EX-1.01 2 novt-ex101_6.htm EX-1.01 novt-ex101_6.htm

 

 

Exhibit 1.01

 

NOVANTA INC.

Conflict Minerals Report

For the Period January 1 to December 31, 2017

 

 

Introduction

 

This report has been prepared by Novanta Inc. (“Novanta,” the “Company,” “we,” or “our”) for the period from January 1, 2017 to December 31, 2017 (the “Reporting Period”) in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, which was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”).

 

The term “conflict minerals” is defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are currently limited to tin, tantalum, tungsten, and gold (“the 3TGs”) for the purposes of this report. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain 3TGs that are necessary to the functionality or production of their products.

 

The Company conducted an analysis of its products and found that 3TGs are present in many of the electronic parts and components included in the Company’s products. Therefore, the Company is subject to the reporting obligations of Rule 13p-1.

 

The Company’s supply chain is complex.  The Company uses a wide variety of raw materials, key components and parts that are purchased from both domestic and international suppliers.  The Company also uses contract manufacturers to make certain key components used in the production of the Company’s finished products. As the Company’s manufacturing process consists mostly of final assembly of components and parts that are purchased from suppliers, there are typically several tiers of companies between Novanta and the mines, smelters or refiners of conflict minerals.  The Company does not directly source 3TG minerals as raw materials.  Therefore, it is difficult to identify the origin of conflict minerals that are present in the Company’s products.

 

Due to the size and complexity of the Company’s supply chain, Novanta has to rely on its suppliers to provide information on the origin of the conflict minerals contained in the components and materials supplied to Novanta, including sources of conflict minerals present in the materials and components supplied to Novanta’s suppliers themselves.

 

Company Overview and Products Covered by This Report

 

Novanta is a global supplier of core technology solutions that give medical and advanced industrial Original Equipment Manufacturers (“OEMs”) a competitive advantage. We combine deep proprietary technology expertise and competencies in photonics, vision and precision motion with a proven ability to solve complex technical challenges. This enables Novanta to engineer core components and sub-systems that deliver extreme precision and performance, tailored to our customers’ demanding applications. The driving force behind our growth is the team of innovative professionals who share a commitment to innovation and customer success.

 

The Company is organized into three reportable segments: Phontonics, Vision and Precision Motion. The Photonics segment designs, manufactures and markets photonics-based solutions, including CO2 laser sources, galvanometer and polygon-based optical scanning components and scan heads, continuous wave diode-pumped solid state lasers and optical light engines. The Vision segment designs, manufactures and markets a wide range of medical grade technologies, including insufflators, pumps, video cameras, light sources and video couplers, gamma probes and laser lithotripters for minimally invasive surgery, high definition visualization solutions, imaging informatics products, wireless video signal transmission devices, embedded capacitive and resistive touch panel technology, camera-based machine vision products and solutions, RFID technologies, embedded and handheld data collection products for barcode scanning, rugged thermal

 

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chart recorders, and light and color measurement devices. The Precision Motion segment designs, manufactures and markets optical encoders, precision motor and motion control products, air bearing spindles and precision machined components. The vast majority of the Company’s product offerings are sold to OEM customers.

 

Reasonable Country of Origin Inquiry

 

The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals necessary to the functionality or production of its products.  Our RCOI was reasonably designed to determine whether such conflict minerals originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (collectively, the “Covered Countries”) or came from scrap or recycled sources. The Company began the scoping process by compiling a list of all suppliers that provide us with products that may contain any 3TGs. Once this list was populated, we provided the list and the applicable contacts for the suppliers to our third-party service provider (the “Service Provider”). This list was then uploaded to our service provider’s software platform that allows us to store and manage supplier requests, documentation, and data.

 

Our scoping process was then further refined by removing service providers, indirect materials suppliers, and suppliers who are now inactive. This ensures that all suppliers surveyed actually provided items to Novanta that were used in the final products in 2017. Using this process, we were able to remove approximately 5% of suppliers from scope for the 2017 reporting period.

 

Our Service Provider then conducted the supplier survey portion of the RCOI on our behalf. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 5.0 or higher, developed by the Responsible Business Alliance and The Global e-Sustainability Initiative, the suppliers were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide materials to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.

  

During the supplier survey process, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform of the Service Provider. Non-responsive suppliers were contacted a minimum of three times and then were also contacted by our Service Provider’s Supply Chain Team in one-on-one communications. This included at least two follow-ups in order to encourage their responses via CMRTs. Members of Novanta supply chain teams contacted the remaining non-responsive suppliers via email and telephone follow-ups. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our Service Provider have offered training to suppliers through webinars, videos, documentation, and one-on-one discussions.

