Clean Energy Fuels Corp.
Clean Energy Fuels Corp. (Form: SD, Received: 05/31/2017 16:48:14)


 



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

Specialized Disclosure Report

CLEAN ENERGY FUELS CORP.
(Exact Name of Registrant as Specified in Charter)

Delaware
(State or Other Jurisdiction of
Incorporation or Organization)
 
001-33480  
(Commission File Number)
 
33-0968580  
(IRS Employer Identification No.)

4675 MacArthur Court, Suite 800
Newport Beach, California
 
92660
(Address of Principal Executive Offices)
 
(Zip Code)

J. Nathan Jensen
Vice President and General Counsel
Clean Energy Fuels Corp.
4675 MacArthur Court, Suite 800
Newport Beach, California 92660
(949) 437-1000
(Name and Telephone Number, including Area Code,
of the Person to Contact in Connection with This Report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.



 









Section 1 — Conflict Minerals Disclosure

Item 1.01
Conflict Minerals Disclosure and Report.

Conflict Minerals Disclosure

This Form SD of Clean Energy Fuels Corp. (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2016 to December 31, 2016.

A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD, is hereby incorporated by reference herein, and is publicly available at http://investors.cleanenergyfuels.com/corporate-governance.cfm. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this Form SD or the Conflict Minerals Report filed herewith.

Item 1.02
Exhibit.

The Conflict Minerals Report required by Item 1.01 of Form SD is filed as Exhibit 1.01 to this Form SD.

Section 2 — Exhibits

Item 2.01    Exhibits

Exhibit
No.
 
Description
1.01
 
Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016 as required by Items 1.01 and 1.02 of this Form.

1







SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 
Clean Energy Fuels Corp.
 
 
 
 
By:
/s/ Andrew J. Littlefair
Date: May 31, 2017
 
Name: Andrew J. Littlefair
 
 
Title: President and Chief Executive Officer
 

2







EXHIBIT INDEX

Exhibit
No.
 
Description
1.01
 
Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016 as required by Items 1.01 and 1.02 of this Form.

3













































Exhibit 1.01


CLEAN ENERGY FUELS CORP.
Conflict Minerals Report
For the Reporting Period from January 1, 2016 to December 31, 2016

This Conflict Minerals Report (the “Report”) of Clean Energy Fuels Corp. (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2016 to December 31, 2016 (the “Reporting Period”). As permitted by applicable guidance of the Securities and Exchange Commission, the Company did not obtain an independent private sector audit within the meaning of the Rule.

Overview of the Company and the Rule

The Company is the leading provider of natural gas as an alternative fuel for vehicle fleets in the United States and Canada, based on the number of stations operated and the amount of gasoline gallon equivalents (“GGEs”) of compressed natural gas (“CNG”), liquefied natural gas (“LNG”) and renewable natural gas (“RNG”) delivered. The Company’s principal business is supplying CNG, LNG and RNG (which can be delivered in the form of CNG or LNG) for light, medium and heavy-duty vehicles and providing operation and maintenance (“O&M”) services for vehicle fleet customer stations. As a comprehensive solution provider, the Company also designs, builds, operates and maintains fueling stations; manufactures, sells and services non-lubricated natural gas fueling compressors and other equipment used in CNG stations and LNG stations; offers assessment, design and modification solutions to provide operators with code-compliant service and maintenance facilities for natural gas vehicle fleets; transports and sells CNG and LNG to industrial and institutional energy users who do not have direct access to natural gas pipelines; procures and sells RNG; sells tradable credits it generates by selling natural gas and RNG as a vehicle fuel; helps its customers acquire and finance natural gas vehicles; and obtains federal, state and local tax credits, grants and incentives. The Company serves fleet vehicle operators in a variety of markets, including heavy-duty trucking, airports, refuse, public transit, government fleets, and industrial and institutional energy users. As of December 31, 2016, the Company served nearly 1,000 fleet customers operating over 45,000 natural gas vehicles, and owned, operated or supplied over 570 natural gas fueling stations in 42 states in the United States and in four provinces in Canada.

The Rule requires disclosure of certain information if a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of the products. The Rule also requires such companies to conduct certain inquiries reasonably designed to determine whether such minerals originated in the countries specified in the Rule. The minerals specified in the Rule, which are collectively referred to in this Report as the “Conflict Minerals,” consist of gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The countries specified in the Rule, which are collectively referred to in this Report as the “Covered Countries,” consist of the Democratic Republic of the Congo and all countries that share an international border with the Democratic Republic of Congo, which presently consists of the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products for which the Conflict Minerals are necessary to the functionality or production of the products.

