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, 2022. |
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:
http://aka.ms/conflictmineralreport
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 27, 2023 |
/s/ BRADFORD L. SMITH | |
| Bradford L. Smith | ||
| Vice Chair and President | ||
Exhibit 1.01
MICROSOFT CORPORATION
CONFLICT MINERALS REPORT
FOR 2022 REPORTING YEAR
Contents
| I. | Introduction | 2 | ||||||||
| II. | Due Diligence Framework | 2 | ||||||||
| OECD Step #1: Establish Strong Company Management Systems | 3 | |||||||||
| 1. | Company Policies | 3 | ||||||||
| 2. | Internal Management Team and Corporate Approval | 4 | ||||||||
| 3. | System of Supply Chain Controls, Data Disclosure, and Due Diligence Assurance | 4 | ||||||||
| 4. | Leveraging Industry Partnerships for Greater Impact | 5 | ||||||||
| 5. | Supplier Engagement to Ensure Conformance | 6 | ||||||||
| 6. | Grievance Mechanism | 7 | ||||||||
| OECD Step #2: Identify and Assess Risk in the Supply Chain | 7 | |||||||||
| Figure 1. CMRT Response Rate (2013-2022 Reporting Years) | 8 | |||||||||
| OECD Step #3: Design and Implement a Strategy to Respond to Risks | 8 | |||||||||
| 7. | Microsoft Supplier Specifications—H00594, H00642, and H02050 | 8 | ||||||||
| 8. | Implementation of OECD Guidance | 9 | ||||||||
| OECD Step #4: Independent Third-Party Audits of Supply Chain Due Diligence | 9 | |||||||||
| OECD Step #5: Report on Supply Chain Due Diligence | 9 | |||||||||
| III. | Conflict Mineral Disclosure | 10 | ||||||||
| Reasonable Countries of Origin of 3TGs | 10 | |||||||||
| Figure 2. Identified SORs by Audit Status (2013- 2022 Reporting Years) | 11 | |||||||||
| 3TG Countries of Origin | 12 | |||||||||
| IV. | Microsoft Commitment | 13 | ||||||||
| Appendix A: Eligible Smelters and Refiners for 2022 Reporting Year | A-1 | |||||||||
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| I. | Introduction |
This Conflict Minerals Report (“CMR”) for MICROSOFT CORPORATION (“Microsoft”) is filed with the United States Securities and Exchange Commission (SEC) as an exhibit to Microsoft’s Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, (the “Rule”) for the 2022 Reporting Year (“RY”) (January 1, 2022-December 31, 2022).1 The CMR covers all Microsoft majority-owned subsidiaries and variable interest entities that are subject to the Rule.2 During the 2022 Reporting Year, covered devices included the Surface line of computers, tablets, mobile phones, and accessories; Xbox gaming consoles and accessories; personal computing accessories (mice, headsets, and keyboards); and HoloLens mixed reality device.
Our commitment to the responsible sourcing of raw materials is established by Microsoft’s Responsible Sourcing of Raw Materials (“RSRM”) Policy, which guides our work to ensure that all raw materials used in our devices, unbounded by specific materials or locations, are sourced from responsible suppliers. We commit to the responsible sourcing of tin, tantalum, tungsten and gold (“3TGs”) from Conflict Affected and High-Risk Areas (“CAHRAs”), including the Democratic Republic of the Congo (“DRC”) or DRC-adjoining countries (each a “Covered Country” under the Rule), rather than restricting or avoiding sourcing from such regions. We do this in in recognition of the harmful societal and economic impacts that curtailing 3TG mineral sourcing from such regions might cause.
Based on our supply chain due diligence, we determined that 3TGs that were necessary to the functionality or production of devices we manufactured or contracted to manufacture during the 2022 Reporting Year may have originated in a Covered Country.
| II. | Due Diligence Framework |
This CMR is based on Microsoft Devices’ Due Diligence Framework (“Due Diligence Framework”), which conforms to 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 and its related Supplements (“OECD Guidance”).
| 1 | This CMR contains links to internal and external websites for informational purposes only. References to such websites and information available through such websites are not incorporated into this CMR. Additionally, this CMR includes forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These forward- looking statements are based on current expectations and assumptions regarding the future implementation of our responsible sourcing program and are subject to change. Statements in this CMR are based on due diligence activities that were performed in good faith and to the best of our ability at the time of this filing. Factors that could affect the accuracy of such statements include, but are not limited to, incomplete or incorrect data submitted by suppliers, amendments to the Rule or SEC guidance. |
| 2 | Throughout this CMR, we use “Microsoft,” “Microsoft Devices,” “we,” “our,” “us” and similar terms to refer to Microsoft Corporation and its subsidiaries and various interest entities subject to the Rule (collectively, “Microsoft”), unless otherwise indicated. |
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Our Devices supply chain contains many layers of upstream suppliers positioned between Microsoft and 3TG raw material mines and Smelters or Refiners (“SORs”). We use contractual provisions to require our direct suppliers to disclose 3TG sourcing information through the industry standard Conflict Mineral Reporting Template (CMRT) and meet audit requirements regarding the sources and chains of custody of 3TGs necessary for the functionality or production of our covered devices. We also require our direct suppliers to cascade down Microsoft requirements regarding 3TG sources and chains of custody to their own suppliers. In this manner, we work to promote responsible sourcing across our direct and indirect supply chains.
Our due diligence actions go beyond the Rule and OECD Guidance by including several quality assurance steps. We review all supplier responses to identify and address any inaccuracies or inconsistencies in the 3TG sourcing data that is reported to us. We engage a third party to review all 3TG sourcing data reported to us, to conduct enhanced research and due diligence on identified SORs. If a non-conformant SOR is reported by a supplier, we work with the supplier to engage with the SOR to bring them into conformance. If the SOR is not interested or not able to become conformant, we instruct suppliers to remove the SOR from their supply chain and source from conformant alternatives or face business termination with Microsoft.
