UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
ViaSat, Inc.
(Exact Name of Registrant as Specified in its Charter)
| Delaware | 000-21767 | 33-0174996 | ||
| (State or Other Jurisdiction of Incorporation) |
(Commission File No.) |
(I.R.S. Employer Identification No.) |
6155 El Camino Real
Carlsbad, California 92009
(Address of Principal Executive Offices, Including Zip Code)
Paul G. Castor
(760) 476-2200
(Name and Telephone Number, Including Area Code, of the Person to Contact in connection with this Report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016 |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
CONFLICT MINERALS DISCLOSURE
ViaSat, Inc. is filing a Conflict Minerals Report for the calendar year ended December 31, 2016, which is attached hereto as Exhibit 1.01 and is publicly available in the Financial Information section of its website at investors.viasat.com under the heading “SEC Filings.”
Item 1.02 Exhibit
Item 2.01 of this Form SD is incorporated by reference into this Item 1.02.
Section 2 – Exhibits
Item 2.01 Exhibits
| Exhibit |
Description of Exhibit | |
| 1.01 | Conflict Minerals Report | |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| VIASAT, INC. | ||||||
| Date: May 30, 2017 | By | /s/ Shawn Duffy | ||||
| Shawn Duffy | ||||||
| Senior Vice President and Chief Financial Officer | ||||||
EXHIBIT 1.01
VIASAT, INC.
CONFLICT MINERALS REPORT
Reporting Period:
January 1, 2016 - December 31, 2016
This Conflict Minerals Report (this “Report”) of ViaSat, Inc. for calendar year 2016 has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on every registrant having conflict minerals that are necessary to the functionality or production of a product manufactured by the registrant or contracted by the registrant to be manufactured. Please refer to the Rule, Special Disclosure Report on Form SD (“Form SD”) and the 1934 Act Release No. 34-67716 (August 22, 2012) for definitions of the terms used in this Report, unless otherwise defined herein. This Report does not address any conflict minerals that were “outside the supply chain” prior to January 31, 2013, as any such conflict minerals are exempted under the Rule and Form SD. References in this Report to “ViaSat,” “we,” “us” and “our” mean ViaSat, Inc. and its consolidated subsidiaries.
A. Overview
ViaSat is an innovator in broadband technologies and services. Our end-to-end platform of high-capacity Ka-band satellites, ground infrastructure and user terminals enables us to provide cost-effective, high-speed, high-quality broadband solutions to enterprises, consumers and government users around the globe, whether on the ground, on the move or in flight. In addition, we develop and provide advanced wireless communications systems, secure networking systems and cybersecurity and information assurance products and services.
We manufacture or contract to manufacture a variety of advanced satellite-based and wireless products, systems and solutions. We have determined that the Rule applies to our business because necessary conflict minerals are contained in our products.
Therefore, in accordance with the Rule and Form SD, we have conducted, in good faith, a reasonable country of origin inquiry (“RCOI”) with our suppliers that was reasonably designed to determine whether any conflict minerals in our products originated in the Democratic Republic of Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”) or are from recycled or scrap sources. Based on our RCOI, we had reason to believe that, in calendar year 2016, necessary conflict minerals contained in our products may have originated in the Covered Countries, and had reason to believe that such necessary conflict minerals may not be from recycled or scrap sources. Therefore, given the possibility that necessary conflict minerals in our products may have originated from Covered Countries and may not be from recycled or scrap sources, we have conducted due diligence on the source and chain of custody of those conflict minerals.
B. Design of Conflict Minerals Program
We designed our conflict minerals program to conform in all material respects with the internationally recognized due diligence framework developed by The Organisation for Economic Co-operation and Development (“OECD”). See OECD (2013), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing, available at http://www.oecd.org/corporate/mne/GuidanceEdition2.pdf and the related Supplements for gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).
Our conflict minerals program has been designed to address each of the five steps in the OECD Guidance due diligence framework as they relate to our position as a “downstream” purchaser in the conflict minerals supply chain, namely:
| • | establish strong company management systems regarding conflict minerals; |
| • | identify and assess risks in our supply chain; |
| • | design and implement a strategy to respond to identified risks in our supply chain; |
| • | utilize independent third-party audits of smelters and refiners; and |
| • | report publicly on our supply chain due diligence. |
Because we are a downstream supplier, we are many steps removed from the mining of conflict minerals. The components and materials contained in our products are supplied by a large number of suppliers, through multiple tiers of distribution. Once minerals are in the supply chain, determining the smelter or the origin of minerals is a challenging process, and we are realistic about the limitations on what we can identify and control.
