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May 25, 2016 4:16 PM EDT


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


 
 
FORM SD 
 
 


SPECIALIZED DISCLOSURE REPORT

________________________

EMC CORPORATION
(Exact name of registrant as specified in its charter)

Massachusetts
1-9853
04-2680009
(State or other jurisdiction of
incorporation or organization)
(Commission
File Number)
(IRS Employer
Identification No.)
 
 
176 South Street
Hopkinton, Massachusetts
(Address of principal executive offices)
 
01748
(Zip code)
 
 
 
Paul T. Dacier
Executive Vice President and General Counsel
(508) 435-1000
(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.





Item 1.01
Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

A copy of EMC Corporation’s Conflict Minerals Report filed for the calendar year ended December 31, 2015 is publicly available at http://www.emc.com/collateral/sustainability/conflict-minerals-report-2015.pdf.

The Conflict Minerals Report includes a description of the Corporation’s Reasonable Country of Origin Inquiry and its conclusions on the origin of conflict minerals, including any facilities that process only recycled or scrap material.

Item 1.02
Exhibit

EMC Corporation’s Conflict Minerals Report for the calendar year ended December 31, 2015 is filed as Exhibit 1.01 hereto.

Item 2.01
Exhibits

Exhibit 1.01
Conflict Minerals Report of EMC Corporation as required by Items 1.01 and 1.02 of this Form.




SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
            
EMC CORPORATION
 
By:
/s/ Denis G. Cashman
 
Denis G. Cashman
 
Chief Financial Officer and Chief Accounting Officer
                
Date:    May 25, 2016





Exhibit 1.01
EMC CORPORATION
CONFLICT MINERALS REPORT
For the year ended December 31, 2015
INTRODUCTION
As part of our global approach to the protection of human rights, EMC is committed to the ethical sourcing of minerals, and in particular of tantalum, tin, tungsten and gold (“3TG”). There is concern that 3TG, often referred to as “conflict minerals,” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.
As stated in our Conflict Minerals Policy, it is our goal not to purchase product materials containing 3TG whose sale finance armed conflict in the DRC. However, we believe being “DRC Conflict-Free” should not mean “DRC-Free”. We intend to source responsibly from the DRC and adjoining countries (collectively, the “Covered Countries”) in order to support peaceful economic activity in the region.
SUMMARY
In 2015, EMC manufactured and contracted to manufacture products in which “conflict minerals” (defined in the U.S. Securities and Exchange Commission Release No. 34-67716 as cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to 3TG) are necessary to the functionality or production of such products. As we do not yet know the source of all the 3TG in these products, we do not have sufficient information to conclude that any of these products are “DRC Conflict-Free.”
In 2015, we saw an increase in the percentage of smelters and refiners in our supply chain that are compliant with the Conflict-Free Smelter Program (CFSP). However, we also identified new sources of concern in our 3TG supply chain, as described below. Therefore, we continue our work to build a responsible and transparent mineral supply chain, and intend to use our increased visibility into potential risks to inform our due diligence. This report describes our approach and our efforts.
OUR APPROACH
Researching the origin of minerals through the supply chain is a complex endeavor. As a manufacturer of enterprise IT systems, we consume components and materials containing 3TG and do not purchase 3TG directly from mines, smelters or refiners. Therefore, to meet our goal of being DRC Conflict-Free, we must collaborate with suppliers, industry peers, and other stakeholders.
EMC is a member of, and active participant in, the Conflict-Free Sourcing Initiative (the “CFSI”), a multi-industry initiative addressing conflict minerals issues in the supply chain. The CFSI’s Conflict Minerals Reporting Template (the “CMRT”) is a widely-used standard form to collect information through the supply chain, including the names of 3TG smelters and refiners. CFSI also manages the CFSP, which uses independent third-party audits to assess whether 3TG smelters and refiners have systems in place to assure sourcing of only DRC Conflict-Free materials. We use the CMRT to survey our suppliers and identify smelters and refiners in our supply chain, and the CFSP to determine the country of origin and DRC Conflict-Free status of minerals.




