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
(State or Other Jurisdiction
of Incorporation)
| 001-37845 | 91-1144442 | |
| (Commission File Number) |
(IRS Employer Identification No.) |
| One Microsoft Way, Redmond, Washington | 98052-6399 | |
| (Address of Principal Executive Offices) | (Zip Code) |
(425) 882-8080
(Registrant’s Telephone Number, Including Area Code)
(Former Name or Former Address, if Changed Since Last Report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the period from January 1 to December 31, 2016. |
Section 1 - Conflict Minerals Disclosure
Items 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Microsoft’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at https://www.microsoft.com/en-us/about/corporate-responsibility/responsible-sourcing under the “Raw materials” tab.
Item 1.02 Exhibits
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
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| MICROSOFT CORPORATION | ||
| (Registrant) | ||
| Date: May 31, 2017 |
/s/ BRADFORD L. SMITH | |
| Bradford L. Smith | ||
| President and Chief Legal Officer | ||
INDEX TO EXHIBITS
| Exhibit |
Description | |
| 1.01 | Conflict Minerals Report | |
Exhibit 1.01
MICROSOFT CORPORATION
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2016
| I. | INTRODUCTION |
This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION is filed as an exhibit to Microsoft’s Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the 2016 reporting year. The report covers 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, licenses, and supports a wide range of software products, services, and hardware devices (“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 Microsoft’s Responsible Sourcing of Raw Materials (“RSRM”) policy. Under our policy, Microsoft takes a holistic approach to the responsible sourcing of raw materials while working toward the use of conflict-free minerals in our 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” under the Rule.
This year’s CMR demonstrates continued improvement and meaningful progress for the 2016 reporting year. The number of Conflict-Free Smelter Program1 (“CFSP”) compliant smelters or refiners (the “SORs”) in our supply chain increased from 213 to 249 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% of tantalum smelters identified in Microsoft’s supply chain were CFSP compliant. Our 2016 supplier response rate continued to improve and reached 99% during this reporting period (See Figure 1, p. 8).
Since our last CMR filing, we have also acted to improve our conflict minerals due diligence, including the following:
| 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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| • | Completed implementation of third-party audit firm recommendations covering 2015 reporting year assessment; |
| • | Implemented process improvements to increase supplier response rate, including leveraging sourcing manager’s ownership of the supplier response rate, supplier resource support, and tailored outreach to both new suppliers and previously unresponsive suppliers; |
| • | Completed integration of RSRM policy into Microsoft’s Social and Environmental Accountability (“SEA”) audit process to ensure RSRM policy is embedded in suppliers’ business processes, particularly in sourcing and quality management systems; |
| • | Refined internal controls and procedures to improve in-scope supplier determination, data collection and validation, and supply chain due diligence such as early engagement with suppliers during on-boarding through Microsoft’s SEA online Audit Management System; and |
| • | Expanded our supplier engagement by continuously collecting supplier data throughout the year and training suppliers on our RSRM policy to proactively identify and mitigate potential sourcing risk from an unvalidated SOR with minerals from a Conflict-Affected and High-Risk Area (“CAHRA”). |
Microsoft devices contain one or more 3TGs and are within the Rule’s scope. Devices manufactured during the 2016 reporting year included:
| • | Surface line of computers and accessories; |
| • | Xbox gaming/entertainment consoles and accessories; and |
| • | Personal computing accessories (mice, headsets and keyboards). |
On the basis of our “Reasonable Country of Origin Inquiry” (“RCOI”) (see Section II), we cannot exclude the possibility that 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 during the 2016 reporting year, as an exhibit to our Form SD. We have published the CMR externally on our corporate website: see Responsible Sourcing under the “Raw materials” tab.
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 2016 reporting year may have been smelted and refined prior to January 31, 2013 and 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 2016 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 and is currently the only internationally recognized framework for raw material due diligence.
Microsoft does not source directly from 3TG raw material providers. We source products from suppliers, which source materials, components, and products from their sub-tier suppliers. Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and 3TG SORs. We refer collectively in this CMR to Microsoft owned manufacturing facilities, directly contracted manufacturing partners, and our strategic component suppliers as “in-scope suppliers.” Due to our extended supply chain, we leverage our in-scope suppliers to provide information on the sources and chains of custody of 3TGs necessary to the manufacture 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 RSRM 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. This commitment extends to the harvesting, extraction, and transportation of raw materials globally and to all substances used in our devices - unbounded by specific materials or locations. Our policy supports our implementation of programs that are region-specific and work 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.
The Microsoft Global Human Rights Statement and Supplier Code of Conduct defines our expectations concerning ethical business, employment, environmental, and worker safety practices. Our Standards of Business Conduct outlines expected behaviors for all Microsoft employees. Our supplier specifications and internal procedures establish supplier commitments for the responsible sourcing of raw materials, including 3TGs. We incorporate these requirements into our hardware and packaging contracts and audit our suppliers to ensure these requirements are met.
The Microsoft Span of Influence
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| 2. | Internal Management Team |
A cross-functional team supports Microsoft’s responsible sourcing and 3TG compliance activities. The Corporate Vice President of Microsoft’s Manufacturing and Supply Chain organization sponsors the team. The team consists of representatives from 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 quarterly to assess the program’s progress and identify steps 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. Related procedures are documented in our internal Responsible Sourcing Program Manual. Team members also develop, review, file, and publish the CMR.
| 3. | System of Supply Chain Controls and Transparency |
Our Suppliers 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. These suppliers rely on information provided by their upstream suppliers to meet their compliance obligations. Our contracts require all Microsoft in-scope suppliers partners to identify by weight each and every substance contained in the materials, components, and products supplied to us, including 3TGs. Our in-scope suppliers are responsible for communicating our sourcing requirements and specifications to their sub-tier suppliers and incorporating 3TG information 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 a failure to fully complete the CMRT, data inconsistencies, and possible sourcing from a CAHRA. Microsoft investigates each identified issue and engages with those suppliers to address all concerns in conformance to Microsoft policies, procedures, and specifications. In cases where the supplier is identified as sourcing from a CAHRA, suppliers are required to submit a CMRT more frequently.
If we find that a supplier has introduced unmitigated risk to the Microsoft supply chain, such as using an upstream SOR that does not comply with Microsoft’s RSRM policy or specifications, Microsoft requires corrective action to address the non-conformity. The response time for corrective action is calibrated to the severity of the identified risk. Risks are mitigated by supplier engagement, corrective actions, training, and/or additional audits. These controls and related documentation are detailed in H02050 - Microsoft Supplier Social and Environmental Accountability Manual and other Microsoft internal operating procedures.
Microsoft works with impacted suppliers to find sources for 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 the non-conformance is resolved. Microsoft may also terminate its business relationship with the supplier.
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Microsoft is a longstanding member of the Global e-Sustainability Initiative (“GeSI”) and the Electronics Industry Citizenship Coalition (“EICC”). These organizations initiated the Conflict-Free Sourcing Initiative (“CFSI”) in 2008. 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 monitor whether SORs process 3TGs from sources that directly or indirectly finance or benefit armed groups in a Covered Country. Microsoft funded an early adopters program to subsidize audit costs, enabling more SORs to be CFSP audited. Microsoft also financially supports the Industrial Technology Research Institute’s Tin Supply Chain Initiative (“iTSCi”), which has established a system of traceability and due diligence in Covered Countries.
