Exhibit 1.01
Conflict Minerals
Report
Macy's, Inc. has
included this Conflict Minerals Report as an exhibit to its Form SD for 2014 as
required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended,
and Form SD (collectively, the "Conflict Minerals Rule"). The date of
filing of this Conflict Minerals Report is May 29, 2015.
Unless the
context indicates otherwise, the terms "Company," "we,"
"its," "us" and "our" refer to Macy's, Inc. and
its consolidated subsidiaries. As used herein and in the Conflict Minerals
Rule, "Conflict Minerals" are columbite-tantalite (coltan),
cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten,
without regard to the location of origin of the minerals or derivative metals.
Forward-Looking
Statements
This document
contains forward-looking statements within the meaning of the federal
securities laws. Any statements that do not relate to historical or current
facts or matters are forward-looking statements. You can identify some of the
forward-looking statements by the use of forward-looking words, such as
intend" and the like, or the use of future tense. Statements concerning
current conditions may also be forward-looking if they imply a continuation of
current conditions. Examples of forward-looking statements include, but are not
limited to, statements concerning the additional steps that we intend to take
to mitigate the risk that our necessary Conflict Minerals benefit armed groups.
Forward-looking
statements are subject to risks and uncertainties that could cause actual
actions or performance to differ materially from those expressed in the
forward-looking statements. These risks and uncertainties include, but are not
limited to, (1) the continued implementation of satisfactory traceability and
other compliance measures by our direct and indirect suppliers on a timely
basis or at all, (2) whether smelters and refiners and other market
participants responsibly source Conflict Minerals and (3) political and
regulatory developments, whether in the Democratic Republic of the Congo
("DRC") region, the United States or elsewhere. You are cautioned not
to place undue reliance on these forward-looking statements, which speak only
as of the date of filing of this document. We do not intend, and undertake no
obligation, to publish revised forward-looking statements to reflect events or
circumstances after the date of filing of this document or to reflect the
occurrence of unanticipated events.
Overview;
Applicability of the Conflict Minerals Rule to Our Company
We
are an omnichannel retail organization operating stores, websites and mobile
applications. As of April 4, 2015, we operated 885 stores in 45 states, the
District of Columbia, Guam and Puerto Rico under the names of Macy's,
Bloomingdale's, Bloomingdales Outlet and Bluemercury, as well as the
macys.com, bloomingdales.com and bluemercury.com websites. We sell a wide range
of merchandise, including apparel and accessories (men's, women's and
children's), cosmetics, home furnishings and other consumer goods. We acquired
Bluemercury, Inc. in March, 2015 and, therefore, it is not required to be
covered by this filing.
In
2014, we purchased merchandise from approximately 3,600 suppliers. We do not
manufacture any products. Many of the products that we sell are third party
branded products that are available from many retailers, including our company,
and are therefore not in-scope for purposes of our compliance with the
Conflict Minerals Rule. In addition, we believe that most of our products do
not contain any Conflict Minerals and, for those that do, Conflict Minerals
content usually constitutes a small portion of the materials content of the
products.
A
portion of our products are private brand products, primarily consisting of
apparel, accessories and home products. We have determined that we are subject
to the Conflict Minerals Rule because of the degree of influence that we
exercise over the materials, parts, ingredients or components of some of our
private brand products that contain Conflict Minerals. With respect to 2014, we
sourced our private brand products from approximately 640 suppliers, or
approximately 18%, of our total supplier base. The responses that we received
from our private label suppliers in respect of 2014 indicated that only a small
portion of these suppliers supplied us with products that were in-scope for our
Conflict Minerals Rule compliance. See "Product Information" below
for additional information concerning our in-scope products.
We
do not directly source Conflict Minerals from mines, smelters or refiners, and
we believe that we are in most cases many levels removed from these market
participants. We therefore have limited influence over them. Furthermore,
because of the depth, geographic diversity and constant evolution of our supply
chain, and due to competitive factors, we often have significant difficultly
identifying market participants upstream from our direct suppliers. However,
through the efforts described in this Conflict Minerals Report, we seek to
ensure that our sourcing practices are consistent with our responsible sourcing
values.
