UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
SPECIALIZED DISCLOSURE REPORT
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EMC CORPORATION
(Exact name of registrant as specified in its charter)
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Massachusetts | 1-9853 | 04-2680009 |
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) |
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176 South Street Hopkinton, Massachusetts (Address of principal executive offices) | | 01748 (Zip code) |
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Paul T. Dacier Executive Vice President and General Counsel (508) 435-1000 |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
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Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
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Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
A copy of EMC Corporation’s Conflict Minerals Report filed for the calendar year ended December 31, 2014 is publicly available at http://www.emc.com/collateral/sustainability/conflict-minerals-report-2014.pdf
The Conflict Minerals Report includes a description of the Corporation’s Reasonable Country of Origin Inquiry and its conclusions on the origin of conflict minerals, including any facilities that process only recycled or scrap material.
EMC Corporation’s Conflict Minerals Report for the calendar year ended December 31, 2014 is filed as Exhibit 1.01 hereto.
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Exhibit 1.01 | Conflict Minerals Report of EMC Corporation as required by Items 1.01 and 1.02 of this Form. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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EMC CORPORATION |
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By: | /s/ Zane C. Rowe |
| Zane C. Rowe |
| Executive Vice President and Chief Financial Officer |
Date: June 1, 2015
Exhibit 1.01
EMC CORPORATION
Conflict Minerals Report
For the year ended December 31, 2014
Introduction
As part of our global approach to the protection of human rights, EMC is committed to the ethical sourcing of minerals, and in particular of tantalum, tin, tungsten and gold (“3TG”). There is concern that 3TG, often referred to as “conflict minerals,” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.
As stated in our Conflict Minerals Policy, it is our goal not to purchase product materials containing 3TG whose sale finance armed conflict in the DRC. However, we believe being “DRC Conflict-Free” should not mean “DRC-Free”. We intend to source responsibly from the DRC and adjoining countries (collectively, the “Covered Countries”) in order to support peaceful economic activity in the region.
Summary
In 2014, EMC manufactured and contracted to manufacture products in which “conflict minerals” (defined in the U.S. Securities and Exchange Commission Release No. 34-67716 as cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to 3TG) are necessary to the functionality or production of such products. As we do not yet know the source of all the 3TG in these products, we do not have sufficient information to conclude that any of these products are “DRC Conflict-Free.” However, in 2014 we did see an increase in the percentage of smelters and refiners in our supply chain that are compliant with the Conflict-Free Smelter Program (CFSP), as described below. This report describes our approach and our efforts toward responsible sourcing of 3TG.
Our Approach
Researching the origin of minerals through the supply chain is a complex endeavor. As a manufacturer of enterprise storage systems, we consume components and materials containing 3TG and do not purchase 3TG directly from mines, smelters or refiners. Therefore, to meet our goal of being DRC Conflict-Free, we must collaborate with suppliers, industry peers, and other stakeholders. To this end, we seek to advance tools and programs that simplify due diligence processes through the supply chain and increase the supply of verifiably DRC Conflict-Free minerals.
EMC is a member of the Conflict-Free Sourcing Initiative (the “CFSI”), a multi-industry initiative addressing conflict minerals issues in the supply chain. The CFSI’s Conflict Minerals Reporting Template (the “CMRT”) is a widely-used standard form to collect information through the supply chain, including the names of 3TG smelters and refiners. The CFSI’s Conflict-Free Smelter Program (the “CFSP”) uses independent third-party audits to assess whether 3TG smelters and refiners have systems in place to assure sourcing of only conflict-free materials. We use the CMRT to survey our suppliers and identify smelters and refiners in our supply chain, and the CFSP to determine the country of origin and conflict-free status of minerals.
EMC is an active participant in CFSI workgroups and projects. This collaboration helps us advance toward our goal, and it also helps to build a global supply chain system for responsible and ethical mineral sourcing that makes it more widely possible for companies to source DRC Conflict-Free minerals for their products.
Our Strategy
To reach our goal of being DRC Conflict-Free, we set a three-pronged strategy focusing first on supplier-level engagement, where we have the most direct influence, then on the smelter and refiner level, and third on encouraging responsible sourcing from the Covered Countries.
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1. | Engage suppliers in due diligence and DRC Conflict-Free sourcing |
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• | Survey suppliers using the CMRT |
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• | Offer resources and education on the issue of conflict minerals and best practices in due diligence |
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• | Influence the supply chain to shift to CFSP-compliant smelters and refiners |
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2. | Increase the number of Conflict-Free Smelters and Refiners |
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• | Identify smelters and refiners in our supply chain |
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• | Help advance the CFSP through active participation in CFSI workgroups |
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• | Encourage smelters and refiners in our supply chain to undergo an audit to be CFSP-compliant |
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3. | Encourage responsible sourcing from the Covered Countries: |
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• | Promote verifiable conflict-free sourcing from the Covered Countries in order to support peaceful economic activity |
Our Products
This report relates to products EMC manufactured or contracted to be manufactured in 2014 that contain 3TG that may be considered necessary to the functionality or production of such products. EMC offers a comprehensive portfolio of storage systems including EMC VMAX, EMC VNX, EMC Isilon, EMC XtremIO, EMC Atmos, EMC ECS, EMC VPEX, and PCIe-based flash cards. Our data protection and availability systems span the backup, archive and availability categories, including EMC Avamar, EMC Data Domain, EMC Recoverpoint, EMC VPLEX, and EMC Disk Library for mainframe products. Federation subsidiary VCE also offers a portfolio of hardware-based converged storage, compute and networking systems known as Vblock. RSA, the Security Division of EMC, manufactures RSA SecureID tokens and offers a number of other security products provided either as Virtual Machines or via an EMC common server-based appliance. These hardware products were in scope for our conflict minerals due diligence efforts in 2014.
