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

FORM SD

SPECIALIZED DISCLOSURE REPORT


STMicroelectronics N.V.
(Exact name of the registrant as specified in its charter)


The Netherlands
1-13546
26-0047957
(State or other jurisdiction of
incorporation or organization)
(Commission
File Number)
(IRS Employer
Identification No.)


WTC Schiphol Airport
Schiphol Boulevard 265
1118 BH Schiphol
The Netherlands
N/A
(Address of principal executive offices)
(Zip code)

 
Steven Rose
+1 (972) 466-6000
 
(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:

_√__
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018


Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02   Conflict Minerals Disclosure and Report; Exhibit

The Company has filed as an exhibit to this Form SD a Conflict Minerals Report.  This Form SD and Conflict Minerals Report are available on our website at the following address:  http://investors.st.com.

Section 2 - Exhibits

Item 2.01  Exhibits

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.




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.

 
STMicroelectronics N.V. 
(Registrant)
 
       
       
By:  /s/ Jean-Marc Chery Date: May 30, 2019
  Name: Jean-Marc Chery
 
  Title:
President and Chief Executive Officer and Sole
Member of our Managing Board
       
 
 

Exhibit 1.01

Conflict Minerals Report of STMicroelectronics N.V.
in accordance with Rule 13p-1 under the Securities Exchange Act of 1934

This Conflict Minerals Report (the “Report”) for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 and guidance in relation thereto promulgated by the Securities and Exchange Commission (the “SEC”) (collectively, the “Rule”).

In this Report, references to “ST”, “we”, “us” and “Company” are to STMicroelectronics N.V. together with its consolidated subsidiaries.  Furthermore, the SEC defines “conflict minerals” as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten; we therefore ascribe the same meaning to the term “conflict minerals” throughout this Report. The content of any website referenced in this Report is included for general information only and is not incorporated by reference in this Report.

In accordance with the Rule, this Report is available on our website at the following address:  http://investors.st.com.

1.
Company Overview

Business and products

We are a global leader in the semiconductor market, serving a broad range of customers across different areas.  Our products are used in a wide variety of applications, which address four end markets: automotive, industrial, personal electronics and communications equipment, computers and peripherals.

Our main categories of products1 are as follows:


·
Automotive and Discrete Group (ADG), comprised of dedicated automotive ICs (both digital and analog), and discrete and power transistor products for all market segments.


·
Analog, MEMS and Sensors Group (AMS), comprised of low-power high-end analog ICs (both custom and general purpose) for all markets, smart power products for Industrial, Computer and personal electronics markets, Touch Screen Controllers, Low Power Connectivity solutions (both wireline and wireless) for IoT, power conversion products, metering solutions for Smart Grid, specialized imaging sensors and modules, and all MEMS products for sensors or Actuators.


·
Microcontrollers and Digital ICs Group (MDG), comprised of general purpose and secure microcontrollers, EEPROM memories, Digital ASICs, Aerospace & Defense products including components for microwave and millimeter wave.

A more detailed discussion of our product categories and the products relating to each category is contained in our Annual Report on Form 20-F in relation to the 2018 calendar year which was filed with the SEC on February 28, 2019.


1 We derive less than 0.09% of our total annual revenue from sales of promotional evaluation and development boards assembled by third party subcontractors, which represent prototypical system-level applications that include our integrated circuit products as well as components originating from third parties. These boards are useful to demonstrate the features and functionality of our semiconductor products and assist our customers in transitioning from initial prototype designs to final production releases. References herein to our “products” are to our integrated circuit products (excluding such boards) representing 99.91% or more of our total annual revenue.

1

Manufacturing processes

The manufacture of semiconductor products requires, among other things, the mastery of the properties of conductivity, isolation and/or amplification. The manufacturing of an integrated circuit can be divided into two phases. The first, wafer fabrication, is the extremely sophisticated and intricate process of manufacturing the silicon chip. The second, assembly, is the highly precise and automated process of packaging the die. Those two phases are commonly known respectively as “Front-End” and “Back-End”.