Reasonable
Country of Origin Inquiry Information
As required by
the Conflict Minerals Rule, for 2014, we conducted a "reasonable country
of origin inquiry" ("RCOI"). We designed our RCOI in good faith
to determine the origin of Conflict Minerals that are necessary to the
functionality or production of products that we contract to manufacture.
Our outreach for
2014 included 640 suppliers that supplied our private-brand merchandise (we refer
to our suppliers of private-brand merchandise, both in respect of 2014 and
generally as "Suppliers"). The Suppliers identified 52 smelters and
refiners that may be in our supply chain. Based on our RCOI, we concluded that
31 of these smelters and refiners sourced entirely from outside of the DRC and
its adjoining countries, including from recycled or scrap sources. Our conclusions
concerning mineral origin are based on information provided by a third-party
information management service provider (the "Service Provider") that
we used to complement our internal management processes. Some of the RCOI and
due diligence activities described in this Conflict Minerals Report were taken
on our behalf by the Service Provider.
For 2014, we
were unable to determine the origin of at least a portion of the necessary
Conflict Minerals in each of our in-scope products. None of the necessary
Conflict Minerals contained in the in-scope products were determined by us to
directly or indirectly finance or benefit armed groups in the DRC or an
adjoining country. However, we did not conclude that any of our in-scope
products were "DRC conflict free." The terms "adjoining
country," "armed group" and "DRC conflict free" have
the meanings contained in the Conflict Minerals Rule.
Pursuant to the
Conflict Minerals Rule, based on the results of our RCOI, we were required to
conduct due diligence for 2014. These due diligence efforts are discussed
below.
For our RCOI, to
the extent applicable, we utilized the same processes and procedures as for our
due diligence.
Due Diligence Program Design
Design Framework
We designed our
due diligence measures relating to Conflict Minerals in general conformance
with the criteria set forth in the Organisation for Economic Co-operation and
Development's Due Diligence Guidance for Responsible Supply Chains of Minerals
from Conflict-Affected and High-Risk Areas, including the Supplement on Tin,
Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013) (the
"OECD Guidance").
Selected
Elements of Design Framework
The OECD
Guidance has established a five-step framework for due diligence as a basis for
responsible global supply chain management of minerals from conflict-affected
and high-risk areas. Selected elements of our program design are discussed
below. However, these are not all of the discrete procedures of the program
that we have put in place to help ensure that the Conflict Minerals contained
in our products are responsibly sourced. The headings below conform to the
headings used in the OECD Guidance for each of the five steps. Selected due
diligence measures that we took in respect of 2014 are discussed under
"Due Diligence Program Execution."
1. OECD
Guidance Step One: "Establish strong company management
systems"
a. We
have a task force that includes senior staff under the General Counsel charged
with managing our Conflict Minerals compliance strategy. The following
functional areas are represented on the task force: Financial Reporting;
Information Technology; Internal Audit; Legal; Overseas Offices; Quality
Assurance/Product Integrity; Risk Management; and Social Compliance. In
addition, we include merchants and product development teams from all of our
business divisions in the compliance process.
b. We
utilize specialist outside counsel and other consultants to advise us in
connection with our Conflict Minerals Rule compliance. In addition, we use the
Service Provider to assist with our RCOI and due diligence, including to, on
our behalf, (i) engage in supplier outreach and follow-up, (ii) validate
supplier responses, (iii) identify risks based on smelter and refiner sourcing
practices of suppliers and (iv) store records of due diligence processes,
findings and resulting decisions on a computerized database.
c. We
use the Conflict Minerals Reporting Template (the "CMRT") developed
by the Conflict-Free Sourcing Initiative (the CFSI) to determine the
Suppliers that include Conflict Minerals in our private-label products and to
identify smelters and refiners in our supply chain.
d. We
encourage participation in the multi-stakeholder initiatives relating to
Conflict Minerals traceability and compliance of the following organizations,
all of which we are members of: the American Apparel and Footwear Association;
the National Retail Federation; and the United States Fashion Industry
Association.
e.
