Form SD - Specialized disclosure report

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 _________________

 FORM SD

  _________________

Specialized Disclosure Report

 

_________________________________

CIRRUS LOGIC, INC.

(Exact name of registrant as specified in its charter)

 

_________________________________

 

 

DELAWARE						0-17795
(State or other jurisdiction of incorporation)						(Commission File Number)

800 W. 6th Street, Austin, TX 78701

(Address of principal executive offices)

Registrant’s telephone number, including area code: [phone]

 

_________________________________

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed:

 

þ			Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023.
☐			Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____________.

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SECTION 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Cirrus Logic, Inc. (the “Company”) has evaluated its current product lines and determined that certain products that we manufactured, or contracted to manufacture, during calendar year 2023 use “conflict minerals” that are necessary to the functionality or production of those products. Conflict minerals are defined by the Securities and Exchange Commission (“SEC”) as cassiterite, columbite-tantalite, gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (the “3TG” minerals). The Company conducted a good faith reasonable country of origin inquiry regarding those 3TG minerals to determine whether any of the 3TG minerals originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola (the “Covered Countries”), and whether any of the 3TG minerals may be from recycled or scrap sources. Based on its inquiry, the Company undertook due diligence on the source or chain of custody of its 3TG minerals and filed a Conflict Minerals Report as Exhibit 1.01 to this Form SD. A copy of the Company’s Conflict Minerals Report, along with a copy of this Form SD, is publicly available online at www.cirrus.com/company/quality/corporate-compliance in the Corporate Compliance section of our website.

Item 1.02 Exhibit

A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.

SECTION 2 – Resource Extraction Issuer Disclosure

Item 2.01 Resource Extraction Issuer Disclosure and Report

Not applicable.

SECTION 3 – Exhibits

Item 3.01 Exhibits

The following exhibit is filed as part of this Report:

 

•Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, Registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.

 

CIRRUS LOGIC, INC.

Date: May 24, 2024

By:

/s/ Gregory S. Thomas

Name:

Gregory S. Thomas

Title:

General Counsel

Exhibit 1.01

Cirrus Logic, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2023

I. Introduction

This Conflict Minerals Report (the “Report”) has been prepared by Cirrus Logic, Inc. (the “Company”) pursuant to Rule 13p-1 and Form SD (the “Rule”), which were promulgated under the Securities Exchange Act of 1934. The Report covers the reporting period January 1, 2023 to December 31, 2023. The Securities and Exchange Commission (the “SEC”) adopted the Rule to implement the reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain certain specified materials that are necessary to the functionality or production of their products. The specified materials, which are collectively referred to as the “Conflict Minerals,” are defined by the SEC as cassiterite, columbite-tantalite, gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold (the “3TG” minerals).

According to the Rule, if a registrant has reason to believe that any of the 3TG minerals in its supply chain may have originated in the Covered Countries, or if the registrant is unable to determine that the 3TG minerals either did not originate in the Covered Countries or were from recycled or scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the 3TG minerals. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. The registrant must annually submit a report, a Conflict Minerals Report (the “CMR”), to the SEC that includes a description of those due diligence measures.

This Report has been prepared by management of the Company and includes the activities of all majority-owned subsidiaries and entities that are required to be consolidated. The Company did not subject this Report to an independent private sector audit and we do not believe such an audit was required based on the guidance provided by the SEC in its “Statement of the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014 because we have not elected to describe any of our covered products as “DRC conflict free” at this time.

Company Overview

The Company is a leader in low-power, high-precision mixed-signal processing solutions that create innovative user experiences for the world’s top mobile and consumer applications.

Description of the Company’s Products Covered by this Report

This Report relates to products: (i) for which 3TG minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2023. The Company’s products covered by this Report are integrated circuits.

II. Reasonable Country of Origin Inquiry

The Company has conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals. This RCOI was reasonably designed to determine whether any of the 3TG minerals originated in the Covered Countries and whether any of the 3TG minerals may be from recycled or scrap sources. To conduct the RCOI, we requested our suppliers to report the origin of the 3TG minerals used in the manufacture of our products. Specifically, suppliers were expected to utilize

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the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) to report on the use of 3TG minerals used in the manufacture of our products.