When this Report uses the term “conflict-free,” it means the applicable mine, smelter or refiner has been verified as complying with the Conflict-Free Smelter Program (the “CFSP”) of the Conflict-Free Sourcing Initiative (“CFSI”) or an equivalent third-party audit program.

The Company’s Products Covered by this Report

This Report covers products: (i) for which Conflict Minerals are necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are collectively referred to in this Report as the “Covered Products,” consist of the following:

CNG Compressors – Products that create CNG by compressing natural gas. This product category also includes replacement parts for CNG compressors.





CNG Dispensers – Products that dispense CNG into vehicles. This product category also includes replacement parts for CNG dispensers.
CNG Pressure Reduction Systems – Systems that reduce the pressure of the natural gas that is supplied to a location. This product category also includes replacement parts for CNG pressure reduction systems.
LNG Pumps – Products that offload LNG from cryogenic tanker trailers into storage tanks at LNG fueling stations. LNG pumps also deliver LNG to dispensers from storage tanks. This product category also includes replacement parts for LNG pumps.
LNG Dispensers – Products that dispense LNG into vehicles. This product category also includes replacement parts for LNG dispensers.
Fueling Station Support Panels – Electrical storage panels used in natural gas fueling stations. A fueling station support panel houses the point of sale system that tracks dispenser transactions, the communications system, purge fans, a digital video recorder and camera to record activities at the station and power circuits for station lighting and electrical control. This product category also includes replacement parts for fueling station support panels.

Third-party products that the Company sells at retail but does not manufacture or contract to manufacture are outside the scope of this Report.

Overview of the Company’s Supply Chain

The Company’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the original sources of Conflict Minerals and the ultimate manufacture of the Covered Products. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners. The Company must therefore rely on its suppliers to provide information regarding the origin of Conflict Minerals that are necessary to the functionality or production of the Covered Products. Moreover, the Company believes the mines, smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and therefore has sought to identify the applicable mines, smelters and refiners of Conflict Minerals in the Company’s supply chain.

The Company’s Conflict Minerals Policy

The Company maintains a policy relating to the Conflict Minerals (the “Company Policy”) that provides as follows:

The Company is guided by its core beliefs and values as stated in the Company’s Code of Ethics. The Company is committed to ethical practices and compliance with applicable laws and regulations wherever it does business. The Company believes that its commitment to integrity and citizenship extends to its worldwide supply base. The Company is committed to sourcing its products responsibly, and it expects its suppliers to also source materials from responsible suppliers.
The Company expects its suppliers to partner with it to comply with the Rule. The Company expects its suppliers to:
o
Complete the Company’s Conflict Minerals survey, identifying whether any Conflict Mineral is present in the material that they sell to the Company and the smelter, refiner or mine that originally provided it (for this purpose, the Company’s direct suppliers may have to require successive upstream suppliers to complete the Company’s Conflict Minerals survey until the applicable smelter, refiner or mine is identified);
o
Agree to cooperate fully with the Company in connection with any due diligence that the Company chooses to perform with respect to its inquiries; and
o
When the Company deems it necessary, to provide reasonable proof of the due diligence performed by the supplier to support the information provided by the supplier to the Company.
The Company evaluates its relationships with its suppliers on an ongoing basis, and reserves the right to consider the extent to which a supplier has failed to reasonably comply with the Company Policy in the course of such evaluation.

The Company has designed its Conflict Minerals reporting efforts to align and comply with the Rule. The full text of the Company Policy is available at http://investors.cleanenergyfuels.com/corporate-governance.cfm. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not intended to be incorporated into this Report.

The Company’s Reasonable Country of Origin Inquiry

The Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) regarding the Conflict Minerals. This RCOI was reasonably designed to determine whether any of the Conflict Minerals necessary to the functionality or production of a Covered Product originated in the Covered Countries or may be from recycled or scrap sources. Based on the RCOI, the Company





has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources. As a result, the Company exercised due diligence on the source and chain of custody of such Conflict Minerals, as described below.

Due Diligence Process

Due diligence process design

The Company’s due diligence measures have been designed to conform, in all material respects, to the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Second Edition (2013) , including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”).