We
maintain business records relating to Conflict Minerals due diligence,
including records of due diligence processes, findings and resulting decisions,
for at least five years. We also have instructed the Service Provider to
maintain our records in its possession for at least five years.
f. We
have both a corporate and a vendor Conflict Minerals Policy. Our policies
provide that we expect our Suppliers to seek minerals from sources that do not
directly or indirectly contribute to the conflict in the DRC and its adjoining
countries and require Suppliers to cooperate with us in the implementation and
execution of our processes to comply with the Conflict Mineral Rule. We
communicate the corporate Conflict Minerals Policy internally to impacted
personnel by e-mail and post it on our corporate Internet website at http://macysinc.com/social-responsibility/conflict-minerals-policy.
Our vendor Conflict Minerals Policy includes additional detail about the
actions we expect our Suppliers to take with respect to Conflict Minerals Rule
compliance. We provide the vendor Conflict Minerals Policy to Suppliers.
g. We
have a mechanism at www.macysinc.com/contact-us that enables internal
and external stakeholders to provide comments or
questions, or register grievances, to us on various subjects, including with
respect to the sourcing of Conflict Minerals contained in our products.
h. We
furnish new Suppliers with written communications discussing the Conflict Minerals
Rule, the OECD Guidance and our compliance requirements. We also communicate
to them our commitment to comply with the Conflict Minerals Rule and request
that they sign an acknowledgment that they have reviewed our vendor Conflict
Minerals Policy, understands its requirements and will comply with it. In
addition, new Suppliers that are not covered by our nominated trim supplier
program are requested to provide us with a copy of their Conflict Minerals
policy. Company personnel review the policies and encourage new Suppliers with
Conflict Minerals policies that do not include due diligence frameworks and
management systems that are consistent with our responsible sourcing values to
review the training and educational materials available to them and revise
their policies and processes to better facilitate compliance.
i. We
furnish Suppliers with free access to the Conflict Minerals Resource Center
site sponsored by seven industry associations and two service providers that
provides, among other things, information and web-based training for suppliers
with respect to the Conflict Minerals Rule and compliance requirements.
j. Suppliers
are required to source metal trim components from a CFSI-compliant nominated
trim supplier list. The trim program covers all zippers, all childrens press
fasteners, and all other metal trim components for apparel, accessories,
footwear, home textiles, and plush toys.
k. Our
private brand purchase order terms and conditions and certain testing and
vendor standards manuals include a provision requiring Suppliers to
acknowledge, accept and agree that all products supplied to us will be free of
any Conflict Minerals sourced from mines, smelters or
refiners
that finance
or benefit armed groups in the DRC or an adjoining country.
2. OECD
Guidance Step Two: "Identify and assess risk in the supply
chain"
a. Each
year, the Service Provider requests that the Suppliers complete a CMRT.
Following the initial introduction to the Conflict Minerals compliance program
and the CMRT information request, the Service Provider sends reminder emails to
each non-responsive Supplier requesting completion of the CMRT. The Service
Provider contacts by phone the Suppliers who remain non-responsive to the email
reminders. When needed, the Service Provider obtains assistance from our
personnel in reaching out to non-responsive Suppliers.
b. The
Service Provider, in conjunction with our personnel, reviews the completed
responses received from Suppliers. The Service Provider reviews the responses
for plausibility, consistency and gaps as described in its procedures. It
follows up by email or phone with Suppliers that submit a response that
triggers specified quality control flags. Under the Service Provider's
procedures, responses that do not identify a smelter or refiner, responses that
indicate a sourcing location without supporting information, and organizations
that are identified as smelters or refiners but were not identified as such by
the CFSI trigger follow-up with either the Supplier or the smelter or refiner.