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Consistent with these limitations, the OECD Guidance acknowledges that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. The Electronic Industry Citizenship Coalition and The Global e-Sustainability Initiative (the “EICC/GeSI”) Conflict-Free Sourcing Initiative guidance on implementing the OECD Guidance further recommends that, in conducting due diligence, downstream companies identify relevant or highest priority “tier-1” (direct) suppliers and focus their due diligence efforts on those priority suppliers first. Suggested factors for prioritizing tier-1 suppliers include annual spend.
Company Management Systems
We have established an internal conflict minerals program to manage risks in our supply chain through policies and procedures that are designed to help us understand whether the minerals in our products contribute to the ongoing conflict in the DRC. As part of our program, we have established and maintain company management systems that involve multiple levels of our organization.
ViaSat’s Statement on Conflict Minerals (which is publicly available on our website at www.viasat.com/legal/legal-statements) reflects our commitment to respect human rights through our responsible sourcing practices, as well as our commitment to avoid practices that may contribute to human rights abuses.
Our conflict minerals steering committee oversees the design and execution of our conflict minerals program. Members of our steering committee include senior executives from our finance, legal, operations, engineering and supply chain departments. The steering committee’s responsibilities include reviewing and approving our Statement on Conflict Minerals, the design of our conflict minerals program and the results of our RCOI and due diligence measures. Our steering committee meets as required throughout each calendar year to review and discuss our conflict minerals program, and is briefed as to the status and findings of the supply chain due diligence we conduct each year.
Our conflict minerals program is managed by a cross-functional compliance team, comprised of representatives from our contracts, supply chain, engineering, quality, finance and legal groups. This compliance team reports directly to our conflict minerals steering committee.
In addition to the company management systems described above, we have also implemented the following company management controls:
| • | we provide our Statement on Conflict Minerals to all of our “tier-1” (direct) suppliers that supply relevant components and materials to us (referred to in this Report as our “Tier-1 Suppliers”) and communicate to them our expectations as to our supply chain and the responsible sourcing of conflict minerals; |
| • | we have adopted internal procedures with respect to conflict minerals into our quality management system (QMS); |
| • | we have put in place a grievance mechanism regarding our conflict minerals program; |
| • | we have established and maintain a central repository of information to facilitate analysis and identification of supplier responses received from our supply chain due diligence; and |
| • | we have incorporated provisions on conflict minerals as part of our standard terms and conditions for purchase orders. |
We also support the establishment of industry forums to share and communicate information and develop policies on conflict minerals. In 2014, we became a member of the Conflict-Free Sourcing Initiative (“CFSI”), an organization committed to the responsible sourcing of conflict minerals, and we continue to be a supportive member of the organization.
Identification and Assessment of Supply Chain Risk
We have developed and implemented a risk management plan to identify and assess risks in our supply chain. To identify and assess these risks, we identify all of our Tier-1 Suppliers and conduct an annual supply chain survey of our Tier-1 Suppliers using the EICC/GeSI Conflict Minerals Reporting Template (the “EICC/GeSI Form”). We have elected to use the EICC/GeSI Form to elicit supply chain information from our suppliers because (1) it provides information critical to our due diligence efforts, and (2) it is a commonly used tool across many industries, thus easing the burden on our suppliers.
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To maximize the effectiveness of our due diligence measures, we concentrate our due diligence efforts primarily on those Tier-1 Suppliers representing a substantial majority of our total annual expenditure on relevant components and materials (referred to in this Report as our “Priority Suppliers”).
In reviewing the diligence data we receive (whether from completed EICC/GeSI Forms, responses to our inquiries or otherwise), we apply evaluation processes to assess the reasonableness of the data and to check for the presence of “red flags.” We consider red flags to be obvious indications or circumstances that indicate the supplier disclosure may be inaccurate or improper and thus, may not be reliable. Factors we take into account in identifying and assessing supplier risk include:
| • | the failure of a supplier to respond to our inquiries; |
| • | statements by a supplier that no conflict minerals are used in its products; |
| • | inadequacies and inconsistencies in, or incompleteness of, a supplier’s responses; |
| • | suppliers that indicate conflict minerals in their products may be sourced from Covered Countries; and |
| • | a supplier’s lack of sophistication, including unfamiliarity with the Rule. |
In addition, we use the EICC/GeSI Form to identify conflict minerals processing facilities when reported in our supply chain by our Priority Suppliers. We obtain and validate information (where available) on the country of origin and mine location of conflict minerals processed at the identified facilities by relying on the information received through the CFSI’s third party audit program: the Conflict-Free Smelter Program (“CFSP”), which offers third-party audits of smelters and refiners to certify that the minerals they process originate from conflict-free sources.
