UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_________________
FORM SD
_________________
Specialized Disclosure Report
_________________________________
CIRRUS LOGIC, INC.
(Exact name of registrant as specified in its charter)
_________________________________
| | | | | | | | |
| DELAWARE | | 0-17795 |
| (State or other jurisdiction of incorporation) | | (Commission File Number) |
800 W. 6th Street, Austin, TX 78701
(Address of principal executive offices)
Registrant’s telephone number, including area code: (512) 851-4000
_________________________________
Check the appropriate box to indicate the rule pursuant to which this form is being filed:
| | | | | |
| þ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| ☐ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____________. |
SECTION 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Cirrus Logic, Inc. (the “Company”) has evaluated its current product lines and determined that certain products that we manufactured, or contracted to manufacture, during calendar year 2023 use “conflict minerals” that are necessary to the functionality or production of those products. Conflict minerals are defined by the Securities and Exchange Commission (“SEC”) as cassiterite, columbite-tantalite, gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (the “3TG” minerals). The Company conducted a good faith reasonable country of origin inquiry regarding those 3TG minerals to determine whether any of the 3TG minerals originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola (the “Covered Countries”), and whether any of the 3TG minerals may be from recycled or scrap sources. Based on its inquiry, the Company undertook due diligence on the source or chain of custody of its 3TG minerals and filed a Conflict Minerals Report as Exhibit 1.01 to this Form SD. A copy of the Company’s Conflict Minerals Report, along with a copy of this Form SD, is publicly available online at www.cirrus.com/company/quality/corporate-compliance in the Corporate Compliance section of our website.
Item 1.02 Exhibit
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.
SECTION 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
SECTION 3 – Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this Report:
•Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, Registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| | | | | | | | | | | | | | | | | | | | |
| | | | CIRRUS LOGIC, INC. |
| | | |
| Date: May 24, 2024 | | | | By: | | /s/ Gregory S. Thomas |
| | | | Name: | | Gregory S. Thomas |
| | | | Title: | | General Counsel |
Exhibit 1.01
Cirrus Logic, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2023
I. Introduction
This Conflict Minerals Report (the “Report”) has been prepared by Cirrus Logic, Inc. (the “Company”) pursuant to Rule 13p-1 and Form SD (the “Rule”), which were promulgated under the Securities Exchange Act of 1934. The Report covers the reporting period January 1, 2023 to December 31, 2023. The Securities and Exchange Commission (the “SEC”) adopted the Rule to implement the reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain certain specified materials that are necessary to the functionality or production of their products. The specified materials, which are collectively referred to as the “Conflict Minerals,” are defined by the SEC as cassiterite, columbite-tantalite, gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (the “3TG” minerals).
According to the Rule, if a registrant has reason to believe that any of the 3TG minerals in its supply chain may have originated in the Covered Countries, or if the registrant is unable to determine that the 3TG minerals either did not originate in the Covered Countries or were from recycled or scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the 3TG minerals. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. The registrant must annually submit a report, a Conflict Minerals Report (the “CMR”), to the SEC that includes a description of those due diligence measures.
This Report has been prepared by management of the Company and includes the activities of all majority-owned subsidiaries and entities that are required to be consolidated. The Company did not subject this Report to an independent private sector audit and we do not believe such an audit was required based on the guidance provided by the SEC in its “Statement of the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014 because we have not elected to describe any of our covered products as “DRC conflict free” at this time.
Company Overview
The Company is a leader in low-power, high-precision mixed-signal processing solutions that create innovative user experiences for the world’s top mobile and consumer applications.
Description of the Company’s Products Covered by this Report
This Report relates to products: (i) for which 3TG minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2023. The Company’s products covered by this Report are integrated circuits.
II. Reasonable Country of Origin Inquiry
The Company has conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals. This RCOI was reasonably designed to determine whether any of the 3TG minerals originated in the Covered Countries and whether any of the 3TG minerals may be from recycled or scrap sources. To conduct the RCOI, we requested our suppliers to report the origin of the 3TG minerals used in the manufacture of our products. Specifically, suppliers were expected to utilize
the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) to report on the use of 3TG minerals used in the manufacture of our products.
Annex I includes a summary of the country of origin information collected as a result of our RCOI. The data on which we relied for certain statements in this report was obtained through our membership in the RMI, using the Reasonable Country of Origin Inquiry report for member “CRUS.”
