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May 31, 2016 5:11 PM EDT



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

FORM SD
Specialized Disclosure Report

Alphabet Inc.
(Exact name of registrant as specified in its charter)

Delaware
001-37580
61-1767919
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(IRS Employer Identification No.)
1600 Amphitheatre Parkway, Mountain View, CA
94043
(Address of principal executive offices)
(Zip code)
Kenneth H. Yi (650) 253-0000
(Name and telephone number, including area code, of the person to contact in connection with this report)

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

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





Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

A copy of Alphabet Inc.'s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available online at
https://abc.xyz/conflictminerals.

Section 2 - Exhibits

Item 2.01 Exhibits

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




SIGNATURES

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

ALPHABET INC.

By:    /s/ RUTH PORAT                                Date:    May 31, 2016
Ruth Porat
Senior Vice President and Chief Financial Officer



Exhibit 1.01

Alphabet Inc.
Conflict Minerals Report
For The Year Ended December 31, 2015
                    
This Conflict Minerals Report for the year ended December 31, 2015 (this “CMR”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”), which requires certain reporting and disclosure related to conflict minerals. Conflict minerals are currently defined as cassiterite, columbite-tantalite, wolframite, gold, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”)1 for the purpose of this assessment. These requirements apply to registrants whatever the geographic origin of their conflict minerals and whether or not their conflict minerals fund armed conflict. Please refer to the Rule, Form SD, and SEC Release No. 34-67716 for definitions to the terms used in this CMR, unless otherwise defined herein.
                    
Statements in this CMR are based on our due diligence activities performed in good faith through April 30, 2016 for the calendar year 2015 and are based on information available at the time of this filing, unless otherwise indicated. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter and refiner (collectively referred to as “smelters”) data, errors or omissions by suppliers or smelters, ongoing certifications of smelters, continued guidance or amendments to the Rule, and other issues. Additionally, this CMR may contain forward-looking statements that reflect what we strive to achieve in the future as we continue to improve our responsible sourcing program. These forward-looking statements are based on current expectations and assumptions that are subject to risks and uncertainties.
                    
References to our website do not incorporate information from the website into this CMR.
                    
Throughout this CMR, we use “Alphabet,” “we,” “our,” “us” and similar terms to refer to Alphabet Inc. and its subsidiaries (collectively, “Alphabet”), unless otherwise indicated, and use “Google” to refer to Google Inc., a wholly owned subsidiary of Alphabet.    









                
__________________________
1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.

1

1. Overview
                    
(A) Company
                    
On October 2, 2015, we implemented a holding company reorganization in which Alphabet became the successor issuer to Google. Alphabet is a collection of businesses, the largest of which is Google and its internet-related businesses and hardware products. It also includes businesses that for financial reporting purposes we combine as Other Bets that are pretty far afield of our main Internet products, such as Verily, Calico, X, Nest, GV, Google Capital and Access/Google Fiber. The objective of our Alphabet structure is about helping businesses within Alphabet prosper through strong leaders and independence.

Our Google segment represented approximately 99% of our consolidated revenues in 2015. It generates revenues primarily by delivering online advertising that consumers find relevant and that advertisers find cost-effective. Our Other Bets businesses are also making important strides in their industries, and our goal is for them to become thriving, successful businesses in the long term. This CMR covers all products as described below from Google and Other Bets.
                    
(B) In-Scope Products
                    
While we generate revenues primarily from advertising, we also generate revenues from the sale of hardware and other devices. The hardware and other devices that were considered in scope for this CMR pertain primarily to Chrome and Android-related devices and Nest branded hardware products. These product lines include a variety of consumer-facing devices such as phones, tablets, laptops, thermostats, smoke alarms, video cameras and other electronics.
                    
(C) Supply Chain
                    
Our supply chain consists of a diverse range of suppliers and several manufacturing models. The products described above were manufactured by other companies through models that range from licensing software with minimum hardware specifications to us contracting directly with contract manufacturers. Whether we are working with an Original Equipment Manufacturer or working more closely with the product’s design, we are several tiers away from the smelter and country of origin of the 3TG used in our products. We do not directly purchase raw materials. In addition, many of the suppliers we work with are not directly subject to the Rule and its corresponding regulations.
                    
