EICC® and GeSI Tin Supply Chain Transparency: Smelter Audit Revision: 15 September 2011

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 1 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

A)

Audit Overview

I) The scope of who and what will be audited 1

The EICC and GeSI tin transparency audit for smelters will apply to all tin smelters supplying into the electronic supply chain or those of partner company or partner industry sector supply chains. The initial audit will cover the period from one year prior to the time of the audit. The audit will cover tin inventory, tin receipts and tin product shipments during this audit period as well as closing inventory at the time of the audit. It should be noted that the opening and closing inventories are calculated stocks. Using the calculated inventory at the beginning of the audit period as the opening stock, the expected closing stock at the time of audit can be deduced using a material mass balance approach with the following formula: Closing stock at audit (+/- 10%) = Opening stock + Tin receipts – Tin product shipments – losses . The key element of this exercise is to ensure that the quantity of tin received during the audit period matches that expected from the above calculation, taking into account the possible error margin of inventory, stock and loss estimation. It is also the purpose of the audit to ensure that all related documentary records are in order for the relevant period. In the tin industry primary smelters are referred to as companies treating tin containing ore concentrates in order to produce crude or fully refined tin (≥99.85% pure). Secondary smelters are companies which treat secondary2 materials for the production of crude or fully refined tin. Refiners are companies that treat crude tin or suitable secondary materials to produce fully refined tin. Companies may be one of, or a combination of the above. The specific smelters listed below (including all sites of these smelters receiving any tin bearing materials as defined within this Standard) are types of companies expected to be audited as identified by EICC and GeSI, or its partner companies or partner industry sectors. This list does not include every tin smelter in the world. Yunnan Tin (China)

PT BilliTin Makmur Lestari (Indonesia)

PT Timah (includes Tambang) (Indonesia) Minsur (Peru) / Mineração Taboca S.A. (Brazil) Malaysia Smelting Corp (Malaysia)

PT Yinchendo Mining Industry (Indonesia)

Thailand Smelting and Refining Co., Ltd.[Thaisarco] (Thailand) Yunnan Chengfeng (China)

CV DS Jaya Abadi (Indonesia)

CV Duta Putra Bangka (Indonesia) PT Bangka Putra Karya (Indonesia)

PT Bukit Timah (Indonesia)

1

This document only uses the term "smelter" throughout but can be considered interchangeable with "refiner". Referenced as "conflict minerals from recycled or scrap" in the U.S. Securities and Exchange Commission (SEC) December 2010 Conflict Minerals draft rule. Note that the Dodd-Frank Act defines “conflict minerals” as including their derivatives, and thus the metals and compounds including tin. 2

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 2 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

Liuzhou China Tin (China)

PT Stanindo Inti Perkasa (Indonesia)

EM Vinto (Bolivia)

PT Tinindo Inter Nusa (Indonesia)

PT Koba Tin (Indonesia)

PT Mitra Stania Prima (Indonesia)

Gejiu Zi-Li (China)

CV Prima Timah Utama (Indonesia)

OMSA (Bolivia)

PT Sariwiguna Binasentosa (Indonesia)

Gold Bell Group (China)

PT Sumber Jaya Indah (Indonesia)

Novosibirsk (Russia)

PT Bangka Kudai Tin (Indonesia)

Mitsubishi Material (Japan) Cookson (USA)

PT Bangka Timah Utama Sejahtera (Indonesia) CV United Smelting (Indonesia)

Metallo Chimique (Belgium)

PT Belitung Industri Sejahtera (Indonesia)

Jiangxi Nanshan (China)

PT Fang Di MulTindo (Indoensia)

PT Timah Nusantara (Indonesia)

PT Alam Lestari Kencana (Indonesia)

PT HP Metals Indonesia

CV Makmur Jaya (Indonesia)

PT Babel Surya Alam Lestari

PT Eunindo Usaha Mandiri (Indonesia)

CV Nurjanah (Indonesia)

PT Babel Inti Perkasa (Indonesia)

CV JusTindo (Indonesia)

PT Artha Cipta Langgeng (Indonesia)