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. We 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 partnerships that work to establish responsible mining standards and the responsible sourcing of minerals. We partner closely with Pact, the Initiative for Responsible Mining Assurance (“IRMA”), and Alliance for Responsible Mining (“ARM”). These organizations address human rights concerns in mining and leverage data and technology to bring about even greater change. Empowered by digital technology, Microsoft and our partners can drive transformations in the mining sector by addressing issues of increased scope and complexity. We believe this integrated approach improves conditions for the people working in raw material supply chains.
Our primary relationships are further described below:
| • | Pact: Since 2014, Microsoft has partnered with Pact on the Watoto Inje ya Mungoti, or “Children out of Mining” program - a scalable, repeatable, and sustainable strategy to address child labor in the DRC mining sector. The program employs a two-pronged approach, focused on raising community awareness of the child labor issue and improving economic stability of caregivers. By October 2016, Pact reported a 97% reduction in children working in the mines. The program and Microsoft’s leadership have been recognized by others and was the only cited best practice by the OECD in its report, Practical Actions for Companies to Identify and Address the Worst Forms of Child Labour in the Minerals Supply Chain, presented at the OECD-ICGLR-UN Group of Expert Forum on Responsible Mineral Supply Chain in May 2016. As the program expands and develops, Microsoft will continue to partner with Pact with the goal of transforming this initiative into a best practice standard to address child labor in mining. Please find more about the project in Pact’s Report. |
| • | Initiative for Responsible Mining Assurance (“IRMA”): IRMA established a multi-stakeholder and independently verifiable responsible mining assurance system that improves social and environmental performance through the development of global mining standards for large-scale mines. Our partnership involves more than just participation - we are bringing technology to help scope, scale, and implement effective programs. Microsoft recently donated a technology platform to IRMA that will allow the organization to better implement |
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| these assurance standards. By pairing the technology platform with Power BI, a cloud-based business analytics service, stakeholders will be able to track mining performance against the assurance standards. This real-time information, presented in an easy-to-see and easy-to-use interface, will help mining companies and Non-Governmental Organizations (“NGOs”) overcome the inherent difficulties of scope and complexity of these programs to create new insights and inspire additional progress. With learnings from this engagement, we hope to enable additional NGO partners to expand their work to create sustainable mining communities. |
| • | Alliance for Responsible Mining (“ARM”): ARM sets standards for responsible artisanal and small scale mining and supports and creates opportunities for gold miners, providing them with incentives to become responsible economic, technological, and environmental enterprises. Seed funding from Microsoft helped ARM secure further resources to develop a Market Entry Standard for Artisanal and Small-scale Gold Miners. |
| 4. | Supplier Engagement |
Given the complexities of the global mineral supply chain, we work closely with our suppliers around the world to ensure they share our commitment and reflect it in their own programs. CFSI’s “Practical Guidance for Downstream Companies” 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 3TG sourcing risks 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.
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. We communicate, monitor, and track electronically supplier adherance 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. With the empowerment of digital technology, Microsoft and our partners can drive transformations in the mining sector by addressing issues of increased scope and complexity. We invest in industry programs, such as the CFSP, to increase suppliers’ capabilities and provide them with platforms to share best practices. |
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| • | Supplier Audits: Microsoft conducts audits of its directly contracted suppliers to assess their conformance to Microsoft requirements. All new contracted hardware and packaging suppliers undergo an Initial Capability Assessment (“ICA”) to verify conformance. Existing contracted hardware and packaging suppliers also undergo a Sustaining Maintenance Audit (“SMA”) on an annual, biannual, or triannual basis depending on their risk level. Suppliers must establish and maintain a corporate policy and effective procedures for responsible sourcing of raw materials. Microsoft selects and retains only those business partners committed to meeting these requirements. A failure by a supplier or sub-tier supplier to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft. During the 2016 reporting year, Microsoft-engaged auditors conducted 165 ICAs and SMAs of approximately 320 directly contracted hardware and packaging suppliers to assess areas of SEA conformance. These ICAs and SMAs addressed whether the suppliers had a conflict minerals policy, systems in place to implement that policy, and documentation to verify conformance to Microsoft’s responsible sourcing requirements. |
| 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 allows employees and others to anonymously ask compliance questions or report concerns regarding Microsoft’s business operations, including our mineral sourcing policies or those of our suppliers. We investigate and, where appropriate, take remedial action to address reported concerns. We also participate in industry efforts to develop grievance mechanisms for conflict minerals-related issues.
| B. | Identify and Assess Risk in the Supply Chain |
We took the following steps to identify and assess supplier conflict mineral sourcing risk during this reporting year2:
| • | 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 2016 reporting year by utilizing the CFSI-standard CMRT and the services of a third-party solution provider. The survey followed OECD Guidance as tailored for Microsoft’s role as a downstream company. Our survey included questions regarding the supplier’s 3TG due diligence policies and procedures, 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. |
| 2 | Microsoft completed its supplier conflict mineral sourcing data analysis for the 2016 reporting year on March 31, 2017. |
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| • | 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 252 active in-scope suppliers for the 2016 reporting year. Of the 252 active in-scope suppliers surveyed, we received responses from 251 by our March 31st deadline. This resulted in a 99% response rate - an improvement from previous years as shown in Figure 1. |
Figure 1. Response Rate for Active In-scope Suppliers (2013-2016 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.
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| B. | Due Diligence Performed |
| 1. | Design and Implement a Strategy to Respond to Risks |
Microsoft requires its suppliers to minimize the possible sourcing of 3TGs from CAHRAs through contract requirements incorporating supplier specifications.
| a. | Microsoft Supplier Specifications - H00594 and HO0642 |
Microsoft requires 100% identification of all materials, including 3TGs, used in packaging and hardware products and parts on a component-by-component level through supplier specification H00594, Restricted Substances for Hardware Products. H00594 requires contracted suppliers to:
| • | Post a responsible sourcing policy, conforming to the OECD Guidance, on their website; |
| • | Exercise due diligence on the source and chain of custody of 3TGs contained in materials, components, or products supplied 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 available CFSP or an equivalent third-party conflict-free audit scheme; |
| • | Confirm 3TGs in their supply chain are sourced from available SORs that are compliant with the CFSP or an equivalent independent private sector audit firm; and |
| • | Notify Microsoft immediately if minerals used in the supplied materials, components, or products may contain 3TGs sourced from a Covered Country. |
H00594 requires Microsoft suppliers to impose these same requirements on their sub-tier suppliers and to assist sub-tier suppliers with appropriate training and support. To facilitate this process, H00642, Restricted Substances Control System for Hardware Products, requires Microsoft suppliers to utilize the CMRT provided by the CFSI and available at www.conflictfreesourcing.org. Suppliers must submit an annual CMRT and updated data upon request or when sourcing practices change.
| b. | Responsible Sourcing Program Manual Processes to Implement OECD Guidance |
Microsoft uses OECD Guidance to review supplier CMRT data and identify potential red flags for the sourcing of 3TGs. We take additional action when indentifying red flags such as:
| • | The minerals originated from or were transported via a CAHRA; |
| • | The minerals were claimed to have originated from a country that has limited known reserves for the mineral in question; |
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| • | The minerals were claimed to have originated from a country in which minerals from a CAHRA 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. |
Microsoft’s program includes an escalation process that requires 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 RSRM issue with a supplier that has warranted contract termination.
