Form SD MICROSOFT CORP

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, DC 20549

 

 

FORM SD

Specialized Disclosure Report

 

 

Microsoft Corporation

(Exact Name of Registrant as Specified in Its Charter)

 

 

 

Washington		0-14278		91-1144442
(State or Other Jurisdiction of Incorporation)		(Commission File Number)		(IRS Employer Identification No.)

 

One Microsoft Way, Redmond, Washington		98052-6399
(Address of Principal Executive Offices)		(Zip Code)

Bradford L. Smith

President, Chief Legal Officer

(425) 706-3024

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

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

 

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

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Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

A copy of The Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://www.microsoft.com/about/csr/responsible-sourcing/.

Item 1.02 Exhibit

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

Section 2 - Exhibits

Item 2.01 – Exhibits

Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2015 - December 31, 2015 is attached per Section 1.

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SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

MICROSOFT CORPORATION

                (Registrant)

 

/s/ Bradford L. Smith				May 31, 2016
Bradford L. Smith
President, Chief Legal Officer

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INDEX TO EXHIBITS

 

Exhibit No.		Description
1.01		Conflict Minerals Report for the reporting period January 1, 2015 - December 31, 2015

Exhibit 1.01

MICROSOFT CORPORATION

CONFLICT MINERALS REPORT

FOR THE REPORTING PERIOD FROM

JANUARY 1 TO DECEMBER 31, 2015

 

I.	INTRODUCTION

This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1 to December 31, 2015 (“2015 reporting year”). The report covers activities of all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule (“Microsoft”). The Rule imposes certain due diligence and reporting obligations on US Securities and Exchange Commission (“SEC”) registrants whose manufactured products (including products contracted to be made for each registrant) contain “conflict minerals” necessary to the functionality or production of those products. The Rule defines “conflict minerals” to include cassiterite, columbite-tantalite, gold, wolframite and their derivatives limited to tin, tantalum, tungsten, and gold (collectively referred to as “3TGs”).

Microsoft develops and markets software, services, and hardware devices that deliver new opportunities, greater convenience, and enhanced value to people’s lives. Microsoft is committed to the responsible sourcing of raw materials globally in support of human rights, labor, health and safety, environmental protection, and business ethics. Our commitment and strategy are outlined in the Microsoft Responsible Sourcing of Raw Materials policy. Under our policy, Microsoft takes a holistic approach to responsible sourcing while working toward the use of conflict-free minerals in our hardware devices (“devices”). One of our objectives is to ensure that we do not harm communities through an inadvertent de facto embargo of minerals from the Democratic Republic of the Congo (“DRC”) or an adjoining country (defined as a country that shares an internationally recognized border with the DRC) - both considered a “Covered Country” for purposes of the Rule.

This year’s report documents our efforts for the 2015 reporting year, which demonstrate meaningful progress. The number of Conflict-Free Smelter Program¹ (“CFSP”)-compliant smelters or refiners (the “SORs”) in our supply chain increased from 148 to 213 due to targeted supplier outreach and maturation of the CFSP - of which Microsoft is a founding partner and strong supporter. Based on Microsoft’s data analysis, we also concluded that 100 percent of tantalum smelters identified in Microsoft’s supply chain were CFSP compliant.

Since the 2014 reporting year (January 1 to December 31, 2014), we have also taken several notable actions to improve our conflict minerals due diligence, including the following:

 

•

Completed implementation of recommendations from third party audit firm covering 2014 reporting year external assessment;

 

¹ Please note: this CMR contains references and hyper-text links to non-Microsoft, external websites. These links are provided for informational purposes only. Their inclusion in this CMR does not establish Microsoft’s endorsement of or assumption of liability for content posted on these external websites.

 

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•

Implemented process improvements to increase supplier response rate, including extensive sourcing manager involvement, supplier resource support, and tailored outreach to both new suppliers and 2014 unresponsive suppliers;

 

•

Developed and refined internal controls and procedures to improve in-scope supplier determination, data collection and validation, and supply chain due diligence, including early engagement with suppliers upon initial on-boarding through Microsoft’s Social and Environmental Accountability (“SEA”) online Audit Management System; and

 

•

Enhanced our supplier data collection process such as addition of automated “red flags” to identify quality control issues and Covered Country sourcing risk early in the surveying process.

Microsoft devices contain one or more 3TGs and are within the Rule’s scope. Devices manufactured during the 2015 reporting year included:

 

•

Surface line of tablet and laptop computers and accessories;

 

•

Xbox gaming/entertainment consoles and accessories;

 

•

Personal computing accessories, including mice and keyboards;

 

•

Mobile devices, including Nokia and Lumia branded mobile phones and devices;

 

•

Surface Hub computing displays; and

 

•

Microsoft Band wellness devices.

On the basis of our performance of the required “Reasonable Country of Origin Inquiry” (“RCOI”) (see Section II), we cannot exclude the possibility that some of the 3TGs contained in our devices may have originated in a Covered Country. Therefore, we are submitting this CMR, which describes the conflict minerals due diligence we performed, as an exhibit to our Form SD.

We are submitting this CMR to the SEC under the reporting requirements of the Rule and have published the CMR externally on our corporate website: see Responsible Sourcing. The manufacture of devices during any specified time period may include raw materials sourced before, as well as during, that time period. In particular, some 3TGs used during the 2015 reporting year may have been smelted and refined prior to January 31, 2013 and are exempt under the Rule because they were outside the supply chain prior to the Rule’s initial reporting period. While such 3TGs are excluded from the Rule’s scope, our RCOI and supply chain due diligence conducted for the 2015 reporting year may have included such minerals.

 

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II.	REASONABLE COUNTRY OF ORIGIN INQUIRY

Our RCOI corresponds to the first and second steps of the five-step OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”), as that Guidance (including its Supplements) applies to each of the 3TGs and to Microsoft as a “downstream company.” The OECD Guidance provides a framework for detailed due diligence to support responsible global supply chain management of minerals, including 3TGs, and is currently the only nationally or internationally recognized framework for conflict minerals due diligence.

Microsoft does not contract with raw material providers in preparation for manufacturing our devices and does not source 3TGs directly. We source products from suppliers, which, in turn, source materials, components, and products from their suppliers (“sub-tier suppliers”). Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG SORs. Our contracts require all Microsoft supplier partners to identify, by weight, each and every substance contained in the materials, components, and products supplied to us, including 3TGs. We refer collectively in this CMR to our own manufacturing facilities, contracted manufacturing partners, and our strategic component suppliers as “in-scope suppliers.” Due to our extended supply chain, we leverage our in-scope suppliers, which provide us with information concerning the sources and chains of custody of 3TGs necessary to the functionality or production of our devices. We provide more detail on our supply chain due diligence process in Section III. The graphic below demonstrates Microsoft’s span of influence with its suppliers.

 

 

A.

Establish Strong Company Management Systems

 

1.

Company Policies

Microsoft’s Responsible Sourcing of Raw Materials policy describes our commitment and strategy to responsibly source raw materials used in our devices. Microsoft is committed to the sourcing of raw materials in a way that supports human rights, labor, health and safety, environment, and ethics. Consistent with this mission, we address the issues associated with the harvesting, extraction, and transportation of raw materials as a global responsibility applicable to all substances used in our devices - unbounded by specific materials or locations. This policy also states that we implement programs that are region-specific, such as working toward the use of conflict-free minerals in our devices. We expect our suppliers to support our commitment to the responsible sourcing of raw materials.

