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, 2019.
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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 20, 2020
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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 20, 2020
Conflict Minerals Report
For the Year Ended December 31, 2019
This report for the year ended December 31, 2019 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 14, 2020.
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
99.8% of the dollar value of 2019 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 comprising of Senior management and is sponsored by the Assistant to the Chief Executive Officer ("CEO"). 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 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 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.
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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 2019. 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, to 227, or 99.1% in 2019.
4
As of May 5, 2020 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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Tantalum
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Resind Industria e Comercio Ltda.
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CID002707
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Compliant
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Tantalum
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Asaka Riken Co., Ltd.
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CID000092
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Compliant
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Tantalum
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KEMET Blue Metals
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CID002539
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Compliant
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Tantalum
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H.C. Starck Co., Ltd.
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CID002544
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Compliant
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Tantalum
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H.C. Starck Tantalum and Niobium GmbH
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CID002545
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Compliant
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Tantalum
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H.C. Starck Hermsdorf GmbH
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CID002547
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Compliant
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Tantalum
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H.C. Starck Inc.
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CID002548
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Compliant
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Tantalum
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H.C. Starck Ltd.
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CID002549
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Compliant
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Tantalum
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H.C. Starck Smelting GmbH & Co. KG
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CID002550
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Compliant
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Tantalum
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Global Advanced Metals Boyertown
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CID002557
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Compliant
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Tantalum
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Global Advanced Metals Aizu
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CID002558
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Compliant
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Tantalum
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PRG Dooel
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CID002847
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Compliant
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Tantalum
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Changsha South Tantalum Niobium Co., Ltd.
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CID000211
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Compliant
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Tantalum
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Exotech Inc.
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CID000456
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Compliant
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Tantalum
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Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
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CID002512
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Compliant
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Tantalum
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D Block Metals, LLC
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CID002504
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Compliant
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Tantalum
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Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
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CID002506
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Compliant
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Tantalum
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Jiangxi Tuohong New Raw Material
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CID002842
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Compliant
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Tantalum
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F&X Electro-Materials Ltd.
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CID000460
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Compliant
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Tantalum
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Guangdong Zhiyuan New Material Co., Ltd.
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CID000616
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Compliant
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Tantalum
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Hengyang King Xing Lifeng New Materials Co., Ltd.
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CID002492
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Compliant
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Tantalum
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JiuJiang JinXin Nonferrous Metals Co., Ltd.
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CID000914
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Compliant
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Tantalum
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Jiujiang Tanbre Co., Ltd.
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CID000917
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Compliant
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Tantalum
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FIR Metals & Resource Ltd.
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CID002505
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Compliant
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Tantalum
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XinXing HaoRong Electronic Material Co., Ltd.
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CID002508
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Compliant
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Tantalum
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LSM Brasil S.A.
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CID001076
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Compliant
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Tantalum
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Metallurgical Products India Pvt., Ltd.
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CID001163
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Compliant
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Tantalum
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Mineracao Taboca S.A.
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CID001175
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Compliant
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Tantalum
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Mitsui Mining and Smelting Co., Ltd.
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CID001192
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Compliant
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Tantalum
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NPM Silmet AS
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CID001200
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Compliant
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Tantalum
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Ningxia Orient Tantalum Industry Co., Ltd.
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CID001277
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Compliant
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Tantalum
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QuantumClean
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CID001508
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Compliant
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Tantalum
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Yanling Jincheng Tantalum & Niobium Co., Ltd.
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CID001522
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Compliant
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Tantalum
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Solikamsk Magnesium Works OAO
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CID001769
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Compliant
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Tantalum
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Taki Chemical Co., Ltd.
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CID001869
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Compliant
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Tantalum
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Telex Metals
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CID001891
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Compliant
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Tantalum
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Ulba Metallurgical Plant JSC
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CID001969
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Compliant
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|
Tin
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Fenix Metals
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CID000468
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Compliant
|
|
Tin
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Gejiu Non-Ferrous Metal Processing Co., Ltd.
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CID000538
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Compliant
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|
Tin
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EM Vinto
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CID000438
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Compliant
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|
Tin
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Gejiu Zili Mining And Metallurgy Co., Ltd.
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CID000555
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Compliant
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|
Tin
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Dowa
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CID000402
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Compliant
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|
Tin
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Tin Technology & Refining
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CID003325
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Compliant
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|
Tin
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Huichang Jinshunda Tin Co., Ltd.
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CID000760
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Compliant
|
|
Tin
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Gejiu Kai Meng Industry and Trade LLC
|
CID000942
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Compliant
|
5
|
Tin
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Magnu's Minerais Metais e Ligas Ltda.