The manufacturing process of semiconductor products requires various materials, gases and chemicals. We have identified tin, tantalum, tungsten and gold (collectively, “3TG”) as being among the materials necessary to the functionality or production of certain of our products manufactured during the 2018 calendar year.

Supply chain

We are not engaged in the mining and trade of minerals, nor in any refining or smelting activities. We purchase materials, commodities, chemicals and gases which potentially contain a conflict mineral as part of their composition. In general, we do not conduct business directly with smelters and refiners.

Because of our large size, the complexity of our products, and the depth, breadth, and constant evolution of our global supply chain, it is difficult and resource-intensive to identify actors upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives as described in section 2 below.

Conflict minerals policy

ST began to address the conflict minerals issue as early as 2007 by requiring our tantalum suppliers to confirm they were not sourcing metals from conflict areas. We are a member of the Responsible Business Alliance (the “RBA”), have adopted the RBA’s Code of Conduct and participate in the Responsible Minerals Initiative (the “RMI”), which is a program run jointly by the RBA and the Global e-Sustainability Initiative (the “GeSI”). We require all our suppliers and subcontractors to provide evidence that they are not sourcing 3TG through any channels that fund armed groups in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the “Covered Countries”).

Additional information on our Policy Statement on Conflict Minerals and Responsible Minerals Sourcing (our “Policy Statement”) is available at: www.st.com/conflict-free_minerals. In addition, the respective websites of the RBA, the RMI and the GeSI are available at http://www.responsiblebusiness.org/, http://www.responsiblemineralsinitiative.org/ and http://gesi.org/.

2.
Due Diligence Process

Design of due diligence

Our due diligence measures have been designed to conform, in all material respects, to the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and the related Supplements for tin, tantalum, tungsten and gold, as well as related RBA recommendations. The OECD is an international organization that is endorsed by the United Nations and currently offers the only recognized framework available for such use.

Management system

In addition to implementing our Policy Statement as outlined above, evidencing our top management’s commitment to the issue, we have implemented our conflict minerals management system in alignment with the OECD Guidance. We have established roles and duties within the Company’s relevant internal organizations involved in the program. The roles and duties established for several key internal organizations are outlined below.

2

Our Corporate Quality and Social Responsibility organizations are responsible for the following:


·
proactively working with our customers to define the scope and form of our conflict minerals disclosures;

·
defining the strategy and annual objectives related to the implementation of the conflict minerals programs within the Company and the coordination thereof with the appropriate internal organizations responsible for sourcing and purchasing materials and subcontracted services and products (including our Global Procurement Organization);

·
establishing the appropriate internal and external communication content on these programs through the relevant and necessary media and according to our internal processes, including, without limitation, our Policy Statement and dedicated content in our annual Sustainability Report, both of which are made available on our website; and

·
reviewing and updating our conflict minerals management procedures on a regular basis.

Our Global Procurement Organization helps to implement our conflict minerals program by supporting the communication of Company requirements to our suppliers and monitoring our suppliers’ engagement and progress in relation to our conflict minerals program.

Our Global Outsourcing Business Management group helps to implement our conflict minerals program by supporting the communication of Company requirements to Back-End subcontractors and monitoring our subcontractors’ engagement and progress in relation to our conflict minerals program.

Our Wafer Foundry group supports our conflict minerals program by communicating our requirements to wafer foundries and by monitoring our suppliers’ engagement and progress in relation to our conflict minerals program.

In addition, our conflict minerals program is included as part of our sustainability and quality strategies and is highlighted as a key objective for each of our relevant internal organizations, in addition to the key internal groups discussed above, as applicable within the scope of their respective activities. A working group with representatives from the principal organizations involved regularly reviews the progress of our conflict minerals program implementation. Based on need as appropriate for the situation, such working group implements the appropriate risk mitigation measures.

