UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
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Vishay Intertechnology, Inc.
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(Exact name of registrant as specified in its charter)
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Delaware
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1-7416
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38-1686453
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(State or Other Jurisdiction of Incorporation)
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(Commission File Number)
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(I.R.S. Employer Identification Number)
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63 Lancaster Avenue
Malvern, PA 19355-2143
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19355-2143
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(Address of Principal Executive Offices)
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Zip Code
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Lori Lipcaman,
Executive Vice President and
Chief Financial Officer
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610-644-1300
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(Name and telephone number, including area code, of the
Person to contact in connection with this report.)
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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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☑
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022.
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Section 1 – Conflict Minerals Disclosure
Item 1.01 – Conflict Minerals Disclosure and Report
Vishay Intertechnology, Inc. ("Vishay," the "Company," "we," "us," or "our") is a leading global manufacturer and supplier of discrete semiconductors and passive components.
Substantially all of our products utilize one or more of the minerals tantalum, tin, tungsten or gold—"conflict minerals" (as defined in Section 1, Item 1.01 (d)(3) of Form SD)—that are necessary to the functionality
or production of such products. Based on a "reasonable country of origin inquiry" Vishay knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or
an adjoining country (collectively, the "Covered Countries") and knows or has reason to believe that those necessary conflict minerals may not be from recycled or scrap sources.
Accordingly, Vishay designed its due diligence process regarding the source and chain of custody of such conflict minerals, based upon the Organization for Economic Co-operation and Development ("OECD") Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, an internationally recognized due diligence framework.
Vishay continues to work with industry groups, including the Responsible Business Alliance (formerly known as the Electronic Industry Citizenship Coalition), and its supply chain partners to attempt to determine the
country of origination of such materials.
In accordance with Rule 13p-1, Vishay has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report filed as an exhibit to this Form SD, and both reports are posted to our publicly
available website at http://ir.vishay.com/sec-filings. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Item 1.02 – Exhibit
Exhibit 1.01 is hereby incorporated into this item by reference.
Section 2 – Exhibits
Item 2.01 – Exhibits
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Exhibit No.
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Description
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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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VISHAY INTERTECHNOLOGY, INC.
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By:
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/s/ Lori Lipcaman
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Date: May 23, 2023
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Name:
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Lori Lipcaman
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Title:
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Executive Vice President
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Chief Financial Officer
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Exhibit 1.01
Vishay Intertechnology, Inc.
May 23, 2023
Conflict Minerals Report
For the Year Ended December 31, 2022
This report for the year ended December 31, 2022 is presented to comply with Rule 13p-1 and Form SD (collectively, the "Rule") promulgated under the Securities Exchange Act of 1934, as amended. The Rule was adopted by
the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). The Rule imposes
certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold,
wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG"). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.
The report presented herein is not audited.
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I.
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Company overview
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Vishay Intertechnology, Inc.
("Vishay," the "Company," "we," "us," or "our") is a leading global manufacturer and supplier of discrete semiconductors and passive components. Semiconductors include MOSFETs, diodes, and optoelectronic components. Passive components include
resistors, inductors, and capacitors. Discrete semiconductors and passive components are essential elements of virtually every type of electronic circuit. Substantially all of our products contain 3TG. Our products are more fully described in Item 1
of our Annual Report on Form 10-K filed with the SEC on February 22, 2023.
We are a major consumer of the
world's annual production of tantalum, a metal used in the manufacturing of tantalum capacitors. There are few suppliers that process tantalum ore into capacitor grade tantalum powder. Although most materials incorporated in our products are available
from a number of sources, certain materials are available only from a relatively limited number of suppliers, the source for which may include the Democratic Republic of the Congo ("DRC") or adjoining countries (collectively, the "Covered Countries").
Vishay is a member of
the Responsible Business Alliance ("RBA") and Responsible Minerals Initiative ("RMI") and fully supports the position of these organizations in avoiding the use of 3TG which directly or indirectly finance or benefit armed groups in the Covered
Countries. As such, our position is in full compliance with the RBA Code of Conduct.
Our reasonable country of origin
inquiry ("RCOI") included only our manufactured products and excluded our buy/resale business, in which we do not manufacture or contract to manufacture products, as permitted by the Rule.
Vishay Intertechnology is working
toward the elimination of conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries from its supply chain. Vishay's ultimate goal is to have a supply chain that consists of material that is DRC Conflict
Free.