Due diligence performed

Below is a summary of the Company’s due diligence process performed for the Covered Products in the Reporting Period. The measures described below are not all of the measures that the Company took in respect of the Reporting Period in furtherance of the Company Policy or pursuant to the Rule and the OECD Guidance.

OECD Guidance Step 1: Maintain a management system

The Company continued to make the Company Policy publicly available.
The Company maintained a working group that oversaw its due diligence process (the “Working Group”). The Working Group was led by the Company’s General Counsel and included the Company’s Director, Supply Chain, the Supplier Development Specialist of the Company’s Clean Energy Compression subsidiary, the Supply Chain Manager of the Company’s Clean Energy Cryogenics subsidiary, and the Company’s Director, Legal Affairs. The Company also engaged an external service provider to support the due diligence process.
The Company continued to use CFSI’s Conflict Minerals Reporting Template (the “Template”) as a means for the collection of information relating to the use and origin of Conflict Minerals (including smelter data) in the Company’s supply chain.

OECD Guidance Step 2: Identify and assess risks

The Company contacted its 48 identified in-scope suppliers and provided them with a summary of the Rule, links to the Template and the Company Policy, and contact information for the Company.
To aid in the identification and assessment of potentially adverse impacts, the Company defined several “Red Flags,” or indicators that one or more items in a response are worthy of further action by the Company. The Red Flags were designed to ensure that the Template has been completely filled out and to capture (i) reasonableness of responses using logic checks; (ii) whether a supplier has initiated its own due diligence on minerals sourcing; (iii) whether any Conflict Minerals are sourced from one of the Covered Countries, and if sourced from one of the Covered Countries, whether the identified mines, smelters or refiners are conflict-free; and (iv) whether the mines, smelters or refiners identified by suppliers are “certified” or “active” under the CFSI.
Suppliers that did not submit the Template by the requested deadline or presented Red Flags were contacted by members of the Working Group.

OECD Guidance Step 3: Design and implement strategy to respond to risk

The Working Group reported the findings of the due diligence program to the Company’s senior management and Board of Directors.
The Company maintained a risk management plan that establishes supplier risk management strategies, and followed up with suppliers as needed in accordance with this plan.

OECD Guidance Step 4: Carry out independent third-party audits of the supply chain

The Company relied on the CFSI and that organization’s CFSP for independent third-party audits of the mines, smelters and refiners in its supply chain.
As noted above, the Company did not obtain an independent private sector audit within the meaning of the Rule.





OECD Guidance Step 5: Report on supply chain due diligence

The Company is reporting the results of the due diligence it performed by providing this Report as Exhibit 1.01 to a Form SD filed with the Securities and Exchange Commission. The Company also has made this Report publicly available on its website.

Results of Due Diligence Performed

The Company’s efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in the Covered Products with the greatest possible specificity consisted primarily of the due diligence measures described in this Report. The Company received responses from 69% of its identified in-scope suppliers.

As compared to 2015, more of the suppliers contacted by the Company provided the names of the facilities from which they source Conflict Minerals. A small number of suppliers, however, responded that they were not requesting mine, smelter or refiner names from their suppliers and/or had not implemented due diligence procedures to determine the origin of Conflict Minerals in their respective supply chains.

Based on the information provided by the Company’s suppliers, and taking into account the supplier responses described in the preceding paragraph, the Company believes that the facilities that may have been used to process the necessary Conflict Minerals contained in the Covered Products include the processing facilities listed in Tables 1, 2 and 3 at the end of this Report. Of the 313 processing facilities identified for the Reporting Period by the Company’s suppliers, 243 were validated as conflict-free, 14 have agreed to participate in the CFSP but have not yet completed the program and 56 have not been validated as conflict-free.

Many of the supplier responses represented their supply chain at a company-level rather than being product-specific. As such, the list of processing facilities disclosed in this Report may contain more facilities than those that actually processed the Conflict Minerals contained in the Covered Products.

Based on its due diligence efforts, the Company does not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in the Covered Products. Based on the information provided by the Company’s suppliers, however, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products may have originated from the Covered Countries or may not be from recycled or scrap sources.