Microsoft’s internal Responsible Sourcing Program Manual requires self-assessment, monitoring, and internal reporting of the RSRM program progress and compliance. The internal management team provided monthly program status updates, including metrics and audit results, to Microsoft’s Corporate Vice President of Manufacturing and Supply Chain. 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 leveraged Microsoft’s SEA Steering Committee meetings with senior management to report findings and receive program guidance. Microsoft employees accessed the results of the program through Microsoft’s Windows and Devices Group’s internal 2016 Sustainability Report.
| c. | Industry and Partner Engagement |
Microsoft participated in or has been a member of several industry-wide responsible mining and smelting initiatives: CFSI, ITRI’s iTSCi program, IRMA, Pact, and ARM. We also conducted smelter outreach on behalf of the CFSI Smelter Engagement Team to further the CFSI program.
| 2. | Carried Out Independent Third-Party Audit of Supply Chain Due Diligence |
As contemplated by OECD Guidance, our due diligence program leveraged independent SOR audits. The audits complied with the CFSP and other similar programs. Microsoft obtained SOR data from the CFSP Compliant Smelter List using Reasonable Country of Origin Inquiry Data for member MSFT. The list identifies SORs that have undergone assessment through the CFSP or industry equivalent program, such as Responsible Jewellery Council (“RJC”) or London Bullion Market Association (“LBMA”). We used the list to support certain statements contained in this CMR. Microsoft also participated in CFSI’s Smelter Engagement Team during the 2016 reporting year.
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| 3. | Reported on Supply Chain Due Diligence |
Microsoft’s RSRM policy and other responsible sourcing documents are available on our external website. We have filed our CMR with the SEC and concurrently posted it on our external Responsible Sourcing website. These disclosures meet the fifth step of the OECD Guidance.
| IV. | SOR INFORMATION |
| A. | 3TG Processing Facilities |
Microsoft has made a reasonable good faith effort to collect and evaluate information concerning 3TG SORs provided by our in-scope suppliers. The vast majority of our in-scope suppliers provided data at a company or divisional level. This level of disclosure was expected given the multiple tiers of supply chain actors positioned between our in-scope suppliers and 3TG SORs.
Our supplier survey data revealed 17,823 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. We then verified if the alleged smelters were active and participants in the CFSP audit program. We determined 303 smelters met this criteria.
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 CFSP audit status and reporting year. Figure 2 indicates the percentage of compliant or CFSP active smelters has steadily increased each year. For the 2016 reporting year, 87% of suppliers were either compliant or on the CFSP active list. This is an increase from 85% in 2015, 73% in 2014 and 60% in 2013. Figure 2 also indicates that the number of compliant smelters increased significantly from 213 to 249.
Figure 3 categorizes the SORs by 3TG mineral and CFSP audit status. A comparison from the 2015 reporting year showed that gold, tungsten, and tin all increased in the number and percentage of Compliant and Active smelters. Tin had the greatest increase with the percentage of Compliant or Active smelters growing from 85% to 91%. Gold and tungsten had moderate increases while tantalum remained 100% compliant.
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Figure 2. Identified SORs by CFSP Audit Status (2013-2016 Reporting Years)
Outreach Required Active Non-Compliant Due Diligence Vetting Restriction - Not Applicable In Communication Compliant Communication Suspended - Not Interested
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Figure 3: Identified SORs by 3TG and CFSP Audit Status
|
| |
|
| |
Tin SORs 82 Total Tungsten SORs 45 Total Tantalum SORs 44 Total Gold SORs
132 Total
Outreach Required Active Non-Compliant Due Diligence Vetting Restriction - Not Applicable In Communication Compliant
Communication Suspended - Not Interested
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Table 1 (below) summarizes the conflict mineral status of the 303 SORs identified in Microsoft’s supply chain during the 2016 reporting year.
The CFSP classifies audit status in the following manner:
| • | Compliant: SOR has been audited and found to be compliant with the relevant audit protocols, including CFSP, LBMA, or RJC; |
| • | 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; |
| • | Due Diligence Vetting Restriction- Not Applicable: SOR cannot be audited as per CFSI’s due diligence vetting process; |
| • | Communication Suspended: SOR has strongly communicated a lack of interest in participation; and |
| • | Non-Compliant: SOR was audited but found not compliant with the relevant CFSP protocol |
Note: Due Diligence Vetting Restriction, Communication Suspended, and Non-Compliant are new CFSI audit statuses developed in 2016. This is the first year we will note this status. We also will no longer indicate the status of TI-CMC Member Company as an audit status.
Table 1: Summary of CFSP Audit Status of Identified SORs
| Number of SORs Identified in Microsoft Supply Chain |
CFSP Audit Status | |
| 249 |
Compliant (Indicates CFSP, LBMA and/or RJC compliant) | |
| 27 |
Outreach Required | |
| 14 |
Active | |
| 5 |
In Communication | |
| 5 |
Communication Suspended- Not Interested | |
| 2 |
Due Diligence Vetting Restriction - Not Applicable | |
| 1 |
Non-Compliant | |
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Figures 4-7 show the geographic distribution of the 303 SORs identified in the Microsoft supply chain by 3TG mineral for the 2016 reporting year. 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 - Tin3
| 3 | Note: While the locations of most SORs remained relatively constant for tantalum, tungsten, and gold, the location of tin SORs has been more dynamic this year. We saw a decrease in number of SORs in Indonesia and an increase in China. |
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Figure 5: Location and Relative Number of Identified SORs - Tantalum
Figure 6: Location and Relative Number of Identified SORs - Tungsten
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Figure 7: Location and Relative Number of Identified SORs - Gold
Appendix A provides the complete list of 303 SORs which, to the extent known, processed 3TGs used in Microsoft devices during the 2016 reporting year. Appendix A provides each SOR’s country location, 3TG processed, and audit status. Marked with an asterisk are gold SORs certified as LBMA Responsible Gold.
| B. | 3TG Countries of Origin |
Countries of origin for the 3TGs are listed in the below table.
| Countries of Origin identified by CFSP Compliant SORs |
Additional Possible Countries of Origin | |
| • Australia
• Austria
• Benin
• Bolivia
• Brazil
• Burkina Faso
• Burundi
• Cambodia
• Canada
• Chile
• China
|
These countries were identified through research or were listed by suppliers in their CMRT. These countries require continual due diligence and investigation.