Our Conflict Minerals Policy and Program
EMC’s Conflict Minerals Policy states our goal to be DRC Conflict-Free, our expectations of our suppliers, and our approach of broad collaboration with suppliers, industry peers, and other stakeholders. EMC’s program is overseen by a Conflict Minerals Governance Committee that provides strategic direction and input to EMC’s conflict minerals policy, supplier requirements, communications, and risk management. This committee includes executives from Global Supply Chain Management, Global Supply Chain Engineering, and the Office of Sustainability, as well as representatives from Finance, Legal, Global Product Operations Sustainability, Government Affairs and Internal Audit. This committee reports to the Audit Committee of the Board of Directors.
Supplier requirements for conflict minerals due diligence are embedded in EMC’s supply chain management. Our Supplier Code of Conduct requires direct materials suppliers to have a conflict minerals policy and conduct due diligence on the source and chain of custody of the 3TG in their products. These same requirements are included in our standard contracts and purchase agreements.
Our Supply Chain
Reasonable Country of Origin Inquiry
The first step in our compliance process was to identify where 3TG are used in our products and by which suppliers. We searched our Full Material Disclosure database, which catalogues the substances used in EMC products, to generate a list of suppliers from whom we would need information. We included Tier 1 suppliers who sell directly to EMC, and other suppliers from whom we instruct Tier 1 suppliers to purchase parts for the components they sell to us (“Tier 2+”). We asked these suppliers to survey their own supply chain, report to us using the CMRT, and publish a conflict minerals policy. Suppliers representing 99% of our Tier 1 and 93% of our Tier 2+ 2014 spend submitted CMRTs.
EMC compared the list of smelters and refiners reported by suppliers against the CFSI’s list of verified 3TG smelters and refiners. As of April 30, 2015, of the 256 verified 3TG smelter and refiner facilities in our supply chain, 155 are compliant with CFSP and have been found to be DRC Conflict-Free. The list of these verified smelters and refiners that our suppliers reported as being in their supply chains is set forth in Appendix A. The list of countries from which we believe the 3TG in our products may have originated is set forth in Appendix B. Some 3TG also originated from recycled or scrap sources. This information was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report dated April 30, 2015 that is available to EMC as a
member of CFSI. This report provides information on smelters and refiners that are compliant with CFSP, including smelter facility name, location, and countries from which minerals were sourced.
We then mapped our suppliers against our covered products and reviewed the smelter lists for those suppliers. We found that for each covered product category:
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• | Some 3TG is sourced through verified smelters or refiners that are not yet CFSP-compliant and therefore we have not yet determined the country of origin of those minerals; and |
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• | Some 3TG is sourced from CFSP-compliant smelters or refiners, including smelters or refiners that source responsibly from the Covered Countries. |
This supplier survey and smelter review process constituted our Reasonable Country of Origin Inquiry (RCOI). This RCOI combined with our risk assessment and mitigation efforts described below represent EMC’s best efforts to trace the source of the 3TG in our supply chain to the mine or location of origin as necessary.
Supply Chain Risk Assessment
In keeping with our strategy, we focus our risk assessment and mitigation where we expect to have the most impact: evaluating supplier responses to our conflict minerals survey and the CFSP-compliant status of the smelters and refiners in our supply chain. As a downstream company, EMC utilizes the CFSP for smelter and refiner audits and assessment of risks in the mineral supply chain from the mine to the smelter or refiner.
Assessing supplier responses
We depend on supplier reporting to conduct our due diligence. Therefore, complete and correct supplier reporting, as well as supplier cooperation with our commitment to DRC conflict-free sourcing, reduces the risk that EMC will purchase products and/or materials containing minerals whose sale financed armed conflict in the DRC.
Each supplier’s CMRT was reviewed against an internally-developed framework for reasonableness and risk. We sought to understand our suppliers’ progress on due diligence, confirm whether they had published a conflict minerals policy, and obtain a list of 3TG smelters and refiners in their supply chain. In analyzing supplier responses to our survey, we found three areas of concern: inaccurate smelter and refiner lists, inconsistent approaches to determining whether 3TG was sourced from the Covered Countries, and absence of conflict minerals policies.