 

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Microsoft’s policies also include Microsoft’s Global Human Rights Statement; our Supplier Code of Conduct, which defines our expectations concerning ethical business, employment, environmental, and worker safety practices; and our internal Standards of Business Conduct, which outlines expected behaviors for all Microsoft employees. Microsoft uses supplier specifications and internal procedures to establish supplier commitments for the responsible sourcing of raw materials, including 3TGs. We incorporate these requirements into our hardware and packaging contracts.

 

2.

Internal Management Team

A cross-functional team (“team”) supports Microsoft’s responsible sourcing activities, including compliance activities associated with the Rule. The Corporate Vice President of Microsoft’s Manufacturing and Supply Chain organization is the executive sponsor of the team. Representatives from various Microsoft corporate groups are involved in the development, review and filing of the CMR. Corporate groups represented on the team include Sourcing, Social and Environmental Accountability, Manufacturing, Accounting/Finance, Internal Audit, Windows and Devices Group, Corporate, External and Legal Affairs, Business and Corporate Responsibility, Information Services, and Product Environmental Compliance.

This team meets according to Microsoft’s internal Responsible Sourcing Program Manual and, at a minimum, quarterly to assess the progress of our program and identify steps that are necessary to meet our compliance obligations. The team also trains other internal stakeholders on their roles and responsibilities for implementing and supporting Microsoft’s responsible sourcing program.

 

3.

System of Supply Chain Controls and Transparency

We require our in-scope suppliers to fully disclose all substances and materials that are present in the devices or components they supply to us by component and weight. These material disclosure requirements explicitly cover 3TGs. Our in-scope suppliers are responsible for communicating these 3TG sourcing requirements and specifications to their sub-tier suppliers. Data obtained from our in-scope suppliers, therefore, includes 3TG information obtained from their sub-tier suppliers.

In addition, we require all in-scope suppliers to submit a Conflict Minerals Reporting Template (“CMRT”) annually. These CMRTs are evaluated for completeness, data integrity, due diligence thoroughness, and sourcing risk. Potential risks may include, but are not limited to, failure to fully complete the CMRT, inconsistencies in the CMRT, and possible sourcing from a Covered Country. If data gaps or risks are identified, Microsoft investigates each issue and engages with those suppliers to address all concerns in conformance to Microsoft policies, procedures and specifications..

In cases where the supplier still poses risk, Microsoft initiates supplier corrective action calibrated to the severity of the identified risk. H02050 - Microsoft Supplier Social and Environmental Accountability Manual and Microsoft internal operating procedures establish controls for documenting supplier engagement, supplier response, and corrective action for any non-conformance findings.

If we confirm that a supplier’s upstream SOR is using raw materials that do not comply with Microsoft’s Responsible Sourcing of Raw Materials policy or the specifications referenced in this CMR, Microsoft initiates actions to address the non-conformance. These actions may include supplier engagement, training, and/or additional audits. Microsoft works with impacted suppliers to find alternate sources for non-compliant minerals. If a supplier does not commit to an alternate source within a reasonable time period, Microsoft places the supplier on restricted status with no new Microsoft business awarded until any non-conformance is resolved. Termination of Microsoft’s business relationship with the supplier may also occur.

 

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Microsoft is a longstanding member of the Global e-Sustainability Initiative (“GeSI”) and the Electronics Industry Citizenship Coalition (“EICC”) - two organizations that initiated the Conflict-Free Sourcing Initiative (“CFSI”). Founded in 2008 by GeSI and EICC members, the CFSI is one of the most utilized and respected resources for addressing supply chain conflict minerals issues. The CFSI, through its CFSP, uses an independent third-party audit to verify SORs that demonstrate that the 3TGs, which they process, do not originate from sources that may be directly or indirectly financing or benefitting armed groups in a Covered Country. Microsoft funded an early adopters program that provided initial audit funds, enabling more SORs to be CFSP audited. Microsoft also provides financial support to the Industrial Technology Research Institute’s Tin Supply Chain Initiative (“iTSCi”) that has established a system of traceability and due diligence in Covered Countries and we support the efforts of organizations, including the Public-Private Alliance for Minerals Trade (“PPA”), that promote responsible mining and raw material sourcing. Microsoft is a sponsor of the Multi-Stakeholder Group, hosted by the Responsible Sourcing Network, which coordinates efforts to promote security and stability in the DRC region by engaging governments to bring an end to the conflict in the DRC.

Microsoft works to positively impact end-to-end mining sustainability, from artisanal mines to larger mining enterprises. Through this work, we aspire to improve conditions directly at the source across a broad scope of issues in partnership with the electronics industry, the mining industry, and other not-for-profit partners. In particular, Microsoft believes that it can improve practices associated with the mining of metal ores at their source through participation in collaborative initiatives related to the upstream mining industry. Microsoft supports and participates in numerous additional partnerships that work to establish responsible mining standards and the responsible sourcing of minerals, including the following:

 

•

Initiative for Responsible Mining Assurance (“IRMA”): established a multi-stakeholder and independently verifiable responsible mining assurance system that improves social and environmental performance;

 

•

Pact: empowers small and medium sized miners to achieve legal, safe and secure livelihoods; and

 

•

Alliance for Responsible Mining (“ARM”): sets standards for responsible artisanal and small scale mining and supports and creates opportunities for gold miners and provides them incentives to become responsible economic, technological and environmental enterprises.

 

4.

Supplier Engagement

In light of our corporate size, the complexity of our devices, and the depth, breadth, and constant evolution of our supply chain; we rely on our in-scope suppliers to provide us with information concerning the source and chain of custody of 3TGs contained in the products and components they supply to us. Many of our in-scope suppliers are also subject to the Rule, and they rely on information provided by their upstream suppliers to meet their compliance obligations.

 

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We drive responsible sourcing through our extended supply chain by surveying our in-scope suppliers’ sourcing of raw materials in their upstream supply chains. We also use tools that include supplier and smelter capability building and support broader industry efforts to promote responsible mining and sourcing. Finally, we conduct audits of our contracted suppliers to verify conformance to Microsoft requirements. More information is set forth below.

 

•

Supplier Requirements: We require our in-scope suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications that we communicate, monitor, and track electronically to ensure conformance. These policies and procedures are outlined in Section III. We also train our directly contracted suppliers to meet our requirements through training sessions, educational forums, and direct communications.

 

•

Capability Building and Partnerships: We work closely with our supply chain partners to build the raw material supplier capabilities for achieving our responsible sourcing goals. We invest in industry programs, such as the CFSP, to increase suppliers’ capabilities and provide them with platforms to share best practices with each other.

 

•

Supplier Audits: Microsoft conducts audits of its contracted suppliers to assess their conformance to Microsoft requirements, including supply chain transparency. All new contracted hardware and packaging suppliers undergo an initial capability assessment to verify conformance to Microsoft requirements. Microsoft requires that suppliers have a policy and effective procedures to establish and monitor their responsible sourcing of raw materials. Microsoft selects and retains only those business partners that commit to meeting these requirements. A failure by a supplier or any sub-tier supplier to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft. During the 2015 reporting year, Microsoft-engaged auditors conducted onsite audits of 129 contracted hardware and packaging suppliers to assess areas of SEA conformance, including whether the suppliers had an established conflict minerals policy, systems in place to implement that policy, and documentation to verify conformance to Microsoft responsible sourcing requirements.