c. If
a Supplier is unable to provide information concerning the processors of
Conflict Minerals in its supply chain, the Service Provider requests
information on the Supplier's suppliers of products or components that may have
required Conflict Minerals for their functionality or production (the
"Tier 2 suppliers"). The Tier 2 suppliers, and subsequent tiers of
suppliers as identified to the Service Provider, are then contacted by the
Service Provider and asked to complete a CMRT. The Service Provider sends
reminder emails to each non-responsive Tier 2 and subsequent tiers of suppliers
requesting completion of the CMRT. The Service Provider contacts by phone
those suppliers who remain non-responsive to the email reminders.
d. If
a Supplier indicates that there is no Conflict Minerals content in the products
that it supplied to us, a senior executive of the Supplier is requested to
certify to that determination.
e. To
the extent that a completed response identifies a smelter or refiner, the
Service Provider reviews this information against the list of compliant or the
equivalent smelters and refiners published in connection with the CFSI's
Conflict-Free Smelter Program ("CFSP"), the London Bullion Market
Association's ("LBMA") Good Delivery List and the Responsible
Jewellery Council's ("RJC") Chain-of-Custody Certification.
f. If
a smelter or refiner identified by a Supplier is not certified as compliant or
the equivalent by an independent third-party, the Service Provider attempts to
contact that smelter or refiner by email or phone to gain information about its
sourcing practices and to determine whether that smelter or refiner obtained the
Conflict Minerals it processed from sources that directly or indirectly
financed or benefitted armed groups in the DRC or an adjoining country.
Internet research also is performed by it to determine whether there are any
outside sources of information regarding the smelters or refiners sourcing
practices.
3. OECD
Guidance Step Three: "Design and implement a strategy to respond to
identified risks"
a. Our
Conflict Minerals task force reports the findings of its supply chain risk
assessment to our General Counsel.
b. Under
our risk mitigation strategy, we take such risk mitigation efforts as we deem
to be appropriate based on the findings of our supply chain risk assessment.
Our risk mitigation efforts are determined by the particular facts and
circumstances and risks identified.
4. OECD
Guidance Step Four: "Carry out independent third-party audit of
supply chain due diligence at identified points in the supply chain"
In connection
with our due diligence, we utilize information made available by the CFSP,
LBMA and RJC concerning independent third-party audits of smelters and
refiners.
5. OECD
Guidance Step 5: "Report on supply chain due
diligence"
a. We
file a Form SD and Conflict Minerals Report with the Securities and Exchange
Commission and make these filings available on our website.
b. We
include information regarding our Conflict Minerals sourcing in our Report on
Social Responsibility, which we make publicly available on our website.
Due Diligence Program Execution
In furtherance of our Conflict Minerals
due diligence in respect of 2014, we performed the following due diligence
measures. These were not all of the measures that we took in furtherance of our
Conflict Minerals compliance program or pursuant to the Conflict Minerals Rule
and the OECD Guidance.
1. The
Service Provider sent requests to 640 Suppliers to complete a CMRT. The
Service Provider sent reminder emails to each non-responsive Supplier
requesting completion of the CMRT and attempted to contact by phone the
Suppliers who remained non-responsive to the email reminders. If a Supplier
was still non-responsive, the Service Provider obtained assistance from our personnel
in reaching out to the Supplier. We received a response from over 90% of the
Suppliers surveyed.
2. The
Service Provider, in conjunction with our personnel, reviewed the completed
responses received from Suppliers. The Service Provider reviewed the responses
received from Suppliers for plausibility, consistency and gaps as described in
its procedures. It followed up by email or phone with Suppliers that submitted
a response that triggered specified quality control flags.
3. With
respect to those completed CMRTs that identified a smelter or refiner, the
Service Provider reviewed the information provided against the list of
compliant or equivalent smelters and refiners published in connection with the
CFSP, the LBMA's Good Delivery List and the RJC's Chain-of-Custody
Certification. 39 of the smelters and refiners identified by the Suppliers
were listed as compliant and 4 were listed as active by the CFSI as of April 15,
2015.
