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, 2018.
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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 28, 2019
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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 28, 2019
Conflict Minerals Report
For the Year Ended December 31, 2018
This report for the year ended December 31, 2018 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 resistive products, capacitors, and inductors. Discrete semiconductors and passive components
are essential elements of virtually every type of electronic circuit. They support the microprocessor chips and other integrated circuits ("ICs") that coordinate and control the functions of electronic devices and equipment. 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 15, 2019.
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 Responsible Minerals 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% of the dollar value of 2018 in-scope procurement activities. The survey responses identified 229 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 Conflict Minerals 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 Conflict Mineral 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 Conflict Minerals Policy and Program. Vishay
has established a management system for 3TG, which includes a core team of the 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 Conflict Minerals
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 hotline. The contact
information for the ethics hotline 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 semi-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 UltraSource, Inc. ("UltraSource"), a U.S.-based, privately-held thin film circuit and thin film interconnect manufacturer, acquired in
2018. A substantial number of UltraSource's products utilize one or more 3TG necessary to the functionality or production of such products. UltraSource's products will be covered commencing with Vishay's Conflict Minerals report for 2019.
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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 2018. We have increased the number and percentage of validated "conflict free" smelters and
refiners from 53, or 49%, in 2013 to 126, or 76%, in 2014 to 163, or 94%, in 2015 to 216, or 96%, in 2016 to 221 or 99% in 2017, to 228, or 99.6%, in 2018.
4
As of May 13, 2019 our smelters and refiners identified by our suppliers are listed below:
| Metal |
Smelter Reference List |
Smelter ID |
RMI Status |
| Validated as "Conflict Free" |
|||
|
Tin
|
Minsur
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CID001182
|
Compliant
|
|
Tin
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PT Timah Tbk Mentok
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CID001482
|
Compliant
|
|
Tin
|
Malaysia Smelting Corporation (MSC)
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CID001105
|
Compliant
|
|
Tin
|
PT Timah Tbk Kundur
|
CID001477
|
Compliant
|
|
Tin
|
Thaisarco
|
CID001898
|
Compliant
|
|
Tin
|
Metallo Belgium N.V.
|
CID002773
|
Compliant
|
|
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
CID002036
|
Compliant
|
|
Tin
|
Mineracao Taboca S.A.
|
CID001173
|
Compliant
|
|
Tin
|
PT Mitra Stania Prima
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CID001453
|
Compliant
|
|
Tin
|
PT Tinindo Inter Nusa
|
CID001490
|
Compliant
|
|
Tin
|
Yunnan Tin Company Limited
|
CID002180
|
Compliant
|
|
Tin
|
CV Venus Inti Perkasa
|
CID002455
|
Compliant
|
|
Tin
|
Rui Da Hung
|
CID001539
|
Compliant
|
|
Tin
|
PT Refined Bangka Tin
|
CID001460
|
Compliant
|
|
Tin
|
PT Bangka Tin Industry
|
CID001419
|
Compliant
|
|
Tin
|
Operaciones Metalurgicas S.A.
|
CID001337
|
Compliant
|
|
Tin
|
PT DS Jaya Abadi
|
CID001434
|
Compliant
|
|
Tin
|
CV United Smelting
|
CID000315
|
Compliant
|
|
Tin
|
PT Bukit Timah
|
CID001428
|
Compliant
|
|
Gold
|
Metalor USA Refining Corporation
|
CID001157
|
Compliant
|
|
Tin
|
PT Stanindo Inti Perkasa
|
CID001468
|
Compliant
|
|
Tin
|
PT Bangka Prima Tin
|
CID002776
|
Compliant
|
|
Tin
|
Fenix Metals
|
CID000468
|
Compliant
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
CID000538
|
Compliant
|
|
Gold
|
Metalor Technologies S.A.
