EX-1.01 2 exhibit10105272016.htm EXHIBIT 1.01 Exhibit

Exhibit 1.01 to Form SD

Conflict Minerals Report


CREE, INC.
For The Year Ended December 31, 2015
This Conflict Minerals Report (CMR) of Cree, Inc. (Cree, the Company, we, us, or our) for the year ended December 31, 2015 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule) promulgated by the Securities and Exchange Commission (the SEC) pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). This CMR has been prepared on behalf of Cree management.

This CMR contains forward-looking statements regarding our business and conflict minerals efforts, including steps we intend to take to mitigate the risk that conflict minerals in our products benefit certain armed groups. Words such as “expects,” “intends,” “believes,” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this CMR. Additionally, statements concerning future matters that are not historical are forward-looking statements. Forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated by the forward-looking statements. Risks, uncertainties, assumptions, and other factors that could cause or contribute to such differences in results and outcomes include, among other things, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our conflict minerals program and our ability to identify and mitigate related risks in our supply chain. We undertake no obligation to review or update any forward-looking statements to reflect events or circumstances occurring after filing this CMR with the SEC.

Cree has performed due diligence measures as required by the Rule with the goal of determining the chain of custody and country of origin information for the necessary conflict minerals,1 also referred to as 3TGs, used in our products manufactured in 2015. In particular, we sought to determine whether any of the necessary conflict minerals in our product supply chains may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country, also referred to as the Covered Countries, and whether any conflict minerals originating in the Covered Countries directly or indirectly financed or benefited armed groups in the Covered Countries. As used herein, the term “manufactured” includes products manufactured or contracted to be manufactured by Cree.
_______________
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The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country.



Because not all suppliers have provided smelter and refiner data and the data provided by some of our suppliers is incomplete, Cree is unable at this time to determine the exact origin of the conflict minerals in all of the assemblies, components, and minerals supplied to us. Therefore, we cannot exclude the possibility that some conflict minerals used in our products manufactured in 2015 may have originated in the Covered Countries, come from sources other than recycled or scrap sources, or come from sources that directly or indirectly financed or benefited armed groups in the Covered Countries.  We have obtained no information, however, to indicate that any conflict minerals used in our products manufactured in 2015 originated in the Covered Countries and directly or indirectly financed or benefited armed groups in the Covered Countries.

Pursuant to the Rule, Cree is submitting this CMR as an Exhibit to its Form SD.

Company and Product Overview
Cree is a leading innovator of lighting-class light emitting diode (LED) products, lighting products, and semiconductor products for power and radio-frequency (RF) applications. Our products are targeted for applications such as indoor and outdoor lighting, video displays, transportation, electronic signs and signals, power supplies, solar inverters, and wireless systems.

We develop and manufacture semiconductor materials and devices primarily based on silicon carbide (SiC), gallium nitride (GaN), and related compounds. Our LED products consist of LED components, LED chips, and SiC materials. Our lighting products primarily consist of LED lighting systems, lamps and bulbs. We design, manufacture and sell lighting systems, lamps, and bulbs for indoor and outdoor applications, with our primary focus on LED lighting systems for the commercial and industrial markets. In addition, we develop, manufacture and sell power products made from SiC and RF devices made from GaN.

The majority of our products are manufactured at our production facilities located in North Carolina, Wisconsin, and China. We also use contract manufacturers for certain aspects of product fabrication, assembly, and packaging.

Our SiC materials, in the form of substrates and boules, do not contain any 3TGs, and thus no further due diligence is required with respect to those products. All other Cree products have the potential to include one or more of the conflict minerals. Table 1 below outlines Cree’s products and provides typical conflict mineral content along with the percent of revenue per business unit.


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Table 1
Cree Business Unit
Percent of Cree Revenue*
Products
Percentage of Products that contain Conflict Minerals?
Typical Conflict Mineral Content by Weight Percentage
Au
Sn
W
Ta
LED Lighting Products
58%
LED Lamps and Bulbs
100%
0.1 - 1%
0.1 - 1%
< 0.1%
< 0.1%
LED Lighting
100%
0.05 - 1%
0.1 - 1%
< 0.1%
< 0.05%
Accessories
50-75%
< 0.1%
0 - 1%
< 0.05%
< 0.1%
LED Products
35%
Materials
0%
N/A
N/A
N/A
N/A
LED Chips
100%
0.5 - 3%
0.2 - 10%
0 - 0.6%
0 %
LED Components
100%
0.1 - 0.3%
0 - 0.3%
0 - 0.1%
0 - 0.1%
Modules + Drivers
100%
0.1 - 0.3%
0.1 - 0.5%
0 - 0.01%
0 - 0.1%
Accessories
30-50%
< 0.1%
< 0.5%
0%
0%
Power & RF Products
7%
RF Die
100%
0.5 - 35%
0.2 - 10%
0 - 0.6%
0 %
Power Diodes
100%
< 0.05%
< 0.05%
< 0.1%
0%
RF Transistor Packages
100%
0.01 - 0.1%
< 0.01%
0 - 85%
< 0.05%
*Note: Based on reported revenue for six months ended December 27, 2015.

Conflict Minerals Policy

Cree has adopted a Conflict Minerals Policy under which it expects its suppliers to develop internal conflict mineral policies, due diligence frameworks, and management systems that meet the minimum requirements of the guidelines developed by the Organisation for Economic Co-operation and Development (OECD). Our suppliers’ conflict minerals policies must be designed to identify and eliminate from use in products sold to Cree any conflict minerals which are known to come from sources funding armed groups in the DRC region. Cree requires its direct suppliers to source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program such as the Conflict-Free Sourcing Initiative (CFSI) or its equivalent. Cree fully expects our suppliers to cooperate with us and to provide information to support these efforts, even if the supplier is not directly subject to the Act. Suppliers that do not reasonably comply with Cree’s Conflict Mineral Policy will be reviewed by Cree’s supply chain management to assess whether Cree will conduct business with those suppliers in the future.

