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Form SD WALT DISNEY CO/

May 27, 2016 5:02 PM EDT


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

FORM SD

SPECIALIZED DISCLOSURE REPORT







(Exact name of the registrant as specified in its charter)

Incorporated in Delaware
1-11605
No. 95-4545390
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(I.R.S. Employer Identification No.)

500 South Buena Vista Street, Burbank, California 91521
(Address of principal executive offices) (Zip code)

Christine M. McCarthy
(818) 560-1000
(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.







Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

With respect to products manufactured by or contracted to be manufactured by the Registrant and for which the Registrant believes conflict minerals (as defined in Item 1.01(d) (3) of Form SD) are necessary to the functionality or production of the product, the Registrant has conducted a reasonable country of origin inquiry to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country, or are from recycled or scrap sources. Based on that inquiry, the Registrant is unable to determine that (i) all necessary conflict minerals did not originate in the Democratic Republic of the Congo or an adjoining country, (ii) there is no reason to believe that any necessary conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country, or (iii) all necessary conflict minerals came from recycled or scrap sources. Accordingly, the Registrant has completed a Conflict Minerals Report, which is filed herewith as Exhibit 1.01, and is available at https://ditm-twdc-us.storage.googleapis.com/Conflict-Minerals-Report.pdf.

Item 1.02 Exhibit

The Conflict Minerals Report for the calendar year ended December 31, 2015 is filed as Exhibit 1.01 hereto.


Section 2 - Exhibits

Item 2.01 Exhibits

Exhibit 1.01     Conflict Minerals Report for Calendar Year 2015






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.


 
 
 
 
 
THE WALT DISNEY COMPANY
 
 
(Registrant)
 
 
By:
 
/s/ CHRISTINE M. MCCARTHY
 
 
Christine M. McCarthy
Senior Executive Vice President and Chief Financial Officer


May 27, 2016




Exhibit 1.01
Conflict Minerals Report
For Calendar Year 2015

This is The Walt Disney Company’s 2015 Conflict Minerals Report pursuant to Rule 13p-1 of the Securities and Exchange Commission (the “Conflict Minerals Rule”).
Background
The Walt Disney Company, together with its subsidiaries, is a diversified worldwide entertainment company with operations in four business segments: Media Networks, Parks and Resorts, Studio Entertainment and Consumer Products and Interactive Media. For convenience, the terms “Company,” “Disney” and “we” are used in this report to refer collectively to the parent company and its subsidiaries through which our various businesses are actually conducted.
The Company derives the vast majority of its revenues from the licensing of intellectual property, the sale of advertising time, and charges for entertainment, lodging and associated food and beverage sales at its theme parks, resorts, and cruise lines. We also derive revenue from the sales of physical products (such as physical copies of films and music) that we have determined do not include columbite-tantalite, cassiterite, gold, wolframite or their derivatives (collectively, the “Subject Minerals”) as necessary to the products’ functionality or production (“necessary Subject Minerals”).
The products we sell that may include necessary Subject Minerals are items such as books, clothing, accessories, electronic toys, jewelry and other consumer goods. We classify these items together as retail merchandise, and that is the product category covered by this report. We sell many of these items directly through Disney Stores throughout the world and at our entertainment venues, including our parks and resorts. We also sell retail merchandise wholesale to other retailers.
The sale of retail merchandise constituted less than 10% of our revenue in calendar 2015. The number of individual items sold is, however, large. We estimate that we sold retail merchandise with approximately 150,000 stock-keeping units (SKUs) in calendar 2015. Moreover, due to the dynamic nature of our business, the items we sell change rapidly, with many items sold for only a few months, and then replaced by other items sourced from other suppliers.
The Company does not manufacture any of the retail merchandise it sells, sourcing the specific merchandise items that may contain Subject Minerals from over 1,300 suppliers in calendar 2015. We believe that many of our suppliers themselves source components of these items from numerous other suppliers, and our direct suppliers are often many steps removed from the source of the raw materials contained in the items. In addition, we believe that in many cases the items we acquire from a supplier represent a small portion of the supplier’s total production.
The number, diversity and frequent turnover of the retail merchandise we sell, the number and turnover of suppliers, and our remote position in the supply chain make it difficult for us to determine and track the source of individual items, the nature of the raw materials included in the items, and the source of those raw materials. Nevertheless, our Conflict Minerals Compliance Program described below is designed to gain relevant information about the sources of raw materials in our products that is as complete as reasonably possible in light of our position in the supply chain.