 

The RCOI also included automated data validation on all submitted CMRTs through our Service Provider. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our Service Provider’s system for future reporting and transparency. As of May 11, 2018, approximately 3% of our surveyed suppliers had yet to correct their invalid submissions.

 

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.

 

Design of Due Diligence

 

The Company’s due diligence process and efforts have been developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-risk Area (second edition) and the related supplements for gold and for tin, tantalum and tungsten (collectively referred to as the “OECD Guidance”).  The Company designed its due diligence process and

 

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measures to conform in all material respects with the OECD framework.

 

Due Diligence Performed

 

1.

Maintain Strong Company Management System

 

1.1.

Internal Team

 

The Company’s conflict minerals compliance program is sponsored by the Chief Executive Officer and is executed by a global task force that comprises of the Global Sourcing Leader, the Corporate Controller and Chief Accounting Officer, and a project leader for each of the product lines.  The product line project leader is typically the director of operations or manager of the procurement function and is supported by procurement and engineering professionals knowledgeable about the products and materials contained in those products.

 

The Company developed Conflict Minerals Process procedures that are required to be followed to perform the RCOI by all businesses globally. Supply chain leaders are responsible for ensuring compliance with Conflict Minerals Process procedures at the local business level.  

 

1.2.

Control Systems

 

The Company developed a global Conflict Minerals policy and Supplier Code of Conduct that are communicated widely both internally and externally and are posted on the Company’s external website. The Company clearly states its commitment to comply with laws and regulations surrounding conflict minerals.  

 

The Company requires all of its suppliers to use materials that have been sourced in a legally responsible manner and to confirm that they have not, and will not, procure conflict minerals from mines that are not DRC conflict free. These expectations are stated in our Conflict Minerals Policy and Supplier Code of Conduct, which can be accessed at: www.novanta.com/about-us/corporate-citizenship/.

 

1.3.

Supplier Engagement

 

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 5.10 and our Service Provider’s software reporting tool for collecting conflict minerals declarations from our suppliers.

 

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to the conflict minerals program. This includes obtaining information to support the chain of custody of the 3TGs identified in our products. We included Conflict Minerals terms and conditions on our purchase orders for raw materials and components used in our production process.

 

1.4.

Grievance Mechanism

 

The Company maintains an Ethics Hotline, a 24x7 confidential messaging system and an anonymous electronic mailbox managed by a third-party service provider, which provides means for employees, customers and suppliers to report deviations from the Company’s Code of Ethics and Business Conduct.

 

1.5.

Document Retention

 

As part of the Conflict Minerals Process procedures, the Company established documentation and record maintenance mechanism to ensure that relevant documentation is retained in a structured electronic database maintained by our Service Provider.


 

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2.

Identify and Assess Risks in the Supply Chain

 

We have relied on supplier responses for information about the source of conflict minerals contained in the parts and components that they supplied to us. Similarly, our direct suppliers also relied on information provided by their suppliers. This chain of information created a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.

 

Each facility that meets the Responsible Minerals Initiative (“RMI”) definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Our Service Provider uses three factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:

 

 

Geographic proximity to the DRC and covered countries;

 

 

Responsible Minerals Assurance Process (“RMAP”) audit status; and

 

 

Credible evidence of unethical or conflict sourcing.

 

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers in their CMRT. The criteria used to evaluate the strength of the program are:

 

 

Has the supplier established a conflict minerals sourcing policy?

 

 

Has the supplier implemented due diligence measures for conflict-free sourcing?

 

 

Does the supplier review due diligence information received from suppliers against its expectations?

 

 

Does the supplier’s review process include corrective action management?

 

When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

 

3.

Design and Implement a Strategy to Respond to Identified Risks

 

We have developed a risk management plan to ensure that all identified risks are responded to. This includes communicating any identified risks to upper management, escalating suppliers who do not meet our expectations, and increased supplier education.

 

If the Company discovers through its RCOI efforts that any conflict minerals directly or indirectly benefit the armed groups in the Covered Countries, the Company will take steps to work with its suppliers to stop using such conflict minerals and, if not possible, stop purchasing such raw materials or components from the supplier in question.

 

4.

Carry Out Independent Third-Party Audit

 

We do not have any direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain. We rely on industry efforts, such as the RMI, to influence smelters and refiners to become certified as part of RMI’s Responsible Minerals Assurance Process.

 

5.

Report Annually on Supply Chain Due Diligence

 

This Report, which constitutes our annual report on our due diligence efforts, is available on our website at www.novanta.com/about-us/corporate-citizenship/ and is filed with the SEC.