As part of this policy, Vishay will:
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1.
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Exercise due diligence as specified 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 (2nd Edition) ("OECD Framework") and related 3T and gold supplements.
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2.
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Support and participate in industry groups such as the RBA and collaborations such as Conflict Free Sourcing Initiative that are focusing on industry-wide solutions.
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3.
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Commit to transparency by providing necessary reports and information to the SEC and customers.
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Vishay expects its first tier suppliers of 3TG ("In-scope Suppliers") to:
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1.
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Have conflict mineral policies in place to ensure material is sourced from socially responsible suppliers.
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2.
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Exercise due diligence to determine the source of conflict minerals.
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3.
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Not procure material from the DRC or adjoining countries that is not "DRC Conflict Free."
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4.
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Provide the necessary declarations in order to determine if the conflict minerals in the supply chain are DRC Conflict Free.
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In-scope Suppliers who are not in compliance with these requirements will be reviewed in order for us to determine the extent to which Vishay will continue
to do business with those Suppliers. Vishay will terminate business with any In-scope Supplier if we determine that the Supplier's sourcing of 3TG directly or indirectly finance armed groups in the Covered Countries.
1
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II.
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RCOI Process and results
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Vishay's RCOI employed a
combination of measures to determine whether the necessary 3TG in Vishay's products originated from the Covered Countries. Vishay's supply chain is complex and there are multiple tiers between the Company and the mine. Vishay relies on its In-scope
Suppliers to provide information on the origin of the 3TG contained in components which are included in the Company's products. Vishay's primary means of determining country of origin of necessary 3TG was conducting a supply-chain survey with In-scope
Suppliers using the RMI Conflict Minerals Reporting Template and RCOI data from the RMI.
Vishay conducted a survey of
potential In-scope Suppliers of 3TG, representing all of its potential In-scope suppliers of 3TG. Vishay obtained survey responses from In-scope Suppliers representing 99.5% of the dollar value of 2022 in-scope procurement activities. The survey
responses identified 228 smelters and refiners of 3TG. Based on the survey responses obtained, we have reason to believe that some of our supplies of 3TG may have originated in the Covered Countries, some from outside of the Covered Countries, some
from recycled/scrap materials, and some from sources that are currently unknown.
As we do not typically have a
direct relationship with 3TG smelters and refiners, we rely on the tools available to members of the RBA and RMI to disclose upstream actors in the supply chain.
There is significant overlap
between our RCOI efforts and our due diligence process.
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III.
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Due Diligence Process
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Design
Our due diligence measures have been designed to conform, in all material respects, with the framework in the OECD Framework and related Supplements for
gold, tantalum, tin, and tungsten.
Performance
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a.
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Company Management Systems
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i.
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Policy
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Our Responsible Minerals Sourcing Policy is summarized above under "Company Overview" and is also available on our website at www.vishay.com.
The content of any website referred to in this Conflict Minerals Report is included for general information only and is not incorporated by reference in
this Conflict Minerals Report.
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ii.
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Communication with In-scope Suppliers
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In-scope Suppliers are one of the key components in the execution of the Vishay's 3TG program. As such, Vishay has specified its expectations of the Supplier through the following sources:
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1.
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Vishay's Responsible Minerals Sourcing Policy via the Vishay website and direct communication with the Suppliers.
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2.
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Conflict Mineral requirements as part of new or renewed Supplier Agreements.
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3.
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Yearly Supplier information requests to gather and/or update sourcing information.
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iii.
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Education of Personnel
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Vishay has educated key personnel
involved in the procurement of materials on the Company's Responsible Minerals Sourcing Policy and Program. Vishay has established a management system for 3TG, which includes a core team comprising vice president-level management and is sponsored by
executive vice president-level management. Executive management is briefed about the results of our due diligence efforts and provides feedback and direction to the core Conflict Minerals management team.
If agreed with Supplier, Vishay
provides training or meetings to communicate Vishay's expectations under the Company's Responsible Minerals Sourcing Policy and Program and to explain any issues that may arise. From time to time, Vishay may also provide reference material to its
In-scope Suppliers in order to help them comply with Vishay and industry requirements.
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iv.
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Tracking mechanisms
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Vishay uses a third-party software system to distribute, track, collect, analyze, and assign risk assessment metrics to Supplier responses.