Annex I includes a summary of the country of origin information collected as a result of our RCOI. The data on which we relied for certain statements in this report was obtained through our membership in the RMI, using the Reasonable Country of Origin Inquiry report for member “CRUS.”

III. Due Diligence Design and Performance

1.Due Diligence Design:

Our due diligence measures have been designed to conform with the framework provided by the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”).

In conjunction with its due diligence process, the Company has adopted a policy relating to 3TG minerals (the “Conflict Minerals Policy”), incorporating the standards set forth in the OECD Guidance. The Conflict Minerals Policy states that, to promote stability and security, we expect our suppliers to source materials from environmentally and socially responsible supply chains. Our policy forbids our suppliers from placing an outright ban on procuring minerals from the Covered Countries. In addition, the Conflict Minerals Policy states that our suppliers must report at least annually the origin of the 3TG minerals by identifying smelters or refiners (“SORs”) used in the manufacture of our products. As outlined in the OECD Guidance, we also participate in groups and forums focused on responsible sourcing of the 3TG minerals, including the Responsible Business Alliance (“RBA”) and utilize RMI’s Responsible Minerals Assurance Process (“RMAP”), which provides suppliers with an independent, third-party audit that determines which smelters and refiners can be verified as having systems in place to responsibly source minerals in line with current global standards.

Summarized below are the design components of our conflict minerals program as they relate to the five-step framework as provided by the OECD Guidance:

•Establishment of a strong company management system through:

•Adopting a Conflict Minerals Policy;

•Establishing an internal team of subject matter experts that includes members of our supply chain, legal, and quality organizations, and is managed by our General Counsel;

•Instituting processes for new suppliers of our integrated circuits whereby conflict mineral conformance is discussed during initial business reviews;

•Including a flow-down clause in new or renewed supplier contracts relating to the sourcing of 3TG minerals;

•Requiring our integrated circuit suppliers abide by the Cirrus Logic Supplier Code of Conduct, which is based on the RBA Code of Conduct;

•Communicating our Supplier Code of Conduct to our suppliers with, in certain cases, accompanying training;

•Participating in RMI initiatives; and

•Providing multiple communication channels to serve as grievance mechanisms for early warning risk awareness, including an anonymous reporting hotline available for reporting possible violations of the Company’s policies (https://secure.ethicspoint.com/domain/media/en/gui/6355/index.html) and the RBA Voices platform, a review system established by RMI to provide a record and communication channel for identification, review, and resolution of grievances.

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•Identification and assessment of risks in the supply chain by:

•Identifying first-tier suppliers to engage in our due diligence efforts;

•For subcontractors associated with the manufacture of our integrated circuit products, incorporating conflict minerals data review as part of our annual audits;

•Conducting a survey of our direct supply chain using the template known as the RMI CMRT;

•Reviewing and validating smelter information provided by suppliers and working with our supply chain to correct any inaccuracies in reporting;

•Requiring sourcing only from SORs that are RMAP-conformant or that have successfully undergone a similar independent third-party audit verification;

•Identifying smelter usage by greatest risk and prioritizing efforts, if any, associated with our due diligence with those smelters; and

•Participating in RMI as a member of the smelter engagement team (level one) to validate SORs and assist in efforts to encourage smelter participation in the RMAP.

•Design and implement a strategy to respond to identified risks by:

•Responding to risks identified in the supply chain by confirming that all smelters identified in survey responses from our suppliers have been verified by the RMAP;

•Mitigating risks by performing direct outreach when necessary with smelters at risk for non-conformance to RMAP protocols to ensure continued compliance;

•Collaborating with our supply chain to apply appropriate and reasonable leverage to ensure identified risks are tracked and removing non-conformant and/or inactive SORs in a timely manner if such SORs are unable or unwilling to remediate identified risks; this is done in consultation with information that RMI makes available to its members;

•Exercising leverage over our upstream suppliers through contractual obligations and requirements to comply with our Supplier Code of Conduct, which is based on the RBA Code of Conduct and includes provisions requiring responsible sourcing of conflict minerals;

•Reporting on a quarterly basis to senior management, including the Company’s Senior Vice President of Supply Chain; Senior Vice President of Global Operations; and Senior Vice President, General Counsel, the status and findings derived from our due diligence efforts;

•Informing the Company’s Audit Committee yearly on our due diligence activities and Conflict Minerals Report;

•Designing and implementing training or recommendations for relevant first-tier suppliers as needed to improve their systems of transparency and control; and

•Communicating our Conflict Minerals Policy to suppliers.

