Form SD XEROX CORP

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

 

 

SPECIALIZED DISCLOSURE REPORT

 

 

 

XEROX CORPORATION

(Exact name of registrant as specified in its charter)

 

 

 

New York		001-04471		16-0468020
(State or other jurisdiction of incorporation)		(Commission File Number)		(IRS Employer Identification No.)

P. O. Box 4505

45 Glover Avenue

Norwalk, Connecticut

06856-4505

Registrant’s telephone number, including area code: (203) 968-3000

Not Applicable

(Former name or former address, if changed since last 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 – Conflicts Minerals Disclosure

Items 1.01 and 1.02 – Conflicts Minerals Disclosure and Report, Exhibit

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available on our website under Supplier Relations – Conflict Minerals at www.xerox.com/corporate-citizenship-2015/business/supplier-relations.html as well as the SEC’s EDGAR database at www.sec.gov. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.

Section 2 – Exhibits

Item 2.01 – Exhibits

Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015 as required by Items 1.01 and 1.02 of this Form.

Forward Looking Statements

This Specialized Disclosure Report on Form SD and any exhibits to this Report may contain “forward-looking statements” as defined in the Private Securities Litigation Reform Act of 1995. These forward-looking statements and other information are based on our beliefs as well as assumptions made by us using information currently available. The words “anticipate,” “believe,” “estimate,” “expect,” “intend,” “will,” “should,” and similar expressions, as they relate to us, are intended to identify forward-looking statements. These statements reflect our current views with respect to future events and are subject to certain risks, uncertainties and assumptions and are subject to a number of factors that may cause actual results to differ materially. These factors include, but are not limited to: changes in economic conditions, political conditions, trade protection measures, licensing requirements and tax matters in the United States and in the foreign countries in which we do business; changes in foreign currency exchange rates; our ability to successfully develop new products, technologies and service offerings and to protect our intellectual property rights; the risk that multi-year contracts with governmental entities could be terminated prior to the end of the contract term and that civil or criminal penalties and administrative sanctions could be imposed on us if we fail to comply with the terms of such contacts and applicable law; the risk that our bids do not accurately estimate the resources and costs required to implement and service very complex, multi-year governmental and commercial contracts, often in advance of the final determination of the full scope and design of such contracts or as a result of the scope of such contracts being changed during the life of such contracts; the risk that subcontractors, software vendors and utility and network providers will not perform in a timely, quality manner; service interruptions; actions of competitors and our ability to promptly and effectively react to changing technologies and customer expectations; our ability to obtain adequate pricing for our products and services and to maintain and improve cost efficiency of operations, including savings from restructuring actions and the relocation of our service delivery centers; the risk that individually identifiable information of customers, clients and employees could be inadvertently disclosed or disclosed as a result of a breach of our security systems; the risk in the hiring and retention of qualified personnel; the risk that unexpected costs will be incurred; our ability to recover capital investments; the risk that our Services business could be adversely affected if we are unsuccessful in managing the start-up of new contracts; the collectibility of our receivables for unbilled services associated with very large, multi-year contracts; reliance on third parties, including subcontractors, for manufacturing of products and provision of services; our ability to expand equipment placements; interest rates, cost of borrowing and access to credit markets; the risk that our products may not comply with applicable worldwide regulatory requirements, particularly environmental regulations and directives; the outcome of litigation and regulatory proceedings to which we may be a party; the possibility that the proposed separation of the Business Process Outsourcing (BPO) business from the Document Technology and Document Outsourcing business will not be consummated within the anticipated time period or at all, including as the result of regulatory, market or other factors; the potential for disruption to our business in connection with the proposed separation; the potential that the BPO and Document Technology and Document Outsourcing do not realize all of the expected benefits of the separation, and other factors that are set forth in the “Risk Factors” section, the “Legal Proceedings” section, the “Management’s Discussion and Analysis of Financial Condition and Results of Operations” section and other sections of our Quarterly Report on Form 10-Q for the quarter ended March 31, 2016 and our 2015 Annual Report on Form 10-K filed with the Securities and Exchange Commission as well as in our Current Reports on Form 8-K. Xerox assumes no obligation to update any forward-looking statements as a result of new information or future events or developments, except as required by law.

---

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 undersigned duly authorized.