 

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Results of Due Diligence

 

As of May 11, 2018, the Company had surveyed 1,559 suppliers that are considered in scope and received responses from approximately 68% of such suppliers. The suppliers that provided us with a CMRT were also asked to submit smelters or refiners (“SOR”) information.

 

Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and are unable to represent that 3TGs from the processing facilities they listed had actually been used in the components that they supplied to us.  The quality of the responses that we received from our surveyed suppliers continue to be varied. Many of the responses included the names and locations of smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our Service Provider followed up on these invalid responses, urging the suppliers to resubmit the CMRT and include smelter or refiner information. There are still suppliers that are unable to provide smelters and refiner information.

 

In accordance with OECD Guidance, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRTs. Our Service Provider compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2017 calendar year.

 

In order to assess the risk that any of these smelters posed to our supply chain, our Service Provider determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

 

Appendix A lists the smelters and refiners that our suppliers have reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix B also includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and the RMI.

 

Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 257 smelters that are deemed RMAP Conformant, namely, they are conformant with the RMAP assessment protocols. There are 11 more smelters or refiners that are deemed RMAP Active, which means that these facilities have committed to undergo a RMAP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.

 

Additional Steps to Be Taken to Mitigate Risks

 

The Company will continue to work with those suppliers who have not responded, responded with invalid smelters and refiners information, or responded as “DRC Conflict Undeterminable” to identify the source of such minerals using available tools, such as the CMRT and the related Smelter Reference list that is publicly available.  Should a supplier conclude, and report to us, that they have conflict minerals sourced from the Covered Countries and benefited armed groups, the Company will require such suppliers to implement measures to become DRC conflict free and find alternative suppliers to the extent alternative DRC conflict free sources of supply are available. 

 

Safe Harbor and Forward-Looking Statements

 

Certain statements in this Conflict Minerals Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 and are based on current expectations and assumptions that are subject to risks and uncertainties. All statements contained in this Conflict Minerals Report that do not relate to matters of historical fact should be considered forward-looking statements, and are generally identified by words such as “will,”“expects,” “intends,” “plans,” “believes,” “anticipates,” and other similar expressions.  These forward-looking

 

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statements include, but are not limited to, statements regarding expectation or intention relating to our compliance efforts and expected actions.  These statements are neither promises nor guarantees, but involve risks and uncertainties that may cause future expectations or actions to be different. Undue reliance should not be placed on these statements, which are only effective as of the date of this report. The Company disclaims any obligation to update any forward-looking statements as a result of developments occurring after the date of this document except as required by law.

 


 

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Appendix A

 

The following is a list of identified smelters or refiners for the 2017 reporting period:

 

Metal

Standard Smelter Name

Smelter or Refiner Country

Gold

Abington Reldan Metals, LLC

UNITED STATES

Gold

Advanced Chemical Company

UNITED STATES

Gold

African Gold Refinery

UGANDA

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

Gold

Al Etihad Gold LLC

UNITED ARAB EMIRATES

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

Gold

Argor-Heraeus S.A.

SWITZERLAND

Gold

Asahi Pretec Corp.

JAPAN

Gold

Asahi Refining Canada Ltd.

CANADA

Gold

Asahi Refining USA Inc.

UNITED STATES

Gold

Asaka Riken Co., Ltd.

JAPAN

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

Gold

AU Traders and Refiners

SOUTH AFRICA

Gold

Aurubis AG

GERMANY

Gold

Bangalore Refinery

INDIA

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Gold

Boliden AB

SWEDEN

Gold

C. Hafner GmbH + Co. KG

GERMANY

Gold

Caridad

MEXICO

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

Gold

Cendres + Métaux S.A.

SWITZERLAND

Gold

Chimet S.p.A.

ITALY

Gold

Chugai Mining

JAPAN

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

Gold

DODUCO Contacts and Refining GmbH

GERMANY

Gold

Dowa

JAPAN

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

Gold

Eco-System Recycling Co., Ltd.

JAPAN

Gold

Elemetal Refining, LLC

UNITED STATES

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

Gold

Geib Refining Corporation

UNITED STATES

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

Gold

Guangdong Jinding Gold Limited

CHINA

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

Gold

HeeSung

KOREA, REPUBLIC OF

Gold

Heimerle + Meule GmbH

GERMANY

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

 

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Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

Gold

Hwasung CJ Co., Ltd.

KOREA, REPUBLIC OF

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

Gold

Istanbul Gold Refinery

TURKEY

Gold

Italpreziosi

ITALY

Gold

Japan Mint

JAPAN

Gold

Jiangxi Copper Co., Ltd.