Additional Future Measures

The Company aims to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups (perpetrators of serious human rights abuses) in the Covered Countries:

Enhancing its employee training relating to the Rule, the Company Policy and the Company’s procedures to identify and work with in-scope suppliers.
Continuing to engage with suppliers to help them better understand the Rule and the Company Policy and to obtain accurate and complete information about the origin of Conflict Minerals in the Company’s supply chain, including improving the quality of the processing facility data provided by suppliers.
Seeking opportunities to assist suppliers in building capabilities with a view to improving due diligence performance.
Continuing its initiative to include language in its new supply contracts that requires suppliers to comply with the Company Policy.
Engaging in industry initiatives that encourage conflict-free supply chains.

Inherent Limitations on Due Diligence Measures

As a downstream purchaser of products that contain Conflict Minerals, the Company’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals contained in the Covered Products. The supply chain of commodities such as the Conflict Minerals is a complex and multi-step process that involves a number of different parties. Since the Company does not have direct contractual relationships with mines, smelters and refiners, its due diligence processes must rely on information provided by its direct suppliers, as well as similar information provided to those suppliers within their supply chains, to identify the original sources of the necessary Conflict Minerals contained in the Covered Products. The Company also relies on information collected and provided by independent third-party audit programs. These sources of information may yield unreliable, inaccurate or incomplete information due to a variety of factors, including human or other errors or fraudulent actions.






Forward-Looking Statements

This Report contains forward-looking statements regarding the Company’s business, products and Conflict Minerals efforts, including steps the Company intends to take to mitigate the risk that Conflict Minerals in its products finance or benefit armed groups in the Covered Countries. Words such as “expects,” “believes,” “aims” 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 Report. All statements made in this Report concerning future matters that are not historical in nature are forward-looking statements. Although forward-looking statements in this Report reflect the Company’s good faith judgment, such statements can only be based on facts and assumptions currently known by the Company. Consequently, 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 or implied by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, among others: the risk that information reported to the Company by its suppliers, or other industry information used by the Company, may be inaccurate; the risk that mines, smelters or refiners may not participate in the CFSP, which is a voluntary initiative; and risks related to the Company’s compliance with government regulations and policies, which, among other risks, are discussed under “Risk Factors” in the Company’s Quarterly Report on Form 10-Q most recently filed with the Securities and Exchange Commission. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this Report. The Company undertakes no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.





Tables of Our Conflict Minerals Processing Facilities

Table 1. CFSP-compliant processing facilities as of April 18, 2017.

Processing facilities reported in the Company’s supply chain validated as compliant according to the CFSP.

Metal
Processing Facility Name
Processing Facility Location
Gold
Advanced Chemical Company
United States
Gold
Aida Chemical Industries Co. Ltd.
Japan
Gold
Al Etihad Gold Refinery DMCC
United Arab Emirates
Gold
Allgemeine Gold- und Silberscheideanstalt A.G.
Germany
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
Uzbekistan
Gold
AngloGold Ashanti Córrego do Sítio Mineração
Brazil
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp
Japan
Gold
Asahi Refining Canada Limited
Canada
Gold
Asahi Refining USA Inc.
United States
Gold
Asaka Riken Co Ltd
Japan
Gold
AU Traders and Refiners
South Africa
Gold
Aurubis AG
Germany
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Boliden AB
Sweden
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Chimet S.p.A.
Italy
Gold
Daejin Indus Co. Ltd
Korea, Republic Of
Gold
Do Sung Corporation
Korea, Republic Of
Gold
Doduco
Germany
Gold
Dowa
Japan
Gold
Eco-System Recycling Co., Ltd.
Japan
Gold
Emirates Gold DMCC
United Arab Emirates
Gold
FSE Novosibirsk Refinery
Russian Federation
Gold
Geib Refining Corporation
United States
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Ltd Hong Kong
China
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
China
Gold
Ishifuku Metal Industry Co., Ltd.
Japan
Gold
Istanbul Gold Refinery
Turkey
Gold
Japan Mint
Japan
Gold
Jiangxi Copper Co., Ltd.
China
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Russian Federation
Gold
JSC Uralectromed
Russian Federation
Gold
JX Nippon Mining & Metals Co., Ltd
Japan
Gold
Kazzinc
Kazakhstan
Gold
Kennecott Utah Copper LLC
United States
Gold
Kojima Chemicals Co. Ltd
Japan
Gold
Korea Zinc Co. Ltd.
Korea, Republic Of
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
Gold
LS-Nikko
Korea, Republic Of