4. For
those smelters and refiners identified by a Supplier that were not listed as
compliant or the equivalent by an independent third-party, the Service Provider
attempted to contact the smelter or refiner to gain information about its
sourcing practices and to determine the source and chain of custody of the
Conflict Minerals it processed. Internet research also was performed by it to
determine whether there were any outside sources of information regarding the
smelter's or refiner's sourcing practices.
5. With
respect to those Suppliers that were unable to provide information concerning
the processors of Conflict Minerals in their supply chain, the Service Provider
requested information on the Supplier's Tier 2 suppliers. The Tier 2
suppliers, and subsequent tiers of suppliers as identified to the Service
Provider, were then contacted by the Service Provider and asked to complete the CMRT. The Service Provider sent reminder emails to each non-responsive Tier 2
and subsequent tiers of suppliers requesting completion of the CMRT. The
Service Provider attempted to contact by phone those suppliers who remained
non-responsive to the email reminders.
6. For
those Suppliers that indicated that there was no Conflict Minerals content in
the products that they supplied to us, a senior executive of the Supplier was
requested to certify to that determination.
7. Our
Conflict Minerals task force reported the findings of its supply chain risk
assessment to our General Counsel.
8. In
addition, to mitigate the risk that the necessary Conflict Minerals contained
in our in-scope products directly or indirectly finance or benefit armed groups
in the DRC or an adjoining country, we took the actions below in respect of the
2014 compliance period:
a. We
adopted both a corporate and vendor Conflict Minerals Policy. We communicated
the applicable policy to impacted company personnel and to the Suppliers
and implemented
procedures to ensure that new suppliers receive and review the vendor Conflict
Minerals Policy. We posted the corporate Conflict Minerals Policy on our
corporate Internet website.
b. We
educated senior management at both Macys and Bloomingdales, our merchants,
our international general managers, our product development personnel and
selected other internal personnel on the Conflict Minerals Rule and our
compliance plan. We did so in writing, by telephone and through in-person
meetings.
c. We
furnished the Suppliers with written communications discussing the Conflict
Minerals Rule, the OECD Guidance and our compliance requirements. In addition,
we made available to the Suppliers free access to the multi-industry Conflict
Minerals Resource Center site described earlier in this Conflict Minerals
Report.
d. We
developed a program pursuant to which Suppliers are required to source metal
trim components from a conflict free nominated trim supplier list. We
sponsored a trim suppliers fair to introduce this nominated trim supplier
program to our merchants and explain its requirements with respect to sourcing.
e. We
revised our private brand purchase order terms and conditions and certain
testing and vendor standards manuals in order to help further drive compliance
by Suppliers with our vendor Conflict Minerals Policy, including a provision
requiring Suppliers to acknowledge, accept and agree that all products supplied
to us will be free of any Conflict Minerals sourced from mines,
smelters or refiners
that finance
or benefit armed groups in the DRC or an adjoining country.
f. The
Service Provider requested from each Supplier that is not covered by our
nominated trim supplier program a copy of that Suppliers Conflict Minerals
policy. Seventy-three percent of the Suppliers complied with our request. Company
personnel reviewed the Supplier policies and encouraged Suppliers with Conflict
Minerals policies that did not include due diligence frameworks and management
systems to review the training and educational materials available to them and
revise their policies and processes to better facilitate traceability of their
supply chains and conflict free sourcing.
g. The
Service Provider requested an acknowledgment from each Supplier that it had
reviewed our vendor Conflict Minerals Policy, understood its requirements and
would comply with them. We received affirmative acknowledgment of our Conflict
Minerals Policy from 86% of the Suppliers.
h. We
provided feedback to the Service Provider on measures it could take to enhance
its RCOI procedures, quality control processes and processes related to
identifying and validating smelters and refiners.
i. We
published a Report on Social Responsibility, which we made publicly available
on our website, that discussed our position on Conflict Minerals sourcing.
