SEC Document


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD
SPECIALIZED DISCLOSURE REPORT




HALLIBURTON COMPANY
(Exact name of registrant as specified in its charter)

 
                                    
Delaware
001-03492
No. 75-2677995
(State or other jurisdiction of
(Commission File Number)
(IRS Employer
incorporation or organization)
 
Identification No.)
 
 
 
 
 
 
3000 North Sam Houston Parkway East
 
 77032
Houston, Texas
 
 
 (Address of principal executive offices)
 
(Zip Code)
 
 
 
Christian A. Garcia
Senior Vice President, Finance and Acting Chief Financial Officer
(281) 871-2699
(Name and telephone number, including area code, of the person to contact in connection with this report)


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:

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period January 1, 2015 to December 31, 2015.












SECTION 1 - CONFLICT MINERALS DISCLOSURE

Item 1.01 Conflict Minerals Disclosure and Report

Halliburton Company (the Company or Halliburton) has conducted a reasonable country of origin inquiry (RCOI) of its suppliers to determine whether any conflict minerals, as defined by paragraph (d)(3) of Item 1.01 of Form SD, necessary to the functionality or production of a product manufactured or contracted to be manufactured by the Company during 2015 (the Products) originated from the Democratic Republic of the Congo or an adjoining country, as defined by paragraph (d)(1) of Item 1.01 of Form SD. Halliburton exercised due diligence on the source and chain of custody of its conflict minerals, as discussed in paragraph (c)(1) of Item 1.01 of Form SD, that conforms to the Organization for Economic Cooperation and Development (OECD) Due Diligence Framework for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

In accordance with paragraph (c) of Item 1.01 of Form SD, Halliburton’s Conflict Minerals Report (CMR) for the reporting period January 1, 2015 to December 31, 2015 is provided as Exhibit 1.01 hereto, and is publicly available at Halliburton's website: http://ir.halliburton.com/phoenix.zhtml?c=67605&p=irol-sec.

This CMR was subject to an independent private sector audit per paragraph (c)(1)(ii) of Item 1.01 of Form SD.

Item 1.02 Exhibit

The Company has contemporaneously filed the CMR with this Form SD, which is attached as Exhibit 1.01.


SECTION 2 - EXHIBITS

Item 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report for the reporting period January 1, 2015 to December 31, 2015.


SIGNATURES

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 duly authorized undersigned.

Date: May 24, 2016
 
HALLIBURTON COMPANY
 
 
 
 
By:
/s/ Christian A. Garcia
 
 
Christian A. Garcia
 
 
Senior Vice President, Finance and
 
 
Acting Chief Financial Officer



SEC Exhibit
Exhibit 1.01



Conflict Minerals Report

Section I - Introduction of Applicability

Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, this report has been prepared for the reporting period January 1, 2015 to December 31, 2015 (Reporting Period).

Halliburton Company (“the Company”, “Halliburton”, “We” or “Our”) is a leading provider of services and products to the oil and natural gas industry. Halliburton has significant manufacturing operations in various locations, including the United States, Canada, China, Malaysia, Singapore, and the United Kingdom.

Halliburton comprises thirteen product service lines (PSLs). The PSLs operate in two divisions: Drilling and Evaluation, and Completion and Production. Our Consulting and Project Management PSL works across both divisions and is the spearhead of our integrated-services strategy. Its financial results are included in the Drilling and Evaluation Division. PSLs are primarily responsible and accountable for strategy, technology development, process development, people development, and capital allocation.

Drilling and Evaluation Division
Baroid
Sperry Drilling
Drill Bits & Services
Testing & Subsea
Landmark
Wireline & Perforating

Completion and Production Division
Artificial Lift
Multi-Chem
Cementing
Production Enhancement
Completion Tools
Production Solutions
Pipeline and Process Services

Supporting Both Divisions
Consulting & Project Management

During the Reporting Period, the products that were manufactured, or were contracted to be manufactured, contain one or more of the following minerals: tantalum, tin, tungsten, and gold (3TG).