CV Serumpun Sebalai (Indonesia) Any smelter may request to be included in the audit process provided the smelter meets the basic requirements of participating in the tin supply chain, has a conflict minerals policy, agrees to fund the audit, initiates a request (http://www.conflictfreesmelter.org) with EICC and GeSI and signs the appropriate agreements. If a smelter receives tin material from another supplying smelter, it is therefore necessary that the supplying smelter is also compliant with the requirements of an EICC and GeSI audit which is identical to the scope of work mentioned in this document. If such audit has not been previously completed then the supplying-smelter will be audited as a component of the smelter’s operation. Tin receipts from a supplying-smelter for any tin-bearing material which is determined to not meet the secondary material definition will require documented ore source of origin over the audit period, or need to be purchased from a CFS compliant smelter. Audit failure or audit refusal of a supplying smelter of tin materials will be considered noncomplaint to the audit of the smelter which received those materials during the audit period. The smelter will cease to source tin bearing material from the supplier which had refused or had failed the audit. However, this would not affect material in transit to or which is residing at the receiving smelter. Material issues prior to the protocol’s official initial release will be managed by exception, and will require declaration that states further procurement from non-conforming sources will no longer occur. The non-compliant material must be processed by the smelter and a re-audit 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 3 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

performed within 3 months of finding the non-conforming material. During the re-audit the material balance is re-done and it is validated that no continued procurement occurs from suppliers deemed non-compliant. Material received as part of a tolling provision during the audit period will be considered as part of the smelter's receipts and tin product shipments, and will require corresponding documentation related to ore source of origin for received ore, concentrate, or any other materials not meeting the secondary definition. Materials received from a CFS compliant smelter are accepted to have proven source of origin. Respective sources for any received secondary materials under a toll provision will also be required. If a supplying-smelter has passed the EICC and GeSI compliance audit, then all items that supplying-smelter has supplied to the smelter being audited can be excluded from the detailed ore source of origin.

II) Description of Levels of Documentation required for each Source of Origin for the Tin ores There are four (4) levels of documentation required to ensure conflict minerals are excluded from the supply chain. Each level requires increasing documentation as the source of the tin approaches conflict regions. Additionally the level of documentation increases when sources are identified to be from regions which are not known to have tin ore sources. The lists are not applicable to material determined to be secondary as identification of ore source is not required. Several smelters receive significant quantities of crude metal primarily from Indonesia for refining. Indonesia’s tin export regulation requires tin bars to be >99.85% pure to be legal for export, requires identification of region of origin, and demonstration of royalty payment. As the supply source is largely artisanal and small-scale mining (ASM) in Indonesia, it may not be possible in most cases to trace back to mine of origin however purchasers should request that any existing local regulations on traceability are being applied as part of the export procedures, and request respective documentation3. A significant proportion of tin is mined by artisanal or small scale mining (ASM). This may represent between 40-60% of mine production in any year depending on prevailing circumstances and is likely to occur in almost every tin production country globally. As noted above, ASM material may not be traceable to mine of origin. Where it cannot be determined, the origin therefore needs to be mapped back to the region within the country of source. For all ASM sourcing going forward after the release of this standard, it will be expected that the smelter obtains a declaration of country region of origin from their supplier, to supplement export documents. It is especially applicable to smelters purchasing from domestic ASM to obtain the regional declaration of origin from their suppliers (e.g. collectors, consolidators, traders, comptoirs, negociants). Level 1 Documentation is for countries with known active ore production which are not identified as conflict regions or plausible areas of smuggling or export of conflict minerals4. 3

Indonesia regulation 04/M-DAG/PER/1/2007 regulates the export of tin bars including traceability analysis within the country. Appropriate documentation should be available from Indonesian exporters. 4 The definition of Conflict Minerals in this standard is not the same as the definition in the Frank Dodd Act. The definition herein specifically refers to minerals from jurisdictions “under the control of armed groups” as defined in the Dodd Frank Act. 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 4 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

The Auditor should validate the plausibility of these tin ore sources with the Plausibility Report and take appropriate further investigation if a source identified is not a plausible source. If countries that do not have a plausible supply source of tin ore, but are represented as Level 1 sourcing origins by the smelters, then the auditor should require the documentation consistent starting with Level 2A countries to ensure the source is valid. Further listing of plausible countries and volumes are explained, where known, in the Plausibility Report. As an added check for plausibility the auditor shall review the list of suppliers to the smelters to determine if any of the suppliers listed in Table 2 of the Plausibility Report have sold materials to the smelter. If a company in Table 2 is found in the smelter's supply chain then the auditor should inquire as to whether these transactions were in support of an internationally recognized certification scheme if coming from Level 2B or Level 3 countries. If this claim is asserted, proof of this company's participation should be included. This information should be included in the auditor’s final audit report, including the purchase details and transaction dates. Level 2 In accordance with the red flag concept outlined in the OECD Guidance for Tin, Tantalum and Tungsten, countries listed in this section require documentation for ore sources as they are known or plausible countries for the smuggling, export out of region, or transit of conflict mineral (cassiterite). Furthermore Level 2 countries have been sub-divided into two sub categories. Level 2A Countries (defined as known or plausible countries for the smuggling, export out of region, or transit of conflict mineral (cassiterite)):

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 5 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