Product
Information
Our
in-scope products included:
1.
apparel, that includes functional metal hardware such as
zippers and other functional trim;
2.
accessories, primarily consisting of handbags, shoes, belts
and jewelry; and
3.
home goods, primarily consisting of cookware and kitchen
gadgets.
However,
not all of our products in each of these categories contained Conflict Minerals
or were otherwise in-scope for purposes of our compliance with the Conflict
Minerals Rule.
For
a broader discussion of our products, see our Annual Report on Form 10-K for
the fiscal year ended January 31, 2015. The information contained in our Form
10-K is not incorporated by reference into this Conflict Minerals Report or our
Form SD and should not be considered part of this Conflict Minerals Report or
our Form SD.
Identified
Smelters and Refiners; Country of Origin
The
Suppliers identified to us 52 smelters and refiners that may have been used to
supply the Conflict Minerals contained in our in-scope products.
Forty-three of the identified smelters and refiners were listed
as compliant by the CFSI or are in the process of acquiring such certification
(i.e., active).
According to information provided by the Service Provider, 11
of the identified smelters and refiners may have sourced in part from mines
located in the DRC and/or an adjoining country. Ten of these 11 smelters and refiners
were listed as compliant by the CFSI and one was listed as active.
The
foregoing facilities are listed on Annex 1. Annex 1 also lists
possible countries of origin of the Conflict Minerals processed by certain of
the smelters and refiners. Due to our position in the supply chain, which we
discuss earlier in this Conflict Minerals Report, we rely on our suppliers for
accurate smelter and refiner information. Our due diligence measures cannot
provide absolute certainty regarding the source and chain of custody of the
necessary Conflict Minerals contained in our 2014 in-scope products.
The
Suppliers reported smelter and refiner information at a company level (i.e.,
for all of their products, not just those that they sold to us). Therefore, we
were unable to conclusively determine whether any of the identified smelters or
refiners were actually in our supply chain. In addition, the smelters and
refiners identified by the Suppliers may not include all of the smelters and
refiners in our supply chain, since some Suppliers did not identify all or part
of their smelters and refiners and because not all Suppliers responded to our
inquiries. See the notes to the table in Annex 1 for additional
information concerning the data presented in the table.
For
2014, we do not have any information indicating that any of the necessary Conflict
Minerals in our in-scope products were used to support conflict in the DRC or
an adjoining country (i.e., the Conflict Minerals directly or indirectly
financed or benefitted an armed group in the DRC or an adjoining country). However,
we did not conclude that any of our products were "DRC conflict
free."
We endeavored to
determine the mine or location of origin of the necessary Conflict Minerals
contained in our in-scope products by requesting that the Suppliers provide us
with a completed CMRT. For the smelters and refiners that were identified by
the Suppliers, to the extent that the origin of their Conflict Minerals was not
known to the Service Provider, it attempted to contact the smelter or refiner
and/or consulted publicly available information to attempt to determine the
mine or location of origin of the Conflict Minerals processed by the smelter or
refiner.
Future
Risk Mitigation Efforts
We
intend to take the following additional steps to improve our due diligence
measures and mitigate the risk that the necessary Conflict Minerals in our
in-scope products benefit armed groups:
1. Continue
to enhance our nominated trim supplier program, including through training of
new merchants and Suppliers, and implement an escalation process for trim
Suppliers not in compliance with the program.
2. Continue
to require Suppliers not covered by our nominated trim supplier program to
upload copies of their Conflict Minerals policies and continue our review of
the adequacy of such policies.
3. Based
on the results of our inquiries and due diligence in respect of 2014, adopt and
implement a risk management plan that, among other things, addresses Supplier
non-responsiveness and non-compliance.
4. Utilize
Revision 4.0 of the CMRT for our 2015 Supplier outreach.
