EX-1.01 2 a16-12256_1ex1d01.htm EX-1.01

Exhibit 1.01

MAGNA INTERNATIONAL INC.

CONFLICT MINERALS REPORT

(For the reporting period from January 1, 2015 to December 31, 2015)

SECTION 1: INTRODUCTION

A.  Background

(a) The Conflict Minerals Rule

The Securities and Exchange Commission (“SEC”) adopted Rule 13p-1 (17 CFR 240.13p-1) (the “Rule”) under the Securities and Exchange Act of 1934, as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) (17 CFR Parts 240 and 249b). The Rule implemented a requirement for SEC registrant companies to disclose the use of  “Conflict Minerals” in their products, where such use is “necessary to the functionality or production of a product” manufactured by that company. The Rule defines “Conflict Minerals” as cassiterite, columbite-tantalite, wolframite, and their derivatives, tin, tantalum, tungsten, as well as gold (collectively, “3TG minerals”) that originated in the Democratic Republic of the Congo or an adjoining country specified in the Rule (collectively, the “Covered Countries”).

As a registrant with 3TG minerals present in certain of our manufactured products, Magna International Inc. (referred to as “Magna”, “we”, “us” or “our” in this report) is subject to Section 1502 of the Dodd-Frank Act and the Rule, and are required to perform a “reasonable country of origin inquiry” (“RCOI”) into the sources of the 3TG minerals to determine whether any such minerals in our products originated in a Covered Country.

Based on the results of our RCOI for the year ended December 31, 2015, Magna cannot exclude the possibility that a portion of the 3TG minerals in its products originated in one or more Covered Countries. As a result, Magna conducted due diligence activities on the source and chain of custody of these conflict minerals as described in this Conflict Minerals Report, which has been prepared for calendar year 2015 in accordance with the Rule.

(b) Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements relating to actions that we may take in the future with respect to our conflict minerals program. Such statements are based on the current expectations of our management and are not promises or guarantees of future performance of such actions. The forward-looking statements represent management’s expectations as of the date of this report. Subsequent events and developments may cause management’s views to change. We do not undertake any obligation to update any forward-looking statements in the future, and the forward-looking statements should not be relied upon as representing our views as of any date subsequent to the date of this report.

(c) Documents Incorporated by Reference

Unless expressly incorporated by reference in this report, any documents, third-party materials or references to websites (including Magna’s website) are not incorporated by reference in, or considered a part of, this Conflict Minerals Report.

B. Company Overview

(a) Our Company

We are a leading global automotive supplier with 306 manufacturing operations and 92 product development, engineering and sales centres in 29 countries as of the date of this Conflict Minerals Report. We have over 147,000 employees focused on delivering superior value to our customers through innovative products and processes, and World Class Manufacturing. These figures include manufacturing operations, product development, engineering and sales centres and employees in equity accounted operations.

(b) Our Products

Our products are designed to meet the requirements and specifications of our automotive customers. Certain of these requirements and specifications entail the use of 3TG minerals. Our product capabilities include producing body, chassis, exterior, seating, powertrain, electronic, vision, closure and roof systems and modules, as well as complete vehicle engineering and contract manufacturing. A more detailed listing of our products can be found on pages 17-24 of our Annual Information Form, which is available on Magna’s corporate website at: http://www.magna.com/investors/financial-reports-public-filings?rpt=annualinfo

(c) Reliance on Supply Chain & Industry-Driven Initiatives

Due to the number and complexity of the products we manufacture, our supply chain consists of a substantial number of suppliers globally, the composition of which changes within each calendar year and from year to year. Moreover, we are generally many tiers removed from the smelters or refiners (“SORs”) of 3TG minerals in our supply chain. We do not, to the best of our knowledge, directly purchase 3TG minerals from any of the Covered Countries. As a downstream consumer of 3TG minerals, Magna must rely on its direct suppliers to gather and report to us information about SORs in the supply chain. Our direct suppliers are similarly reliant upon information provided to them by their own suppliers.

The structure, size and breadth of our supply chain, as well as the fact that a substantial portion of the suppliers in our supply chain are not obligated to file reports with the SEC (including reports under the Rule), makes gathering of complete and accurate conflict minerals information a lengthy and challenging process. In most cases, we do not have meaningful leverage over upstream suppliers or other actors in the supply chain. As a result of these challenges, in addition to our ongoing engagement with our direct production suppliers  as part of our conflict minerals compliance program (the “Program”), we participate in several industry-driven initiatives aimed at increasing awareness of, and participation in, conflict minerals reporting by suppliers.