Date: May 13, 2016

 

XEROX CORPORATION
By:		/s/ Hervé Tessler
		Hervé Tessler
		Senior Vice President

---

EXHIBIT INDEX

 

Exhibit Number		Description
1.01		Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015

Exhibit 1.01

Conflict Minerals Report

 

Xerox Corporation

For the Year Ended December 31, 2015

This report for the year ended December 31, 2015 is made by Xerox Corporation and its subsidiaries (Xerox) in compliance with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (3TG). These requirements apply to registrants regardless of the geographic origin of the conflict minerals and whether or not the trading in those minerals benefits armed groups.

If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries), or a registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the source and chain of custody of those conflict minerals. The registrant must annually submit a specialized disclosure (Form SD) and Conflict Minerals Report (CMR) to the SEC that includes a description of those due diligence measures.

 

1.	COMPANY OVERVIEW

Xerox is a leading enterprise for business process and document management solutions. Its two largest operating segments are Business Process Outsourcing and Document Technology. Xerox’s products include but are not limited to multifunction printers/copiers, scanners, and multifunction/all in one printers, digital printing equipment, production printers & digital presses, continuous feed printers, wide format printers and consumables (e.g., toner cartridges), ticket vending machines, parking payment stations, automated coin machines, in-vehicle units and media information displays. These products are more fully described on our Xerox website, which can be accessed at www.xerox.com.

The content of any website referred to in this CMR is included for general information only and is not incorporated by reference in this Report.

 

2.	OUR CONFLICT MINERALS PROGRAM

2.1 Supply Chain – Reasonable Country of Origin Inquiry

Xerox is many steps removed from the mining of conflict minerals. The origin of conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The 3TG smelters or refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. Xerox has conducted an analysis of our products and found that, although we do not directly purchase conflict minerals from our suppliers, Xerox purchases products, component parts and materials that contain metals, some of which contain conflict minerals. We rely on our Tier 1 suppliers to provide information on the origin of the conflict minerals contained in components that are included in our products by using the CFSI Conflict Minerals Reporting Template (CMRT), which allows us to perform our Reasonable Country of Origin Inquiry (RCOI).

2.2 Supplier Risk Assessment

Because of the size of our company, the complexity of our products and the depth and breadth of our supply chain, it is difficult to identify sources upstream from our direct suppliers. As a result, Xerox conducted a product review to determine products in scope and developed a supplier risk assessment process, through which the conflict minerals program is implemented, managed and monitored. With a goal of targeting 3TG minerals, this risk assessment process was developed to identify those suppliers whose products may contain the presence of tin, tantalum, tungsten and gold.

We conducted a survey of these suppliers to determine whether the conflict minerals in components contained in our products originated from the DRC or adjoining countries. This supply-chain survey was conducted with our Tier 1 production suppliers using the CMRT, which contains questions about the facilities used to process these minerals, as well

---

as supplier RCOI. The goal of this activity was to identify, where applicable, the 3TG smelters or refiners who contribute refined conflict minerals to Xerox components, assemblies and Original Equipment Manufacturer (OEM) Products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters or refiners that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters or refiners the company and its suppliers use. Our supplier survey request also included the Conflict Free Sourcing Initiative (CFSI) informational links on available conflict mineral and smelter information. In 2015, Xerox surveyed 362 suppliers with a 60% response rate.

The responses contained varying degrees of information regarding the names and locations of 3TG smelters or refiners which process necessary conflict minerals used by our suppliers, which are ultimately incorporated into our products. We have designed and adopted a risk management plan that summarizes our risk mitigation efforts. Under our risk-assessment process, we perform due diligence reviews of supplier responses for their use of 3TG and conduct follow-up actions on suppliers, encouraging further requests for accurate, complete or missing template information where responses identified red flags based on our risk assessment of the level of risk of the commodities supplied to us.

In 2015, we further refined our process of evaluating the CMRTs to assist with our ongoing risk assessment by analyzing supplier responses and providing feedback to suppliers on errors and corrections. We also provide a hot-line for supplier communication. In addition, we provide monthly reports and quarterly management reviews to our senior management and elevate non-responsive issues as necessary.

2.3 Company Management Systems

Policy

Xerox has adopted a company policy which is posted on our website under Supplier Relations – Conflict Minerals at
www.xerox.com/corporate-citizenship-2015/business/supplier-relations.html.

Internal Team

Xerox has established a management system for conflict minerals. Our management system includes a Senior Management Steering Committee sponsored by the President of Corporate Operations, who reports directly to our CEO and who is responsible for signing the Form SD, as well as senior executives from Global Procurement, Environment Health Safety & Sustainability, Internal Controls and Legal. Our team of functional subject matter experts is responsible for implementing our conflict minerals compliance strategy. Senior management is provided with updates on the program and results of our conflict minerals program efforts on a regular basis.