To view Cree’s complete Conflict Minerals Policy, visit our webpage located at: http://www.cree.com/Support/Conflict-Minerals. By this reference we are incorporating into this Conflict Minerals Report only our Conflicts Minerals Policy and not the entire contents of our webpage.

Description of Our RCOI Process
Cree’s scoping process included creating a master supplier list of potential in-scope suppliers for 2015 by filtering our supplier database to remove suppliers known to be outside of the scope of the reasonable country of origin inquiry (RCOI), such as service providers, equipment vendors, and indirect material suppliers. The objective of filtering was to identify only suppliers that provided to

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Cree items potentially containing 3TGs that were incorporated into final products in the calendar year 2015.

Once filtered, the master list was provided to Cree’s third-party conflict mineral compliance service provider (the CSP) to conduct a survey using the Conflict Minerals Reporting Template (CMRT). The CMRT was developed by the CFSI, an initiative sponsored by the Electronic Industry Citizenship Coalition, or the EICC, and the Global e-Sustainability Initiative, or the GeSI, and requires suppliers to identify the smelters and refiners that process the necessary conflict minerals contained in the items supplied and the country of origin thereof. During the supplier survey process, suppliers were contacted and responses were tracked using the CSP’s interactive cloud-based platform. This platform allows suppliers to upload completed survey forms directly to the system for review and management.

The CSP launched Cree’s 2015 campaign by providing information about itself and training materials to educate the suppliers believed to be in-scope on 3TGs and the CSP’s reporting system. The full campaign involved multiple communications by the CSP and/or Cree to each supplier, including automated emails, personalized emails, and in some instances phone calls. All significant communications were monitored and tracked in the CSP’s platform for transparency and future reporting.

Based on supplier feedback, the CSP and Cree determined which surveyed suppliers were also outside the scope of the RCOI. These suppliers were marked out-of-scope on the master list. In all other cases, the CSP and Cree reviewed the information provided by each supplier to determine the quality and nature of the response and to determine whether further action was needed to meet Cree’s expectations at this point in the process.

Although nearly 93% of Cree’s in-scope suppliers responded to the RCOI, up from 69% in 2014, some of those suppliers have not yet provided complete smelter or refiner data after several requests by Cree and the CSP. For the suppliers that responded and provided smelter or refiner data, the CSP reviewed all supplier responses that claimed in the declaration section of the CMRT to have known DRC sourced material. The CSP compared the smelting and refining facilities identified in each of these surveys to the list of facilities that have received a “conflict-free” designation from the Conflict-Free Smelter (CFS) program, another resource developed by the CFSI, to determine whether each facility has been certified “conflict-free.”

Because there is considerable overlap between our RCOI and due diligence processes, the determinations we were able to make based on our survey efforts are discussed in more detail in the section below entitled “Due Diligence Results.”

Design of Our Due Diligence Process

Cree’s due diligence measures have been designed to conform in all material respects with the 5-step framework in The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the OECD Guidance) as it relates to our position in the conflict minerals supply chain. A summary of the correlation between our due diligence measures

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and the 5-step framework set forth in the OECD Guidance is described below.

Step 1: Establish strong company management systems

Cree has established a strong management system to address our compliance with the Rule. Our management system is sponsored by the Company’s Chief Financial Officer with support from a team of internal subject matter experts from relevant functions such as Engineering, Procurement, Legal, and Internal Audit. The team of subject matter experts is responsible for implementing Cree’s conflict minerals compliance strategy and in 2015 was led by the Vice President, Supply Chain and Logistics, who acted as the conflict minerals program manager. The program manager informs senior management about the results of our due diligence efforts on a regular basis, and the Company’s Chief Financial Officer briefs the Company’s Audit Committee at least quarterly.

As described above, Cree has adopted a Conflict Minerals Policy. Cree has developed a due diligence strategy to implement our policy that includes using a CSP to educate Cree’s suppliers on the requirements of the Rule annually, or more frequently when deemed necessary, survey our suppliers using the CMRT, review and analyze results, and maintain records for transparency, reporting, and accountability purposes. Consistent with the OECD Guidelines, documentation relevant to Cree’s compliance with the Rule will be retained for a minimum period of five years after the date the related CMR is submitted to the SEC.

We have strengthened our engagement with our suppliers by providing education, through the CSP, on the Rule as well as by communicating, through our Conflict Minerals Policy and contractual provisions, our expectations for suppliers desiring to continue to do business with Cree. Specifically, this includes adding to our standard contracts language that obligates suppliers to exercise due diligence to comply with our Conflict Minerals Policy, which includes a requirement that the supplier must source conflict minerals from smelters and refiners whose due diligence practices have been validated by an independent third party audit program, such as the CFSI or a mutually agreed equivalent. As existing contracts are renewed with suppliers, the new conflict mineral language is being incorporated as well. We have also leveraged the existing communications between Cree’s procurement team and our suppliers to encourage the suppliers to interact with the CSP.