SECTION 2: REASONABLE COUNTRY OF ORIGIN INQUIRY & CONCLUSION

Magna conducted the following RCOI for the 2015 reporting year:

A.            Applicability Assessment of Direct Production Suppliers

We conducted a good faith, risk-based applicability assessment of 8,064 suppliers, representing all of our direct production suppliers in 2015 (the “2015 Suppliers”), to identify those suppliers that were reasonably believed to represent the highest risk of supplying products or components to Magna that do or may contain 3TG minerals from one or more of the Covered Countries for the period between January 1, 2015 and December 31, 2015.

The set of criteria used to conduct the risk-based applicability assessment of suppliers included: (i) the likelihood of 3TG minerals content in supplied materials based on information available to Magna in its existing databases, including the International Material Data System (IMDS); and (ii) internal assessments by Magna purchasing personnel, engineering personnel and/or materials specialists. Responses received from suppliers in previous reporting years were also considered, but were not necessarily determinative.

Based on the criteria described above, the 2015 Suppliers were categorized as representing a “high” (Red), “uncertain/undeterminable” (Yellow) or “low/no” (Green) risk that their products supplied to Magna in 2015 contained 3TG minerals. 2015 Suppliers classified as Green were considered “out-of-scope” for 2015 reporting. 2015 Suppliers classified as Red or Yellow were considered “in-scope” for 2015 reporting. The results of Magna’s applicability assessment for 2015 were as follows:

· 6,533 (81%) of the 2015 Suppliers were classified as Green or out-of-scope for 2015 (the “Out-of-Scope Suppliers”).

· 1,542 (19%) of the 2015 Suppliers were classified as Red (245, or approximately 3%) or Yellow (1286, or approximately 16%) and therefore “in-scope” for 2015 reporting (the “In-Scope Suppliers”).

B.            Conclusion based on RCOI

We concluded in good faith that during the 2015 calendar year Magna:

i. manufactured and/or contracted to manufacture products containing 3TG minerals and determined that the use of such minerals was necessary to the functionality or production of these products; and

ii. could not exclude the possibility that a portion of the Company’s 3TG minerals originated in the Covered Countries (and were not from recycled or scrap sources).

Based on this conclusion, Magna conducted due diligence activities on the source and chain of custody of these necessary conflict minerals as described in this Conflict Minerals Report.

SECTION 3: DUE DILIGENCE PROCESS

A. Design of Due Diligence Framework

On the basis of the information obtained as part of our RCOI, we conducted due diligence regarding the source and chain of custody of the 3TG minerals contained in our products. Magna designed its due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2013) and related supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance specifies a five-step framework for risk-based due diligence for responsible supply chains of minerals sourced from conflict-affected and high-risk areas, which are described below in connection with our Program.

B.            Due Diligence Measures Performed

Magna’s due diligence measures for the 2015 reporting year included the following:

a. Establish Strong Company Management Systems

In accordance with the OECD Guidance, we previously established company management systems with regard to conflict minerals reporting, the main elements of which are described below:

i. Conflict Minerals Steering Committee & Program

We maintain a cross-functional conflict minerals steering committee (the “Steering Committee”), comprised of representatives from Magna’s legal and purchasing departments, which is tasked with managing and directing the day-to-day activities of Magna’s Program, including overseeing the activities of our Program team members in each region in which we operate.

The Program, which includes a supply chain system of controls and transparency through the adoption and use of the CMRT (defined in Subsection 3(b) (ii) below), facilitates the transfer of information through the supply chain regarding, among other things: (i) mineral country of origin; (ii) SORs being utilized; and (iii) the identity of new SORs to potentially undergo an audit through the Conflict-Free Smelter Program (described below). The Steering Committee is also responsible for our conflict minerals reporting to our automotive customers, as well as monitoring conflict minerals developments, including evolving industry best practices.

The Steering Committee includes representation from each of our operating segments: North America, Europe, Asia and Rest of World, and met or communicated regularly during 2015 and 2016 in connection with 2015 reporting year requirements, including in advance of key Program milestones.

ii. Oversight

The Steering Committee periodically reports the status of Magna’s Program to designated senior management.

iii. Policy Statement & Grievance Mechanism

We are committed to working with our supply chain to ensure compliance with the Rule. We previously adopted a policy statement which addresses our commitment to comply with the Rule and the expectations we place on our suppliers with respect to engagement in due diligence of their supply chains, as well as, conflict minerals reporting to us. The policy statement is publicly available on our corporate website at: http://www.magna.com/docs/default-source/corporate-governance/conflict-minerals-policy-statement.pdf.