OUR STRATEGY
To reach our goal of being DRC Conflict-Free, we set a three-pronged strategy focusing first on supplier-level engagement, where we have the most direct influence, then on the smelter and refiner level, and third on encouraging responsible sourcing from the Covered Countries.
1.
Engage suppliers in due diligence and conflict-free sourcing
◦
Survey suppliers using the CMRT
◦
Offer resources and education on the issue of conflict minerals and best practices in due diligence
◦
Influence the supply chain to shift to CFSP-compliant smelters and refiners
2.
Increase the number of conflict-free smelters and refiners
◦
Identify 3TG smelters and refiners in our supply chain
◦
Help advance the CFSP through active participation in CFSI workgroups
◦
Encourage smelters and refiners in our supply chain to undergo an audit to be CFSP-compliant
3.
Encourage responsible sourcing from the Covered Countries
◦
Promote verifiable conflict-free sourcing from the Covered Countries in order to support peaceful economic activity
OUR PRODUCTS
This report relates to products EMC manufactured or contracted to be manufactured in 2015 that contain 3TG that may be considered necessary to the functionality or production of such products. EMC offers a comprehensive portfolio of storage systems, data protection and availability systems, converged infrastructure, and security products. These hardware products were in scope for our conflict minerals due diligence efforts in 2015.
OUR CONFLICT MINERALS POLICY AND PROGRAM
EMC’s Conflict Minerals Policy states our goal to be DRC Conflict-Free, our expectations of our suppliers, and our approach of broad collaboration with suppliers, industry peers, and other stakeholders. Supplier requirements for conflict minerals due diligence are embedded in EMC’s supply chain management. Our Supplier Code of Conduct requires direct materials suppliers to have a conflict minerals policy and conduct due diligence on the source and chain of custody of the 3TG in their products. These same requirements are included in our standard contracts and purchase agreements.
EMC’s program is overseen by a Conflict Minerals Governance Committee that provides strategic direction and input to EMC’s conflict minerals policy, supplier requirements, communications, and risk management. This committee includes executives from Global Supply Chain Management, Global Supply Chain Engineering, and the Office of Sustainability, as well as representatives from Finance, Legal, Global Product Operations Sustainability, Government Affairs and Internal Audit. This committee reports to the Audit Committee of the Board of Directors.
OUR SUPPLY CHAIN
Reasonable Country of Origin Inquiry
The first step in our compliance process was to identify suppliers who provide us with components that are known to, or could potentially, contain 3TG. We included Tier 1 suppliers who sell directly to EMC, and other suppliers from whom we instruct Tier 1 suppliers to purchase parts for the components they sell to us (“Tier 2+”). We asked these suppliers to survey their own supply chain and report to us using the CMRT. Suppliers representing 99% of our Tier 1 and 98% of our Tier 2+ 2015 spend submitted CMRTs to us.




EMC compared the list of smelters and refiners reported by suppliers against the CFSI’s smelter reference list (verified 3TG smelters and refiners). As of May 6, 2016, of the 302 verified 3TG smelter and refiner facilities in our supply chain, 214 are compliant with CFSP and have been found to be DRC Conflict-Free. The list of these verified smelters and refiners that our suppliers reported as being in their supply chains is set forth in Appendix A. The list of countries from which we believe the 3TG in our products may have originated is set forth in Appendix B. Some 3TG also originated from recycled or scrap sources. This information was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report dated May 3, 2016 that is available to EMC as a member of CFSI.
We then mapped our suppliers against our covered products and reviewed the smelter lists for those suppliers. We found that for each covered product category:
•
Some 3TG is sourced through verified smelters and refiners that are not yet CFSP-compliant and therefore we have not yet determined the country of origin of those minerals; and

•
Some 3TG is sourced from CFSP-compliant smelters or refiners, including smelters or refiners that source responsibly from the Covered Countries.

This supplier survey and smelter review process constituted our Reasonable Country of Origin Inquiry (RCOI). This RCOI combined with our risk assessment and mitigation efforts described below represent EMC’s best efforts to trace the source of the 3TG in our supply chain to the mine or location of origin as necessary.
Supply Chain Risk Assessment
Assessing supplier responses
We depend on supplier reporting to conduct our due diligence. Therefore, complete and correct supplier reporting, as well as supplier cooperation with our commitment to DRC Conflict-Free sourcing, reduces the risk that EMC will purchase products and/or materials containing minerals whose sale financed armed conflict in the DRC.
Each supplier’s CMRT was reviewed against an internally-developed framework for reasonableness and risk. We sought to understand our suppliers’ progress on due diligence, confirm whether they had published a conflict minerals policy, and obtain a list of 3TG smelters and refiners in their supply chain. In analyzing supplier responses to our survey, we found three areas that pose challenges: accurate smelter and refiner lists, determining whether 3TG was sourced from the Covered Countries, and publication of conflict minerals policies.
Smelter and Refiner Lists: Obtaining a complete and accurate list of smelters and refiners in our supply chain is an essential step in the RCOI process. The quality of suppliers’ smelter lists improved in 2015 compared to previous years, with fewer suppliers reporting company names that are not actual 3TG smelters or refiners. However, as would be expected in a complex global supply chain, we continue to receive new smelter or refiner names which must be researched to determine if they are, in fact, actual 3TG smelters or refiners.
Determining Whether 3TG Was Sourced from the Covered Countries: EMC is committed to being DRC Conflict-Free and to sourcing responsibly from the Covered Countries through CFSP-compliant smelters or refiners. However, many suppliers are still learning how to determine the country of origin of 3TG. For example, some of our suppliers reported that none of the 3TG in their products originated from the Covered Countries when, in fact, CFSP-compliant smelters in their supply chain publicly disclose that they do source from the Covered Countries. Other suppliers reported that they were sourcing 3TG from the Covered Countries, but did not specify how they had come to this conclusion, or whether that 3TG was sourced through CFSP-compliant smelters. In both situations, when we contacted these suppliers to discuss their responses, we found that many had either misunderstood how to use CFSP to determine country of origin, or they had based their responses solely on what their suppliers had reported to them.