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Disney’s Conflict Minerals Compliance Program
Our Conflict Minerals Compliance Program (the “Program”) is focused on identifying suppliers of retail merchandise that may contain necessary Subject Minerals and gathering information about the supply chain practices of those suppliers.

The Program includes: (1) an internal management structure; (2) a Conflict Minerals Policy; (3) reasonable inquiry into the country of origin of any necessary Subject Minerals; and (4) appropriate diligence into whether any necessary Subject Minerals that may have originated in the Democratic Republic of the Congo or adjoining countries (“Covered Countries”) support armed conflict. The due diligence aspects of the Program have been designed in conformance with the guidance set forth in the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition (OECD Guidance).
1.
Internal Management Structure. The Conflict Minerals Steering Committee is comprised of executive-level representatives from Integrated Trade Management, Legal, Investor Relations, Controllership, Corporate Communications, International Labor Standards, Global Public Policy, and Corporate Citizenship. The Committee is responsible for providing governance and oversight over the execution of the Program and for monitoring the Program’s compliance with regulatory requirements and satisfaction of enterprise goals. The day-to-day implementation of the Program is conducted by a Conflict Minerals Compliance Program Team within our Integrated Trade Management organization, which reports to an executive officer of the Company. The Conflict Minerals Compliance Program Team engages regularly with a third party professional services firm to manage, assist, and monitor the progress of the Program.

2.
Conflict Minerals Policy. The Company’s Conflict Minerals Policy sets forth the steps we are taking to comply with the Conflict Minerals Rule. These steps include: the establishment of the internal management structure described above; engagement with suppliers as described in this report; reporting required by the Conflict Minerals Rule; and monitoring developments relating to conflict minerals with an eye to enhancing the Program. Our policy was distributed to suppliers who may supply us with products covered by the rule and is posted on our web site at https://ditm-twdc-us.storage.googleapis.com/Conflict-Minerals-Policy.pdf. The policy includes a mechanism for reporting concerns or asking questions regarding the policy.

3.
Reasonable Country of Origin Inquiry. Based on lists of historic suppliers of retail merchandise updated through interviews with sourcing executives, we compile a list each year of the suppliers we are able to identify as supplying retail merchandise in the prior calendar year that may contain necessary Subject Minerals.

Each year, we distribute a survey to these suppliers regarding their supply chain practices relating to Subject Minerals. The 2015 survey was based on the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (CMRT), revision 4.01b. We supplemented this template with additional questions designed to provide visibility into our suppliers’ sourcing activities, including the basis for their responses regarding the source of Subject Minerals in the retail merchandise they supplied to us. We also provided suppliers with our Conflict Minerals Policy, a survey translation guide, and training material on conflict minerals, which included links to other sources of information (including Conflict-Free Sourcing Initiative’s website: http://www.conflictfreesourcing.org/). Our communications included our expectations for response and noted that the Conflict Minerals Rule was not intended to stop companies and their suppliers from sourcing from the Covered Countries and that such an embargo would be contrary to the intent of the Conflict Minerals Rule.


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In 2015, we identified and surveyed 1,320 suppliers to us of retail merchandise that we sell to our customers. We received responses from 716, or 54.2% compared to a response rate of 39.7% for calendar 2014. We received responses from 79.0% of our 100 largest suppliers of merchandise for resale, and 95.1% of the suppliers we initially identified as most likely to be supplying us with products that contained Subject Minerals.

The vast majority of the suppliers who completed the survey responded that the merchandise they supplied to us did not contain any necessary Subject Minerals. Based on survey responses, interviews, and our further review of the retail merchandise supplied, we identified 76 suppliers who manufactured retail merchandise for us that contained necessary Subject Minerals. Of these suppliers:

One supplier responded that the Subject Minerals in all the products it supplied to us for resale by us did not originate in Covered Countries and provided sufficient information regarding its supply chain program for us to determine that this response was reliable.
Two suppliers responded that the Subject Minerals in retail merchandise manufactured for us originated in the Covered Countries. As noted below, we determined that both of these suppliers only sourced Subject Minerals in the Covered Countries from smelters and refiners that are compliant with the CFSI’s Conflict Free Smelters Program (CFSP).
12 suppliers responded that the Subject Minerals in the products they supplied us did not originate in Covered Countries, but did not provide sufficient information regarding their supply chain programs for us to determine that this conclusion was reliable.
61 suppliers responded that they could not determine the country of origin of all of the Subject Minerals in retail merchandise they manufactured for us. Some of these suppliers provided smelter information with respect to some of the Subject Minerals they sourced, and three of these suppliers responded that they sourced Subject Minerals from smelters and refiners that we determined were in the Covered Countries. As noted below, we determined that the smelters and refiners in the Covered Countries identified by these three suppliers are compliant with the CFSI’s CFSP.