The policy statement includes a grievance mechanism to facilitate reporting of concerns relating to Magna’s Program through Magna’s existing confidential and anonymous Good Business Line (GBL) (www.magnagbl.com). The  GBL is structured such that reports are received and tracked by an independent third-party provider, and communicated to members of the Steering Committee for review and appropriate action. To date, we have not received any GBL reports regarding our Program.

iv. Records Retention

We have a policy to retain conflict minerals documentation for at least five (5) years from the date of creation.

v. Supply Chain Engagement

We previously updated Magna’s standard global contract terms and conditions, including our global standard supplier requirements manual, to require suppliers to provide information or certification with respect to the origin of their products supplied to Magna. The requirements manual is incorporated by reference into our standard global contract terms and conditions. Purchase orders and other agreements in place with our direct suppliers are, however, typically in force for an extended period of time and we have limited ability to impose: (i) new contract terms, or (ii) other requirements that our suppliers must flow down to their own suppliers.

We also communicated with all direct production suppliers regarding our Program as detailed in this Conflict Minerals Report. In addition to the GBL grievance mechanism described above, we continue to maintain and communicate to our suppliers, a dedicated email address (conflict.minerals@magna.com) to facilitate supplier communication with us regarding the Program, including requests for assistance in fulfilling their reporting obligations to Magna.

vi. Industry Participation & Collaboration

The OECD Guidance encourages participation in industry-driven programs to establish a system of controls over the mineral supply chain which includes either a chain of custody or traceability system.

With respect to initiatives aimed at improving SOR validation, we continue to support the Conflict Free Sourcing Initiative (CFSI) as a member, as well as through participation in CFSI plenary member conference calls and as a part of its Due Diligence Practice Team. The CFSI has designed and manages a program (the Conflict Free Smelter Program (CFSP)) to identify the SORs that process 3TG minerals and independently audit those smelters and refiners to validate those that source only conflict-free 3TG minerals. Through our membership, which we view as critical to our Program, we have benefited from access to RCOI and smelter validation data, information regarding sourcing initiatives and regulatory developments, and access to valuable tools and resources which we are able to use to enhance our Program. Through our membership in the CFSI, we also support several complementary programs/organizations with which the CFSI regularly collaborates to address conflict minerals issues from an industry perspective, including: the ITRI Tin Supply Chain Initiative (iTSCi) program, the Better Sourcing Program, the Public-Private Alliance for Responsible Minerals Trade, and Solutions for Hope.

Throughout 2015 we also engaged with and actively participated as a member of several industry associations, particularly the Automotive Industry Action Group (AIAG). The initiatives of the AIAG and its Conflict Minerals Working Group include: efforts to improve supply chain transparency and compliance with the conflict minerals reporting requirements; development of best practices for conducting due diligence, supply chain engagement and reporting; development of common standards and reporting tools; engagement with SORs to promote conflict-free validation programs; and provision of training and awareness. We also provided opportunities for increased supply chain awareness of the conflict mineral reporting requirements and emerging best practices by sponsoring several AIAG industry events.  Magna also actively participates in the Original Equipment Suppliers Association (OESA), including its activities relating to conflict minerals compliance.

b. Identification and assessment of risks in the supply chain

i. Identification of Risks

To identify risks in the supply chain, Magna undertook the following measures:

· Conducted the risk-based applicability assessment of the 2015 Suppliers described above.

· Communicated at least once with all Out-of-Scope Suppliers (6,533 Suppliers) advising of their Green applicability rating and directing them to contact us if they believed their rating to be incorrect.

· Communicated regularly with all In-Scope Suppliers (as described below), including frequent reminders in situations where responses were not received by applicable deadlines.

· Enhanced the process for ensuring that changes to our supplier list were captured in our Program, including changes arising as a result of acquisitions or divestitures.

· Continued to enhance our methodology and processes for reviewing and responding to red flags generated by supplier survey responses, including more detailed communication to suppliers of our requirements for addressing the specific red flag(s) generated.

· Validated the accuracy and completeness of the SORs identified by In-Scope Suppliers, including by reviewing the list of such SORs against the CFSI (members-only access) list of processing facilities which have received a “Compliant” or other designation under the CFSP.

ii. In-Scope Supplier Due Diligence

Our due diligence efforts were focused primarily on communicating with the In-Scope Suppliers to obtain information with respect to the source and chain of custody of the necessary 3TG minerals in the products they supplied to us.  All In-Scope Suppliers, regardless of whether they were assigned a Yellow or Red rating, were sent an initial communication package requesting that they complete a survey based on the standardized template originally developed by the Electronic Industry Citizenship Coalition (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the “Conflict Minerals Reporting Template” or “CMRT”.  The CMRT was developed to facilitate disclosure and communication of information regarding SORs that provide materials in a company’s supply chain and includes, among other things, questions regarding a supplier’s conflict minerals policy, engagement with its own suppliers, origin of 3TG minerals in its products, and supplier due diligence.