2
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v.
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Whistleblower mechanisms
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In the event that a Vishay
employee, supplier, or customer has a concern regarding the accuracy of information relative to 3TG, they are directed to contact their supervisor or purchasing or sales contact respectively regarding their concern. If such contact is not possible or
practical, the employee, supplier, or customer is instructed to contact Vishay's ethics helpline. The contact information for the ethics helpline is available at http://www.vishay.com/company/ethics.
This policy has been communicated
to affected employees and suppliers via email.
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b.
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Identify and assess risks in the supply chain
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All 3TG In-scope Suppliers are
loaded into the Company Conflict Minerals software. The software sends RMI questionnaires and analyzes the responses according to internally defined red flags. Vishay's purchasing team works with its In-scope Suppliers to address any identified red
flags. Unresolved red flags are escalated to the 3TG management team. Such suppliers are designated internally as "Red Flag Suppliers."
The smelters and refiners
identified by Vishay's In-scope Suppliers are then consolidated into one smelters and refiners list. The origin and mine information obtained from the Supplier surveys and from external resources, such as the RMI, are used in our reasonable country of
origin procedures.
Vishay
checks all smelters and refiners against the RMI Standard Smelter List and investigates any smelters or refiners not currently on the list. If it is determined that an identified smelter or refiner that is not on the list is truly a smelter or
refiner of 3TG, Vishay contacts RBA to request that such smelter or refiner be added to the RBA Standard Smelter List. Lists of Conflict-Free Smelter Program compliant smelters and refiners are available at the RMI website at http://www.responsiblemineralsinitiative.org/.
Vishay's smelters and refiners
list is checked against internal criteria to identify if the smelter or refiner could potentially be sourcing from the Covered Countries and be benefiting armed conflict.
Smelters and refiners identified
on our consolidated list that do not meet the internal criteria are considered to present a risk of possibly not being DRC Conflict Free and are subject to Vishay's risk mitigation procedures.
As an active member of the RBA and
RMI, Vishay communicates to its In-scope Suppliers the requirement that at-risk smelters and refiners be independently certified.
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c.
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Design and implement strategy to respond to identified risks
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Red Flag Suppliers, smelters and refiners not on the RMI Standard Smelter list, smelters and refiners with unknown country sourcing, and other smelters and refiners that are
considered to present risk (collectively, "Identified Risk Entities") are all subject to Vishay's risk mitigation procedures. Vishay tailors its risk mitigation procedures for each Identified Risk Entity based on the individual Identified Risk
Entity's facts and circumstances. The risk mitigation procedures for Identified Risk Entities generally include the following procedures:
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1.
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Establish a defined time period that the Identified Risk Entity will work with Vishay's purchasing department to mitigate its identified risks.
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2.
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Work with RMI to obtain additional information or certifications.
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3.
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Conduct formal reviews of Identified Risk Entities that do not mitigate their identified risks by the established deadline date. The 3TG
management team will then implement one or more of the following actions for Identified Risk Entities that cannot be verified to not directly or indirectly benefit armed rebels through their 3TG sourcing:
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a.
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Grant additional time to mitigate the identified risk;
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b.
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Develop a long-term improvement plan with the supplier;
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c.
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Suspend purchasing activities from the In-scope Supplier that has red flags and/or sources from the Identified Risk Entity;
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d.
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Establish a phase-out plan for the In-scope supplier that has red flags and/or sources from the Identified Risk Entity.
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4.
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If it is determined that the Identified Risk Entity has or likely has directly or indirectly benefited armed rebels through their 3TG sourcing,
the 3TG management team will then implement one or more of the following actions:
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a.
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Require that the affected In-scope Supplier remove the smelter or refiner that is an Identified Risk Entity from Vishay's supply chain; or
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b.
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Terminate purchasing activities with the In-scope Supplier if the Supplier does not remove the smelter or refiner that is an Identified Risk
Entity from its supply chain.
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The 3TG management team maintains records of its actions as well as tracks several metrics used to monitor the effectiveness of its
risk management procedures. The status and results of the risk management procedures are reviewed with senior management semi-annually. Vishay updates its supplier determinations and risk management procedures annually.
3
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d.