We also survey our supply chain for minerals beyond 3TGs and beyond the Covered Countries consistent with our RSRM Policy, which is unbounded by specific materials or location. In addition to the CMRT survey, which is focused on 3TGs, we require our in-scope suppliers to report on their use of cobalt and other priority minerals, including aluminum, copper, gallium, lithium, nickel, silicon, and rare earth elements.
OECD Step #1: Establish Strong Company Management Systems
| 1. | Company Policies |
Microsoft’s commitment to corporate responsibility and integrity guides everything we do as a company. We have established high ethical standards to govern the way we conduct our business, which also apply to our suppliers and business partners. Microsoft policies include the Microsoft Global Human Rights Statement, Microsoft Supply Chain Human Rights Policy Statement, Trust Code, and our Supplier Code of Conduct. These policies establish Microsoft expectations for our suppliers concerning legal and regulatory compliance; business practices and ethics; human rights and fair labor practices; health and safety; environmental protection; and data and privacy protection.
As previously described, our RSRM Policy describes our commitment to responsibly source raw materials. This pledge extends to the harvesting, extraction, and transportation of raw materials, unbounded by specific material or location, and supports implementation of programs that advance the use of responsibly sourced minerals in our manufactured devices
Our policies are based on internationally recognized standards, including the following declaration and covenants: Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, and International Covenant on Economic, Social and Cultural Rights. Our business operations
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are informed by human rights guidelines described in the following documents: International Labour Organization’s (“ILO”) Declaration on Fundamental Principles and Rights at Work, OECD Guidelines for Multinational Enterprises, and the United Nations Global Compact. As a global Information and Communications Technology company operating in more than 100 countries, we respect all human rights - civil, political, economic, social, and cultural; and our supplier requirements expect the same level of commitment.
| 2. | Internal Management Team and Corporate Approval |
A cross-functional internal team supports CMR development. Microsoft’s Senior Director of Devices Responsible Sourcing sponsors the team, which consists of representatives from Devices Manufacturing and Sourcing; Responsible Sourcing; Corporate, External and Legal Affairs; Information Services; Product Environmental Compliance; Global Trade; Finance; and Public Relations. The team assesses program progress, identifies steps needed to meet our compliance obligations, and identifies areas for continuous improvement. The team annually develops, reviews, and submits the final CMR to Microsoft’s President for approval and signature before being filed as an Exhibit to Microsoft’s Form SD and posted on the Microsoft website pursuant to the Rule.
| 3. | System of Supply Chain Controls, Data Disclosure, and Due Diligence Assurance |
Our Due Diligence Framework is based on a system of supply chain controls, data disclosure, and due diligence assurance. Our contracts require our suppliers to meet Microsoft specifications. Our environmental compliance specifications - H00594, Restricted Substances for Hardware Products; and H00642, Microsoft Restricted Substances Control System for Hardware Products (both available at this link) - require the disclosure of every substance contained in the materials, components, and products supplied to us, including 3TGs, by weight.
We require suppliers to annually submit a CMRT, providing source and chain of custody information for 3TGs that are contained in the products and components they supply to us. Our contracts also require suppliers to obtain the same information from their upstream suppliers. We collect these supply chain disclosures, conduct controls to ensure data integrity, and assess 3TG sourcing risk.
Microsoft supply chain mineral disclosure requirements go beyond 3TGs and cover additional prioritized minerals. Since 2019, we have required suppliers to report on their use of cobalt, using the Responsible Minerals Initiative’s Extended Minerals Reporting Template (“EMRT”). In 2020, we expanded our due diligence requirements and began collecting data on aluminum, copper, lithium, magnesium, and nickel using the Microsoft Material Reporting Template (“MMRT”). In 2022, we worked with the Responsible Minerals Initiative (“RMI”) to develop a common industry standard template to facilitate the gathering of data on additional minerals beyond 3TG, and cobalt. RMI’s new Pilot Reporting Template (“PRT”) has replaced our MMRT for RY 2022.
Further, in 2022, we completed a regular minerals prioritization exercise, whereby we redefined and expanded the scope of our data collection beyond 3TG and cobalt to include aluminum, copper, gallium, lithium, nickel, silicon, and rare earth elements. These additional materials are prioritized
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through an extensive internal review and risk analysis of the materials present in our products. This regular prioritization exercise ensures that the materials on which we focus are representative of identified need, and thus this list is dynamic over time. For example, in RY 2022 we added gallium, silicon, and rare earth elements to our priority list; meanwhile, we removed magnesium from our priority list as its risk profile – including the level of consumption of the material – had decreased year-on-year.
Microsoft Devices’ Supplier Social and Environmental Accountability Manual (“H02050”) provides an operational framework for Microsoft to achieve supplier conformance with Microsoft’s Supplier Code of Conduct and other responsible sourcing requirements. H02050 establishes a minimum set of requirements that suppliers must meet, including compliance with all applicable laws and regulations with respect to labor, ethics, occupational health and safety, and protection of the environment. Suppliers are encouraged to go beyond legal compliance by meeting relevant international standards
(e.g., ILO and relevant United Nations Conventions) and committing to a process of continuous improvement.