CFSI’s “Practical Guidance for Downstream Companies” document states that “all of the [OECD Guidance’s] red flag triggers are contained in the upstream portion of the supply chain.” Because these conflict mineral supply chain “triggers” are directed to upstream companies, rather than downstream manufacturers, such as Microsoft, we mitigate risks associated with the sourcing of 3TGs by working with our in-scope suppliers to identify 3TG SORs and encourage those facilities to become CFSP compliant or, failing to do so, use an alternate facility that is CFSP compliant. We also participate in industry-wide initiatives, such as the CFSP, that assess SOR compliance with the OECD Guidance as recommended by CFSI guidance documents. We require our in-scope suppliers to actively work with their upstream suppliers to mitigate risks associated with their sourcing of 3TGs.

 

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5.

Grievance Mechanism

Microsoft’s Global Human Rights Statement expresses our commitment to provide an anonymous grievance reporting mechanism for our employees and other stakeholders who may be impacted by our operations. Microsoft’s Business Conduct Hotline provides that mechanism, which allows employees and others to ask compliance questions or report concerns regarding Microsoft’s business operations, including its mineral sourcing policies or those of its suppliers. We investigate and, where appropriate, take remedial action to address reported incidents. We also participate in industry efforts to develop specific grievance mechanisms for conflict minerals-related issues, including PPA’s efforts to establish an in-region hotline.

 

B.

Identify and Assess Risk in the Supply Chain

We took the following steps to identify and assess supplier conflict mineral sourcing risk in connection with 2015 reporting year data²:

 

•

Using the Rule and SEC guidance, we generated a list of potential in-scope suppliers to receive Microsoft’s annual CMRT survey.

 

•

We surveyed all potential in-scope suppliers to determine the status of any 3TGs contained in devices manufactured during the 2015 reporting year by utilizing the CFSI-standard CMRT and the services of a third party solution provider. The survey included questions regarding a supplier’s responsible sourcing policies, its practices for engaging with its upstream suppliers, a request to list all SORs from which its 3TGs were sourced, and other detailed questions concerning the origins of 3TGs contained in the supplier’s products as well as its 3TG due diligence policies and procedures.

 

•

The survey followed the OECD Guidance as tailored for Microsoft’s role as a downstream company. We reviewed all supplier CMRT submissions to validate that they were complete and to identify any contradictions or inconsistencies. We worked with our third-party solution provider to secure updated responses from suppliers, as needed.

 

•

We identified 276 active and in-scope suppliers for reporting year 2015. Of the 276 active and in-scope suppliers surveyed, we received responses from 267. This resulted in a 97% response rate - an improvement from the 2014 reporting year rate of 82% and the 2013 reporting year rate of 71% as shown in Figure 1.

 

² Microsoft completed its supplier conflict mineral sourcing data analysis for the 2015 reporting year on March 31, 2016.

 

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Figure 1. Response Rate for Active and In-scope Suppliers (2013-2015 Reporting Years)

 

III. DUE DILIGENCE DESIGN AND PERFORMANCE

On the basis of our RCOI, we determined that 3TGs contained in our devices may have originated in one or more Covered Country. Accordingly, we designed and performed due diligence on the source and chain-of-custody of those 3TGs.

 

A.

Due Diligence Design

Our 3TG due diligence process conforms to the third and fourth steps of the five-step OECD Guidance. The first and second steps of the five-step OECD Guidance were addressed in Section II.

 

B.

Due Diligence Performed

 

1.

Design and Implement a Strategy to Respond to Risks

Microsoft requires its suppliers to take affirmative actions to minimize the possible sourcing of 3TGs from conflict-affected and high-risk areas. This is required through contracts with our suppliers and supplier specifications.

 

a.

Microsoft Supplier Specifications - H00594 and HO0642

Microsoft’s supplier specification H00594, Restricted Substances for Hardware Products (“H00594”), requires 100 percent identification of all materials, including 3TG, used in all packaging and hardware products and parts supplied to Microsoft on a component-by-component level. Specifically, H00594 requires contracted suppliers to do the following:

 

•

Post a responsible sourcing policy, conforming to the OECD Guidance, on their website;

 

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Exercise due diligence on the source and chain of custody of any 3TG contained in materials, components, or products they supply to Microsoft;

 

•

Identify, by name, each SOR that has processed or otherwise handled 3TGs contained in those materials, components, or products;

 

•

Encourage those SORs to participate in the CFSP or an equivalent third-party conflict-free audit scheme, when available;

 

•

Confirm that 3TGs in their supply chain are sourced from SORs that are compliant with the CFSP or an equivalent independent private sector audit firm, when available; and

 

•

Notify Microsoft immediately if they obtain information or knowledge that the minerals used in the materials, components, or products that they supply to Microsoft may contain 3TGs sourced from a Covered Country.

H00594 requires Microsoft suppliers to impose these same requirements on their sub-tier suppliers and to provide appropriate training and support to help their sub-tier suppliers meet Microsoft responsible sourcing requirements. To facilitate this process, H00642, Restricted Substances Control System for Hardware Products. requires Microsoft suppliers to utilize the common CMRT provided by the CFSI and found at www.conflictfreesourcing.org. Suppliers are responsible for submitting the annual CMRT as well as updating the CMRT upon request or when changes occur.

 

b.

Responsible Sourcing Program Manual Processes to Implement OECD Guidance

To respond to possible conflict mineral risks that were identified during our due diligence process, Microsoft implemented responsible sourcing practices, to communicate with suppliers that may be sourcing 3TGs under conditions that may be directly or indirectly financing or benefitting armed groups in a Covered Country. Under our Responsible Sourcing of Raw Materials Program, we use the OECD Guidance to review supplier CMRT data and identify potential red flags for the sourcing of 3TGs, including the following:

 

•

The minerals originated from or were transported via a conflict-affected or high-risk area;

 

•

The minerals were claimed to originate from a country that has limited known reserves for the mineral in question;

 

•

The minerals were claimed to originate from a country in which minerals from conflict-affected and high-risk areas are known to transit;

 

•

The company’s suppliers or other known upstream companies have shareholder or other interests in companies that supply minerals or operate in one of the red flag locations of mineral origin and transit; and

 

•

The company’s suppliers’ or other known upstream companies were known to have sourced minerals from a red flag location of mineral origin and transit in the last 12 months.

 

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Microsoft’s program includes an escalation process that may require an in-scope supplier to find an alternative to a non-CFSP compliant source of 3TGs for use in materials, components, or products supplied to Microsoft or risk termination as a Microsoft supplier. To date, we have not encountered a responsible sourcing issue with a supplier that has warranted contract termination.

Also, as required by Microsoft’s internal Responsible Sourcing Program Manual, our team assessed the progress of our conflict minerals program and identified steps necessary to meet our compliance obligations. The team also provided monthly program status updates, including metrics and audit results, to Microsoft’s Corporate Vice President of Manufacturing and Supply Chain organization. We utilized supplier survey updates, supplier communications, supplier social and environmental accountability audits, and new supplier briefings to prevent the introduction of any new 3TG sourcing risk to our supply chain. We also leveraged meetings with executives to report findings and receive program guidance.

 

c.