In 2015, Cree implemented a Supplier Code of Conduct, which requires among other things that each Cree in-scope supplier eliminate from use in its products sold to Cree any Conflict Minerals which are known to come from sources funding armed groups in the DRC region. To assist in determining in-scope suppliers and to provide an opportunity for earlier interaction, we have also included in our new supplier setup procedures a section asking the new supplier to indicate if any product(s) sold to Cree may contain 3TG material. Lastly, we have created a Cree conflict minerals on-line platform that provides employees, suppliers, and other stakeholders a place to report any grievances or concerns with our conflict minerals program (http://www.cree.com/Support/Conflict-Minerals/Conflict-Minerals-Form).


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Step 2: Identify and assess risk in the supply chain

Because of our size, the complexity of our products, our position in the supply chain, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify sources of conflict minerals upstream from our direct suppliers. Further, we typically do not have direct relationships with 3TG smelters or refiners. Accordingly, we must rely on our direct suppliers to provide information on the origin of the 3TGs contained in assemblies, components, and materials supplied to us - including sources of 3TGs that are supplied to them from upstream sources.

The RCOI activities described above are an integral part of Cree’s efforts to identify and assess the risks in our supply chain. As further described below regarding our due diligence process, our CSP’s system is designed to automatically identify and flag missing information and inconsistencies in supplier CMRTs. Flagged suppliers are contacted to gather pertinent data and perform an assessment of the supplier's commitment to the due diligence process. A revised CMRT is requested and stored in the CSP’s database along with all of the information and findings from this process. During the RCOI process, known DRC sources are identified, and the smelter or refiner (SOR) status is validated against the current CFSI status. If further investigation of a SOR is deemed necessary, we gather additional information through other independent third party audit programs such as TI-CMC, the Responsible Jewellery Council’s Chain-of-Custody Certification Program, and the London Bullion Market Association’s Responsible Gold Programme.

Step 3: Design and implement a strategy to respond to identified risks

While many risks exist in the search for the origin of the conflict minerals used in assemblies, components, and materials supplied to Cree, we believe that one of the greatest risks to Cree is the inability to obtain complete and accurate information to make determinations about our own products. Without this information, we in turn become an obstacle to our customers making determinations about their products.

While there are numerous initiatives working to improve transparency and accountability at the smelter and refiner levels of the supply chain, we can only benefit from the information being developed by these initiatives if our suppliers are able to trace back the conflict minerals in their products to a specific smelter or refiner.
 
This objective is reflected in our Conflict Minerals Policy, which indicates that we expect all of our suppliers to develop their own conflict mineral policies, due diligence frameworks, and management systems, and to provide us all information reasonably needed for us to comply with the Rule. We have included similar obligations in our contractual agreements with our direct suppliers. Our primary focus has shifted from ascertaining whether our immediate suppliers have undertaken efforts to build their own due diligence capabilities meeting the expectations set forth in our Conflicts Minerals Policy to collecting and validating smelter information in completed CMRTs. Our due diligence framework also includes a corrective action management plan designed to move our suppliers toward compliance with our Conflict Minerals Policy. This includes a requirement that any suppliers identified as utilizing a smelter that is known to process Conflict Minerals from sources funding armed groups in the DRC region be placed in escalation mode for further review by our supply chain management and interaction with the supplier in accordance with our Conflict Minerals

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Policy. For 2015, all known DRC sources identified in our supply chain were either CFSI “compliant” or “active”.

Step 4: Carry out independent third-party audit of refiner’s due diligence practices
We typically do not have direct relationships with any 3TG smelter or refiner, so it is impracticable if not impossible for us to perform or direct audits of these entities within our supply chain. Rather, we have relied on audits conducted under the CFS program operated by the CFSI and other reputable auditors. The CFSI publishes a list of smelters, by conflict mineral, found to be compliant with the CFS protocol. Pursuant to the CFS program, a smelter voluntarily submits to an independent third party evaluation of its procurement activities and an assessment as to whether the materials processed by the smelter originated from conflict-free sources. If the smelter is able to demonstrate that the materials it processes are conflict-free, based on the sourcing location requirements of the CFS program, the smelter will be considered CFS-compliant.

The CFSI also makes available to its members information on the countries of origin of the conflict minerals processed by each CFS-compliant smelter. We are an active member of the CFSI in order to support their efforts and to have broader access to the country of origin information as well as other valuable tools and resources provided to its members.

Cree management has determined that it is reasonable and appropriate to rely on the results of the CFS program audits and other comparable audits. Given our position in the supply chain, however, our due diligence measures can provide only reasonable assurances, not guarantees, regarding the chain of custody and country of origin of the necessary conflict minerals in our products.

Step 5: Report on supply chain due diligence

The measures we took in 2015 to exercise due diligence on the source and chain of custody of our conflict minerals were as follows:

•
communicated our Conflict Minerals Policy to our suppliers and posted a copy on our webpage at http://www.cree.com/Support/Conflict-Minerals;
•
directed our in-scope suppliers to provide information concerning SORs in their supply chains by completing and sending to us the Conflict Minerals Reporting Template (CMRT) that provides a common means for suppliers to provide customers with information on the source of conflict minerals;
•
analyzed suppliers’ CMRT responses for completeness and accuracy and pursued further information from the supplier when warranted;
•
sent outreach letters to SORs to influence and leverage their participation to becoming CFS-compliant;
•
sent outreach letters to our in-scope suppliers to influence and leverage, or ultimately remove SORs who are not CFS-compliant; and
•
written a Supplier Code of Conduct defining our expectations of our in-scope suppliers to develop internal Conflict Minerals policies, due diligence frameworks, and management systems that are designed to identify and eliminate from use in products sold to Cree any conflict minerals which are known to come from sources funding armed groups in the DRC

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region. Our Supplier Code of Conduct is located at http://www.cree.com/About-Cree/Info-for-Cree-Suppliers.