Kenya Mozambique South Africa Level 2B Countries (defined as the nine adjoining countries (of the DRC) which has been outlined in section 1502 in the Dodd Frank Act): Burundi Rwanda Republic of the Congo Uganda Tanzania Central African Republic Zambia Angola Sudan For Level 2B countries added measures (see Section B below) will be needed to ensure that the traceability demonstrates that the provenance of the material is from the country in question and not the DRC. Level 3 Documentation is for ore sources for countries that are currently within conflict regions and are potentially supplying tin ore materials. Level 3 Countries: Democratic Republic of the Congo

III) Excluded Materials from the Audit Source of Origin Determination (Secondary Materials) Secondary tin-containing materials for recycling are excluded from the requirement to demonstrate ore source of origin5. Recycled metals as defined by the OECD Guidance6 are, “reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing including: excess, obsolete, defective, and scrap metal materials which contain refined or processed metals that are appropriate to recycle in the production of tin.” “Minerals partially processed, unprocessed or a by-product from another ore are not recycled metals.”7 5

Requirement based on the Dec. 2010 proposed rule of the U.S. Securities and Exchange Commission (SEC) to implement the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 (“Dodd-Frank”) provisions on conflict minerals. 6 OECD Due Diligence Guidance for Responsible Supply Chains on Minerals from Conflict-Affected and HighRisk Areas [http://www.oecd.org/document/36/0,3746,en_2649_34889_44307940_1_1_1_1,00.html] 7 The recycled metals definition contained within this protocol document will be updated upon the publication of the SEC rule provisions on conflict minerals. As will the rest of the protocol, as necessary. 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 6 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

The audit will confirm details of the supplying source of the secondary materials to ensure it conforms to the definition and/or examples. The secondary material received during the audit period is included in the overall site tin material balance to ensure all materials are incorporated into the scope of the audit. The Line Item Summary will be used to identify each receipt of secondary material and the supplying source during the audit period and validate adherence to the definition for exclusion (including reasonably assumed recycled materials8). Inventory of secondary material received prior to the audit period will be included within the tin material balance, but not in the compliance analysis provided it remains as received from the supplier in an un-tampered state. Tin has many hundreds of uses both as the metal, and as organic and inorganic compounds. Tin containing material may therefore arise from many hundreds of sources and cannot be specifically described. As an indication, secondary materials and sources may include, but are not limited to those mentioned in the list below; 1. Manufacturers of tin tubes, foils and other similar forms. Producers of tin, lead, copper (e.g. bronzes, brasses, gunmetal, babbitt metal etc), zinc, titanium, aluminium, steel, cast iron and a variety of other metal alloy manufactures;  melting drosses, skimmings, ashes and runouts from the casting process  refining and spent dross  off-cuts, out of specification or contaminated material  gas cleaning sludge and dust  water treatment sludge  filter dust or similar materials, for example tin oxides 2. Alloy users manufacturing components, powders or final products, for a range of industries such as automotive, electrical and electronics, plumbing and building, radiator manufacture, bearings, brazing, coins, printing, model making, jigging and fixturing, ammunition, dental, ornamental items, toys and jewellery and for various types of general engineering;  ashes, drosses, skimmings and runouts from the anode casting melting dross,  contaminated or waste metal,  out of specification or contaminated material,  metallic blocks or items as off-cuts of casting failures  runners and risers from casting processes  scrap wire, strip, stampings, trimmings, turnings, pieces, cuttings, dust, powder etc  machining, grinding and polishing waste, ball mill fines  gas cleaning sludge and dust,  water treatment sludge  filter dust or similar materials, for example tin oxides  slags and refractory slags from the copper alloying or other alloying industries

8

As according to OECD Guidance, “Metals reasonably assumed to be recycled are excluded from the scope of this Guidance.” 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 7 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