|
CID001153
|
Compliant
|
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG
|
CID000711
|
Compliant
|
|
Tin
|
PT Prima Timah Utama
|
CID001458
|
Compliant
|
|
Tin
|
PT Sariwiguna Binasentosa
|
CID001463
|
Compliant
|
|
Gold
|
Royal Canadian Mint
|
CID001534
|
Compliant
|
|
Tin
|
PT Menara Cipta Mulia
|
CID002835
|
Compliant
|
|
Gold
|
Heraeus Metals Hong Kong Ltd.
|
CID000707
|
Compliant
|
|
Tin
|
EM Vinto
|
CID000438
|
Compliant
|
|
Tin
|
China Tin Group Co., Ltd.
|
CID001070
|
Compliant
|
|
Tin
|
PT Belitung Industri Sejahtera
|
CID001421
|
Compliant
|
|
Tin
|
PT Aries Kencana Sejahtera
|
CID000309
|
Compliant
|
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
CID001980
|
Compliant
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
CID002503
|
Compliant
|
|
Tin
|
Alpha
|
CID000292
|
Compliant
|
|
Tin
|
PT Babel Inti Perkasa
|
CID001402
|
Compliant
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
CID002158
|
Compliant
|
|
Gold
|
United Precious Metal Refining, Inc.
|
CID001993
|
Compliant
|
|
Tin
|
PT Inti Stania Prima
|
CID002530
|
Compliant
|
|
Tin
|
PT Sukses Inti Makmur
|
CID002816
|
Compliant
|
|
Gold
|
Kennecott Utah Copper LLC
|
CID000969
|
Compliant
|
|
Tin
|
PT Rajehan Ariq
|
CID002593
|
Compliant
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
CID001149
|
Compliant
|
|
Gold
|
Metalurgica Met-Mex Penoles S.A. De C.V.
|
CID001161
|
Compliant
|
|
Tin
|
PT Tommy Utama
|
CID001493
|
Compliant
|
|
Gold
|
Asahi Refining Canada Ltd.
|
CID000924
|
Compliant
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
CID001875
|
Compliant
|
5
|
Gold
|
Umicore Brasil Ltda.
|
CID001977
|
Compliant
|
|
Tin
|
PT Artha Cipta Langgeng
|
CID001399
|
Compliant
|
|
Gold
|
Allgemeine Gold-und Silberscheideanstalt A.G.
|
CID000035
|
Compliant
|
|
Gold
|
CCR Refinery - Glencore Canada Corporation
|
CID000185
|
Compliant
|
|
Tin
|
Mitsubishi Materials Corporation
|
CID001191
|
Compliant
|
|
Gold
|
Argor-Heraeus S.A.
|
CID000077
|
Compliant
|
|
Tin
|
PT Panca Mega Persada
|
CID001457
|
Compliant
|
|
Gold
|
Asahi Refining USA Inc.
|
CID000920
|
Compliant
|
|
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
CID001147
|
Compliant
|
|
Gold
|
Heimerle + Meule GmbH
|
CID000694
|
Compliant
|
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
CID001152
|
Compliant
|
|
Tin
|
CV Dua Sekawan
|
CID002592
|
Compliant
|
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
CID003116
|
Compliant
|
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
CID001119
|
Compliant
|
|
Tin
|
Metallic Resources, Inc.
|
CID001142
|
Compliant
|
|
Gold
|
Aurubis AG
|
CID000113
|
Compliant
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CID001622
|
Compliant
|
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
CID002030
|
Compliant
|
|
Gold
|
C. Hafner GmbH + Co. KG
|
CID000176
|
Compliant
|
|
Gold
|
Asahi Pretec Corp.
|
CID000082
|
Compliant
|
|
Tin
|
Dowa
|
CID000402
|
Compliant
|
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
CID001231
|
Compliant
|
|
Gold
|
Materion
|
CID001113
|
Compliant
|
|
Gold
|
Solar Applied Materials Technology Corp.
|
CID001761
|
Compliant
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
CID001798
|
Compliant
|
|
Gold
|
Chimet S.p.A.