1.1 Conflict Minerals Policy
                    
We believe it is essential to establish validated conflict-free sources of 3TG within the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) so that these minerals can be procured in a way that contributes to economic growth and development in the regions. To aid in this effort, we have established a conflict minerals policy and an internal team to implement the policy. Our conflict minerals policy is accessible on our website at https://abc.xyz/conflictminerals.

2


We expect our suppliers to source 3TG from compliant conflict-free smelters (such as those audited through the Conflict-Free Sourcing Initiative’s (the “CFSI”) Conflict-Free Smelter Program (the “CFSP”) (www.conflictfreesourcing.org)), perform due diligence on the source and chain of custody of the 3TG used in our products, and provide their due diligence measures to us upon request.
                    
2. Reasonable Country of Origin Inquiry
                    
To identify which of our suppliers to survey regarding the source of the 3TG used in our products, we inventoried our products to determine which were in scope of the Rule. Products were considered in scope if they were manufactured by us or contracted for manufacture by us between January 1, 2015 and December 31, 2015, and if they were intended to enter the stream of commerce.2 For products in scope, we identified and compiled a list of our suppliers from whom we requested information regarding their sourcing of 3TG (our “in-scope suppliers”).
                    
We requested that such identified in-scope suppliers provide us with information regarding their supply chain using the Conflict Minerals Reporting Template (“CMRT”) from the CFSI, which included questions about location or mine of origin of the 3TG in the products, and obligated those in-scope suppliers to make similar efforts to survey their supply chains using the CMRT, and report the smelters and location or mine of origin of necessary 3TG. We reviewed and monitored responses from our in-scope suppliers and followed up with any questions, as appropriate, to further qualify their responses. If an in-scope supplier did not respond, we made multiple attempts to contact the in-scope supplier.
                    
Although we received a high response rate from our in-scope suppliers, certain in-scope suppliers identified some smelters in their supply chains that we were unable to independently verify as businesses with valid smelting operations. Our in-scope suppliers provided data to us at either the supplier level or the product level but, in many cases, in-scope supplier responses did not relate specifically or solely to the products supplied to us. Additionally, some of our in-scope suppliers indicated that they are still in the process of gathering information from their suppliers. We continue to work with our in-scope suppliers to ensure that all of their suppliers are represented.                            

In-scope supplier responses indicated that some of the smelters used by certain in-scope suppliers at various levels of our supply chain obtain 3TG from the Covered Countries. In-scope supplier responses also indicated sourcing 3TG from outside of the Covered Countries, from recycled or scrap sources, and from unknown origins. Based on the results of our supply chain survey and due to the nature of our supply chain as described in Section 1(C) above, we were unable to verify with certainty the source and chain of custody of all of the 3TG used in our products. Due to the



__________________________
2 Products manufactured or contracted for manufacture by Lift Labs, a company acquired by Google in September 2014, were considered out of scope in accordance with Instruction 3 to Form SD.

3

fact that 15% of the smelters, all of which are compliant, disclosed by our in-scope suppliers have been reported by the CFSI to source from the Covered Countries, we proceeded by conducting due diligence as described in Section 3 below.

3. Due Diligence
                    
Our due diligence measures were designed in accordance with the framework set forth in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, 2013 (“OECD Guidance”), and the related Supplements for 3TG.
                    
Below is a description of our due diligence activities performed for the 2015 reporting year as they relate to the five-step framework set forth in the OECD Guidance.
                    
OECD Step 1 - Establish strong company management systems
                    
•
Our conflict minerals policy described in Section 1.1 is publicly available on our website.
•
We have an internal team, which includes representatives from supply chain, legal, and finance organizations, that is responsible for our conflict minerals program.
•
Our governance structure includes executives from our in-scope supply chains, legal and finance organizations who are responsible for reviewing due diligence activities.
•
We include responsible sourcing and due diligence requirements in Google’s Supplier Code of Conduct and in our supplier contract templates.
•
We have a grievance mechanism for reporting violations of our policies.
•
We communicated with our in-scope suppliers to use the CMRT and other publicly available tools on the CFSI website.
•
We implemented a system that includes an online platform for storing and managing our conflict minerals due diligence procedures and results.
•
We have a document retention policy for maintaining conflict minerals program documentation for a minimum of five years.
                            
