Document





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

______________________


FORM SD
Specialized Disclosure Report

______________________


STEELCASE INC.
(Exact name of registrant as specified in its charter)
 

Michigan
1-13873
38-0819050
(State or other jurisdiction of incorporation or organization)
(Commission File Number)
(IRS employer identification number)
 
 
 
901 44th Street SE
 
 
Grand Rapids, Michigan
 
49508
(Address of principal executive offices)
 
(Zip code)
 
 
 
Liesl A. Maloney (616) 247-2710
(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, 2017.






Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of Steelcase Inc. is filed in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1, 2017 to December 31, 2017. As used in this Form SD, unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are to Steelcase Inc. and its consolidated subsidiaries.

Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in Rule 13p-1 are necessary to the production or functionality of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). The “Covered Countries” for the purposes of Rule 13p-1 are the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

Certain of our operations manufacture or contract to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products. We conducted a reasonable country of origin inquiry regarding such Conflict Minerals, which was designed to determine whether any of the Conflict Minerals originated in the Covered Countries or were from recycled or scrap sources. For those Conflict Minerals which we believe may have originated in the Covered Countries and which we were unable to conclude were from scrap or recycled sources, we exercised due diligence on the source and chain of custody of those Conflict Minerals. Our reasonable country of origin inquiry and due diligence processes are described in our Conflict Minerals Report, which is filed as Exhibit 1.01 to this Form SD, and is publicly available at ir.steelcase.com/financials.cfm.

Item 1.02 Exhibit

As specified in Section 2, Item 2.01, Steelcase Inc. is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.

Exhibit
Number
Description
1.01
Conflict Minerals Report of Steelcase Inc.






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.
STEELCASE INC.
 


By: 
/s/ Lizbeth S. O'Shaughnessy
 
Lizbeth S. O'Shaughnessy
Senior Vice President, Chief Administrative Officer,
General Counsel and Secretary
Date: May 16, 2018






EXHIBIT INDEX

Exhibit
Number
Description
1.01
Conflict Minerals Report of Steelcase Inc.




Exhibit

Exhibit 1.01
STEELCASE INC.
Conflict Minerals Report

For the reporting period from January 1, 2017 to December 31, 2017

Introduction

This Conflict Minerals Report (“Report”) of Steelcase Inc. has been prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period January 1, 2017 to December 31, 2017. As used in this Report and unless otherwise expressly stated or the context otherwise requires, all references to “Steelcase,” “we,” “our,” “Company” and similar references are references to Steelcase Inc. and its consolidated subsidiaries.

Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to implement certain disclosure requirements related to minerals specified in the rule. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (“Conflict Minerals”). Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products for which Conflict Minerals are necessary to the production or functionality of those products (such minerals are referred to herein as “Necessary Conflict Minerals”).

Company Overview

We offer a comprehensive portfolio of architecture, furniture, furnishings and technology products and services which are designed to unlock human promise and support social, economic and environmental sustainability globally.

Conflict Minerals Policy and Supplier Code of Conduct

Our Conflict Minerals Policy states our intent to refrain from purchasing products, components or materials containing any Necessary Conflict Minerals from the Covered Countries that directly or indirectly finance or benefit armed groups and are not otherwise from recycled or scrap sources. The policy also expresses our expectation that our suppliers follow this same practice, establish appropriate due diligence programs and provide us with information, upon our request, regarding the source and chain of custody of any Necessary Conflict Minerals in the products, components or materials they sell to us. In addition, our Supplier Code of Conduct includes a Fair Operating Practices section regarding “Responsible Sourcing of Minerals” which is consistent with our Conflict Minerals Policy. Our policy and our Supplier Code of Conduct are publicly available on our website at www.steelcase.com/discover/steelcase/sustainability/#resources.

Reasonable Country of Origin Inquiry

Pursuant to Rule 13p-1, we conducted a Reasonable Country of Origin Inquiry (“RCOI”). Our RCOI began with an evaluation of our global suppliers who provided materials, components or products that became part of products we manufactured or contracted to be manufactured in 2017 which contained or were likely to contain Necessary Conflict Minerals. This evaluation consisted of examining internal records such as bills of materials or other product specifications and performing a qualitative review of purchasing records and/or information provided by the supplier. Based on our evaluation, we surveyed the suppliers of those materials, components or products which we concluded contained or were likely to contain Necessary Conflict Minerals. The suppliers were asked to report on the presence of any Necessary Conflict Minerals in the goods sold to us. In cases where we knew or confirmed that Necessary Conflict



Minerals were present, we asked the applicable supplier to submit information to us about the country of origin of the Necessary Conflict Minerals.