|
CID000233
|
Compliant
|
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
CID000942
|
Compliant
|
|
Gold
|
Mitsubishi Materials Corporation
|
CID001188
|
Compliant
|
|
Tin
|
Soft Metais Ltda.
|
CID001758
|
Compliant
|
|
Gold
|
PAMP S.A.
|
CID001352
|
Compliant
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
CID000228
|
Compliant
|
|
Tin
|
Metallo Spain S.L.U.
|
CID002774
|
Compliant
|
|
Gold
|
AngloGold Ashanti Corrego do Sitio Mineracao
|
CID000058
|
Compliant
|
|
Gold
|
Boliden AB
|
CID000157
|
Compliant
|
|
Gold
|
Dowa
|
CID000401
|
Compliant
|
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
CID000937
|
Compliant
|
|
Gold
|
Ishifuku Metal Industry Co., Ltd.
|
CID000807
|
Compliant
|
|
Tin
|
Magnu's Minerais Metais e Ligas Ltda.
|
CID002468
|
Compliant
|
|
Tin
|
Melt Metais e Ligas S.A.
|
CID002500
|
Compliant
|
|
Gold
|
LS-NIKKO Copper Inc.
|
CID001078
|
Compliant
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
CID001193
|
Compliant
|
|
Gold
|
Nihon Material Co., Ltd.
|
CID001259
|
Compliant
|
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
CID001585
|
Compliant
|
|
Gold
|
Tokuriki Honten Co., Ltd.
|
CID001938
|
Compliant
|
|
Tin
|
PT Sumber Jaya Indah
|
CID001471
|
Compliant
|
|
Gold
|
Istanbul Gold Refinery
|
CID000814
|
Compliant
|
|
Tin
|
Resind Industria e Comercio Ltda.
|
CID002706
|
Compliant
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
CID002517
|
Compliant
|
|
Gold
|
Aida Chemical Industries Co., Ltd.
|
CID000019
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CID002082
|
Compliant
|
6
|
Gold
|
Asaka Riken Co., Ltd.
|
CID000090
|
Compliant
|
|
Tin
|
PT Bangka Serumpun
|
CID003205
|
Compliant
|
|
Tin
|
PT Premium Tin Indonesia
|
CID000313
|
Compliant
|
|
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
CID000760
|
Compliant
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
CID001314
|
Compliant
|
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
CID001908
|
Compliant
|
|
Tin
|
PT Kijang Jaya Mandiri
|
CID002829
|
Compliant
|
|
Tin
|
Guanyang Guida Nonferrous Metal Smelting Plant
|
CID002849
|
Compliant
|
|
Tin
|
Gejiu Fengming Metallurgy Chemical Plant
|
CID002848
|
Compliant
|
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
CID001916
|
Compliant
|
|
Tin
|
CV Gita Pesona
|
CID000306
|
Compliant
|
|
Gold
|
SAXONIA Edelmetalle GmbH
|
CID002777
|
Compliant
|
|
Gold
|
WIELAND Edelmetalle GmbH
|
CID002778
|
Compliant
|
|
Gold
|
Kojima Chemicals Co., Ltd.
|
CID000981
|
Compliant
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CID002224
|
Compliant
|
|
Gold
|
Advanced Chemical Company
|
CID000015
|
Compliant
|
|
Gold
|
Rand Refinery (Pty) Ltd.
|
CID001512
|
Compliant
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CID000875
|
Compliant
|
|
Gold
|
Valcambi S.A.
|
CID002003
|
Compliant
|
|
Tungsten
|
Global Tungsten & Powders Corp.
|
CID000568
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CID002320
|
Compliant
|
|
Gold
|
DODUCO Contacts and Refining GmbH
|
CID000362
|
Compliant
|
|
Gold
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
|
CID000801
|
Compliant
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CID000258
|
Compliant
|
|
Tin
|
Modeltech Sdn Bhd
|
CID002858
|
Compliant
|
|
Gold
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
|
CID000128
|
Compliant
|
|
Gold
|
Eco-System Recycling Co., Ltd.