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Audits of smelters' and refiners' due diligence processes
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Vishay will rely on third party audit results from the RBA, RMI, London Bullion Market Association, Responsible Jewelry Council, and the Tungsten Industry – Conflict Minerals
Council to satisfy the verification of due diligence according to the OECD guidelines and third party audit requirements for high risk smelters and refiners to certify which smelters or refiners are DRC Conflict Free.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of
conflict minerals, Vishay's due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Vishay's due diligence processes are based on the necessity of
seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. Vishay also relies, 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.
Another complicating factor is the
unavailability of country of origin and chain of custody information from suppliers on a continuous, real-time basis. Under the Dodd-Frank Act and the Rule, a product is DRC Conflict Free if it meets the required standard every day of the reporting
year; conversely, a product would "not be found to be DRC Conflict Free" if it does not meet the required standard even one day of the reporting year. The supply chain of commodities such as conflict minerals is a multi-step process operating more or
less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market
locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since Vishay does not have direct contractual relationships with most smelters and refiners, it relies on its direct
suppliers to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. Vishay directly seeks sourcing data on a periodic basis from its
direct suppliers as well as certain smelters and refiners. Vishay requests that the data cover the entire reporting year.
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IV.
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Reporting
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a.
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Future Steps to be taken
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Vishay continues to work with industry groups, including the RBA and RMI, and its In-scope Supply chain partners to enable it to assess the origination and chain of custody of
materials in its supply chain.
We expect to take the following steps to improve the due diligence conducted to further mitigate the risk that necessary 3TG in our products could possibly
benefit armed groups in the Covered Countries:
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1.
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Work to increase the response rate of suppliers to our due diligence inquiries.
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2.
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Request In-scope Suppliers to require at risk smelters or refiners to obtain a Conflict Free designation from an industry program such as the RMI.
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3.
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Continue to validate In-scope Supplier responses using information collected from independent conflict free smelter validation programs such as the RMI, to which we
provide financial support.
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b.
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Exclusion of acquired entities
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In accordance with the Rule, entities acquired during the reporting period are excluded from the scope of this Conflict Minerals Report. This
includes the business of MaxPower Semiconductor, Inc., ("MaxPower"), a California-based fabless power semiconductor provider, acquired in 2022. A substantial number of MaxPower's products utilize one or more 3TG necessary to the functionality or
production of such products. MaxPower's products are first required to be included in Vishay's Conflict Minerals reporting for the year ending December 31, 2024.
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c.
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Results
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The initial and subsequent responses from Vishay's In-scope Suppliers in our reasonable country of origin procedures did not contain sufficient information to determine the country of origin of all
of the 3TG necessary for functionality of all of the products that Vishay manufactured in 2021. We have increased the number and percentage of validated "conflict free" smelters and refiners from 53, or 49%, in 2013 to 217, or 95%, in 2022. We have
validated over 94% of smelters and refiners as "conflict free" each year since 2017.
4
As of May 11, 2023 our smelters and refiners identified by our suppliers are listed below:
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Metal
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Smelter Reference List
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Smelter ID
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RMI Status
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Validated as "Conflict Free"
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Gold
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Abington Reldan Metals, LLC
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CID002708
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Compliant
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Gold
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Advanced Chemical Company
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CID000015
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Compliant
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Gold
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Agosi AG
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CID000035
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Compliant
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Gold
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Aida Chemical Industries Co., Ltd.
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CID000019
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Compliant
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Gold
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Al Etihad Gold Refinery DMCC
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CID002560
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Compliant
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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CID000041
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Compliant
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Gold
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AngloGold Ashanti Corrego do Sitio Mineracao
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CID000058
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Compliant
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Gold
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Argor-Heraeus S.A.
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CID000077
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Compliant
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Gold
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Asahi Pretec Corp.
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CID000082
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Compliant
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Gold
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Asahi Refining Canada Ltd.
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CID000924
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Compliant
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Gold
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Asahi Refining USA Inc.
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CID000920
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Compliant
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Gold
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Asaka Riken Co., Ltd.
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CID000090
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Compliant
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Gold
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Aurubis AG
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CID000113
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Compliant
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Gold
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Bangalore Refinery
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CID002863
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Compliant
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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CID000128
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Compliant
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Gold
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Boliden AB
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CID000157
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Compliant
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Gold
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C. Hafner GmbH + Co. KG
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CID000176
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Compliant
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Gold
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CCR Refinery - Glencore Canada Corporation
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CID000185
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Compliant
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Gold
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Chimet S.p.A.