•Auditing supply chain due diligence by:

•Requesting our suppliers to report to us using an industry-developed audit program through RMI, in collaboration with the London Bullion Market Association (“LBMA”) and the Responsible Jewellery Council (“RJC”), that is administered by independent third-party auditors;

•Assessing the conflict minerals processes, procurement, and documentation of our suppliers; and

•Supporting, through our participation in and financial support of, RMI’s efforts to determine mine or location of origin of conflict minerals and to improve and align industry expectations for due diligence as described on the RMI website at http://www.responsiblemineralsinitiative.org.

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•Reporting on supply chain due diligence by:

•Communicating our Conflict Minerals Policy on our website at www.cirrus.com/company/quality/corporate-compliance/;

•Reporting annually our Specialized Disclosure Report on Form SD and Conflict Mineral Report filed with the SEC and publicly communicated on our website at www.cirrus.com/company/quality/corporate-compliance/; and

•Discussing our Environmental, Social, and Governance (“ESG”) program in our annual ESG report available on our website at www.cirrus.com/company/esg/.

2.Due Diligence Measures Performed:

The Company exercised due diligence on the source and chain of custody of the 3TG minerals. Below is a description of the measures we performed for this reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:

•Communicated our Conflict Minerals Policy to our suppliers;

•Conducted a supply-chain survey of 16 direct suppliers of our integrated circuit products using the RMI’s CMRT, requesting information regarding the necessary conflict minerals and identification of smelter and refiners that process such minerals;

•Received responses to surveys from 100% of our suppliers with respect to our integrated circuits component suppliers for at least the seventh consecutive year;

•Reviewed survey data for completeness, and contacted those suppliers that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information;

•Compared smelters identified by our suppliers against lists of smelters certified as conflict-free through the RMAP; and

•Continued work through our conflict minerals program to assess16 suppliers and implement program updates as necessary, focusing on the due diligence processes and policies of certain direct suppliers of our integrated circuit products.

IV. Results of Due Diligence Measures

Based on our due diligence efforts as it relates to our integrated circuits, we identified the facilities set forth in Annex II that potentially could have produced the necessary 3TG minerals in our products. Of the 102 smelters that we identified, 20 were believed to be potentially sourcing directly from the Covered Countries. However, none of the smelters identified in our supply chain are known to us as sourcing 3TG minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. In Annex II, we have indicated the facilities identified in our supply chain as of 09 April 2024.

V. Inherent Limitations and Risks with our Due Diligence Measures

The Company employs a “fabless” model for the manufacture, assembly, and test of our integrated circuits. We do not own or operate our own foundries or manufacturing facilities, and therefore, outsource our integrated circuit manufacturing to third-party foundries in Asia and Europe. We also outsource all product assembly, packaging, and testing of our products to several assembly and test subcontractors in Asia.

With our fabless manufacturing strategy, we are a downstream consumer of certain 3TG minerals and our due diligence efforts can provide only reasonable, not absolute, assurance regarding the source and chain of custody for the necessary conflict minerals in the products that we sell. Our supply chain is complex, and there are multiple tiers between our company and the mines that ultimately supply 3TG materials. Given our place in the supply chain, we have no direct relationships with smelters and refiners, and therefore, possess no independent means of determining the source and origin of conflict mineral ores

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processed by smelters and refiners. We are regularly monitoring the RBA Smelter or Refiner Master tool prepared and distributed by RMI; we work with our suppliers to understand how those SORs whose status is flagged as “Not Eligible” or “Non-Conformant” fit into our supply chain and request their removal from our supply chain as appropriate. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers, who similarly rely on their supply chains to identify the original sources of the necessary conflict minerals. We may not receive CMRT data at the product-specific level for our Company, and information received from our suppliers may include SORs outside our direct supply chain. We also rely, to a large extent, on information collected and provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud; for example, data may not be provided with sufficient granularity to enable us to accurately determine the number of smelters included as part of a program’s RCOI. This concern may be exacerbated after the U.S. Securities & Exchange Commission’s statement on the Rule in April 2017 indicating that, in light of the regulatory uncertainties relating to the Rule, the staff of the SEC will not recommend an enforcement action if companies only file a Form SD, and not a Conflict Minerals Report, to the extent otherwise required to be filed as an exhibit under the Rule.