Industry and NGO Partner Engagement

Microsoft participated in, or has been a member of, several industry-wide responsible mining and smelting initiatives, including CFSI, PPA, ITRI’s iTSCi program, IRMA, Pact, and ARM. As part of our due diligence, we also conducted smelter outreach on behalf of the CFSI Smelter Engagement Team.

 

2.

Carried Out Independent Third-Party Audit of Supply Chain Due Diligence

As contemplated by the OECD Guidance, our due diligence program leveraged independent SOR audits, which were undertaken in accordance with the CFSP and other similar programs. Microsoft obtained SOR data from the CFSP Compliant Smelter List through our membership in the CFSI using the Reasonable Country of Origin Inquiry Data for member MSFT. This data was used to support certain statements contained in this CMR. The CFSP Compliant Smelter List is a published list of SORs that have undergone assessment through the CFSP or industry equivalent program (such as Responsible Jewellery Council or London Bullion Market Association (“LBMA”)). Microsoft also participated in CFSI’s Smelter Engagement Team during the 2015 reporting year and we engaged a third party to assist smelters prepare for CFSP audits.

 

3.

Reported on Supply Chain Due Diligence

Microsoft’s Responsible Sourcing of Raw Materials policy and other responsible sourcing documents are available on our external website. We have filed our CMR, required by the Rule, with the SEC and we have posted it on our external Responsible Sourcing website. These disclosures meet the fifth step of the five-step OECD Guidance.

 

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IV.	SOR INFORMATION

 

A.

3TG Processing Facilities

Microsoft has made a reasonable good faith effort to collect and evaluate information concerning 3TG SORs based on data provided by our in-scope suppliers. The vast majority of our in-scope suppliers provided data at a company or divisional level or otherwise were unable to identify specific entities that had processed 3TGs contained in the materials, components, or products supplied to us. This was expected given the multiple tiers of supply chain actors that are positioned between our in-scope suppliers and 3TG SORs.

Our supplier survey data revealed 19,568 potential 3TG SORs in the Microsoft supply chain. We validated the data by removing duplicate SORs, reconciling multiple SOR names for a single entity, and eliminating otherwise invalid SOR names. This process reduced the list to 688 entities. Of this list, 226 SORs were unknown to CFSI (but are being investigated by CFSI members) and another 160 SORs were confirmed as misidentified and/or were not actual SORs. After removing those entities, 302 SORs remained.

The Figures below provide a visual depiction of the SORs identified in Microsoft’s supply chain by CFSP audit status. Figure 2 categorizes the SORs by audit status and reporting year. Figure 3 categorizes the SORs by 3TG mineral and audit status.

Appendix A to this CMR lists the 302 SORs which, to the extent known, processed 3TGs in Microsoft devices during the 2015 reporting year. Appendix A provides each SOR’s country location, 3TG processed, and CFSP audit status. Appendix A includes several gold SORs which have received the LBMA Responsible Gold Certificate - these are marked with an asterisk.

Table 1 (below) summarizes the conflict mineral status of the 302 SORs that were identified in the Microsoft supply chain.

CFSI defines each audit stage in the following manner:

 

•

Compliant: SOR has been audited and found to be compliant with the relevant audit protocols;

 

•

Active: SOR has been engaged but is not yet compliant;

 

•

In Communication: SOR is not yet active but is in communication with CFSP and/or member company;

 

•

Outreach Required: SOR is not yet active and outreach is needed by CFSI member companies to encourage SOR participation in CFSP; and

 

•

TI-CMC Member Company: SOR is a member of the Tungsten Industry – Conflict Mineral Council (“TI-CMC”) and has agreed to undergo an audit within 2 years of joining TI-CMC.

 

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Figure 2. Identified SORs by CFSP Audit Status (2013-2015 Reporting Years)

 

 

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Figure 3: Identified SORs by 3TG and CFSP Audit Status

 

 

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Table 1: Summary of CFSP Audit Status of Identified SORs

 

Number of SORs Identified in Microsoft Supply Chain		Audit Status
213		Compliant
40		Active
17		In Communication
28		Outreach Required
4		TI-CMC
673		LBMA

Figures 4-7 show the geographic distribution of the 302 SORs identified in the Microsoft supply chain by 3TG mineral. The circle size corresponds to the relative number of times our in-scope suppliers identified each 3TG SOR in their completed CMRT form.

Figure 4: Location and Relative Number of Identified SORs by 3TG Mineral (Tin)

 

 

³ These 67 LBMA Gold SORs are included in the 302 SORs listed in Appendix A and identified by asterisk.

 

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Figure 5: Location and Relative Number of Identified SORs by 3TG Mineral (Tantalum)

 

Figure 6: Location and Relative Number of Identified SORs by 3TG Mineral (Tungsten)

 

 

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Figure 7: Location and Relative Number of Identified SORs by 3TG Mineral (Gold)

 

 

B.

3TG Countries of Origin

Countries of origin for the 3TGs that were identified by our CFSP-compliant SORs include: Argentina, Angola, Australia, Austria, Belgium, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe. Other countries of origin identified through additional due diligence included: Armenia, Belarus, Ghana, Guinea, Hong Kong, Italy, Jersey, Kyrgyzstan, Mali, Mexico, Morocco, Niger, Papua New Guinea, Philippines, Poland, Saudi Arabia, Sweden, Tajikistan, Turkey, United Arab Emirates, and Uzbekistan.

Figure 8 provides a graphical presentation of the countries of origin for 3TGs that were identified as being used in the Microsoft supply chain during the 2015 reporting year. Although Covered Countries are listed in Microsoft’s countries of origin list, the SORs located in those countries are CFSP-compliant, verifying that they have been determined by CFSP to source 3TGs in a manner that does not directly or indirectly finance or benefit armed groups in a Covered Country. At this time, we have country-of-origin information for CFSP-compliant SORs and countries identified through additional due diligence.

 

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Figure 8: Country-of-Origin Information for SORs Identified in Microsoft’s Supply Chain

 

For the identified conflict-free SORs for which minerals sourcing information is available from CFSI⁴:

 

•

55% process recycled or scrap material.

 

•

75% are not sourcing from Covered Countries.

 

•

38 SORs are sourcing from Covered Countries but are CFSP compliant.

 

C.

3TG Mines or Locations of Origin

Microsoft obtained Reasonable Country of Origin data through our membership in the CFSI using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin of SORs identified in Microsoft’s supply chain. Microsoft supports the continued refinement and expansion of the list of participating SORs in the CFSP audit program through our membership in CFSI, which oversees the CFSP. We encourage SORs to participate in the CFSP by contacting all non-compliant SORs identified in our supply chain each reporting year. We also require all of our suppliers that reported non-compliant SORs to conduct outreach to those SORs and encourage them to join the CFSP. In addition, we have encouraged other SORs to participate in the CFSP by contacting SORs directly and by engaging in outreach events to encourage greater CFSP participation. We funded a third party to help educate SORs and prepare the SORs for the audit process. We have also offered to visit SORs to facilitate their participation in the CFSP.

 

⁴ These numbers include metrics on indirect sourcing that were not included in the 2014 reporting year report as they were made available for the first time this year by CFSI.