H02050 requires all in-scope suppliers to:
| • | Adopt a company policy for raw material sourcing, including a commitment to source raw materials from responsible sources and clearly communicate such policy to their suppliers and the public; |
| • | Exercise due diligence on the source and chain of custody of high-risk raw materials, including 3TGs, contained in materials, products, or parts supplied to Microsoft; |
| • | Require SORs to participate in the Responsible Mining Assurance Process (“RMAP”) or an equivalent independent, third-party audit program for 3TGs; and |
| • | Timely communicate potential sourcing risks to Microsoft and propose a contingency plan and mitigation strategy to achieve conformance. |
| • | Establish a system to gather, examine, and verify sourcing information for raw materials, including 3TGs, contained in products supplied to Microsoft and request their upstream suppliers to do the same. This supply chain transfer of audit data, source and chain of custody information, and risk assessment enables and facilitates raw material due diligence, mapping, and transparency. |
Microsoft works with its suppliers to use SORs that are conformant to RMAP or another equivalent independent, third-party audit program for 3TGs. If we find that a supplier has introduced responsible sourcing risk to the Microsoft supply chain, such as use of an upstream SOR that is not conformant, Microsoft engages with such supplier to address the non-conformance. Risks are mitigated by supplier engagement, corrective actions, audits, training, and business termination when appropriate. These controls and related documentation are detailed in H02050 and Microsoft internal operating procedures.
| 4. | Leveraging Industry Partnerships for Greater Impact |
We leverage partnerships with industry peers and partners to scale our responsible sourcing impact. Microsoft is a long-standing member of the Responsible Business Alliance (“RBA”) and the RMI. The
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RMI is one of the most utilized and respected resources for supply chain minerals due diligence and is aligned to the OECD Guidance. The RMI operates and manages the RMAP, which uses independent, third-party audits to assess, monitor, and validate whether SORs process 3TGs from sources that directly or indirectly finance or benefit armed groups in a CAHRA, including Covered Countries.
In 2022, Microsoft provided direct financial support to the RMI upstream smelter due diligence fund to further the reach and success of the RMAP. Microsoft also supported the development of a new RMI minerals reporting template, known as the PRT, which provides a common, industry standard tool for the collection of mineral supply chain data on any mineral outside the scope of either the CMRT or EMRT. This new reporting template will help suppliers disclose data on a broader range of critical minerals, aligning with Microsoft’s expanded supply chain disclosure requirements for aluminum, copper, gallium, lithium, nickel, silicon, and rare earth elements.
We also work outside of our supply chain to promote responsible mining practices in CAHRAs, including Covered Countries, by partnering with organizations, including the RMI, the Initiative for Responsible Mining Assurance (“IRMA”), the Public-Private Alliance for Responsible Minerals Trade (“PPA”), and others. In this manner, we go beyond the minimum due diligence established by the OECD Guidance to assess and reduce our supply chain sourcing risk and improve working conditions in raw material supply chains.
| 5. | Supplier Engagement to Ensure Conformance |
We apply several supplier-focused strategies to promote responsible mining and sourcing, including the supplier engagement tools set forth below.
| • | Supplier Requirements: We require our suppliers to meet our material disclosure requirements and related responsible sourcing policies through contractual provisions and product specifications. We communicate, monitor, and track supplier adherence to these requirements, ensuring conformance through the Microsoft Audit Management System (“AMS”). |
| • | Training: We train suppliers on our responsible sourcing requirements through classes, educational forums, and direct communications. The “SEA Academy” is part of the supplier on-boarding process. Existing suppliers and newly onboarded suppliers are required to complete training modules to understand and implement Microsoft Social and Environmental Accountability (“SEA”) requirements. We leverage the online component of our SEA Academy to educate factory management, workers, and third-party auditors as well as internal Microsoft teams with the goal of promoting responsible sourcing across our supply chain. |
| • | Capability Building and Partnerships: We work closely with in-scope suppliers and third-party auditors to build suppliers’ raw material due diligence capabilities and advance conformance to the RMAP or equivalent independent, third-party audit program for 3TGs. We invest in industry programs to increase suppliers’ abilities and provide platforms for sharing best practices. |
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| • | Supplier Audits and Conformance Assurance: Microsoft requires audits of its directly contracted suppliers to assess their conformance to these requirements. Newly contracted suppliers undergo an Initial Capability Assessment prior to onboarding and Sustaining Maintenance Audits after onboarding to verify their initial conformance and to confirm their sustained conformance to our requirements. |
Microsoft selects and retains business partners that have committed to meet these requirements. A failure by a supplier or their upstream suppliers to conform to these requirements may constitute a breach of the supplier’s contractual agreement with Microsoft, resulting in possible business termination.
| 6. | Grievance Mechanism |
Microsoft provides an anonymous grievance reporting mechanism for 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 responsible sourcing policies or those of our suppliers. Additionally, Microsoft continues to scale its Worker Voice Hotline Program3 across our supplier factories. This program provides workers with a reliable and anonymous reporting channel for raising workplace concerns. The Hotline is operated by a neutral third-party provider. We investigate and, where appropriate, take remedial action to address reported issues. We also participate in the development of industry grievance mechanisms that seek to address responsible sourcing of raw materials-related issues.
OECD Step #2: Identify and Assess Risk in the Supply Chain
In order to make a Reasonable Country of Origin Inquiry (“RCOI”) determination, Microsoft took the following steps, which are consistent with OECD Guidance and Microsoft procedure, to identify and assess 3TG sourcing risk in our supply chain during the 2022 RY:
| • | We generated a list of in-scope suppliers by surveying 186 Devices direct suppliers to determine whether they used any 3TGs in the products or parts supplied to Microsoft by utilizing the CMRT and the services of a third-party solution provider. All in-scope suppliers responded to our survey request – a 100% response rate. |
| • | We excluded suppliers that did not report the use of 3TG minerals in the products or parts supplied to Microsoft during the 2022 RY from our in-scope supplier list. |
| 3 | Please see page 23 of our 2022 Devices Responsible Sourcing Report for more details regarding our Workers’ Voice Hotline Program. |
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| • | For the 2022 RY, we identified 186 in-scope suppliers that reported the use of 3TG minerals in the products or parts supplied to Microsoft. For these suppliers, we reviewed their CMRT responses to validate completion and to identify any contradictions or inconsistencies. |
| • | Based on the CMRTs, 342 SORs were found to be eligible for the RMAP or an equivalent, independent, third-party audit program for 3TG minerals such as cross-recognized programs overseen by the London Bullion Market Association (“LBMA”) or Responsible Jewellery Council (“RJC”). |
Figure 1. CMRT Response Rate (2013-2022 Reporting Years)
OECD Step #3: Design and Implement a Strategy to Respond to Risks
We determined that 3TGs that were necessary to the functionality or production of covered devices may have originated in one or more Covered Country. Accordingly, we performed due diligence on the source and chain-of-custody of those 3TGs to assess our conflict minerals sourcing risk.
| 7. | Microsoft Supplier Specifications—H00594, H00642, and H02050 |
For the 2022 RY, Microsoft required its in-scope suppliers to conduct due diligence to address the potential sourcing of 3TGs from CAHRAs, including Covered Countries, through contract requirements (H00594, H00642, and H02050), incorporating Microsoft’s supplier specifications and responsible sourcing requirements, as detailed above.