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CID000233
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Compliant
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Gold
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Chugai Mining
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CID000264
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Compliant
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Gold
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Dowa
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CID000401
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Compliant
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Gold
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DSC (Do Sung Corporation)
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CID000359
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Compliant
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Gold
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Eco-System Recycling Co., Ltd. East Plant
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CID000425
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Compliant
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Gold
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Eco-System Recycling Co., Ltd. North Plant
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CID003424
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Compliant
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Gold
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Eco-System Recycling Co., Ltd. West Plant
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CID003425
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Compliant
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Gold
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Emirates Gold DMCC
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CID002561
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Compliant
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Gold
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Geib Refining Corporation
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CID002459
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Compliant
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Gold
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Gold by Gold Colombia
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CID003641
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Compliant
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Gold
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Gold Refinery of Zijin Mining Group Co., Ltd.
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CID002243
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Compliant
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Gold
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Heimerle + Meule GmbH
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CID000694
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Compliant
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Gold
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Heraeus Germany GmbH Co. KG
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CID000711
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Compliant
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Gold
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Heraeus Metals Hong Kong Ltd.
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CID000707
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Compliant
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
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CID000801
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Compliant
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Gold
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Ishifuku Metal Industry Co., Ltd.
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CID000807
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Compliant
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Gold
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Istanbul Gold Refinery
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CID000814
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Compliant
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Gold
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Italpreziosi
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CID002765
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Compliant
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Gold
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Japan Mint
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CID000823
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Compliant
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Gold
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Jiangxi Copper Co., Ltd.
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CID000855
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Compliant
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Gold
|
JX Nippon Mining & Metals Co., Ltd.
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CID000937
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Compliant
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|
Gold
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Kazzinc
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CID000957
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Compliant
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Gold
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Kennecott Utah Copper LLC
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CID000969
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Compliant
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|
Gold
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KGHM Polska Miedz Spolka Akcyjna
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CID002511
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Compliant
|
|
Gold
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Kojima Chemicals Co., Ltd.
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CID000981
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Compliant
|
|
Gold
|
Korea Zinc Co., Ltd.
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CID002605
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Compliant
|
|
Gold
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L'Orfebre S.A.
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CID002762
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Compliant
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Gold
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LS-NIKKO Copper Inc.
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CID001078
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Compliant
|
|
Gold
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LT Metal Ltd.
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CID000689
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Compliant
|
|
Gold
|
Materion
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CID001113
|
Compliant
|
|
Gold
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Matsuda Sangyo Co., Ltd.
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CID001119
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Compliant
|
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Gold
|
Metal Concentrators SA (Pty) Ltd.
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CID003575
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Compliant
|
5
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Gold
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Metalor Technologies (Hong Kong) Ltd.
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CID001149
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Compliant
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|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
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CID001152
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Compliant
|
|
Gold
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Metalor Technologies (Suzhou) Ltd.
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CID001147
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Compliant
|
|
Gold
|
Metalor Technologies S.A.
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CID001153
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Compliant
|
|
Gold
|
Metalor USA Refining Corporation
|
CID001157
|
Compliant
|
|
Gold
|
Metalurgica Met-Mex Penoles S.A. De C.V.
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CID001161
|
Compliant
|
|
Gold
|
Mitsubishi Materials Corporation
|
CID001188
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Compliant
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
CID001193
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Compliant
|
|
Gold
|
MKS PAMP SA
|
CID001352
|
Compliant
|
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
CID002509
|
Compliant
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
CID001220
|
Compliant
|
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
CID001236
|
Compliant
|
|
Gold
|
NH Recytech Company
|
CID003189
|
Compliant
|
|
Gold
|
Nihon Material Co., Ltd.
|
CID001259
|
Compliant
|
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
CID002779
|
Compliant
|
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
CID001325
|
Compliant
|
|
Gold
|
Planta Recuperadora de Metales SpA
|
CID002919
|
Compliant
|
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
CID001397
|
Compliant
|
|
Gold
|
PX Precinox S.A.
|
CID001498
|
Compliant
|
|
Gold
|
Rand Refinery (Pty) Ltd.
|
CID001512
|
Compliant
|
|
Gold
|
REMONDIS PMR B.V.