Industry-wide initiatives

As we are a participating member of the RBA, we employ due diligence methodologies defined by a joint working group comprised of RBA and GeSI representatives. Tools available for participants in the RBA include a template known as the Conflict Minerals Reporting Template (the “CMRT”). The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free sourcing policy, engagement with its direct suppliers, and a listing of the smelters a company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in a company’s products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are also available. The CMRT is used by many companies in their due diligence processes related to conflict minerals.

In addition, the RBA and GeSI developed in 2010 the RMI, which is a voluntary initiative in which an independent third party audits smelter procurement and processing activities and determines if the smelter has provided sufficient documentation to demonstrate with reasonable confidence that the minerals it processed originated from conflict-free sources. In 2012, the RMI, the London Bullion Market Association (“LBMA”) and Responsible Jewelry Council (“RJC”) announced their mutual cross-recognition of gold refiner audits. All three programs focus on independent third party audits of refiners’ due diligence in conformity with the OECD Guidance, which recognizes refiners as a key “choke point” in the gold supply chain.

We, along with other leading participants in the electronics industry, rely on the RMI’s Responsible Minerals Assurance Process (“RMAP”) or an equivalent industry-wide program for audits of smelters and/or refiners. Further details on this program are available on the RMI’s website at the address referenced above.

3

Methodology

The Company undertook due diligence on the source and chain of custody of its necessary conflict minerals. Our due diligence measures consisted of:


·
conducting a supply-chain survey with direct suppliers and subcontractors using the CMRT to identify the smelters and refiners which contribute refined conflict minerals to our products; and

·
comparing the smelters and refiners identified by direct suppliers and subcontractors via the supply-chain survey against the list of smelter facilities which have received a “conformant” validation by the RMAP.

We conducted an inquiry, using the CMRT, with all of the suppliers and subcontractors which we identified within our supply chain. All such suppliers and subcontractors responded to our due diligence inquiry.

We reviewed the responses received against criteria developed to determine which responses required further engagement with our suppliers. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the CMRT.

CMRT inquiry responses

We rely on the good faith efforts of our suppliers and subcontractors to provide us with reasonable representations of the processing facilities used to supply the necessary conflict minerals in our products. As a result of our inquiry via the CMRT, our suppliers and subcontractors reported to us a total of 253 smelters as sources of 3TG during the 2018 calendar year, two of which we had discontinued as sources as of December 31, 2018, as reflected in the table below. The table below indicates the percentage of reported smelters sourcing each metal which were RMAP conformant as of December 31, 2018.  Information relating to RMAP conformant smelters is extracted from the RBA database. The information presented in the below table represents the state of affairs as of December 31, 2018, but should not be interpreted as necessarily having applied consistently throughout the entire 2018 calendar year. Although we have received, and regularly continue to receive, updates to the RMAP conformance information presented in this table, we have presented it as of December 31, 2018.


Metal
Gold
Tantalum
Tin
Tungsten
Total number of smelters declared during 2018 calendar year which remained as sources of 3TG as of December 31, 2018
99
39
73
40
Percentage of above smelters which were RMAP conformant as of December 31, 2018
100%
100%
100%
100%

Analysis of our products in light of due diligence results

From the figures in the above table, we can conclude that 100% of the smelters declared to us by our suppliers and subcontractors which remained as our sources of 3TG as of December 31, 2018 were validated by the RMAP as being conformant as of December 31, 2018. We have included in Table 1 on Appendix I to this Report a list of these processing facilities as well as their identification number as used by the RMAP.

Two of the 253 smelters declared to us by our suppliers and subcontractors were RMAP conformant at some point during calendar year 2018 but no longer qualified as such as of December 31, 2018 and were therefore removed from our authorized sources of 3TG as of such date. We are not in a position to know whether a certain 3TG material which was used in the manufacture of a product during 2018 originated with one of such smelters before or after it lost its status as RMAP conformant. We have identified these smelters and the month during which we were notified of their removal from the RMAP conformance list in Table 2 on Appendix I to this Report.

3.
Further Risk Mitigation

Discussion is included below as to certain efforts we are making, and will continue to make, to further mitigate the risk that our necessary conflict minerals do not benefit armed groups, including steps we are taking to improve our due diligence.