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| 8. | Implementation of OECD Guidance |
Microsoft screened its in-scope supplier CMRT data for the 2022 RY against the OECD Guidance” red flag” triggers4 to assess the in-scope suppliers that required due diligence per the OECD Guidance.
OECD Step #4: Independent Third-Party Audits of Supply Chain Due Diligence
Our due diligence program leveraged independent SOR audits to provide assurance that the 342 Eligible 3TG SORs that were identified in our supply chain for the 2022 Reporting Year conducted an appropriate level of conflict minerals due diligence. Microsoft obtained SOR data from the RMAP Conformant Smelter List5 using Reasonable Country of Origin Inquiry Data for member MSFT and used the SOR data to assess the conflict mineral audit status of our in-scope suppliers and to support our due diligence findings.
Recognizing the importance of broad and consistent participation in the RMAP, Microsoft proactively engages directly with certain SORs where it is believed that a SOR may be at risk of becoming non-conformant. Microsoft also asks its suppliers to engage directly with potentially non-conformant SORs in order to prevent potential non-conformance and to develop Corrective Action Plans (“CAPs”) to identify sourcing alternatives in case a SOR becomes non-conformant.
Although Microsoft’s Responsible Sourcing program operates an escalation and engagement process should non-conformant SORs be detected, taking a proactive approach to potentially non-conformant SORs helps prevent potential non-conformances from occurring. During the 2022 RY, we did not identify a SOR non-conformance that supported business termination with any in-scope supplier.
OECD Step #5: Report on Supply Chain Due Diligence
We have filed our CMR with the SEC and posted it on our Microsoft Devices Responsible Sourcing website. The results of our Responsible Sourcing program are also presented in Microsoft’s FY22 Devices Responsible Sourcing Report. The Microsoft Corporate Social Responsibility Responsible Sourcing website provides additional information about Microsoft’s RSRM Program. Each year, Microsoft Devices publishes a list of its Top 100 Production Suppliers. These disclosures meet the fifth step of the OECD Guidance.
| 4 | See p. 33 of the OECD Guidance. |
| 5 | The RMAP Conformant Smelter list identifies the SORs that have undergone conformance audits through the RMAP or equivalent independent, third-party audit programs for 3TGs. |
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| III. | Conflict Mineral Disclosure |
| A. | Reasonable Countries of Origin of 3TGs |
Microsoft obtained Reasonable Country of Origin data through our membership in the RMAP using the Reasonable Country of Origin Inquiry Data for member MSFT. We used this data to determine the 3TG country of origin for the 342 Eligible SORs identified in Microsoft Devices’ supply chain for the 2022 RY.
The RMAP classifies SOR audit status in the manner described in the table below. The breakdown of the identified 342 Eligible 3TG SORs (for which minerals sourcing information was available from RMAP or an equivalent, independent, third-party audit program for 3TGs) by their RMI Status was as follows:
| Audit Status |
Audit Status Description |
SORs | % | |||||||
| Conformant |
SOR has been audited and found to conform with a relevant, third- party audit protocol, including RMAP, LBMA, or RJC | 221 | 64.6 | % | ||||||
| Active |
SOR has been engaged but is not yet conformant | 9 | 2.6 | % | ||||||
| Non-Conformant |
SOR was audited but found not to conform to a relevant, third-party audit protocol or failed to renew its assessment | 24 | 7.0 | % | ||||||
| Communication Suspended | Not Interested: SOR has strongly communicated a lack of interest in participation | 6 | 1.8 | % | ||||||
| Outreach Required | SOR is not yet active and outreach is needed by RMAP member companies to encourage SOR participation in RMAP | 46 | 13.5 | % | ||||||
| In Communication | SOR is not yet active but is in communication with RMAP and/or member company | 14 | 4.1 | % | ||||||
| RMI Due Diligence Review | Unable to Proceed: SOR has not met the threshold for Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted | 22 | 6.4 | % | ||||||
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For the identified 342 Eligible 3TG SORs –
| • | 67 SORs sourced from Covered Countries, of which 59 (88%) were Conformant. For these 67 SORs, the audit status per 3TG mineral was: |
| • | 72.7% Conformant for Gold; |
| • | 100% Conformant for Tantalum; |
| • | 93.8% Conformant for Tungsten; and |
| • | 75.0% Conformant and 6.2% Active status for Tin. |
| • | Out of 342 Eligible SORs, 221 (64.6%) were Conformant; and |
| • | Out of 342 Eligible SORs, 316 (92.4%) were Conformant, Active, or are reasonably believed to have sourced 3TGs from outside the Covered Countries. |
Figure 2 depicts the 342 SORs by 3TG audit status and Reporting Year.
Figure 2. Identified SORs by Audit Status (2013- 2022 Reporting Years)
Appendix A provides the list of 342 Eligible SORs identified in Microsoft Devices’ supply chain which processed 3TGs during the 2022 Reporting Year. Appendix A lists each SOR by mineral, official name, and country of operation.