Smelter and Refiner Lists: Obtaining a complete and accurate list of smelters and refiners in our supply chain is an essential step in the RCOI process. We have experienced some challenges in collecting this information. For example, we found that many of the smelter and refiner names reported through the supply chain either are not 3TG smelters or refiners, or that more research is required to make that determination. While we believe our suppliers are providing information in good faith, this challenge underscores the need for supplier education and improved information on smelter and refiner facilities worldwide.
Determining Whether 3TG Was Sourced from the Covered Countries: EMC is committed to being DRC conflict-free and to sourcing responsibly from the Covered Countries through CFSP-compliant smelters and refiners. However, we found that many suppliers are still learning how to determine the country of origin of 3TG. For example, some of our suppliers reported that none of the 3TG in their products originated from the Covered Countries when, in fact, CFSP-compliant smelters in their supply chain publicly disclose that they do source from the Covered Countries. Other suppliers reported that they were sourcing 3TG from the Covered Countries, but did not specify how they had come to this conclusion, or whether that 3TG was sourced through CFSP-compliant smelters. In both situations, when we contacted these suppliers to discuss their responses, we found that many had either misunderstood how to use CFSP to determine country of origin, or they had based their responses solely on what their suppliers had reported to them.
Conflict Minerals Policy: Suppliers who publish their conflict minerals policy show commitment to responsible sourcing. We found that some suppliers declared that they use 3TG, but either did not have, or had not published, a conflict minerals policy.
Assessing smelter and refiner data
In analyzing our smelter and refiner data, we identified two major areas of concern: smelter verification and the limited supply of CFSP-compliant smelters and refiners.
Smelter and Refiner Verification: While we expect that our suppliers will continue to improve their reporting, there is a need for additional research on reported smelter names to verify whether they actually are 3TG smelters or refiners. Without an accurate list of 3TG smelters and refiners in our supply chain, we will not be able to target the smelters and refiners that would benefit from participation in the CFSP audits, or fully understand the progress toward our goal to be DRC Conflict-Free.
Supply of CFSP-compliant Smelters and Refiners: In order for our products to be verified as DRC Conflict-Free, there must be a sufficient number of confirmed conflict-free smelters and refiners to allow a viable supply of minerals. There is still a need for more smelters and refiners to participate in the program. Table 1 shows the percentage of CFSP-compliant smelters and refiners for 3TG in our supply chain, broken out by metal.
Table 1
3TG Smelters and Refiners in EMC’s Supply Chain
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Mineral | Total # smelters and refiners in our supply chain | Total # CFSP-compliant smelters and refiners in our supply chain | % of CFSP-compliant smelters and refiners in our supply chain |
Tantalum | 2013: 24 2014: 39 | 2013: 21 2014: 39 | 2013: 88% 2014: 100% |
Tin | 2013: 47 2014: 71 | 2013: 11 2014: 36 | 2013: 23% 2014: 51% |
Tungsten | 2013: 21 2014: 35 | 2013: 1 2014: 14 | 2013: 5% 2014: 40% |
Gold | 2013: 90 2014: 111 | 2013: 40 2014: 66 | 2013: 44% 2014: 59% |
Based on EMC supplier data as of April 1, 2015 and CFSI’s Reasonable Country of Origin Inquiry report dated April 30, 2015. Numbers only include facilities reported by suppliers that are on the CFSI standard smelter list as of April 30, 2015.
Addressing Identified Risks: Our Approach
EMC is taking steps to improve our due diligence process and further mitigate the risk of purchasing 3TG whose sale finance armed conflict in the DRC. In keeping with our conflict minerals strategy, we focus our risk mitigation efforts in three areas: supplier engagement; increasing the number of conflict-free smelters and refiners; and encouraging responsible sourcing from the Covered Countries.
Engage suppliers in due diligence and DRC Conflict-Free sourcing
EMC issues targeted communications to help our suppliers improve their reporting, informed by the risks identified in our supplier surveys. At the launch of the 2014 survey, we distributed information to help suppliers return more complete and accurate smelter and refiner lists, and better understand the role of CFSP audits in determining the country of origin and the DRC Conflict-Free status of the minerals in their products. As suppliers returned CMRTs, we reviewed their responses against our internally-developed framework for reasonableness and risk. We contacted those whose answers did not seem reasonable, or indicated potential risk, in order to obtain additional information and request corrective actions. Unresponsive suppliers were escalated through supply chain management staff responsible for managing the commercial relationships. We also set a 2014 goal for 100% of Tier 1 direct material suppliers that sell us products containing 3TG to have a conflict minerals policy published on their website. More than 99% (by spend) of our Tier 1 suppliers in scope have done so.
Conflict minerals requirements and incentives are embedded in EMC’s supply chain management business processes. These activities target the Tier 1 and Tier 2 suppliers with whom we have the strongest business
relationship and therefore the greatest influence. For example, suppliers’ conflict minerals risk scores, based on their response to the survey, are incorporated into the supplier scorecard. This scorecard also includes other metrics such as quality, cost and availability, and provides a key input into business decisions. Suppliers’ risk scores and corrective actions are also made available in EMC’s supplier portal, and are included in suppliers’ Quarterly and Executive Business Reviews. Going forward, we will continue to raise our expectations of suppliers to improve due diligence and source from CFSP-compliant smelters.