CHINA

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Gold

Kazzinc

KAZAKHSTAN

Gold

Kennecott Utah Copper LLC

UNITED STATES

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

Gold

Lingbao Gold Co., Ltd.

CHINA

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

Gold

L'Orfebre S.A.

ANDORRA

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

Gold

Marsam Metals

BRAZIL

Gold

Materion

UNITED STATES

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Gold

Metalor Technologies S.A.

SWITZERLAND

Gold

Metalor USA Refining Corporation

UNITED STATES

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

MEXICO

Gold

Mitsubishi Materials Corporation

JAPAN

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

Gold

Modeltech Sdn Bhd

MALAYSIA

Gold

Morris and Watson

NEW ZEALAND

Gold

Morris and Watson Gold Coast

AUSTRALIA

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Gold

Nadir Metal Rafineri San. Ve Tic. A.Ş.

TURKEY

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Gold

NH Recytech Company

KOREA, REPUBLIC OF

Gold

Nihon Material Co., Ltd.

JAPAN

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

 

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Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

Gold

PAMP S.A.

SWITZERLAND

Gold

Pease & Curren

UNITED STATES

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Gold

Planta Recuperadora de Metales SpA

CHILE

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

Gold

PX Précinox S.A.

SWITZERLAND

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

Gold

Remondis Argentia B.V.

NETHERLANDS

Gold

Republic Metals Corporation

UNITED STATES

Gold

Royal Canadian Mint

CANADA

Gold

SAAMP

FRANCE

Gold

Sabin Metal Corp.

UNITED STATES

Gold

Safimet S.p.A

Italy

Gold

SAFINA A.S.

CZECH REPUBLIC

Gold

Sai Refinery

INDIA

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

Gold

SAXONIA Edelmetalle GmbH

GERMANY

Gold

Schone Edelmetaal B.V.

NETHERLANDS

Gold

SEMPSA Joyería Platería S.A.

SPAIN

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

Gold

Singway Technology Co., Ltd.

TAIWAN

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Gold

Solar Applied Materials Technology Corp.

TAIWAN

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

Gold

Sudan Gold Refinery

SUDAN

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

Gold

SungEel HiTech

KOREA, REPUBLIC OF

Gold

T.C.A S.p.A

ITALY

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Gold

Tony Goetz NV

BELGIUM

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

Gold

Torecom

KOREA, REPUBLIC OF

Gold

Umicore Brasil Ltda.

BRAZIL

Gold

Umicore Precious Metals Thailand

THAILAND

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Gold

United Precious Metal Refining, Inc.

UNITED STATES

Gold

Universal Precious Metals Refining Zambia

ZAMBIA

Gold

Valcambi S.A.

SWITZERLAND

Gold

Western Australian Mint trading as The Perth Mint

AUSTRALIA

Gold

WIELAND Edelmetalle GmbH

GERMANY

Gold

Yamamoto Precious Metal Co., Ltd.

JAPAN

Gold

Yokohama Metal Co., Ltd.

JAPAN

 

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Gold

Yunnan Copper Industry Co., Ltd.

CHINA

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Tantalum

Asaka Riken Co., Ltd.

JAPAN

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Tantalum

D Block Metals, LLC

UNITED STATES

Tantalum

Duoluoshan

CHINA

Tantalum

Exotech Inc.

UNITED STATES

Tantalum

F&X Electro-Materials Ltd.

CHINA

Tantalum

FIR Metals & Resource Ltd.

CHINA

Tantalum

Global Advanced Metals Aizu

JAPAN

Tantalum

Global Advanced Metals Boyertown

UNITED STATES

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

Tantalum

H.C. Starck Co., Ltd.

THAILAND

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

Tantalum

H.C. Starck Inc.

UNITED STATES

Tantalum

H.C. Starck Ltd.

JAPAN

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

Tantalum

KEMET Blue Metals

MEXICO

Tantalum

KEMET Blue Powder

UNITED STATES

Tantalum

King-Tan Tantalum Industry Ltd.

CHINA

Tantalum

LSM Brasil S.A.

BRAZIL

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

Tantalum

Mineracao Taboca S.A.

BRAZIL

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Tantalum

NPM Silmet AS

ESTONIA

Tantalum

Power Resources Ltd.

MACEDONIA

Tantalum

QuantumClean

UNITED STATES

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

Tantalum

RFH Tantalum Smeltry Co., Ltd.

CHINA

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

Tantalum

Taki Chemicals

JAPAN

Tantalum

Telex Metals

UNITED STATES

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

CHINA

Tin

Alpha

UNITED STATES

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

Tin

China Tin Group Co., Ltd.