Designing and Implementing a Strategy to Respond to Risk
We have developed processes to assess and respond to the risks identified in our supply chain ranging from continued procurement with corrective action letter requests to disengagement at the discretion of management. Our cross-functional compliance team manages the due diligence of our supply chain, and monitors, tracks and evaluates supplier responses to our due diligence efforts. Members of our cross-functional compliance team meet periodically to review the status and results of our due diligence measures and to discuss any actual or potential risks and red flags identified during diligence. Members of our cross-functional compliance team also monitor and track the measures we take to mitigate risks, and report on risk management to our steering committee. In addition, we support the development of due diligence practices through participation in CFSI working groups.
Independent Third-Party Audits of Smelters and Refiners
We do not have direct relationships with any smelters or refiners and accordingly do not directly audit any smelters or refiners in our supply chain. Instead, we rely on the third-party audits of smelters and refiners conducted as part of the CFSP. The CFSP uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program. The smelters and refiners that are found by the CFSP to be “compliant” are those for which the independent auditor has verified that the smelter and/or refiner does not process conflict minerals that have originated from mines in the Covered Countries that directly or indirectly financed or benefited armed groups. We also rely on the publicly available results of the CFSP third-party audits to validate the responsible sourcing practices of processing facilities in our supply chain. We support independent third-party audits of processing facilities through our CFSI membership.
Public Reporting on our Supply Chain Due Diligence
We publish our Form SDs and Conflict Mineral Reports (including this Report) in the Financial Information section of our website at investors.viasat.com under the heading “SEC Filings,” and our Statement on Conflict Minerals is publicly available on our website at www.viasat.com/legal/legal-statments. Information found on or accessed through ViaSat’s website is not considered part of this Report and is not incorporated by reference herein. We also publicly file our Form SDs (which include our Conflict Minerals Reports) with the Securities and Exchange Commission.
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C. Due Diligence Measures Performed
Set forth below is a description of the measures we performed to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products for calendar year 2016.
To determine whether necessary conflict minerals in our products in calendar year 2016 originated in Covered Countries, we assembled a comprehensive list of suppliers that provide goods and services directly to us. From this list, we identified over 800 Tier-1 Suppliers. We contacted each of these Tier-1 Suppliers individually, provided them with a link to our Statement on Conflict Minerals and a copy of the EICC/GeSI Form, and requested the return of the completed EICC/GeSI Form to us. Follow-up requests were sent to all Tier-1 Suppliers who did not respond. To maximize the effectiveness of our due diligence measures, we concentrate our due diligence efforts primarily on Priority Suppliers. We used our manufacturing data system to identify Priority Suppliers, and took additional measures to maximize the response rate from Priority Suppliers. We received responses from a majority of our Tier-1 Suppliers and nearly all of our Priority Suppliers.
We electronically aggregated and reviewed the data from all of the responses we received from our Tier-1 Suppliers by utilizing a conflict minerals data management tool that we designed to track communications with Tier-1 Suppliers, automate the identification of quality issues (e.g. incomplete EICC/GeSI Forms, inconsistent responses and red flags based on criteria defined internally) and aggregate EICC/GeSI Forms responses for analysis and reporting. We applied our evaluation processes to data received to assess the reasonableness of the data and to check for the presence of “red flags.” Where red flags were identified, we undertook further analysis of the information provided on the EICC/GeSI Form in order to assess any actual or potential risks to our supply chain and develop a recommended course of action. Where supplier responses indicated a need to conduct further due diligence, we conducted additional analysis or requested more detailed information, as appropriate.
We determine if the processing facilities reported to us by our Priority Suppliers adhere to responsible sourcing practices by verifying whether they are included on the list of CFSP-compliant processing facilities. We communicated red flags identified in the EICC/GeSI Forms responses through corrective action letter requests with our Priority Suppliers who answered that reported processing facilities are known to source conflict minerals from the Covered Countries. Members of our cross-functional compliance team met periodically to review the results from our due diligence efforts for calendar year 2016, and presented their findings to our steering committee.