Increase the number of Conflict-Free Smelters and Refiners
EMC is working to develop a more accurate list of 3TG smelters and refiners in our supply chain, and to encourage verified 3TG smelters and refiners to undergo CFSP audits if they have not already done so. We participate in the CFSI workgroup that conducts research to verify alleged 3TG smelters and refiners, and outreach to engage them in the CFSP audit program. We also contributed to CFSP’s Initial Audit Fund, which pays the costs of a smelter or refiner’s first CFSP audit, a major incentive for smelters to participate. As the number of CFSP-compliant smelters and refiners grows, we can more effectively engage our suppliers to shift purchasing to CFSP-compliant smelters and refiners. There has been measurable improvement from 2013 in the percentage of CFSP-compliant smelters in our supply chain, as shown in Table 1 above.
Encourage responsible sourcing from the Covered Countries
EMC desires to be DRC Conflict-Free, but not at the expense of supporting responsible mining operations in the Covered Countries. In 2014, we educated suppliers who mistakenly believed that CFSP-compliant smelters are, by definition, not sourcing from the Covered Countries, or whose conflict minerals policies indicated that they intend not to source from the Covered Countries at all. In addition, EMC has applied to join the Public-Private Alliance for Responsible Minerals Trade (the PPA), a multi-sector and multi-stakeholder initiative to support supply chain solutions to conflict minerals challenges in the DRC and the Great Lakes Region of Central Africa.
Due Diligence Design
EMC’s due diligence framework conforms in all material respects with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and supplements (Second Edition, 2014).
Due Diligence Performed
Step 1: Establish strong company management systems
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• | Published our company’s conflict minerals policy on EMC.com |
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• | Convened a Conflict Minerals Governance Committee to oversee program |
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• | Maintained an Implementation Team for program execution |
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• | Updated the Standard Operating Procedure |
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• | Improved the tools, processes and materials for supplier communications |
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• | Engaged EMC supply chain staff to support the conflict minerals program through existing business communications and processes |
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• | Maintained conflict minerals program data |
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• | Identified the EMC hotline, email address, and secure web report, which are publicly available on EMC.com, as the mechanism through which any interested party can voice concerns |
Step 2: Identify and assess risks in the supply chainIdentified products and suppliers in scope
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• | Surveyed suppliers in scope with the CMRT |
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• | Reviewed suppliers’ completed CMRTs to determine if they met internally-developed standards of reasonableness and risk |
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• | Reviewed smelters and refiners identified by suppliers |
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◦ | Confirmed 256 CFSI-verified 3TG smelters and refiners in our supply chain |
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▪ | 155 of those smelters and refiners were CFSP-compliant as of April 30, 2015 |
Step 3: Design and implement a strategy to respond to identified risks
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• | Convened the Conflict Minerals Governance Committee regularly to report metrics and discuss identified risks |
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• | Implemented a risk mitigation plan including: |
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◦ | Providing supplier education on conflict-free sourcing and how to improve reporting |
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◦ | Requiring Tier 1 suppliers to publish conflict minerals policies on their corporate websites |
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◦ | Adding supplier conflict mineral risk scores as an indicator in the supplier scorecard |
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◦ | Including conflict minerals risk scores and corrective actions in suppliers’ Executive and Quarterly Business Reviews |
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◦ | Participating in the CFSI’s Smelter Engagement Team to: |
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▪ | Perform research and outreach to verify smelters and refiners that were reported by suppliers but were not on CFSI’s smelter reference list |
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▪ | Communicate with verified smelters and refiners to ask them to become CFSP-compliant |
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◦ | Contributing to CFSI’s Initial Audit Fund, which pays the cost of a smelter or refiner’s first CFSP audit |
Step 4: Plan an independent third-party audit of the smelter or refiner’s due diligence
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• | Relied on the independent third-party audits managed by the CFSP |
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• | Supported the CFSP through active participation in CFSI workgroups |
Step 5: Report annually on supply chain due diligence
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• | Submitted Form SD for the calendar year ended December 31, 2014 to the U.S. Securities and Exchange Commission and published this report on EMC.com. |
To Voice Concerns about EMC’s Conflict Minerals Program
EMC actively encourages its employees and other parties to report concerns either directly to the company or through EMC’s hotline, which is maintained by a third-party provider. The different ways through which reports can be made are included in EMC’s Business Conduct Guidelines, corporate compliance training materials, and elsewhere. Specifically, questions and guidance regarding a potential violation of law, regulation, the Business Conduct Guidelines, or other EMC policies can be reported in any of the following ways:
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• | Contact the Office of the General Counsel by telephone (508-435-1000, extension 77267), facsimile (508-497-8079), or email (General_Counsel@emc.com). |
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• | Contact the Audit Committee of the EMC Board of Directors by email (AuditCommitteeChairman@emc.com) or by mail (Alertline, PMB 3767, 13950 Ballantyne Corporate Place, Charlotte, NC 28277). |
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• | If you are located within the United States, contact the EMC hotline, which is monitored by an independent third-party provider, by telephone (877-764-0557), or via a secure web report to https://emccorporation.alertline.com. |
This report contains forward‑looking statements, within the meaning of the Federal securities laws, about our business and prospects. The forward-looking statements do not include the potential impact of any mergers, acquisitions, divestitures, securities offerings or business combinations that may be announced or closed after the date hereof. Any statements contained herein that are not statements of historical fact may be deemed to be forward-looking statements. Without limiting the foregoing, the words “believes,” “plans,” “intends,” “expects,” “goals” and similar expressions are intended to identify forward-looking statements, although not all forward-looking statements contain these words. Our future results may differ materially from our past results and from those projected in the forward-looking statements due to various uncertainties and risks, including, but not limited to, those described in this report. The forward-looking statements speak only as of the date of this report and undue reliance should not be placed on these statements. We disclaim any obligation to update any forward-looking statements contained herein after the date of this report. Websites referred to in this report are not incorporated by reference unless specifically indicated.