CHINA

Tin

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

 

10

 


 

Tin

CV Ayi Jaya

INDONESIA

Tin

CV Dua Sekawan

INDONESIA

Tin

CV Gita Pesona

INDONESIA

Tin

CV Tiga Sekawan

INDONESIA

Tin

CV United Smelting

INDONESIA

Tin

CV Venus Inti Perkasa

INDONESIA

Tin

Dowa

JAPAN

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

Tin

EM Vinto

BOLIVIA

Tin

Estanho de Rondônia S.A.

BRAZIL

Tin

Fenix Metals

POLAND

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

Tin

Gejiu Jinye Mineral Company

CHINA

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

CHINA

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

CHINA

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Tin

Melt Metais e Ligas S.A.

BRAZIL

Tin

Metallic Resources, Inc.

UNITED STATES

Tin

Metallo Belgium N.V.

BELGIUM

Tin

Metallo Spain S.L.U.

SPAIN

Tin

Mineracao Taboca S.A.

BRAZIL

Tin

Minsur

PERU

Tin

Mitsubishi Materials Corporation

JAPAN

Tin

Modeltech Sdn Bhd

MALAYSIA

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

Tin

Operaciones Metalurgical S.A.

BOLIVIA

Tin

Pongpipat Company Limited

MYANMAR

Tin

PT Aries Kencana Sejahtera

INDONESIA

Tin

PT Artha Cipta Langgeng

INDONESIA

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

Tin

PT Babel Inti Perkasa

INDONESIA

Tin

PT Bangka Prima Tin

INDONESIA

Tin

PT Bangka Serumpun

INDONESIA

Tin

PT Bangka Tin Industry

INDONESIA

Tin

PT Belitung Industri Sejahtera

INDONESIA

Tin

PT Bukit Timah

INDONESIA

Tin

PT DS Jaya Abadi

INDONESIA

Tin

PT Eunindo Usaha Mandiri

INDONESIA

Tin

PT Inti Stania Prima

INDONESIA

 

11

 


 

Tin

PT Karimun Mining

INDONESIA

Tin

PT Kijang Jaya Mandiri

INDONESIA

Tin

PT Lautan Harmonis Sejahtera

INDONESIA

Tin

PT Menara Cipta Mulia

INDONESIA

Tin

PT Mitra Stania Prima

INDONESIA

Tin

PT O.M. Indonesia

INDONESIA

Tin

PT Panca Mega Persada

INDONESIA

Tin

PT Premium Tin Indonesia

INDONESIA

Tin

PT Prima Timah Utama

INDONESIA

Tin

PT Refined Bangka Tin

INDONESIA

Tin

PT Sariwiguna Binasentosa

INDONESIA

Tin

PT Stanindo Inti Perkasa

INDONESIA

Tin

PT Sukses Inti Makmur

INDONESIA

Tin

PT Sumber Jaya Indah

INDONESIA

Tin

PT Timah (Persero) Tbk Kundur

INDONESIA

Tin

PT Timah (Persero) Tbk Mentok

INDONESIA

Tin

PT Tinindo Inter Nusa

INDONESIA

Tin

PT Tommy Utama

INDONESIA

Tin

Resind Industria e Comercio Ltda.

BRAZIL

Tin

Rui Da Hung

TAIWAN

Tin

Soft Metais Ltda.

BRAZIL

Tin

Super Ligas

Brazil

Tin

Thaisarco

THAILAND

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Tin

Yunnan Tin Company Limited

CHINA

Tungsten

A.L.M.T. TUNGSTEN Corp.

JAPAN

Tungsten

ACL Metais Eireli

BRAZIL

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Tungsten

H.C. Starck Smelting GmbH & Co.KG

GERMANY

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

Tungsten

Japan New Metals Co., Ltd.

JAPAN

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

 

12

 


 

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Tungsten

Kennametal Fallon

UNITED STATES

Tungsten

Kennametal Huntsville

UNITED STATES

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Tungsten

Moliren Ltd

RUSSIAN FEDERATION

Tungsten

Niagara Refining LLC

UNITED STATES

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

VIET NAM

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

 

 


 

13

 


 

Appendix B

 

The list below sets out possible countries of origin of 3TGs used in the manufacture of our products containing 3TGs for the 2017 reporting year.  The list is based on publicly available information, our reasonable country of origin inquiries, and other due diligence efforts. However, for the reasons described in the CMR, these possible countries of origin cannot be linked to our products with reasonable certainty.

 

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, and Zimbabwe.

 

 

***

 

14