• Angola
• Argentina
• Armenia
• Belarus
• Belgium
• Bermuda
• Central African Republic, Congo (Brazzaville)
|
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| • Colombia
• DRC
• Ecuador
• Eritrea
• Ethiopia
• France
• Ghana
• Guatemala
• Guinea
• Guyana
• Honduras
• India
• Indonesia
• Japan
• Laos
• Madagascar
• Malaysia
• Mali
• Mexico
• Mongolia
• Mozambique
• Myanmar
• Namibia
• Nicaragua
• Nigeria
• Panama
• Peru
• Portugal
• Russia
• Rwanda
• Senegal
• Sierra Leone
• South Africa
• Spain
• Thailand
• Togo
• Uganda
• United States of America
• Uzbekistan
• Vietnam
• Zimbabwe |
• Czech Republic
• Djibouti
• Egypt
• Estonia
• Finland
• Germany
• Hong Kong
• Hungary
• Ireland
• Israel
• Italy
• Jersey
• Kazakhstan
• Kenya
• Republic of Korea
• Kyrgyzstan
• Luxembourg
• Morocco
• Netherlands
• New Zealand
• Niger
• Papua New Guinea
• Philippines
• Poland
• Saudi Arabia
• Singapore
• Slovakia
• South Sudan
• Suriname
• Sweden
• Switzerland
• Taiwan
• Tajikistan
• Tanzania
• Turkey
• United Arab Emirates
• United Kingdom
• Zambia |
18
Figure 8 provides a graphical presentation of the countries of origin for 3TGs that were identified as being present in Microsoft’s supply chain during the 2016 reporting year.
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:
| • | 53% process recycled or scrap material |
| • | 77% are not sourcing from Covered Countries |
| • | 41 SORs are sourcing from Covered Countries and 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. The CFSI oversees the CFSP.
We encouraged SORs to participate in the CFSP by contacting all non-compliant SORs identified in our supply chain each reporting year. We also required suppliers reporting non-compliant
| 4 | All numbers include both direct and indirect sourcing |
19
SORs to contact these SORs and motivate them to join the CFSP. We actively supported outreach events to increase CFSP SOR coverage. We funded a third party to help educate SORs and prepare them for the audit process. We have also offered to visit SORs to facilitate their participation in the CFSP.
| V. | IMPROVEMENTS |
This year’s report documents our efforts to expand the number of verified conflict-free SORs in our supply chain and demonstrates strong progress. While comparisons to 2015 reporting year data are not precise due to supply chain year-to-year variances, the progress is meaningful. Microsoft’s key 2016 reporting year accomplishments and improvements are detailed below:
| • | Increased number of CFSP-compliant SORs identified in Microsoft’s supply chain from 213 to 249 due to enhanced supplier outreach, and maturation of CFSI’s CFSP; |
| • | Increased supplier response rate to 99% in the 2016 reporting year - an increase from 71% in 2013; |
| • | Enhanced engagement with external organizations, such as Pact, IRMA, and ARM 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. We partner closely with these organizations and leverage data and technology to bring about even greater change. With the further empowerment that digital technology can provide toward increased scope and complexity, Microsoft and our partners can drive positive transformations in the mining sector. We believe this integrated approach is the most effective way to improve conditions for the people working in raw material supply chains; |
| • | Refined and improved internal procedures and processes to enhance alignment with OECD Guidance, including Microsoft’s supplier escalation process and supplier audit procedures; |
| • | Increased Microsoft’s level of engagement with suppliers and internal stakeholders by holding supplier forums, webinars, and in-person trainings, and by providing resources; and |
| • | Continued refinement of supplier data by conducting outreach when reported data was incomplete or uncertain. |
| VI. | FUTURE ACTIONS |
Microsoft is committed to human rights, labor, health and safety, environmental protection, and business ethics in our supply chain. We will advance implementation of our RSRM policy. The policy consists of supply chain identification and risk assessment, standardized requirements and verification, capability building, transparency, and partnerships.
We will continue encouraging SORs to participate in the CFSP and expanding our knowledge about 3TGs in our supply chain. Our ability to identify, assess, and mitigate risks associated with our raw materials sourcing will improve with ongoing due diligence efforts - both direct and with our
20
partners. Consistent with our commitments, we intend to take the following steps to improve our responsible sourcing of raw materials due diligence efforts:
| • | Enhance our use of digital technology to improve supply chain information and risk mitigation; |
| • | Increase use of external data sources to proactively identify raw material risk in CAHRAs; |
| • | Continue our active participation in the CFSI Smelter Engagement Team to bring non-compliant SORs into the CFSP; and |
| • | Further our engagement with organizations like IRMA, ARM, and Pact to establish global responsible sourcing standards and supporting programs in the mineral supply chain. |
21
APPENDIX A
Conflict Mineral Status of Identified SORs1
This Appendix lists the 303 SORs which, to the extent known, processed 3TGs that were used to manufacture Microsoft devices during the 2016 reporting year. The SORs are listed by their audit status, 3TG processed, and country location. Gold SORs marked with an asterisk are certified as LBMA Responsible Gold.
| Official Smelter Name |
CFSI Smelter ID |
Mineral |
Smelter |
Audit Status | ||||
| Abington Reldan Metals, LLC |
CID002708 | Gold | United States | Active | ||||
| Advanced Chemical Company |
CID000015 | Gold | United States | Compliant | ||||
| Aida Chemical Industries Co., Ltd. |
CID000019 | Gold | Japan | Compliant | ||||
| Al Etihad Gold |
CID002560 | Gold | United Arab Emirates | Compliant | ||||
| Allgemeine Gold-und Silberscheideanstalt A.G. |
CID000035 | Gold | Germany | Compliant | ||||
| Almalyk Mining and Metallurgical Complex (AMMC) |
CID000041 | Gold | Uzbekistan | Compliant | ||||
| AngloGold Ashanti |
CID000058 | Gold | Brazil | Compliant | ||||