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CID002468
|
Compliant
|
|
Tin
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Malaysia Smelting Corporation (MSC)
|
CID001105
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Compliant
|
|
Tin
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Jiangxi New Nanshan Technology Ltd.
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CID001231
|
Compliant
|
|
Tin
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Melt Metais e Ligas S.A.
|
CID002500
|
Compliant
|
|
Tin
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Mineracao Taboca S.A.
|
CID001173
|
Compliant
|
|
Tin
|
Minsur
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CID001182
|
Compliant
|
|
Tin
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Mitsubishi Materials Corporation
|
CID001191
|
Compliant
|
|
Tin
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O.M. Manufacturing (Thailand) Co., Ltd.
|
CID001314
|
Compliant
|
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
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CID003116
|
Compliant
|
|
Tin
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Operaciones Metalurgicas S.A.
|
CID001337
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Compliant
|
|
Tin
|
PT Artha Cipta Langgeng
|
CID001399
|
Compliant
|
|
Tin
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Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
CID001908
|
Compliant
|
|
Tin
|
PT Mitra Stania Prima
|
CID001453
|
Compliant
|
|
Tin
|
PT Refined Bangka Tin
|
CID001460
|
Compliant
|
|
Tin
|
Resind Industria e Comercio Ltda.
|
CID002706
|
Compliant
|
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
CID003190
|
Compliant
|
|
Tin
|
PT Timah Tbk Kundur
|
CID001477
|
Compliant
|
|
Tin
|
PT Timah Tbk Mentok
|
CID001482
|
Compliant
|
|
Tin
|
Rui Da Hung
|
CID001539
|
Compliant
|
|
Tin
|
Soft Metais Ltda.
|
CID001758
|
Compliant
|
|
Tin
|
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
|
CID003397
|
Compliant
|
|
Tin
|
Thaisarco
|
CID001898
|
Compliant
|
|
Tin
|
White Solder Metalurgia e Mineracao Ltda.
|
CID002036
|
Compliant
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
CID002158
|
Compliant
|
|
Tin
|
Yunnan Tin Company Limited
|
CID002180
|
Compliant
|
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
CID000228
|
Compliant
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
CID002517
|
Compliant
|
|
Tin
|
Guanyang Guida Nonferrous Metal Smelting Plant
|
CID002849
|
Compliant
|
|
Tin
|
Ma'anshan Weitai Tin Co., Ltd.
|
CID003379
|
Compliant
|
|
Tin
|
Metallo Belgium N.V.
|
CID002773
|
Compliant
|
|
Tin
|
Metallo Spain S.L.U.
|
CID002774
|
Compliant
|
|
Tin
|
Thai Nguyen Mining and Metallurgy Co., Ltd.
|
CID002834
|
Compliant
|
|
Tin
|
PT Menara Cipta Mulia
|
CID002835
|
Compliant
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
CID002503
|
Compliant
|
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
CID002844
|
Compliant
|
|
Tin
|
Metallic Resources, Inc.
|
CID001142
|
Compliant
|
|
Tin
|
Alpha
|
CID000292
|
Compliant
|
|
Tin
|
China Tin Group Co., Ltd.
|
CID001070
|
Compliant
|
|
Gold
|
Geib Refining Corporation
|
CID002459
|
Compliant
|
|
Gold
|
SAXONIA Edelmetalle GmbH
|
CID002777
|
Compliant
|
|
Gold
|
WIELAND Edelmetalle GmbH
|
CID002778
|
Compliant
|
|
Gold
|
OJSC Novosibirsk Refinery
|
CID000493
|
Compliant
|
|
Gold
|
Heimerle + Meule GmbH
|
CID000694
|
Compliant
|
|
Gold
|
Heraeus Metals Hong Kong Ltd.
|
CID000707
|
Compliant
|
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG
|
CID000711
|
Compliant
|
6
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
CID002779
|
Compliant
|
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
CID000937
|
Compliant
|
|
Gold
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
|
CID000801
|
Compliant
|
|
Gold
|
Kazzinc
|
CID000957
|
Compliant
|
|
Gold
|
Ishifuku Metal Industry Co., Ltd.
|
CID000807
|
Compliant
|
|
Gold
|
Kennecott Utah Copper LLC
|
CID000969
|
Compliant
|
|
Gold
|
Istanbul Gold Refinery
|
CID000814
|
Compliant
|
|
Gold
|
Kojima Chemicals Co., Ltd.
|
CID000981
|
Compliant
|
|
Gold
|
Japan Mint
|
CID000823
|
Compliant
|
|
Gold
|
Jiangxi Copper Co., Ltd.