No other contents from our website are intended to be incorporated into the Conflict Minerals Report by these website references.

Description of Our Due Diligence Process

Cree’s due diligence process reflects our strategy for identifying, assessing, and responding to the risk that conflict minerals known to have directly or indirectly financed or benefited armed groups in the Covered Countries may be included in our product supply chains. This description is of our process only and is not intended to imply that we have fully implemented this process for all of our suppliers in calendar year 2015.

Our due diligence process includes data evaluation in three phases, all of which are designed to move supplier responses toward compliance with our Conflict Minerals Policy:

Phase 1 - Did the supplier pass our minimum criteria for its CMRT, as assessed by our CSP?
Phase 2 - Did the supplier provide information in its 2015 CMRT survey response which passed Cree’s data validation criteria, as assessed by our CSP?
Phase 3 - Were the CSP’s conclusions reasonable, as assessed by Cree’s subject matter experts on the products supplied to us, and can the smelter information be validated by Cree?

In designing our due diligence process for calendar year 2015, we first reviewed prior year minimum criteria for evaluation during Phase 1 and reaffirmed the applicability for 2015. In evaluating a supplier’s CMRT, we primarily look for three things: effective date—is the information in the report current; completeness—are all of the questions reasonably answered; and consistency—are the supplier’s responses internally consistent.

Suppliers that do not meet these three requirements are contacted with the objective of helping them to understand the requirements for submitting a valid and complete CMRT. Phase 1 is essentially Cree’s corrective action management stage. By implementing supplier corrective action measures, Cree is helping to ensure its suppliers put policies and procedures in place that will produce the necessary data in an accurate and reliable manner.

During Phase 2, the CSP reviews the supplier’s information in its 2015 survey response to validate smelter and refiner information. Smelter and refiner information is reviewed and corrected, and duplicate information is removed whenever possible. All of this data and correspondence is stored in the CSP’s platform. Verified smelter and refiner information is used to obtain reliable information from CFSI and other reputable auditors on the country of origin of the conflict minerals processed by the known smelters or refiners in Cree’s supply chains.
 
If there are no obvious inaccuracies in the supplier’s CMRT responses, the supplier’s CMRT is deemed reliable by the CSP. If the supplier’s CMRT response is inadequate, the supplier’s survey response will be placed in escalation mode and corrective action measures will be applied.

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After the CSP completes its analysis under the first two phases, Cree commences its own evaluation in Phase 3. During this evaluation, Cree’s subject matter experts review the information provided by each supplier and the conclusions reached by the CSP from that supplier’s survey data to determine whether those conclusions were reasonable based on information the experts have about the assemblies, components, or materials supplied to Cree. By bringing our specialized knowledge of the industry and Cree’s products into the analysis, Cree is able to identify inaccuracies and inconsistencies in the survey data that may not be obvious to the CSP. If Cree finds inaccuracies and inconsistencies in the survey data, the supplier’s survey response will be placed in escalation mode and corrective action measures will be applied.

Additionally, during Phase 3 Cree validates supplier provided smelter information against the most current known CFSI aliases, smelter status, and mine sourcing. This step allows Cree to determine the certification status of the smelters, as provided in Table 3 below.

There were many challenges in 2015 similar to the previous year’s RCOI, and it is clear that many suppliers do not fully understand the scope of the requirements of the Rule, and that many privately held companies put little or no effort into screening their SOR lists. This, coupled with SOR and recycler dynamics, such as acquisitions, mergers, relocation, or simply going out of business, resulted in uncertainty with respect to SOR accuracy at any given moment in time. We continue to be reminded that it is impractical to expect all supply chain participants to have completed their due diligence procedures or even to be at the same stage of completion. Accordingly, our goal at this point, as reflected in our multi-phase due diligence efforts, is to get all suppliers to demonstrate that they are on the right path to obtain and provide to Cree complete and accurate SOR data. We believe that this will enable us in future years to better determine the facilities used to process the necessary conflict minerals used in the assemblies, components, and materials supplied to us, the country of origin of the necessary conflict minerals in those items, and the mine or location of origin with the greatest possible specificity.

Due Diligence Results
We received responses from the majority of our suppliers known to be in scope. We reviewed the responses against the minimum criteria we developed to determine which ones required further assistance to progress through Phase 3. The CSP and Cree worked directly with the suppliers that required further assistance to obtain revised responses or a commitment to meet the minimum criteria within a reasonable period of time.

Of the responses received, most of our suppliers met our minimum criteria for Phase 1. Of the suppliers contacted for additional information and clarification, a significant percentage provided sufficient information in Phase 2 to validate the accuracy of the survey responses. Further, during our evaluation in Phase 3, Cree determined that the conclusions reached by the CSP in Phase 2 were correct in almost all cases and that most of the smelters could be validated and accurately classified.

Despite our efforts, our due diligence measures can provide only reasonable, not absolute, assurances regarding the source and chain of custody of the necessary conflict minerals because we are relying on source information provided by our suppliers, many of whom in turn obtained the

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information from their suppliers. We also are relying on information obtained and disseminated by independent third party audit programs, and such sources of information may provide inaccurate or incomplete information.

Additionally, a majority of the responses that included SOR data provided data at a company level as opposed to a product level. We were therefore unable to determine with certainty that the 3TGs reported by these suppliers were contained in assemblies, components, or materials actually supplied to us in 2015. None of the respondents, however, provided information that the necessary conflict minerals used in the assemblies, components, and materials they supplied to Cree were known to have directly or indirectly financed or benefited armed groups in the Covered Countries.