Appendix A
3TG Smelters and Refiners in EMC’s Supply Chain
This list is based on EMC supplier data as of April 1, 2015. In many cases, suppliers provided information encompassing their entire supply chain; this information was not limited to facilities that contributed 3TG used only in EMC products. As a result, we are unable to validate whether our products in fact contain 3TG from all of these sources. Smelters listed as “Active” have committed to undergo a CFSP audit. This list only includes facilities reported by suppliers that are on the CFSI standard smelter list as of April 30, 2015.
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Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
GOLD | | | |
Advanced Chemical Company | CID000015 | UNITED STATES | |
Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN | Compliant |
Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | GERMANY | Compliant |
Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN | |
AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | BRAZIL | Compliant |
Argor-Heraeus SA | CID000077 | SWITZERLAND | Compliant |
Asahi Pretec Corporation | CID000082 | JAPAN | Compliant |
Asaka Riken Co., Ltd. | CID000090 | JAPAN | Active |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY | Compliant |
Aurubis AG | CID000113 | GERMANY | Compliant |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES | |
Bauer Walser AG | CID000141 | GERMANY | |
Boliden AB | CID000157 | SWEDEN | Compliant |
C. Hafner GmbH + Co. KG | CID000176 | GERMANY | Compliant |
Caridad | CID000180 | MEXICO | |
CCR Refinery - Glencore Canada Corporation | CID000185 | CANADA | Compliant |
Cendres + Métaux SA | CID000189 | SWITZERLAND | Active |
Chimet S.p.A. | CID000233 | ITALY | Compliant |
Chugai Mining | CID000264 | JAPAN | |
Daejin Indus Co., Ltd. | CID000328 | KOREA, REPUBLIC OF | |
Daye Non-Ferrous Metals Mining Ltd. | CID000343 | CHINA | |
Do Sung Corporation | CID000359 | KOREA, REPUBLIC OF | |
Doduco | CID000362 | GERMANY | Active |
Dowa | CID000401 | JAPAN | Compliant |
Eco-System Recycling Co., Ltd. | CID000425 | JAPAN | Compliant |
Faggi Enrico S.p.A. | CID002355 | ITALY | |
Gansu Seemine Material Hi-Tech Co., Ltd. | CID000522 | CHINA | |
Geib Refining Corporation | CID002459 | UNITED STATES | |
Guangdong Jinding Gold Limited | CID002312 | CHINA | |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | CHINA | |
Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | CHINA | |
Heimerle + Meule GmbH | CID000694 | GERMANY | Compliant |
Heraeus Ltd. Hong Kong | CID000707 | HONG KONG | Compliant |
Heraeus Precious Metals GmbH & Co. KG | CID000711 | GERMANY | Compliant |
Hunan Chenzhou Mining Group Co., Ltd. | CID000767 | CHINA | |
Hwasung CJ Co., Ltd. | CID000778 | KOREA, REPUBLIC OF | |
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CID000801 | CHINA | |
Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN | Compliant |
Istanbul Gold Refinery | CID000814 | TURKEY | Compliant |
Japan Mint | CID000823 | JAPAN | Compliant |
Jiangxi Copper Company Limited | CID000855 | CHINA | |
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Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
Johnson Matthey Inc. | CID000920 | UNITED STATES | Compliant |
Johnson Matthey Limited | CID000924 | CANADA | Compliant |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION | Compliant |
JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION | Compliant |
JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN | Compliant |
Kazzinc | CID000957 | KAZAKHSTAN | Compliant |
Kennecott Utah Copper LLC | CID000969 | UNITED STATES | Compliant |
Kojima Chemicals Co., Ltd. | CID000981 | JAPAN | Compliant |
Korea Metal Co., Ltd. | CID000988 | KOREA, REPUBLIC OF | |
Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN | |
L' azurde Company For Jewelry | CID001032 | SAUDI ARABIA | Compliant |
Lingbao Gold Company Limited | CID001056 | CHINA | |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | CHINA | |
LS-NIKKO Copper Inc. | CID001078 | KOREA, REPUBLIC OF | Compliant |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | CHINA | |
Materion | CID001113 | UNITED STATES | Compliant |
Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN | Compliant |
Metalor Technologies (Hong Kong) Ltd. | CID001149 | HONG KONG | Compliant |
Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | SINGAPORE | Compliant |
Metalor Technologies (Suzhou) Ltd. | CID001147 | CHINA | |
Metalor Technologies SA | CID001153 | SWITZERLAND | Compliant |