|
CID000855
|
Compliant
|
|
Gold
|
Kyrgyzaltyn JSC
|
CID001029
|
Compliant
|
|
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
CID001147
|
Compliant
|
|
Gold
|
Asahi Refining USA Inc.
|
CID000920
|
Compliant
|
|
Gold
|
Asahi Refining Canada Ltd.
|
CID000924
|
Compliant
|
|
Gold
|
LS-NIKKO Copper Inc.
|
CID001078
|
Compliant
|
|
Gold
|
JSC Uralelectromed
|
CID000929
|
Compliant
|
|
Gold
|
SungEel HiMetal Co., Ltd.
|
CID002918
|
Compliant
|
|
Gold
|
Materion
|
CID001113
|
Compliant
|
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
CID001119
|
Compliant
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
CID001149
|
Compliant
|
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
CID001152
|
Compliant
|
|
Gold
|
Metalor Technologies S.A.
|
CID001153
|
Compliant
|
|
Gold
|
Metalor USA Refining Corporation
|
CID001157
|
Compliant
|
|
Gold
|
Planta Recuperadora de Metales SpA
|
CID002919
|
Compliant
|
|
Gold
|
Al Etihad Gold Refinery DMCC
|
CID002560
|
Compliant
|
|
Gold
|
Emirates Gold DMCC
|
CID002561
|
Compliant
|
|
Gold
|
Metalurgica Met-Mex Penoles S.A. De C.V.
|
CID001161
|
Compliant
|
|
Gold
|
Mitsubishi Materials Corporation
|
CID001188
|
Compliant
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd.
|
CID001193
|
Compliant
|
|
Gold
|
Moscow Special Alloys Processing Plant
|
CID001204
|
Compliant
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
CID001220
|
Compliant
|
|
Gold
|
DS PRETECH Co., Ltd.
|
CID003195
|
Compliant
|
|
Gold
|
Nihon Material Co., Ltd.
|
CID001259
|
Compliant
|
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
CID001325
|
Compliant
|
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
CID001326
|
Compliant
|
|
Gold
|
PAMP S.A.
|
CID001352
|
Compliant
|
|
Gold
|
KGHM Polska Miedz Spolka Akcyjna
|
CID002511
|
Compliant
|
|
Gold
|
SAAMP
|
CID002761
|
Compliant
|
|
Gold
|
L'Orfebre S.A.
|
CID002762
|
Compliant
|
|
Gold
|
8853 S.p.A.
|
CID002763
|
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
|
Rand Refinery (Pty) Ltd.
|
CID001512
|
Compliant
|
|
Gold
|
Royal Canadian Mint
|
CID001534
|
Compliant
|
7
|
Gold
|
Italpreziosi
|
CID002765
|
Compliant
|
|
Gold
|
T.C.A S.p.A
|
CID002580
|
Compliant
|
|
Gold
|
REMONDIS PMR B.V.
|
CID002582
|
Compliant
|
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
CID001585
|
Compliant
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CID001622
|
Compliant
|
|
Gold
|
Umicore Precious Metals Thailand
|
CID002314
|
Compliant
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
CID001756
|
Compliant
|
|
Gold
|
Umicore S.A. Business Unit Precious Metals Refining
|
CID001980
|
Compliant
|
|
Gold
|
Singway Technology Co., Ltd.
|
CID002516
|
Compliant
|
|
Gold
|
Safimet S.p.A
|
CID002973
|
Compliant
|
|
Gold
|
Aida Chemical Industries Co., Ltd.
|
CID000019
|
Compliant
|
|
Gold
|
Allgemeine Gold-und Silberscheideanstalt A.G.
|
CID000035
|
Compliant
|
|
Gold
|
Almalyk Mining and Metallurgical Complex (AMMC)
|
CID000041
|
Compliant
|
|
Gold
|
Solar Applied Materials Technology Corp.
|
CID001761
|
Compliant
|
|
Gold
|
United Precious Metal Refining, Inc.
|
CID001993
|
Compliant
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd.
|
CID001798
|
Compliant
|
|
Gold
|
Valcambi S.A.
|
CID002003
|
Compliant
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
CID001875
|
Compliant
|
|
Gold
|
Western Australian Mint (T/a The Perth Mint)
|
CID002030
|
Compliant
|
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CID001736
|
Compliant
|
|
Gold
|
Korea Zinc Co., Ltd.
|
CID002605
|
Compliant
|
|
Gold
|
Bangalore Refinery
|
CID002863
|
Compliant
|
|
Gold
|
AngloGold Ashanti Corrego do Sitio Mineracao
|
CID000058
|
Compliant
|
|
Gold
|
Argor-Heraeus S.A.
|
CID000077
|
Compliant
|
|
Gold
|
Yamakin Co., Ltd.