Additionally, the complete supply chain from the SORs to our final integrated circuits involves a complex multi-step process that may be subject to changes without our knowledge on a frequent basis. We seek sourcing data from directs suppliers on at least an annual basis and request that the data cover the entire reporting year. However, due to timing of our requests, there is a risk that the data that we acquire will not reflect every supplier in the supply chain during the relevant period.

As a result of the COVID-19 pandemic, the Company adapted certain audits and assessments to comply with travel restrictions and/or local regulations. The Company was able to keep individuals safe while maintaining the quality of reviews, and therefore continued remote audits during calendar year 2023, even as RBA returned to its standard practices for in-person onsite audits.

VI. Future Steps to Mitigate Risks

Based on our efforts to collect data, we believe the main risks that we have identified are related to the lack of data and the quality of data. We intend to continue the activities described above as well as take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG minerals in our products could benefit armed groups in the Covered Countries:

1.Continue to engage with suppliers and direct them to training resources to attempt to maintain the response rate and improve the content of the supplier survey responses;

2.Continue to incorporate conflict minerals data review that we perform on 100% of our subcontractors associated with the manufacture of our integrated circuit products;

3.Continue to participate with RMI to expand the smelters and refiners participating in the RMAP;

4.Continue to work with the OECD or relevant trade associations to define and improve best practices and encourage responsible sourcing of 3TG minerals, including from the Covered Countries, in accordance with the OECD Guidance;

5.Continue to encourage suppliers to utilize the public source RMI e-Learning training platform; and

6.Continue to regularly monitor the RBA Voices platform as well as track grievances generated by RMI’s Grievance Mechanism, established by RMI to provide a record and communication channel to assess and respond to risks and potential opportunities for improvement related to concerns raised about participating SORs, RMI assessment of auditor or audit firm, and the RMI organization itself. This grievance mechanism allows from anonymous reporting of grievances and whistleblower protections.

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Annex I

Countries of Origin of 3TG
Andorra			Kyrgyzstan
Antigua and Barbuda			Laos
Argentina			Latvia
Australia			Liberia
Austria			Lithuania
Azerbaijan			Luxembourg
Bahamas			Madagascar
Bangladesh			Malaysia
Barbados			Mali
Belarus			Malta
Belgium			Mauritania
Benin			Mexico
Beralus			Mongolia
Bolivia			Morocco
Bosnia and Herzegovina			Mozambique
Botswana			Myanmar
Brazil			Namibia
Bulgaria			Netherlands
Burkina Faso			New Zealand
Burundi			Nicaragua
Cambodia			Niger
Cameroon			Nigeria
Canada			Oman
Cayman Islands			Pakistan
Chile			Panama
China			Papua New Guinea
Colombia			Peru
Congo, Democratic Republic of the			Philippines
Costa Rica			Poland
Côte d'Ivoire			Portugal
Croatia			Puerto Rico
Curacao			Romania
Cyprus			Russia
Czech Republic			Rwanda
Denmark			Saint Kitts and Nevis

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Dominican Republic			Saudi Arabia
Ecuador			Senegal
Egypt			Serbia
El Salvador			Sierra Leone
Estonia			Singapore
Fiji			Saint Maarten
Finland			Slovakia
France			Slovenia
French Guiana			South Africa
Georgia			Spain
Germany			St Vincent and Grenadines
Ghana			Sudan
Greece			Suriname
Grenada			Sweden
Guatemala			Switzerland
Guinea			Taiwan, Province of China
Guyana			Tanzania
Honduras			Thailand
Hong Kong			Trinidad and Tobago
Hungary			Tunisia
India			Turkey
Indonesia			Turks and Caicos
Ireland			Uganda
Israel			United Arab Emirates
Italy			United Kingdom of Great Britain and Northern Ireland
Japan			United States of America
Jordan			Uruguay
Kazakhstan			Uzbekistan
Kenya			Vietnam
Korea, Republic of			Zimbabwe
Kuwait