III. Due Diligence Design and Performance
1.Due Diligence Design:
Our due diligence measures have been designed to conform with the framework provided by 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”).
In conjunction with its due diligence process, the Company has adopted a policy relating to 3TG minerals (the “Conflict Minerals Policy”), incorporating the standards set forth in the OECD Guidance. The Conflict Minerals Policy states that, to promote stability and security, we expect our suppliers to source materials from environmentally and socially responsible supply chains. Our policy forbids our suppliers from placing an outright ban on procuring minerals from the Covered Countries. In addition, the Conflict Minerals Policy states that our suppliers must report at least annually the origin of the 3TG minerals by identifying smelters or refiners (“SORs”) used in the manufacture of our products. As outlined in the OECD Guidance, we also participate in groups and forums focused on responsible sourcing of the 3TG minerals, including the Responsible Business Alliance (“RBA”) and utilize RMI’s Responsible Minerals Assurance Process (“RMAP”), which provides suppliers with an independent, third-party audit that determines which smelters and refiners can be verified as having systems in place to responsibly source minerals in line with current global standards.
Summarized below are the design components of our conflict minerals program as they relate to the five-step framework as provided by the OECD Guidance:
•Establishment of a strong company management system through:
•Adopting a Conflict Minerals Policy;
•Establishing an internal team of subject matter experts that includes members of our supply chain, legal, and quality organizations, and is managed by our General Counsel;
•Instituting processes for new suppliers of our integrated circuits whereby conflict mineral conformance is discussed during initial business reviews;
•Including a flow-down clause in new or renewed supplier contracts relating to the sourcing of 3TG minerals;
•Requiring our integrated circuit suppliers abide by the Cirrus Logic Supplier Code of Conduct, which is based on the RBA Code of Conduct;
•Communicating our Supplier Code of Conduct to our suppliers with, in certain cases, accompanying training;
•Participating in RMI initiatives; and
•Providing multiple communication channels to serve as grievance mechanisms for early warning risk awareness, including an anonymous reporting hotline available for reporting possible violations of the Company’s policies (https://secure.ethicspoint.com/domain/media/en/gui/6355/index.html) and the RBA Voices platform, a review system established by RMI to provide a record and communication channel for identification, review, and resolution of grievances.
•Identification and assessment of risks in the supply chain by:
•Identifying first-tier suppliers to engage in our due diligence efforts;
•For subcontractors associated with the manufacture of our integrated circuit products, incorporating conflict minerals data review as part of our annual audits;
•Conducting a survey of our direct supply chain using the template known as the RMI CMRT;
•Reviewing and validating smelter information provided by suppliers and working with our supply chain to correct any inaccuracies in reporting;
•Requiring sourcing only from SORs that are RMAP-conformant or that have successfully undergone a similar independent third-party audit verification;
•Identifying smelter usage by greatest risk and prioritizing efforts, if any, associated with our due diligence with those smelters; and
•Participating in RMI as a member of the smelter engagement team (level one) to validate SORs and assist in efforts to encourage smelter participation in the RMAP.
•Design and implement a strategy to respond to identified risks by:
•Responding to risks identified in the supply chain by confirming that all smelters identified in survey responses from our suppliers have been verified by the RMAP;
•Mitigating risks by performing direct outreach when necessary with smelters at risk for non-conformance to RMAP protocols to ensure continued compliance;
•Collaborating with our supply chain to apply appropriate and reasonable leverage to ensure identified risks are tracked and removing non-conformant and/or inactive SORs in a timely manner if such SORs are unable or unwilling to remediate identified risks; this is done in consultation with information that RMI makes available to its members;
•Exercising leverage over our upstream suppliers through contractual obligations and requirements to comply with our Supplier Code of Conduct, which is based on the RBA Code of Conduct and includes provisions requiring responsible sourcing of conflict minerals;
•Reporting on a quarterly basis to senior management, including the Company’s Senior Vice President of Supply Chain; Senior Vice President of Global Operations; and Senior Vice President, General Counsel, the status and findings derived from our due diligence efforts;
•Informing the Company’s Audit Committee yearly on our due diligence activities and Conflict Minerals Report;
•Designing and implementing training or recommendations for relevant first-tier suppliers as needed to improve their systems of transparency and control; and
•Communicating our Conflict Minerals Policy to suppliers.