Metal
Processing Facility Name
Processing Facility Location
Gold
Materion
United States
Gold
Matsuda Sangyo Co. Ltd
Japan
Gold
Metalor Technologies (Hong Kong) Ltd
Hong Kong
Gold
Metalor Technologies (Singapore) Pte., Ltd.
Singapore
Gold
Metalor Technologies (Suzhou) Ltd.
China
Gold
Metalor Technologies S.A.
Switzerland
Gold
Metalor USA Refining Corporation
United States
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
Mexico
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Kinzoku Co., Ltd.
Japan
Gold
MMTC-PAMP India Pvt., Ltd.
India
Gold
Moscow Special Alloys Processing Plant
Russian Federation
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
Turkey
Gold
Nihon Material Co. LTD
Japan
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Austria
Gold
Ohura Precious Metal Industry Co., Ltd
Japan
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
Russian Federation
Gold
PAMP S.A.
Switzerland
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Gold
PX Précinox S.A.
Switzerland
Gold
Rand Refinery (Pty) Ltd
South Africa
Gold
Republic Metals Corporation
United States
Gold
Royal Canadian Mint
Canada
Gold
Samduck Precious Metals
Korea, Republic Of
Gold
SAXONIA Edelmetalle GmbH
Germany
Gold
Schone Edelmetaal
Netherlands
Gold
SEMPSA Joyería Platería S.A.
Spain
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
China
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Gold
Singway Technology Co., Ltd.
Taiwan
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
Gold
Solar Applied Materials Technology Corp.
Taiwan
Gold
Sumitomo Metal Mining Co. Ltd.
Japan
Gold
T.C.A S.p.A
Italy
Gold
Tanaka Kikinzoku Group
Taiwan
Gold
The Refinery of Shandong Gold Mining Co. Ltd
China
Gold
Tokuriki Honten Co. Ltd
Japan
Gold
Torecom
Korea, Republic Of
Gold
Umicore Brasil Ltda
Brazil
Gold
Umicore Precious Metals Thailand
Thailand
Gold
Umicore S.A. Business Unit Precious Metals Refining
Belgium
Gold
United Precious Metal Refining, Inc.
United States
Gold
Valcambi S.A.
Switzerland
Gold
Western Australian Mint trading as The Perth Mint
Australia
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
YAMAMOTO PRECIOUS METAL CO., LTD.
Japan
Gold
Yokohama Metal Co Ltd
Japan





Metal
Processing Facility Name
Processing Facility Location
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Gold
Zijin Mining Group Co. Ltd
China
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Tantalum
CHONGYI
China
Tantalum
Conghua Tantalum and Niobium Smeltry
China
Tantalum
D Block Metals, LLC
United States
Tantalum
Duoluoshan
China
Tantalum
Exotech
United States
Tantalum
F&X Electro-Materials Limited
China
Tantalum
FIR Metals & Resource Ltd.
China
Tantalum
Global Advanced Metals Aizu
Japan
Tantalum
Global Advanced Metals Boyertown
United States
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
Tantalum
H.C. Starck Co., Ltd.
Thailand
Tantalum
H.C. Starck GmbH
Germany
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Tantalum
H.C. Starck Inc.
United States
Tantalum
H.C. Starck Ltd.
Japan
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Tantalum
Hi-Temp
United States
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Tantalum
Jiangxi Tuohong New Raw Material
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co. Ltd.
China
Tantalum
Jiujiang Tanbre
China
Tantalum
Kemet Blue Metals
Mexico
Tantalum
KEMET Blue Powder
United States Of America
Tantalum
King-Tan Tantalum Industry Ltd
China
Tantalum
LMS Brasil S.A.
Brazil
Tantalum
Metallurgical Products India Pvt. Ltd.
India
Tantalum
Mineração Taboca S.A.
Brazil
Tantalum
Mitsui Mining & Smelting
Japan
Tantalum
Molycorp Silmet A.S.
Estonia
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China
Tantalum
Power Resources Ltd.
Macedonia, Republic Of
Tantalum
QuantumClean
United States
Tantalum
Resind Indústria e Comércio Ltda
Brazil
Tantalum
RFH Tantalum Smeltry Co., Ltd
China
Tantalum
Solikamsk
Russian Federation
Tantalum
Taki Chemical Co., Ltd.
Japan
Tantalum
Telex
United States
Tantalum
Tranzact, Inc.
United States
Tantalum
Ulba
Kazakhstan
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd
China
Tantalum
Zhuzhou Cement Carbide
China
Tin
Alpha
United States
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China