2.4 Control Systems

Controls include, but are not limited to, our Code of Business Conduct for our employees, our Supplier Code of Conduct (adopted from the Electronic Industry Citizenship Coalition (EICC) code of conduct) and a conflict minerals contract clause incorporated in our Multi-National Master Purchasing Agreement for new contracts.

Xerox worked with the EICC in the early stages to support the CFSI and continues to be a member of the CFSI, a group assisting in the development of tools and processes to improve conflict minerals due diligence, which is an EICC and Global eSustainability initiative. As outlined in the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas; 2^nd Edition (OECD 2013), the internationally recognized standard on which our company’s system is based, we support an industry initiative, the CFSI, that audits smelters’ and refiners’ due diligence activities. The data on which we relied for certain statements in this declaration was obtained through our membership in the CFSI, using the CFSI Compliant Smelter Sourcing Information Report created specifically for Xerox.

In addition, our current standard supplier contracts also require our suppliers to adopt a policy on the responsible sourcing of minerals, implement due diligence processes to support that policy, and complete and return to Xerox the CFSI CMRT.

2.5 Grievance Mechanism

We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Xerox policies. This is communicated annually in our employee code of ethics training process and the supplier ethics letter. This mechanism helps us to identify and assess risk.

 

2

---

3.	DUE DILIGENCE

3.1 Design of Due Diligence

Xerox designed its due diligence measures to be in conformity, in all material respects, with the nationally or internationally recognized due diligence framework in the OECD 2013.

3.2 Smelter or Refiner Results*

Our due diligence process includes participation in CFSI and following the OECD implementation framework. We requested that our suppliers complete the CMRT survey in order to obtain information about 3TG smelters or refiners in our supply chain. We have determined that these actions represent the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

The majority of survey responses provided smelter and refiner data, although some responses did not completely list all the smelters or refiners used in their supply chain. We analyzed and compared all the 3TG smelter and refiner data we received against information obtained from the CFSI smelter database. For the calendar year 2015, our due diligence identified 463 smelters and refiners as potential sources of 3TG minerals that were reported to be in our supply chain.

In order to provide compliance status, we completed further analysis of the 463 smelters and refiners, of which 225 have been certified as conflict-free compliant by the CFSI approved program. An additional 78 are known to be legitimate smelters whom the CFSI outreach program is working to engage in their audit program, but have yet to be certified. The remaining 160 are alleged smelters which have been allocated a Smelter Identification CID number and are awaiting validation through the CFSI audit program.

 

*	Note: The data above was obtained from the non-public (member only access) CFSI Data Exchange Forum as of 2/29/2016.

Smelters or refiners verified as conflict-free or in the audit process**

 

Tantalum			47 of 55 (85%)
Tin			84 of 172 (49%)
Tungsten			43 of 60 (72%)
Gold			129 of 176 (73%)
Total			303 of 463 (65%)

 

**	Note: CFSI compliance results are as of 2/29/2016 (available at http://www.conflictfreesourcing.org).

 

4.	DETERMINATION

The information received from our due diligence efforts from suppliers or other sources is not sufficient to determine the origin of all 3TG our products contain, whether the 3TG come from recycled or scrap sources, the facilities used to process them, their country of origin, or their mine or location of origin. We have found no reasonable basis for concluding that these refiners, or the other smelters preparing to be audited, sourced 3TG minerals that directly or indirectly finance or benefit armed groups of the conflict region of the Covered Countries.

Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the 3TG minerals in our products include the CFSI compliant smelters listed in Appendix I below. Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG minerals in our products or whether the 3TG minerals in our products are from recycled or scrap sources. However, based on the information provided by our suppliers, as well as from the CFSI and other sources, we believe that the countries of origin of the 3TG minerals contained in our products include the countries listed in Appendix II below as well as recycled and scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.

 

3

---

Through our participation in the CFSI, we continue to support independent third party audits through the CFSI or other third party certification schemes.

In accordance with the OECD Guidance and the Rule, this CMR is available on our website under Supplier Relations – Conflict Minerals at www.xerox.com/corporate-citizenship-2015/business/supplier-relations.html.

 

5.	STEPS TO BE TAKEN IN 2016 TO MITIGATE RISK

Xerox plans to undertake the following steps during 2016 to improve the due diligence conducted in order to further mitigate the risk that the necessary conflict minerals in our products do not benefit armed groups in the DRC or adjoining countries, including:

 

•

Continue to strengthen engagement with relevant suppliers and to provide training, as appropriate, to help them understand and satisfy Xerox requirements related to 3TG minerals under the Rule.