Due Diligence

Design of Due Diligence

We designed our due diligence measures to conform to the Organisation for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tin, tantalum, tungsten, and gold (collectively, the “OECD Guidance”).

Due Diligence Measures Performed

Pursuant to Rule 13p-1, we undertook due diligence measures on the source and chain of custody of the Necessary Conflict Minerals in our products which we had reason to believe may have originated from the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") and which may not have come from recycled or scrap sources. Following is a summary of the due diligence actions we performed with regard to the reporting period:

1.    Establish strong company management systems

As referenced previously, we have a Conflict Minerals Policy which is shared with our supply chain and publicly available on our website.
We have an established project team from our Global Compliance & Sustainability department which leads the RCOI, due diligence and reporting processes. Our Conflict Minerals Governance Committee provides oversight for the project team and is comprised of senior management from our legal, compliance and internal audit functions.
We are a “downstream company” in our supply chain, meaning we are generally several tiers removed from the smelters and refiners which process the Necessary Conflict Minerals present in some of our products. Accordingly, we rely on communication with and through our immediate suppliers to provide us with information relating to the presence and sourcing of the Necessary Conflict Minerals present in our products.
We intend to maintain our records relating to Conflict Minerals reporting for a minimum of five years after each applicable reporting period, in accordance with the OECD Guidance and our own Records Retention Policy.
Our Supplier Code of Conduct includes language that reinforces our Conflict Minerals Policy, and we have included Conflict Minerals reporting requirements in our purchasing contract templates.
We have implemented Conflict Minerals checkpoints into both our supplier qualification and product development processes to begin engaging new suppliers and suppliers of new materials early in the process.
We have continued to educate our suppliers and employees about Conflict Minerals and the related reporting requirements in each of the regions in which we operate: the Americas, Europe, Middle East and Africa, and Asia Pacific.
We have continued to provide an international integrity helpline to both employees and non-employees for reporting ethics and compliance issues, including those related to Conflict Minerals. Information about contacting the helpline can be found at http://integrity.steelcase.com.


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2.    Identify and assess risks in the supply chain

We surveyed suppliers we either knew or had reason to believe may have provided materials, components or products which may contain Necessary Conflict Minerals, using the due diligence tool created by the Electronic Industry Citizenship Coalition (“EICC”) and the Global e-Sustainability Initiative (“GESI”)’s Responsible Minerals Initiative (“RMI”)’s Conflict Minerals Reporting Template (“CMRT”), which is a survey designed to identify the smelters and refiners that process, and the country of origin of, Conflict Minerals contained in the products supplied by the applicable supplier.
We selected a subset of suppliers among all surveyed suppliers to be targeted for prioritized follow up. We referred to this subset as “prioritized suppliers.” Prioritized suppliers were selected for additional follow up to capture the greatest risk in our supply chain. The criteria used to select prioritized suppliers included: material composition, previously submitted smelter and refiner information, geographic region, spend, type of supplier and quantity of parts purchased.
We followed up with prioritized suppliers that did not respond to our survey request or that we identified as providing incomplete or potentially inaccurate information to seek additional clarification or remediation and to bring them into conformity with our Conflict Minerals Policy and contractual agreements.
We cross-referenced smelters and refiners identified in the CMRTs submitted by our suppliers against the list of facilities that have received a “conformant” designation from the Responsible Minerals Assurance Process ("RMAP") and its cross-recognized programs (e.g. the Responsible Jewellery Council and the London Bullion Market Association, otherwise known as “RJC” and “LBMA” respectfully), whose designations provide country of origin and additional due diligence information on the Conflict Minerals sourced by such facilities.
We continued to encourage the participation of smelters and refiners in the RMAP, through our continued membership and active participation in the RMI and related working groups, and by conducting outreach to those smelters and refiners identified by our supply chain.

3.    Design and implement a strategy to respond to identified risks

The status and findings of our RCOI and due diligence efforts were reported to our Conflict Minerals Governance Committee during monthly updates between the months of September 2017 and May 2018.
We intend to follow a risk mitigation plan that is consistent with our Conflict Minerals Policy. If a smelter or refiner in our supply chain were known to be sourcing from a mine within a Covered Country which directly or indirectly finances or benefits armed groups, we would consider all available options, including, but not limited to, making changes to our sourcing of those items.