Metal
Processing Facility Name
Processing Facility Location
Tin
China Rare Metal Materials Company
China
Tin
China Tin Group Co., Ltd.
China
Tin
China Yunnan Tin Co Ltd.
China
Tin
Cooper Santa
Brazil
Tin
CV Ayi Jaya
Indonesia
Tin
CV Dua Sekawan
Indonesia
Tin
CV Gita Pesona
Indonesia
Tin
CV Nurjanah
Indonesia
Tin
CV Serumpun Sebalai
Indonesia
Tin
CV Tiga Sekawan
Indonesia
Tin
CV United Smelting
Indonesia
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Dowa
Japan
Tin
Elmet S.L.U.
Spain
Tin
EM Vinto
Bolivia
Tin
Fenix Metals
Poland
Tin
Geiju Non-Ferrous Metal Processing Co. Ltd.
China
Tin
Gejiu Fengming Metallurgy Chemical Plant
China
Tin
Gejiu Jinye Mineral Company
China
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
Tin
Indra Eramulti Logam
Indonesia
Tin
Kundur Smelter
Indonesia
Tin
Magnu's Minerais Metais e Ligas LTDA
Brazil
Tin
Malaysia Smelting Corp
Malaysia
Tin
Melt Metais e Ligas S.A.
Brazil
Tin
Metallic Resources, Inc.
United States
Tin
Metallo Chimique
Belgium
Tin
Mineração Taboca S.A.
Brazil
Tin
Minsur
Peru
Tin
Mitsubishi Material
Japan
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
OMSA
Bolivia
Tin
PT Artha Cipta Langgeng
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
Indonesia
Tin
PT Babel Inti Perkasa
Indonesia
Tin
PT Bangka Prima Tin
Indonesia
Tin
PT Bangka Tin Industry
Indonesia
Tin
PT Belitung Industri Sejahtera
Indonesia
Tin
PT Cipta Persada Mulia
Indonesia
Tin
PT DS Jaya Abadi
Indonesia
Tin
PT Eunindo Usaha Mandiri
Indonesia
Tin
PT Inti Stania Prima
Indonesia
Tin
PT Karimun Mining
Indonesia
Tin
PT Kijang Jaya Mandiri
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT O.M. Indonesia
Indonesia
Tin
PT Panca Mega
Indonesia





Metal
Processing Facility Name
Processing Facility Location
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Refined Bangka Tin
Indonesia
Tin
PT Sariwiguna Binasentosa
Indonesia
Tin
PT Stanindo Inti Perkasa
Indonesia
Tin
PT Sukses Inti Makmur
Indonesia
Tin
PT Sumber Jaya Indah
Indonesia
Tin
PT Timah (Persero) Tbk Mentok
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Tommy Utama
Indonesia
Tin
Resind Indústria e Comércio Ltda
Brazil
Tin
Rui Da Hung
Taiwan
Tin
Soft Metais Ltda.
Brazil
Tin
Thaisarco
Thailand
Tin
VQB Mineral and Trading Group JSC
Vietnam
Tin
White Solder Metalurgia
Brazil
Tungsten
A.L.M.T. Corp.
Japan
Tungsten
Asia Tungsten Products Vietnam Ltd.
Vietnam
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
Tungsten
Ganzhou Huaxing Tungsten Products Co. LTD.
China
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp
United States
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Tungsten
H.C. Starck GmbH
Germany
Tungsten
H.C. Starck Smelting GmbH & Co.KG
Germany
Tungsten
Hunan Chenzhou Mining Co., Ltd.
China
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
China
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
China
Tungsten
Hydrometallurg, JSC
Russian Federation
Tungsten
Japan New Metals Co Ltd
Japan
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Germany
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Tungsten
Kennametal Fallon
United States
Tungsten
Kennametal Huntsville
United States
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
Tungsten
Moliren Ltd
Russian Federation
Tungsten
Niagara Refining LLC
United States
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Vietnam
Tungsten
Philippine Chuangin Industrial Co., Inc.
Philippines
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
China
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
Vietnam
Tungsten
Unecha Refractory metals plant
Russian Federation
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd
Vietnam
Tungsten
Wolfram Bergbau und Hütten AG
Austria





Metal
Processing Facility Name
Processing Facility Location
Tungsten
Woltech Korea Co., Ltd.
Korea, Republic Of
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
China
Tungsten
Xiamen Tungsten Co Ltd
China
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
China
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
China


Table 2. CFSP -participating processing facilities as of April 18, 2017.