4

Mitigating the effects of multi-sourcing

Certain of the challenges we encountered in our due diligence were a result of multi-sourcing. We conduct business with a large number of suppliers in obtaining the materials required for our products, in an effort to ensure continuity in our supply chain. Those suppliers, in turn, work with a large number of smelters and refiners to source materials (including conflict minerals) which ultimately are contained in our products. As a consequence, each of our material parts is linked to several suppliers and, consequently, to several smelters, each with a potentially differing conflict mineral status.

Our suppliers also service other semiconductor manufacturers and other electronics industry participants whose supply needs may or may not coincide with ours. Accordingly, the total number of smelters from which our suppliers source materials may exceed the number of such smelters whose conflict minerals are ultimately contained in our products.

Currently, the representations included within the responses to our CMRT inquiries which we receive from our suppliers and subcontractors cover all smelters providing materials to them, and do not necessarily correlate solely to the smelters whose minerals are contained only in our products (and not in those of other customers of such suppliers and subcontractors without also being contained in our products). This adds further complexity to linking the conflict minerals used in a particular product category to a specific source of origin, as the list of all potential smelters provided by our suppliers may be broader than the list of only those smelters from which our suppliers source conflict minerals for use in our product categories (and may include smelters sourcing conflict minerals for end use by other customers of such suppliers and not us).

A result of this complexity is that we are forced to include all smelters providing materials to our suppliers and subcontractors when performing our due diligence on the origin of the conflict minerals contained in our products, as our suppliers and subcontractors do not always provide us with a list that excludes the smelters whose conflict minerals are not contained in our products.

One method in which we expect to improve our due diligence is to continue to work with our suppliers and subcontractors with a view to obtaining certifications which are better tailored only to our end products, as opposed to blanket company-wide certifications from each supplier or subcontractor. For example, the CMRT contains a reporting category in which reporting parties can more specifically link a particular smelter to a particular product, which we will encourage our suppliers and subcontractors to complete. During the 2018 calendar year, we made progress with certain of our suppliers in obtaining more specific disclosures which are more closely aligned with our actual sourcing of materials. As a result of this effort, we may be able to eliminate in the future certain smelters from the list of potential smelters from which the conflict minerals contained in our products may originate. As referenced above, during 2018 we discontinued sourcing of materials from two gold smelters in a continuing effort to depart from non-RMAP conformant smelters within our supply chain. Such two smelters are identified in Table 2 of Appendix 1 to this Report.

Additional initiatives

We do not directly conduct business with most of the smelters from which the conflict minerals in our products originate.  We have, however, conducted our own investigative research with respect to certain smelters, which is aimed at supplementing information available to us through the RMAP. We also have maintained direct contact with certain smelters which previously did not participate in the RMAP conformant smelters program, and we have succeeded in influencing them to seek full RMAP conformant smelters validation. We expect our continuing efforts to focus on increasing and/or maintaining our suppliers’ and subcontractors’ compliance with the RMAP conformant smelters program as it applies to the smelters and refiners from which such suppliers and subcontractors source conflict minerals which may ultimately be contained in our products.

A significant portion of our supply chain is not required to file reports with the SEC under Sections 13(a) or 14(d) of the Securities Exchange Act of 1934, and is therefore not concerned by reporting obligations pursuant to the Rule. Accordingly, the influence that we are able to exert on our supply chain is due in large part to market forces created as a result of a cumulative effort by us and other participants in the electronics industry to ensure compliance with the RMAP conformant smelters program by their lower tier providers. In general, we intend to continue to request that our suppliers and subcontractors not source materials for us from any smelters which have not been validated by the RMAP conformant smelters program (and to discontinue sourcing from any smelters which fail to maintain their RMAP conformant smelters validation status).