| Argor-Heraeus SA |
CID000077 | Gold | Switzerland | Compliant | ||||
| Asahi Pretec Corporation |
CID000082 | Gold | Japan | Compliant | ||||
| Asahi Refining Canada Limited |
CID000924 | Gold | Canada | Compliant | ||||
| Asahi Refining USA Inc. |
CID000920 | Gold | United States | Compliant | ||||
| Asaka Riken Co., Ltd. |
CID000090 | Gold | Japan | Compliant | ||||
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
CID000103 | Gold | Turkey | Due Diligence Vetting Restriction- Not Applicable | ||||
| AU Traders and Refiners |
CID002850 | Gold | South Africa | Compliant | ||||
| Aurubis AG |
CID000113 | Gold | Germany | Compliant | ||||
| Bangalore Refinery |
CID002863 | Gold | India | Active | ||||
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
CID000128 | Gold | Philippines | Compliant | ||||
| Boliden AB |
CID000157 | Gold | Sweden | Compliant | ||||
| C. Hafner GmbH + Co. KG |
CID000176 | Gold | Germany | Compliant | ||||
| Caridad |
CID000180 | Gold | Mexico | Communication Suspended - Not Interested | ||||
| CCR Refinery - Glencore Canada Corporation |
CID000185 | Gold | Canada | Compliant | ||||
| Cendres + Métaux SA |
CID000189 | Gold | Switzerland | Active | ||||
| Chimet S.p.A. |
CID000233 | Gold | Italy | Compliant |
| 1 | Data as of April 15, 2017. |
A-1
| Chugai Mining |
CID000264 | Gold | Japan | In Communication | ||||
| Daejin Indus Co., Ltd. |
CID000328 | Gold | Korea, Republic of | Compliant | ||||
| Daye Non-Ferrous Metals Mining Ltd. |
CID000343 | Gold | China | Compliant | ||||
| DODUCO GmbH |
CID000362 | Gold | Germany | Compliant | ||||
| Dowa |
CID000401 | Gold | Japan | Compliant | ||||
| DSC (Do Sung Corporation) |
CID000359 | Gold | Korea, Republic of | Compliant | ||||
| Eco-System Recycling Co., Ltd. |
CID000425 | Gold | Japan | Compliant | ||||
| Elemetal Refining, LLC |
CID001322 | Gold | United States | Compliant | ||||
| Emirates Gold DMCC |
CID002561 | Gold | United Arab Emirates | Compliant | ||||
| Gansu Seemine Material Hi-Tech Co Ltd |
CID000522 | Gold | China | Outreach Required | ||||
| Geib Refining Corporation |
CID002459 | Gold | United States | Compliant | ||||
| Gold Refinery of Zijin Mining Group Co., Ltd |
CID002243 | Gold | China | Compliant | ||||
| Great Wall Precious Metals Co., Ltd. of CBPM |
CID001909 | Gold | China | Compliant | ||||
| Guangdong Jinding Gold Limited |
CID002312 | Gold | China | Outreach Required | ||||
| Gujarat Gold Centre |
CID002852 | Gold | India | Outreach Required | ||||
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CID000651 | Gold | China | Outreach Required | ||||
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
CID000671 | Gold | China | Outreach Required | ||||
| Heimerle + Meule GmbH |
CID000694 | Gold | Germany | Compliant | ||||
| Heraeus Metals Hong Kong Ltd |
CID000707 | Gold | China | Compliant | ||||
| Heraeus Precious Metals GmbH & Co. KG |
CID000711 | Gold | Germany | Compliant | ||||
| Hunan Chenzhou Mining Co., Ltd. |
CID000767 | Gold | China | Outreach Required | ||||
| HwaSeong CJ Co. Ltd |
CID000778 | Gold | Korea, Republic of | Communication Suspended - Not Interested | ||||
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CID000801 | Gold | China | Compliant | ||||
| Ishifuku Metal Industry Co., Ltd. |
CID000807 | Gold | Japan | Compliant | ||||
| Istanbul Gold Refinery |
CID000814 | Gold | Turkey | Compliant | ||||
| Japan Mint |
CID000823 | Gold | Japan | Compliant | ||||
| Jiangxi Copper Company Limited |
CID000855 | Gold | China | Compliant | ||||
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
CID000927 | Gold | Russian Federation | Compliant | ||||
| JSC Uralelectromed |
CID000929 | Gold | Russian Federation | Compliant | ||||
| JX Nippon Mining & Metals Co., Ltd. |
CID000937 | Gold | Japan | Compliant |
A-2
| Kaloti Precious Metals |
CID002563 | Gold | United Arab Emirates | Outreach Required | ||||
| Kazzinc |
CID000957 | Gold | Kazakhstan | Compliant | ||||
| Kennecott Utah Copper LLC |
CID000969 | Gold | United States | Compliant | ||||
| KGHM Polska Miedź Spółka Akcyjna |
CID002511 | Gold | Poland | Active | ||||
| Kojima Chemicals Co., Ltd. |
CID000981 | Gold | Japan | Compliant | ||||
| Korea Zinc Co., Ltd. |
CID002605 | Gold | Korea, Republic of | Compliant | ||||
| Kyrgyzaltyn JSC |
CID001029 | Gold | Kyrgyzstan | Compliant | ||||
| L’azurde Company For Jewelry |
CID001032 | Gold | Saudi Arabia | Due Diligence Vetting Restriction - Not Applicable | ||||
| Lingbao Gold Company Ltd. |
CID001056 | Gold | China | Outreach Required | ||||
| Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
CID001058 | Gold | China | Outreach Required | ||||
| LS-NIKKO Copper Inc. |
CID001078 | Gold | Korea, Republic of | Compliant | ||||
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CID001093 | Gold | China | Outreach Required | ||||
| Materion |
CID001113 | Gold | United States | Compliant | ||||
| Matsuda Sangyo Co., Ltd. |
CID001119 | Gold | Japan | Compliant | ||||
| Metalor Technologies (Hong Kong) Ltd. |
CID001149 | Gold | China | Compliant | ||||
| Metalor Technologies (Singapore) Pte., Ltd. |
CID001152 | Gold | Singapore | Compliant | ||||
| Metalor Technologies (Suzhou) Co Ltd |
CID001147 | Gold | China | Compliant | ||||
| Metalor Technologies SA |
CID001153 | Gold | Switzerland | Compliant | ||||
| Metalor USA Refining Corporation |
CID001157 | Gold | United States | Compliant | ||||
| METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
CID001161 | Gold | Mexico | Compliant | ||||
| Mitsubishi Materials Corporation |
CID001188 | Gold | Japan | Compliant | ||||
| Mitsui Mining and Smelting Co., Ltd. |
CID001193 | Gold | Japan | Compliant | ||||
| MMTC-PAMP India Pvt., Ltd. |
CID002509 | Gold | India | Compliant | ||||
| Modeltech Sdn Bhd |
CID002857 | Gold | Malaysia | Active | ||||
| Morris and Watson |
CID002282 | Gold | New Zealand | Communication Suspended - Not Interested | ||||
| Morris and Watson Gold Coast |
CID002866 | Gold | Australia | Communication Suspended - Not Interested | ||||
| Moscow Special Alloys Processing Plant |
CID001204 | Gold | Russian Federation | Compliant | ||||
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