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3TG Countries of Origin
The table below lists the countries of origin for the 342 Eligible SORs identified in Microsoft Devices’ supply chain which processed 3TG minerals during the 2022 RY.
| Argentina | Guatemala | Peru | ||
| Armenia | Guinea | Philippines | ||
| Australia | Guyana | Poland | ||
| Austria | Honduras | Portugal | ||
| Azerbaijan | India | Russian Federation | ||
| Benin | Indonesia | Rwanda | ||
| Bolivia | Italy | Saudi Arabia | ||
| Botswana | Japan | Senegal | ||
| Brazil | Kazakhstan | Serbia | ||
| Burkina Faso | Kenya | Sierra Leone | ||
| Burundi | Kyrgyzstan | Slovakia | ||
| Cambodia | Laos | South Africa | ||
| Canada | Liberia | Spain | ||
| Chile | Madagascar | Sudan | ||
| China | Malaysia | Suriname | ||
| Colombia | Mali | Swaziland | ||
| Congo, Democratic Republic | Mauritania | Sweden | ||
| Congo, Republic | Mexico | Taiwan | ||
| Cote d’Ivoire | Mongolia | Tajikistan | ||
| Dominican Republic | Morocco | Tanzania | ||
| Ecuador | Mozambique | Thailand | ||
| Egypt | Myanmar | Turkey | ||
| Eritrea | Namibia | Uganda | ||
| Ethiopia | New Zealand | United Kingdom | ||
| Fiji | Nicaragua | United States | ||
| Finland | Niger | Uzbekistan | ||
| France | Nigeria | Venezuela | ||
| Incl. French Guiana |
Oman | Viet Nam | ||
| Georgia | Panama | Zambia | ||
| Ghana | Papua New Guinea | Zimbabwe |
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| IV. | Microsoft Commitment |
Microsoft is committed to the responsible sourcing of raw materials in support of human rights; labor, health and safety; and environmental protection. We continue to advance implementation of our RSRM policy in our Devices supply chain to promote supply chain identification, traceability, risk assessment, and due diligence.
Our 2022 RY achievements included the following:
| • | We supported supplier efforts to increase their responsible sourcing capabilities through supplier forums, training, webinars, and by providing technical resources; |
| • | We continued our engagements with external responsible sourcing organizations, including but not limited to the RMI, that are committed to advancing responsible sourcing on a global basis; |
| • | We achieved a 100% supplier CMRT response rate through extensive supplier outreach, including a supplementary campaign to directly contact suppliers to encourage reporting; |
| • | We conducted a data validation and verification program to randomly audit CMRT information submitted to us by suppliers to validate and confirm that supplier data was accurate and complete; |
| • | We supported the efforts of the RMI in developing the Pilot Reporting Template (“PRT”), released in late 2022, which provides a platform to collect data on all minerals, thus significantly expanding the scope of industry-wide minerals due diligence; |
| • | We expanded due diligence program across all in-scope suppliers to capture sourcing data on additional priority minerals including aluminum, cobalt, copper, gallium, lithium, nickel, silicon, and rare earth elements. |
Going forward, Microsoft will remain focused on internal and external efforts to promote the responsible sourcing of minerals, including:
| • | Expanding our knowledge about 3TGs, cobalt, and other critical raw materials to effectively implement our RSRM strategy to promote the responsible sourcing of raw materials across our hardware supply chains; |
| • | Requiring our in-scope suppliers to meet our requirements for responsibly sourcing raw materials and finding alternative upstream suppliers if they are found to be sourcing from non-conformant SORs; |
| • | Engaging with in-scope suppliers so that they utilize supplier best practices and tools for responsibly sourcing raw materials from CAHRAs, including Covered Countries; |
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| • | Furthering engagement with industry organizations and external stakeholders to improve mineral traceability, establish global responsible sourcing standards, and support due diligence programs in the mineral supply chain; |
| • | Leveraging Full Material Disclosure and other supplier data to fine-tune supplier data requests and verify and confirm reported critical raw material information. |
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Appendix A
Eligible SORs for 2022 Reporting Year
This Appendix lists the 342 Eligible SORs which processed 3TG minerals during the 2022 RY. Please note that Eligible SORs are listed for each 3TG they processed. Therefore, certain Eligible SORs may be represented more than once.
