankang Nanshan Tin Manufactory Co., Ltd.		CHINA		On Reference List Only
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		VIET NAM		Active
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND		Compliant
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES		Compliant
Tin		Operaciones Metalurgical S.A.		BOLIVIA		Compliant
Tin		Phoenix Metal Ltd.		RWANDA		Active
Tin		PT Alam Lestari Kencana		INDONESIA		On Reference List Only
Tin		PT Aries Kencana Sejahtera		INDONESIA		Compliant
Tin		PT Artha Cipta Langgeng		INDONESIA		Compliant
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA		Compliant
Tin		PT Babel Inti Perkasa		INDONESIA		Compliant
Tin		PT Bangka Kudai Tin		INDONESIA		On Reference List Only
Tin		PT Bangka Prima Tin		INDONESIA		Compliant
Tin		PT Bangka Timah Utama Sejahtera		INDONESIA		On Reference List Only
Tin		PT Bangka Tin Industry		INDONESIA		Compliant
Tin		PT Belitung Industri Sejahtera		INDONESIA		Compliant
Tin		PT BilliTin Makmur Lestari		INDONESIA		Compliant
Tin		PT Bukit Timah		INDONESIA		Compliant
Tin		PT Cipta Persada Mulia		INDONESIA		Compliant
Tin		PT DS Jaya Abadi		INDONESIA		Compliant
Tin		PT Eunindo Usaha Mandiri		INDONESIA		Compliant
Tin		PT Fang Di MulTindo		INDONESIA		On Reference List Only
Tin		PT Inti Stania Prima		INDONESIA		Compliant
Tin		PT Justindo		INDONESIA		Compliant
Tin		PT Karimun Mining		INDONESIA		Active
Tin		PT Kijang Jaya Mandiri		INDONESIA		Active
Tin		PT Mitra Stania Prima		INDONESIA		Compliant
Tin		PT Panca Mega Persada		INDONESIA		Compliant
Tin		PT Pelat Timah Nusantara Tbk		INDONESIA		On Reference List Only
Tin		PT Prima Timah Utama		INDONESIA		Compliant
Tin		PT Refined Bangka Tin		INDONESIA		Compliant
Tin		PT Sariwiguna Binasentosa		INDONESIA		Compliant
Tin		PT Seirama Tin Investment		INDONESIA		On Reference List Only
Tin		PT Stanindo Inti Perkasa		INDONESIA		Compliant

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Tin		PT Sukses Inti Makmur		INDONESIA		Compliant
Tin		PT Sumber Jaya Indah		INDONESIA		Compliant
Tin		PT Timah (Persero) Tbk Kundur		INDONESIA		Compliant
Tin		PT Timah (Persero) Tbk Mentok		INDONESIA		Compliant
Tin		PT Tinindo Inter Nusa		INDONESIA		Compliant
Tin		PT Tirus Putra Mandiri		INDONESIA		On Reference List Only
Tin		PT Tommy Utama		INDONESIA		Compliant
Tin		PT Wahana Perkit Jaya		INDONESIA		Compliant
Tin		Resind Indústria e Comércio Ltda.		BRAZIL		Compliant
Tin		Rui Da Hung		TAIWAN		Compliant
Tin		Soft Metais Ltda.		BRAZIL		Compliant
Tin		Thaisarco		THAILAND		Compliant
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIET NAM		Active
Tin		VQB Mineral and Trading Group JSC		VIET NAM		Compliant
Tin		White Solder Metalurgia e Mineração Ltda.		BRAZIL		Compliant
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA		Active
Tin		Yunnan Tin Group (Holding) Company Limited		CHINA		Compliant
Tungsten		A.L.M.T. TUNGSTEN Corp.		JAPAN		Compliant
Tungsten		ACL Metais Eireli		BRAZIL		Active
Tungsten		Asia Tungsten Products Vietnam Ltd.		VIET NAM		Compliant
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA		Compliant
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Dayu Jincheng Tungsten Industry Co., Ltd.		CHINA		TI-CMC Member
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		CHINA		TI-CMC Member
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Ganxian Shirui New Material Co., Ltd.		CHINA		On Reference List Only
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA		Compliant
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA		Compliant
Tungsten		Ganzhou Non-ferrous Metals Smelting Co., Ltd.		CHINA		TI-CMC Member
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA		Compliant
Tungsten		Ganzhou Yatai Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES		Compliant
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		H.C. Starck GmbH		GERMANY		Compliant
Tungsten		H.C. Starck Smelting GmbH & Co.KG		GERMANY		Compliant
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA		Compliant
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA		Compliant
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin		CHINA		On Reference List Only
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA		Compliant
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION		Compliant
Tungsten		Japan New Metals Co., Ltd.		JAPAN		Compliant
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA		Active
Tungsten		Jiangxi Dayu Longxintai Tungsten Co., Ltd.		CHINA		Active
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA		On Reference List Only
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA		Active