3. Printed circuit board manufacturers and other industrial solder users of any kind of lead, lead-free, high temperature or other solders;  solder dross,  spent anodes,  return solder products, for example bar, pastes, spheres, preforms and wire  contaminated solder pot material  waste solder paste  spillings and drippings  filter dust or similar materials 4. Users of tin metal or chemicals in the plating industry, for example, manufacture of components for automotive, electrical, electronic, medical and general engineering industries, etch resist material as well as canning and other types of packaging. Plating may be pure tin or tin alloy coatings such as tin-nickel, tin-zinc, tin-copper, tin-lead or any other combination of materials producing the required final properties. Tin plating may be applied to almost any other metal alloy, including but not exclusively steel and copper and its alloys;  ashes, drosses, skimmings and runouts from the anode casting process,  spent anodes,  plating sludges from any hydro-metallurgical or electrolytic tinning process  plated off-cuts or reject items 5. Hot tinning and solder dipping operations as well as thermal spray coating processes in general engineering, electrical and electronic and other product manufacture;  drosses  contaminated metal  filter dust or similar materials, for example tin oxides  overspray  filter dust or similar materials 6. The glass manufacturing, forming and coatings industries using tin metal and/or compounds;  metal and drosses from glass float process  metal and drosses from sputtering targets  filter dust or similar materials, for example tin oxides  spent sputtering targets 7. Manufacturers and users of tin chemicals in a very wide range of industries for example, brake pads, fire retardants, foams, polymers, rubbers, ceramic pigments, glazes, conductive films, crystal glasses, mirrors, textiles, wood and other preservatives, food additives, soaps, toothpaste and cosmetics, vetinary products, cements, mercury sorbants, fluxes and antisludge agents;  tinny sludge from tin chemical or pharmaceutical manufacturing processes  other waste or reject tin containing chemicals  any other type of residues, drosses, skimmings as a by-product of production  filter dust or similar materials 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 8 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

8. Tin or tin compounds used as catalysts for polymerisation, alkylation, esterification, oxidation, hydrogenation and use in gas sensors, as well as, reducing agents, activators, sensitizing agents, passivation, and stabilizers during a manufacturing process  tinny sludge from manufacturing processes  other waste or reject tin containing chemicals  any other type of residues, drosses, skimmings as a by-product of production 9. De-tinning operations for recovery of tin from any type of plated or coated general items, for example tin coated copper alloy or steel;  tin bearing sponge 10. Operators reclaiming any tin containing metals, and items manufactured from them such as organ pipes, wires, pewter plates and vessels, costume jewellery, candlesticks, light fittings, clocks, kilt pins  all forms of materials 11. Copper recovery operations using pyro-metallurgical and/or other relevant processes  all forms of materials 12. Lead refiners or similar processors recovering tin from drosses, stannates and other materials from, for example of battery and other lead based alloys  all forms of materials 13. Recovery of end of life scrap and other wastes from any semi-finished or final products related to the above processes, for example, electrical or electronic equipment, automobiles, heat exchangers, plumbing, ships, aircraft, packaging, building demolition, infrastructure replacement and any consumer product  all forms of materials 14. Recovery of end of life engineering components of tin compounds and minerals, such as tin oxide bricks.  all forms of materials In summary, any forms of tin which have been extracted, smelted and then used for their primary purpose and are no longer used for such purpose are capable of being recycled. Tin containing secondary materials suitable for recovery may arise from practically any type of metal, polymer, ceramic, glass, rubber, chemical production, use or recovery plant as well as numerous types of industrial and consumer products. Note that residues such as ashes, drosses, skimmings and other forms of similar material mentioned above may be 100% oxidic, 100% metallic or any combination of both oxidic and metallic mixtures, with or without organic contamination or moisture.

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 9 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

Additionally recycling of any materials internal to the smelter (and used within the smelter, not purchased, sold or related to a toll agreement) in any form is excluded from the scope of the audit, line item summary, and source of origin documentation. If such items are sold, tolled, or purchased between smelters they are not considered to meet the secondary material definition or examples and would require source of origin analysis over the audit period, or need to be purchased from a CFS compliant smelter.

B)

Standards for Compliance

I)

The smelter will have a documented, effective and communicated policy for procurement of tin containing materials which explicitly avoids utilization of conflict minerals. Specifically the policy will cover the applicable items below: a) b) c) d) e) f)

II)

Tin Materials Conflict Regions Public Communication of the Policy Policy embedded into Standard Operating Procedures and individuals trained Effective Date established For those companies sourcing from the DRC and nine surrounding countries, their sourcing policy will have to comply with Annex II of the OECD Guidance for Tin, Tantalum and Tungsten9.

The smelter will have a mechanism to document tin receipts and products sold and shipped, and a reconciliation process for receipts, inventories, losses, tolling and sales. Components will include: a) Receiving documentation Documented list of all purchases and/or receipts with suppliers identified. Lot numbers assigned (including toll materials) b) All tin tolled and sales documented with specific lot numbers Documented list summarizing total tolled and sales quantity c) Reconciliation of tin receipts, inventories, losses, tolled and sales quantities to demonstrate receipts are fully accounted for in a tin mass balance. (involves certain degree of estimation of inventories to arrive at tin balance e.g. work in progress or materials removed at intermediate stages of the process) d) Due to mixing of batches in the smelting process or continuous flow operations, it may not be possible to directly trace finished lots to the source at receipt. In this case,