OECD Step 2 - Identify and assess risk in the supply chain
                    
•
We requested that our in-scope suppliers provide a CMRT in order to collect information about the smelters of 3TG used in our products.
•
We assessed the CMRTs received from our in-scope suppliers for completeness and reasonableness based on internally defined review criteria.
•
We validated whether each smelter disclosed by our in-scope suppliers was a verified or active smelter by checking against the smelter data provided by the CFSI, which also indicates if each smelter is designated as compliant or active by the CFSI.
•
We have also integrated conflict minerals criteria into our Sustainable Supply Chain audit program.
                            


4

OECD Step 3 - Design and implement a strategy to respond to identified risks
                            
•
We inform our audit committee and sustainable supply chain team yearly on our due diligence activities and Conflict Minerals Report.
•
We have begun adding conflict-free criteria to our supplier selection process through the integration of conflict-free requirements in our contracts, Supplier Code of Conduct, and in RFPs.
•
We have begun to contact verified smelters that are not yet compliant to emphasize the importance of being certified by the CFSI as conflict-free.
•
We continue to support the CFSI’s programs such as the CFSP and the Initial Audit Fund.
•
We joined the Public-Private Alliance for Responsible Minerals Trade.
                            
OECD Step 4 - Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain

•
Google joined the CFSI in 2013 (member ID: GOOG) and continues to be a member.
•
We rely upon the CFSI to validate that companies meet the criteria of smelter and then certify them as conflict-free.
                            
OECD Step 5 - Report on supply chain due diligence

•
We publish a CMR annually, and our reports are accessible on our website at https://abc.xyz/conflictminerals.
                    
4. Due Diligence Results
                    
Smelter Disclosure
                    
Based on our due diligence, we have reason to believe that a portion of the 3TG used in our products originated from the Covered Countries, but we have not identified any instances of sourcing that directly or indirectly supported conflict in the Covered Countries. Our conclusion is based on information provided by in-scope suppliers for the 2015 reporting period. In some instances, information provided by our in-scope suppliers was unverifiable or incomplete and, as such, we were unable to verify with certainty the source and chain of custody of all of the necessary 3TG in our products. Based on our due diligence, we have identified 287 total smelters, of which 75% are considered to be conflict free based on the CFSP website. This represents an improvement from 57% in 2014. Additionally, we have identified 32 active smelters bringing the total number of compliant and active smelters to 246 or 86% of our total smelters.
                    



5

The results of our due diligence on the 3TG used in our in-scope products are noted below:
Smelters*
Tin
Tungsten
Tantalum
Gold
Total
Number of smelters
78
41
45
123
287
Number (%) of smelters listed as “compliant” by the CFSI
59 (76%)
30 (73%)
45 (100%)
80 (65%)
214 (75%)
Number (%) of smelters listed as “active” by CFSI
12 (15%)
5 (12%)
0 (0%)
15 (12%)
32 (11%)
    
* The table represents those smelters disclosed by our suppliers that are listed on the CFSI’s Standard Smelter List as having valid smelting or refining operations, and those which are listed as compliant or active based on information available on the CFSI's website (www.conflictfreesourcing.org) as of March 31, 2016. Smelters and refiners on the Active list have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs and have submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts. Please refer to Appendix I for a combined list of smelters as disclosed in this table.    
                
Efforts to Determine Mine or Location of Origin
                    
As part of our due diligence process described in Section 3 above, we have worked to ensure that our efforts to identify mines and the country of origin of the 3TG in our products has been reasonable and aligned to industry practices through our support of processes and tools developed by the CFSI. Appendix I includes the country of origin data provided to the CFSI for compliant smelters only.
                    
5. Continuous Improvement in Understanding Source of Material
                    
We recognize that efforts to reduce violence associated with conflict minerals are ongoing and require continually adapting to changing situations. We will continue to improve our compliance processes including, but not limited to, taking the following steps:
                    
•
In the 2016 reporting year, we will continue to engage with in-scope suppliers to gain better visibility of the country of origin and chain of custody of the 3TG used in our products.
•
We will continue to use and encourage our in-scope suppliers to use publicly available tools from the CFSI and will continue to work with our in-scope suppliers and engage with our supply chain to increase the quality of the data provided to us.
•
We will continue to be a member of the CFSI and the Initial Audit Fund, which includes membership dues, support of initial audits and the transfer of our membership from Google to Alphabet.
•
We will continue to encourage our in-scope suppliers to source from conflict-free smelters that are listed as compliant by the CFSI.
•
As we enter into contracts with new suppliers and renew contracts with existing suppliers, we will include requirements that our suppliers support our conflict minerals policy and due diligence efforts.                                 
    