Conflict Minerals Policies: Suppliers who publish their conflict minerals policy show commitment to responsible sourcing. We found that some suppliers declared that they use 3TG, but either did not have, or had not published, a conflict minerals policy. Some suppliers who did publish a conflict minerals policy stated their intent not to source from central Africa. While we believe these suppliers have good intentions, policies that include such statements raise concerns that suppliers do not understand that it is possible to source responsibly from the Covered Countries, and that these misconceptions could contribute to a drop in trade of conflict-free minerals from that region. Under our Conflict Minerals Policy, we intend to be “DRC Conflict-Free,” not “DRC-free,” and therefore we support responsible sourcing from the Covered Countries in order to support peaceful economic activity in the region.
Assessing smelters and refiners
In analyzing our smelter and refiner data, we identified three areas of concern: the need for more smelters and refiners to be CFSP-compliant, smelters and refiners being removed from responsible sourcing program lists, and the discovery of other potential risks that were not related to conflict in the DRC. We found that these areas of concern are more prevalent among gold refiners than among 3T smelters.
Supply of CFSP-compliant Smelters and Refiners: As a downstream company, EMC utilizes the CFSP for smelter and refiner audits and to assess risks in the mineral supply chain from the mine to the smelter or refiner. Figure 1 shows the number of CFSP-Compliant or Active1 smelters and refiners for 3TG in our supply chain, broken out by metal. There is still a need for more smelters and refiners to participate in the program.
Removal from Responsible Sourcing Program Lists: Several smelters or refiners in our supply chain failed a CFSP re-audit or were removed from the lists of other responsible sourcing audit programs. When these situations occur, we consider the underlying reasons, if made available, to inform our risk assessment as described in “Addressing Identified Risks: Our Approach.”
Other Risks: In 2015, we identified concerns about some smelters and refiners that were unrelated to conflict in the DRC. These concerns included potential labor issues in mineral sourcing and links to other conflicts, and are factors in our overall risk assessment.









______________
1 Active smelters and refiners are defined by CFSP as those that have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewellry Program Chain of Custody Certification.





2015 data based on EMC supplier data as of April 1, 2016 and CFSI’s Smelter Database as of May 6, 2016. Numbers only include facilities reported by suppliers that were on the CFSI standard smelter list as of April 1, 2016.
ADDRESSING IDENTIFIED RISKS: OUR APPROACH
Engage suppliers in due diligence and DRC Conflict-Free sourcing
In 2015, EMC issued targeted communications to help our suppliers improve their reporting and due diligence. At the launch of the supplier survey, we distributed information to help suppliers return complete and accurate CMRTs. As suppliers returned CMRTs, we reviewed their responses against our internally-developed framework for reasonableness and risk. We contacted those whose answers did not seem reasonable, or indicated potential risk, in order to obtain additional information and request corrective actions. We also offered guidance to suppliers who did not understand how to determine whether 3TG originated in the Covered Countries, or whose conflict minerals policies indicated that they did not intend to source from the Covered Countries. Suppliers who did not respond to the survey or did not address high-priority issues were escalated through supply chain management staff responsible for managing the commercial relationships.
Conflict minerals requirements and incentives are embedded in EMC’s supply chain management business processes. These activities target the Tier 1 and Tier 2 suppliers with whom we have the strongest business relationship and therefore the greatest influence. For example, suppliers’ conflict minerals risk scores, based on their response to the survey, are incorporated into EMC’s supplier scorecard. This scorecard also includes other metrics such as quality, cost and availability, and provides a key input into business decisions. Suppliers’ risk scores and corrective actions are also made available for suppliers’ Quarterly and Executive Business Reviews.
In 2016, we will continue to raise our expectations of suppliers to source from CFSP-compliant smelters and refiners and take steps to address risks in the 3TG supply chain. While suppliers’ due diligence practices and reporting have, in general, improved since 2013, education is still needed. Therefore, we intend to increase our




training and resources for suppliers to help them meet our expectations and mitigate risks, including the concerns described in this report. We will also contribute to training being developed by CFSI which will be more widely available.
Increase sourcing from Conflict-Free smelters and refiners
In 2015, EMC continued its participation in the CFSI workgroup that encourages verified 3TG smelters and refiners to engage in the CFSP. We also contributed to CFSP’s Initial Audit Fund, which pays the costs of a smelter’s or refiner’s first CFSP audit as an incentive to participate. As the number of CFSP-compliant smelters and refiners grows, we can more effectively influence our suppliers to shift purchasing to CFSP-compliant smelters and refiners. There has been measurable improvement from 2013 in the percentage of CFSP-compliant smelters and refiners in our supply chain, as shown in Figure 1 above.
We also participated in the development of CFSP’s low risk audit pilot program, which reduces the audit burden for 3TG recyclers and smelters or refiners who source domestically in low-risk countries. We believe this will help to engage and retain more smelters and refiners in CFSP (especially small businesses for whom the cost and effort of an audit is a barrier), as well as allow CFSP and its member companies to redirect resources where there is higher risk.
In 2016, we will continue our efforts to encourage smelters to join CFSP. At the same time, we will increase our focus on removing smelters and refiners of concern from our supply chain. We will also continue to refine our risk assessment of smelters and refiners. This assessment includes whether they have engaged with CFSP, geographical location, metal, industry group membership, sourcing information, and other potential risks (see “Assessing smelters and refiners” above). Smelters and refiners identified as presenting higher risk and having low probability of remediation will be prioritized for removal from our supply chain. We also intend to focus more effort in 2016 on gold through CFSI working groups, whose efforts will include reaching out to other industries with influence in the gold trade.
Encourage responsible sourcing
EMC desires to be DRC Conflict-Free, but not at the expense of supporting responsible mining operations in the Covered Countries. As described above, we educate suppliers who mistakenly believe that CFSP-compliant smelters are, by definition, not sourcing from the Covered Countries, or whose conflict minerals policies indicate that they intend not to source from the Covered Countries at all.
Also, in recognition that the issue of responsible mineral sourcing extends beyond “DRC Conflict-Free,” we will review our due diligence program in 2016 to assess how best to address other risks in our mineral supply chain. To this end, we also support CFSI’s expansion of the CFSP audit protocols to address risks in addition to conflict in the DRC, in alignment with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 