| Official Smelter Name |
Smelter Country | |
| Gold |
||
| 8853 S.p.A. | Italy | |
| ABC Refinery Pty Ltd. | Australia | |
| Abington Reldan Metals, LLC | United States of America | |
| Advanced Chemical Company | United States of America | |
| African Gold Refinery | Uganda | |
| Agosi AG | Germany | |
| Aida Chemical Industries Co., Ltd. | Japan | |
| Al Etihad Gold Refinery DMCC | United Arab Emirates | |
| Albino Mountinho Lda. | Portugal | |
| Alexy Metals | United States of America | |
| Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | |
| AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | |
| Argor-Heraeus S.A. | Switzerland | |
| Asahi Pretec Corp. | Japan | |
| Asahi Refining Canada Ltd. | Canada | |
| Asahi Refining USA Inc. | United States of America | |
| Asaka Riken Co., Ltd. | Japan | |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | |
| AU Traders and Refiners | South Africa | |
| Augmont Enterprises Private Limited | India | |
| Aurubis AG | Germany | |
| Bangalore Refinery | India | |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | |
| Boliden AB | Sweden | |
| C. Hafner GmbH + Co. KG | Germany | |
| C.I Metales Procesados Industriales SAS | Colombia | |
| Caridad | Mexico | |
| CCR Refinery - Glencore Canada Corporation | Canada | |
| Cendres + Metaux S.A. | Switzerland | |
| CGR Metalloys Pvt Ltd. | India | |
| Chimet S.p.A. | Italy | |
A-1
| Chugai Mining | Japan | |
| Daye Non-Ferrous Metals Mining Ltd. | China | |
| Degussa Sonne / Mond Goldhandel GmbH | Germany | |
| Dijllah Gold Refinery FZC | United Arab Emirates | |
| DODUCO Contacts and Refining GmbH | Germany | |
| Dongwu Gold Group | China | |
| Dowa | Japan | |
| DSC (Do Sung Corporation) | Korea, Republic of | |
| Eco-System Recycling Co., Ltd. East Plant | Japan | |
| Eco-System Recycling Co., Ltd. North Plant | Japan | |
| Eco-System Recycling Co., Ltd. West Plant | Japan | |
| Emerald Jewel Industry India Limited (Unit 1) | India | |
| Emerald Jewel Industry India Limited (Unit 2) | India | |
| Emerald Jewel Industry India Limited (Unit 3) | India | |
| Emerald Jewel Industry India Limited (Unit 4) | India | |
| Emirates Gold DMCC | United Arab Emirates | |
| Fidelity Printers and Refiners Ltd. | Zimbabwe | |
| Fujairah Gold FZC | United Arab Emirates | |
| Geib Refining Corporation | United States of America | |
| GGC Gujrat Gold Centre Pvt. Ltd. | India | |
| Gold by Gold Colombia | Colombia | |
| Gold Coast Refinery | Ghana | |
| Gold Refinery of Zijin Mining Group Co., Ltd. | China | |
| Great Wall Precious Metals Co., Ltd. of CBPM | China | |
| Guangdong Jinding Gold Limited | China | |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | |
| Hangzhou Fuchunjiang Smelting Co., Ltd. | China | |
| Heimerle + Meule GmbH | Germany | |
| Heraeus Germany GmbH Co. KG | Germany | |
| Heraeus Metals Hong Kong Ltd. | China | |
| Hunan Chenzhou Mining Co., Ltd. | China | |
| Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | |
| HwaSeong CJ CO., LTD. | Korea, Republic of | |
| Industrial Refining Company | Belgium | |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | |
| International Precious Metal Refiners | United Arab Emirates | |
| Ishifuku Metal Industry Co., Ltd. | Japan | |
| Istanbul Gold Refinery | Turkey | |
| Italpreziosi | Italy | |
| JALAN & Company | India | |
| Japan Mint | Japan | |
| Jiangxi Copper Co., Ltd. | China | |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | |
| JSC Novosibirsk Refinery | Russian Federation |
A-2
| JSC Uralelectromed | Russian Federation | |
| JX Nippon Mining & Metals Co., Ltd. | Japan | |
| K.A. Rasmussen | Norway | |
| Kaloti Precious Metals | United Arab Emirates | |
| Kazakhmys Smelting LLC | Kazakhstan | |
| Kazzinc | Kazakhstan | |
| Kennecott Utah Copper LLC | United States of America | |
| KGHM Polska Miedz Spolka Akcyjna | Poland | |
| Kojima Chemicals Co., Ltd. | Japan | |
| Korea Zinc Co., Ltd. | Korea, Republic of | |
| Kundan Care Products Ltd. | India | |
| Kyrgyzaltyn JSC | Kyrgyzstan | |
| Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | |
| L’azurde Company For Jewelry | Saudi Arabia | |
| Lingbao Gold Co., Ltd. | China | |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | |
| L’Orfebre S.A. | Andorra | |
| LS-NIKKO Copper Inc. | Korea, Republic of | |
| LT Metal Ltd. | Korea, Republic of | |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | |
| Marsam Metals | Brazil | |
| Materion | United States of America | |
| Matsuda Sangyo Co., Ltd. | Japan | |
| MD Overseas | India | |
| Metal Concentrators SA (Pty) Ltd. | South Africa | |
| Metallix Refining Inc. | United States of America | |
| Metalor Technologies (Hong Kong) Ltd. | China | |
| Metalor Technologies (Singapore) Pte., Ltd. | Singapore | |
| Metalor Technologies (Suzhou) Ltd. | China | |
| Metalor Technologies S.A. | Switzerland | |
| Metalor USA Refining Corporation | United States of America | |
| Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | |
| Mitsubishi Materials Corporation | Japan | |
| Mitsui Mining and Smelting Co., Ltd. | Japan | |
| MKS PAMP SA | Switzerland | |
| MMTC-PAMP India Pvt., Ltd. | India | |
| Modeltech Sdn Bhd | Malaysia | |
| Morris and Watson | New Zealand | |
| Moscow Special Alloys Processing Plant | Russian Federation | |
| Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | |
| Navoi Mining and Metallurgical Combinat | Uzbekistan | |
| NH Recytech Company | Korea, Republic of | |
| Nihon Material Co., Ltd. | Japan | |
| Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
A-3