4.     Independent third-party audit of smelter or refiner’s due diligence practices

As a downstream company and an active member of the RMI, we support the independent third-party audits of smelters and refiners performed by the RMAP and other cross-recognized programs (e.g. RJC and LBMA) to audit the conformant status of smelters and refiners.

5.     Report annually on supply chain due diligence

We plan to report annually to the SEC by filing a Form SD and Conflict Minerals Report as required by applicable law.


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Results of Due Diligence Measures Performed

Inherent Limitations of Due Diligence Measures

As a downstream company in a complex supply chain, our due diligence measures can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Necessary Conflict Minerals contained in our products. Our due diligence processes rely on obtaining data from our tier one suppliers and those suppliers seeking similar information from their supply chains to identify the original sources of the Necessary Conflict Minerals. We also rely on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information.

Product Description

For the reporting period, we identified the following types of products which we either manufactured or contracted with others to manufacture that contained Necessary Conflict Minerals which may have originated in the Covered Countries but for which we could not confirm the countries of origin of all the Necessary Conflict Minerals contained in such products:

Some of our desking products, wall systems, doors, tiles, panels, lighting, and other office furniture products which contain one or more of the following: electrical components, lighting components and glass panels.

Determination

Based on the information provided by our suppliers, the facilities that may have been used to process the Necessary Conflict Minerals used in our products may include the smelters and refiners listed in Annex I.

Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of all the Necessary Conflict Minerals in the products described above in the “Product Description” section of this report or whether the Necessary Conflict Minerals were from recycled or scrap sources. However, based on the information provided by our suppliers and available from the RMI, the countries of origin of the Necessary Conflict Minerals contained in the products described above may include, but may not be limited to, the countries listed in Annex II, in addition to recycled or scrap sources.

Smelter and Refiner Summary

In response to our survey, our suppliers identified 309 smelter and refiner facilities which may have processed the Necessary Conflict Minerals contained in the materials provided to us. Of those facilities, as of May 8, 2018:

250 have received a “conformant” designation from the RMAP;
8 have not yet received a “conformant” designation but are considered “active” in the RMAP; and,
the remaining facilities are not currently participating in the RMAP

Under the RMAP’s standards, “conformant” means a facility has been audited and found to be conformant with the relevant RMAP protocol, and “active” means a facility that is engaged in the program but has not yet been found to be "conformant."

Each of the facilities which we believe may source Conflict Minerals from the Covered Countries has received a “conformant” designation from the RMAP.

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To our knowledge, none of the Necessary Conflict Minerals contained in the products we manufactured or contracted to be manufactured during the reporting period directly or indirectly financed or benefitted armed groups in the Covered Countries.

Risk Mitigation

We remain committed to familiarizing our supply chain with our compliance process and enhancing our internal systems of controls, and we expect to continue improving upon the steps outlined below. These are the steps we took for our 2017 reporting cycle to mitigate the risk that the Necessary Conflict Minerals contained in the products we manufacture or contract to be manufactured may have benefitted armed groups:

further educated our supply chain and employees about Conflict Minerals reporting requirements;
continued pursuing Conflict Minerals identification during our supplier qualification and product development processes;
continued including our Conflict Minerals clause into purchasing contracts, either upon establishment or during the renewal process;
performed additional material research and further identified where Necessary Conflict Minerals are present in our existing products and likely to be present in future products;
surveyed suppliers and collected responses for the respective reporting period;
prioritized supplier follow up by using criteria which captured the greatest risk and leverage in our supply chain;
continued to encourage our suppliers to obtain current, accurate and complete smelter and refiner information that is specific to the products they sell to us;
compared and validated supplier-identified smelters and refiners to information collected via independent smelter and refiner audit programs such as the RMAP; and,
maintained our membership and active participation in the RMI and related working groups.

Conclusion Statement

We have provided the information in this Report as of the date of filing with the SEC.