In addition to describing the requirements of the Dodd-Frank Act and the Rule, and reinforcing Magna’s compliance expectations, the initial communication package directed In-Scope Suppliers to:

· Complete the CMRT through Magna’s preferred  web-based reporting method, the iPoint Conflict Minerals Platform (“iPCMP”), or alternatively, submitting the CMRT in Microsoft Excel spreadsheet format, by  the specified reporting deadline; and

· Request and obtain completed CMRTs from their own production suppliers, and encourage those suppliers to cascade the same requirement throughout their supply chain.

The supplier communication package, which was translated into multiple languages, also included: step-by-step instructions on how to complete each CMRT question; recommendations with regard to implementing or

enhancing a supplier’s own conflict minerals program; and details regarding AIAG and other conflict minerals tools and resources available to improve supplier reporting.

In-Scope Suppliers that provided responses in a format other than the CMRT were advised to resubmit their response in the requested format. In-Scope Suppliers that failed to respond at all to Magna were sent several reminders to submit a CMRT by a specified deadline.

iii. In-Scope Supplier Response Results

Magna received responses in a valid format from 1,058 (approximately 69%) of the In-Scope Suppliers, a modest improvement over the prior reporting year. The remaining 484 (approximately 31%) of the In-Scope Suppliers did not provide a response, despite our repeated communications, or provided a response in an invalid format that was not remedied by our reporting deadline.

iv. CMRT Review

Using the latest version of the AIAG CM-3 Guide for Responding to the Conflict Minerals Reporting Templates, other industry guidance and the experience gained during the first two reporting years of our Program, Magna reviewed the CMRT responses received from In-Scope Suppliers for red flags that would identify inconsistent, incomplete, or inaccurate responses. Responses that triggered select red flags were targeted for priority follow up and those suppliers were sent a request to address and resolve the red flag(s).

Following our review of valid responses submitted by In-Scope Suppliers, we determined that 210 (approximately 20%) of such responses were acceptable to Magna without the need for further follow up. When combined with the Out-of-Scope Suppliers, the aggregate of the 2015 Suppliers, that were ultimately designated as Green through either the applicability assessment, or as a result of the due diligence process, was 6,743, representing 84% of our 2015 Suppliers. No supplier indicated that they receive any 3TG minerals from sources that directly or indirectly financed or benefitted armed groups within the meaning of the Rule.

v. Efforts to Determine Mine or Location of Origin

As a downstream company, the primary focus of our due diligence on the source and chain of custody of the 3TG minerals in our supply chain was the collection and analysis of the CMRT responses received from our direct production suppliers. As described in this report, we verify the SOR information in the CMRT responses with data obtained from the CFSI. We believe this represents the most reasonable effort we can make to determine the mines or locations of origin of any 3TG minerals that may be used in our products, as discussed in Section 4 below.

c. Design and implement a strategy to respond to identified risks

Magna designed a risk management plan to identify, monitor and mitigate identified risks, the key elements of such plan being:

· Based on the red flag review, In-Scope Suppliers whose responses to select CMRT questions were identified as incomplete, inconsistent or inaccurate, were asked to address and resolve the red flag(s) and resubmit their CMRT.

· In-Scope Suppliers that did not respond to Magna’s initial survey request were sent frequent follow-up reminders, either directly or through periodic iPCMP system generated notices, requesting that they complete a CMRT and were advised that a failure to do so would receive elevated scrutiny from our purchasing department, and could affect future sourcing decisions.

· Suppliers who sent responses to Magna in a format other than the CMRT were asked to resubmit a response using the CMRT.

· The Steering Committee regularly reviewed a supplier response status dashboard and determined the timing and frequency of supplier follow-up communications.

· In order to increase supplier awareness and facilitate compliance with the conflict minerals reporting requirements, Magna’s written communications directed suppliers to visit the CFSI website (www.conflictfreesourcing.org) to take advantage of useful resources and tools, training information and guidance documents relating to the completion of the CMRT and conflict minerals reporting in general. In addition, Magna sponsors the AIAG’s annual Conflict Minerals Industry Briefing, which is organized to provide an update on industry strategies regarding conflict minerals reporting and due diligence best practices, as well as SOR engagement activities.

d. Carry out independent third-party audit of SOR due diligence practices

Magna is a downstream consumer of necessary conflict minerals and is several supply chain tiers removed from smelters and refiners which provide minerals and ores. Therefore, Magna does not perform, or direct the performance of, audits of SORs within the supply chain.  As outlined in the OECD Guidance upon which our Program is based, we support the CFSI’s cross-industry initiative that audits SORs to identify those facilities that have systems in place to assure sourcing of only conflict-free materials. The data on which we relied for certain statements in this Conflict Minerals Report (including in Appendix I) was obtained using the RCOI report we receive through our membership in the CFSI (Unique CFSI membership code: MAGN).

e. Report annually on supply chain due diligence

Magna’s conflict minerals policy states that we will comply with Section 1502 of the Dodd-Frank Act, which includes filing our Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report with the SEC (www.edgar.com) and making both documents publicly available on our corporate website (www.magna.com).