5

Cautionary Note Regarding Forward‑Looking Statements

Some of the statements contained in this Report that are not historical facts are statements of future expectations and other forward-looking statements (within the meaning of Section 27A of the Securities Act of 1933 or Section 21E of the Securities Exchange Act of 1934, each as amended) that are based on management’s current views and assumptions, and are conditioned upon and also involve known and unknown risks and uncertainties that could cause actual results, performance or events to differ materially and adversely from those anticipated by such forward-looking statements. Certain forward-looking statements can be identified by the use of forward-looking terminology, such as “believes”, “expects”, “may”, “are expected to”, “should”, “would be”, “seeks” or “anticipates” or similar expressions or the negative thereof or other variations thereof or comparable terminology, or by discussions of strategy, plans or intentions. Should one or more of these risks or uncertainties materialize, or should underlying assumptions prove incorrect, actual results may vary materially from those described in this Report as anticipated, believed or expected. We do not intend, and do not assume any obligation, to update any information or forward-looking statements set forth in this Report to reflect subsequent events or circumstances.

6



Appendix I

Lists of Processing Facilities


Table 1: Processing facilities reported in our supply chain in relation to calendar year 2018 which were validated by the RMAP conformant smelters program as of December 31, 2018

Smelter Identification
Metal
Smelter Name
Gold
CID000015
Advanced Chemical Company
Gold
CID000019
Aida Chemical Industries Co., Ltd.
Gold
CID002560
Al Etihad Gold LLC
Gold
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
Gold
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
Gold
CID000058
AngloGold Ashanti Mineração Ltda
Gold
CID000077
Argor-Heraeus S.A.
Gold
CID000082
Asahi Pretec Corp.
Gold
CID000924
Asahi Refining Canada Ltd.
Gold
CID000920
Asahi Refining USA Inc.
Gold
CID000090
Asaka Riken Co., Ltd.
Gold
CID002850
AU Traders and Refiners
Gold
CID000113
Aurubis AG
Gold
CID000128
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold
CID000157
Boliden AB
Gold
CID000176
C. Hafner GmbH + Co. KG
Gold
CID000185
CCR Refinery - Glencore Canada Corporation
Gold
CID000189
Cendres + Metaux S.A.
Gold
CID000233
Chimet S.p.A.
Gold
CID000328
Daejin Indus Co., Ltd.
Gold
CID000362
DODUCO Contacts and Refining GmbH
Gold
CID000401
Dowa
Gold
CID000359
DSC (Do Sung Corporation)
Gold
CID000425
Eco-System Recycling Co., Ltd.
Gold
CID002561
Emirates Gold DMCC
Gold
CID002459
Geib Refining Corporation
Gold
CID002243
Gold Refinery of Zijin Mining Group Co., Ltd.
Gold
CID000689
HeeSung Metal Ltd.
Gold
CID000694
Heimerle + Meule GmbH
Gold
CID000707
Heraeus Metals Hong Kong Ltd.
Gold
CID000711
Heraeus Precious Metals GmbH & Co. KG
Gold
CID000801
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold
CID000807
Ishifuku Metal Industry Co., Ltd.
Gold
CID000814
Istanbul Gold Refinery
Gold
CID002765
Italpreziosi
Gold
CID000823
Japan Mint
Gold
CID000855
Jiangxi Copper Co., Ltd.
Gold
CID000929
JSC Uralelectromed
Gold
CID000937
JX Nippon Mining & Metals Co., Ltd.
Gold
CID000957
Kazzinc
Gold
CID000969
Kennecott Utah Copper LLC
Gold
CID000981
Kojima Chemicals Co., Ltd.
Gold
CID002605
Korea Zinc Co., Ltd.
Gold
CID001029
Kyrgyzaltyn JSC