DUE DILIGENCE DESIGN
EMC’s due diligence framework conforms in all material respects with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and supplements (Second Edition, 2014).
Due Diligence Performed
Step 1: Establish strong company management systems
•
Published our company’s conflict minerals policy on EMC.com
•
Convened a Conflict Minerals Governance Committee to oversee program
•
Communicated EMC’s conflict minerals due diligence expectations to suppliers
•
Collected and stored supplier data on a third party tool
•
Utilized the EMC hotline, email address, and secure web report, which are publicly available on EMC.com, as the mechanism through which any interested party can voice concerns
Step 2: Identify and assess risks in the supply chain
•
Identified suppliers in scope and surveyed those suppliers with the CMRT
•
Reviewed suppliers’ completed CMRTs to determine if they met internally-developed standards of reasonableness and risk
•
Compared smelters and refiners identified by suppliers against CFSI’s smelter reference list to determine CFSP status
Step 3: Design and implement a strategy to respond to identified risks
•
Educated suppliers on conflict-free sourcing and how to improve reporting
•
Included suppliers’ conflict mineral risk scores as an indicator in the supplier scorecard
•
Participated in the CFSI’s Smelter Engagement Team to communicate with verified smelters and refiners and ask them to become CFSP-compliant
•
Contributed to CFSI’s Initial Audit Fund, which pays the cost of a smelter or refiner’s first CFSP audit
Step 4: Plan an independent third-party audit of the smelter or refiner’s due diligence
•
Relied on the independent third-party audits managed by the CFSP
Step 5: Report annually on supply chain due diligence
•
Submitted Form SD for the calendar year ended December 31, 2015 to the U.S. Securities and Exchange Commission and published this report on EMC.com
TO VOICE CONCERNS ABOUT EMC’S CONFLICT MINERALS PROGRAM
EMC actively encourages its employees and other parties to report concerns either directly to the company or through EMC’s hotline, which is maintained by a third-party provider. The different ways through which reports can be made are included in EMC’s Business Conduct Guidelines, corporate compliance training materials, and elsewhere. Specifically, questions and guidance regarding a potential violation of law, regulation, the Business Conduct Guidelines, or other EMC policies can be reported in any of the following ways:
•
Contact the Office of the General Counsel by telephone (508-435-1000, extension 77267), facsimile (508-497-8079), or email ([email protected]).
•
Contact the Audit Committee of the EMC Board of Directors by email ([email protected]) or by mail (Alertline, PMB 3767, Suite 300, 13950 Ballantyne Corporate Place, Charlotte, NC 28277).




•
If you are located within the United States, contact the EMC hotline, which is monitored by an independent third-party provider, by telephone (877-764-0557), or via a secure web report to
https://emccorporation.alertline.com.

This report contains forward looking statements, within the meaning of the Federal securities laws, about our business and prospects. The forward-looking statements do not include the potential impact of any mergers, acquisitions, divestitures, securities offerings or business combinations that may be announced or closed after the date hereof. Any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “believes,” “plans,” “intends,” “expects,” “goals” and similar expressions are intended to identify forward-looking statements, although not all forward-looking statements contain these words. Our future results may differ materially from our past results and from those projected in the forward looking statements due to various uncertainties and risks, including, but not limited to, those described in this report. The forward-looking statements speak only as of the date of this report and undue reliance should not be placed on these statements. We disclaim any obligation to update any forward-looking statements contained herein after the date of this report. Websites referred to in this report are not incorporated by reference unless specifically indicated.




APPENDIX A
3TG Smelters and Refiners in EMC’s Supply Chain
This list is based on EMC supplier data as of April 1, 2016. In many cases, suppliers provided information encompassing their entire supply chain; this information was not limited to facilities that contributed 3TG used only in EMC products. As a result, we are unable to validate whether our products in fact contain 3TG from all of these sources. This list only includes facilities reported by suppliers that are on the CFSI standard smelter list as of April 1, 2016.
SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
GOLD
 
 
 
Advanced Chemical Company
CID000015
UNITED STATES
Active
Aida Chemical Industries Co., Ltd.
CID000019
JAPAN
Compliant
Al Etihad Gold Refinery DMCC
CID002560
UNITED ARAB EMIRATES
 
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
GERMANY
Compliant
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
UZBEKISTAN
Active
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
BRAZIL
Compliant
Argor-Heraeus S.A.
CID000077
SWITZERLAND
Compliant
Asahi Pretec Corp.
CID000082
JAPAN
Compliant
Asahi Refining Canada Ltd.
CID000924
CANADA
Compliant
Asahi Refining USA Inc.
CID000920
UNITED STATES
Compliant
Asaka Riken Co., Ltd.
CID000090
JAPAN
Compliant
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
TURKEY
 
AURA-II
CID002851
UNITED STATES
 
Aurubis AG
CID000113
GERMANY
Compliant
Bangalore Refinery
CID002863
INDIA
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
PHILIPPINES
Compliant
Boliden AB
CID000157
SWEDEN
Compliant
C. Hafner GmbH + Co. KG
CID000176
GERMANY
Compliant
Caridad
CID000180
MEXICO
 