Metalor USA Refining Corporation | CID001157 | UNITED STATES | Compliant |
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | CID001161 | MEXICO | Compliant |
Mitsubishi Materials Corporation | CID001188 | JAPAN | Compliant |
Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN | Compliant |
Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION | |
Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | TURKEY | Compliant |
Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN | |
Nihon Material Co., Ltd. | CID001259 | JAPAN | Compliant |
Ohio Precious Metals, LLC | CID001322 | UNITED STATES | Compliant |
Ohura Precious Metal Industry Co., Ltd. | CID001325 | JAPAN | Compliant |
OJSC Krastvetmet | CID001326 | RUSSIAN FEDERATION | Compliant |
OJSC Kolyma Refinery | CID001328 | RUSSIAN FEDERATION | |
OJSC Novosibirsk Refinery | CID000493 | RUSSIAN FEDERATION | |
PAMP SA | CID001352 | SWITZERLAND | Compliant |
Penglai Penggang Gold Industry Co., Ltd. | CID001362 | CHINA | |
Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION | |
PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA | Compliant |
Rand Refinery (Pty) Ltd. | CID001512 | SOUTH AFRICA | Compliant |
Republic Metals Corporation | CID002510 | UNITED STATES | Compliant |
Royal Canadian Mint | CID001534 | CANADA | Compliant |
Sabin Metal Corp. | CID001546 | UNITED STATES | |
Samduck Precious Metals | CID001555 | KOREA, REPUBLIC OF | |
SAMWON Metals Corp. | CID001562 | KOREA, REPUBLIC OF | |
Schone Edelmetaal | CID001573 | NETHERLANDS | Compliant |
SEMPSA Joyería Platería SA | CID001585 | SPAIN | Compliant |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | CHINA | |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | CHINA | Compliant |
Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | CHINA | Compliant |
So Accurate Group, Inc. | CID001754 | UNITED STATES | |
SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION | Active |
|
| | | |
Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
Solar Applied Materials Technology Corp. | CID001761 | TAIWAN | Compliant |
Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN | Compliant |
Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN | Compliant |
The Great Wall Gold and Silver Refinery of China | CID001909 | CHINA | |
The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | CHINA | Compliant |
Tokuriki Honten Co., Ltd. | CID001938 | JAPAN | Compliant |
Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | CHINA | |
Torecom | CID001955 | KOREA, REPUBLIC OF | Active |
Umicore Brasil Ltda. | CID001977 | BRAZIL | Compliant |
Umicore Precious Metals Thailand | CID002314 | THAILAND | Compliant |
Umicore SA Business Unit Precious Metals Refining | CID001980 | BELGIUM | Compliant |
United Precious Metal Refining, Inc. | CID001993 | UNITED STATES | Compliant |
Valcambi SA | CID002003 | SWITZERLAND | Compliant |
Western Australian Mint trading as The Perth Mint | CID002030 | AUSTRALIA | Compliant |
Yamamoto Precious Metal Co., Ltd. | CID002100 | JAPAN | Compliant |
Yokohama Metal Co., Ltd. | CID002129 | JAPAN | Active |
Yunnan Copper Industry Co., Ltd. | CID000197 | CHINA | |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA | Compliant |
Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 | CHINA | Compliant |
TANTALUM | | | |
Changsha South Tantalum Niobium Co., Ltd. | CID000211 | CHINA | Compliant |
Conghua Tantalum and Niobium Smeltry | CID000291 | CHINA | Compliant |
Duoluoshan | CID000410 | CHINA | Compliant |
Exotech Inc. | CID000456 | UNITED STATES | Compliant |
F&X Electro-Materials Ltd. | CID000460 | CHINA | Compliant |
Global Advanced Metals Aizu | CID002558 | UNITED STATES | Compliant |
Global Advanced Metals Boyertown | CID002557 | UNITED STATES | Compliant |
Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | CHINA | Compliant |
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CID002501 | CHINA | Compliant |
H.C. Starck Co., Ltd. | CID002544 | THAILAND | Compliant |
H.C. Starck GmbH Goslar | CID002545 | GERMANY | Compliant |
H.C. Starck GmbH Laufenburg | CID002546 | GERMANY | Compliant |
H.C. Starck Hermsdorf GmbH | CID002547 | GERMANY | Compliant |
H.C. Starck Inc. | CID002548 | UNITED STATES | Compliant |
H.C. Starck Ltd. | CID002549 | JAPAN | Compliant |
H.C. Starck Smelting GmbH & Co.KG | CID002550 | GERMANY | Compliant |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA | Compliant |
Hi-Temp Specialty Metals, Inc. | CID000731 | UNITED STATES | Compliant |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA | Compliant |
Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA | Compliant |
KEMET Blue Metals | CID002539 | MEXICO | Compliant |
KEMET Blue Powder | CID002568 | UNITED STATES | Compliant |
King-Tan Tantalum Industry Ltd. | CID000973 | CHINA | Compliant |
LSM Brasil S.A. | CID001076 | BRAZIL | Compliant |
Metallurgical Products India Pvt., Ltd. | CID001163 | INDIA | Compliant |
Mineração Taboca S.A. | CID001175 | BRAZIL | Compliant |
Mitsui Mining & Smelting | CID001192 | JAPAN | Compliant |
Molycorp Silmet A.S. | CID001200 | ESTONIA | Compliant |
Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA | Compliant |
Plansee SE Liezen | CID002540 | AUSTRIA | Compliant |
Plansee SE Reutte | CID002556 | AUSTRIA | Compliant |
|
| | | |
Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
QuantumClean | CID001508 | UNITED STATES | Compliant |
RFH Tantalum Smeltry Co., Ltd. | CID001522 | CHINA | Compliant |
Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION | Compliant |
Taki Chemicals | CID001869 | JAPAN | Compliant |
Telex Metals | CID001891 | UNITED STATES | Compliant |
Ulba Metallurgical Plant JSC | CID001969 | KAZAKHSTAN | Compliant |
Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 | CHINA | Compliant |
Zhuzhou Cemented Carbide | CID002232 | CHINA | Compliant |
TIN | | | |
Alpha | CID000292 | UNITED STATES | Compliant |
China Tin Group Co., Ltd. | CID001070 | CHINA | Active |
CNMC (Guangxi) PGMA Co., Ltd. | CID000278 | CHINA | |
Cooperativa Metalurgica de Rondônia Ltda. | CID000295 | BRAZIL | Compliant |
CV Gita Pesona | CID000306 | INDONESIA | |
CV Serumpun Sebalai | CID000313 | INDONESIA | |
CV United Smelting | CID000315 | INDONESIA | Compliant |
Dowa | CID000402 | JAPAN | Compliant |
EM Vinto | CID000438 | BOLIVIA | Compliant |
Estanho de Rondônia S.A. | CID000448 | BRAZIL | |
Feinhütte Halsbrücke GmbH | CID000466 | GERMANY | |
Fenix Metals | CID000468 | POLAND | Active |
Gejiu Kai Meng Industry and Trade LLC | CID000942 | CHINA | |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | CHINA | Compliant |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | CHINA | |
Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | CHINA | |
Huichang Jinshunda Tin Co., Ltd. | CID000760 | CHINA | |
Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | CHINA | Compliant |
Linwu Xianggui Ore Smelting Co., Ltd. | CID001063 | CHINA | |
Magnu's Minerais Metais e Ligas Ltda. | CID002468 | BRAZIL | Compliant |
Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA | Compliant |
Melt Metais e Ligas S/A | CID002500 | BRAZIL | Compliant |
Metallic Resources, Inc. | CID001142 | UNITED STATES | |
Metallo-Chimique N.V. | CID002773 | BELGIUM | Compliant |
Mineração Taboca S.A. | CID001173 | BRAZIL | Compliant |
Minsur | CID001182 | PERU | Compliant |
Mitsubishi Materials Corporation | CID001191 | JAPAN | Compliant |
Nankang Nanshan Tin Manufactory Co., Ltd. | CID001231 | CHINA | |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | VIET NAM | Active |
Novosibirsk Processing Plant Ltd. | CID001305 | RUSSIAN FEDERATION | |
O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | THAILAND | Active |
O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines | Active |
Operaciones Metalurgical S.A. | CID001337 | BOLIVIA | Compliant |
PT Alam Lestari Kencana | CID001393 | INDONESIA | |
PT Aries Kencana Sejahtera | CID000309 | INDONESIA | Active |
PT Artha Cipta Langgeng | CID001399 | INDONESIA | Compliant |
PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA | Compliant |
PT Babel Inti Perkasa | CID001402 | INDONESIA | Compliant |
PT Bangka Kudai Tin | CID001409 | INDONESIA | |
PT Bangka Putra Karya | CID001412 | INDONESIA | Compliant |
PT Bangka Timah Utama Sejahtera | CID001416 | INDONESIA | |
PT Bangka Tin Industry | CID001419 | INDONESIA | Compliant |
|
| | | |
Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
PT Belitung Industri Sejahtera | CID001421 | INDONESIA | Compliant |
PT BilliTin Makmur Lestari | CID001424 | INDONESIA | Active |
PT Bukit Timah | CID001428 | INDONESIA | Compliant |
PT DS Jaya Abadi | CID001434 | INDONESIA | Compliant |
PT Eunindo Usaha Mandiri | CID001438 | INDONESIA | Compliant |
PT Fang Di MulTindo | CID001442 | INDONESIA | |
PT Inti Stania Prima | CID002530 | INDONESIA | Active |
PT Justindo | CID000307 | INDONESIA | Active |
PT Karimun Mining | CID001448 | INDONESIA | Active |
PT Mitra Stania Prima | CID001453 | INDONESIA | Compliant |
PT Panca Mega Persada | CID001457 | INDONESIA | Compliant |
PT Pelat Timah Nusantara Tbk | CID001486 | INDONESIA | |
PT Prima Timah Utama | CID001458 | INDONESIA | Compliant |