 

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V.	IMPROVEMENTS

Microsoft’s key 2015 reporting year accomplishments and improvements are detailed below. Although comparisons to the 2014 reporting year data are of limited utility due to supply chain year-to-year variances in the data pool, this year’s report, which documents our efforts to expand the number of verified conflict-free SORs in our supply chain, demonstrates meaningful progress, including the following improvements:

 

•

Increased the number of CFSP-compliant SORs identified through our due diligence from 148 to 213 due to enhanced supplier outreach, and maturation of CFSI’s CFSP;

 

•

Increased supplier response rate from 71% in 2013 and 82% in 2014 to 97% in the 2015 reporting year;

 

•

Developed early risk identification mechanisms with third party solution provider;

 

•

Strengthened supplier corrective action process to drive and improve supplier due diligence;

 

•

Developed new internal operational controls to standardize responsible sourcing, scoping determination, data collection, data validation and reporting;

 

•

Initiated external review of Microsoft’s conflict minerals program by a third-party audit firm to assess alignment with OECD Guidance and implemented audit recommendations; and

 

•

Enhanced engagement with external organizations, such as Pact, ARM and IRMA that are committed to advancing responsible sourcing on a global basis by developing mining standards and addressing issues such as child labor in the mining industry.

 

VI.	FUTURE ACTIONS

Microsoft is committed to the sourcing of raw materials in ways that fundamentally support human rights, labor, health and safety, environmental protection, and business ethics in our supply chain. We will continue to improve our ability to identify, assess, and mitigate risks associated with our raw materials sourcing. We will continue to implement our Responsible Sourcing of Raw Materials policy that includes a combination of building cross-industry sector capability, supporting electronics industry efforts, implementing region-specific programs such as working toward the use of conflict-free minerals in our devices and working with in-region expert NGOs that are able to implement community programs that are linguistically and culturally effective. Encouraging SORs to participate in the CFSP will improve our knowledge about the 3TGs in our raw material supply chain and we will continue to encourage CFSP participation.

Microsoft is aware of concerns that have been raised regarding the Rule’s possible unintended negative consequences for local communities. Microsoft is committed to complying with the OECD Guidance and the Rule in such a way that mitigates such concerns through implementation of our Responsible Sourcing of Raw Materials program, which is a holistic program that extends beyond the geographic limitations and the scope of the Rule. Consistent with our commitments, we intend to take the following steps to continuously improve our responsible sourcing of raw materials due diligence efforts:

 

•

Continue to refine and improve internal procedures and processes to enhance alignment with the OECD Guidance, including Microsoft’s supplier escalation process and supplier audit procedures;

 

18

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•

Increase Microsoft’s level of engagement with suppliers by holding supplier forums, webinars, and providing resources;

 

•

Continue to refine supplier data by conducting outreach where reported data is incomplete or uncertain;

 

•

Enhance our usage of software tools and technology for improved tracking, evaluating and storing of supplier 3TG due diligence data;

 

•

Strengthen engagement with relevant industry groups and external stakeholders to define and improve best practices and build supplier and SOR capabilities (including encouraging SORs to become CSFP compliant);

 

•

Continue active participation in the CFSI Smelter Engagement Team, which seeks to bring non-compliant SORs into the CFSP; and

 

•

Continue our engagement with organizations like IRMA, ARM, and Pact to establish global responsible sourcing standards and programs in the mineral supply chain

 

19

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APPENDIX A

Conflict Mineral Status of Identified SORs¹

This Appendix lists the 302 SORs which, to the extent known, processed 3TGs that were used to manufacture Microsoft devices during the 2015 reporting year. The SORs are listed by their audit status, 3TG processed, and country location. Appendix A includes several gold SORs which have received the LBMA Responsible Gold Certificate - these are marked with an asterisk.

 

#		SOR Name		Conflict Free         Audit Status		Metal		Country
1		Aida Chemical Industries Co., Ltd.		Compliant		Gold		JAPAN
2		Allgemeine Gold-und Silberscheideanstalt A.G.*		Compliant		Gold		GERMANY
3		AngloGold Ashanti Córrego do Sĺtio Mineração*		Compliant		Gold		BRAZIL
4		Argor-Heraeus S.A.*		Compliant		Gold		SWITZERLAND
5		Asahi Pretec Corp.*		Compliant		Gold		JAPAN
6		Asahi Refining Canada Ltd.*		Compliant		Gold		CANADA
7		Asahi Refining USA Inc.*		Compliant		Gold		UNITED STATES
8		Asaka Riken Co., Ltd.		Compliant		Gold		JAPAN
9		Aurubis AG*		Compliant		Gold		GERMANY
10		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*		Compliant		Gold		PHILIPPINES
11		Boliden AB*		Compliant		Gold		SWEDEN
12		C. Hafner GmbH + Co. KG*		Compliant		Gold		GERMANY
13		CCR Refinery - Glencore Canada Corporation*		Compliant		Gold		CANADA
14		Chimet S.p.A.*		Compliant		Gold		ITALY
15		DODUCO GmbH		Compliant		Gold		GERMANY
16		Dowa		Compliant		Gold		JAPAN
17		Eco-System Recycling Co., Ltd.		Compliant		Gold		JAPAN
18		Elemetal Refining, LLC		Compliant		Gold		UNITED STATES
19		Emirates Gold DMCC*		Compliant		Gold		UNITED ARAB EMIRATES
20		Heimerle + Meule GmbH		Compliant		Gold		GERMANY
21		Heraeus Ltd. Hong Kong*		Compliant		Gold		CHINA
22		Heraeus Precious Metals GmbH & Co. KG*		Compliant		Gold		GERMANY
23		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.*		Compliant		Gold		CHINA
24		Ishifuku Metal Industry Co., Ltd.*		Compliant		Gold		JAPAN
25		Istanbul Gold Refinery*		Compliant		Gold		TURKEY
26		Japan Mint*		Compliant		Gold		JAPAN
27		Jiangxi Copper Co., Ltd.*		Compliant		Gold		CHINA

 

¹ Data as of April 15, 2016.

 