CCR Refinery - Glencore Canada Corporation
CID000185
CANADA
Compliant
Cendres + Métaux S.A.
CID000189
SWITZERLAND
Active
Chimet S.p.A.
CID000233
ITALY
Compliant
Chugai Mining
CID000264
JAPAN
 
Daejin Indus Co., Ltd.
CID000328
KOREA, REPUBLIC OF
Active
Daye Non-Ferrous Metals Mining Ltd.
CID000343
CHINA
 
DODUCO GmbH
CID000362
GERMANY
Compliant
Dowa
CID000401
JAPAN
Compliant
DSC (Do Sung Corporation)
CID000359
KOREA, REPUBLIC OF
Active
Eco-System Recycling Co., Ltd.
CID000425
JAPAN
Compliant
Elemetal Refining, LLC
CID001322
UNITED STATES
Compliant
Emirates Gold DMCC
CID002561
UNITED ARAB EMIRATES
Compliant
Faggi Enrico S.p.A.
CID002355
ITALY
Active
Fidelity Printers and Refiners Ltd.
CID002515
ZIMBABWE
 
Gansu Seemine Material Hi-Tech Co., Ltd.
CID000522
CHINA
 
Geib Refining Corporation
CID002459
UNITED STATES
Active
Great Wall Precious Metals Co., Ltd. of CBPM*
CID001909
CHINA
 




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
Guangdong Jinding Gold Limited
CID002312
CHINA
 
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
CHINA
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
CHINA
 
Heimerle + Meule GmbH
CID000694
GERMANY
Compliant
Heraeus Ltd. Hong Kong
CID000707
CHINA
Compliant
Heraeus Precious Metals GmbH & Co. KG
CID000711
GERMANY
Compliant
Hunan Chenzhou Mining Co., Ltd.
CID000767
CHINA
 
Hwasung CJ Co., Ltd.
CID000778
KOREA, REPUBLIC OF
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
CHINA
Compliant
Ishifuku Metal Industry Co., Ltd.
CID000807
JAPAN
Compliant
Istanbul Gold Refinery
CID000814
TURKEY
Compliant
Japan Mint
CID000823
JAPAN
Compliant
Jiangxi Copper Co., Ltd.
CID000855
CHINA
Compliant
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
RUSSIAN FEDERATION
Compliant
JSC Uralelectromed
CID000929
RUSSIAN FEDERATION
Compliant
JX Nippon Mining & Metals Co., Ltd.
CID000937
JAPAN
Compliant
Kaloti Precious Metals
CID002563
UNITED ARAB EMIRATES
 
Kazakhmys Smelting LLC
CID000956
KAZAKHSTAN
 
Kazzinc
CID000957
KAZAKHSTAN
Compliant
Kennecott Utah Copper LLC
CID000969
UNITED STATES
Compliant
KGHM Polska Miedz Spółka Akcyjna
CID002511
POLAND
Active
Kojima Chemicals Co., Ltd.
CID000981
JAPAN
Compliant
Korea Metal Co., Ltd.
CID000988
KOREA, REPUBLIC OF
 
Korea Zinc Co., Ltd.
CID002605
KOREA, REPUBLIC OF
Active
Kyrgyzaltyn JSC*
CID001029
KYRGYZSTAN
 
L'azurde Company For Jewelry
CID001032
SAUDI ARABIA
 
Lingbao Gold Co., Ltd.
CID001056
CHINA
 
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
CHINA
 
LS-NIKKO Copper Inc.
CID001078
KOREA, REPUBLIC OF
Compliant
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
CHINA
 
Materion
CID001113
UNITED STATES
Compliant
Matsuda Sangyo Co., Ltd.
CID001119
JAPAN
Compliant
Metalor Technologies (Hong Kong) Ltd.
CID001149
CHINA
Compliant
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
SINGAPORE
Compliant
Metalor Technologies (Suzhou) Ltd.
CID001147
CHINA
Active
Metalor Technologies S.A.
CID001153
SWITZERLAND
Compliant
Metalor USA Refining Corporation
CID001157
UNITED STATES
Compliant
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
MEXICO
Compliant
Mitsubishi Materials Corporation
CID001188
JAPAN
Compliant
Mitsui Mining and Smelting Co., Ltd.
CID001193
JAPAN
Compliant
MMTC-PAMP India Pvt., Ltd.
CID002509
INDIA
Compliant
Morris and Watson
CID002282
NEW ZEALAND
 
Moscow Special Alloys Processing Plant
CID001204
RUSSIAN FEDERATION
Compliant
Nadir Metal Rafineri San. Ve Tic. A.Ş.
CID001220
TURKEY
Compliant
Navoi Mining and Metallurgical Combinat
CID001236
UZBEKISTAN
Active
Nihon Material Co., Ltd.
CID001259
JAPAN
Compliant




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
AUSTRIA
Compliant
Ohura Precious Metal Industry Co., Ltd.
CID001325
JAPAN
Compliant
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
RUSSIAN FEDERATION
Compliant
OJSC Novosibirsk Refinery
CID000493
RUSSIAN FEDERATION
Compliant
PAMP S.A.
CID001352
SWITZERLAND
Compliant
Penglai Penggang Gold Industry Co., Ltd.
CID001362
CHINA
 