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Annex I

Metal
Facility Name
Facility Location
Gold
Abington Reldan Metals, LLC
United States of America
Gold
Advanced Chemical Company
United States of America
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 Corrego do Sitio Mineracao
Brazil
Gold
Argor-Heraeus S.A.
Switzerland
Gold
Asahi Pretec Corp.
Japan
Gold
Asahi Refining Canada Ltd.
Canada
Gold
Asahi Refining USA Inc.
United States of America
Gold
Asaka Riken Co., Ltd.
Japan
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Turkey
Gold
AU Traders and Refiners
South Africa
Gold
Aurubis AG
Germany
Gold
Bangalore Refinery
India
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Philippines
Gold
Boliden AB
Sweden
Gold
C. Hafner GmbH + Co. KG
Germany
Gold
Caridad
Mexico
Gold
CCR Refinery - Glencore Canada Corporation
Canada
Gold
Cendres + Metaux S.A.
Switzerland
Gold
Chimet S.p.A.
Italy
Gold
Chugai Mining
Japan
Gold
Daejin Indus Co., Ltd.
Korea, Republic of
Gold
Daye Non-Ferrous Metals Mining Ltd.
China
Gold
Degussa Sonne / Mond Goldhandel GmbH
Germany
Gold
DODUCO Contacts and Refining GmbH
Germany
Gold
Dowa
Japan
Gold
DSC (Do Sung Corporation)
Korea, Republic of
Gold
Eco-System Recycling Co., Ltd.
Japan
Gold
Elemetal Refining, LLC
United States of America
Gold
Emirates Gold DMCC
United Arab Emirates
Gold
Fidelity Printers and Refiners Ltd.
Zimbabwe
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
India
Gold
Geib Refining Corporation
United States of America
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
China
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
China
Gold
Guangdong Jinding Gold Limited
China
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
China
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
China
Gold
HeeSung Metal Ltd.
Korea, Republic of

6


Metal
Facility Name
Facility Location
Gold
Heimerle + Meule GmbH
Germany
Gold
Heraeus Metals Hong Kong Ltd.
China
Gold
Heraeus Precious Metals GmbH & Co. KG
Germany
Gold
Hunan Chenzhou Mining Co., Ltd.
China
Gold
HwaSeong CJ CO., LTD.
Korea, Republic of
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
Italpreziosi
Italy
Gold
Japan Mint
Japan
Gold
Jiangxi Copper Co., Ltd.
China
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Russian Federation
Gold
JSC Uralelectromed
Russian Federation
Gold
JX Nippon Mining & Metals Co., Ltd.
Japan
Gold
Kaloti Precious Metals
United Arab Emirates
Gold
Kazakhmys Smelting LLC
Kazakhstan
Gold
Kazzinc
Kazakhstan
Gold
Kennecott Utah Copper LLC
United States of America
Gold
KGHM Polska Miedz Spolka Akcyjna
Poland
Gold
Kojima Chemicals Co., Ltd.
Japan
Gold
Korea Zinc Co., Ltd.
Korea, Republic of
Gold
Kyrgyzaltyn JSC
Kyrgyzstan
Gold
Kyshtym Copper-Electrolytic Plant ZAO
Russian Federation
Gold
L'azurde Company For Jewelry
Saudi Arabia
Gold
Lingbao Gold Co., Ltd.
China
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
China
Gold
L'Orfebre S.A.
Andorra
Gold
LS-NIKKO Copper Inc.
Korea, Republic of
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
China
Gold
Marsam Metals
Brazil
Gold
Materion
United States of America
Gold
Matsuda Sangyo Co., Ltd.
Japan
Gold
Metalor Technologies (Hong Kong) Ltd.
China
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 of America
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
Mexico
Gold
Mitsubishi Materials Corporation
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
Japan
Gold
MMTC-PAMP India Pvt., Ltd.
India
Gold
Modeltech Sdn Bhd
Malaysia
Gold
Morris and Watson
New Zealand
Gold
Morris and Watson Gold Coast
Australia

7


Metal
Facility Name
Facility Location
Gold
Moscow Special Alloys Processing Plant
Russian Federation
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
Turkey
Gold
Navoi Mining and Metallurgical Combinat
Uzbekistan
Gold
Nihon Material Co., Ltd.
Japan
Gold
Ogussa Osterreichische 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
OJSC Novosibirsk Refinery
Russian Federation
Gold
PAMP S.A.
Switzerland
Gold
Pease & Curren
United States of America
Gold
Penglai Penggang Gold Industry Co., Ltd.
China
Gold
Planta Recuperadora de Metales SpA
Chile
Gold
Prioksky Plant of Non-Ferrous Metals
Russian Federation
Gold
PT Aneka Tambang (Persero) Tbk
Indonesia
Gold
PX Precinox S.A.
Switzerland
Gold
Rand Refinery (Pty) Ltd.
South Africa
Gold
Refinery of Seemine Gold Co., Ltd.
China
Gold
Remondis Argentia B.V.
Netherlands
Gold
Republic Metals Corporation
United States of America
Gold
Royal Canadian Mint
Canada
Gold
SAAMP
France
Gold
Sabin Metal Corp.
United States of America
Gold
Safimet S.p.A
Italy
Gold
SAFINA A.S.
Czech Republic
Gold
Sai Refinery
India
Gold
Samduck Precious Metals
Korea, Republic of
Gold
Samwon Metals Corp.
Korea, Republic of
Gold
SAXONIA Edelmetalle GmbH
Germany
Gold
SEMPSA Joyeria Plateria S.A.
Spain
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
China
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
China
Gold
Sichuan Tianze Precious Metals Co., Ltd.
China
Gold
Singway Technology Co., Ltd.
Taiwan, Province of China
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
Russian Federation
Gold
Solar Applied Materials Technology Corp.
Taiwan, Province of China
Gold
State Research Institute Center for Physical Sciences and Technology
Lithuania
Gold
Sudan Gold Refinery
Sudan
Gold
Sumitomo Metal Mining Co., Ltd.
Japan
Gold
SungEel HiMetal Co., Ltd.
Korea, Republic of
Gold
T.C.A S.p.A
Italy
Gold
Tanaka Kikinzoku Kogyo K.K.
Japan
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
China
Gold
Tokuriki Honten Co., Ltd.
Japan