A-1

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
28		JSC Ekaterinburg Non-Ferrous Metal Processing Plant*		Compliant		Gold		RUSSIAN FEDERATION
29		JSC Uralelectromed*		Compliant		Gold		RUSSIAN FEDERATION
30		JX Nippon Mining & Metals Co., Ltd.*		Compliant		Gold		JAPAN
31		Kazzinc*		Compliant		Gold		KAZAKHSTAN
32		Kennecott Utah Copper LLC*		Compliant		Gold		UNITED STATES
33		Kojima Chemicals Co., Ltd.		Compliant		Gold		JAPAN
34		LS-NIKKO Copper Inc.*		Compliant		Gold		KOREA, REPUBLIC OF
35		Materion		Compliant		Gold		UNITED STATES
36		Matsuda Sangyo Co., Ltd.*		Compliant		Gold		JAPAN
37		Metalor Technologies (Hong Kong) Ltd.*		Compliant		Gold		CHINA
38		Metalor Technologies (Singapore) Pte., Ltd.*		Compliant		Gold		SINGAPORE
39		Metalor Technologies S.A.*		Compliant		Gold		SWITZERLAND
40		Metalor USA Refining Corporation*		Compliant		Gold		UNITED STATES
41		Metalúrgica Met-Mex Peñoles S.A. De C.V.*		Compliant		Gold		MEXICO
42		Mitsubishi Materials Corporation*		Compliant		Gold		JAPAN
43		Mitsui Mining and Smelting Co., Ltd.*		Compliant		Gold		JAPAN
44		MMTC-PAMP India Pvt., Ltd.*		Compliant		Gold		INDIA
45		Moscow Special Alloys Processing Plant*		Compliant		Gold		RUSSIAN FEDERATION
46		Nadir Metal Rafineri San. Ve Tic. A.Ş.*		Compliant		Gold		TURKEY
47		Nihon Material Co., Ltd.*		Compliant		Gold		JAPAN
48		Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH		Compliant		Gold		AUSTRIA
49		Ohura Precious Metal Industry Co., Ltd.		Compliant		Gold		JAPAN
50		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)*		Compliant		Gold		RUSSIAN FEDERATION
51		OJSC Novosibirsk Refinery*		Compliant		Gold		RUSSIAN FEDERATION
52		PAMP S.A.*		Compliant		Gold		SWITZERLAND
53		Prioksky Plant of Non-Ferrous Metals*		Compliant		Gold		RUSSIAN FEDERATION
54		PT Aneka Tambang (Persero) Tbk*		Compliant		Gold		INDONESIA
55		PX Précinox S.A.*		Compliant		Gold		SWITZERLAND
56		Rand Refinery (Pty) Ltd.*		Compliant		Gold		SOUTH AFRICA
57		Republic Metals Corporation		Compliant		Gold		UNITED STATES
58		Royal Canadian Mint*		Compliant		Gold		CANADA
59		Schone Edelmetaal B.V.*		Compliant		Gold		NETHERLANDS
60		SEMPSA Joyerĺa Platerĺa S.A.*		Compliant		Gold		SPAIN
61		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*		Compliant		Gold		CHINA
62		Sichuan Tianze Precious Metals Co., Ltd.*		Compliant		Gold		CHINA

 

A-2

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
63		Singway Technology Co., Ltd.		Compliant		Gold		TAIWAN
64		SOE Shyolkovsky Factory of Secondary Precious Metals*		Compliant		Gold		RUSSIAN FEDERATION
65		Solar Applied Materials Technology Corp.*		Compliant		Gold		TAIWAN
66		Sumitomo Metal Mining Co., Ltd.*		Compliant		Gold		JAPAN
67		T.C.A S.p.A*		Compliant		Gold		ITALY
68		Tanaka Kikinzoku Kogyo K.K.*		Compliant		Gold		JAPAN
69		The Refinery of Shandong Gold Mining Co., Ltd.*		Compliant		Gold		CHINA
70		Tokuriki Honten Co., Ltd.*		Compliant		Gold		JAPAN
71		Umicore Brasil Ltda.*		Compliant		Gold		BRAZIL
72		Umicore Precious Metals Thailand		Compliant		Gold		THAILAND
73		Umicore S.A. Business Unit Precious Metals Refining*		Compliant		Gold		BELGIUM
74		United Precious Metal Refining, Inc.		Compliant		Gold		UNITED STATES
75		Valcambi S.A.*		Compliant		Gold		SWITZERLAND
76		Western Australian Mint trading as The Perth Mint*		Compliant		Gold		AUSTRALIA
77		Yamamoto Precious Metal Co., Ltd.		Compliant		Gold		JAPAN
78		Yokohama Metal Co., Ltd.		Compliant		Gold		JAPAN
79		Zhongyuan Gold Smelter of Zhongjin Gold Corporation*		Compliant		Gold		CHINA
80		Zijin Mining Group Co., Ltd. Gold Refinery*		Compliant		Gold		CHINA
81		Advanced Chemical Company		Active		Gold		UNITED STATES
82		Almalyk Mining and Metallurgical Complex (AMMC)*		Active		Gold		UZBEKISTAN
83		Cendres + Métaux S.A.		Active		Gold		SWITZERLAND
84		Daejin Indus Co., Ltd.		Active		Gold		KOREA, REPUBLIC OF
85		DSC (Do Sung Corporation)		Active		Gold		KOREA, REPUBLIC OF
86		Faggi Enrico S.p.A.		Active		Gold		ITALY
87		Geib Refining Corporation		Active		Gold		UNITED STATES
88		KGHM Polska Miedź Spółka Akcyjna		Active		Gold		POLAND
89		Korea Zinc Co., Ltd.		Active		Gold		KOREA, REPUBLIC OF
90		Metalor Technologies (Suzhou) Ltd.		Active		Gold		CHINA
91		Navoi Mining and Metallurgical Combinat*		Active		Gold		UZBEKISTAN
92		Samduck Precious Metals		Active		Gold		KOREA, REPUBLIC OF
93		SAXONIA Edelmetalle GmbH		Active		Gold		GERMANY
94		Torecom		Active		Gold		KOREA, REPUBLIC OF
95		WIELAND Edelmetalle GmbH		Active		Gold		GERMANY
96		Caridad		In Communication		Gold		MEXICO

 

A-3

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
97		Chugai Mining		In Communication		Gold		JAPAN
98		Daye Non-Ferrous Metals Mining Ltd.		In Communication		Gold		CHINA
99		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		In Communication		Gold		CHINA
100		Hunan Chenzhou Mining Co., Ltd.		In Communication		Gold		CHINA
101		Hwasung CJ Co., Ltd.		In Communication		Gold		KOREA, REPUBLIC OF
102		Kazakhmys Smelting LLC		In Communication		Gold		KAZAKHSTAN
103		Korea Metal Co., Ltd.		In Communication		Gold		KOREA, REPUBLIC OF
104		Morris and Watson		In Communication		Gold		NEW ZEALAND
105		Remondis Argentia B.V.		In Communication		Gold		NETHERLANDS
106		SAMWON Metals Corp.		In Communication		Gold		KOREA, REPUBLIC OF
107		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		In Communication		Gold		CHINA
108		Al Etihad Gold Refinery DMCC		Outreach Required		Gold		UNITED ARAB EMIRATES
109		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		Outreach Required		Gold		TURKEY
110		AURA-II		Outreach Required		Gold		UNITED STATES
111		Gansu Seemine Material Hi-Tech Co., Ltd.		Outreach Required		Gold		CHINA
112		Great Wall Precious Metals Co., Ltd. of CBPM*		Outreach Required		Gold		CHINA
113		Guangdong Jinding Gold Limited		Outreach Required		Gold		CHINA
114		Hangzhou Fuchunjiang Smelting Co., Ltd.		Outreach Required		Gold		CHINA
115		Kaloti Precious Metals		Outreach Required		Gold		UNITED ARAB EMIRATES
116		Kyrgyzaltyn JSC*		Outreach Required		Gold		KYRGYZSTAN
117		L’azurde Company For Jewelry		Outreach Required		Gold		SAUDI ARABIA
118		Lingbao Gold Co., Ltd.		Outreach Required		Gold		CHINA
119		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		Outreach Required		Gold		CHINA
120		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		Outreach Required		Gold		CHINA
121		Penglai Penggang Gold Industry Co., Ltd.		Outreach Required		Gold		CHINA
122		Sabin Metal Corp.		Outreach Required		Gold		UNITED STATES

 

