UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
Lumentum Holdings Inc.
(Exact name of Registrant as specified in its charter)
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Delaware | | 001-36861 | | |
(State or Other Jurisdiction of Incorporation) | | (Commission File Number) | | |
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1001 Ridder Park Drive, San Jose, CA | | | | 95131 |
(Address of Principal Executive Offices) | | | | (Zip Code) |
Jae Kim, Sr. Vice President, General Counsel and Secretary
(408) 546-5483
(Name and telephone number, including area code, of the person to contact in connection with this report)
Not Applicable
(Former Name or Former Address, if Changed Since Last 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:
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| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2023 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
Conflict Minerals Disclosure
Information required by this Item is incorporated by reference to the Conflict Minerals Report attached hereto as Exhibit 1.01.
A copy of this Form SD, including the Lumentum Holdings Inc. Conflict Minerals Report, is publicly available at www.lumentum.com/investors.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 3 - Exhibits
Item 3.01 Exhibits
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| | The following exhibit is filed as part of this Report. | |
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Exhibit No. | | Description |
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1.01 | | |
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Signature
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 undersigned hereunto duly authorized.
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| | | LUMENTUM HOLDINGS INC. |
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| | | By: | | /s/ Jae Kim |
| | | Name: | | Jae Kim |
| | | Title: | | Sr. Vice President, General Counsel and Secretary |
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| May 31, 2024 | | | | |
Lumentum Holdings Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2023
Introduction
Lumentum Holdings Inc. (“we”, “our”, “Lumentum” or the “Company”) is an industry-leading provider of optical and photonic products defined by revenue and market share addressing a range of end market applications including Optical Communications (“OpComms”) and Commercial Lasers (“Lasers”) for manufacturing, inspection and life-science applications. We seek to use our core optical and photonic technology and our volume manufacturing capability to expand into attractive emerging markets that benefit from advantages that optical or photonics-based solutions provide, including 3D sensing for consumer electronics and diode light sources for a variety of consumer and industrial applications. The majority of our customers tend to be original equipment manufacturers (“OEMs”) that incorporate our products into their products which then address end-market applications. For example, we sell fiber optic components that our network equipment manufacturer (“NEM”) customers assemble into communications networking systems, which they sell to network service providers or enterprises with their own networks. Similarly, many of our customers for our Lasers products incorporate our products into tools they produce, which are used for manufacturing processes by their customers. For 3D sensing, we sell diode lasers to manufacturers of consumer electronics products for mobile, personal computing, and gaming who then integrate our devices within their products, for eventual resale to consumers and also into other industrial applications. Lumentum has a global marketing and sales footprint that enables us to address global market opportunities for our products. Lumentum has manufacturing capabilities and facilities in North America, Asia-Pacific, and Europe, with employees engaged in research and development, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum’s Annual Report on Form 10-K for the fiscal year ended July 1, 2023, filed with the U.S. Securities and Exchange Commission (“SEC”) on August 23, 2023.
This Report has been prepared in accordance with the requirements of Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”, or “3TG”) contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2023 (“Covered Products”). Third-party products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report. This Report can be found on our website at www.lumentum.com/investors.
Executive Summary
Lumentum reviewed its supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2023 and contained Conflict Minerals. We then contacted these identified suppliers, each of which completed a Conflict Minerals Reporting Template (‘CMRT”) as part of our reasonable country of origin inquiry (“RCOI”). In connection with the CMRT, these suppliers generally provided us with a list of smelter or refiner names (collectively, “smelters”) that may have provided the Conflict Minerals in the parts or materials provided to us. We do not have a direct contractual or business relationship with these smelters, thus we worked closely with our suppliers-in-scope for our RCOI process. In the RCOI process, 287 unique smelter entities were identified. Of these 287 smelters, 42 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the “DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 35 of the 42 smelters were found to be conflict-free certified and 5 smelters verified that they were not the source for metals used in our supply chain. The remaining two (2) smelters sourcing from Covered Countries were removed from being reported as Responsible Minerals Assurance Process (“RMAP”) conformant in August 2023, due to not undergoing the required RMAP re-assessment and were subject to Lumentum’s risk mitigation process described below.
Design of Due Diligence
Lumentum designed its due diligence measures to conform to 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: Third Edition (the “OECD Guidance”). The OECD Guidance sets forth five steps for supply chain due diligence. There is significant overlap between our reasonable country of origin inquiry (“RCOI”) efforts and our due diligence measures performed, both of which are described below.