9

Smelters conflict minerals policy should be in compliance with requirements of the OECD Due Diligence Guidance for Responsible Supply Chains on Minerals from Conflict-Affected and High-Risk Areas [http://www.oecd.org/document/36/0,3746,en_2649_34889_44307940_1_1_1_1,00.html] 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 10 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

inline capacity and residence time should be determined and information regarding that inline capacity quantity also evaluated for ore source of origin (residence time of the process provides the time period over which to look at receipts, and the inline capacity estimates the amount of incoming material processed during the residence time). III)

Tin-containing materials are appropriately documented to be non-conflict minerals per guidelines of EICC and GeSI (as stated in section a below). All tin materials received are included whether direct purchases or part of a tolling or other business agreement. Secondary materials (as explained in section b below) are exempt from having mine of origin data; however, the audit will verify that this material meets the general requirement and given examples in section A.III above. a) Ore, concentrate or other non-secondary materials are identified as per the requirements listed below. i) Level 1 – Countries with known production outside of conflict regions and not known or plausible export/smuggling routes for Level 3 countries. a) Government issued country of origin certificate or copy of mine license/certificate (for domestic mines only), either must have the mining company identified NOTE: prior to 01Jan2012, in lieu of Certificate of Origin, a purchase contract specifying origin and corresponding mining license is acceptable for Level 1 countries only b) Government issued export certificate/document (for imported material) c) Bill of ladings or transportation documentation d) Sample analysis/results from supplier and smelter e) For ASM sources specifically, the requirement is limited to export documentation (for imported material), country of origin certificate (where countries provide them), and region of origin within the source country needs to be provided. For purchases after the initial release of this audit protocol, a declaration from the supplier stating the region of origin within the source country will be required. ii)

15Sep2011

Level 2A includes all Level 1 requirements plus the items immediately below (f-h): f) On-site mine visit reports by the smelter or their supplier or representative (e.g. AH Knight) for larger mine sites (includes the following completed during the visit or subsequent to the visit, visits may not be feasible and information may not be available for smaller ASM) 1) Verification that mining location agrees with concession, license or other form of Governmental sanctioning of the operation 2) Assessment of capabilities - staffing, equipment, available transportation routes 3) Validation by the smelter that the material comes from that source, sampling of typical materials close to the mine site EICC and GeSI Audit Standard and Instructions

Page 11 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

4) Historical (1 year) production capability reviewed and volume is confirmed to be feasible. g) All documents that validate Chain of Custody from Mine to Smelter, specifically identifying the seller/mining company (or supplier declaration of production region within a country for ASM) h) Government issued mining license/certificate for industrial operations or registered cooperatives (if available) Level 2B includes all Level 1 and 2A requirements plus items immediately below (i-j) i) Additionally for Level 2B countries only, it will be required to determine the amount of material coming from a given mine or general production area in the case of ASM. The figures obtained will be compared against the mines production capacity or country capacity in the case of ASM. For materials procured after April 1st 2011, smelters will have to demonstrate to an independent third party that they have implemented the OECD Due Diligence Guidance for Responsible Supply Chains on Minerals from Conflict-Affected and High-Risk Areas, which includes introducing a chain of custody and/or traceability system, coupled with on-the-ground risk assessments. With specific regard to the determination of the origin of minerals, smelters will have to collect the information required under the OECD Guidance. In order to generate the requested information, smelters may rely on a credible conflict free mineral traceability scheme that has been independently verified to conform to the OECD Guidance. Once the smelter’s due diligence program has been verified they will be eligible for a CFS review. During this review the smelter will have to demonstrate that all material received from Level 2B countries has come from a conflict-free source (based on the OECD compliant process mentioned above). For ASM sources this may include bagging and tagging of mineral ore as a means to demonstrate due diligence on the original provenance of the ore or a similarly robust and credible system. Regardless of the traceability mechanism the smelter must possess enough documentation to reasonably assure the origin concerning the in-region sourcing at the smelters facility or by other suitable means. For example if a bagging and tagging traceability scheme is used, the smelter must possess the final bag tag(s) and shipment number (e.g. iTSCi shipment number), and possess the supporting information which indicates mine or area of origin for any material related to the audit period. When the supply originates from an industrial operation, an OECDcompliant system (tracking, record keeping, on the ground assessment, etc.) must be in place and available from the smelter. The date printed on the export documentation will be used to demonstrate compliance. 