7


Gold
CID001078
LS-NIKKO Copper Inc.
Gold
CID002606
Marsam Metals
Gold
CID001113
Materion
Gold
CID001119
Matsuda Sangyo Co., Ltd.
Gold
CID001149
Metalor Technologies (Hong Kong) Ltd.
Gold
CID001152
Metalor Technologies (Singapore) Pte., Ltd.
Gold
CID001147
Metalor Technologies (Suzhou) Ltd.
Gold
CID001153
Metalor Technologies S.A.
Gold
CID001157
Metalor USA Refining Corporation
Gold
CID001161
Metalurgica Met-Mex Penoles S.A. De C.V.
Gold
CID001188
Mitsubishi Materials Corporation
Gold
CID001193
Mitsui Mining and Smelting Co., Ltd.
Gold
CID002509
MMTC-PAMP India Pvt., Ltd.
Gold
CID001204
Moscow Special Alloys Processing Plant
Gold
CID001220
Nadir Metal Rafineri San. Ve Tic. A.S.
Gold
CID001259
Nihon Material Co., Ltd.
Gold
CID002779
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
Gold
CID001325
Ohura Precious Metal Industry Co., Ltd.
Gold
CID001326
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
Gold
CID000493
OJSC Novosibirsk Refinery
Gold
CID001352
PAMP S.A.
Gold
CID002919
Planta Recuperadora de Metales SpA
Gold
CID001386
Prioksky Plant of Non-Ferrous Metals
Gold
CID001397
PT Aneka Tambang (Persero) Tbk
Gold
CID001498
PX Precinox S.A.
Gold
CID001512
Rand Refinery (Pty) Ltd.
Gold
CID002510
Republic Metals Corporation
Gold
CID001534
Royal Canadian Mint
Gold
CID002761
SAAMP
Gold
CID002973
Safimet S.p.A
Gold
CID001555
Samduck Precious Metals
Gold
CID002777
SAXONIA Edelmetalle GmbH
Gold
CID001585
SEMPSA Joyeria Plateria S.A.
Gold
CID001622
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold
CID001736
Sichuan Tianze Precious Metals Co., Ltd.
Gold
CID002516
Singway Technology Co., Ltd.
Gold
CID001756
SOE Shyolkovsky Factory of Secondary Precious Metals
Gold
CID001761
Solar Applied Materials Technology Corp.
Gold
CID001798
Sumitomo Metal Mining Co., Ltd.
Gold
CID002918
SungEel HiMetal Co., Ltd.
Gold
CID002580
T.C.A S.p.A
Gold
CID001875
Tanaka Kikinzoku Kogyo K.K.
Gold
CID001916
The Refinery of Shandong Gold Mining Co., Ltd.
Gold
CID001938
Tokuriki Honten Co., Ltd.
Gold
CID001955
Torecom
Gold
CID001977
Umicore Brasil Ltda.
Gold
CID002314
Umicore Precious Metals Thailand
Gold
CID001980
Umicore S.A. Business Unit Precious Metals Refining
Gold
CID001993
United Precious Metal Refining, Inc.
Gold
CID002003
Valcambi S.A.
Gold
CID002030
Western Australian Mint (T/a The Perth Mint)
Gold
CID002778
WIELAND Edelmetalle GmbH
Gold
CID002100
Yamakin Co., Ltd.
Gold
CID002129
Yokohama Metal Co., Ltd.
Gold
CID002224
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum
CID000092
Asaka Riken Co., Ltd.