Table 2 lists the number of known and verified SORs identified by our suppliers as potentially having processed the necessary conflict minerals in each of Cree’s specific business units.

Table 2
Cree Business Unit
Number of SORs*
LED Lighting Products
303
LED Products
178
Power & RF Products
298
*It should be noted that the number of SORs in each Cree business unit is inflated from the actual number that would have provided necessary conflict minerals to Cree because most suppliers are reporting at a company level instead of a product level.

Table 3 below lists the SORs identified by our suppliers as potentially having processed the necessary conflict minerals in Cree’s products that are known and verified by the CFSI.

Table 3
Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Gold
Argor-Heraeus S.A.
CID000077
Switzerland
(1)
Gold
Asahi Pretec Corp.
CID000082
Japan
(1)
Gold
Dowa
CID000401
Japan
(1)
Gold
Heimerle + Meule GmbH
CID000694
Germany
(1)
Gold
Heraeus Ltd. Hong Kong
CID000707
China
(1)
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Germany
(1)
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Japan
(1)
Gold
Jiangxi Copper Co., Ltd.
CID000855
China
(1)
Gold
Johnson Matthey Inc.
CID000920
United States
(1)
Gold
Johnson Matthey Limited
CID000924
Canada
(1)
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Japan
(1)
Gold
LS-NIKKO Copper Inc.
CID001078
Korea, Republic Of
(1)
Gold
Materion
CID001113
United States
(1)
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Japan
(1)
Gold
Metalor Technologies S.A.
CID001153
Switzerland
(1)
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
China
(1)

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Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Gold
Metalor USA Refining Corporation
CID001157
United States
(1)
Gold
Mitsubishi Materials Corporation
CID001188
Japan
(1)
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Japan
(1)
Gold
Royal Canadian Mint
CID001534
Canada
(1)
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
China
(1)
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Japan
(1)
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Japan
(1)
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
China
(1)
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Australia
(1)
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Canada
(1)
Gold
Eco-System Recycling Co., Ltd.
CID000425
Japan
(1)
Gold
Kojima Chemicals Co., Ltd.
CID000981
Japan
(1)
Gold
Nihon Material Co., Ltd.
CID001259
Japan
(1)
Gold
Solar Applied Materials Technology Corp.
CID001761
Taiwan
(1)
Gold
Tokuriki Honten Co., Ltd.
CID001938
Japan
(1)
Gold
Advanced Chemical Company
CID000015
United States
(3)
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Japan
(1)
Gold
Al Etihad Gold Refinery DMCC
CID002560
United Arab Emirates
 
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Germany
(1)
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Uzbekistan
(3)
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
Brazil
(1)
Gold
Asaka Riken Co., Ltd.
CID000090
Japan
(1)
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Turkey
 
Gold
Aurubis AG
CID000113
Germany
(1)
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Philippines
(1)
Gold
Boliden AB
CID000157
Sweden
(1)
Gold
C. Hafner GmbH + Co. KG
CID000176
Germany
(1)
Gold
Caridad
CID000180
Mexico
 
Gold
Cendres + M?taux SA
CID000189
Switzerland
(3)
Gold
Chimet S.p.A.
CID000233
Italy
(1)
Gold
Chugai Mining
CID000264
Japan
 
Gold
Daejin Indus Co., Ltd.
CID000328
Korea, Republic Of
(3)
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
China
 
Gold
Do Sung Corporation
CID000359
Korea, Republic Of
(3)
Gold
Doduco
CID000362
Germany
(1)
Gold
Elemetal Refining, LLC
CID001322
United States
(1)
Gold
Emirates Gold DMCC
CID002561
United Arab Emirates
(1)
Gold
Faggi Enrico S.p.A.
CID002355
Italy
(3)
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Zimbabwe
 
Gold
FSE Novosibirsk Refinery
CID000493
Russian Federation
(1)
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CID000522
China
 

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Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Gold
Geib Refining Corporation
CID002459
United States
(3)
Gold
Guangdong Jinding Gold Limited
CID002312
China
 
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
China
 
Gold
Hwasung CJ Co., Ltd.
CID000778
Korea, Republic Of
 
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
China
 
Gold
Istanbul Gold Refinery
CID000814
Turkey
(1)
Gold
Japan Mint
CID000823
Japan
(1)
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Russian Federation
(1)
Gold
JSC Uralelectromed
CID000929
Russian Federation
(1)
Gold
Kaloti Precious Metals
CID002563
United Arab Emirates
 
Gold
Kazakhmys Smelting LLC
CID000956
Kazakhstan
 
Gold
Kazzinc
CID000957
Kazakhstan
(1)
Gold
Kennecott Utah Copper LLC
CID000969
United States
(1)
Gold
KGHM Polska MiedŸ Spó³ka Akcyjna
CID002511
Poland
(3)
Gold
Korea Metal Co., Ltd.
CID000988
Korea, Republic Of
 
Gold
Korea Zinc Co., Ltd.
CID002605
Korea, Republic Of
(3)
Gold
Kyrgyzaltyn JSC
CID001029
Kyrgyzstan
 
Gold
L'azurde Company For Jewelry
CID001032
Saudi Arabia
 
Gold
Lingbao Gold Co., Ltd.
CID001056
China
 
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
China
 
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Singapore
(1)
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
China
(3)
Gold
Met-Mex Penoles, S.A.
CID001161
Mexico
(1)
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
India
(1)
Gold
Morris and Watson
CID002282
New Zealand
 
