0001178913-20-001586.txt : 20200526 0001178913-20-001586.hdr.sgml : 20200526 20200526060235 ACCESSION NUMBER: 0001178913-20-001586 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20191231 1.02 20191231 FILED AS OF DATE: 20200526 DATE AS OF CHANGE: 20200526 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RADWARE LTD CENTRAL INDEX KEY: 0001094366 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-30324 FILM NUMBER: 20907929 BUSINESS ADDRESS: STREET 1: 22 RAOUL WALLENBERG STREET CITY: TEL AVIV STATE: L3 ZIP: 69710 MAIL ADDRESS: STREET 1: 575 CORPORATE DR STREET 2: LOBBY 2 CITY: MAHWAH STATE: NJ ZIP: 07430 SD 1 zk2024469.htm SD


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

Form SD
 
SPECIALIZED DISCLOSURE REPORT


Radware Ltd.
(Exact Name of Registrant as Specified in Charter)

 
Israel
 000-30324
 N/A
 (State or Other Jurisdiction
of Incorporation)
 (Commission File No.)
(I.R.S. Employer
Identification Number)

22 Raoul Wallenberg Street, Tel Aviv, Israel
 
6971917  
(Address of Principal Executive Offices)   
 
 (Zip Code)
 
Doron Abramovitch
Chief Financial Officer
 +972-3-7668666
(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:

☒  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from: January 1 to December 31, 2019.



CAUTIONARY STATEMENT REGARDING FORWARD-LOOKING STATEMENTS

Except for the historical information contained herein, the statements contained in this report (including exhibits) may contain forward-looking statements, within the meaning of the Private Securities Litigation Reform Act of 1995.  Actual outcomes could differ materially from those anticipated in these forward-looking statements as a result of various factors.
 
We urge you to consider that statements which use the terms “believe,” “do not believe,” “expect,” “plan,” “intend,” “estimate,” “anticipate,” and similar expressions are intended to identify forward-looking statements.  Examples of forward-looking statements include statements relating to our future plans and any other statement that does not directly relate to any historical or current fact.  These statements reflect our current views, expectations and assumptions with respect to future events, are based on assumptions, are subject to risks and uncertainties and may not prove to be accurate.  These risks and uncertainties, as well as others, are discussed in greater detail in Radware’s latest Annual Report on Form 20-F and Radware’s other filings with, or submissions to, the Securities and Exchange Commission ("SEC"). Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date hereof.
 
Except as required by applicable law, we do not intend to update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.
 
INTRODUCTION
 
This Specialized Disclosure Report on Form SD (this “Form SD”) of Radware Ltd. (“Radware,” the “Company”  or “we”) for the year ended December 31, 2019 is presented to comply with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (the “Rule”).
 
The Rule was adopted by the SEC to implement reporting and disclosure requirements related to “Conflict Minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten, originating in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), as directed by the Rule.
 
Our responsible sourcing efforts were designed to align, in all material respects, with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the “OECD Guidance”). The OECD Guidance distinguishes between the roles of and the corresponding due diligence recommendations addressed to upstream companies and downstream companies in the supply chain, whereby “upstream” generally means the mineral supply chain from the mine to smelters or refineries, and “downstream” generally means the minerals supply chain from smelters/refiners to retailers. Accordingly, we designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners as we believe that we qualify as a “downstream” company.
 
In connection with the Rule, we have adopted a policy with respect to our sourcing of conflict minerals. The full text of our Conflict Minerals Policy and previously filed Conflict Minerals Reports are available on our website at https://www.radware.com/corporategovernance/conflictminerals.
 
The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference herein.
 