|
CID002582
|
Compliant
|
|
Gold
|
Royal Canadian Mint
|
CID001534
|
Compliant
|
|
Gold
|
SAAMP
|
CID002761
|
Compliant
|
|
Gold
|
SAFINA A.S.
|
CID002290
|
Compliant
|
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
CID001585
|
Compliant
|
|
Gold
|
Shandong Gold Smelting Co., Ltd.
|
CID001916
|
Compliant
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CID001622
|
Compliant
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CID001736
|
Compliant
|
|
Gold
|
Solar Applied Materials Technology Corp.
|
CID001761
|
Compliant
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
CID001798
|
Compliant
|
|
Gold
|
SungEel HiMetal Co., Ltd.
|
CID002918
|
Compliant
|
|
Gold
|
T.C.A S.p.A
|
CID002580
|
Compliant
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
CID001875
|
Compliant
|
|
Gold
|
Tokuriki Honten Co., Ltd.
|
CID001938
|
Compliant
|
|
Gold
|
TOO Tau-Ken-Altyn
|
CID002615
|
Compliant
|
|
Gold
|
Torecom
|
CID001955
|
Compliant
|
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
CID001980
|
Compliant
|
|
Gold
|
United Precious Metal Refining, Inc.
|
CID001993
|
Compliant
|
|
Gold
|
Valcambi S.A.
|
CID002003
|
Compliant
|
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
CID002030
|
Compliant
|
|
Gold
|
WIELAND Edelmetalle GmbH
|
CID002778
|
Compliant
|
|
Gold
|
Yamakin Co., Ltd.
|
CID002100
|
Compliant
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
CID002129
|
Compliant
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CID002224
|
Compliant
|
|
Tantalum
|
AMG Brasil
|
CID001076
|
Compliant
|
|
Tantalum
|
D Block Metals, LLC
|
CID002504
|
Compliant
|
|
Tantalum
|
F&X Electro-Materials Ltd.
|
CID000460
|
Compliant
|
|
Tantalum
|
FIR Metals & Resource Ltd.
|
CID002505
|
Compliant
|
|
Tantalum
|
Global Advanced Metals Aizu
|
CID002558
|
Compliant
|
|
Tantalum
|
Global Advanced Metals Boyertown
|
CID002557
|
Compliant
|
6
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CID002492
|
Compliant
|
|
Tantalum
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
|
CID002512
|
Compliant
|
|
Tantalum
|
Jiangxi Tuohong New Raw Material
|
CID002842
|
Compliant
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
CID000914
|
Compliant
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
CID000917
|
Compliant
|
|
Tantalum
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
|
CID002506
|
Compliant
|
|
Tantalum
|
KEMET de Mexico
|
CID002539
|
Compliant
|
|
Tantalum
|
Materion Newton Inc.
|
CID002548
|
Compliant
|
|
Tantalum
|
Metallurgical Products India Pvt., Ltd.
|
CID001163
|
Compliant
|
|
Tantalum
|
Mineracao Taboca S.A.
|
CID001175
|
Compliant
|
|
Tantalum
|
Mitsui Mining and Smelting Co., Ltd.
|
CID001192
|
Compliant
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CID001277
|
Compliant
|
|
Tantalum
|
NPM Silmet AS
|
CID001200
|
Compliant
|
|
Tantalum
|
QuantumClean
|
CID001508
|
Compliant
|
|
Tantalum
|
Resind Industria e Comercio Ltda.
|
CID002707
|
Compliant
|
|
Tantalum
|
RFH Yancheng Jinye New Material Technology Co., Ltd.
|
CID003583
|
Compliant
|
|
Tantalum
|
Taki Chemical Co., Ltd.
|
CID001869
|
Compliant
|
|
Tantalum
|
TANIOBIS Co., Ltd.
|
CID002544
|
Compliant
|
|
Tantalum
|
TANIOBIS GmbH
|
CID002545
|
Compliant
|
|
Tantalum
|
TANIOBIS Japan Co., Ltd.
|
CID002549
|
Compliant
|
|
Tantalum
|
TANIOBIS Smelting GmbH & Co. KG
|
CID002550
|
Compliant
|
|
Tantalum
|
Telex Metals
|
CID001891
|
Compliant
|
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
CID001969
|
Compliant
|
|
Tantalum
|
XIMEI RESOURCES (GUANGDONG) LIMITED
|
CID000616
|
Compliant
|
|
Tantalum
|
XinXing HaoRong Electronic Material Co., Ltd.