•Auditing supply chain due diligence by:
•Requesting our suppliers to report to us using an industry-developed audit program through RMI, in collaboration with the London Bullion Market Association (“LBMA”) and the Responsible Jewellery Council (“RJC”), that is administered by independent third-party auditors;
•Assessing the conflict minerals processes, procurement, and documentation of our suppliers; and
•Supporting, through our participation in and financial support of, RMI’s efforts to determine mine or location of origin of conflict minerals and to improve and align industry expectations for due diligence as described on the RMI website at http://www.responsiblemineralsinitiative.org.
•Reporting on supply chain due diligence by:
•Communicating our Conflict Minerals Policy on our website at www.cirrus.com/company/quality/corporate-compliance/;
•Reporting annually our Specialized Disclosure Report on Form SD and Conflict Mineral Report filed with the SEC and publicly communicated on our website at www.cirrus.com/company/quality/corporate-compliance/; and
•Discussing our Environmental, Social, and Governance (“ESG”) program in our annual ESG report available on our website at www.cirrus.com/company/esg/.
2.Due Diligence Measures Performed:
The Company exercised due diligence on the source and chain of custody of the 3TG minerals. Below is a description of the measures we performed for this reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:
•Communicated our Conflict Minerals Policy to our suppliers;
•Conducted a supply-chain survey of 16 direct suppliers of our integrated circuit products using the RMI’s CMRT, requesting information regarding the necessary conflict minerals and identification of smelter and refiners that process such minerals;
•Received responses to surveys from 100% of our suppliers with respect to our integrated circuits component suppliers for at least the seventh consecutive year;
•Reviewed survey data for completeness, and contacted those suppliers that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information;
•Compared smelters identified by our suppliers against lists of smelters certified as conflict-free through the RMAP; and
•Continued work through our conflict minerals program to assess16 suppliers and implement program updates as necessary, focusing on the due diligence processes and policies of certain direct suppliers of our integrated circuit products.
IV. Results of Due Diligence Measures
Based on our due diligence efforts as it relates to our integrated circuits, we identified the facilities set forth in Annex II that potentially could have produced the necessary 3TG minerals in our products. Of the 102 smelters that we identified, 20 were believed to be potentially sourcing directly from the Covered Countries. However, none of the smelters identified in our supply chain are known to us as sourcing 3TG minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. In Annex II, we have indicated the facilities identified in our supply chain as of 09 April 2024.
V. Inherent Limitations and Risks with our Due Diligence Measures
The Company employs a “fabless” model for the manufacture, assembly, and test of our integrated circuits. We do not own or operate our own foundries or manufacturing facilities, and therefore, outsource our integrated circuit manufacturing to third-party foundries in Asia and Europe. We also outsource all product assembly, packaging, and testing of our products to several assembly and test subcontractors in Asia.
With our fabless manufacturing strategy, we are a downstream consumer of certain 3TG minerals and our due diligence efforts can provide only reasonable, not absolute, assurance regarding the source and chain of custody for the necessary conflict minerals in the products that we sell. Our supply chain is complex, and there are multiple tiers between our company and the mines that ultimately supply 3TG materials. Given our place in the supply chain, we have no direct relationships with smelters and refiners, and therefore, possess no independent means of determining the source and origin of conflict mineral ores
processed by smelters and refiners. We are regularly monitoring the RBA Smelter or Refiner Master tool prepared and distributed by RMI; we work with our suppliers to understand how those SORs whose status is flagged as “Not Eligible” or “Non-Conformant” fit into our supply chain and request their removal from our supply chain as appropriate. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers, who similarly rely on their supply chains to identify the original sources of the necessary conflict minerals. We may not receive CMRT data at the product-specific level for our Company, and information received from our suppliers may include SORs outside our direct supply chain. We also rely, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud; for example, data may not be provided with sufficient granularity to enable us to accurately determine the number of smelters included as part of a program’s RCOI. This concern may be exacerbated after the U.S. Securities & Exchange Commission’s statement on the Rule in April 2017 indicating that, in light of the regulatory uncertainties relating to the Rule, the staff of the SEC will not recommend an enforcement action if companies only file a Form SD, and not a Conflict Minerals Report, to the extent otherwise required to be filed as an exhibit under the Rule.
Additionally, the complete supply chain from the SORs to our final integrated circuits involves a complex multi-step process that may be subject to changes without our knowledge on a frequent basis. We seek sourcing data from directs suppliers on at least an annual basis and request that the data cover the entire reporting year. However, due to timing of our requests, there is a risk that the data that we acquire will not reflect every supplier in the supply chain during the relevant period.