Processing facilities reported in the Company’s supply chain that have agreed to participate in the CFSP but have not yet completed the program.

Metal
Processing Facility Name
Processing Facility Location
Gold
Abington Reldan Metals, LLC
United States
Gold
Bangalore Refinery
India
Gold
Cendres & Métaux SA
Switzerland
Gold
KGHM Polska Miedź Spółka Akcyjna
Poland
Gold
Modeltech Sdn Bhd
Malaysia
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
Tony Goetz NV
Belgium
Tin
Chengfeng Metals Co Pte Ltd
China
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Vietnam
Tin
Gejiu Kai Meng Industry and Trade LLC
China
Tin
Gejiu YunXin Colored Electrolysis Ltd
China
Tin
Huichang Jinshunda Tin Co. Ltd
China
Tin
Jiangxi Nanshan
China
Tin
Modeltech Sdn Bhd
Malaysia


Table 3. No CFSP validation as of April 18, 2017.

Processing facilities reported in the Company’s supply chain that have not been validated as CFSP-compliant.

Metal
Processing Facility Name
Processing Facility Location
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Turkey
Gold
AURA-II
United States
Gold
Caridad
Mexico
Gold
CHALCO Yunnan Copper Co. Ltd.
China
Gold
Chugai Mining
Japan
Gold
Daye Non-Ferrous Metals Mining Ltd.
China
Gold
Degussa Sonne / Mond Goldhandel GmbH
Germany
Gold
Elemetal Refining, LLC
United States
Gold
Fidelity Printers and Refiners Ltd.
Zimbabwe
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
China
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China
Gold
Guangdong Jinding Gold Limited
China
Gold
Gujarat Gold Centre
India
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
China
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
China





Metal
Processing Facility Name
Processing Facility Location
Gold
Hunan Chenzhou Mining Co., Ltd.
China
Gold
Hwasung CJ Co., Ltd
Korea, Republic Of
Gold
Kaloti Precious Metals
United Arab Emirates
Gold
Kazakhmys Smelting LLC
Kazakhstan
Gold
Korea Metal Co., Ltd.
Korea, Republic Of
Gold
L'azurde Company For Jewelry
Saudi Arabia
Gold
Lingbao Gold Co., Ltd.
China
Gold
Lingbao Jinyuan tonghu
China
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
China
Gold
Morris and Watson
New Zealand
Gold
Penglai Penggang Gold Industry Co Ltd
China
Gold
Remondis Argentia B.V.
Netherlands
Gold
SAAMP
France
Gold
Sabin Metal Corp.
United States
Gold
SAFINA A.S.
Czech Republic
Gold
Sai Refinery
India
Gold
SAMWON METALS Corp.
Korea, Republic Of
Gold
So Accurate Group, Inc.
United States
Gold
Tongling Nonferrous Metals Group Co., Ltd.
China
Gold
TOO Tau-Ken-Altyn
Kazakhstan
Gold
Universal Precious Metals Refining Zambia
Zambia
Tantalum
E.S.R. Electronics
United States
Tantalum
H.C. Starck GmbH Laufenburg
Germany
Tantalum
Plansee SE Liezen
Austria
Tantalum
Plansee SE Reutte
Austria
Tin
An Thai Minerals Co., Ltd.
Vietnam
Tin
An Vinh Joint Stock Mineral Processing Company
Vietnam
Tin
CNMC (Guangxi) PGMA Co., Ltd.
China
Tin
CV JusTindo
Indonesia
Tin
Estanho de Rondônia S.A.
Brazil
Tin
Gejiu Zi-Li
China
Tin
NGHE TIN NON-FERROUS METAL
Vietnam
Tin
PT Tirus Putra Mandiri
Indonesia
Tin
PT Wahana Perkit Jaya
Indonesia
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Vietnam
Tungsten
ACL Metais Eireli
Brazil
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
China
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
China
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
China
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
China
Tungsten
Jiangxi Minmetals Gao'an Non-Ferrous Metals Co., Ltd.
China