CID001220 | Gold | Turkey | Compliant | ||||
| Navoi Mining and Metallurgical Combinat |
CID001236 | Gold | Uzbekistan | Active | ||||
| Nihon Material Co., Ltd. |
CID001259 | Gold | Japan | Compliant |
A-3
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
CID002779 | Gold | Austria | Compliant | ||||
| Ohura Precious Metal Industry Co., Ltd. |
CID001325 | Gold | Japan | Compliant | ||||
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
CID001326 | Gold | Russian Federation | Compliant | ||||
| OJSC Novosibirsk Refinery |
CID000493 | Gold | Russian Federation | Compliant | ||||
| PAMP S.A. |
CID001352 | Gold | Switzerland | Compliant | ||||
| Penglai Penggang Gold Industry Co Ltd |
CID001362 | Gold | China | Outreach Required | ||||
| Prioksky Plant of Non-Ferrous Metals |
CID001386 | Gold | Russian Federation | Compliant | ||||
| PT Aneka Tambang (Persero) Tbk |
CID001397 | Gold | Indonesia | Compliant | ||||
| PX Precinox SA |
CID001498 | Gold | Switzerland | Compliant | ||||
| Rand Refinery (Pty) Ltd. |
CID001512 | Gold | South Africa | Compliant | ||||
| Remondis Argentia B.V. |
CID002582 | Gold | Netherlands | In Communication | ||||
| Republic Metals Corporation |
CID002510 | Gold | United States | Compliant | ||||
| Royal Canadian Mint |
CID001534 | Gold | Canada | Compliant | ||||
| SAAMP |
CID002761 | Gold | France | Compliant | ||||
| Sabin Metal Corp. |
CID001546 | Gold | United States | Outreach Required | ||||
| SAFINA A.S. |
CID002290 | Gold | Czech Republic | In Communication | ||||
| Sai Refinery |
CID002853 | Gold | India | Outreach Required | ||||
| Samduck Precious Metals |
CID001555 | Gold | Korea, Republic of | Compliant | ||||
| SAMWON METALS Corp. |
CID001562 | Gold | Korea, Republic of | In Communication | ||||
| SAXONIA Edelmetalle GmbH |
CID002777 | Gold | Germany | Compliant | ||||
| Schone Edelmetaal B.V. |
CID001573 | Gold | Netherlands | Compliant | ||||
| SEMPSA Joyería Platería SA |
CID001585 | Gold | Spain | Compliant | ||||
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CID001619 | Gold | China | Outreach Required | ||||
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CID001622 | Gold | China | Compliant | ||||
| Sichuan Tianze Precious Metals Co., Ltd. |
CID001736 | Gold | China | Compliant | ||||
| Singway Technology Co., Ltd. |
CID002516 | Gold | Taiwan | Compliant | ||||
| So Accurate Group, Inc. |
CID001754 | Gold | United States | Outreach Required | ||||
| SOE Shyolkovsky Factory of Secondary Precious Metals |
CID001756 | Gold | Russian Federation | Compliant | ||||
| Solar Applied Materials Technology Corp. |
CID001761 | Gold | Taiwan | Compliant | ||||
| Sumitomo Metal Mining Co., Ltd. |
CID001798 | Gold | Japan | Compliant |
A-4
| T.C.A S.p.A |
CID002580 | Gold | Italy | Compliant | ||||
| Tanaka Kikinzoku Kogyo K.K. |
CID001875 | Gold | Japan | Compliant | ||||
| The Refinery of Shandong Gold Mining Co., Ltd. |
CID001916 | Gold | China | Compliant | ||||
| Tokuriki Honten Co., Ltd. |
CID001938 | Gold | Japan | Compliant | ||||
| TongLing Nonferrous Metals Group Holdings Co., Ltd. |
CID001947 | Gold | China | Outreach Required | ||||
| Tony Goetz NV |
CID002587 | Gold | Belgium | Active | ||||
| Torecom |
CID001955 | Gold | Korea, Republic of | Compliant | ||||
| Umicore Brasil Ltda. |
CID001977 | Gold | Brazil | Compliant | ||||
| Umicore Precious Metals Thailand |
CID002314 | Gold | Thailand | Compliant | ||||
| Umicore SA Business Unit Precious Metals Refining |
CID001980 | Gold | Belgium | Compliant | ||||
| United Precious Metal Refining, Inc. |
CID001993 | Gold | United States | Compliant | ||||
| Universal Precious Metals Refining Zambia |
CID002854 | Gold | Zambia | Communication Suspended - Not Interested | ||||
| Valcambi SA |
CID002003 | Gold | Switzerland | Compliant | ||||
| Western Australian Mint trading as The Perth Mint |
CID002030 | Gold | Australia | Compliant | ||||
| WIELAND Edelmetalle GmbH |
CID002778 | Gold | Germany | Compliant | ||||
| Yamamoto Precious Metal Co., Ltd. |
CID002100 | Gold | Japan | Compliant | ||||
| Yokohama Metal Co., Ltd. |
CID002129 | Gold | Japan | Compliant | ||||
| Yunnan Copper Industry Co Ltd |
CID000197 | Gold | China | Outreach Required | ||||
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CID002224 | Gold | China | Compliant | ||||
| Changsha South Tantalum Niobium Co., Ltd. |
CID000211 | Tantalum | China | Compliant | ||||
| Conghua Tantalum and Niobium Smeltry |
CID000291 | Tantalum | China | Compliant | ||||
| D Block Metals, LLC |
CID002504 | Tantalum | United States | Compliant | ||||
| Duoluoshan |
CID000410 | Tantalum | China | Compliant | ||||
| Exotech Inc. |
CID000456 | Tantalum | United States | Compliant | ||||
| F&X Electro-Materials Ltd. |
CID000460 | Tantalum | China | Compliant | ||||
| FIR Metals & Resource Ltd. |
CID002505 | Tantalum | China | Compliant | ||||
| Global Advanced Metals Aizu |
CID002558 | Tantalum | Japan | Compliant | ||||
| Global Advanced Metals Boyertown |
CID002557 | Tantalum | United States | Compliant | ||||
| Guangdong Zhiyuan New Material Co., Ltd. |
CID000616 | Tantalum | China | Compliant | ||||
| H.C. Starck Co., Ltd. |
CID002544 | Tantalum | Thailand | Compliant | ||||
| H.C. Starck Hermsdorf GmbH |
CID002547 | Tantalum | Germany | Compliant | ||||
| H.C. Starck Inc. |
CID002548 | Tantalum | United States | Compliant | ||||
| H.C. Starck Ltd. |
CID002549 | Tantalum | Japan | Compliant | ||||
| H.C. Starck Smelting GmbH & Co. KG |
CID002550 | Tantalum | Germany | Compliant |
A-5
| H.C. Starck Tantalum and Niobium GmbH |
CID002545 | Tantalum | Germany | Compliant | ||||
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
CID002492 | Tantalum | China | Compliant | ||||
| Hi-Temp Specialty Metals, Inc. |
CID000731 | Tantalum | United States | Compliant | ||||
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CID002512 | Tantalum | China | Compliant | ||||
| Jiangxi Tuohong New Raw Material |
CID002842 | Tantalum | China | Compliant | ||||
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CID000914 | Tantalum | China | Compliant | ||||
| Jiujiang Nonferrous Metals Smelting Company Limited |