                

6

APPENDIX I Smelter List and Country of Origin List

Metal
Smelter Name (* indicates CFSI Compliant Conflict-Free Smelter, ** indicates CFSI Active Smelter)
Gold
Advanced Chemical Company**
Gold
Aida Chemical Industries Co. Ltd.*
Gold
Al Etihad Gold Refinery DMCC
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold
Almalyk Mining and Metallurgical Complex (AMMC)**
Gold
AngloGold Ashanti Córrego do Sítio Minerção*
Gold
Argor-Heraeus SA*
Gold
Asahi Pretec Corp*
Gold
Asaka Riken Co Ltd*
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold
Aurubis AG*
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Gold
Boliden AB*
Gold
C. Hafner GmbH + Co. KG*
Gold
Caridad
Gold
CCR Refinery – Glencore Canada Corporation*
Gold
Cendres + Métaux SA**
Gold
Chimet S.p.A.*
Gold
Chugai Mining
Gold
Daejin Indus Co., Ltd.**
Gold
Daye Non-Ferrous Metals Mining Ltd.
Gold
Do Sung Corporation**
Gold
Doduco*
Gold
Dowa*
Gold
Eco-System Recycling Co., Ltd.*
Gold
Emirates Gold DMCC*
Gold
Faggi Enrico S.p.A.**
Gold
Fidelity Printers and Refiners Ltd.
Gold
FSE Novosibirsk Refinery*
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
Gold
Geib Refining Corporation**
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
Gold
Guangdong Jinding Gold Limited
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold
Heimerle + Meule GmbH*
Gold
Heraeus Ltd. Hong Kong*
Gold
Heraeus Precious Metals GmbH & Co. KG*
Gold
Hunan Chenzhou Mining Group Co., Ltd.
Gold
Hwasung CJ Co., Ltd.
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited*
Gold
Ishifuku Metal Industry Co., Ltd.*
Gold
Istanbul Gold Refinery*

7

Gold
Japan Mint*
Gold
Jiangxi Copper Company Limited*
Gold
Johnson Matthey Inc*
Gold
Johnson Matthey Ltd*
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold
JSC Uralectromed*
Gold
JX Nippon Mining & Metals Co., Ltd*
Gold
Kaloti Precious Metals
Gold
Kazakhmys Smelting LLC
Gold
Kazzinc Ltd*
Gold
Kennecott Utah Copper LLC*
Gold
KGHM Polska Miedź Spółka Akcyjna**
Gold
Kojima Chemicals Co., Ltd*
Gold
Korea Zinc Co. Ltd.**
Gold
Kyrgyzaltyn JSC
Gold
L' azurde Company For Jewelry
Gold
Lingbao Gold Company Limited
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold
LS-NIKKO Copper Inc.*
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold
Materion*
Gold
Matsuda Sangyo Co., Ltd.*
Gold
Met-Mex Peñoles, S.A.*
Gold
Metalor Technologies (Hong Kong) Ltd*
Gold
Metalor Technologies (Singapore) Pte. Ltd.*
Gold
Metalor Technologies (Suzhou) Ltd.**
Gold
Metalor Technologies SA*
Gold
Metalor USA Refining Corporation*
Gold
Mitsubishi Materials Corporation*
Gold
Mitsui Mining and Smelting Co., Ltd.*
Gold
MMTC-PAMP India Pvt., Ltd.*
Gold
Morris and Watson
Gold
Moscow Special Alloys Processing Plant*
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.*
Gold
Navoi Mining and Metallurgical Combinat**
Gold
Nihon Material Co. LTD*
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH*
Gold
Ohio Precious Metals, LLC*
Gold
Ohura Precious Metal Industry Co., Ltd*
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)*
Gold
PAMP SA*
Gold
Penglai Penggang Gold Industry Co., Ltd.
Gold
Prioksky Plant of Non-Ferrous Metals*
Gold
PT Aneka Tambang (Persero) Tbk*
Gold
PX Précinox SA*
Gold
Rand Refinery (Pty) Ltd*
Gold
Republic Metals Corporation*