1


Listed below are examples of where 3TG may be present in Halliburton products:
Metal
Industry Applications
Applications in Halliburton
Tantalum
Refined from Columbite-tantalite (coltan)
Capacitors, resistors
Tantalum Capacitors, Alloys
Tin
Refined from Cassiterite
Chemical solutions, capacitors, electrodes, Tin alloys, dioxide, electroplating
Integrated Circuits, Pins, Resistors, Capacitors, PCBs, and Soldering
Tungsten
Refined from Wolframite
Tungsten Carbide, Alloy, light bulb, heating elements, and Tungsten Inert Gas Welding
Electrodes, Tungsten carbide (Drill bits), Welding
Gold
Electrical wiring, connectors, contact, and gold plating
Contacts, Pins, Connectors, Cable Harness, Wire Harness, gold plating

This Conflict Minerals Report was subject to an independent private sector audit per Item 1.01 of Form SD, paragraph (c)(1)(ii).


Section II - Reasonable Country of Origin Inquiry (RCOI)

Halliburton has conducted RCOI among our suppliers on the source and chain of custody of certain minerals necessary to the functionality or production of a product manufactured or contracted to be manufactured by the Company (the Products) during the Reporting Period to determine whether they originated from the Democratic Republic of the Congo (DRC) or an adjoining country.

The RCOI for the Reporting Period was designed in accordance with the Organization for Economic Cooperation and Development (OECD) Due Diligence Framework for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the OECD Framework). The suppliers could either respond to our RCOI online via SAP eSourcing portal or return the completed Conflict Minerals Reporting Template (CMRT), a survey tool commonly utilized to identify smelters or refiners (SORs). We required our direct suppliers to submit CMRT version 4.0 or newer.



2


Section III - Halliburton Design of Conflict Minerals Program1

We are a downstream purchaser of products that include conflict minerals. Our program was designed in accordance with the 5-Step OECD Framework as follows:

OECD Step 1: Establish strong company management systems
Developed and published the Conflict-Free Sourcing Procurement Policy on the external website of Halliburton at http://www.halliburton.com/en-US/about-us/supplier-relations/conflict-minerals-policy.page?node-id=hgeyxt74. This policy is applicable to our global operations including our Supply Chain;
Assembled a cross-functional internal team among Procurement, Material Management, Finance, Information Technology, and the Legal departments led by our Procurement, Materials & Logistics (PM&L) Performance Management Group;
Established a system of controls and transparency by developing a due diligence process using the CMRT. We utilized the SAP e-Sourcing portal to distribute and collect RCOI information from our direct suppliers. This portal gives Halliburton better reporting and data validation capabilities, with real time supplier information from our Enterprise Resource Planning (ERP) system, and allows our suppliers to access our request via an already familiar tool, increasing the participation rate;
Stored relevant records in an electronic database on a SharePoint site and in our in-house SAP e-Sourcing portal;
Educated 3TG suppliers through Halliburton’s RCOI and due diligence process to take reasonable steps and make good faith efforts to conduct due diligence on the materials supplied to Halliburton; and
Offered the Conflict-Free Sourcing Initiative (CFSI) eLearning Academy “Conflict Minerals” course for direct suppliers and selected Halliburton employees.

OECD Step 2: Identify and assess risks in the supply chain
Identified direct suppliers that supply products to Halliburton which may contain 3TG. The suppliers were selected in good faith based on the following criteria:
Products supplied to Halliburton plants within the Reporting Period;
Harmonized Tariff Codes and Material Groups of supplied products that may contain metal;
Product sales from Halliburton procurement plants to third party customers; and
Halliburton newly acquired manufacturers with the reporting obligations pursuant to Rule 13p-1 under the Securities Exchange Act of 1934;
Conducted a survey using the CMRT and SAP e-Sourcing portal. A phone number and email address were available for suppliers and internal stakeholders to correspond;
For distributors, provided a product list so distributors could work with second-tier suppliers and asked distributors for a product-level CMRT. If necessary, directly interacted with second-tier suppliers requesting their responses;
Implemented deadlines for suppliers’ CMRT submissions;
Followed up with non-responsive suppliers requesting their responses. Requested from suppliers the correct/most current point of contact to update our master contact list;
Reviewed suppliers’ CMRTs and their reported SORs list, identified any inconsistencies, and required suppliers to take corrective actions and update their submission as needed; and
Compared the SORs identified by the supply chain with the CFSI Conflict-Free Smelter Program
(CFSP) or an equivalent third-party audit program such as the London Bullion Market Association (LBMA) and Responsible Jewelry Council (RJC) to validate suppliers’ submission.
1 Section III has been audited by an Independent Private Sector Auditor (IPSA). The audit report is set forth as Annex III.