CID000917 | Tantalum | China | Compliant | ||||
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CID002506 | Tantalum | China | Compliant | ||||
| KEMET Blue Metals |
CID002539 | Tantalum | Mexico | Compliant | ||||
| Kemet Blue Powder |
CID002568 | Tantalum | United States | Compliant | ||||
| King-Tan Tantalum Industry Ltd. |
CID000973 | Tantalum | China | Compliant | ||||
| LSM Brasil S.A. |
CID001076 | Tantalum | Brazil | Compliant | ||||
| Metallurgical Products India Pvt., Ltd. |
CID001163 | Tantalum | India | Compliant | ||||
| Mineração Taboca S.A. |
CID001175 | Tantalum | Brazil | Compliant | ||||
| Mitsui Mining and Smelting Co., Ltd. |
CID001192 | Tantalum | Japan | Compliant | ||||
| Ningxia Orient Tantalum Industry Co., Ltd. |
CID001277 | Tantalum | China | Compliant | ||||
| NPM Silmet AS |
CID001200 | Tantalum | Estonia | Compliant | ||||
| Power Resources Ltd. |
CID002847 | Tantalum | Macedonia, The Former Yugoslav Republic Of | Compliant | ||||
| QuantumClean |
CID001508 | Tantalum | United States | Compliant | ||||
| Resind Indústria e Comércio Ltda. |
CID002707 | Tantalum | Brazil | Compliant | ||||
| RFH Tantalum Smeltry Co., Ltd. |
CID001522 | Tantalum | China | Compliant | ||||
| Solikamsk Magnesium Works OAO |
CID001769 | Tantalum | Russian Federation | Compliant | ||||
| Taki Chemical Co., Ltd. |
CID001869 | Tantalum | Japan | Compliant | ||||
| Telex Metals |
CID001891 | Tantalum | United States | Compliant | ||||
| Tranzact, Inc. |
CID002571 | Tantalum | United States | Compliant | ||||
| Ulba Metallurgical Plant JSC |
CID001969 | Tantalum | Kazakhstan | Compliant | ||||
| XinXing Haorong Electronic Material Co., Ltd. |
CID002508 | Tantalum | China | Compliant | ||||
| Yichun Jin Yang Rare Metal Co., Ltd. |
CID002307 | Tantalum | China | Compliant | ||||
| Zhuzhou Cemented Carbide Group Co., Ltd. |
CID002232 | Tantalum | China | Compliant | ||||
| Alpha |
CID000292 | Tin | United States | Compliant | ||||
| An Thai Minerals Company Limited |
CID002825 | Tin | Viet Nam | Outreach Required | ||||
| An Vinh Joint Stock Mineral Processing Company |
CID002703 | Tin | Viet Nam | Outreach Required | ||||
| Chenzhou Yunxiang Mining and Metallurgy Company Limited |
CID000228 | Tin | China | Compliant |
A-6
| China Tin Group Co., Ltd. |
CID001070 | Tin | China | Compliant | ||||
| CNMC (Guangxi) PGMA Co. Ltd. |
CID000278 | Tin | China | Outreach Required | ||||
| Cooperativa Metalurgica de Rondônia Ltda. |
CID000295 | Tin | Brazil | Compliant | ||||
| CV Ayi Jaya |
CID002570 | Tin | Indonesia | Compliant | ||||
| CV Dua Sekawan |
CID002592 | Tin | Indonesia | Compliant | ||||
| CV Gita Pesona |
CID000306 | Tin | Indonesia | Compliant | ||||
| CV Serumpun Sebalai |
CID000313 | Tin | Indonesia | Compliant | ||||
| CV Tiga Sekawan |
CID002593 | Tin | Indonesia | Compliant | ||||
| CV United Smelting |
CID000315 | Tin | Indonesia | Compliant | ||||
| CV Venus Inti Perkasa |
CID002455 | Tin | Indonesia | Compliant | ||||
| Dowa |
CID000402 | Tin | Japan | Compliant | ||||
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
CID002572 | Tin | Viet Nam | Active | ||||
| Elmet S.L.U. |
CID002774 | Tin | Spain | Compliant | ||||
| EM Vinto |
CID000438 | Tin | Bolivia | Compliant | ||||
| Estanho de Rondônia S.A. |
CID000448 | Tin | Brazil | Outreach Required | ||||
| Fenix Metals |
CID000468 | Tin | Poland | Compliant | ||||
| Gejiu Fengming Metallurgy Chemical Plant |
CID002848 | Tin | China | Compliant | ||||
| Gejiu Jinye Mineral Company |
CID002859 | Tin | China | Compliant | ||||
| Gejiu Kai Meng Industry and Trade LLC |
CID000942 | Tin | China | Active | ||||
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CID000538 | Tin | China | Compliant | ||||
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CID001908 | Tin | China | Active | ||||
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
CID000555 | Tin | China | In Communication | ||||
| Guanyang Guida Nonferrous Metal Smelting Plant |
CID002849 | Tin | China | Compliant | ||||
| HuiChang Hill Tin Industry Co., Ltd. |
CID002844 | Tin | China | Compliant | ||||
| Huichang Jinshunda Tin Co. Ltd |
CID000760 | Tin | China | Active | ||||
| Jiangxi Ketai Advanced Material Co., Ltd. |
CID000244 | Tin | China | Compliant | ||||
| Magnu’s Minerais Metais e Ligas Ltda. |
CID002468 | Tin | Brazil | Compliant | ||||
| Malaysia Smelting Corporation (MSC) |
CID001105 | Tin | Malaysia | Compliant | ||||
| Melt Metais e Ligas S.A. |
CID002500 | Tin | Brazil | Compliant | ||||
| Metallic Resources, Inc. |
CID001142 | Tin | United States | Compliant | ||||
| Metallo-Chimique N.V. |
CID002773 | Tin | Belgium | Compliant | ||||
| Mineração Taboca S.A. |
CID001173 | Tin | Brazil | Compliant | ||||
| Minsur |
CID001182 | Tin | Peru | Compliant | ||||
| Mitsubishi Materials Corporation |
CID001191 | Tin | Japan | Compliant | ||||
| Modeltech Sdn Bhd |
CID002858 | Tin | Malaysia | Active |
A-7
| Nankang Nanshan Tin Co., Ltd. |
CID001231 | Tin | China | Active | ||||
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
CID002573 | Tin | Viet Nam | Outreach Required | ||||
| O.M. Manufacturing (Thailand) Co., Ltd. |
CID001314 | Tin | Thailand | Compliant | ||||
| O.M. Manufacturing Philippines, Inc. |
CID002517 | Tin | Philippines | Compliant | ||||
| Operaciones Metalurgical S.A. |
CID001337 | Tin | Bolivia | Compliant | ||||
| PT Aries Kencana Sejahtera |
CID000309 | Tin | Indonesia | Compliant | ||||
| PT Artha Cipta Langgeng |
CID001399 | Tin | Indonesia | Compliant | ||||
| PT ATD Makmur Mandiri Jaya |
CID002503 | Tin | Indonesia | Compliant | ||||
| PT Babel Inti Perkasa |
CID001402 | Tin | Indonesia | Compliant | ||||
| PT Bangka Prima Tin |
CID002776 | Tin | Indonesia | Compliant | ||||
| PT Bangka Tin Industry |
CID001419 | Tin | Indonesia | Compliant | ||||
| PT Belitung Industri Sejahtera |
CID001421 | Tin | Indonesia | Compliant | ||||
| PT Bukit Timah |
CID001428 | Tin | Indonesia | Compliant | ||||
| PT Cipta Persada Mulia |
CID002696 | Tin | Indonesia | Compliant | ||||
| PT DS Jaya Abadi |
CID001434 | Tin | Indonesia | Compliant | ||||
| PT Eunindo Usaha Mandiri |
CID001438 | Tin | Indonesia | Compliant | ||||