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 12 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

j) Again for Level 2B countries only, the amount of material coming from each mine and each artisanal region will be documented. The information comparing the mines production capacity or country's production capacity (in the case of ASM) will be included in the auditor’s final audit report. iii)

Level 3 includes all Level 1, Level 2A and 2B requirements plus the items immediately below (a-b): a) Beyond just an export document, documentation to show that all applicable taxes and royalties had been paid i.e. Analysis and Country Taxation documents (form B1 item 2 - CEEC Certificat d’Analyse des Minerais Stanniferes de Production Artisanale, Certificate of Analysis of Stanniferous minerals from artisanal production)

b) Prior to April 1st 2011, Level 1 and 2 plus all documents identified on the iTSCi Phase 1 documents list10. After April 1st 2011, the iTSCi Phase 1 documents are required, the smelter must ensure an on-the-ground risk assessment is carried out, and the source of information used to determine whether the mine was under the control of armed groups must be documented. While making such a determination, the smelter may rely on such sources as the US State Department’s Conflict Minerals Map, other recognized equivalent maps and other official sources, as they exist. If the smelter has more accurate and reliable sources of information than the maps mentioned above, these are acceptable in terms of this determination. b) Secondary/scrap materials purchased by the smelter must identify the supplier of the material, or provide information that allows the auditor to reasonably assume the material is secondary and not primary (e.g. sample analysis data). Each supplier will be documented through bill of lading or transportation documentation, or purchase agreement and/or product description. Both the description of the material and the operations of the supplier will be taken into consideration to determine if the material fits the secondary material definition of excluded items from the original source of origin requirement of the audit. If material does not fit the definition then compliance related to Section B.III.a (above) is required. Secondary materials received by the smelter for tolling will also be subjected to this provision. If a purchase agreement does not exist for the toll material, then another form(s) of documentation must be provided which identifies the supplier of the material and defines the tolling agreement. c) A provision is made to exclude purchased developmental, assay sample and other small quantities of materials from the scope of the compliance audit provided the 10

iTSCi Phase 1 List to be provided to Audit Firms directly. These documents were only collected from the 1st of July 2009 and cannot be valid before then. 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 13 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

aggregate amount over the audit period is less than that of sales of tin materials and each lot or shipment received is less than 0.1% contained tin versus relative to annual production. Slag, drosses, hardhead and other materials arising from the smelting or refining processes which are not able to be tracked to original mine source by the purchasing smelter during their audit will require the supplying-smelter to also pass a CFS audit or provide mine source of origin over the period of the supplied material which meets conflict-free expectation in order for the purchasing smelter to be able to become compliant.

C)

Process for Conducting the Audit

The third party auditing firms must conduct the audits in accordance with the requirements in ISO 19011:2002. A “reasonable” approach to making determinations should be employed as identified in the OECD Guidance and the U.S. SEC draft ruling. 1) The audit process will begin with the confirmation of the information provided by the smelter on the pre-audit checklist: Name, Location, Types of tin containing feed materials received, complete list of suppliers for each type of tin feed material, types of tin products produced, types of tin products sold, tin products transferred to other locations, tin materials transferred in from other company locations, unit operations on site where tin materials are processed. The pre-audit checklist should be returned to the EICC and GeSI Audit Coordinator to enable audit scheduling. The line-item summary must be completed and returned to the assigned auditor 14 calendar days prior to the audit start date. 2) The audited smelter will provide a copy of the Company Policy related to procurement of tin containing materials and the auditor will review it against part B.I of the Standard above. 3) The audited smelter will provide a list of total estimated tin inventory at the beginning of audit period (one year prior to the time of the audit) and at the end of the audit period, including inline material. 4) The audited smelter will provide a detailed total tin sales and toll quantity during the audit period. The auditor will select three (3) random monthly sales lots. The audited smelter will provide the specific sales receipts for those months. The auditor will sum up all sales receipts for those months and match them to the total sales quantity provided. 5) The audited smelter will provide a detailed list of all tin receipts from the beginning of the audit period to the time of the audit. 6) The audited smelter will use the information in steps 3-5 to conduct a total tin material balance (+/-10%) for the audit period to determine if the reported receipts, inventories, 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 14 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