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Annex II

Conflict Mineral			Processing Facility Name			Processing Facility Location
Gold			Argor-Heraeus S.A.			SWITZERLAND
Gold			Asahi Pretec Corp.			JAPAN
Gold			Heraeus Metals Hong Kong Ltd.			CHINA
Gold			Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.			CHINA
Gold			Ishifuku Metal Industry Co., Ltd.			JAPAN
Gold			Jiangxi Copper Co., Ltd.			CHINA
Gold			Asahi Refining Canada Ltd.			CANADA
Gold			JX Nippon Mining & Metals Co., Ltd.			JAPAN
Gold			Matsuda Sangyo Co., Ltd.			JAPAN
Gold			Metalor Technologies (Suzhou) Ltd.			CHINA
Gold			Metalor Technologies (Hong Kong) Ltd.			CHINA
Gold			Metalor Technologies (Singapore) Pte., Ltd.			SINGAPORE
Gold			Metalor Technologies S.A.			SWITZERLAND
Gold			Metalor USA Refining Corporation			UNITED STATES OF AMERICA
Gold			Mitsubishi Materials Corporation			JAPAN
Gold			Mitsui Mining and Smelting Co., Ltd.			JAPAN
Gold			Nihon Material Co., Ltd.			JAPAN
Gold			PX Precinox S.A.			SWITZERLAND
Gold			Rand Refinery (Pty) Ltd.			SOUTH AFRICA
Gold			Sumitomo Metal Mining Co., Ltd.			JAPAN
Gold			Tanaka Kikinzoku Kogyo K.K.			JAPAN
Gold			Tokuriki Honten Co., Ltd.			JAPAN
Gold			Valcambi S.A.			SWITZERLAND
Gold			Western Australian Mint (T/a The Perth Mint)			AUSTRALIA
Gold			Zhongyuan Gold Smelter of Zhongjin Gold Corporation			CHINA
Tantalum			Changsha South Tantalum Niobium Co., Ltd.			CHINA
Tantalum			F&X Electro-Materials Ltd.			CHINA
Tantalum			XIMEI RESOURCES (GUANGDONG) LIMITED			CHINA
Tantalum			JiuJiang JinXin Nonferrous Metals Co., Ltd.			CHINA
Tantalum			Jiujiang Tanbre Co., Ltd.			CHINA
Tantalum			Metallurgical Products India Pvt., Ltd.			INDIA
Tantalum			Mitsui Mining and Smelting Co., Ltd.			JAPAN
Tantalum			NPM Silmet AS			ESTONIA
Tantalum			Ningxia Orient Tantalum Industry Co., Ltd.			CHINA
Tantalum			Yanling Jincheng Tantalum & Niobium Co., Ltd.			CHINA
Tantalum			Telex Metals			UNITED STATES OF AMERICA