Prioksky Plant of Non-Ferrous Metals
CID001386
RUSSIAN FEDERATION
Compliant
PT Aneka Tambang (Persero) Tbk
CID001397
INDONESIA
Compliant
PX Précinox S.A.
CID001498
SWITZERLAND
Compliant
Rand Refinery (Pty) Ltd.
CID001512
SOUTH AFRICA
Compliant
Remondis Argentia B.V.
CID002582
NETHERLANDS
 
Republic Metals Corporation
CID002510
UNITED STATES
Compliant
Royal Canadian Mint
CID001534
CANADA
Compliant
SAAMP
CID002761
FRANCE
 
Sabin Metal Corp.
CID001546
UNITED STATES
 
Samduck Precious Metals
CID001555
KOREA, REPUBLIC OF
Active
SAMWON Metals Corp.
CID001562
KOREA, REPUBLIC OF
 
SAXONIA Edelmetalle GmbH
CID002777
GERMANY
Active
Schone Edelmetaal B.V.
CID001573
NETHERLANDS
Compliant
SEMPSA Joyería Platería S.A.
CID001585
SPAIN
Compliant
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
CHINA
 
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CHINA
Compliant
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
CHINA
Compliant
Singway Technology Co., Ltd.
CID002516
TAIWAN
Compliant
So Accurate Group, Inc.
CID001754
UNITED STATES
 
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
RUSSIAN FEDERATION
Compliant
Solar Applied Materials Technology Corp.
CID001761
TAIWAN
Compliant
Sumitomo Metal Mining Co., Ltd.
CID001798
JAPAN
Compliant
T.C.A S.p.A
CID002580
ITALY
Compliant
Tanaka Kikinzoku Kogyo K.K.
CID001875
JAPAN
Compliant
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CHINA
Compliant
Tokuriki Honten Co., Ltd.
CID001938
JAPAN
Compliant
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
CHINA
 
Torecom
CID001955
KOREA, REPUBLIC OF
Active
Umicore Brasil Ltda.
CID001977
BRAZIL
Compliant
Umicore Precious Metals Thailand
CID002314
THAILAND
Compliant
Umicore S.A. Business Unit Precious Metals Refining
CID001980
BELGIUM
Compliant
United Precious Metal Refining, Inc.
CID001993
UNITED STATES
Compliant
Valcambi S.A.
CID002003
SWITZERLAND
Compliant
Western Australian Mint trading as The Perth Mint
CID002030
AUSTRALIA
Compliant
WIELAND Edelmetalle GmbH
CID002778
GERMANY
Active
Yamamoto Precious Metal Co., Ltd.
CID002100
JAPAN
Compliant
Yokohama Metal Co., Ltd.
CID002129
JAPAN
Compliant
Yunnan Copper Industry Co., Ltd.
CID000197
CHINA
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CHINA
Compliant




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
Zijin Mining Group Co., Ltd. Gold Refinery
CID002243
CHINA
Compliant
TANTALUM
 
 
 
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CHINA
Compliant
Conghua Tantalum and Niobium Smeltry
CID000291
CHINA
Compliant
D Block Metals, LLC
CID002504
UNITED STATES
Compliant
Duoluoshan
CID000410
CHINA
Compliant
Exotech Inc.
CID000456
UNITED STATES
Compliant
F&X Electro-Materials Ltd.
CID000460
CHINA
Compliant
FIR Metals & Resource Ltd.
CID002505
CHINA
Compliant
Global Advanced Metals Aizu
CID002558
JAPAN
Compliant
Global Advanced Metals Boyertown
CID002557
UNITED STATES
Compliant
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
CHINA
Compliant
H.C. Starck Co., Ltd.
CID002544
THAILAND
Compliant
H.C. Starck GmbH Goslar
CID002545
GERMANY
Compliant
H.C. Starck GmbH Laufenburg
CID002546
GERMANY
Compliant
H.C. Starck Hermsdorf GmbH
CID002547
GERMANY
Compliant
H.C. Starck Inc.
CID002548
UNITED STATES
Compliant
H.C. Starck Ltd.
CID002549
JAPAN
Compliant
H.C. Starck Smelting GmbH & Co. KG
CID002550
GERMANY
Compliant
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
CHINA
Compliant
Hi-Temp Specialty Metals, Inc.
CID000731
UNITED STATES
Compliant
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
CHINA
Compliant
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
CHINA
Compliant
Jiujiang Tanbre Co., Ltd.
CID000917
CHINA
Compliant
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
CHINA
Compliant
KEMET Blue Metals
CID002539
MEXICO
Compliant
KEMET Blue Powder
CID002568
UNITED STATES
Compliant
King-Tan Tantalum Industry Ltd.
CID000973
CHINA
Compliant
LSM Brasil S.A.
CID001076
BRAZIL
Compliant
Metallurgical Products India Pvt., Ltd.
CID001163
INDIA
Compliant
Mineração Taboca S.A.
CID001175
BRAZIL
Compliant
Mitsui Mining & Smelting
CID001192
JAPAN
Compliant
Molycorp Silmet A.S.
CID001200
ESTONIA
Compliant
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CHINA
Compliant
Plansee SE Liezen
CID002540
AUSTRIA
Compliant
Plansee SE Reutte
CID002556
AUSTRIA
Compliant
QuantumClean
CID001508
UNITED STATES
Compliant
Resind Indústria e Comércio Ltda.
CID002707
BRAZIL
Compliant
RFH Tantalum Smeltry Co., Ltd.
CID001522
CHINA
Compliant
Solikamsk Magnesium Works OAO
CID001769
RUSSIAN FEDERATION
Compliant
Taki Chemicals
CID001869
JAPAN
Compliant
Telex Metals
CID001891
UNITED STATES
Compliant
Tranzact, Inc.
CID002571
UNITED STATES
Compliant
Ulba Metallurgical Plant JSC
CID001969
KAZAKHSTAN
Compliant
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
CHINA
Compliant
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
CHINA
Compliant
Zhuzhou Cemented Carbide
CID002232
CHINA
Compliant