A-4

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
123		So Accurate Group, Inc.		Outreach Required		Gold		UNITED STATES
124		Tongling Nonferrous Metals Group Co., Ltd.		Outreach Required		Gold		CHINA
125		Yunnan Copper Industry Co., Ltd.		Outreach Required		Gold		CHINA
126		Changsha South Tantalum Niobium Co., Ltd.		Compliant		Tantalum		CHINA
127		Conghua Tantalum and Niobium Smeltry		Compliant		Tantalum		CHINA
128		D Block Metals, LLC		Compliant		Tantalum		UNITED STATES
129		Duoluoshan		Compliant		Tantalum		CHINA
130		Exotech Inc.		Compliant		Tantalum		UNITED STATES
131		F&X Electro-Materials Ltd.		Compliant		Tantalum		CHINA
132		FIR Metals & Resource Ltd.		Compliant		Tantalum		CHINA
133		Global Advanced Metals Aizu		Compliant		Tantalum		JAPAN
134		Global Advanced Metals Boyertown		Compliant		Tantalum		UNITED STATES
135		Guangdong Zhiyuan New Material Co., Ltd.		Compliant		Tantalum		CHINA
136		H.C. Starck Co., Ltd.		Compliant		Tantalum		THAILAND
137		H.C. Starck GmbH Goslar		Compliant		Tantalum		GERMANY
138		H.C. Starck GmbH Laufenburg		Compliant		Tantalum		GERMANY
139		H.C. Starck Hermsdorf GmbH		Compliant		Tantalum		GERMANY
140		H.C. Starck Inc.		Compliant		Tantalum		UNITED STATES
141		H.C. Starck Ltd.		Compliant		Tantalum		JAPAN
142		H.C. Starck Smelting GmbH & Co. KG		Compliant		Tantalum		GERMANY
143		Hengyang King Xing Lifeng New Materials Co., Ltd.		Compliant		Tantalum		CHINA
144		Hi-Temp Specialty Metals, Inc.		Compliant		Tantalum		UNITED STATES
145		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		Compliant		Tantalum		CHINA
146		JiuJiang JinXin Nonferrous Metals Co., Ltd.		Compliant		Tantalum		CHINA
147		Jiujiang Tanbre Co., Ltd.		Compliant		Tantalum		CHINA
148		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		Compliant		Tantalum		CHINA
149		KEMET Blue Metals		Compliant		Tantalum		MEXICO
150		KEMET Blue Powder		Compliant		Tantalum		UNITED STATES
151		King-Tan Tantalum Industry Ltd.		Compliant		Tantalum		CHINA
152		LSM Brasil S.A.		Compliant		Tantalum		BRAZIL
153		Metallurgical Products India Pvt., Ltd.		Compliant		Tantalum		INDIA
154		Mineração Taboca S.A.		Compliant		Tantalum		BRAZIL
155		Mitsui Mining & Smelting		Compliant		Tantalum		JAPAN
156		Molycorp Silmet A.S.		Compliant		Tantalum		ESTONIA
157		Ningxia Orient Tantalum Industry Co., Ltd.		Compliant		Tantalum		CHINA
158		Plansee SE Liezen		Compliant		Tantalum		AUSTRIA
159		Plansee SE Reutte		Compliant		Tantalum		AUSTRIA
160		QuantumClean		Compliant		Tantalum		UNITED STATES
161		Resind Indústria e Comércio Ltda.		Compliant		Tantalum		BRAZIL
162		RFH Tantalum Smeltry Co., Ltd.		Compliant		Tantalum		CHINA

 

A-5

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
163		Solikamsk Magnesium Works OAO		Compliant		Tantalum		RUSSIAN FEDERATION
164		Taki Chemicals		Compliant		Tantalum		JAPAN
165		Telex Metals		Compliant		Tantalum		UNITED STATES
166		Tranzact, Inc.		Compliant		Tantalum		UNITED STATES
167		Ulba Metallurgical Plant JSC		Compliant		Tantalum		KAZAKHSTAN
168		XinXing HaoRong Electronic Material Co., Ltd.		Compliant		Tantalum		CHINA
169		Yichun Jin Yang Rare Metal Co., Ltd.		Compliant		Tantalum		CHINA
170		Zhuzhou Cemented Carbide		Compliant		Tantalum		CHINA
171		Alpha		Compliant		Tin		UNITED STATES
172		China Tin Group Co., Ltd.		Compliant		Tin		CHINA
173		Cooperativa Metalurgica de Rondônia Ltda.		Compliant		Tin		BRAZIL
174		CV Ayi Jaya		Compliant		Tin		INDONESIA
175		CV Gita Pesona		Compliant		Tin		INDONESIA
176		CV Serumpun Sebalai		Compliant		Tin		INDONESIA
177		CV United Smelting		Compliant		Tin		INDONESIA
178		CV Venus Inti Perkasa		Compliant		Tin		INDONESIA
179		Dowa		Compliant		Tin		JAPAN
180		Elmet S.L.U.		Compliant		Tin		SPAIN
181		EM Vinto		Compliant		Tin		BOLIVIA
182		Fenix Metals		Compliant		Tin		POLAND
183		Gejiu Non-Ferrous Metal Processing Co., Ltd.		Compliant		Tin		CHINA
184		Jiangxi Ketai Advanced Material Co., Ltd.		Compliant		Tin		CHINA
185		Magnu’s Minerais Metais e Ligas Ltda.		Compliant		Tin		BRAZIL
186		Malaysia Smelting Corporation (MSC)		Compliant		Tin		MALAYSIA
187		Melt Metais e Ligas S.A.		Compliant		Tin		BRAZIL
188		Metallic Resources, Inc.		Compliant		Tin		UNITED STATES
189		Metallo-Chimique N.V.		Compliant		Tin		BELGIUM
190		Mineração Taboca S.A.		Compliant		Tin		BRAZIL
191		Minsur		Compliant		Tin		PERU
192		Mitsubishi Materials Corporation		Compliant		Tin		JAPAN
193		O.M. Manufacturing (Thailand) Co., Ltd.		Compliant		Tin		THAILAND
194		O.M. Manufacturing Philippines, Inc.		Compliant		Tin		PHILIPPINES
195		Operaciones Metalurgical S.A.		Compliant		Tin		BOLIVIA
196		PT Aries Kencana Sejahtera		Compliant		Tin		INDONESIA
197		PT Artha Cipta Langgeng		Compliant		Tin		INDONESIA
198		PT ATD Makmur Mandiri Jaya		Compliant		Tin		INDONESIA
199		PT Babel Inti Perkasa		Compliant		Tin		INDONESIA
200		PT Bangka Prima Tin		Compliant		Tin		INDONESIA
201		PT Bangka Tin Industry		Compliant		Tin		INDONESIA
202		PT Belitung Industri Sejahtera		Compliant		Tin		INDONESIA
203		PT BilliTin Makmur Lestari		Compliant		Tin		INDONESIA

 