3



OECD Step 3: Design and implement strategy to respond to identified risks
Amended our Standard Master Purchase Agreement and Standard Purchase Order Terms & Conditions template to include conflict-free sourcing and disclosure requirements. Communicated these updates to internal stakeholders;
Adopted a risk management plan to review due diligence of suppliers and SORs;
Monitored and tracked direct suppliers and selected SORs that were identified as not meeting our requirements;
Performed risk mitigation efforts by following up with direct suppliers for validation and additional information. We also encouraged smelters with CFSP “Outreach Required” status to participate in an independent third-party audit program;
Monitored internal mailbox daily to respond to inquiries in timely manner;
Provided findings and progress reports at least bi-weekly to senior management, including the senior director of PM&L Performance Management and the senior manager of Business Controls;
Attended various webinars and the CFSI Annual Conference 2015 to understand new developments and best practices; and
Obtained an Independent Private Sector Audit (IPSA) by Crowe Horwath attached to this Report.

OECD Step 4: Carry out independent third-party audit of smelter/refiner's due diligence process

        

Supported CFSI efforts with our membership (Halliburton member code is HALL). Halliburton also reviewed meeting minutes and discussion from the CFSI Smelter Engagement Team (SET), which contacts smelters to encourage participation and reports potential smelters not in the CFSP database; and
Participated in periodic Oil & Gas Services Working Group for Conflict Minerals meetings and/or conference calls to discuss best practices as an industry group. Six companies, including Halliburton, have sent joint letters via email to notify non-compliant smelters stating the expectations of compliance industry wide.

OECD Step 5: Report on supply chain due diligence
Report annually on supply chain due diligence by filing with the SEC a Form SD and Conflict Minerals Report; and
Report annually on our company website at
http://ir.halliburton.com/phoenix.zhtml?c=67605&p=irol-sec.



4


Section IV - Due Diligence Measures2

In accordance with the OECD Framework, Halliburton has exercised the following due diligence measures on the source and chain of custody of 3TG contained in our products which may have originated from the Democratic Republic of the Congo (DRC) or an adjoining country and may not have come from recycled or scrap sources:
Developed and published the Conflict-Free Sourcing Procurement Policy on the external website of Halliburton at http://www.halliburton.com/en-US/about-us/supplier-relations/conflict-minerals-policy.page?node-id=hgeyxt74. We informed direct suppliers via our RCOI email;
Conducted a conflict minerals survey by reaching to direct suppliers via email and our SAP eSourcing portal. We informed the suppliers that, upon their request, an available Year-To-Date product list purchased by Halliburton can be provided via email. We requested our direct suppliers to provide an updated CMRT if additional information becomes available;
Educated 3TG suppliers through Halliburton’s RCOI by providing suppliers with various conflict minerals resources (3TG definition, CFSI website, link to download the most current CMRT, SEC website, how to walk through our SAP eSourcing portal);
Offered the CFSI eLearning Academy “Conflict Minerals” course for direct suppliers and selected Halliburton employees. Halliburton sent step-by-step instructions to walk our suppliers and employees through the course information and access. Through Halliburton internal Learning Management System (HalU), we created a course to add completion credit for employees’ training record;
Sent multiple reminders to non-responsive suppliers requesting their responses via phone calls and emails. Involved category managers and procurement employees to leverage suppliers’ relationship to reach out to non-responsive suppliers;
Reviewed responses from suppliers and requested corrective actions and update if the suppliers provided incomplete or potentially inaccurate information;
Compared the SORs identified by the supply chain with the CFSP or an equivalent third-party audit program, such as the London Bullion Market Association (LBMA) and Responsible Jewelry Council (RJC);
Forwarded the name of the SOR to the CFSI staff if we could not confirm a SOR so they could perform additional diligence;
Attended the CFSI Annual Conference 2015 to understand new developments and best practices. Halliburton also financially supported this initiative through membership to CFSI, along with over 300 other member companies and associations from seven different industries, contributing to a range of tools and resources, including the CFSP;
Sent 37 outreach emails to date to operational SORs with CFSP “Outreach Required” status identified from CFSI SET team to encourage their participation in an independent third-party audit program. We periodically compared their status with the CFSP database and continue to contact each smelter up to three times if their status has not changed. To date, we have sent follow-up emails with 30 SORs twice and 15 SORs three times; and
Participated in periodic Oil & Gas Services Working Group for Conflict Minerals meetings and/or conference calls to understand new developments and best practices as an industry group. Six companies, including Halliburton, have sent joint letters to notify eight non-compliant SORs identified by the group stating the expectations of compliance industry wide.