We provide funding to non-profit and industry initiatives that support the responsible sourcing of conflict minerals through our CFSI membership.
D. Product Description
Products Containing Necessary Conflict Minerals
We have determined that substantially all of the products we manufacture or contract to manufacture contain conflict minerals necessary to the functionality or production of such products.
Facilities Used to Process, and Country of Origin of, the Necessary Conflict Minerals in our Products
Based on the information provided by our Tier-1 Suppliers and information made available by CFSI and the CFSP, we believe that the facilities that have been used to process conflict minerals in our products in calendar year 2016 may include the smelters and refiners listed in Annex I. As discussed above, we are a downstream supplier, many steps removed from the mining of conflict minerals, and accordingly rely on the information provided to us by our Tier-1 Suppliers (who are themselves generally multiple tiers downstream) to determine the country of origin of, or the facilities used to process, the conflict minerals contained in our products.
Of the 267 smelters and refiners identified as potentially being in our supply chain:
| • | 242 smelters and refiners were identified as “CFSP-compliant,” meaning that the processing facility has been audited and certified as compliant with CFSP audit protocols (including processing facilities currently undergoing re-audit); |
| • | 24 smelters and refiners were identified as “CFSP-active,” meaning that the processing facility is actively pursuing CFSP certification in that they have either committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs; and |
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| • | one processing facility was non-participating, meaning that it met the definition of a smelter or refiner under the CFSP audit protocols but does not participate in the CFSP. |
Not all of these facilities may have processed conflict minerals in our products. Much of the smelter and refiner information provided by our Tier-1 Suppliers was provided at a “company” level (meaning that they reported all of the smelters and refiners that may have processed the conflict minerals contained in all of their products, not just those pertaining to the products sold to us). They may also have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their own suppliers or for other reasons. Therefore, the list of processing facilities disclosed in Annex I may over-represent the number of processing facilities that process the conflict minerals contained in our products.
Efforts to Determine Mine or Location of Origin
We have determined that our due diligence efforts, including requesting our Tier-1 Suppliers to complete the EICC/GeSI Form and reviewing the CFSP status of identified smelters and refiners, represent our reasonable best efforts to determine the mines or locations of origin of the conflict minerals in our supply chain.
E. Future Steps to Mitigate Risk
Our conflict minerals program is aimed at the continuous improvement of our understanding of our supply chain and risk reduction over time. We intend to continue to take steps to improve our due diligence processes and to minimize the risk that our necessary conflict minerals benefit armed groups. Due diligence is an ongoing, proactive and reactive process, and we are continuing to work with our suppliers to identify and prevent or mitigate risks of adverse impacts associated with conflict minerals.
The primary risks we identified in calendar year 2016 continue to be related to inconsistencies or inadequacies in, or the incompleteness of, suppliers’ responses to the EICC/GeSI Forms, the inability of our suppliers to confirm whether or not minerals used in their parts and components were sourced from Covered Countries, and the associated difficulties in identifying the smelters and refiners in our supply chain. With respect to necessary conflict minerals contained in our products with respect to calendar year 2017, we expect to continue to engage with our suppliers to clearly communicate our expectations with regard to conflict minerals sourcing and to educate them on the importance of conflict minerals supply chain diligence. In particular, we continue to encourage our suppliers to work with their own immediate suppliers to improve the transparency, accuracy, validity, reliability and completeness of conflict minerals sourcing information (particularly with regard to information provided regarding smelters and refiners used to process conflict minerals and mine or location of origin and country of origin information), and to minimize the risk that our necessary conflict minerals benefit armed groups in the Covered Countries. As our Tier-1 Suppliers continue to report smelters and refiners that we believe are not operational or that may have been misidentified as smelters or refiners, we continue to work with our suppliers to re-validate, improve and refine reported information. We strive to use only Priority Suppliers that source from CFSP-compliant processing facilities in our supply chain to the maximum extent practicable. In addition, we may consider improving automated solutions to help us analyze conflict minerals information received from our suppliers more efficiently. We also intend to continue to encourage suppliers to source conflict minerals from smelters or refiners that have been identified as “compliant” by the CFSP.
Certain of the matters discussed in this Report, including in particular, future steps to mitigate risks that the conflict minerals contained in our products could benefit armed groups in the Covered Countries, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We disclaim any obligation to update publicly any forward-looking statements, whether in response to new information, future events or otherwise, except as required by applicable law.