lossess and sales figures provide a general agreement. The Auditor will validate the information. 7) The audited company will provide a list of all received tin materials from beginning of audit period to end of audit period. (including total amount on a tin basis) 8) The auditor will then inspect the warehouse and determine if all tin received/purchased inventory is accounted for and if inventory exists which is not identified on the submitted documents. See explanation for all sections in Part B.III of the Standard above. 9) The auditor will review documentation for all (100%) receipt or purchases of tin material for compliance to the standard. Exceptions will be noted in the final audit report. For each lot of material the auditor will determine if the exceptions create a reasonable doubt as to the authenticity of the origin of the material or that the origin of the material is conflict free by following the provided guidelines. See explanation for all sections in part B.III of the Standard above. 10) The auditor will review documentation for all (100%) existing inventory of tin purchased/received material for compliance to the standard. Exceptions will be noted in the final audit report. For each lot of material the auditor will determine if the exceptions create a reasonable doubt as to the authenticity of the origin of the material or that the origin of the material is conflict free by following the provided guidelines. See explanation for all sections in part B.III of the Standard above. 11) The auditor will then review documentation as well as visibly check samples of secondary tin-containing input materials to ensure it meets the definition of secondary which is excluded from the audit. Secondary materials not excluded from the audit will be incorporated into items 9 and 10 noted above. 12) If materials are found to originate from any Level 2B or Level 3 country after April 1st 2011, the auditor will assess the OECD Guidance compliance audit of the due diligence process relied on by the audited smelter. The audited smelter must have available the tracking and record keeping information validated by the OECD Guidance compliance audit that provides reasonable assurance that the origin of the material is valid and conflict free. The overall result of the OECD Guidance compliance audit is to be noted by the auditor in the final audit report. 13) If materials are found to originate from a Level 3 country prior to April 1st 2011, then the auditor will review the smelter's documentation as identified in Section B.III.a.iii 14) The auditor will summarize total tin receipts by country and mine of origin (see Line Item Summary). The auditor will then compare this summary to the plausibility report provided by EICC and GeSI. Exceptions will be noted in the final audit report.

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 15 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

15) The auditor will verify lot traceability by selecting at least 3 finished (sold) lots and follow the documentation back to the ore source (for continuous flow processes or inline batch mixing this may include determining the total inline capacity and residence time of the production line to predict incoming material lots as described in Section B.II.d above). The selected 3 finished lots may cover materials outside of the provisions of the audit (i.e. Received materials prior to the audit period) so will only be used to confirm lot traceability and not compliance. If irregularities are noted within the traceability assessment that covers materials within the audit period then further resolution as noted above and in Section B, IId is required. The traceability will follow 2 specific lots (excluding recycled/scrap) at each step of the process. Origin of ore source will be reviewed and will impact compliance if within the audit period or will be noted if outside of the audit period. Failure in matching product lots to incoming material lots is impossible and does not contribute to failure of the audit. 16) The auditor will prepare a summary report for the audited smelter and provide a copy to the EICC and GeSI Audit Review Committee. Documents supplied to the auditor which are utilized to complete the assessment: Audit Checklist - Checklist for implementing the audit - Audit Summary Results Template EICC and GeSI Audit Line Item Summary - Line item for summarizing documentation for each tin receipt - Explanation of Documentation items - Summary of key points in the OECD Guidance “On the Ground Assessment” . Plausibility Assessment Summary - Explanation of purpose and use - Tables of detailed country capabilities Example Information - Certificate of Origin (Acceptable/Unacceptable) - Export License - Certified Analysis/Sample - Mining License/Concession

D)

Summary Results of the Audit

1) Types of outcomes The audit will have 5 different potential outcomes at the conclusion of the audit review by the Audit Review Committee:

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 16 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

A) Conflict mineral (tin containing source from Level 3 areas which was reasonably believed to have been received or exported (as noted on export document) within the audit period) was found in the smelter records. Material is from Level 3 sources exported after 1st April 2011 without an OECD Guidance compliant scheme being utilized. Material from such scheme after April 1st would be considered compliant as long as the smelter audit is within one month after the scheme’s OECD compliance is validated (applies within 2011). For example as specified in part B.III.a.iii of the Standard. The result will be non-compliant. B) The smelter refuses to participate in the audit process or does not provide adequate information or access to facilities. Smelter shall not offer or accept bribes or other means of obtaining undue or improper advantage. The result will be non-compliant. C) There is insufficient documentation to substantiate the source of all tin containing materials. The smelter cannot or does not agree to provide further information. The result is non-compliant. D) There is insufficient documentation to reasonably substantiate the source of all tin containing materials. The smelter agrees to provide additional information to address documentation deficiencies identified by the audit. The additional information will be supplied to the auditors within 2 months and a follow-up assessment (as required by the auditor) will be completed within one additional month. The auditor will then determine if adequate information has been provided to reasonably substantiate the source of the tin containing materials. The result will be non-compliant if insufficient documentation remains. E) If adequate documentation is available which reasonably demonstrates the source of all tin containing purchases/receipts within the audit period were non conflict minerals then the result will be compliant. 2) Continuous Improvement Plans Should a smelter be found to be non-compliant then a corrective action plan needs to be implemented and verified prior to becoming compliant. The details of the action plan will be agreed to between the smelter and the Audit Review Committee of EICC and GeSI. If any lot of incoming tin ore or tin-containing material is identified to be non-compliant (either insufficient documentation or identified to be conflict minerals) then the smelter should quarantine this material immediately until reviewed by the EICC and GeSI audit review committee to discuss disposition. The smelter’s action plan must contain the following components: A) Disposition of any non-conforming tin material (inadequate documentation or reasonably identified as conflict mineral as per the Audit Standard) must be reviewed and approved 15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 17 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