2 Section IV has been audited by an Independent Private Sector Auditor (IPSA). The audit report is set forth as Annex III.

5


Section V - Results of Due Diligence Measures

A substantial percentage of selected suppliers confirmed that their supply to Halliburton did not contain conflict minerals originating from the DRC or an adjoining country. Halliburton did, however, receive some incomplete responses from those surveyed. Some suppliers were unable to determine if they had provided conflict minerals originating from the DRC or an adjoining country, and other suppliers did not respond. Additionally, we determined that certain SORs identified by our suppliers’ responses purchase 3TG from the DRC or an adjoining country. While these SORs have been verified compliant with the CFSP, the information provided by these SORs was not at a product-level specific to the materials and components we use. As such, Halliburton does not have sufficient information to determine all SORs in our supply chain, as well as the country of origin of the 3TG or other conflict minerals.

Based on the information provided by Halliburton’s suppliers and our own due diligence efforts through May 3, 2016 with 281 operational SORs (see Annex I), we have identified as below:
208 SORs (74.02%) have received compliant status; meaning audited and found compliant with the relevant CFSP protocol;
9 SORs identified to source 3TG from the DRC or adjoining countries. However to the best of our knowledge, none of these SORs are known to source minerals that benefit armed group in the DRC and adjoining countries.
34 SORs (12.10%) have received active status, meaning engaged in the program but not yet certified compliant; and
the remaining 39 SORs (13.88%) have not yet received compliant or active status. These will be noted as “Others” in Annex I.


6


For the 281 SORs mentioned above, we used the CFSI RCOI report available to CFSI members to identify the countries of origin. The countries of origin for the Products purchased by the identified SORs are listed in Annex II.

Number of Each Mineral by CFSP Audit Status


Geographic Location of the 281 Operational SORs Providing 3TG


Geographic Location per Region of the 281 Operational SORs Providing 3TG



7


Section VI - Risk Mitigation for Future Due Diligence

Halliburton will continually work towards a conflict-free supply chain. There are many stakeholders that are dependent directly or indirectly on legal mining operations in the DRC or an adjoining country which are not benefiting armed groups in that region. Halliburton promotes verifiable conflict-free sourcing from the DRC or an adjoining country.

Halliburton will take the following measures to enhance its due diligence on the source and chain of custody of conflict minerals and to mitigate the risk that its necessary conflict minerals benefit armed groups in the DRC or an adjoining country:
Encourage suppliers to evaluate the business relationship with the SORs that refuse to proceed with an independent third-party audit program;
Explore options on how to improve identification and reporting by 3TG product-level identification in our SAP system;
Continue providing assistance and education for conflict minerals programs for direct suppliers so that the compliance requirements can escalate down to more tiers of our supply chain;
Continue encouraging eligible SORs’ identification from the direct suppliers; and
Continue directly contacting identified non-compliant SORs in our supply chain to participate in an independent third-party audit program.

Reference: The OECD Framework can be found at http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.


Section VII - Inherent Limitations on Due Diligence Measures

As a downstream purchaser of conflict minerals, Halliburton’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our 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. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud. Halliburton has undertaken measures to verify responses and minimize these limitations.

Halliburton’s supply chains are diverse between product service lines. Our products are many tiers removed from the SORs. To determine whether any 3TG were sourced from the DRC or an adjoining country, we relied on our direct suppliers responding with accurate SOR identification information. Many suppliers provided responses with SOR information based on a company or divisional level, rather than a product-level specific to the materials and components we use. As such, Halliburton was unable to identify all SORs in the supply chain for the Products we sold in the Reporting Period.

8



ANNEX I - Smelters or Refiners (SORs)


The information in this Annex is an aggregation of data provided by the Halliburton’s suppliers and not a confirmation of conflict minerals contained in our products.