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Annex I
List of Smelters and Refiners Reported in ViaSat’s Supply Chain in 2016
| Conflict Mineral | Name of Smelter or Refiner | Country Location of Smelter or Refiner | ||
| Gold |
Abington Reldan Metals, LLC (**) | U.S.A. | ||
| Gold |
Planta Recuperadora de Metales SpA (**) | Chile | ||
| Gold |
Al Etihad Gold Refinery DMCC (**) | United Arab Emirates | ||
| Gold |
Bangalore Refinery (**) | India | ||
| Gold |
Cendres + Métaux S.A. (**) | Switzerland | ||
| Gold |
Daejin Indus Co., Ltd. (**) | South Korea | ||
| Gold |
Geib Refining Corporation (**) | U.S.A. | ||
| Gold |
KGHM Polska Miedź Spółka Akcyjna (**) | Poland | ||
| Gold |
Korea Zinc Co., Ltd. (**) | South Korea | ||
| Gold |
Metalor Technologies (Suzhou) Ltd. (**) | China | ||
| Gold |
Modeltech Sdn Bhd (**) | Malaysia | ||
| Gold |
Navoi Mining and Metallurgical Combinat (**) | Uzbekistan | ||
| Gold |
SungEel HiTech (**) | South Korea | ||
| Gold |
Advanced Chemical Company (*) | U.S.A. | ||
| Gold |
Aida Chemical Industries Co., Ltd. (*) | Japan | ||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. (*) | Germany | ||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) (*) | Uzbekistan | ||
| Gold |
AngloGold Ashanti Córrego do Sítio Mineração (*) | Brazil | ||
| Gold |
Argor-Heraeus S.A. (*) | Switzerland | ||
| Gold |
Asahi Pretec Corp. (*) | Japan | ||
| Gold |
Asahi Refining Canada Ltd. (*) | Canada | ||
| Gold |
Asahi Refining USA Inc. (*) | U.S.A. | ||
| Gold |
Asaka Riken Co., Ltd. (*) | Japan | ||
| Gold |
AU Traders and Refiners (*) | South Africa | ||
| Gold |
Aurubis AG (*) | Germany | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) (*) | Philippines | ||
| Gold |
Boliden AB (*) | Sweden | ||
| Gold |
C. Hafner GmbH + Co. KG (*) | Germany | ||
| Gold |
CCR Refinery - Glencore Canada Corporation (*) | Canada | ||
| Gold |
Chimet S.p.A. (*) | Italy | ||
| Gold |
DODUCO GmbH (*) | Germany | ||
| Gold |
Dowa (*) | Japan | ||
| Gold |
DSC (Do Sung Corporation) (*) | South Korea | ||
| Gold |
Eco-System Recycling Co., Ltd. (*) | Japan | ||
| Gold |
Elemetal Refining, LLC (*) | U.S.A. | ||
| Gold |
Emirates Gold DMCC (*) | United Arab Emirates | ||
| Gold |
Heimerle + Meule GmbH (*) | Germany | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG (*) | Germany | ||
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| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. (*) | China | ||
| Gold |
Ishifuku Metal Industry Co., Ltd. (*) | Japan | ||
| Gold |
Istanbul Gold Refinery (*) | Turkey | ||
| Gold |
Japan Mint (*) | Japan | ||
| Gold |
Jiangxi Copper Co., Ltd. (*) | China | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant (*) | Russia | ||
| Gold |
JSC Uralelectromed (*) | Russia | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. (*) | Japan | ||
| Gold |
Kazzinc (*) | Kazakhstan | ||
| Gold |
Kennecott Utah Copper LLC (*) | U.S.A. | ||
| Gold |
Kojima Chemicals Co., Ltd. (*) | Japan | ||
| Gold |
Kyrgyzaltyn JSC (*) | Kyrgyzstan | ||
| Gold |
LS-NIKKO Copper Inc. (*) | South Korea | ||
| Gold |
Materion (*) | U.S.A. | ||
| Gold |
Matsuda Sangyo Co., Ltd. (*) | Japan | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd. (*) | China | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. (*) | Singapore | ||
| Gold |
Metalor USA Refining Corporation (*) | U.S.A. | ||
| Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. (*) | Mexico | ||
| Gold |
Mitsubishi Materials Corporation (*) | Japan | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. (*) | Japan | ||
| Gold |
MMTC-PAMP India Pvt., Ltd. (*) | India | ||
| Gold |
Moscow Special Alloys Processing Plant (*) | Russia | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. (*) | Turkey | ||
| Gold |
Nihon Material Co., Ltd. (*) | Japan | ||
| Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH (*) | Austria | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd. (*) | Japan | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) (*) | Russia | ||
| Gold |
OJSC Novosibirsk Refinery (*) | Russia | ||
| Gold |
PAMP S.A. (*) | Switzerland | ||
| Gold |
Prioksky Plant of Non-Ferrous Metals (*) | Russia | ||
| Gold |
PT Aneka Tambang (Persero) Tbk (*) | Indonesia | ||
| Gold |
PX Précinox S.A. (*) | Switzerland | ||
| Gold |
Rand Refinery (Pty) Ltd. (*) | South Africa | ||
| Gold |
Republic Metals Corporation (*) | U.S.A. | ||
| Gold |
Royal Canadian Mint (*) | Canada | ||
| Gold |
Samduck Precious Metals (*) | South Korea | ||
| Gold |
SAXONIA Edelmetalle GmbH (*) | Germany | ||
| Gold |
Schone Edelmetaal B.V. (*) | Netherlands | ||
| Gold |
SEMPSA Joyería Platería S.A. (*) | Spain | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. (*) | China | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. (*) | China | ||
| Gold |
Singway Technology Co., Ltd. (*) | Taiwan | ||
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| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals (*) | Russia | ||
| Gold |
Solar Applied Materials Technology Corp. (*) | Taiwan | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. (*) | Japan | ||
| Gold |
T.C.A S.p.A (*) | Italy | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K. (*) | Japan | ||
| Gold |
The Refinery of Shandong Gold Mining Co., Ltd. (*) | China | ||
| Gold |
Tokuriki Honten Co., Ltd. (*) | Japan | ||
| Gold |
Torecom (*) | South Korea | ||
| Gold |
Umicore Brasil Ltda. (*) | Brazil | ||
| Gold |
Umicore Precious Metals Thailand (*) | Thailand | ||
| Gold |
Umicore S.A. Business Unit Precious Metals Refining (*) | Belgium | ||
| Gold |
United Precious Metal Refining, Inc. (*) | U.S.A. | ||
| Gold |
Valcambi S.A. (*) | Switzerland | ||
| Gold |
Western Australian Mint trading as The Perth Mint (*) | Australia | ||
| Gold |
WIELAND Edelmetalle GmbH (*) | Germany | ||
| Gold |
Yamamoto Precious Metal Co., Ltd. (*) | Japan | ||
| Gold |
Yokohama Metal Co., Ltd. (*) | Japan | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation (*) | China | ||
| Gold |
Zijin Mining Group Co., Ltd. Gold Refinery (*) | China | ||
| Gold |
Heraeus Ltd. Hong Kong (*) | China | ||
| Gold |
Metalor Technologies S.A. (*) | Switzerland | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. (*) | China | ||
| Tantalum |
Conghua Tantalum and Niobium Smeltry (*) | China | ||
| Tantalum |
D Block Metals, LLC (*) | U.S.A. | ||
| Tantalum |
Duoluoshan (*) | China | ||
| Tantalum |
Exotech Inc. (*) | U.S.A. | ||
| Tantalum |
F&X Electro-Materials Ltd. (*) | China | ||
| Tantalum |
FIR Metals & Resource Ltd. (*) | China | ||
| Tantalum |
Global Advanced Metals Aizu (*) | Japan | ||
| Tantalum |
Global Advanced Metals Boyertown (*) | U.S.A. | ||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. (*) | China | ||
| Tantalum |
H.C. Starck Co., Ltd. (*) | Thailand | ||
| Tantalum |
H.C. Starck GmbH Goslar (*) | Germany | ||
| Tantalum |
H.C. Starck GmbH Laufenburg (*) | Germany | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH (*) | Germany | ||
| Tantalum |
H.C. Starck Inc. (*) | U.S.A. | ||
| Tantalum |
H.C. Starck Ltd. (*) | Japan | ||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG (*) | Germany | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. (*) | China | ||
| Tantalum |
Hi-Temp Specialty Metals, Inc. (*) | U.S.A. | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. (*) | China | ||
| Tantalum |
Jiangxi Tuohong New Raw Material (*) | China | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. (*) | China | ||
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| Tantalum |
Jiujiang Tanbre Co., Ltd. (*) | China | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. (*) | China | ||
| Tantalum |
KEMET Blue Metals (*) | Mexico | ||
| Tantalum |
KEMET Blue Powder (*) | U.S.A. | ||
| Tantalum |