 

•

Continue using internal elevation process within our supply chain organization in working (or requiring) with suppliers to obtain required information.

 

•

Review third party programs to further improve our conflict mineral process in obtaining accurate and complete information about smelters/refiners.

 

•

Continue to provide ongoing feedback to suppliers on errors and corrections required in connection with the CMRT assessment.

 

•

Continue to participate as a member in the EICC and the CFSI, including Conflict Free Smelter Program smelter validation and supplier outreach.

 

•

Continue to work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.

 

 

 

 

4

---

APPENDIX I

 

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
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 S.A.		Switzerland
Gold		Asahi Pretec Corp.		Japan
Gold		Asahi Refining Canada Ltd.		Canada
Gold		Asahi Refining USA Inc.		USA
Gold		Asaka Riken Co., Ltd.		Japan
Gold		Atasay Kuyumculuk 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		DODUCO GmbH		Germany
Gold		Dowa		Japan
Gold		Eco-System Recycling Co., Ltd.		Japan
Gold		Elemetal Refining, LLC		USA
Gold		Emirates Gold DMCC		United Arab Emirates
Gold		Heimerle + Meule GmbH		Germany, Austria
Gold		Heraeus Ltd. Hong Kong		China
Gold		Heraeus Precious Metals GmbH & Co. KG		Germany
Gold		Ishifuku Metal Industry Co., Ltd.		Japan
Gold		Istanbul Gold Refinery		Turkey
Gold		Japan Mint		Japan
Gold		Jiangxi Copper Co., Ltd.		China
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		Russia
Gold		JSC Uralelectromed		Russia
Gold		JX Nippon Mining & Metals Co., Ltd.		Japan
Gold		Kazzinc		Kazakhstan
Gold		Kennecott Utah Copper LLC		USA
Gold		Kojima Chemicals Co., Ltd.		Japan
Gold		L’ azurde Company For Jewelry		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) Pte., Ltd.		Singapore
Gold		Metalor Technologies S.A.		Switzerland

 

A-1

---

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
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		MMTC-PAMP India Pvt., Ltd.		India
Gold		Moscow Special Alloys Processing Plant		Moscow
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		Turkey
Gold		Nihon Material Co., Ltd.		Japan
Gold		Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH		Austria
Gold		Ohura Precious Metal Industry Co., Ltd.		Japan
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)		Russia
Gold		OJSC Novosibirsk Refinery		Russia
Gold		PAMP S.A.		Switzerland
Gold		Prioksky Plant of Non-Ferrous Metals		Russia
Gold		PT Aneka Tambang (Persero) Tbk		Indonesia
Gold		PX Précinox S.A.		Switzerland
Gold		Rand Refinery (Pty) Ltd.		South Africa
Gold		Republic Metals Corporation		USA
Gold		Royal Canadian Mint		Canada
Gold		Schone Edelmetaal B.V.		The Netherlands
Gold		SEMPSA Joyería Platería S.A.		Spain
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		China
Gold		Sichuan Tianze Precious Metals Co., Ltd.		China
Gold		Singway Technology Co., Ltd.		Taiwan
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		Russia
Gold		Solar Applied Materials Technology Corp.		Taiwan
Gold		Sumitomo Metal Mining Co., Ltd.		Japan
Gold		T.C.A S.p.A		Italy
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 S.A. Business Unit Precious Metals Refining		Belgium
Gold		United Precious Metal Refining, Inc.		USA
Gold		Valcambi S.A.		Switzerland
Gold		Western Australian Mint trading as The Perth Mint		Australia
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

 

A-2

---

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
Tantalum		D Block Metals, LLC		China
Tantalum		Duoluoshan		China
Tantalum		Exotech Inc.		USA
Tantalum		F&X Electro-Materials Ltd.		China
Tantalum		FIR Metals & Resource Ltd.		China
Tantalum		Global Advanced Metals Aizu		Japan
Tantalum		Global Advanced Metals Boyertown		USA
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		China
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		Hengyang King Xing Lifeng New Materials Co., Ltd.		China
Tantalum		Hi-Temp Specialty Metals, Inc.		USA
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		China
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		China
Tantalum		Jiujiang Tanbre Co., Ltd.		China
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		China
Tantalum		KEMET Blue Metals		Mexico
Tantalum		KEMET Blue Powder		USA
Tantalum		King-Tan Tantalum Industry Ltd.		China
Tantalum		LSM Brasil S.A.		Brazil
Tantalum		Metallurgical Products India Pvt., Ltd.		India
Tantalum		Mineração Taboca S.A.		Brazil
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		QuantumClean		USA
Tantalum		Resind Indústria e Comércio Ltda.		Brazil
Tantalum		RFH Tantalum Smeltry Co., Ltd.		China
Tantalum		Solikamsk Magnesium Works OAO		Russia
Tantalum		Taki Chemicals		Japan
Tantalum		Telex Metals		USA
Tantalum		Tranzact, Inc.		USA
Tantalum		Ulba Metallurgical Plant JSC		Kazakhstan
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		China
Tantalum		Yichun Jin Yang Rare Metal Co., Ltd.		China
Tantalum		Zhuzhou Cemented Carbide		China