8


Tantalum
CID000211
Changsha South Tantalum Niobium Co., Ltd.
Tantalum
CID002504
D Block Metals, LLC
Tantalum
CID000456
Exotech Inc.
Tantalum
CID000460
F&X Electro-Materials Ltd.
Tantalum
CID002505
FIR Metals & Resource Ltd.
Tantalum
CID002558
Global Advanced Metals Aizu
Tantalum
CID002557
Global Advanced Metals Boyertown
Tantalum
CID000291
Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum
CID000616
Guangdong Zhiyuan New Material Co., Ltd.
Tantalum
CID002544
H.C. Starck Co., Ltd.
Tantalum
CID002547
H.C. Starck Hermsdorf GmbH
Tantalum
CID002548
H.C. Starck Inc.
Tantalum
CID002549
H.C. Starck Ltd.
Tantalum
CID002550
H.C. Starck Smelting GmbH & Co. KG
Tantalum
CID002545
H.C. Starck Tantalum and Niobium GmbH
Tantalum
CID002492
Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum
CID002512
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum
CID002842
Jiangxi Tuohong New Raw Material
Tantalum
CID003191
Jiujiang Janny New Material Co., Ltd.
Tantalum
CID000914
JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum
CID000917
Jiujiang Tanbre Co., Ltd.
Tantalum
CID002506
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum
CID002539
KEMET Blue Metals
Tantalum
CID002568
KEMET Blue Powder
Tantalum
CID001076
LSM Brasil S.A.
Tantalum
CID001163
Metallurgical Products India Pvt., Ltd.
Tantalum
CID001175
Mineracao Taboca S.A.
Tantalum
CID001192
Mitsui Mining and Smelting Co., Ltd.
Tantalum
CID001277
Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum
CID001200
NPM Silmet AS
Tantalum
CID001508
QuantumClean
Tantalum
CID002707
Resind Industria e Comercio Ltda.
Tantalum
CID001522
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tantalum
CID001769
Solikamsk Magnesium Works OAO
Tantalum
CID001869
Taki Chemical Co., Ltd.
Tantalum
CID001891
Telex Metals
Tantalum
CID001969
Ulba Metallurgical Plant JSC
Tantalum
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
Tin
CID000292
Alpha
Tin
CID000228
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin
CID003190
Chifeng Dajingzi Tin Industry Co., Ltd.
Tin
CID001070
China Tin Group Co., Ltd.
Tin
CID002570
CV Ayi Jaya
Tin
CID002592
CV Dua Sekawan
Tin
CID000306
CV Gita Pesona
Tin
CID002593
CV Tiga Sekawan
Tin
CID000315
CV United Smelting
Tin
CID002455
CV Venus Inti Perkasa
Tin
CID000402
Dowa
Tin
CID000438
EM Vinto
Tin
CID000468
Fenix Metals
Tin
CID002848
Gejiu Fengming Metallurgy Chemical Plant
Tin
CID002859
Gejiu Jinye Mineral Company
Tin
CID000942
Gejiu Kai Meng Industry and Trade LLC
Tin
CID000538
Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin
CID001908
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.


9


Tin
CID003116
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
Tin
CID002849
Guanyang Guida Nonferrous Metal Smelting Plant
Tin
CID002844
HuiChang Hill Tin Industry Co., Ltd.
Tin
CID000760
Huichang Jinshunda Tin Co., Ltd.
Tin
CID000244
Jiangxi Ketai Advanced Material Co., Ltd.
Tin
CID001231
Jiangxi New Nanshan Technology Ltd.
Tin
CID002468
Magnu's Minerais Metais e Ligas Ltda.
Tin
CID001105
Malaysia Smelting Corporation (MSC)
Tin
CID002500
Melt Metais e Ligas S.A.
Tin
CID001142
Metallic Resources, Inc.
Tin
CID002773
Metallo Belgium N.V.
Tin
CID002774
Metallo Spain S.L.U.
Tin
CID001173
Mineracao Taboca S.A.
Tin
CID001182
Minsur
Tin
CID001191
Mitsubishi Materials Corporation
Tin
CID002858
Modeltech Sdn Bhd
Tin
CID001314
O.M. Manufacturing (Thailand) Co., Ltd.
Tin
CID002517
O.M. Manufacturing Philippines, Inc.
Tin
CID001337
Operaciones Metalurgical S.A.
Tin
CID000309
PT Aries Kencana Sejahtera
Tin
CID001399
PT Artha Cipta Langgeng
Tin
CID002503
PT ATD Makmur Mandiri Jaya
Tin
CID001402
PT Babel Inti Perkasa
Tin
CID002776
PT Bangka Prima Tin
Tin
CID003205
PT Bangka Serumpun
Tin
CID001419
PT Bangka Tin Industry
Tin
CID001421
PT Belitung Industri Sejahtera
Tin
CID001428
PT Bukit Timah
Tin
CID001434
PT DS Jaya Abadi
Tin
CID001438
PT Eunindo Usaha Mandiri
Tin
CID002530
PT Inti Stania Prima
Tin
CID001448
PT Karimun Mining
Tin
CID002829
PT Kijang Jaya Mandiri
Tin
CID002870
PT Lautan Harmonis Sejahtera
Tin
CID002835
PT Menara Cipta Mulia
Tin
CID001453
PT Mitra Stania Prima
Tin
CID001457
PT Panca Mega Persada
Tin
CID000313
PT Premium Tin Indonesia
Tin
CID001458
PT Prima Timah Utama
Tin
CID001460
PT Refined Bangka Tin
Tin
CID001463
PT Sariwiguna Binasentosa
Tin
CID001468
PT Stanindo Inti Perkasa
Tin
CID002816
PT Sukses Inti Makmur
Tin
CID001471
PT Sumber Jaya Indah
Tin
CID001477
PT Timah (Persero) Tbk Kundur
Tin
CID001482
PT Timah (Persero) Tbk Mentok
Tin
CID001490
PT Tinindo Inter Nusa
Tin
CID001493
PT Tommy Utama
Tin
CID002706
Resind Industria e Comercio Ltda.
Tin
CID001539
Rui Da Hung
Tin
CID001758
Soft Metais Ltda.
Tin
CID001898
Thaisarco
Tin
CID002036
White Solder Metalurgia e Mineracao Ltda.
Tin
CID002158
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin
CID002180
Yunnan Tin Company Limited
Tungsten
CID000004
A.L.M.T. TUNGSTEN Corp.