Gold
Moscow Special Alloys Processing Plant
CID001204
Russian Federation
(1)
Gold
Nadir Metal Rafineri San. Ve Tic. A.ª.
CID001220
Turkey
(1)
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Uzbekistan
(3)
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Austria
(1)
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Japan
(1)
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326
Russian Federation
(1)
Gold
PAMP S.A.
CID001352
Switzerland
(1)
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
China
 
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Russian Federation
(1)
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Indonesia
(1)
Gold
PX Précinox S.A.
CID001498
Switzerland
(1)
Gold
Rand Refinery (Pty) Ltd.
CID001512
South Africa
(1)
Gold
Republic Metals Corporation
CID002510
United States
(1)
Gold
Sabin Metal Corp.
CID001546
United States
 
Gold
Samduck Precious Metals
CID001555
Korea, Republic Of
(3)

12

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Gold
SAMWON METALS Corp.
CID001562
Korea, Republic Of
 
Gold
SAXONIA Edelmetalle GmbH
CID002777
Germany
(3)
Gold
Schone Edelmetaal B.V.
CID001573
Netherlands
(1)
Gold
SEMPSA Joyería Platería S.A.
CID001585
Spain
(1)
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
China
 
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
China
(1)
Gold
Singway Technology Co., Ltd.
CID002516
Taiwan
(1)
Gold
So Accurate Group, Inc.
CID001754
United States
 
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Russian Federation
(1)
Gold
Sudan Gold Refinery
CID002567
Sudan
 
Gold
T.C.A S.p.A
CID002580
Italy
(1)
Gold
The Great Wall Gold and Silver Refinery of China
CID001909
China
 
Gold
TongLing Nonferrous Metals Group Holdings Co., Ltd.
CID001947
China
 
Gold
Torecom
CID001955
Korea, Republic Of
(3)
Gold
Umicore Brasil Ltda.
CID001977
Brazil
(1)
Gold
Umicore Precious Metals Thailand
CID002314
Thailand
(1)
Gold
United Precious Metal Refining, Inc.
CID001993
United States
(1)
Gold
Valcambi S.A.
CID002003
Switzerland
(1)
Gold
WIELAND Edelmetalle GmbH
CID002778
Germany
(3)
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
Japan
(1)
Gold
Yantai NUS Safina tech environmental Refinery Co. Ltd.
CID000651
China
 
Gold
Yokohama Metal Co., Ltd.
CID002129
Japan
(1)
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
China
 
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
China
(1)
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CID002243
China
(1)
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Belgium
(1)
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
China
 
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
China
 
Gold
Remondis Argentia B.V.
CID002582
Netherlands
 
Gold
AURA-II
CID002851
United States
 
Gold
Bangalore Refinery
CID002863
India
 
Tantalum
Global Advanced Metals Aizu
CID002558
Japan
(1)
Tantalum
Global Advanced Metals Boyertown
CID002557
United States
(1)
Tantalum
H.C. Starck Co., Ltd.
CID002544
Thailand
(1)
Tantalum
H.C. Starck GmbH Goslar
CID002545
Germany
(1)
Tantalum
H.C. Starck GmbH Laufenburg
CID002546
Germany
(1)
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Germany
(1)
Tantalum
H.C. Starck Inc.
CID002548
United States
(1)
Tantalum
H.C. Starck Ltd.
CID002549
Japan
(1)
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Germany
(1)
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
China
(1)

13

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
China
(1)
Tantalum
D Block Metals, LLC
CID002504
United States
(1)
Tantalum
Douluoshan Sapphire Rare Metal Co Ltd
CID000410
China
(1)
Tantalum
Exotech Inc.
CID000456
United States
(1)
Tantalum
F&X Electro-Materials Ltd.
CID000460
China
(1)
Tantalum
FIR Metals & Resource Ltd.
CID002505
China
(1)
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
China
(1)
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
China
(1)
Tantalum
Hi-Temp Specialty Metals, Inc.
CID000731
United States
(1)
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
China
(1)
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
China
(1)
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
China
(1)
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
China
(1)
Tantalum
KEMET Blue Metals
CID002539
Mexico
(1)
Tantalum
Kemet Blue Powder
CID002568
United States
(1)
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
China
(1)
Tantalum
LSM Brasil S.A.
CID001076
Brazil
(1)
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
India
(1)
Tantalum
Mineração Taboca S.A.
CID001175
Brazil
(1)
Tantalum
Mitsui Mining & Smelting
CID001192
Japan
(1)
Tantalum
Molycorp Silmet A.S.
CID001200
Estonia
(1)
Tantalum
Plansee SE Liezen
CID002540
Austria
(1)
Tantalum
Plansee SE Reutte
CID002556
Austria
(1)
Tantalum
QuantumClean
CID001508
United States
(1)
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
China
(1)
Tantalum
Solikamsk Metal Works
CID001769
Russian Federation
(1)
Tantalum
Taki Chemicals
CID001869
Japan
(1)
Tantalum
Telex Metals
CID001891
United States
(1)
Tantalum
Tranzact, Inc.
CID002571
United States
(1)
Tantalum
Ulba
CID001969
Kazakhstan
(1)
Tantalum
XinXing Haorong Electronic Material Co., Ltd.
CID002508
China
(1)
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
China
(1)
Tantalum
Zhuzhou Cemented Carbide
CID002232
China
(1)
Tantalum
Conghua Tantalum and Niobium Smeltry
CID000291
China
(1)
Tantalum
Resind Indústria e Comércio Ltda.
CID002707
Brazil
(1)
Tantalum
E.S.R. Electronics
CID002590
United States
(3)
Tin
Cooper Santa
CID000295
Brazil
(1)
Tin
CV United Smelting
CID000315
Indonesia
(1)
Tin
EM Vinto
CID000438
Bolivia
(1)
Tin
Fenix Metals
CID000468
Poland
(1)
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
China
(1)
Tin
China Tin Group Co., Ltd.
CID001070
China
(1)