| PT Inti Stania Prima |
CID002530 | Tin | Indonesia | Compliant | ||||
| PT Karimun Mining |
CID001448 | Tin | Indonesia | Compliant | ||||
| PT Kijang Jaya Mandiri |
CID002829 | Tin | Indonesia | Compliant | ||||
| PT Menara Cipta Mulia |
CID002835 | Tin | Indonesia | Compliant | ||||
| PT Mitra Stania Prima |
CID001453 | Tin | Indonesia | Compliant | ||||
| PT O.M. Indonesia |
CID002757 | Tin | Indonesia | Compliant | ||||
| PT Panca Mega Persada |
CID001457 | Tin | Indonesia | Compliant | ||||
| PT Prima Timah Utama |
CID001458 | Tin | Indonesia | Compliant | ||||
| PT Refined Bangka Tin |
CID001460 | Tin | Indonesia | Compliant | ||||
| PT Sariwiguna Binasentosa |
CID001463 | Tin | Indonesia | Compliant | ||||
| PT Stanindo Inti Perkasa |
CID001468 | Tin | Indonesia | Compliant | ||||
| PT Sukses Inti Makmur |
CID002816 | Tin | Indonesia | Compliant | ||||
| PT Sumber Jaya Indah |
CID001471 | Tin | Indonesia | Compliant | ||||
| PT Timah (Persero) Tbk Kundur |
CID001477 | Tin | Indonesia | Compliant | ||||
| PT Timah (Persero) Tbk Mentok |
CID001482 | Tin | Indonesia | Compliant | ||||
| PT Tinindo Inter Nusa |
CID001490 | Tin | Indonesia | Compliant | ||||
| PT Tommy Utama |
CID001493 | Tin | Indonesia | Compliant | ||||
| PT WAHANA PERKIT JAYA |
CID002479 | Tin | Indonesia | Compliant | ||||
| Resind Indústria e Comércio Ltda. |
CID002706 | Tin | Brazil | Compliant | ||||
| Rui Da Hung |
CID001539 | Tin | Taiwan | Compliant | ||||
| Soft Metais Ltda. |
CID001758 | Tin | Brazil | Compliant | ||||
| Thaisarco |
CID001898 | Tin | Thailand | Compliant | ||||
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
CID002574 | Tin | Viet Nam | Outreach Required | ||||
| VQB Mineral and Trading Group JSC |
CID002015 | Tin | Viet Nam | Compliant | ||||
| White Solder Metalurgia e Mineração Ltda. |
CID002036 | Tin | Brazil | Compliant |
A-8
| Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. |
CID002158 | Tin | China | Active | ||||
| Yunnan Tin Group (Holding) Company Limited |
CID002180 | Tin | China | Compliant | ||||
| A.L.M.T. Corp. |
CID000004 | Tungsten | Japan | Compliant | ||||
| ACL Metais Eireli |
CID002833 | Tungsten | Brazil | Outreach Required | ||||
| Asia Tungsten Products Vietnam Ltd. |
CID002502 | Tungsten | Viet Nam | Compliant | ||||
| Chenzhou Diamond Tungsten Products Co., Ltd. |
CID002513 | Tungsten | China | Compliant | ||||
| Chongyi Zhangyuan Tungsten Co., Ltd. |
CID000258 | Tungsten | China | Compliant | ||||
| Fujian Jinxin Tungsten Co., Ltd. |
CID000499 | Tungsten | China | Compliant | ||||
| Ganzhou Haichuang Tungsten Industry Co., Ltd. |
CID002645 | Tungsten | China | Outreach Required | ||||
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
CID000875 | Tungsten | China | Compliant | ||||
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CID002315 | Tungsten | China | Compliant | ||||
| Ganzhou Seadragon W & Mo Co., Ltd. |
CID002494 | Tungsten | China | Compliant | ||||
| Ganzhou Yatai Tungsten Co., Ltd. |
CID002536 | Tungsten | China | Non-Compliant | ||||
| Global Tungsten & Powders Corp. |
CID000568 | Tungsten | United States | Compliant | ||||
| Guangdong Xianglu Tungsten Co., Ltd. |
CID000218 | Tungsten | China | Compliant | ||||
| H.C. Starck Smelting GmbH & Co. KG |
CID002542 | Tungsten | Germany | Compliant | ||||
| H.C. Starck Tungsten GmbH |
CID002541 | Tungsten | Germany | Compliant | ||||
| Hunan Chenzhou Mining Co., Ltd. |
CID000766 | Tungsten | China | Compliant | ||||
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CID002579 | Tungsten | China | Compliant | ||||
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
CID000769 | Tungsten | China | Compliant | ||||
| Hydrometallurg, JSC |
CID002649 | Tungsten | Russian Federation | Compliant | ||||
| Japan New Metals Co., Ltd. |
CID000825 | Tungsten | Japan | Compliant | ||||
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CID002551 | Tungsten | China | Compliant | ||||
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CID002647 | Tungsten | China | Outreach Required | ||||
| Jiangxi Gan Bei Tungsten Co., Ltd. |
CID002321 | Tungsten | China | Compliant | ||||
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
CID002313 | Tungsten | China | Outreach Required | ||||
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CID002318 | Tungsten | China | Compliant | ||||
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CID002317 | Tungsten | China | Compliant | ||||
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
CID002535 | Tungsten | China | Compliant | ||||
| Jiangxi Yaosheng Tungsten Co., Ltd. |
CID002316 | Tungsten | China | Compliant | ||||
| Kennametal Fallon |
CID000966 | Tungsten | United States | Compliant |
A-9
| Kennametal Huntsville |
CID000105 | Tungsten | United States | Compliant | ||||
| Malipo Haiyu Tungsten Co., Ltd. |
CID002319 | Tungsten | China | Compliant | ||||
| Moliren Ltd |
CID002845 | Tungsten | Russian Federation | Compliant | ||||
| Niagara Refining LLC |
CID002589 | Tungsten | United States | Compliant | ||||
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
CID002543 | Tungsten | Viet Nam | Compliant | ||||
| Philippine Chuangxin Industrial Co., Inc. |
CID002827 | Tungsten | Philippines | Compliant | ||||
| South-East Nonferrous Metal Company Limited of Hengyang City |
CID002815 | Tungsten | China | Compliant | ||||
| Tejing (Vietnam) Tungsten Co., Ltd. |
CID001889 | Tungsten | Viet Nam | Compliant | ||||
| Unecha Refractory Metals Plant |
CID002724 | Tungsten | Russian Federation | Compliant | ||||
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
CID002011 | Tungsten | Viet Nam | Compliant | ||||
| Wolfram Bergbau und Hütten AG |
CID002044 | Tungsten | Austria | Compliant | ||||
| Woltech Korea Co., Ltd. |
CID002843 | Tungsten | Korea, Republic of | Compliant | ||||
| Xiamen Tungsten (H.C.) Co., Ltd. |
CID002320 | Tungsten | China | Compliant | ||||
| Xiamen Tungsten Co., Ltd. |
CID002082 | Tungsten | China | Compliant | ||||
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CID002830 | Tungsten | China | Compliant | ||||
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CID002095 | Tungsten | China | Compliant |
A-10