Metal
Smelter or Refiner Name
Smelter Location
Smelter Audit Status≡
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Compliant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Compliant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Active
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Compliant
Gold
Argor-Heraeus SA*
SWITZERLAND
Compliant
Gold
Asahi Pretec Corporation
JAPAN
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Others
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
Caridad
MEXICO
Others
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Cendres + Métaux SA
SWITZERLAND
Active
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Chugai Mining
JAPAN
Others
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Active
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
Active
Gold
Dowa
JAPAN
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Others
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Company Limited
CHINA
Compliant
Gold
Asahi Refining USA Inc.
UNITED STATES
Compliant
Gold
Asahi Refining Canada Limited
CANADA
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Compliant
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Others
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Compliant

9


Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Compliant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Compliant
Gold
Metalor Technologies SA
SWITZERLAND
Compliant
Gold
Metalor USA Refining Corporation
UNITED STATES
Compliant
Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
MEXICO
Compliant
Gold
Mitsubishi Materials Corporation
JAPAN
Compliant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Compliant
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
Compliant
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
RUSSIAN FEDERATION
Compliant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox SA
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
Sabin Metal Corp.
UNITED STATES
Others
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Others
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería SA
SPAIN
Compliant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
Others
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Compliant
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Compliant
Gold
The Great Wall Gold and Silver Refinery of China
CHINA
Others
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Compliant
Gold
Torecom
KOREA, REPUBLIC OF
Active
Gold
Umicore Brasil Ltda.
BRAZIL
Compliant
Gold
Umicore SA Business Unit Precious Metals Refining*
BELGIUM
Compliant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Compliant
Gold
Valcambi SA
SWITZERLAND
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Compliant
Gold
Materion
UNITED STATES
Compliant
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
PAMP SA
SWITZERLAND
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Others
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Others
Gold
Advanced Chemical Company
UNITED STATES
Active
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Others
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Compliant

10


Gold
Guangdong Jinding Gold Limited
CHINA
Others
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Umicore Precious Metals Thailand
THAILAND
Compliant
Gold
Lingbao Gold Company Limited
CHINA
Others
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Others
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Others
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Active
Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Others
Gold
Geib Refining Corporation
UNITED STATES
Active
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Others
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Others
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Active
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Others
Gold
Singway Technology Co., Ltd.
TAIWAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Others
Gold
Republic Metals Corporation
UNITED STATES
Compliant
Gold
Faggi Enrico S.p.A.
ITALY
Active
Gold
WIELAND Edelmetalle GmbH
GERMANY
Active
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Others
Gold
Morris and Watson
NEW ZEALAND
Others
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Active
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Compliant
Gold
KGHM Polska Miedž Spółka Akcyjna
POLAND
Active
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Others
Gold
T.C.A S.p.A
ITALY
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant
Gold
Korea Zinc Co. Ltd.
KOREA, REPUBLIC OF
Active
Gold
Remondis Argentia B.V.
NETHERLANDS
Others
Gold
AURA-II
UNITED STATES
Others
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES
Compliant
Tantalum
F&X Electro-Materials Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Compliant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemicals
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES
Compliant
Tantalum
Ulba Metallurgical Plant JSC*
KAZAKHSTAN
Compliant
Tantalum
Zhuzhou Cemented Carbide
CHINA
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
Compliant
Tantalum
KEMET Blue Powder*
UNITED STATES
Compliant
Tantalum
Global Advanced Metals Boyertown*
UNITED STATES
Compliant

11


Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Global Advanced Metals Aizu
JAPAN
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tantalum
LSM Brasil S.A.
BRAZIL
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
Compliant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Compliant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Compliant
Tantalum
KEMET Blue Metals
MEXICO
Compliant
Tantalum
Plansee SE Reutte
AUSTRIA
Compliant
Tantalum
QuantumClean
UNITED STATES
Compliant
Tantalum
FIR Metals & Resource Ltd.
CHINA
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Compliant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Others
Tin
Alpha
UNITED STATES
Compliant
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Fenix Metals
POLAND
Compliant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Compliant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Others
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Others
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Others
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Active
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CHINA
Others
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
Malaysia Smelting Corporation (MSC)*
MALAYSIA
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
PT Artha Cipta Langgeng
INDONESIA
Compliant
Tin
PT Babel Inti Perkasa
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant

12


Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Mitra Stania Prima
INDONESIA
Compliant
Tin
PT Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
Thaisarco*
THAILAND
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
Yunnan Tin Group (Holding) Company Limited
CHINA
Compliant
Tin
Rui Da Hung
TAIWAN
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
PT Karimun Mining
INDONESIA
Active
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
Tin
PT Justindo
INDONESIA
Compliant
Tin
PT Aries Kencana Sejahtera
INDONESIA
Compliant
Tin
PT BilliTin Makmur Lestari
INDONESIA
Compliant
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Active
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
Others
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Active
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Compliant
Tin
PT Panca Mega Persada
INDONESIA
Compliant
Tin
Melt Metais e Ligas S/A
BRAZIL
Compliant
Tin
Metallic Resources, Inc.
UNITED STATES
Compliant
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
VQB Mineral and Trading Group JSC
VIETNAM
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
Elmet S.L.U. (Metallo Group)
SPAIN
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
PT Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
PT Tirus Putra Mandiri
INDONESIA
Others
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIETNAM
Active
Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Active
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Active
Tin
Gejiu Jin Ye Mineral Co., Ltd.
CHINA
Active
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
An Thai Minerals Company Limited
VIETNAM
Active

13


Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Active
Tin
Chenzhou Yunxiang Mining Smelting Compang LTD
CHINA
Active
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Others
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Wolfram Bergbau und Hütten AG*
AUSTRIA
Compliant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CHINA
Others
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
Compliant
Tungsten
Kennametal Fallon
UNITED STATES
Active
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
CHINA
Compliant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
Compliant
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
Others
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Compliant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIETNAM
Compliant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIETNAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Active
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Active
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIETNAM
Compliant
Tungsten
Pobedit, JSC
RUSSIAN FEDERATION
Others
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Active
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CHINA
Others
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Others
Tungsten
Niagara Refining LLC
UNITED STATES
Compliant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Active
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Active
≡ Reported by the CFSI’s CFSP by May 03, 2016
Compliant - audited and found compliant with the relevant CFSP protocol
Active - engaged in the program but not yet compliant
Others - have not yet received compliant or active status

* SORs reported to source from DRC or an adjoining country

14


ANNEX II - Countries of Origin


The information in this Annex is an aggregation of data provided by the Halliburton’s suppliers and not a confirmation of conflict minerals contained in our products.

Angola
France
Portugal
Argentina
Germany
Republic of Congo
Australia
Guyana
Russia
Austria
Hungary
Rwanda
Belgium
India
Sierra Leone
Bolivia
Indonesia
Singapore
Brazil
Ireland
Slovakia
Burundi
Israel
South Africa
Cambodia
Japan
South Korea
Canada
Kazakhstan
Spain
Central African Republic
Kenya
Suriname
Chile
Laos
Switzerland
China
Luxembourg
Taiwan
Colombia
Madagascar
Tanzania
Côte D'Ivoire
Malaysia
Thailand
Czech Republic
Mongolia
Uganda
Djibouti
Mozambique
United Kingdom
Ecuador
Namibia
United States of America
Egypt
Netherlands
Vietnam
Estonia
Nigeria
Zambia
Ethiopia
Peru
 


15


ANNEX III - Independent Private Sector Audit


INDEPENDENT ACCOUNTANT’S REPORT


The Board of Directors
Halliburton Company
Houston, Texas

We have examined:
whether the design of Halliburton Company’s (the “Company”) due diligence framework as set forth in Section III of the Conflict Minerals Report for the reporting period from January 1, 2015 through December 31, 2015, is in conformity, in all material respects, with the criteria set forth in the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”), and
whether the Company’s description of the due diligence measures it performed, as set forth in section IV of the Conflict Minerals Report for the reporting period from January 1, 2015 through December 31, 2015, is consistent, in all material respects, with the due diligence process that the Company undertook.

Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.

Our examination was not conducted for the purpose of evaluating:
The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance;
The completeness of the Company’s description of the due diligence measures performed;
The suitability of the design or operating effectiveness of the Company’s due diligence process;
Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance;
The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or
The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products.

Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than section II.

16



In our opinion,
the design of the Company’s due diligence framework for the reporting period from January 1, 2015 through December 31, 2015, as set forth in section III of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and
the Company’s description of the due diligence measures it performed as set forth in section IV of the Conflict Minerals Report for the reporting period from January 1, 2015 through December 31, 2015, is consistent, in all material respects, with the due diligence process that the Company undertook.

/s/ Crowe Horwath LLP
Dallas, Texas
May 24, 2016


17