Management Systems
Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies, and maintain an e-mail address conflictminerals@lumentum.com for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the RCOI and due diligence procedures described below. All relevant Conflict Minerals data is kept in our internal database system.
Reasonable Country of Origin Inquiry
Lumentum conducted a RCOI that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2023. We retained a third-party consulting firm to assist with the RCOI and due diligence processes. As part of our RCOI, we contacted approximately 340 suppliers and original manufacturers. Each direct supplier was asked to provide Conflict Minerals data in the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Greater than 90% of these suppliers responded. Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this review, 287 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After performing a risk assessment on each of the 287 smelters regarding their responses, 42 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the smelters as well as other public information available at the time. In accordance with the Rule, Lumentum is required to exercise due diligence on the Conflict Minerals’ source and chain of custody and to follow a nationally or internationally recognized due diligence framework.
Conflict Minerals Policy
Lumentum’s Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/corporate-social-responsibility/our-business.
Risk Assessment and Response
Lumentum’s risk assessment plan was designed to define, identify, mitigate, and manage risks. Risks that arise are reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply chain and performed a risk assessment for 287 smelters. 42 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information obtained directly from the smelters as well as other public information available at the time. Lumentum then compared this list to the list provided by the RMAP and for smelters that were not identified by the RMAP as conformant, Lumentum conducted risk mitigation. 220 of the 287 smelters identified (greater than 75%) have undergone a RMAP audit. These smelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.
Due Diligence Results and Ongoing Risk Mitigation Efforts
Smelters and Country of Origin
Of the 42 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 35 smelters were found to be RMAP conformant at the end of 2023. Lumentum has conducted risk mitigation on the remaining seven (7) smelters that are not RMAP Conformant (Al Etihad Gold Refinery DMCC, Augmont Enterprise Private Limited, Dijllah Gold Refinery FZC, Emirates Gold DMCC, Fujairah Gold FZC, International Precious Metal Refiners, and Shirpur Gold Refinery Ltd.), to determine if they are actually used in parts purchased by Lumentum. After due diligence by Lumentum, the suppliers verified that five (5) of the non RMAP Conformant smelters were not used in their supply chain for parts sold to Lumentum. Lumentum continues to work with suppliers who are reporting two (2) remaining high-risk smelters (Al Etihad Gold Refinery DMCC and Emirates Gold DMCC), which were both RMAP Conformant until August 2023, to phase these smelters out of our supply chain. A list of 282 smelters likely used in our supply chain is listed on Annex A hereto.
Because certain of Lumentum’s suppliers source from smelters that source from the Covered Countries and some of these smelters were not yet conflict free certified at the end of our 2023 due diligence process, Lumentum has been unable to reach a definitive conclusion regarding its products manufactured during calendar year 2023.
Steps to be Taken to Mitigate Risk
Lumentum is committed to continuous improvement in our due diligence and mitigation process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their Conflict Minerals status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.
Given that we are a downstream company, many steps removed from the mining or processing of 3TG, and that we do not purchase raw ore or refined 3TG, Lumentum relies on independent third-party audits of smelters and refiners. Lumentum supports such independent third-party audits, including those conducted by the RMAP, through our financial support for the RMI. Lumentum also actively supports the goal of increasing smelter and refiner participation in the RMAP through our participation in the RMI and direct outreach through our third-party service provider. This assists the RMI with prioritizing outreach to known smelters and refiners to encourage them to participate in the RMAP.
Additional Risk Factors
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our determinations regarding the status of our supply chain with respect to Conflict Minerals. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in conflict free smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to Conflict Minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.
Annex A
Smelters and Refineries
Below is a list of the smelters reported to Lumentum as likely in Lumentum’s supply chain as of December 31, 2023.