A-6

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
204		PT Bukit Timah		Compliant		Tin		INDONESIA
205		PT Cipta Persada Mulia		Compliant		Tin		INDONESIA
206		PT DS Jaya Abadi		Compliant		Tin		INDONESIA
207		PT Eunindo Usaha Mandiri		Compliant		Tin		INDONESIA
208		PT Inti Stania Prima		Compliant		Tin		INDONESIA
209		PT Justindo		Compliant		Tin		INDONESIA
210		PT Mitra Stania Prima		Compliant		Tin		INDONESIA
211		PT Panca Mega Persada		Compliant		Tin		INDONESIA
212		PT Prima Timah Utama		Compliant		Tin		INDONESIA
213		PT Refined Bangka Tin		Compliant		Tin		INDONESIA
214		PT Sariwiguna Binasentosa		Compliant		Tin		INDONESIA
215		PT Stanindo Inti Perkasa		Compliant		Tin		INDONESIA
216		PT Sukses Inti Makmur		Compliant		Tin		INDONESIA
217		PT Sumber Jaya Indah		Compliant		Tin		INDONESIA
218		PT Timah (Persero) Tbk Kundur		Compliant		Tin		INDONESIA
219		PT Timah (Persero) Tbk Mentok		Compliant		Tin		INDONESIA
220		PT Tinindo Inter Nusa		Compliant		Tin		INDONESIA
221		PT Tommy Utama		Compliant		Tin		INDONESIA
222		PT Wahana Perkit Jaya		Compliant		Tin		INDONESIA
223		Resind Indústria e Comércio Ltda.		Compliant		Tin		BRAZIL
224		Rui Da Hung		Compliant		Tin		TAIWAN
225		Soft Metais Ltda.		Compliant		Tin		BRAZIL
226		Thaisarco		Compliant		Tin		THAILAND
227		VQB Mineral and Trading Group JSC		Compliant		Tin		VIETNAM
228		White Solder Metalurgia e Mineração Ltda.		Compliant		Tin		BRAZIL
229		Yunnan Tin Company Limited		Compliant		Tin		CHINA
230		An Thai Minerals Co., Ltd.		Active		Tin		VIETNAM
231		An Vinh Joint Stock Mineral Processing Company		Active		Tin		VIETNAM
232		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		Active		Tin		CHINA
233		CV Dua Sekawan		Active		Tin		INDONESIA
234		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		Active		Tin		VIETNAM
235		Feinhütte Halsbrücke GmbH		Active		Tin		GERMANY
236		Gejiu Fengming Metallurgy Chemical Plant		Active		Tin		CHINA
237		Gejiu Jinye Mineral Company		Active		Tin		CHINA
238		Gejiu Kai Meng Industry and Trade LLC		Active		Tin		CHINA
239		Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.		Active		Tin		CHINA
240		Nghe Tinh Non-Ferrous Metals Joint Stock Company		Active		Tin		VIETNAM
241		Phoenix Metal Ltd.		Active		Tin		RWANDA
242		PT Karimun Mining		Active		Tin		INDONESIA

 

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
243		Tuyen Quang Non-Ferrous Metals Joint Stock Company		Active		Tin		VIETNAM
244		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		Active		Tin		CHINA
245		Estanho de Rondônia S.A.		In Communication		Tin		BRAZIL
246		Gejiu Zili Mining And Metallurgy Co., Ltd.		In Communication		Tin		CHINA
247		Linwu Xianggui Ore Smelting Co., Ltd.		In Communication		Tin		CHINA
248		CNMC (Guangxi) PGMA Co., Ltd.		Outreach Required		Tin		CHINA
249		Huichang Jinshunda Tin Co., Ltd.		Outreach Required		Tin		CHINA
250		Nankang Nanshan Tin Manufactory Co., Ltd.		Outreach Required		Tin		CHINA
251		PT Alam Lestari Kencana		Outreach Required		Tin		INDONESIA
252		PT Bangka Kudai Tin		Outreach Required		Tin		INDONESIA
253		PT Bangka Timah Utama Sejahtera		Outreach Required		Tin		INDONESIA
254		PT Fang Di MulTindo		Outreach Required		Tin		INDONESIA
255		PT Pelat Timah Nusantara Tbk		Outreach Required		Tin		INDONESIA
256		PT Seirama Tin Investment		Outreach Required		Tin		INDONESIA
257		PT Tirus Putra Mandiri		Outreach Required		Tin		INDONESIA
258		A.L.M.T. TUNGSTEN Corp.		Compliant		Tungsten		JAPAN
259		Asia Tungsten Products Vietnam Ltd.		Compliant		Tungsten		VIETNAM
260		Chenzhou Diamond Tungsten Products Co., Ltd.		Compliant		Tungsten		CHINA
261		Chongyi Zhangyuan Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
262		Fujian Jinxin Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
263		Ganzhou Huaxing Tungsten Products Co., Ltd.		Compliant		Tungsten		CHINA
264		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		Compliant		Tungsten		CHINA
265		Ganzhou Seadragon W & Mo Co., Ltd.		Compliant		Tungsten		CHINA
266		Ganzhou Yatai Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
267		Global Tungsten & Powders Corp.		Compliant		Tungsten		UNITED STATES
268		Guangdong Xianglu Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
269		H.C. Starck GmbH		Compliant		Tungsten		GERMANY
270		H.C. Starck Smelting GmbH & Co.KG		Compliant		Tungsten		GERMANY
271		Hunan Chenzhou Mining Co., Ltd.		Compliant		Tungsten		CHINA
272		Hunan Chunchang Nonferrous Metals Co., Ltd.		Compliant		Tungsten		CHINA
273		Hydrometallurg, JSC		Compliant		Tungsten		RUSSIAN FEDERATION
274		Japan New Metals Co., Ltd.		Compliant		Tungsten		JAPAN
275		Jiangxi Gan Bei Tungsten Co., Ltd.		Compliant		Tungsten		CHINA

 

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#		SOR Name		Conflict Free         Audit Status		Metal		Country
276		Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.		Compliant		Tungsten		CHINA
277		Kennametal Huntsville		Compliant		Tungsten		UNITED STATES
278		Malipo Haiyu Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
279		Niagara Refining LLC		Compliant		Tungsten		UNITED STATES
280		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		Compliant		Tungsten		VIETNAM
281		Tejing (Vietnam) Tungsten Co., Ltd.		Compliant		Tungsten		VIETNAM
282		Vietnam Youngsun Tungsten Industry Co., Ltd.		Compliant		Tungsten		VIETNAM
283		Wolfram Bergbau und Hütten AG		Compliant		Tungsten		AUSTRIA
284		Xiamen Tungsten (H.C.) Co., Ltd.		Compliant		Tungsten		CHINA
285		Xiamen Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
286		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		Compliant		Tungsten		CHINA
287		ACL Metais Eireli		Active		Tungsten		BRAZIL
288		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		Active		Tungsten		CHINA
289		Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin		Active		Tungsten		CHINA
290		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		Active		Tungsten		CHINA
291		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		Active		Tungsten		CHINA
292		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		Active		Tungsten		CHINA
293		Jiangxi Yaosheng Tungsten Co., Ltd.		Active		Tungsten		CHINA
294		Kennametal Fallon		Active		Tungsten		UNITED STATES
295		Sanher Tungsten Vietnam Co., Ltd.		Active		Tungsten		VIETNAM
296		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		Active		Tungsten		CHINA
297		Ganxian Shirui New Material Co., Ltd.		In Communication		Tungsten		CHINA
298		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		In Communication		Tungsten		CHINA
299		Dayu Jincheng Tungsten Industry Co., Ltd.		TI-CMC Member Company		Tungsten		CHINA
300		Dayu Weiliang Tungsten Co., Ltd.		TI-CMC Member Company		Tungsten		CHINA
301		Ganzhou Non-ferrous Metals Smelting Co., Ltd.		TI-CMC Member Company		Tungsten		CHINA
302		Pobedit, JSC		TI-CMC Member Company		Tungsten		RUSSIAN FEDERATION

 

A-9

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