King-Tan Tantalum Industry Ltd. (*) | China | ||
| Tantalum |
LSM Brasil S.A. (*) | Brazil | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd. (*) | India | ||
| Tantalum |
Mineração Taboca S.A. (*) | Brazil | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. (*) | Japan | ||
| Tantalum |
Molycorp Silmet A.S. | Estonia | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. (*) | China | ||
| Tantalum |
Plansee SE Liezen (*) | Austria | ||
| Tantalum |
Plansee SE Reutte (*) | Austria | ||
| Tantalum |
Power Resources Ltd. (*) | Macedonia | ||
| Tantalum |
QuantumClean (*) | U.S.A. | ||
| Tantalum |
Resind Indústria e Comércio Ltda. (*) | Brazil | ||
| Tantalum |
RFH Tantalum Smeltry Co., Ltd. (*) | China | ||
| Tantalum |
Solikamsk Magnesium Works OAO (*) | Russia | ||
| Tantalum |
Taki Chemical Co., Ltd. (*) | Japan | ||
| Tantalum |
Telex Metals (*) | U.S.A. | ||
| Tantalum |
Tranzact, Inc. (*) | U.S.A. | ||
| Tantalum |
Ulba Metallurgical Plant JSC (*) | Kazakhstan | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. (*) | China | ||
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. (*) | China | ||
| Tantalum |
Zhuzhou Cemented Carbide Group Co., Ltd. (*) | China | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company (**) | Vietnam | ||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company (**) | Vietnam | ||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant (**) | China | ||
| Tin |
Gejiu Jinye Mineral Company (**) | China | ||
| Tin |
Gejiu Kai Meng Industry and Trade LLC (**) | China | ||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. (**) | China | ||
| Tin |
Modeltech Sdn Bhd (**) | Malaysia | ||
| Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. (**) | China | ||
| Tin |
PT Karimun Mining (**) | Indonesia | ||
| Tin |
PT O.M. Indonesia (**) | Indonesia | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. (**) | China | ||
| Tin |
Alpha (*) | U.S.A. | ||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. (*) | China | ||
| Tin |
China Tin Group Co., Ltd. (*) | China | ||
| Tin |
Cooperativa Metalurgica de Rondônia Ltda. (*) | Brazil | ||
| Tin |
CV Ayi Jaya (*) | Indonesia | ||
| Tin |
CV Dua Sekawan (*) | Indonesia | ||
| Tin |
CV Gita Pesona (*) | Indonesia | ||
9
| Tin |
CV Serumpun Sebalai (*) | Indonesia | ||
| Tin |
CV Tiga Sekawan (*) | Indonesia | ||
| Tin |
CV United Smelting (*) | Indonesia | ||
| Tin |
Dowa (*) | Japan | ||
| Tin |
Elmet S.L.U. (*) | Spain | ||
| Tin |
EM Vinto (*) | Bolivia | ||
| Tin |
Fenix Metals (*) | Poland | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. (*) | China | ||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant (*) | China | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. (*) | China | ||
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd. (*) | China | ||
| Tin |
Malaysia Smelting Corporation (MSC) (*) | Malaysia | ||
| Tin |
Metallic Resources, Inc. (*) | U.S.A. | ||
| Tin |
Metallo-Chimique N.V. (*) | Belgium | ||
| Tin |
Mineração Taboca S.A. (*) | Brazil | ||
| Tin |
Minsur (*) | Peru | ||
| Tin |
Mitsubishi Materials Corporation (*) | Japan | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. (*) | Thailand | ||
| Tin |
Operaciones Metalurgical S.A. (*) | Bolivia | ||
| Tin |
PT Aries Kencana Sejahtera (*) | Indonesia | ||
| Tin |
PT Artha Cipta Langgeng (*) | Indonesia | ||
| Tin |
PT Babel Inti Perkasa (*) | Indonesia | ||
| Tin |
PT Bangka Prima Tin (*) | Indonesia | ||
| Tin |
PT Bangka Tin Industry (*) | Indonesia | ||
| Tin |
PT Belitung Industri Sejahtera (*) | Indonesia | ||
| Tin |
PT Bukit Timah (*) | Indonesia | ||
| Tin |
PT Cipta Persada Mulia (*) | Indonesia | ||
| Tin |
PT DS Jaya Abadi (*) | Indonesia | ||
| Tin |
PT Eunindo Usaha Mandiri (*) | Indonesia | ||
| Tin |
PT Justindo (*) | Indonesia | ||
| Tin |
PT Kijang Jaya Mandiri (*) | Indonesia | ||
| Tin |
PT Lautan Harmonis Sejahtera (*) | Indonesia | ||