5. With
the assistance of the Service Provider, conduct independent research on
smelters and refiners that were reported to us that are not operational or may
have been misidentified, and work directly with Suppliers to re-validate,
improve and refine their reported information.
6. Continue
to engage with Suppliers that provided incomplete responses or that did not
provide responses for 2014 to help ensure that they provide requested
information for 2015.
7. Monitor
and encourage the continuing development and progress of traceability measures
at Suppliers that indicated for 2014 that the source of Conflict Minerals was
unknown or undeterminable.
8. Continue
to participate in selected industry initiatives to identify smelters and
refiners in the supply chain.
9. Request
that our Tier 1 Suppliers continue to encourage uncertified smelters and
refiners identified in our due diligence process to participate in a program
such as the CFSP to obtain a compliant designation.
All of the
foregoing steps are in addition to the steps that we took in respect of 2014,
which we intend to continue to take in respect of 2015 to the extent
applicable.
ANNEX 1
Capitalized terms used and not otherwise defined in this
Annex have the meanings set forth in the Conflict Minerals Report of which this
Annex is a part.
Smelters and Refiners
The following facilities may have been used to process the
necessary Conflict Minerals in our in-scope products. Please see the notes
that accompany the table for information concerning the data in the table.
Conflict
Mineral
|
Smelter/Refiner
|
Compliance Status
|
Gold
|
Asahi
Pretec Corporation
|
Compliant
|
Gold
|
Aurubis
AG
|
Compliant
|
Gold
|
Chimet
S.p.A
|
Compliant
|
Gold
|
China
National Gold Group Corporation
|
Known
|
Gold
|
Faggi
S.p.A.
|
Known
|
Gold
|
Guangdong
Jinding Gold Limited
|
Known
|
Gold
|
Heraeus
Ltd. Hong Kong
|
Compliant
|
Gold
|
Heraeus
Precious Metals GmbH & Co. KG
|
Compliant
|
Gold
|
Inner
Mongolia Qiankun Gold and Silver Refinery Share Company Limited
|
Known
|
Gold
|
Istanbul
Gold Refinery
|
Compliant
|
Gold
|
Japan
Mint
|
Compliant
|
Gold
|
Jiangxi
Copper Company Limited
|
Known
|
Gold
|
LS-NIKKO
Copper Inc.
|
Compliant
|
Gold
|
Metalor
Technologies (Hong Kong) Ltd
|
Compliant
|
Gold
|
Metalor
Technologies SA
|
Compliant
|
Gold
|
Metalor
USA Refining Corporation
|
Compliant
|
Gold
|
Mitsubishi
Materials Corporation
|
Compliant
|
Gold
|
Mitsui
Mining and Smelting Co., Ltd
|
Compliant
|
Gold
|
Moscow
Special Alloys Processing Plant
|
Known
|
Gold
|
Nadir
Metal Rafineri San. Ve Tic A.Ş.
|
Compliant
|
Gold
|
Nihon
Material Co., LTD
|
Compliant
|
Gold
|
Ohio
Precious Metals, LLC
|
Compliant
|
Gold
|
Royal
Canadian Mint
|
Compliant
|
Gold
|
Shandong
Zhaojin Gold & Silver Refinery Co. Ltd
|
Compliant
|
Gold
|
So
Accurate Group, Inc.
|
Known
|
Gold
|
Tanaka
Kikinzoku Kogyo K.K.
|
Compliant
|
Gold
|
The
Refinery of Shandong Gold Mining Co. Ltd
|
Compliant
|
Gold
|
Umicore
Brasil Ltda
|
Compliant
|
Gold
|
Valcambi
SA
|
Compliant
|
Gold
|
Zhongyuan
Gold Smelter of Zhongjin Gold Corporation
|
Compliant
|
Tantalum
|
Conghua
Tantalum and Niobium Smeltry
|
Compliant
|
Tin
|
Alpha
|
Compliant
|
Tin
|
China
Rare Metal Materials Company
|
Compliant
|
Tin
|
China
Tin Group Co., Ltd
|
Active
|
Tin
|
CNMC
(Guangxi) PGMA Co. Ltd
|
Known
|
Tin
|
Cooper
Santa
|
Active
|
Tin
|
CV
United Smelting
|
Compliant
|
Tin
|
Empresa
Metallurgica Vinto
|
Compliant
|
Tin
|
Gejiu
Non-Ferrous Metal Processing Co. Ltd.