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| Metal | Smelter Name |
| Gold | Advanced Chemical Company |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Agosi AG |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração |
| Gold | Argor-Heraeus S.A. |
| Gold | Asahi Pretec Corp. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Aurubis AG |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden Ronnskar |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Métaux S.A. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | DSC (Do Sung Corporation) |
| Gold | Dowa |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | LT Metal Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Germany GmbH Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ Co., Ltd. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | LS MnM Inc. |
| Gold | Materion |
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| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | MKS PAMP SA |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Précinox S.A. |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Royal Canadian Mint |
| Gold | Sabin Metal Corp. |
| Gold | Samduck Precious Metals |
| Gold | SAMWON Metals Corp. |
| Gold | SEMPSA Joyería Platería S.A. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | Super Dragon Technology Co., Ltd. |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | Shandong Gold Smelting Co., Ltd. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | Torecom |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| Gold | Morris and Watson |
| Gold | SAFINA A.S. |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Umicore Precious Metals Thailand |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | KGHM Polska Miedź Spółka Akcyjna |
| Gold | Singway Technology Co., Ltd. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Emirates Gold DMCC |
| Gold | T.C.A S.p.A |
| Gold | REMONDIS PMR B.V. |
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| Gold | Korea Zinc Co., Ltd. |
| Gold | Marsam Metals |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Abington Reldan Metals, LLC |
| Gold | Shenzhen CuiLu Gold Co., Ltd. |
| Gold | Albino Mountinho Lda. |
| Gold | SAAMP |
| Gold | L'Orfebre S.A. |
| Gold | 8853 S.p.A. |
| Gold | Italpreziosi |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Sai Refinery |
| Gold | Bangalore Refinery |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Pease & Curren |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | Safimet S.p.A |
| Gold | NH Recytech Company |
| Gold | QG Refining, LLC |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Sovereign Metals |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Alexy Metals |
| Gold | MD Overseas |
| Gold | Metallix Refining Inc. |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| Gold | WEEEREFINING |
| Gold | Gold by Gold Colombia |
| Gold | Dongwu Gold Group |
| Gold | Coimpa Industrial LTDA |
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| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | AMG Brasil |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineração Taboca S.A. |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | QuantumClean |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | FIR Metals & Resource Ltd. |
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| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET de Mexico |
| Tantalum | TANIOBIS Co., Ltd. |
| Tantalum | TANIOBIS GmbH |
| Tantalum | Materion Newton Inc. |
| Tantalum | TANIOBIS Japan Co., Ltd. |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Resind Indústria e Comércio Ltda. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. |
| Tantalum | PowerX Ltd. |
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| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Alpha |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Premium Tin Indonesia |
| Tin | Dowa |
| Tin | EM Vinto |
| Tin | Estanho de Rondônia S.A. |
| Tin | Fenix Metals |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | China Tin Group Co., Ltd. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Metallic Resources, Inc. |
| Tin | Mineração Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | Operaciones Metalúrgicas S.A. |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Tin Industry |
| Tin | PT Belitung Industri Sejahtera |
| Tin | PT Bukit Timah |
| Tin | PT Mitra Stania Prima |
| Tin | PT Panca Mega Persada |
| Tin | PT Prima Timah Utama |
| Tin | PT Refined Bangka Tin |
| Tin | PT Sariwiguna Binasentosa |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Timah Nusantara |
| Tin | PT Tinindo Inter Nusa |
| Tin | PT Tommy Utama |
| Tin | Rui Da Hung |
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| Tin | Thaisarco |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | White Solder Metalurgia e Mineração Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. |
| Tin | CV Venus Inti Perkasa |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | PT Tirus Putra Mandiri |
| Tin | Melt Metais e Ligas S.A. |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | CV Ayi Jaya |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | PT Rajehan Ariq |
| Tin | PT Cipta Persada Mulia |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Resind Indústria e Comércio Ltda. |
| Tin | Super Ligas |
| Tin | Aurubis Beerse |
| Tin | Aurubis Berango |
| Tin | PT Bangka Prima Tin |
| Tin | PT Sukses Inti Makmur |
| Tin | PT Menara Cipta Mulia |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Modeltech Sdn Bhd |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | PT Bangka Serumpun |
| Tin | Pongpipat Company Limited |
| Tin | Tin Technology & Refining |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | Luna Smelter, Ltd. |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| Tin | Precious Minerals and Smelting Limited |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | PT Mitra Sukses Globalindo |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | CRM Synergies |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. |
| Tin | DS Myanmar |
| Tin | PT Putera Sarana Shakti (PT PSS) |
| Tin | Mining Minerals Resources SARL |
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| Tungsten | A.L.M.T. Corp. |
| Tungsten | Kennametal Huntsville |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Global Tungsten & Powders LLC. |
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| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Kennametal Fallon |
| Tungsten | Wolfram Bergbau und Hütten AG |
| Tungsten | Xiamen Tungsten Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG |
| Tungsten | Masan High-Tech Materials |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | China Molybdenum Tungsten Co., Ltd. |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | Lianyou Metals Co., Ltd. |
| Tungsten | Hubei Green Tungsten Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. |
| Tungsten | Tungsten Vietnam Joint Stock Company |
37 of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. Under the Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries and there is no requirement to identify the specific Covered Country by the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are the DRC, Rwanda and United Arab Emirates.
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