---

Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA		Active
Tungsten		Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.		CHINA		Compliant
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA		Active
Tungsten		Kennametal Fallon		UNITED STATES		Active
Tungsten		Kennametal Huntsville		UNITED STATES		Compliant
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Moliren Ltd		RUSSIAN FEDERATION		Active
Tungsten		Niagara Refining LLC		UNITED STATES		Compliant
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		VIET NAM		Compliant
Tungsten		Philippine Chuangin Industrial Co., Inc.		PHILIPPINES		Compliant
Tungsten		Pobedit, JSC		RUSSIAN FEDERATION		TI-CMC Member
Tungsten		Sanher Tungsten Vietnam Co., Ltd.		VIET NAM		On Reference List Only
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIET NAM		Compliant
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd.		VIET NAM		Compliant
Tungsten		Wolfram Bergbau und Hütten AG		AUSTRIA		Compliant
Tungsten		Woltech Korea Co., Ltd.		KOREA, REPUBLIC OF		Active
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA		Compliant
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA		Compliant
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA		Active
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA		Compliant

We note the following in connection with the information contained in the foregoing tables:

 

(a)

The smelters and refiners reflected in the tables were identified by the Suppliers to us as potentially being part of our 2015 supply chain. However, not all of the included smelters and refiners are believed by us to have processed the necessary 3TG contained in our in-scope products, since most Suppliers reported to us at a “company level” the 3TG contained in all of their products, not just those in the products that they sold to us. Some Suppliers also may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners reflected above may not be all of the smelters and refiners in our supply chain, since many Suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products and not all of the Suppliers responded to our inquiries.

 

(b)	All compliance status information in the tables is as of May 1, 2016.

 

(c)

“Compliant” means that a smelter or refiner was listed as compliant with the Conflict-Free Smelter Program’s (“CSFP”) assessment protocols, including through mutual recognition and those indicated as “Re-audit in process,” as publicly reported by the CFSI. Included smelters and refiners were not necessarily Compliant for all or part of 2015 and may not continue to be Compliant for any future period.

 

(d)

“Active” means that the smelter or refiner was listed as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or the smelter has agreed to complete a CFSP validation audit within two years of membership issuance by the Tungsten Industry – Council Minerals Council, in each case according to information published by the CFSI.

 

(e)	A smelter or refiner is listed as “On Reference List Only” if it was not Compliant or Active.

 

(f)	The compliance status in both tables are based information published by the CFSI, without independent verification by us.

 

(g)	The tables include only entities that are listed as verified smelters on the Smelter Reference List tab of the CMRT, Revision 4.01b, or that are listed on the Commerce Department List.

 

(h)	Smelter and refiner country location is based on information published by the CFSI, without independent verification by us.

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Country of Origin Information

The identified countries of origin of the 3TG processed by the Compliant smelters and refiners listed in the table above may have included the countries in the categories listed below. We have not been able to reliably determine the country of origin of any of the other smelters or refiners listed in the table. The countries below are categorized by risk.

L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries.: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Ecuador, 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, United Kingdom, United States, 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 and South Africa.

L3 – The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.

DRC – The Democratic Republic of the Congo.

Alternatively, or in addition, some of the Compliant smelters and refiners may have sourced from recycled or scrap sources.

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