|
Compliant
|
Tin
|
Malaysia
Smelting Corporation (MSC)
|
Compliant
|
Tin
|
Melt
Matais e Ligas S/A
|
Compliant
|
Tin
|
Metallo
Chimique
|
Compliant
|
Tin
|
Mineração
Taboca S.A.
|
Compliant
|
Tin
|
Minsur
|
Compliant
|
Tin
|
Operaciones
Metalurgical S.A.
|
Compliant
|
Tin
|
PT
Koba Tin
|
Known
|
Tin
|
PT
Tambang Timah
|
Compliant
|
Tin
|
PT
Timah (Persero), Tbk
|
Compliant
|
Tin
|
Thaisarco
|
Compliant
|
Tin
|
Yunnan
Chengfeng Non-ferrous Metals Co., Ltd.
|
Active
|
Tin
|
Yunnan
Tin Company Limited
|
Compliant
|
Tungsten
|
Kennametal
Huntsville
|
Active
|
We
note the following in connection with the information contained in the
foregoing table:
a. The
table only includes entities that were listed as smelters or refiners by the CFSI, the U.S. Department of Commerce, the LBMA or the RJC.
b. Smelter
and refiner status information in the table is as of April 15, 2015 and is
based solely on information made publicly available by the CFSI, LBMA or the
RJC, without independent verification by us.
c. "Compliant"
means that a smelter or refiner is listed as compliant with the CFSP's
assessment protocols, including through mutual recognition, or is listed as
"Re-audit in process" by the CFSI. Included smelters and refiners
were not necessarily Compliant for all or part of 2014 and may not continue to
be Compliant for any future period. We do not have information on the origin of
the Conflict Minerals processed by any of the Compliant smelters and refiners
prior to their respective compliance dates.
d.
"Active"
is a CFSI designation that means that the smelter or refiner is listed as
having submitted a signed Agreement for the Exchange of Confidential
Information and Auditee Agreement contracts to the CFSP or, according to
information published by the CFSI, the smelter has agreed to complete a CFSP
validation audit within two years of membership issuance by the Tungsten Industry
Conflict Minerals Council.
e. "Known"
means that a smelter or refiner is listed on the CFSI Standard Smelter Names
tab or the Commerce Department list, but is not listed as "Compliant"
or "Active."
Country
of Origin
The identified countries of origin of the Conflict Minerals
processed by the smelters and refiners listed in the table above may have
included the countries listed below. The listed countries of origin are
derived from information provided by Suppliers on their CMRT or through the
outreach, review of information and additional research conducted by the
Service Provider.
Argentina
|
Guyana
|
Myanmar
|
South Africa
|
Australia
|
India
|
Niger
|
South Korea
|
Bolivia
|
Indonesia
|
Nigeria
|
Spain
|
Brazil
|
Italy
|
Papua New Guinea
|
Suriname
|
Canada
|
Japan
|
Peru
|
Sweden
|
Chile
|
Kazakhstan
|
Philippines
|
Thailand
|
China
|
Laos
|
Portugal
|
Turkey
|
DRC-Congo (Kinshasa)
|
Malaysia
|
Russia
|
United Kingdom
|
Ethiopia
|
Mexico
|
Rwanda
|
United States
|
France
|
Mongolia
|
Saudi Arabia
|
Uzbekistan
|
Guinea
|
Mozambique
|
|
|
In addition, some of the listed smelters and refiners may
have processed Conflict Minerals originating in whole or in part from recycled
or scrap sources.