4.
Due Diligence Measures. Based on our assessment of survey responses in 2015, we implemented due diligence measures with respect to suppliers who (1) may have manufactured retail merchandise for us containing Subject Minerals and (2) had not reliably demonstrated that the Subject Minerals were not sourced from Covered Countries. These measures included:

Performance of targeted follow-up with suppliers who did not initially respond to the survey.
Verification of information regarding smelters and refiners provided by our suppliers with the CFSI’s list of conflict-free smelters and refiners and other lists provided by accredited organizations such as London Bullion Market Association (LBMA) or Responsible Jewelry Council (RJC). Through this effort, we determined that the smelters and refiners in the Covered Countries that were identified by five of our suppliers were all compliant with the CFSI’s CFSP
Requests for additional information (e.g., certificate of material analysis, bill of materials, statement letters) from suppliers whom we determined supplied items containing Subject Minerals and who provided information that was insufficient for us to determine reliably the source of Subject Minerals in retail merchandise manufactured for us. Through this effort, we were able to obtain more reliable information about the presence of Subject Minerals in items supplied to us and obtain additional smelter and refiner information.
Encouragement of suppliers who provided insufficient information regarding their supply chain to develop more robust supply chain information programs and policies.
Encouragement of suppliers who may have sourced Subject Minerals (or product components from sub-suppliers who may have sourced Subject Minerals) from non-

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compliant smelters or refiners to source from smelters and refiners who are compliant with the relevant CFSP assessment protocols of the CFSI, or from another accredited organization.
Support for and engagement with CFSI. The data on which we relied for certain statements in this report was obtained through our membership in CFSI, using the Reasonable Country of Origin Inquiry report for member DISN.

Smelters, Refiners, and Countries of Origin
The suppliers who manufactured retail merchandise for us that we determined contained necessary Subject Minerals identified 160 smelters or refiners (verified as such by the CFSP and/or LBMA and RJC) that supplied them with Subject Minerals. These suppliers included the single supplier we determined was not sourcing from Covered Countries and the five suppliers that source from CFSI compliant smelters and refiners in the Covered Countries. Although we cannot determine whether retail merchandise manufactured for us contained Subject Minerals from each of these 160 smelters and refiners, we have listed each of them in Attachment A. All but three of these smelters and refiners are compliant with the relevant CFSP assessment protocols of CFSI and/or other accredited organization. Figure 1 shows compliance by mineral.
Figure 1: Of the 64 gold compliant smelters, 62 are compliant with CFSI protocols and two are compliant with the RJC protocols. Of the 62 gold smelters compliant with the CFSI protocols, 49 were also found to be certified by the LBMA and 10 by the RJC. All the suppliers of the other minerals are compliant with the CFSI protocols, except one tin supplier.

Based on the information provided by our suppliers, we have not been able to determine the facilities used to process the necessary Subject Minerals, the country of origin of the necessary Subject Minerals, the mine or location of origin of the necessary Subject Minerals, or whether the Subject Minerals in our retail merchandise are from recycled or scrap sources in all of the retail merchandise we sell. We have been able to determine that, of the 160 smelters and refiners identified in Attachment A, seventeen are identified by CFSI as sourcing Subject Minerals from Covered Countries and that each of these seventeen smelters and refiners were determined by CFSI to be compliant with the relevant CFSP assessment protocols of the CFSI. We have also determined that the countries of origin of the Subject Minerals supplied by the smelters and refiners included in Attachment A may include those listed in Attachment B. However, we cannot determine whether the three smelters and refiners who are not compliant with the relevant CFSP assessment protocols of the CFSI, or another accredited organization, sourced from Covered Countries. We also cannot determine whether the suppliers who provided us with insufficient information regarding the source of Subject Minerals sourced Subject Minerals from the Covered Countries.