8


Metal
Facility Name
Facility Location
Gold
Tongling Nonferrous Metals Group Co., Ltd.
China
Gold
Tony Goetz NV
Belgium
Gold
TOO Tau-Ken-Altyn
Kazakhstan
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 of America
Gold
Universal Precious Metals Refining Zambia
Zambia
Gold
Valcambi S.A.
Switzerland
Gold
Western Australian Mint (T/a The Perth Mint)
Australia
Gold
WIELAND Edelmetalle GmbH
Germany
Gold
Yamakin Co., Ltd.
Japan
Gold
Yokohama Metal Co., Ltd.
Japan
Gold
Yunnan Copper Industry Co., Ltd.
China
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
China
Tantalum
Asaka Riken Co., Ltd.
Japan
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
China
Tantalum
D Block Metals, LLC
United States of America
Tantalum
Exotech Inc.
United States of America
Tantalum
F&X Electro-Materials Ltd.
China
Tantalum
FIR Metals & Resource Ltd.
China
Tantalum
Global Advanced Metals Aizu
Japan
Tantalum
Global Advanced Metals Boyertown
United States of America
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
China
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
China
Tantalum
H.C. Starck Co., Ltd.
Thailand
Tantalum
H.C. Starck Hermsdorf GmbH
Germany
Tantalum
H.C. Starck Inc.
United States of America
Tantalum
H.C. Starck Ltd.
Japan
Tantalum
H.C. Starck Smelting GmbH & Co. KG
Germany
Tantalum
H.C. Starck Tantalum and Niobium GmbH
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
China
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
China
Tantalum
Jiangxi Tuohong New Raw Material
China
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
China
Tantalum
Jiujiang Tanbre Co., Ltd.
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
China
Tantalum
KEMET Blue Metals
Mexico
Tantalum
KEMET Blue Powder
United States of America
Tantalum
LSM Brasil S.A.
Brazil
Tantalum
Metallurgical Products India Pvt., Ltd.
India
Tantalum
Mineracao Taboca S.A.
Brazil
Tantalum
Mitsui Mining and Smelting Co., Ltd.
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
China

9


Metal
Facility Name
Facility Location
Tantalum
NPM Silmet AS
Estonia
Tantalum
Power Resources Ltd.
Macedonia, The Former Yugoslav Republic Of
Tantalum
QuantumClean
United States of America
Tantalum
Resind Industria e Comercio Ltda.
Brazil
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
China
Tantalum
Solikamsk Magnesium Works OAO
Russian Federation
Tantalum
Taki Chemical Co., Ltd.
Japan
Tantalum
Telex Metals
United States of America
Tantalum
Ulba Metallurgical Plant JSC
Kazakhstan
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
China
Tin
Alpha
United States of America
Tin
An Vinh Joint Stock Mineral Processing Company
Vietnam
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
China
Tin
China Tin Group Co., Ltd.
China
Tin
CNMC (Guangxi) PGMA Co., Ltd.
China
Tin
CV Ayi Jaya
Indonesia
Tin
CV Dua Sekawan
Indonesia
Tin
CV Gita Pesona
Indonesia
Tin
CV United Smelting
Indonesia
Tin
CV Venus Inti Perkasa
Indonesia
Tin
Dowa
Japan
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Vietnam
Tin
EM Vinto
Bolivia (Plurinational State of)
Tin
Estanho de Rondonia S.A.
Brazil
Tin
Fenix Metals
Poland
Tin
Gejiu Fengming Metallurgy Chemical Plant
China
Tin
Gejiu Jinye Mineral Company
China
Tin
Gejiu Kai Meng Industry and Trade LLC
China
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
China
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
China
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
China
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
China
Tin
HuiChang Hill Tin Industry Co., Ltd.
China
Tin
Huichang Jinshunda Tin Co., Ltd.
China
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
China
Tin
Jiangxi New Nanshan Technology Ltd.
China
Tin
Magnu's Minerais Metais e Ligas Ltda.
Brazil
Tin
Malaysia Smelting Corporation (MSC)
Malaysia
Tin
Melt Metais e Ligas S.A.
Brazil
Tin
Metallic Resources, Inc.
United States of America
Tin
Metallo Belgium N.V.
Belgium