As a result of the COVID-19 pandemic, the Company adapted certain audits and assessments to comply with travel restrictions and/or local regulations. The Company was able to keep individuals safe while maintaining the quality of reviews, and therefore continued remote audits during calendar year 2023, even as RBA returned to its standard practices for in-person onsite audits.
VI. Future Steps to Mitigate Risks
Based on our efforts to collect data, we believe the main risks that we have identified are related to the lack of data and the quality of data. We intend to continue the activities described above as well as take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG minerals in our products could benefit armed groups in the Covered Countries:
1.Continue to engage with suppliers and direct them to training resources to attempt to maintain the response rate and improve the content of the supplier survey responses;
2.Continue to incorporate conflict minerals data review that we perform on 100% of our subcontractors associated with the manufacture of our integrated circuit products;
3.Continue to participate with RMI to expand the smelters and refiners participating in the RMAP;
4.Continue to work with the OECD or relevant trade associations to define and improve best practices and encourage responsible sourcing of 3TG minerals, including from the Covered Countries, in accordance with the OECD Guidance;
5.Continue to encourage suppliers to utilize the public source RMI e-Learning training platform; and
6.Continue to regularly monitor the RBA Voices platform as well as track grievances generated by RMI’s Grievance Mechanism, established by RMI to provide a record and communication channel to assess and respond to risks and potential opportunities for improvement related to concerns raised about participating SORs, RMI assessment of auditor or audit firm, and the RMI organization itself. This grievance mechanism allows from anonymous reporting of grievances and whistleblower protections.
Annex I
| | | | | |
| Countries of Origin of 3TG |
| Andorra | Kyrgyzstan |
| Antigua and Barbuda | Laos |
| Argentina | Latvia |
| Australia | Liberia |
| Austria | Lithuania |
| Azerbaijan | Luxembourg |
| Bahamas | Madagascar |
| Bangladesh | Malaysia |
| Barbados | Mali |
| Belarus | Malta |
| Belgium | Mauritania |
| Benin | Mexico |
| Beralus | Mongolia |
| Bolivia | Morocco |
| Bosnia and Herzegovina | Mozambique |
| Botswana | Myanmar |
| Brazil | Namibia |
| Bulgaria | Netherlands |
| Burkina Faso | New Zealand |
| Burundi | Nicaragua |
| Cambodia | Niger |
| Cameroon | Nigeria |
| Canada | Oman |
| Cayman Islands | Pakistan |
| Chile | Panama |
| China | Papua New Guinea |
| Colombia | Peru |
| Congo, Democratic Republic of the | Philippines |
| Costa Rica | Poland |
| Côte d'Ivoire | Portugal |
| Croatia | Puerto Rico |
| Curacao | Romania |
| Cyprus | Russia |
| Czech Republic | Rwanda |
| Denmark | Saint Kitts and Nevis |
| | | | | |
| Dominican Republic | Saudi Arabia |
| Ecuador | Senegal |
| Egypt | Serbia |
| El Salvador | Sierra Leone |
| Estonia | Singapore |
| Fiji | Saint Maarten |
| Finland | Slovakia |
| France | Slovenia |
| French Guiana | South Africa |
| Georgia | Spain |
| Germany | St Vincent and Grenadines |
| Ghana | Sudan |
| Greece | Suriname |
| Grenada | Sweden |
| Guatemala | Switzerland |
| Guinea | Taiwan, Province of China |
| Guyana | Tanzania |
| Honduras | Thailand |
| Hong Kong | Trinidad and Tobago |
| Hungary | Tunisia |
| India | Turkey |
| Indonesia | Turks and Caicos |
| Ireland | Uganda |
| Israel | United Arab Emirates |
| Italy | United Kingdom of Great Britain and Northern Ireland |
| Japan | United States of America |
| Jordan | Uruguay |
| Kazakhstan | Uzbekistan |
| Kenya | Vietnam |
| Korea, Republic of | Zimbabwe |
| Kuwait | |
Annex II
| | | | | | | | |
Conflict Mineral |
Processing Facility Name |
Processing Facility Location |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| | | | | | | | |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET de Mexico | MEXICO |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | TANIOBIS GmbH | GERMANY |
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tin | Dowa | JAPAN |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Thaisarco | THAILAND |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | DS Myanmar | MYANMAR |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| | | | | | | | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Masan High-Tech Materials | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
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