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Further Development of Disney’s Conflict Minerals Compliance Program
Our efforts with respect to 2015 were devoted to increasing the response rate to our supplier survey and to obtaining additional information from those suppliers who provided insufficient information regarding their supply chain programs to evaluate adequately the source of materials they supplied. We also encouraged suppliers to improve their supply chain policies, source responsibly, and to source Subject Minerals from (or from sub-suppliers who source from) smelters and refiners who are compliant with the relevant CFSP assessment protocols of CFSI or any other accredited organization. We also built on the information we obtained in our 2014 survey to continue refining our list of suppliers and identifying those who were likely to have supplied us retail merchandise containing Subject Minerals.
We continue to focus on refining our systems for identifying relevant suppliers and the product categories associated with each supplier, and on obtaining additional and more reliable information on each supplier’s own supply chain. We also continue to evaluate the overall quality of supply chain practices of our suppliers, the impact of encouraging adoption of robust supply chain practices in light of developing supply chain certification programs, the practices of our suppliers, and whether it is helpful and feasible to provide further incentives to suppliers to strengthen their supply chain programs.



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Attachment A
Smelters and Refiners Identified by
Suppliers

The following table identifies each of the smelters and refiners identified by our suppliers as sources of Subject Minerals in retail merchandise manufactured by the supplier. The table includes the name of the smelter or refiner, the Subject Minerals supplied by the smelter or refiner, and the location of the smelter or refiner. Our suppliers could not confirm whether each smelter or refiner they used supplied Subject Minerals in retail merchandise manufactured for the Company. All but three of the smelters and refiners identified below are currently compliant with CFSP assessment protocols of the CFSI or other accredited organizations; the three smelters and refiners that have not been certified as compliant are marked with an asterisk (*) in the table below.1 
Subject Mineral
Smelter or Refiner Name
Location
Gold
Advanced Chemical Company*
USA
Gold
Aida Chemical Industries Co. Ltd.
Japan
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
Germany
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Gold
Argor-Heraeus SA
Switzerland
Gold
Asahi Pretec Corporation
Japan
Gold
Asahi Refining Canada Limited
Canada
Gold
Asahi Refining USA Inc.
USA
Gold
Asaka Riken Co Ltd
Japan
Gold
Atasay Kuryumculuk Sanayi Ve Ticaret A.S.
Turkey
Gold
Aurubis AG
Germany
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Boliden AB
Sweden
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Chimet S.p.A.
Italy
Gold
Dowa
Japan
Gold
Eco-System Recycling Co., Ltd.
Japan
Gold
Elemtal Refining, LLC
USA
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Ltd. Hong Kong
China
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Istanbul Gold Refinery
Turkey
Gold
Johnson Matthey Inc
Switzerland
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Kennecott Utah Copper LLC
USA

 
1 Our suppliers identified two additional sources of Subject Minerals (for gold: Gold Mining in Shandong (Laizhou) Ltd. Co.; for tin: China Minmetals), which have not been verified as smelters or refiners by CFSI.

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Subject Mineral
Smelter or Refiner Name
Location
Gold
Kojima Chemicals Co., Ltd
Japan
Gold
LS-NIKKO Copper Inc.
Korea
Gold
Materion
USA
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Metalor Technologies (Hong Kong) Ltd
China
Gold
Metalor Technologies (Singapore) Ltd.
Singapore
Gold
Metalor technologies SA
Switzerland
Gold
Metalor USA Refining Corporation
USA
Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
Mexico
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
Turkey
Gold
Nihon Material Co. LTD
Japan
Gold
Ohura Precious Metal Industry Co., Ltd
Japan
Gold
PAMP SA
Switzerland
Gold
PX Précinox SA
Switzerland
Gold
Rand Refinery (Pty) Ltd
South Africa
Gold
Republic Metals Corporation
USA
Gold
Royal Canadian Mint
Canada
Gold
SEMPSA Joyería Platería SA
Spain
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
China
Gold
So Accurate Group Inc.*
USA
Gold
Solar Applied Materials Technology Corp.
Taiwan
Gold
SPC Precious Metal Co.
Thailand
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
The Refinery of Shandong Gold Mining Co. Ltd
China
Gold
Tokuriki Honten Co., Ltd
Japan
Gold
Umicore Brasil Ltda
Brazil
Gold
Umicore Precious Metals Thailand
Thailand
Gold
Umicore SA Business Unit Precious Metals Refining
Belgium
Gold
United Precious Metal Refining, Inc.
USA
Gold
Valcambi SA
Switzerland
Gold
Western Australian Mint trading as The Perth Mint
Ausralia
Gold
YAMAMOTO PRECIOUS METAL CO., LTD.
Japan
Gold
Yokohama Metal Co Ltd
Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
Zijin Mining Group Co., LTd Gold Refinery
China
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Tantalum
Conghua Tantalum and Niobium Smeltry
China
Tantalum
F&X Electro-Materials Ltd.
China
Tantalum
Global Advanced Metals Boyertown
USA