14

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Malaysia
(1)
Tin
Metallo-Chimique N.V.
CID002773
Belgium
(1)
Tin
Mineração Taboca S.A.
CID001173
Brazil
(1)
Tin
Minsur
CID001182
Peru
(1)
Tin
Mitsubishi Materials Corporation
CID001191
Japan
(1)
Tin
OMSA
CID001337
Bolivia
(1)
Tin
PT Belitung Industri Sejahtera
CID001421
Indonesia
(1)
Tin
PT Bukit Timah
CID001428
Indonesia
(1)
Tin
PT Stanindo Inti Perkasa
CID001468
Indonesia
(1)
Tin
PT Tambang Timah
CID001477
Indonesia
(1)
Tin
Thaisarco
CID001898
Thailand
(1)
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
China
(3)
Tin
PT Mitra Stania Prima
CID001453
Indonesia
(1)
Tin
PT REFINED BANGKA TIN
CID001460
Indonesia
(1)
Tin
Alpha
CID000292
United States
(1)
Tin
An Thai Minerals Co., Ltd.
CID002825
Viet Nam
(3)
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Viet Nam
(3)
Tin
China Rare Metal Material Co., Ltd.
CID000244
China
(1)
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
China
 
Tin
CV Ayi Jaya
CID002570
Indonesia
(1)
Tin
CV Gita Pesona
CID000306
Indonesia
(1)
Tin
CV Nurjanah
CID000309
Indonesia
(1)
Tin
PT Prima Timah Utama
CID001458
Indonesia
(1)
Tin
CV Serumpun Sebalai
CID000313
Indonesia
(1)
Tin
CV Venus Inti Perkasa
CID002455
Indonesia
(1)
Tin
Dowa
CID000402
Japan
(1)
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Viet Nam
(3)
Tin
Elmet S.L.U.
CID002774
Spain
(1)
Tin
Estanho de Rondônia S.A.
CID000448
Brazil
 
Tin
Feinhütte Halsbrücke GmbH
CID000466
Germany
(3)
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
China
(3)
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
China
(3)
Tin
Gejiu Zi-Li
CID000555
China
 
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
China
 
Tin
Jiangxi Nanshan
CID001231
China
 
Tin
Linwu Xianggui Smelter Co
CID001063
China
 
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Brazil
(1)
Tin
Melt Metais e Ligas S.A.
CID002500
Brazil
(1)
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Viet Nam
(3)
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Thailand
(1)
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Philippines
(1)

15

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Tin
Phoenix Metal Ltd.
CID002507
Rwanda
(3)
Tin
PT Alam Lestari Kencana
CID001393
Indonesia
 
Tin
PT Artha Cipta Langgeng
CID001399
Indonesia
(1)
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Indonesia
(1)
Tin
PT Babel Inti Perkasa
CID001402
Indonesia
(1)
Tin
PT Bangka Kudai Tin
CID001409
Indonesia
 
Tin
PT Bangka Prima Tin
CID002776
Indonesia
(1)
Tin
PT Bangka Timah Utama Sejahtera
CID001416
Indonesia
 
Tin
PT Bangka Tin Industry
CID001419
Indonesia
(1)
Tin
PT BilliTin Makmur Lestari
CID001424
Indonesia
(1)
Tin
PT Cipta Persada Mulia
CID002696
Indonesia
(1)
Tin
PT DS Jaya Abadi
CID001434
Indonesia
(1)
Tin
PT Eunindo Usaha Mandiri
CID001438
Indonesia
(1)
Tin
PT Fang Di MulTindo
CID001442
Indonesia
 
Tin
PT Inti Stania Prima
CID002530
Indonesia
(1)
Tin
PT Justindo
CID000307
Indonesia
(1)
Tin
PT Karimun Mining
CID001448
Indonesia
(3)
Tin
PT Panca Mega Persada
CID001457
Indonesia
(1)
Tin
PT Pelat Timah Nusantara Tbk
CID001486
Indonesia
 
Tin
PT Sariwiguna Binasentosa
CID001463
Indonesia
(1)
Tin
PT Seirama Tin investment
CID001466
Indonesia
 
Tin
PT Sukses Inti Makmur
CID002816
Indonesia
(1)
Tin
PT Sumber Jaya Indah
CID001471
Indonesia
(1)
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Indonesia
(1)
Tin
PT Tinindo Inter Nusa
CID001490
Indonesia
(1)
Tin
PT Tirus Putra Mandiri
CID002478
Indonesia
 
Tin
PT Tommy Utama
CID001493
Indonesia
(1)
Tin
PT WAHANA PERKIT JAYA
CID002479
Indonesia
(1)
Tin
Rui Da Hung
CID001539
Taiwan
(1)
Tin
Soft Metais Ltda.
CID001758
Brazil
(1)
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Viet Nam
(3)
Tin
VQB Mineral and Trading Group JSC
CID002015
Viet Nam
(1)
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
Brazil
(1)
Tin
Yunnan Tin Company Limited
CID002180
China
(1)
Tin
Metallic Resources, Inc.
CID001142
United States
(1)
Tin
Resind Indústria e Comércio Ltda.
CID002706
Brazil
(1)
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
China
(3)
Tin
CV Dua Sekawan
CID002592
Indonesia
(3)
Tin
Gejiu Jinye Mineral Company
CID002859
China
(3)
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
China
(1)
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
China
(1)
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
China
(1)