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Tantalum			Ulba Metallurgical Plant JSC			KAZAKHSTAN
Tantalum			Hengyang King Xing Lifeng New Materials Co., Ltd.			CHINA
Tantalum			D Block Metals, LLC			UNITED STATES OF AMERICA
Tantalum			FIR Metals & Resource Ltd.			CHINA
Tantalum			Jiujiang Zhongao Tantalum & Niobium Co., Ltd.			CHINA
Tantalum			KEMET de Mexico			MEXICO
Tantalum			TANIOBIS Co., Ltd.			THAILAND
Tantalum			TANIOBIS GmbH			GERMANY
Tantalum			Materion Newton Inc.			UNITED STATES OF AMERICA
Tantalum			TANIOBIS Japan Co., Ltd.			JAPAN
Tantalum			TANIOBIS Smelting GmbH & Co. KG			GERMANY
Tantalum			Global Advanced Metals Boyertown			UNITED STATES OF AMERICA
Tantalum			Global Advanced Metals Aizu			JAPAN
Tantalum			Jiangxi Tuohong New Raw Material			CHINA
Tin			Dowa			JAPAN
Tin			Fenix Metals			POLAND
Tin			Gejiu Non-Ferrous Metal Processing Co., Ltd.			CHINA
Tin			Malaysia Smelting Corporation (MSC)			MALAYSIA
Tin			Mineracao Taboca S.A.			BRAZIL
Tin			Minsur			PERU
Tin			Mitsubishi Materials Corporation			JAPAN
Tin			Operaciones Metalurgicas S.A.			BOLIVIA (PLURINATIONAL STATE OF)
Tin			PT Refined Bangka Tin			INDONESIA
Tin			PT Sariwiguna Binasentosa			INDONESIA
Tin			PT Stanindo Inti Perkasa			INDONESIA
Tin			PT Timah Tbk Kundur			INDONESIA
Tin			PT Timah Tbk Mentok			INDONESIA
Tin			Rui Da Hung			TAIWAN, PROVINCE OF CHINA
Tin			Thaisarco			THAILAND
Tin			Yunnan Chengfeng Non-ferrous Metals Co., Ltd.			CHINA
Tin			Tin Smelting Branch of Yunnan Tin Co., Ltd.			CHINA
Tin			O.M. Manufacturing Philippines, Inc.			PHILIPPINES
Tin			Aurubis Beerse			BELGIUM
Tin			PT Menara Cipta Mulia			INDONESIA
Tin			DS Myanmar			MYANMAR
Tungsten			A.L.M.T. Corp.			JAPAN
Tungsten			Kennametal Huntsville			UNITED STATES OF AMERICA
Tungsten			Guangdong Xianglu Tungsten Co., Ltd.			CHINA
Tungsten			Chongyi Zhangyuan Tungsten Co., Ltd.			CHINA
Tungsten			Global Tungsten & Powders Corp.			UNITED STATES OF AMERICA

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Tungsten			Hunan Chenzhou Mining Co., Ltd.			CHINA
Tungsten			Japan New Metals Co., Ltd.			JAPAN
Tungsten			Kennametal Fallon			UNITED STATES OF AMERICA
Tungsten			Wolfram Bergbau und Hutten AG			AUSTRIA
Tungsten			Xiamen Tungsten Co., Ltd.			CHINA
Tungsten			Ganzhou Jiangwu Ferrotungsten Co., Ltd.			CHINA
Tungsten			Jiangxi Yaosheng Tungsten Co., Ltd.			CHINA
Tungsten			Jiangxi Xinsheng Tungsten Industry Co., Ltd.			CHINA
Tungsten			Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.			CHINA
Tungsten			Malipo Haiyu Tungsten Co., Ltd.			CHINA
Tungsten			Xiamen Tungsten (H.C.) Co., Ltd.			CHINA
Tungsten			Jiangxi Gan Bei Tungsten Co., Ltd.			CHINA
Tungsten			Ganzhou Seadragon W & Mo Co., Ltd.			CHINA
Tungsten			Asia Tungsten Products Vietnam Ltd.			VIET NAM
Tungsten			Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch			CHINA
Tungsten			H.C. Starck Tungsten GmbH			GERMANY
Tungsten			TANIOBIS Smelting GmbH & Co. KG			GERMANY
Tungsten			Masan High-Tech Materials			VIET NAM
Tungsten			Jiangwu H.C. Starck Tungsten Products Co., Ltd.			CHINA
Tungsten			Niagara Refining LLC			UNITED STATES OF AMERICA
Tungsten			China Molybdenum Tungsten Co., Ltd.			CHINA
Tungsten			Philippine Chuangxin Industrial Co., Inc.			PHILIPPINES
Tungsten			Lianyou Metals Co., Ltd.			TAIWAN, PROVINCE OF CHINA
Tungsten			Hubei Green Tungsten Co., Ltd.			CHINA
Tungsten			Cronimet Brasil Ltda			BRAZIL
Tungsten			Fujian Xinlu Tungsten Co., Ltd.			CHINA

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