by the EICC and GeSI Audit Review Committee prior to taking any action. This material must remain in the as-received tin-containing material state as it was originally purchased by or provided in a tolling agreement to the smelter (or in semi- or final processed state, if applicable), as it is described in the line item summary until the disposition plan is agreed. This will only apply to tin-containing material still residing at the smelter during the audit. The disposition will need to be verified – utilization of this material (or inadequate disposition action) by the smelter will result in immediate non-compliance. In order to avoid being non-compliant by obtaining follow-up documentation from the original supplier, the supplier will have to send all related documents/forms to allow the smelter to meet their requirements even before the material is further processed. B) Documented changes in the smelter’s purchasing policies and recognition of prior issues. These changes must be implemented within a 3 month period following the audit. C) A verification audit conducted by the initial auditor to ensure disposition of the nonconforming tin material and changes to purchasing policies. The entire actions of the audit will be repeated, covering the time period from the initial audit to the re-audit. D) After reviewing information from the second audit (the re-audit) then the audit review committee will determine whether that smelter can be identified as a compliant smelter or whether additional actions are required. For example a more frequent audit schedule may be required for the future. E) Any smelter that has a repeat non-compliance issue identified, or was unable to complete closure on open items within the 3-month post audit mitigation period will be deemed as non-compliant (subject to the final review by the Audit Review Committee mentioned in step D) and will be exempted from participating in the CFS program for a period of one year. 3) Disclosure and Non-Disclosure Agreements (NDAs): Compliant smelters will be posted on the EICC and GeSI websites and made available publicly. Additionally the Conflict Mineral policy of the smelter will also be posted. The detailed data collected during the audit will be made available only to the EICC and GeSI Audit Review Committee to ensure consistency, compile anonymous aggregate information, and identify common issues. The Audit Review Committee who has access to the detailed information are bound by NDA with EICC and GeSI to not share the audit details outside the committee. The Audit Review Committee will be primarily comprised of final OEMs (ie Apple, Intel, HP, etc) and the audit details will not be distributed outside of the Committee. Only in the case of an appeal by the smelter to EICC and GeSI would any relevant portions of the audit details be provided beyond the Committee. NDAs will be implemented separately between the auditing firm, the audit review committee, and the individual smelter. The following specific information will be publicly disclosed regarding the CFS program:

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 18 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

Names of Compliant Smelters Each Smelter's Conflict Mineral Policy Consolidated Information from all audits: Level 1 – Countries of Origin Level 2A – Countries of Origin, Mines of Origins (or regions for ASM) Level 2B - Additional disclosure of weights/amount of ore or concentrate for countries surrounding the DRC (specifically this includes: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, Sudan, Uganda, Tanzania, Zambia). The capacity of the mine the material was procured from will also be disclosed. In the case of ASM the country amount can be used. Level 3 – Level 2 (including weights) information plus the outcome of the OECD Guidance due diligence compliance audit.

About EICC (Electronic Industry Citizenship Coalition) The EICC was established in 2004 to improve social, economic, and environmental conditions in the global electronic supply chain through use of a standardized code of conduct. The EICC was incorporated in 2007 as an association to ensure greater awareness of the Code, and to expand its adoption across the industry. The EICC includes over 60 global electronics companies. For more information or to view the EICC Code of Conduct, see www.eicc.info or the latest EICC annual report. About GeSI (Global e-Sustainability Initiative) The Global e-Sustainability Initiative (GeSI) is an international strategic partnership of the Information Communications Technology (ICT) sector and organisations committed to creating and promoting technologies and practices that foster economic, environmental and social sustainability. Formed in 2001, GeSI’s vision is a sustainable world through responsible, ICT-enabled transformation. GeSI fosters global and open cooperation, informs the public of its members’ voluntary actions to improve their sustainability performance, and promotes technologies that foster sustainable development. GeSI partners with two UN organizations - the United Nations Environment Program (UNEP) and the International Telecommunications Union (ITU) - as well as a range of international stakeholders committed to ICT sustainability objectives. These partnerships help shape GeSI’s global vision regarding the evolution of the ICT sector, and how it can best meet the challenges of sustainable development. For more information, see www.gesi.org. For more information, contact: Mike Loch GeSI Extractives Work Group Co-Lead Board Representative [email protected]

15Sep2011

Bob Leet EICC Extractives Work Group Co-Lead [email protected]

EICC and GeSI Audit Standard and Instructions

Page 19 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.

Revision History Rev – 15Sep2011 Changes: Initial release of the protocol.

15Sep2011

EICC and GeSI Audit Standard and Instructions

Page 20 of 20

© 2011 Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative. All Rights Reserved.