16

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
China
(3)
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
China
(1)
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Viet Nam
(1)
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
China
(1)
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CID002518
China
(2)
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CID000345
China
(2)
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
China
(1)
Tungsten
Ganxian Shirui New Material Co., Ltd.
CID002531
China
 
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
China
(1)
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CID000868
China
(2)
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
China
(1)
Tungsten
Global Tungsten & Powders Corp.
CID000568
United States
(1)
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
China
(1)
Tungsten
H.C. Starck GmbH
CID002541
Germany
(1)
Tungsten
Hunan Chenzhou Mining Group Co., Ltd.
CID000766
China
(1)
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
China
(3)
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CID002578
China
(3)
Tungsten
Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd.
CID000769
China
(1)
Tungsten
Hydrometallurg, JSC
CID002649
Russian Federation
(1)
Tungsten
Japan New Metals Co., Ltd.
CID000825
Japan
(1)
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
China
(3)
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
China
(3)
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
China
(1)
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
China
 
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
China
(3)
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
China
(1)
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
China
(3)
Tungsten
Kennametal Fallon
CID000966
United States
(3)
Tungsten
Kennametal Huntsville
CID000105
United States
(1)
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
China
(1)
Tungsten
Niagara Refining LLC
CID002589
United States
(1)
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Viet Nam
(1)
Tungsten
Pobedit, JSC
CID002532
Russian Federation
(2)
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
CID002538
Viet Nam
(3)
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Viet Nam
(1)
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
Viet Nam
(1)
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Austria
(1)
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
China
(1)
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
China
(1)
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Japan
(1)

17

Metal*
Standard Smelter Names*
Smelter ID*
Location of Facility*
Smelter Status**
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Germany
(1)
Tungsten
Unecha Refractory metals plant
CID002724
Russian Federation
 

* Information as reported by the CFSI as of April 20, 2016.
** Smelter Status, where available, as reported by the CFSI as of April 20, 2016:
(1) SOR has received a “conflict-free” designation under the CFS program of the CFSI based on results from an independent third party audit.
(2) SOR has joined the Tungsten Industry-Conflict Minerals Council (TI-CMC) and agreed to complete a CFS program compliance audit conducted by an independent third party auditor within two (2) years of commencement of its TI-CMC membership.
(3) SOR is listed as “Active” in the CFS program, which means that it has agreed to complete a CFS program compliance audit conducted by an independent third party auditor. If the CFS program Audit Program Manager determines that an “Active” smelter or refiner has not made progress toward an audit, gap closure or re-audit for more than 90 days, that smelter or refiner will be removed from the Active list. A company that is unresponsive for 45 days also will be removed from the Active list.
Based upon the RCOI data made available from the CFSI, the countries of origin of the conflict minerals sourced and processed by the CFS-compliant smelters and refiners identified as potentially being in Cree’s product supply chains may include, but are not necessarily limited to, the following:
Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, DRC, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe.

We are not including any country of origin information relating to other smelters and refiners identified as potentially being in Cree’s product supply chains because we do not have reliable third party audit results for, and we have not completed our due diligence process with respect to, these facilities.

This CMR describes Cree’s efforts to determine the SOR and the country of origin of the necessary conflict minerals in our products manufactured in 2015 with the greatest possible specificity. In response to our RCOI inquiry, our suppliers identified a total of 305 known and verified SORs that may have processed the necessary conflict minerals contained in the materials provided to Cree. Based on the information obtained in our due diligence process, we have no reason to believe that any of these 305 SORs directly or indirectly finance or benefit armed groups in the Covered Countries. Since this does not reflect all of the SORs in our product supply chains, however, we are

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not in a position to conclude that all of the necessary conflict minerals in our products were obtained from conflict-free sources.

While we have not yet succeeded in obtaining a complete and accurate list of SORs for all of our products that include necessary conflict minerals, we believe that we have made good progress given the current state of the data available to us and the relative lack of sophistication of certain portions of our supply chain with respect to the requirements of the Rule.

Steps to Mitigate Risk
The previous parts of this CMR detail the steps taken in 2015 to mitigate risk. In the future, we plan to take or continue taking the following actions to improve the due diligence conducted on our supply chain to further mitigate any risk that the necessary 3TGs in our products could finance or benefit armed groups in the Covered Countries:

a. Leverage our direct suppliers that can most effectively and most directly mitigate the identified risks;
b. Engage with our suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses;
c. Continue to be an active CFSI member and, as a member, support SOR and recycler outreach programs by sending letters and/or emails to them explaining the importance of audit certification;
d. Work with upstream distributors in our supply chain to improve the quality of RCOI data for assemblies, components, and materials coming from those sources;
e. Support supplier outreach programs by sending letters and/or emails to them explaining the importance of conflict-free upstream sourcing; and
f. Monitor to determine if any additional changes in our procurement process are needed to improve visibility to necessary 3TGs in the assemblies, components, and materials purchased.
During the fourth year of Cree’s conflict minerals program, the Company will continue its focus on obtaining complete and reliable SOR and country of origin data by requiring suppliers to provide in a timely manner accurate smelter identification numbers and supplemental information that will allow Cree to determine the correlation between the identified SORs, countries of origin, and the assemblies, components, and materials supplied to Cree.



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