| Ohura Precious Metal Industry Co., Ltd. | Japan | |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | |
| Pease & Curren | United States of America | |
| Penglai Penggang Gold Industry Co., Ltd. | China | |
| Planta Recuperadora de Metales SpA | Chile | |
| Prioksky Plant of Non-Ferrous Metals | Russian Federation | |
| PT Aneka Tambang (Persero) Tbk | Indonesia | |
| PX Precinox S.A. | Switzerland | |
| QG Refining, LLC | United States of America | |
| Rand Refinery (Pty) Ltd. | South Africa | |
| Refinery of Seemine Gold Co., Ltd. | China | |
| REMONDIS PMR B.V. | Netherlands | |
| Royal Canadian Mint | Canada | |
| SAAMP | France | |
| Sabin Metal Corp. | United States of America | |
| Safimet S.p.A | Italy | |
| SAFINA A.S. | Czechia | |
| Sai Refinery | India | |
| Samduck Precious Metals | Korea, Republic of | |
| Samwon Metals Corp. | Korea, Republic of | |
| Sancus ZFS (L’Orfebre, SA) | Colombia | |
| SAXONIA Edelmetalle GmbH | Germany | |
| Sellem Industries Ltd. | Mauritania | |
| SEMPSA Joyeria Plateria S.A. | Spain | |
| Shandong Gold Smelting Co., Ltd. | China | |
| Shandong Humon Smelting Co., Ltd. | China | |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | |
| Shenzhen CuiLu Gold Co., Ltd. | China | |
| Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | |
| Shirpur Gold Refinery Ltd. | India | |
| Sichuan Tianze Precious Metals Co., Ltd. | China | |
| Singway Technology Co., Ltd. | Taiwan | |
| SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | |
| Solar Applied Materials Technology Corp. | Taiwan | |
| Sovereign Metals | India | |
| State Research Institute Center for Physical Sciences and Technology | Lithuania | |
| Sudan Gold Refinery | Sudan | |
| Sumitomo Metal Mining Co., Ltd. | Japan | |
| SungEel HiMetal Co., Ltd. | Korea, Republic of | |
| Super Dragon Technology Co., Ltd. | Taiwan | |
| T.C.A S.p.A | Italy | |
| Tanaka Kikinzoku Kogyo K.K. | Japan | |
| Tokuriki Honten Co., Ltd. | Japan |
A-4
| Tongling Nonferrous Metals Group Co., Ltd. | China | |
| TOO Tau-Ken-Altyn | Kazakhstan | |
| Torecom | Korea, Republic of | |
| TSK Pretech | Korea, Republic of | |
| Umicore Brasil Ltda. | Brazil | |
| Umicore Precious Metals Thailand | Thailand | |
| Umicore S.A. Business Unit Precious Metals Refining | Belgium | |
| United Precious Metal Refining, Inc. | United States of America | |
| Valcambi S.A. | Switzerland | |
| Value Trading | Belgium | |
| WEEEREFINING | France | |
| Western Australian Mint (T/a The Perth Mint) | Australia | |
| WIELAND Edelmetalle GmbH | Germany | |
| Yamakin Co., Ltd. | Japan | |
| Yokohama Metal Co., Ltd. | Japan | |
| Yunnan Copper Industry Co., Ltd. | China | |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | |
| Tantalum |
||
| 5D Production OU | Estonia | |
| AMG Brasil | Brazil | |
| Asaka Riken Co., Ltd. | Japan | |
| Changsha South Tantalum Niobium Co., Ltd. | China | |
| D Block Metals, LLC | United States of America | |
| Exotech Inc. | United States of America | |
| F&X Electro-Materials Ltd. | China | |
| FIR Metals & Resource Ltd. | China | |
| Global Advanced Metals Aizu | Japan | |
| Global Advanced Metals Boyertown | United States of America | |
| Hengyang King Xing Lifeng New Materials Co., Ltd. | China | |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | |
| Jiangxi Tuohong New Raw Material | China | |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | |
| Jiujiang Tanbre Co., Ltd. | China | |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | |
| KEMET de Mexico | Mexico | |
| Materion Newton Inc. | United States of America | |
| Meta Materials | North Macedonia | |
| Metallurgical Products India Pvt., Ltd. | India | |
| Mineracao Taboca S.A. | Brazil | |
| Mitsui Mining and Smelting Co., Ltd. | Japan | |
| Ningxia Orient Tantalum Industry Co., Ltd. | China | |
| NPM Silmet AS | Estonia | |
A-5
| QSIL Metals Hermsdorf GmbH | Germany | |
| QuantumClean | United States of America | |
| Resind Industria e Comercio Ltda. | Brazil | |
| RFH Yancheng Jinye New Material Technology Co., Ltd. | China | |
| Solikamsk Magnesium Works OAO | Russian Federation | |
| Taki Chemical Co., Ltd. | Japan | |
| TANIOBIS Co., Ltd. | Thailand | |
| TANIOBIS GmbH | Germany | |
| TANIOBIS Japan Co., Ltd. | Japan | |
| TANIOBIS Smelting GmbH & Co. KG | Germany | |
| Telex Metals | United States of America | |
| Ulba Metallurgical Plant JSC | Kazakhstan | |
| XIMEI RESOURCES (GUANGDONG) LIMITED | China | |
| XinXing HaoRong Electronic Material Co., Ltd. | China | |
| Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | |
| Tin |
||
| Alpha | United States of America | |
| An Vinh Joint Stock Mineral Processing Company | Viet Nam | |
| Aurubis Beerse | Belgium | |
| Aurubis Berango | Spain | |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | |
| Chifeng Dajingzi Tin Industry Co., Ltd. | China | |
| China Tin Group Co., Ltd. | China | |
| CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | |
| CRM Synergies | Spain | |
| CV Ayi Jaya | Indonesia | |
| CV Venus Inti Perkasa | Indonesia | |
| Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | |
| Dowa | Japan | |
| DS Myanmar | Myanmar | |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | Viet Nam | |
| EM Vinto | Bolivia | |
| Estanho de Rondonia S.A. | Brazil | |
| Fabrica Auricchio Industria e Comercio Ltda. | Brazil | |
| Fenix Metals | Poland | |
| Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | |
| Gejiu Fengming Metallurgy Chemical Plant | China | |
| Gejiu Kai Meng Industry and Trade LLC | China | |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | |
| Gejiu Zili Mining And Metallurgy Co., Ltd. | China | |
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | |
A-6
| Guanyang Guida Nonferrous Metal Smelting Plant | China | |
| HuiChang Hill Tin Industry Co., Ltd. | China | |
| Huichang Jinshunda Tin Co., Ltd. | China | |
| Jiangxi New Nanshan Technology Ltd. | China | |
| Luna Smelter, Ltd. | Rwanda | |
| Ma’anshan Weitai Tin Co., Ltd. | China | |
| Magnu’s Minerais Metais e Ligas Ltda. | Brazil | |
| Malaysia Smelting Corporation (MSC) | Malaysia | |
| Melt Metais e Ligas S.A. | Brazil | |
| Metallic Resources, Inc. | United States of America | |
| Mineracao Taboca S.A. | Brazil | |
| Minsur | Peru | |
| Mitsubishi Materials Corporation | Japan | |
| Modeltech Sdn Bhd | Malaysia | |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | |
| Novosibirsk Tin Combine | Russian Federation | |
| O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | |
| O.M. Manufacturing Philippines, Inc. | Philippines | |
| Operaciones Metalurgicas S.A. | Bolivia | |
| Pongpipat Company Limited | Myanmar | |
| Precious Minerals and Smelting Limited | India | |
| PT Aries Kencana Sejahtera | Indonesia | |
| PT Artha Cipta Langgeng | Indonesia | |
| PT ATD Makmur Mandiri Jaya | Indonesia | |
| PT Babel Inti Perkasa | Indonesia | |
| PT Babel Surya Alam Lestari | Indonesia | |
| PT Bangka Prima Tin | Indonesia | |
| PT Bangka Serumpun | Indonesia | |
| PT Bangka Tin Industry | Indonesia | |
| PT Belitung Industri Sejahtera | Indonesia | |
| PT Bukit Timah | Indonesia | |
| PT Cipta Persada Mulia | Indonesia | |
| PT DS Jaya Abadi | Indonesia | |
| PT Masbro Alam Stania | Indonesia | |
| PT Menara Cipta Mulia | Indonesia | |
| PT Mitra Stania Prima | Indonesia | |
| PT Mitra Sukses Globalindo | Indonesia | |
| PT Panca Mega Persada | Indonesia | |
| PT Premium Tin Indonesia | Indonesia | |
| PT Prima Timah Utama | Indonesia | |
| PT Putera Sarana Shakti (PT PSS) | Indonesia | |
| PT Rajawali Rimba Perkasa | Indonesia | |
| PT Refined Bangka Tin | Indonesia | |
| PT Sariwiguna Binasentosa | Indonesia |
A-7
| PT Stanindo Inti Perkasa | Indonesia | |
| PT Sukses Inti Makmur | Indonesia | |
| PT Timah Nusantara | Indonesia | |
| PT Timah Tbk Kundur | Indonesia | |
| PT Timah Tbk Mentok | Indonesia | |
| PT Tinindo Inter Nusa | Indonesia | |
| PT Tirus Putra Mandiri | Indonesia | |
| PT Tommy Utama | Indonesia | |
| Resind Industria e Comercio Ltda. | Brazil | |
| Rui Da Hung | Taiwan | |
| Soft Metais Ltda. | Brazil | |
| Super Ligas | Brazil | |
| Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | |
| Thaisarco | Thailand | |
| Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | |
| Tin Technology & Refining | United States of America | |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | |
| VQB Mineral and Trading Group JSC | Viet Nam | |
| White Solder Metalurgia e Mineracao Ltda. | Brazil | |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | |
| Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | |
| Tungsten |
||
| Artek LLC | Russian Federation | |
| Asia Tungsten Products Vietnam Ltd. | Viet Nam | |
| Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | |
| China Molybdenum Tungsten Co., Ltd. | China | |
| Chongyi Zhangyuan Tungsten Co., Ltd. | China | |
| CNMC (Guangxi) PGMA Co., Ltd. | China | |
| Cronimet Brasil Ltda | Brazil | |
| Fujian Ganmin RareMetal Co., Ltd. | China | |
| Fujian Xinlu Tungsten Co., Ltd. | China | |
| Ganzhou Haichuang Tungsten Co., Ltd. | China | |
| Ganzhou Huaxing Tungsten Products Co., Ltd. | China | |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | |
| Ganzhou Seadragon W & Mo Co., Ltd. | China | |
| Global Tungsten & Powders LLC | United States of America | |
| Guangdong Xianglu Tungsten Co., Ltd. | China | |
| H.C. Starck Tungsten GmbH | Germany | |
| HANNAE FOR T Co., Ltd. | Korea, Republic of | |
| Hunan Chenzhou Mining Co., Ltd. | China | |
| Hunan Jintai New Material Co., Ltd. | China | |
| Hydrometallurg, JSC | Russian Federation | |
A-8
| Japan New Metals Co., Ltd. | Japan | |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | |
| Jiangxi Gan Bei Tungsten Co., Ltd. | China | |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | |
| Jiangxi Yaosheng Tungsten Co., Ltd. | China | |
| Hubei Green Tungsten Co., Ltd. | China | |
| JSC “Kirovgrad Hard Alloys Plant” | Russian Federation | |
| Kennametal Fallon | United States of America | |
| Kennametal Huntsville | United States of America | |
| Lianyou Metals Co., Ltd. | Taiwan | |
| LLC Vostok | Russian Federation | |
| Malipo Haiyu Tungsten Co., Ltd. | China | |
| Masan High-Tech Materials | Viet Nam | |
| Moliren Ltd. | Russian Federation | |
| Niagara Refining LLC | United States of America | |
| NPP Tyazhmetprom LLC | Russian Federation | |
| OOO “Technolom” 1 | Russian Federation | |
| OOO “Technolom” 2 | Russian Federation | |
| Philippine Chuangxin Industrial Co., Inc. | Philippines | |
| TANIOBIS Smelting GmbH & Co. KG | Germany | |
| Unecha Refractory metals plant | Russian Federation | |
| Wolfram Bergbau und Hutten AG | Austria | |
| Xiamen Tungsten (H.C.) Co., Ltd. | China | |
| Xiamen Tungsten Co., Ltd. | China | |
| YUDU ANSHENG TUNGSTEN CO., LTD. | China | |
| Fujian Jinxin Tungsten Co., Ltd. | China | |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China | |
| Hunan Litian Tungsten Industry Co., Ltd. | China | |
| KGETS Co., Ltd. | Korea, Republic of | |
| Tejing (Vietnam) Tungsten Co., Ltd. | Viet Nam | |
| Woltech Korea Co., Ltd. | Korea, Republic of | |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
A-9