 

A-3

---

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
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		Elmet S.L.U. (Metallo Group)		Spain
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		Perú
Tin		Mitsubishi Materials Corporation		Japan
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		Thailand
Tin		O.M. Manufacturing Philippines, Inc.		Philippines
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 Prima Tin		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 Cipta Persada Mulia		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

 

A-4

---

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
Tin		PT Sariwiguna Binasentosa		Indonesia
Tin		PT Stanindo Inti Perkasa		Indonesia
Tin		PT Sukses Inti Makmur		Indonesia
Tin		PT Sumber Jaya Indah		Indonesia
Tin		PT Timah (Persero) Tbk Kundur		Indonesia
Tin		PT Timah (Persero) Tbk Mentok		Indonesia
Tin		PT Tinindo Inter Nusa		Indonesia
Tin		PT Tommy Utama		Indonesia
Tin		PT Wahana Perkit Jaya		Indonesia
Tin		Resind Indústria e Comércio Ltda.		Brazil
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 Tin Company Limited		China
Tungsten		A.L.M.T. TUNGSTEN Corp.		Japan
Tungsten		Asia Tungsten Products Vietnam Ltd.		Vietnam
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		China
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		China
Tungsten		Dayu Jincheng Tungsten Industry Co., Ltd.		China
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		China
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		China
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		China
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		China
Tungsten		Ganzhou Non-ferrous Metals Smelting Co., Ltd.		China
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		China
Tungsten		Ganzhou Yatai Tungsten 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 Chenzhou Mining Co., Ltd.		China
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		China
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin		China
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		China
Tungsten		Hydrometallurg, JSC		Russia
Tungsten		Japan New Metals Co., Ltd.		Japan
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		China
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		China
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		China
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		China
Tungsten		Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.		China

 

A-5

---

Mineral		Smelter or Refiner Name*		Country Location of Smelter or Refiner
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		China
Tungsten		Kennametal Fallon		USA
Tungsten		Kennametal Huntsville		USA
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		China
Tungsten		Niagara Refining LLC		USA
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		Vietnam
Tungsten		Pobedit, JSC		Russia
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		Vietnam
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd.		Vietnam
Tungsten		Wolfram Bergbau und Hütten AG		Austria
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		China
Tungsten		Xiamen Tungsten Co., Ltd.		China
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		China

 

*	Smelter or refiner names as reported by the CFSI as of 02/29/2016.

 

 

 

A-6

---

APPENDIX II

 

Countries of origin of Smelters or Refiners are believed to include:
Angola		Namibia
Argentina		Netherlands
Australia		Nigeria
Austria		Peru
Belgium		Portugal
Bolivia		Republic of Congo
Brazil		Russia
Burundi		Rwanda
Cambodia		Sierra Leone
Canada		Singapore
Central African Republic		Slovakia
Chile		South Africa
China		South Korea
Colombia		South Sudan
Côte D’Ivoire		Spain
Czech Republic		Suriname
Democratic Republic of Congo		Switzerland
Djibouti		Taiwan
Ecuador		Tanzania
Egypt		Thailand
Estonia		Uganda
Ethiopia		United Kingdom
France		United States of America
Germany		Vietnam
Guyana		Zambia
Hungary		Zimbabwe
India
Indonesia
Ireland
Israel
Japan
Kazakhstan
Kenya
Laos
Luxembourg
Madagascar
Malaysia
Mongolia
Mozambique
Myanmar

 

A-7

---

Serious News for Serious Traders! Try StreetInsider.com Premium Free!

---

You May Also Be Interested In

• Xerox Holdings Corporation Plans Webcast to Discuss 2024 First-Quarter Results
• SFL - Acquisition of two LNG dual-fuel chemical carriers in combination with long term employment
• Swipe Right on Safety: New Study from Norton Finds 64% of Online Daters are Interested in Using AI as a Dating Coach