10


Tungsten
CID002833
ACL Metais Eireli
Tungsten
CID002502
Asia Tungsten Products Vietnam Ltd.
Tungsten
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten
CID000499
Fujian Jinxin Tungsten Co., Ltd.
Tungsten
CID000875
Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten
CID002315
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten
CID002494
Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten
CID000568
Global Tungsten & Powders Corp.
Tungsten
CID000218
Guangdong Xianglu Tungsten Co., Ltd.
Tungsten
CID002542
H.C. Starck Smelting GmbH & Co. KG
Tungsten
CID002541
H.C. Starck Tungsten GmbH
Tungsten
CID000766
Hunan Chenzhou Mining Co., Ltd.
Tungsten
CID002579
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten
CID000769
Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten
CID002649
Hydrometallurg, JSC
Tungsten
CID000825
Japan New Metals Co., Ltd.
Tungsten
CID002551
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten
CID002321
Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten
CID002318
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten
CID002317
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten
CID002316
Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten
CID000966
Kennametal Fallon
Tungsten
CID000105
Kennametal Huntsville
Tungsten
CID002319
Malipo Haiyu Tungsten Co., Ltd.
Tungsten
CID002845
Moliren Ltd.
Tungsten
CID002589
Niagara Refining LLC
Tungsten
CID002543
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten
CID002827
Philippine Chuangxin Industrial Co., Inc.
Tungsten
CID002815
South-East Nonferrous Metal Company Limited of Hengyang City
Tungsten
CID001889
Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten
CID002724
Unecha Refractory metals plant
Tungsten
CID002011
Vietnam Youngsun Tungsten Industry Co., Ltd.
Tungsten
CID002044
Wolfram Bergbau und Hutten AG
Tungsten
CID002843
Woltech Korea Co., Ltd.
Tungsten
CID002320
Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten
CID002082
Xiamen Tungsten Co., Ltd.
Tungsten
CID002830
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten
CID002095
Xinhai Rendan Shaoguan Tungsten Co., Ltd.


11

Table 2: Processing facilities reported in our supply chain in relation to calendar year 2018 which were no longer qualified as RMAP conformant as of December 31, 2018 and from which we have discontinued the sourcing of materials as of such date

Metal
RMAP Smelter Identification Number
Smelter Name
Month of communication date from RMI
(all in 2018)
Gold
CID001573
Schone Edelmetaal B.V.
April
Gold
CID000927
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
May

12