8

Gold
Royal Canadian Mint*
Gold
Sabin Metal Corp.
Gold
Samduck Precious Metals**
Gold
SAMWON METALS Corp.
Gold
SAXONIA Edelmetalle GmbH**
Gold
Schone Edelmetaal*
Gold
SEMPSA Joyería Platería SA*
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd*
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
Gold
Singway Technology Co., Ltd.*
Gold
So Accurate Group, Inc.
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
Gold
Solar Applied Materials Technology Corp.*
Gold
Sumitomo Metal Mining Co., Ltd.*
Gold
T.C.A S.p.A*
Gold
Tanaka Kikinzoku Kogyo K.K.*
Gold
The Refinery of Shandong Gold Mining Co. Ltd*
Gold
Tokuriki Honten Co. Ltd*
Gold
Tongling nonferrous Metals Group Co.,Ltd
Gold
Torecom**
Gold
Umicore Brasil Ltda*
Gold
Umicore Precious Metals Thailand*
Gold
Umicore SA Business Unit Precious Metals Refining*
Gold
United Precious Metal Refining, Inc.*
Gold
Valcambi SA*
Gold
Western Australian Mint trading as The Perth Mint*
Gold
WIELAND Edelmetalle GmbH**
Gold
YAMAMOTO PRECIOUS METAL CO., LTD.*
Gold
Yokohama Metal Co Ltd*
Gold
Yunnan Copper Industry Co Ltd
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*
Gold
Zijin Mining Group Co. Ltd*
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
Tantalum
Conghua Tantalum and Niobium Smeltry*
Tantalum
D Block Metals, LLC*
Tantalum
Duoluoshan*
Tantalum
Exotech Inc.*
Tantalum
F&X Electro-Materials Ltd.*
Tantalum
FIR Metals & Resource Ltd.*
Tantalum
Global Advanced Metals Boyertown*
Tantalum
Global Advanced Metals*
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
Tantalum
H.C. Starck Co., Ltd.*
Tantalum
H.C. Starck GmbH Goslar*
Tantalum
H.C. Starck GmbH Laufenburg*
Tantalum
H.C. Starck Hermsdorf GmbH*

9

Tantalum
H.C. Starck Inc.*
Tantalum
H.C. Starck Ltd.*
Tantalum
H.C. Starck Smelting GmbH & Co.KG*
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
Tantalum
Hi-Temp*
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum
Jiujiang Tanbre Co., Ltd.*
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Tantalum
KEMET Blue Metals*
Tantalum
Kemet Blue Powder*
Tantalum
King-Tan Tantalum Industry Ltd*
Tantalum
LSM Brasil S.A.*
Tantalum
Metallurgical Products India (Pvt.) Ltd.*
Tantalum
Mineração Taboca S.A.*
Tantalum
Mitsui Mining & Smelting*
Tantalum
Molycorp Silmet A.S.*
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum
Plansee SE Liezen*
Tantalum
Plansee SE Reutte*
Tantalum
QuantumClean*
Tantalum
Resind Indústria e Comércio Ltda.*
Tantalum
RFH Tantalum Smeltry Co., Ltd*
Tantalum
Solikamsk Metal Works*
Tantalum
Taki Chemicals*
Tantalum
Telex*
Tantalum
Tranzact, Inc.*
Tantalum
Ulba*
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.*
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.*
Tantalum
Zhuzhou Cement Carbide*
Tin
Alpha*
Tin
An Vinh Joint Stock Mineral Processing Company**
Tin
Chenzhou Yunxiang Mining Smelting Company LTD**
Tin
China Tin Group Co., Ltd.*
Tin
CNMC (Guangxi) PGMA Co. Ltd.
Tin
Cooper Santa*
Tin
CV Ayi Jaya*
Tin
CV Gita Pesona*
Tin
CV JusTindo*
Tin
CV Nurjanah*
Tin
CV Serumpun Sebalai*
Tin
CV United Smelting*
Tin
CV Venus Inti Perkasa*
Tin
Dowa*
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company**
Tin
Elmet S.L.U. (Metallo Group)*