PT Refined Bangka Tin | CID001460 | INDONESIA | Compliant |
PT Sariwiguna Binasentosa | CID001463 | INDONESIA | Compliant |
PT Seirama Tin Investment | CID001466 | INDONESIA | |
PT Stanindo Inti Perkasa | CID001468 | INDONESIA | Compliant |
PT Sumber Jaya Indah | CID001471 | INDONESIA | Active |
PT Supra Sukses Trinusa | CID001476 | INDONESIA | |
PT Timah (Persero) Tbk Kundur | CID001477 | INDONESIA | Compliant |
PT Timah (Persero) Tbk Mentok | CID001482 | INDONESIA | Compliant |
PT Tinindo Inter Nusa | CID001490 | INDONESIA | Compliant |
Rui Da Hung | CID001539 | TAIWAN | Active |
Soft Metais Ltda. | CID001758 | BRAZIL | Active |
Thaisarco | CID001898 | THAILAND | Compliant |
VQB Mineral and Trading Group JSC | CID002015 | VIET NAM | Active |
White Solder Metalurgia e Mineração Ltda. | CID002036 | BRAZIL | Compliant |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | CHINA | Active |
Yunnan Tin Group (Holding) Company Limited | CID002180 | CHINA | Compliant |
TUNGSTEN | | | |
A.L.M.T. TUNGSTEN Corp. | CID000004 | JAPAN | Active |
Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | China | Compliant |
Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | CHINA | Active |
Dayu Weiliang Tungsten Co., Ltd. | CID000345 | CHINA | |
Fujian Jinxin Tungsten Co., Ltd. | CID000499 | CHINA | Compliant |
Ganxian Shirui New Material Co., Ltd. | CID002531 | CHINA | |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | CHINA | Compliant |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA | Compliant |
Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 | CHINA | Active |
Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA | Compliant |
Global Tungsten & Powders Corp. | CID000568 | UNITED STATES | Compliant |
Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | CHINA | Active |
H.C. Starck GmbH | CID002541 | GERMANY | Active |
H.C. Starck Smelting GmbH & Co.KG | CID002542 | GERMANY | Active |
Hunan Chenzhou Mining Group Co., Ltd. | CID000766 | CHINA | Active |
Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | CHINA | Compliant |
Japan New Metals Co., Ltd. | CID000825 | JAPAN | Compliant |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | CHINA | |
Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA | Compliant |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | CHINA | |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | CHINA | |
|
| | | |
Smelter or Refiner Name | Smelter Identification Number | Smelter or Refiner Location | CFSP-Compliant status as of 4/30/15 |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | CHINA | |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 | CHINA | |
Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | CHINA | Active |
Kennametal Fallon | CID000966 | UNITED STATES | |
Kennametal Huntsville | CID000105 | UNITED STATES | |
Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA | Compliant |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 | VIET NAM | Active |
Pobedit, JSC | CID002532 | RUSSIAN FEDERATION | |
Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | VIET NAM | |
Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 | VIET NAM | Compliant |
Wolfram Bergbau und Hütten AG | CID002044 | AUSTRIA | Compliant |
Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA | Compliant |
Xiamen Tungsten Co., Ltd. | CID002082 | CHINA | Compliant |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | CHINA | Active |
Appendix B
Countries from which the minerals in EMC’s products may have originated
Based on CFSI’s Reasonable Country of Origin Inquiry report dated April 30, 2015, the countries of origin of the 3TG processed by facilities listed in Appendix A are believed to include the following:
|
| |
Angola | Luxembourg |
Argentina | Madagascar |
Australia | Malaysia |
Austria | Mongolia |
Belgium | Mozambique |
Bolivia | Myanmar |
Brazil | Namibia |
Burundi | Netherlands |
Canada | Nigeria |
Central African Republic | Peru |
Chile | Portugal |
China | Republic of Congo |
Colombia | Russia |
Cote D’Ivoire | Rwanda |
Czech Republic | Sierra Leone |
Democratic Republic of the Congo | Singapore |
Djibouti | Slovakia |
Egypt | South Africa |
Estonia | South Korea |
Ethiopia | South Sudan |
France | Spain |
Germany | Suriname |
Guyana | Switzerland |
Hungary | Taiwan |
India | Tanzania |
Indonesia | Thailand |
Ireland | Uganda |
Israel | United Kingdom |
Japan | United States of America |
Kazakhstan | Vietnam |
Kenya | Zambia |
Laos | Zimbabwe |
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