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
TIN
 
 
 
Alpha
CID000292
UNITED STATES
Compliant
An Thai Minerals Co., Ltd.
CID002825
VIETNAM
Active
An Vinh Joint Stock Mineral Processing Company
CID002703
VIETNAM
Active
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
CHINA
Active
China Tin Group Co., Ltd.
CID001070
CHINA
Compliant
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
CHINA
 
Cooperativa Metalurgica de Rondônia Ltda.
CID000295
BRAZIL
Compliant
CV Ayi Jaya
CID002570
INDONESIA
Compliant
CV Dua Sekawan
CID002592
INDONESIA
Active
CV Gita Pesona
CID000306
INDONESIA
Compliant
CV Serumpun Sebalai
CID000313
INDONESIA
Compliant
CV United Smelting
CID000315
INDONESIA
Compliant
CV Venus Inti Perkasa
CID002455
INDONESIA
Compliant
Dowa
CID000402
JAPAN
Compliant
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
VIETNAM
Active
Elmet S.L.U.
CID002774
SPAIN
Compliant
EM Vinto
CID000438
BOLIVIA
Compliant
Estanho de Rondônia S.A.
CID000448
BRAZIL
 
Fenix Metals
CID000468
POLAND
Compliant
Gejiu Jinye Mineral Company
CID002859
CHINA
Active
Gejiu Kai Meng Industry and Trade LLC
CID000942
CHINA
Active
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CHINA
Compliant
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
CHINA
Active
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
CHINA
 
HuiChang Hill Tin Industry Co., Ltd.
CID002844
CHINA
Active
Huichang Jinshunda Tin Co., Ltd.
CID000760
CHINA
 
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
CHINA
Compliant
Linwu Xianggui Ore Smelting Co., Ltd.
CID001063
CHINA
 
Magnu's Minerais Metais e Ligas Ltda.
CID002468
BRAZIL
Compliant
Malaysia Smelting Corporation (MSC)
CID001105
MALAYSIA
Compliant
Melt Metais e Ligas S.A.
CID002500
BRAZIL
Compliant
Metallic Resources, Inc.
CID001142
UNITED STATES
Compliant
Metallo-Chimique N.V.
CID002773
BELGIUM
Compliant
Mineração Taboca S.A.
CID001173
BRAZIL
Compliant
Minsur
CID001182
PERU
Compliant
Mitsubishi Materials Corporation
CID001191
JAPAN
Compliant
Nankang Nanshan Tin Manufactory Co., Ltd.
CID001231
CHINA
 
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
VIETNAM
Active
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
THAILAND
Compliant
O.M. Manufacturing Philippines, Inc.
CID002517
PHILIPPINES
Compliant
Operaciones Metalurgical S.A.
CID001337
BOLIVIA
Compliant
Phoenix Metal Ltd.
CID002507
RWANDA
Active
PT Alam Lestari Kencana
CID001393
INDONESIA
 
PT Aries Kencana Sejahtera
CID000309
INDONESIA
Compliant
PT Artha Cipta Langgeng
CID001399
INDONESIA
Compliant




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
PT ATD Makmur Mandiri Jaya
CID002503
INDONESIA
Compliant
PT Babel Inti Perkasa
CID001402
INDONESIA
Compliant
PT Bangka Kudai Tin
CID001409
INDONESIA
 
PT Bangka Prima Tin
CID002776
INDONESIA
Compliant
PT Bangka Timah Utama Sejahtera
CID001416
INDONESIA
 
PT Bangka Tin Industry
CID001419
INDONESIA
Compliant
PT Belitung Industri Sejahtera
CID001421
INDONESIA
Compliant
PT BilliTin Makmur Lestari
CID001424
INDONESIA
Compliant
PT Bukit Timah
CID001428
INDONESIA
Compliant
PT Cipta Persada Mulia
CID002696
INDONESIA
Compliant
PT DS Jaya Abadi
CID001434
INDONESIA
Compliant
PT Eunindo Usaha Mandiri
CID001438
INDONESIA
Compliant
PT Fang Di MulTindo
CID001442
INDONESIA
 
PT Inti Stania Prima
CID002530
INDONESIA
Compliant
PT Justindo
CID000307
INDONESIA
Compliant
PT Karimun Mining
CID001448
INDONESIA
Active
PT Mitra Stania Prima
CID001453
INDONESIA
Compliant
PT Panca Mega Persada
CID001457
INDONESIA
Compliant
PT Pelat Timah Nusantara Tbk
CID001486
INDONESIA
 
PT Prima Timah Utama
CID001458
INDONESIA
Compliant
PT Refined Bangka Tin
CID001460
INDONESIA
Compliant
PT Sariwiguna Binasentosa
CID001463
INDONESIA
Compliant
PT Seirama Tin Investment
CID001466
INDONESIA
 