|
CID002508
|
Compliant
|
|
Tantalum
|
Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
CID001522
|
Compliant
|
|
Tin
|
Alpha
|
CID000292
|
Compliant
|
|
Tin
|
Aurubis Beerse
|
CID002773
|
Compliant
|
|
Tin
|
Aurubis Berango
|
CID002774
|
Compliant
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
CID000228
|
Compliant
|
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
CID003190
|
Compliant
|
|
Tin
|
China Tin Group Co., Ltd.
|
CID001070
|
Compliant
|
|
Tin
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
|
CID003486
|
Compliant
|
|
Tin
|
CRM Synergies
|
CID003524
|
Compliant
|
|
Tin
|
CV Ayi Jaya
|
CID002570
|
Compliant
|
|
Tin
|
CV Venus Inti Perkasa
|
CID002455
|
Compliant
|
|
Tin
|
Dowa
|
CID000402
|
Compliant
|
|
Tin
|
EM Vinto
|
CID000438
|
Compliant
|
|
Tin
|
Estanho de Rondonia S.A.
|
CID000448
|
Compliant
|
|
Tin
|
Fabrica Auricchio Industria e Comercio Ltda.
|
CID003582
|
Compliant
|
|
Tin
|
Fenix Metals
|
CID000468
|
Compliant
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
CID000538
|
Compliant
|
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
CID003116
|
Compliant
|
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
CID001231
|
Compliant
|
|
Tin
|
Luna Smelter, Ltd.
|
CID003387
|
Compliant
|
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.
|
CID002468
|
Compliant
|
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
CID001105
|
Compliant
|
|
Tin
|
Metallic Resources, Inc.
|
CID001142
|
Compliant
|
|
Tin
|
Mineracao Taboca S.A.
|
CID001173
|
Compliant
|
|
Tin
|
Minsur
|
CID001182
|
Compliant
|
7
|
Tin
|
Mitsubishi Materials Corporation
|
CID001191
|
Compliant
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
CID001314
|
Compliant
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
CID002517
|
Compliant
|
|
Tin
|
Operaciones Metalurgicas S.A.
|
CID001337
|
Compliant
|
|
Tin
|
PT Aries Kencana Sejahtera
|
CID000309
|
Compliant
|
|
Tin
|
PT Artha Cipta Langgeng
|
CID001399
|
Compliant
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
CID002503
|
Compliant
|
|
Tin
|
PT Babel Inti Perkasa
|
CID001402
|
Compliant
|
|
Tin
|
PT Babel Surya Alam Lestari
|
CID001406
|
Compliant
|
|
Tin
|
PT Bangka Prima Tin
|
CID002776
|
Compliant
|
|
Tin
|
PT Bangka Serumpun
|
CID003205
|
Compliant
|
|
Tin
|
PT Bukit Timah
|
CID001428
|
Compliant
|
|
Tin
|
PT Cipta Persada Mulia
|
CID002696
|
Compliant
|
|
Tin
|
PT Menara Cipta Mulia
|
CID002835
|
Compliant
|
|
Tin
|
PT Mitra Stania Prima
|
CID001453
|
Compliant
|
|
Tin
|
PT Mitra Sukses Globalindo
|
CID003449
|
Compliant
|
|
Tin
|
PT Prima Timah Utama
|
CID001458
|
Compliant
|
|
Tin
|
PT Putera Sarana Shakti (PT PSS)
|
CID003868
|
Compliant
|
|
Tin
|
PT Rajawali Rimba Perkasa
|
CID003381
|
Compliant
|
|
Tin
|
PT Rajehan Ariq
|
CID002593
|
Compliant
|
|
Tin
|
PT Refined Bangka Tin
|
CID001460
|
Compliant
|
|
Tin
|
PT Sariwiguna Binasentosa
|
CID001463
|
Compliant
|
|
Tin
|
PT Stanindo Inti Perkasa
|
CID001468
|
Compliant
|
|
Tin
|
PT Sukses Inti Makmur
|
CID002816
|
Compliant
|
|
Tin
|
PT Timah Tbk Kundur
|
CID001477
|
Compliant
|
|
Tin
|
PT Timah Tbk Mentok
|
CID001482
|
Compliant
|
|
Tin
|
PT Tommy Utama
|
CID001493
|
Compliant
|
|
Tin
|
Resind Industria e Comercio Ltda.