10

Tin
EM Vinto*
Tin
Estanho de Rondônia S.A.
Tin
Fenix Metals*
Tin
Gejiu Jin Ye Mineral Co., Ltd.**
Tin
Gejiu Kai Meng Industry and Trade LLC**
Tin
Gejiu Non-Ferrous Metal Processing Co. Ltd.*
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.**
Tin
Gejiu Zi-Li
Tin
Huichang Jinshunda Tin Co. Ltd
Tin
Jiangxi Ketai Advanced Material Co., Ltd.*
Tin
Jiangxi Nanshan
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
Tin
Magnu's Minerais Metais e Ligas LTDA*
Tin
Malaysia Smelting Corporation (MSC)*
Tin
Melt Metais e Ligas S/A*
Tin
Metallic Resources Inc*
Tin
METALLO-CHIMIQUE N.V. (MC)*
Tin
Mineração Taboca S.A.*
Tin
Minsur*
Tin
Mitsubishi Materials Corporation*
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company**
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
Tin
O.M. Manufacturing Philippines, Inc.*
Tin
Operaciones Metalurgical S.A.*
Tin
Phoenix Metal Ltd.**
Tin
PT Artha Cipta Langgeng*
Tin
PT ATD Makmur Mandiri Jaya*
Tin
PT Babel Inti Perkasa*
Tin
PT Bangka Prima Tin*
Tin
PT Bangka Tin Industry*
Tin
PT Belitung Industri Sejahtera*
Tin
PT BilliTin Makmur Lestari*
Tin
PT Bukit Timah*
Tin
PT Cipta Persada Mulia*
Tin
PT DS Jaya Abadi*
Tin
PT DS Jaya Abadi**
Tin
PT Eunindo Usaha Mandiri*
Tin
PT Inti Stania Prima*
Tin
PT Karimun Mining**
Tin
PT Mitra Stania Prima*
Tin
PT Panca Mega Persada*
Tin
PT Prima Timah Utama*
Tin
PT REFINED BANGKA TIN*
Tin
PT Sariwiguna Binasentosa*
Tin
PT Stanindo Inti Perkasa*
Tin
PT Sukses Inti Makmur*
Tin
PT Sumber Jaya Indah*

11

Tin
PT Tambang Timah*
Tin
PT Timah (Persero) Tbk Mentok*
Tin
PT Tinindo Inter Nusa*
Tin
PT Tirus Putra Mandiri
Tin
PT Tommy Utama*
Tin
PT Wahana Perkit Jaya*
Tin
Resind Indústria e Comércio Ltda.*
Tin
Rui Da Hung*
Tin
Soft Metais, Ltda.*
Tin
Thaisarco*
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company**
Tin
VQB Mineral and Trading Group JSC*
Tin
White Solder Metalurgia e Mineração Ltda.*
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.**
Tin
Yunnan Tin Company, Ltd.*
Tungsten
A.L.M.T. Corp.*
Tungsten
Asia Tungsten Products Vietnam Ltd.*
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
Tungsten
Chongyi Zhangyuan Tungsten Co Ltd*
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
Tungsten
Ganxian Shirui New Material Co., Ltd.
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.**
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.*
Tungsten
Global Tungsten & Powders Corp.*
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
Tungsten
H.C. Starck GmbH*
Tungsten
H.C. Starck Smelting GmbH & Co.KG*
Tungsten
Hunan Chenzhou Mining Group Co., Ltd.*
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten
Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd.*
Tungsten
Hydrometallurg, JSC*
Tungsten
Japan New Metals Co Ltd*
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.**
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.**
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.*
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.**
Tungsten
Kennametal Fallon**
Tungsten
Kennametal Huntsville*
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*

12

Tungsten
Niagara Refining LLC*
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd*
Tungsten
Wolfram Bergbau und Hütten AG*
Tungsten
Wolfram Company CJSC
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
Tungsten
Xiamen Tungsten Co., Ltd*
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*


Country of Origin List3 

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




            
__________________________
3 The CFSI generally does not specify individual countries of origin of the conflict minerals processed by compliant smelters and refiners and thus we were not able to determine with certainty the specific countries of origin of the conflict minerals processed by the listed compliant smelters and refiners. In addition, for some of the listed compliant smelters and refiners, origin information is not disclosed. The list is based on the country of origin data provided to the CFSI for compliant smelters only.

13

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