|
CID000425
|
Compliant
|
|
Gold
|
Geib Refining Corporation
|
CID002459
|
Compliant
|
|
Gold
|
OJSC Novosibirsk Refinery
|
CID000493
|
Compliant
|
|
Gold
|
Kazzinc
|
CID000957
|
Compliant
|
|
Gold
|
Japan Mint
|
CID000823
|
Compliant
|
|
Gold
|
Jiangxi Copper Co., Ltd.
|
CID000855
|
Compliant
|
|
Gold
|
Al Etihad Gold Refinery DMCC
|
CID002560
|
Compliant
|
|
Gold
|
Emirates Gold DMCC
|
CID002561
|
Compliant
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
CID001220
|
Compliant
|
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
CID001325
|
Compliant
|
|
Tungsten
|
Japan New Metals Co., Ltd.
|
CID000825
|
Compliant
|
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
CID001386
|
Compliant
|
|
Gold
|
PT Aneka Tambang (Persero) Tbk
|
CID001397
|
Compliant
|
|
Gold
|
PX Precinox S.A.
|
CID001498
|
Compliant
|
|
Gold
|
Umicore Precious Metals Thailand
|
CID002314
|
Compliant
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
CID001756
|
Compliant
|
|
Gold
|
Almalyk Mining and Metallurgical Complex (AMMC)
|
CID000041
|
Compliant
|
|
Gold
|
Yamakin Co., Ltd.
|
CID002100
|
Compliant
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
CID002129
|
Compliant
|
|
Gold
|
Gold Refinery of Zijin Mining Group Co., Ltd.
|
CID002243
|
Compliant
|
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
CID002844
|
Compliant
|
|
Gold
|
Daejin Indus Co., Ltd.
|
CID000328
|
Compliant
|
|
Gold
|
Kyrgyzaltyn JSC
|
CID001029
|
Compliant
|
|
Gold
|
JSC Uralelectromed
|
CID000929
|
Compliant
|
7
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
CID003190
|
Compliant
|
|
Gold
|
Moscow Special Alloys Processing Plant
|
CID001204
|
Compliant
|
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
CID001326
|
Compliant
|
|
Gold
|
T.C.A S.p.A
|
CID002580
|
Compliant
|
|
Gold
|
Singway Technology Co., Ltd.
|
CID002516
|
Compliant
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CID002494
|
Compliant
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CID001736
|
Compliant
|
|
Gold
|
Korea Zinc Co., Ltd.
|
CID002605
|
Compliant
|
|
Gold
|
Torecom
|
CID001955
|
Compliant
|
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
CID002509
|
Compliant
|
|
Gold
|
DSC (Do Sung Corporation)
|
CID000359
|
Compliant
|
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
CID002779
|
Compliant
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
CID000769
|
Compliant
|
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
CID002541
|
Compliant
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CID001277
|
Compliant
|
|
Gold
|
AU Traders and Refiners
|
CID002850
|
Compliant
|
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
CID001969
|
Compliant
|
|
Gold
|
SungEel HiMetal Co., Ltd.
|
CID002918
|
Compliant
|
|
Gold
|
Planta Recuperadora de Metales SpA
|
CID002919
|
Compliant
|
|
Gold
|
SAAMP
|
CID002761
|
Compliant
|
|
Gold
|
Italpreziosi
|
CID002765
|
Compliant
|
|
Gold
|
Safimet S.p.A
|
CID002973
|
Compliant
|
|
Gold
|
Marsam Metals
|
CID002606
|
Compliant
|
|
Gold
|
HeeSung Metal Ltd.
|
CID000689
|
Compliant
|
|
Gold
|
Cendres + Metaux S.A.