|
CID002100
|
Compliant
|
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
CID001916
|
Compliant
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
CID002129
|
Compliant
|
|
Gold
|
Tokuriki Honten Co., Ltd.
|
CID001938
|
Compliant
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CID002224
|
Compliant
|
|
Gold
|
Advanced Chemical Company
|
CID000015
|
Compliant
|
|
Gold
|
Samduck Precious Metals
|
CID001555
|
Compliant
|
|
Gold
|
Marsam Metals
|
CID002606
|
Compliant
|
|
Gold
|
Asahi Pretec Corp.
|
CID000082
|
Compliant
|
|
Gold
|
Asaka Riken Co., Ltd.
|
CID000090
|
Compliant
|
|
Gold
|
Aurubis AG
|
CID000113
|
Compliant
|
|
Gold
|
Gold Refinery of Zijin Mining Group Co., Ltd.
|
CID002243
|
Compliant
|
|
Gold
|
Torecom
|
CID001955
|
Compliant
|
|
Gold
|
Umicore Brasil Ltda.
|
CID001977
|
Compliant
|
|
Gold
|
LT Metal Ltd.
|
CID000689
|
Compliant
|
|
Gold
|
MMTC-PAMP India Pvt., Ltd.
|
CID002509
|
Compliant
|
|
Gold
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
|
CID000128
|
Compliant
|
|
Gold
|
Boliden AB
|
CID000157
|
Compliant
|
|
Gold
|
C. Hafner GmbH + Co. KG
|
CID000176
|
Compliant
|
|
Gold
|
CCR Refinery - Glencore Canada Corporation
|
CID000185
|
Compliant
|
|
Gold
|
Cendres + Metaux S.A.
|
CID000189
|
Compliant
|
8
|
Gold
|
Chimet S.p.A.
|
CID000233
|
Compliant
|
|
Gold
|
AU Traders and Refiners
|
CID002850
|
Compliant
|
|
Gold
|
Chugai Mining
|
CID000264
|
Compliant
|
|
Gold
|
DSC (Do Sung Corporation)
|
CID000359
|
Compliant
|
|
Gold
|
DODUCO Contacts and Refining GmbH
|
CID000362
|
Compliant
|
|
Gold
|
Dowa
|
CID000401
|
Compliant
|
|
Gold
|
Eco-System Recycling Co., Ltd. East Plant
|
CID000425
|
Compliant
|
|
Tungsten
|
Ganzhou Haichuang Tungsten Co., Ltd.
|
CID002645
|
Compliant
|
|
Tungsten
|
Hydrometallurg, JSC
|
CID002649
|
Compliant
|
|
Tungsten
|
KGETS Co., Ltd.
|
CID003388
|
Compliant
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CID000218
|
Compliant
|
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
CID000766
|
Compliant
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
CID000769
|
Compliant
|
|
Tungsten
|
Japan New Metals Co., Ltd.
|
CID000825
|
Compliant
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CID002321
|
Compliant
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CID002318
|
Compliant
|
|
Tungsten
|
A.L.M.T. Corp.
|
CID000004
|
Compliant
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CID002317
|
Compliant
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CID000258
|
Compliant
|
|
Tungsten
|
Niagara Refining LLC
|
CID002589
|
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
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CID002316
|
Compliant
|
|
Tungsten
|
Kennametal Fallon
|
CID000966
|
Compliant
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
CID000499
|
Compliant
|
|
Tungsten
|
Kennametal Huntsville
|
CID000105
|
Compliant
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CID000875
|
Compliant
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CID002319
|
Compliant
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
CID002513
|
Compliant
|
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
CID002541
|
Compliant
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co. KG
|
CID002542
|
Compliant
|
|
Tungsten
|
Masan Tungsten Chemical LLC (MTC)
|
CID002543
|
Compliant
|
|
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
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CID002494
|
Compliant
|
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
CID002044
|
Compliant
|
|
Tungsten
|
Global Tungsten & Powders Corp.
|
CID000568
|
Compliant
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CID002551
|
Compliant
|
|
Tungsten
|
ACL Metais Eireli
|
CID002833
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CID002320
|
Compliant
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CID002082
|
Compliant
|
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
CID002095
|
Compliant
|
|
Tungsten
|
Moliren Ltd.
|
CID002845
|
Compliant
|
|
Tungsten
|
Woltech Korea Co., Ltd.
|
CID002843
|
Compliant
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
CID002502
|
Compliant
|
| Not Validated |
|||
|
Tin
|
Estanho de Rondonia S.A.
|
CID000448
|
In Communication
|
|
Tin
|
Modeltech Sdn Bhd
|
CID002858
|
Non-compliant
|
9