EXHIBIT 1.01
Published on May 31, 2017
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:
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CNG Compressors – Products that create CNG by compressing natural gas. This product category also includes replacement parts for CNG compressors.
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CNG Dispensers – Products that dispense CNG into vehicles. This product category also includes replacement parts for CNG dispensers.
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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.
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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.
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LNG Dispensers – Products that dispense LNG into vehicles. This product category also includes replacement parts for LNG dispensers.
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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.
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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:
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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. |
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The Company expects its suppliers to partner with it to comply with the Rule. The Company expects its suppliers to: |
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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); |
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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 |
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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. |
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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
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The Company continued to make the Company Policy publicly available. |
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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. |
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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
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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. |
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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. |
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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
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The Working Group reported the findings of the due diligence program to the Company’s senior management and Board of Directors. |
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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
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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. |
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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
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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:
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Enhancing its employee training relating to the Rule, the Company Policy and the Company’s procedures to identify and work with in-scope suppliers. |
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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. |
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Seeking opportunities to assist suppliers in building capabilities with a view to improving due diligence performance. |
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Continuing its initiative to include language in its new supply contracts that requires suppliers to comply with the Company Policy. |
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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 |