|
CID002706
|
Compliant
|
|
Tin
|
Rui Da Hung
|
CID001539
|
Compliant
|
|
Tin
|
Thaisarco
|
CID001898
|
Compliant
|
|
Tin
|
Tin Smelting Branch of Yunnan Tin Co., Ltd.
|
CID002180
|
Compliant
|
|
Tin
|
Tin Technology & Refining
|
CID003325
|
Compliant
|
|
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
CID002036
|
Compliant
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
CID002158
|
Compliant
|
|
Tungsten
|
A.L.M.T. Corp.
|
CID000004
|
Compliant
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
CID002502
|
Compliant
|
|
Tungsten
|
China Molybdenum Tungsten Co., Ltd.
|
CID002641
|
Compliant
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CID000258
|
Compliant
|
|
Tungsten
|
Cronimet Brasil Ltda
|
CID003468
|
Compliant
|
|
Tungsten
|
Fujian Xinlu Tungsten Co., Ltd.
|
CID003609
|
Compliant
|
|
Tungsten
|
Ganzhou Haichuang Tungsten Co., Ltd.
|
CID002645
|
Compliant
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CID000875
|
Compliant
|
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CID002315
|
Compliant
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CID002494
|
Compliant
|
|
Tungsten
|
Global Tungsten & Powders LLC
|
CID000568
|
Compliant
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CID000218
|
Compliant
|
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
CID002541
|
Compliant
|
|
Tungsten
|
Hubei Green Tungsten Co., Ltd.
|
CID003417
|
Compliant
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
CID000766
|
Compliant
|
|
Tungsten
|
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
|
CID002513
|
Compliant
|
8
|
Tungsten
|
Japan New Metals Co., Ltd.
|
CID000825
|
Compliant
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CID002551
|
Compliant
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CID002321
|
Compliant
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CID002318
|
Compliant
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CID002317
|
Compliant
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CID002316
|
Compliant
|
|
Tungsten
|
Kennametal Fallon
|
CID000966
|
Compliant
|
|
Tungsten
|
Kennametal Huntsville
|
CID000105
|
Compliant
|
|
Tungsten
|
Lianyou Metals Co., Ltd.
|
CID003407
|
Compliant
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CID002319
|
Compliant
|
|
Tungsten
|
Masan High-Tech Materials
|
CID002543
|
Compliant
|
|
Tungsten
|
Niagara Refining LLC
|
CID002589
|
Compliant
|
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
CID002827
|
Compliant
|
|
Tungsten
|
TANIOBIS Smelting GmbH & Co. KG
|
CID002542
|
Compliant
|
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
CID002044
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CID002320
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CID002082
|
Compliant
|
|
Not Validated
|
|||
| Tin |
PT Belitung Industri Sejahtera
|
CID001421
|
On CFSP Active List(a)
|
| Tin |
PT Timah Nusantara
|
CID001486
|
On CFSP Active List(a)
|
| Tin |
Super Ligas
|
CID002756
|
On CFSP Active List(a)
|
|
Gold
|
Samduck Precious Metals
|
CID001555
|
Non-compliant(b)
|
|
Gold
|
Umicore Precious Metals Thailand
|
CID002314
|
Non-compliant(b)
|
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
CID000555
|
Non-compliant(b)
|
|
Tin
|
PT Tinindo Inter Nusa
|
CID001490
|
Non-compliant(b)
|
|
Tungsten
|
ACL Metais Eireli
|
CID002833
|
Non-compliant(b)
|
|
Tungsten
|
Hunan Jintai New Material Co., Ltd.
|
CID000769
|
Non-compliant(b)
|
| Tin |
Gejiu Kai Meng Industry and Trade LLC
|
CID000942
|
Non-compliant(c)
|
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
CID001908
|
Non-compliant(c)
|
| (a) |
Smelters and refiners on the CFSP Active List are currently in the process of becoming compliant.
|
||
| (b) |
Smelter became non-compliant in 2023, subsequent to the end of the reporting period for this report. Vishay's suppliers are working with these smelters to resolve
these issues.
|
||
| (c) |
Smelter became non-compliant in 2022. Vishay is working with its suppliers to remove these smelters from the supply chain. | ||
9