10


Metal
Facility Name
Facility Location
Tin
Metallo Spain S.L.U.
Spain
Tin
Mineracao Taboca S.A.
Brazil
Tin
Minsur
Peru
Tin
Mitsubishi Materials Corporation
Japan
Tin
Modeltech Sdn Bhd
Malaysia
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Vietnam
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
Philippines
Tin
Operaciones Metalurgical S.A.
Bolivia (Plurinational State of)
Tin
PT Aries Kencana Sejahtera
Indonesia
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 Serumpun
Indonesia
Tin
PT Bangka Tin Industry
Indonesia
Tin
PT Belitung Industri Sejahtera
Indonesia
Tin
PT Bukit Timah
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 Lautan Harmonis Sejahtera
Indonesia
Tin
PT Menara Cipta Mulia
Indonesia
Tin
PT Mitra Stania Prima
Indonesia
Tin
PT Panca Mega Persada
Indonesia
Tin
PT Premium Tin Indonesia
Indonesia
Tin
PT Prima Timah Utama
Indonesia
Tin
PT Rajehan Ariq
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 Kundur
Indonesia
Tin
PT Timah (Persero) Tbk Mentok
Indonesia
Tin
PT Tinindo Inter Nusa
Indonesia
Tin
PT Tommy Utama
Indonesia
Tin
Resind Industria e Comercio Ltda.
Brazil
Tin
Rui Da Hung
Taiwan, Province of China
Tin
Soft Metais Ltda.
Brazil
Tin
Super Ligas
Brazil
Tin
Thaisarco
Thailand

11


Metal
Facility Name
Facility Location
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Vietnam
Tin
White Solder Metalurgia e Mineracao Ltda.
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
China
Tin
Yunnan Tin Company Limited
China
Tungsten
A.L.M.T. TUNGSTEN Corp.
Japan
Tungsten
ACL Metais Eireli
Brazil
Tungsten
Asia Tungsten Products Vietnam Ltd.
Vietnam
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
China
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
China
Tungsten
Ganzhou Haichuang 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
Ganzhou Yatai Tungsten Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp.
United States of America
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
China
Tungsten
H.C. Starck Smelting GmbH & Co. KG
Germany
Tungsten
H.C. Starck Tungsten GmbH
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
Hunan Litian Tungsten Industry 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 Dayu Longxintai Tungsten Co., Ltd.
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
China
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
China
Tungsten
Kennametal Fallon
United States of America
Tungsten
Kennametal Huntsville
United States of America
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
China
Tungsten
Moliren Ltd.
Russian Federation
Tungsten
Niagara Refining LLC
United States of America
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Vietnam
Tungsten
Philippine Chuangxin 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

12


Metal
Facility Name
Facility Location
Tungsten
Wolfram Bergbau und Hutten AG
Austria
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


13


Annex II
Argentina
Laos
Australia
Madagascar
Austria
Malaysia
Benin
Mali
Bolivia (Plurinational State of)
Mexico
Brazil
Mongolia
Burkina Faso
Mozambique
Burundi
Myanmar
Cambodia
Namibia
Canada
Nicaragua
Chile
Nigeria
China
Panama
Colombia
Peru
Congo, Democratic Republic of the
Portugal
Ecuador
Russian Federation
Eritrea
Rwanda
Ethiopia
Senegal
France
Sierra Leone
Germany
South Africa
Ghana
Spain
Guatemala
Thailand
Guinea
Togo
Guyana
Uganda
Honduras
United Kingdom of Great Britain and Northern Ireland
India
United States of America
Indonesia
Uzbekistan
Japan
Vietnam
Kazakhstan
Zimbabwe






14