|
CID000189
|
Compliant
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CID002316
|
Compliant
|
|
Tungsten
|
Kennametal Huntsville
|
CID000105
|
Compliant
|
|
Tungsten
|
Masan Tungsten Chemical LLC (MTC)
|
CID002543
|
Compliant
|
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
CID002044
|
Compliant
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CID002551
|
Compliant
|
|
Tungsten
|
Hydrometallurg, JSC
|
CID002649
|
Compliant
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
CID000766
|
Compliant
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CID002321
|
Compliant
|
|
Tungsten
|
A.L.M.T. Corp.
|
CID000004
|
Compliant
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CID002317
|
Compliant
|
|
Tungsten
|
Niagara Refining LLC
|
CID002589
|
Compliant
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
CID000499
|
Compliant
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co. KG
|
CID002542
|
Compliant
|
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
CID002095
|
Compliant
|
|
Tantalum
|
F&X Electro-Materials Ltd.
|
CID000460
|
Compliant
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
CID000917
|
Compliant
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CID000218
|
Compliant
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CID002318
|
Compliant
|
|
Tungsten
|
Unecha Refractory metals plant
|
CID002724
|
Compliant
|
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
CID002579
|
Compliant
|
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
CID002827
|
Compliant
|
|
Tungsten
|
Kennametal Fallon
|
CID000966
|
Compliant
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CID002319
|
Compliant
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
CID002513
|
Compliant
|
|
Tantalum
|
H.C. Starck Tantalum and Niobium GmbH
|
CID002545
|
Compliant
|
8
|
Tungsten
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
CID002830
|
Compliant
|
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CID002315
|
Compliant
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
CID001889
|
Compliant
|
|
Tantalum
|
Global Advanced Metals Boyertown
|
CID002557
|
Compliant
|
|
Tungsten
|
ACL Metais Eireli
|
CID002833
|
Compliant
|
|
Tungsten
|
Moliren Ltd.
|
CID002845
|
Compliant
|
|
Tantalum
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
CID000291
|
Compliant
|
|
Tungsten
|
Woltech Korea Co., Ltd.
|
CID002843
|
Compliant
|
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
CID000616
|
Compliant
|
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CID002492
|
Compliant
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
CID000914
|
Compliant
|
|
Tungsten
|
South-East Nonferrous Metal Company Limited of Hengyang City
|
CID002815
|
Compliant
|
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
CID000555
|
Compliant
|
|
Tin
|
Tin Technology & Refining
|
CID003325
|
Compliant
|
|
Gold
|
L'Orfebre S.A.
|
CID002762
|
Compliant
|
|
Gold
|
REMONDIS PMR B.V.
|
CID002582
|
Compliant
|
|
Tantalum
|
H.C. Starck Co., Ltd.
|
CID002544
|
Compliant
|
|
Tantalum
|
H.C. Starck Inc.
|
CID002548
|
Compliant
|
|
Tantalum
|
H.C. Starck Smelting GmbH & Co. KG
|
CID002550
|
Compliant
|
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
CID000211
|
Compliant
|
|
Tantalum
|
Exotech Inc.
|
CID000456
|
Compliant
|
|
Tantalum
|
NPM Silmet AS
|
CID001200
|
Compliant
|
|
Tantalum
|
H.C. Starck Ltd.
|
CID002549
|
Compliant
|
|
Tantalum
|
D Block Metals, LLC
|
CID002504
|
Compliant
|
|
Tantalum
|
FIR Metals & Resource Ltd.
|
CID002505
|
Compliant
|
|
Tantalum
|
LSM Brasil S.A.
|
CID001076
|
Compliant
|
|
Tantalum
|
Mineracao Taboca S.A.
|
CID001175
|
Compliant
|
|
Tantalum
|
Telex Metals
|
CID001891
|
Compliant
|
| Not Validated |
|||
|
Gold
|
Samduck Precious Metals
|
CID001555
|
Non-compliant
|
9