We also completed Conflict Minerals Reporting Templates for each of our customers who requested us to do so for the 2015 reporting year, in support of such customers’ reporting obligations under the Dodd-Frank Act and the Rule.

SECTION 4: DETERMINATION

Magna does not, to the best of its knowledge, directly purchase 3TG from any of the Covered Countries. As a downstream consumer of 3TG, Magna must rely on its direct production suppliers to gather information about smelters and refiners in the supply chain. Those direct production suppliers are similarly reliant upon information provided by their suppliers throughout the supply chain. There are generally multiple tiers of suppliers between 3TG smelters and refiners and Magna. We have determined that our efforts to seek information about the smelters and refiners in our supply chain through the submission of CMRTs from our

suppliers, as well as efforts to determine and improve the accuracy and quality of such submissions, represents the most reasonable effort Magna can make to determine the mines or locations of origin of the necessary conflict minerals in our supply chain.  However, most of the In-Scope Suppliers who responded to us did so at a company level and not a product level. As a result, despite receiving CMRT responses from In-Scope Suppliers that included SOR names (See Appendix I to this Conflict Minerals Report), including facilities that process minerals in one or more of the Covered Countries, such suppliers were unable to accurately report with specificity those facilities that were part of the supply chain for the products or components that were sold to Magna in 2015. We are therefore unable to determine the source and chain of custody of the necessary conflict minerals in our products for the 2015 reporting year.

SECTION 5: CONTINUOUS IMPROVEMENT EFFORTS TO MITIGATE RISK

Magna intends to take a number of steps to improve the response rate and quality of relevant supplier responses in the future reporting years and to attempt to mitigate the risk that necessary conflict minerals used in Magna products may benefit armed groups in the Covered Countries, including the following:

· Continuing to work with our suppliers to increase the completeness and accuracy of conflict minerals reporting, including, intensifying engagement with those suppliers that did not complete a CMRT, or that submitted an invalid response.

· Assessing opportunities to provide additional awareness, training, best practices or other assistance to our suppliers with respect to conflict minerals reporting.

· Integrating conflict minerals specific criteria to the supplier rating process used by Magna to evaluate sourcing decisions - in order to amplify our expectations with respect to conflict minerals reporting compliance.

· Maintaining our support for industry initiatives aimed at improving supply chain transparency, including, through our membership and participation in the AIAG, OESA and other industry associations.

· Supporting ongoing SOR audit and validation initiatives, including through our membership and participation in the CFSI.

· Annually evaluating opportunities to enhance our Program, including by monitoring best practices adopted by peer companies and automotive customers, and those developed by industry organizations.

· Continuing to monitor legislative developments regarding conflict-free minerals sourcing or reporting, including proposed regulations in the EU and China.

SECTION 6: INDEPENDENT AUDIT

Pursuant to SEC guidance issued April 29, 2014 and the SEC order issued May 2, 2014, we are not required to describe our products as “DRC conflict free”, “DRC conflict underterminable” or “having not been found to be DRC conflict free” (each as defined in the instructions to Form SD), and therefore we make no conclusion in this regard. Accordingly, an independent private sector audit with respect to Magna’s 2015 reporting year is not required.

APPENDIX I

TO THE 2015 CONFLICT MINERALS REPORT OF

MAGNA INTERNATIONAL INC.

PROCESSING FACILITIES IDENTIFIED IN SUPPLIER CMRT RESPONSES

The following table lists the name and country of the processing facilities identified in supplier CMRT responses to Magna International Inc., as well as the validation status of each processing facility under the CFSP, based on the CFSP Standard Smelter List as at May 30, 2016. Facilities included in supplier CMRT responses but identified as “Not Eligible” in the CFSP Standard Smelter List have been excluded.

The CFSP validation statuses used in the table below have the following meanings:

COMPLIANT		The entity is validated with the CFSP assessment and audit protocol (or independent third party audit program) as a result of providing sufficient documentation to demonstrate with reasonable confidence that the 3TG minerals they processed originated from conflict-free sources and have not benefitted armed groups.
ACTIVE		The entity is engaged in the CFSP assessment and audit protocol, but is not yet determined as Compliant.
IN COMMUNICATION		The entity is not yet Active, but is in communication with the CFSI and/or CFSI member companies.
OUTREACH REQUIRED		Outreach is needed by CFSI member companies to contact the entity and encourage their participation in the CFSP assessment and audit protocol.
TI-CMC MEMBER COMPANY		The entity is a member of the Tungsten Industry — Conflict Minerals Council (TI-CMC) and must undergo a CFSP audit within 2 years of joining the TI-CMC.