PT Stanindo Inti Perkasa
CID001468
INDONESIA
Compliant
PT Sukses Inti Makmur
CID002816
INDONESIA
Compliant
PT Sumber Jaya Indah
CID001471
INDONESIA
Compliant
PT Timah (Persero) Tbk Kundur
CID001477
INDONESIA
Compliant
PT Timah (Persero) Tbk Mentok
CID001482
INDONESIA
Compliant
PT Tinindo Inter Nusa
CID001490
INDONESIA
Compliant
PT Tirus Putra Mandiri
CID002478
INDONESIA
 
PT Tommy Utama
CID001493
INDONESIA
Compliant
PT Wahana Perkit Jaya
CID002479
INDONESIA
Compliant
Resind Indústria e Comércio Ltda.
CID002706
BRAZIL
Compliant
Rui Da Hung
CID001539
TAIWAN
Compliant
Soft Metais Ltda.
CID001758
BRAZIL
Compliant
Thaisarco
CID001898
THAILAND
Compliant
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
VIETNAM
Active
VQB Mineral and Trading Group JSC
CID002015
VIETNAM
Compliant
White Solder Metalurgia e Mineração Ltda.
CID002036
BRAZIL
Compliant
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
CHINA
Active
Yunnan Tin Company Limited
CID002180
CHINA
Compliant
TUNGSTEN
 
 
 
A.L.M.T. TUNGSTEN Corp.
CID000004
JAPAN
Compliant
ACL Metais Eireli
CID002833
BRAZIL
Active
Asia Tungsten Products Vietnam Ltd.
CID002502
VIETNAM
Compliant
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
CHINA
Compliant
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
CHINA
Compliant




SMELTER OR REFINER NAME
SMELTER IDENTIFICATION NUMBER
SMELTER OR
REFINER LOCATION
CFSP-COMPLIANT
STATUS AS OF
5/6/16
Dayu Jincheng Tungsten Industry Co., Ltd.
CID002518
CHINA
TI-CMC Category A Member
Dayu Weiliang Tungsten Co., Ltd.
CID000345
CHINA
TI-CMC Category A Member
Fujian Jinxin Tungsten Co., Ltd.
CID000499
CHINA
Compliant
Ganxian Shirui New Material Co., Ltd.
CID002531
CHINA
 
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
CHINA
Compliant
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
CHINA
Compliant
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CID000868
CHINA
TI-CMC Category A Member
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CHINA
Compliant
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
CHINA
Compliant
Global Tungsten & Powders Corp.
CID000568
UNITED STATES
Compliant
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CHINA
Compliant
H.C. Starck GmbH
CID002541
GERMANY
Compliant
H.C. Starck Smelting GmbH & Co.KG
CID002542
GERMANY
Compliant
Hunan Chenzhou Mining Co., Ltd.
CID000766
CHINA
Compliant
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
CHINA
Compliant
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
CHINA
Compliant
Hydrometallurg, JSC
CID002649
RUSSIAN FEDERATION
Compliant
Japan New Metals Co., Ltd.
CID000825
JAPAN
Compliant
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
CHINA
Active
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
CHINA
Compliant
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
CHINA
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
CHINA
Active
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
CHINA
Active
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
CHINA
Compliant
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
CHINA
Active
Kennametal Fallon
CID000966
UNITED STATES
Active
Kennametal Huntsville
CID000105
UNITED STATES
Compliant
Malipo Haiyu Tungsten Co., Ltd.
CID002319
CHINA
Compliant
Moliren Ltd
CID002845
RUSSIAN FEDERATION
Active
Niagara Refining LLC
CID002589
UNITED STATES
Compliant
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
VIETNAM
Compliant
Pobedit, JSC
CID002532
RUSSIAN FEDERATION
TI-CMC Category A Member
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
VIETNAM
Compliant
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
VIETNAM
Compliant
Wolfram Bergbau und Hütten AG
CID002044
AUSTRIA
Compliant
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CHINA
Compliant
Xiamen Tungsten Co., Ltd.
CID002082
CHINA
Compliant
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
CHINA
Compliant
*On the LBMA Good Delivery list for gold, but not on the CFSP compliant list as of 5/6/16. Refiners on this list are eligible for cross-recognition by CFSP.




APPENDIX B
Countries from which the minerals in EMC’s products may have originated
Based on CFSI’s Reasonable Country of Origin Inquiry report dated May 3, 2016, the countries of origin of the 3TG processed by facilities listed in Appendix A are believed to include the following:
Angola
Myanmar
Argentina
Namibia
Australia
Netherlands
Austria
Nigeria
Belgium
Peru
Bolivia
Portugal
Brazil
Republic of Congo
Burundi
Russia
Cambodia
Rwanda
Canada
Sierra Leone
Central African Republic
Singapore
Chile
Slovakia
China
South Africa
Colombia
South Korea
Cote D’Ivoire
South Sudan
Czech Republic
Spain
Democratic Republic of the Congo
Suriname
Djibouti
Switzerland
Ecuador
Taiwan
Egypt
Tanzania
Estonia
Thailand
Ethiopia
Uganda
France
United Kingdom
Germany
United States of America
Guyana
Vietnam
Hungary
Zambia
India
Zimbabwe
Indonesia
 
Ireland
 
Israel
 
Japan
 
Kazakhstan
 
Kenya
 
Laos
 
Luxembourg
 
Madagascar
 
Malaysia
 
Mongolia
 
Mozambique
 




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