| Tin |
PT Menara Cipta Mulia (*) | Indonesia | ||
| Tin |
PT Mitra Stania Prima (*) | Indonesia | ||
| Tin |
PT Panca Mega Persada (*) | Indonesia | ||
| Tin |
PT Prima Timah Utama (*) | Indonesia | ||
| Tin |
PT Refined Bangka Tin (*) | Indonesia | ||
| Tin |
PT Sariwiguna Binasentosa (*) | Indonesia | ||
| Tin |
PT Stanindo Inti Perkasa (*) | Indonesia | ||
| Tin |
PT Sukses Inti Makmur (*) | Indonesia | ||
| Tin |
PT Sumber Jaya Indah (*) | Indonesia | ||
| Tin |
PT Timah (Persero) Tbk Kundur (*) | Indonesia | ||
| Tin |
PT Timah (Persero) Tbk Mentok (*) | Indonesia | ||
10
| Tin |
PT Tinindo Inter Nusa (*) | Indonesia | ||
| Tin |
PT Tommy Utama (*) | Indonesia | ||
| Tin |
Resind Indústria e Comércio Ltda. (*) | Brazil | ||
| Tin |
Rui Da Hung (*) | Taiwan | ||
| Tin |
Soft Metais Ltda. (*) | Brazil | ||
| Tin |
Thaisarco (*) | Thailand | ||
| Tin |
VQB Mineral and Trading Group JSC (*) | Vietnam | ||
| Tin |
White Solder Metalurgia e Mineração Ltda. (*) | Brazil | ||
| Tin |
Yunnan Tin Company Limited (*) | China | ||
| Tin |
O.M. Manufacturing Philippines, Inc. (*) | Philippines | ||
| Tin |
PT Wahana Perkit Jaya (*) | Indonesia | ||
| Tin |
CV Venus Inti Perkasa (*) | Indonesia | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. (*) | Brazil | ||
| Tin |
Melt Metais e Ligas S.A. (*) | Brazil | ||
| Tin |
PT ATD Makmur Mandiri Jaya (*) | Indonesia | ||
| Tin |
PT Inti Stania Prima (*) | Indonesia | ||
| Tungsten |
A.L.M.T. TUNGSTEN Corp. (*) | Japan | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. (*) | Vietnam | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. (*) | China | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. (*) | China | ||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. (*) | China | ||
| Tungsten |
Global Tungsten & Powders Corp. (*) | U.S.A. | ||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
H.C. Starck GmbH (*) | Germany | ||
| Tungsten |
H.C. Starck Smelting GmbH & Co.KG (*) | Germany | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. (*) | China | ||
| Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji (*) | China | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. (*) | China | ||
| Tungsten |
Hydrometallurg, JSC (*) | Russia | ||
| Tungsten |
Japan New Metals Co., Ltd. (*) | Japan | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. (*) | China | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. (*) | China | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. (*) | China | ||
| Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. (*) | China | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Kennametal Fallon (*) | U.S.A. | ||
| Tungsten |
Kennametal Huntsville (*) | U.S.A. | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Moliren Ltd (*) | Russia | ||
11
| Tungsten |
Niagara Refining LLC (*) | U.S.A. | ||
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC (*) | Vietnam | ||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. (*) | Philippines | ||
| Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City (*) | China | ||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. (*) | Vietnam | ||
| Tungsten |
Unecha Refractory metals plant (*) | Russia | ||
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. (*) | Vietnam | ||
| Tungsten |
Wolfram Bergbau und Hütten AG (*) | Austria | ||
| Tungsten |
Woltech Korea Co., Ltd. (*) | South Korea | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. (*) | China | ||
| Tungsten |
Xiamen Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. (*) | China | ||
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. (*) | China | ||
| Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. | China | ||
* Smelters or refiners that have been identified by the CFSP as “compliant.”
** Smelters or refiners that have been identified by the CFSP as “active.”
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