METAL		FACILITY NAME		COUNTRY		CFSP STATUS
Gold		Aida Chemical Industries Co., Ltd.		JAPAN		COMPLIANT
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY		COMPLIANT
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN		ACTIVE
Gold		AngloGold Ashanti Córrego do Sítio Minerção		BRAZIL		COMPLIANT
Gold		Argor-Heraeus S.A.		SWITZERLAND		COMPLIANT
Gold		Asahi Pretec Corp.		JAPAN		COMPLIANT
Gold		Asahi Refining Canada Ltd.		CANADA		COMPLIANT
Gold		Asaka Riken Co., Ltd.		JAPAN		COMPLIANT
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY		OUTREACH REQUIRED
Gold		Aurubis AG		GERMANY		COMPLIANT
Gold		Boliden AB		SWEDEN		COMPLIANT
Gold		Bangko Sentral ng Pilipinas (Central Bank of the Philippines)		PHILIPPINES		COMPLIANT
Gold		C. Hafner GmbH + Co. KG		GERMANY		COMPLIANT
Gold		Caridad		MEXICO		IN COMMUNICATION
Gold		CCR Refinery — Glencore Canada Corporation		CANADA		COMPLIANT
Gold		Cendres + Métaux S.A.		SWITZERLAND		ACTIVE
Gold		Chimet S.p.A.		ITALY		COMPLIANT
Gold		Chugai Mining		JAPAN		IN COMMUNICATION
Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA		IN COMMUNICATION
Gold		DODUCO GmbH		GERMANY		COMPLIANT
Gold		Dowa		JAPAN		COMPLIANT
Gold		DSC (Do Sung Corporation)		KOREA		ACTIVE
Gold		Eco-System Recycling Co., Ltd.		JAPAN		COMPLIANT
Gold		Elemetal Refining, LLC		UNITED STATES		COMPLIANT
Gold		Gansu Seemine Material Hi-Tech Co., Ltd		CHINA		OUTREACH REQUIRED
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA		OUTREACH REQUIRED
Gold		Guangdong Jinding Gold Limited		CHINA		OUTREACH REQUIRED

Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA		OUTREACH REQUIRED
Gold		Heimerle + Meule GmbH		GERMANY		COMPLIANT
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY		COMPLIANT
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA		IN COMMUNICATION
Gold		Hwasung CJ Co., Ltd		KOREA		IN COMMUNICATION
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA		COMPLIANT
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN		COMPLIANT
Gold		Istanbul Gold Refinery		TURKEY		COMPLIANT
Gold		Japan Mint		JAPAN		COMPLIANT
Gold		Jiangxi Copper Co., Ltd.		CHINA		COMPLIANT
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION		COMPLIANT
Gold		JSC Uralelectromed		RUSSIAN FEDERATION		COMPLIANT
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN		COMPLIANT
Gold		Kazzinc		KAZAKHSTAN		COMPLIANT
Gold		Kennecott Utah Copper LLC		UNITED STATES		COMPLIANT
Gold		Kojima Chemicals Co., Ltd.		JAPAN		COMPLIANT
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN		OUTREACH REQUIRED
Gold		L’azurde Company For Jewelry		SAUDI ARABIA		OUTREACH REQUIRED
Gold		Lingbao Gold Co., Ltd.		CHINA		OUTREACH REQUIRED
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA		OUTREACH REQUIRED
Gold		LS-NIKKO Copper Inc.		KOREA		COMPLIANT
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA		OUTREACH REQUIRED
Gold		Materion		UNITED STATES		COMPLIANT
Gold		Matsuda Sangyo Co., Ltd.		JAPAN		COMPLIANT
Gold		Metalor Technologies (Singapore) Pte., Ltd.		SINGAPORE		COMPLIANT
Gold		Metalor Technologies S.A.		SWITZERLAND		COMPLIANT
Gold		Metalor USA Refining Corporation		UNITED STATES		COMPLIANT
Gold		Metalúrgica Met-Mex Peñoles, S.A. De C.V.		MEXICO		COMPLIANT
Gold		Mitsubishi Materials Corporation		JAPAN		COMPLIANT
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN		COMPLIANT
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION		COMPLIANT
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		TURKEY		COMPLIANT
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN		ACTIVE
Gold		Nihon Material Co., Ltd.		JAPAN		COMPLIANT
Gold		OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)		RUSSIAN FEDERATION		COMPLIANT
Gold		OJSC Novosibirsk Refinery		RUSSIAN FEDERATION		COMPLIANT
Gold		PAMP S.A.		SWITZERLAND		COMPLIANT
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA		OUTREACH REQUIRED
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION		COMPLIANT
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA		COMPLIANT
Gold		PX Précinox S.A.		SWITZERLAND		COMPLIANT
Gold		Royal Canadian Mint		CANADA		COMPLIANT
Gold		Sabin Metal Corp.		UNITED STATES		OUTREACH REQUIRED
Gold		Samduck Precious Metals		KOREA		ACTIVE
Gold		SAMWON Metals Corp.		KOREA		IN COMMUNICATION
Gold		SEMPSA Joyería Platería S.A.		SPAIN		COMPLIANT
Gold		So Accurate Group, Inc.		UNITED STATES		OUTREACH REQUIRED
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION		COMPLIANT
Gold		Solar Applied Materials Technology Corp.		TAIWAN		COMPLIANT
Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN		COMPLIANT
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN		COMPLIANT
Gold		Tokuriki Honten Co., Ltd.		JAPAN		COMPLIANT
Gold		Torecom		KOREA		ACTIVE
Gold		Umicore Precious Metals Thailand		THAILAND		COMPLIANT

Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM		COMPLIANT
Gold		United Precious Metal Refining, Inc.		UNITED STATES		COMPLIANT
Gold		Valcambi S.A.		SWITZERLAND		COMPLIANT
Gold		Western Australian Mint trading as The Perth Mint		AUSTRALIA		COMPLIANT
Gold		Yamamoto Precious Metal Co., Ltd.		JAPAN		COMPLIANT
Gold		Yokohama Metal Co., Ltd		JAPAN		COMPLIANT
Gold		Yunnan Copper Industry Co., Ltd		CHINA		OUTREACH REQUIRED
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA		COMPLIANT

METAL		FACILITY NAME		COUNTRY		CFSP STATUS
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA		COMPLIANT
Tantalum		Conghua Tantalum and Niobium Smeltry		CHINA		COMPLIANT
Tantalum		Duoluoshan		CHINA		COMPLIANT
Tantalum		Exotech Inc.		UNITED STATES		COMPLIANT
Tantalum		F&X Electro-Materials Ltd.		CHINA		COMPLIANT
Tantalum		Global Advanced Metals Aizu		JAPAN		COMPLIANT
Tantalum		Global Advanced Metals Boyertown		UNITED STATES		COMPLIANT
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA		COMPLIANT
Tantalum		H.C. Starck Co., Ltd.		THAILAND		COMPLIANT
Tantalum		H.C. Starck GmbH Goslar		GERMANY		COMPLIANT
Tantalum		H.C. Starck GmbH Laufenburg		GERMANY		COMPLIANT
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY		COMPLIANT
Tantalum		H.C. Starck Inc.		UNITED STATES		COMPLIANT
Tantalum		H.C. Starck Ltd.		JAPAN		COMPLIANT
Tantalum		H.C. Starck Smelting GmbH & Co.KG		GERMANY		COMPLIANT
Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA		COMPLIANT
Tantalum		Hi-Temp Specialty Metals, Inc.		UNITED STATES		COMPLIANT
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA		COMPLIANT
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA		COMPLIANT
Tantalum		KEMET Blue Metals		MEXICO		COMPLIANT
Tantalum		KEMET Blue Powder		UNITED STATES		COMPLIANT
Tantalum		LSM Brasil S.A.		BRAZIL		COMPLIANT
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA		COMPLIANT
Tantalum		Mineração Taboca S.A.		BRAZIL		COMPLIANT
Tantalum		Mitsui Mining & Smelting		JAPAN		COMPLIANT
Tantalum		Molycorp Silmet A.S.		ESTONIA		COMPLIANT
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA		COMPLIANT
Tantalum		Plansee SE Liezen		AUSTRIA		COMPLIANT
Tantalum		Plansee SE Reutte		AUSTRIA		COMPLIANT
Tantalum		QuantumClean		UNITED STATES		COMPLIANT
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION		COMPLIANT
Tantalum		Taki Chemicals		JAPAN		COMPLIANT
Tantalum		Telex Metals		UNITED STATES		COMPLIANT
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN		COMPLIANT

METAL		FACILITY NAME		COUNTRY		CFSP STATUS
Tin		Alpha		UNITED STATES		COMPLIANT
Tin		China Tin Group Co., Ltd.		CHINA		COMPLIANT
Tin		Cooperativa Metalurgica de Rondônia Ltda.		BRAZIL		COMPLIANT
Tin		CV Gita Pesona		INDONESIA		COMPLIANT
Tin		Dowa		JAPAN		COMPLIANT
Tin		Estanho de Rondônia S.A.		BRAZIL		IN COMMUNICATION
Tin		Fenix Metals		POLAND		COMPLIANT
Tin		Gejiu Non-Ferrous Metal Processing Co., Ltd.		CHINA		COMPLIANT
Tin		Gejiu Zili Mining and Metallurgy Co., Ltd.		CHINA		IN COMMUNICATION
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL		COMPLIANT
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA		COMPLIANT
Tin		Melt Metais e Ligas S.A.		BRAZIL		COMPLIANT
Tin		Metallo-Chimique N.V.		BELGIUM		COMPLIANT
Tin		Mineração Taboca S.A.		BRAZIL		COMPLIANT
Tin		Minsur		PERÚ		COMPLIANT