2


Subject Mineral
Smelter or Refiner Name
Location
Tantalum
H.C. Starck Co., Ltd.
Thailand
Tantalum
H.C. Starck GmbH Goslar
Germany
Tantalum
H.C. Starck GmbH Laufenburg
Germany
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Tantalum
H.C. Starck Inc.
USA
Tantalum
H.C. Starck Ltd.
Japan
Tantalum
H.C. Starck Smelting GmbH & Co.KG
Germany
Tantalum
Hi-Temp Specialty Metals, Inc.
USA
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
Mitsui Mining & Smelting
Japan
Tantalum
Molycorp Silmet A.S.
Estonia
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Tantalum
Plansee SE Liezen
Austria
Tantalum
Plansee SE Reutte
Austria
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
Tantalum
Taki Chemicals
Japan
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Tantalum
Zhuzhou Cement Carbide
China
Tin
Alpha
USA
Tin
China Tin Group Co., Ltd.
China
Tin
Cooperativa Metalurgica de Rondônia Ltda.
Brazil
Tin
CV Ayi Jaya
Indonesia
Tin
CV Gita Pesona
Indonesia
Tin
CV Serumpun Sebalai
Indonesia
Tin
CV United Smelting
Indonesia
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Dowa
Japan
Tin
EM Vinto
Bolivia
Tin
Fenix Metals
Poland
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.
China
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
China
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Tin
Melt Metais e Ligas S/A
Brazil
Tin
Metallic Resources, Inc.
USA
Tin
Metallo Chimique N.V.
Belgium
Tin
Mineração Taboca S.A.
Brazil
Tin
Minsur
Peru
Tin
Mitsubishi Materials Corporation
Japan
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
Philippines

3


Subject Mineral
Smelter or Refiner Name
Location
Tin
Operaciones Metalurgical S.A.
Bolivia
Tin
PT Aries Kencana Sejahtera
Indonesia
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
PT Bangka Tin Industry
Indonesia
Tin
PT Belitung Industri Sejahtera
Indonesia
Tin
PT BilliTin Makmur Lestari
Indonesia
Tin
PT Bukit Timah
Indonesia
Tin
PT DS Jaya Abadi
Indonesia
Tin
PT Eunindo Usaha Mandiri
Indonesia
Tin
PT Inti Stania Prima
Indonesia
Tin
PT Justindo
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT Panca Mega Persada
Indonesia
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Refined Bangka Tin
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Timah (Persero), Tbk Kundor
Indonesia
Tin
PT Timah (Persero), Tbk Mentok
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Wahana Perkit Jaya
Indonesia
Tin
Rui Da Hung
Taiwan
Tin
Soft Metais Ltda.
Brazil
Tin
Thaisarco
Thailand
Tin
VQB Mineral and Trading Group JSC
Vietnam
Tin
White Solder Metalurgia e Mineração Ltda.
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
China
Tin
Yunnan Tin Company, Ltd.
China
Tungsten
A.L.M.T. Tungsten Corp.
Japan
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp.
USA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Tungsten
H.C. Starck GmbH
Germany
Tungsten
H.C. Starck Smelting GmbH & Co.KG
Germany
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Tungsten
Japan New Metals Co., Ltd
Japan
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China

4


Subject Mineral
Smelter or Refiner Name
Location
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Tungsten
Kennametal Huntsville
USA
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Vietnam
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Vietnam
Tungsten
Wolfram Bergbau und Hütten AG
Austria
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Xiamen Tungsten Co., Ltd.
China



5


Attachment B
Countries of Origin

The following table identifies the countries of origin of the smelters and refiners identified in Attachment A and is based on the smelters and refiners provided by our suppliers and the CFSI’s reasonable country of origin data, which provides country of origin data for those smelters and refiners.

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
Côte D'Ivoire
South Sudan
Czech Republic
Spain
Djibouti
Suriname
Ecuador
Switzerland
Egypt
Taiwan
Estonia
Tanzania
Ethiopia
Thailand
France
The Democratic Republic of Congo (DRC)
Germany
Uganda
Guyana
United Kingdom
Hungary
United States of America
India
Vietnam
Indonesia
Zambia
Ireland
Zimbabwe
Israel
 
Japan
 
Kazakhstan
 
Kenya
 
Laos
 
Luxembourg
 
Madagascar
 
Malaysia
 
Mongolia
 
Mozambique
 



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