Tin		Mitsubishi Materials Corporation		JAPAN		COMPLIANT
Tin		O.M. Manufacturing  Philippines, Inc.		PHILIPPINES		COMPLIANT
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND		COMPLIANT
Tin		Operaciones Metalurgical S.A.		BOLIVIA		COMPLIANT
Tin		PT Aries Kencana Sejahtera		INDONESIA		COMPLIANT
Tin		PT Artha Cipta Langgeng		INDONESIA		COMPLIANT
Tin		PT ATD Makmur Mandiri Jaya		INDONESIA		COMPLIANT
Tin		PT Babel Inti Perkasa		INDONESIA		COMPLIANT
Tin		PT Bangka Tin Industry		INDONESIA		COMPLIANT
Tin		PT Belitung Industri Sejahtera		INDONESIA		COMPLIANT
Tin		PT BilliTin Makmur Lestari		INDONESIA		COMPLIANT
Tin		PT Bukit Timah		INDONESIA		COMPLIANT
Tin		PT Eunindo Usaha Mandiri		INDONESIA		COMPLIANT
Tin		PT Inti Stania Prima		INDONESIA		COMPLIANT
Tin		PT Justindo		INDONESIA		COMPLIANT
Tin		PT Karimun Mining		INDONESIA		ACTIVE
Tin		PT Mitra Stania Prima		INDONESIA		COMPLIANT
Tin		PT Panca Mega Persada		INDONESIA		COMPLIANT
Tin		PT Prima Timah Utama		INDONESIA		COMPLIANT
Tin		PT Refined Bangka Tin		INDONESIA		COMPLIANT
Tin		PT Sariwiguna Binasentosa		INDONESIA		COMPLIANT
Tin		PT Stanindo Inti Perkasa		INDONESIA		COMPLIANT
Tin		PT Sumber Jaya Indah		INDONESIA		COMPLIANT
Tin		PT Timah (Persero) Tbk Kundur		INDONESIA		COMPLIANT
Tin		PT Timah (Persero) Tbk Mentok		INDONESIA		COMPLIANT
Tin		PT Tinindo Inter Nusa		INDONESIA		COMPLIANT
Tin		Rui Da Hung		TAIWAN		COMPLIANT
Tin		Soft Metais Ltda.		BRAZIL		COMPLIANT
Tin		Thaisarco		THAILAND		COMPLIANT
Tin		White Solder Metalurgia e Mineração Ltda.		BRAZIL		COMPLIANT
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA		ACTIVE
Tin		Yunnan Tin Company Limited		CHINA		COMPLIANT

METAL		FACILITY NAME		COUNTRY		CFSP STATUS
Tungsten		A.L.M.T. Tungsten Corp.		JAPAN		COMPLIANT
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA		COMPLIANT
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		CHINA		TI-CMC MEMBER COMPANY
Tungsten		Fujian Jinxin Tungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		Ganxian Shirui New Material Co., Ltd.		CHINA		IN COMMUNICATION
Tungsten		Ganzhou Huaxing Tungsten Products Co., Ltd.		CHINA		COMPLIANT
Tungsten		Ganzhou Jiangwu Ferrotungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		Ganzhou Non-ferrous Metals Smelting Co., Ltd.		CHINA		TI-CMC MEMBER COMPANY
Tungsten		Ganzhou Seadragon W & Mo Co., Ltd.		CHINA		COMPLIANT
Tungsten		Global Tungsten & Powders Corp.		UNITED STATES		COMPLIANT
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		H.C. Starck GmbH		GERMANY		COMPLIANT
Tungsten		H.C. Starck Smelting GmbH & Co.KG		GERMANY		COMPLIANT
Tungsten		Hunan Chenzhou Mining Group Co., Ltd.		CHINA		COMPLIANT
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA		COMPLIANT
Tungsten		Japan New Metals Co., Ltd.		JAPAN		COMPLIANT
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA		IN COMMUNICATION
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA		ACTIVE
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA		ACTIVE
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA		ACTIVE
Tungsten		Kennametal Fallon		UNITED STATES		ACTIVE
Tungsten		Kennametal Huntsville		UNITED STATES		COMPLIANT
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA		COMPLIANT

Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		VIETNAM		COMPLIANT
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIETNAM		COMPLIANT
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd.		VIETNAM		COMPLIANT
Tungsten		Wolfram Bergbau und Hütten AG		AUSTRIA		COMPLIANT
Tungsten		Xiamen Tungsten (H.C.) Co., Ltd.		CHINA		COMPLIANT
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA		COMPLIANT
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA		COMPLIANT