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Section 1 - Conflict Minerals Disclosure
 
Item 1.01 – Conflict Minerals Disclosures and Report
 
In accordance with the Rule and our Conflict Minerals Policy, we have evaluated our current product lines. As more fully described in the Conflict Minerals Report filed as Exhibit 1.01 hereto (the "Conflict Minerals Report"), our supply chain is very complex, and we are several tiers removed from smelters and refiners and, as a downstream company, we do not have direct business relationships with smelters or refiners. In particular, the Company and our suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold (collectively “3TG”) -related materials after processing by smelters or refiners. As a result, despite having conducted a good faith reasonable country of origin inquiry ("RCOI"), we currently do not have sufficient information from our suppliers or independent third party audit bodies (“Third Party Audit”) or other sources to determine the precise country of origin of the conflict minerals used in our products or to identify the facilities used, or likely used, to process those conflict minerals, and we must rely on our In-Scope Suppliers, as defined in the Conflict Minerals Report, to provide information on their upstream supplier sourcing.

In light of the above, we cannot rule out the possibility that some conflict minerals in these products originated, or may have originated, in the DRC or other Covered Countries and are not from entirely recycled or scrap resources. Accordingly, as required by the Rule and in accordance with the OECD Guidance, we have conducted certain due diligence activities, as more fully described in the Conflict Minerals Report. The boundaries and extent of the RCOI inquiry are established in the due diligence management systems, and the efforts to determine the reasonable country of origin of the necessary Conflict Minerals is implemented in unison with the due diligence steps. Therefore, there is significant overlap between our RCOI efforts and the due diligence measures we employed.

Conflict Minerals Disclosure
 
Copies of this Form SD and the Company's Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at https://www.radware.com/corporategovernance/conflictminerals.
 
Item 1.02 -  Exhibit
 
See the Company's Conflict Minerals Report, filed as Exhibit 1.01 hereto.
 
Section 2 – Exhibits
 
Item 2.01 - Exhibits
 

3

 
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.
 
 
RADWARE LTD.
 
 
 
 
 
Date: May 26, 2020
By:
/s/  Doron Abramovitch
 
 
 
Doron Abramovitch
 
 
 
Chief Financial Officer
 

4

 

EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01

 
Exhibit 1.01

Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2019

This Conflict Minerals Report for the year ended December 31, 2019 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company” or “we”) pursuant to Rule 13p-1 (the "Rule" or "Rule 13p-1") promulgated under the Securities Exchange Act of 1934, as amended, and Form SD thereunder.

The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, tungsten and Gold (“conflict minerals” or “3TG”).

In general, if an SEC registrant, like Radware, has reason to believe that any of the conflict minerals in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”) and that such conflict minerals may not originate entirely from recycled or scrap sources, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures as well as measures to address and analyze risks in its supply chain.

This Report relates to the process undertaken for Radware's products that were manufactured or contracted to be manufactured during the calendar year 2019 and that may contain 3TG minerals that are necessary to the functionality or production of such products manufactured or to the products contracted to be manufactured.

A copy of this Report, as well as the Form SD that we filed with the SEC, are available on our website at https://www.radware.com/corporategovernance/conflictminerals.

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in the Rule and Form SD as well as SEC Release No. 34-67716 issued by the SEC on August 22, 2012.

Except as set forth otherwise in this Report, Radware has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers to comply with Radware’s Conflict Minerals Policy or Radware’s other relevant policies for suppliers and contractors, such as our Supplier Code of Conduct, may affect Radware’s future determinations under Rule 13p-1.

As part of Radware's Labor Practice and Human Rights Policy, Radware respects the protection of human rights, including the basic human rights of employees and workers, and supports and recognizes relevant international frameworks and agreements, such as the United Nations’ Declaration of Human Rights and the International Labor Organization’s Declaration of Fundamental Principles. The Company aims to uphold the human rights of those affected by its business activities, and in particular, of the workers engaged in its supply chain. Accordingly, the Company aspires to source components and materials from suppliers that share our values regarding respect for human rights, integrity and environmental responsibility, and that comply with applicable legal standards and requirements. To that end, the Company upholds a Code of Conduct for Suppliers that addresses issues associated with mineral sourcing and/or conflict minerals. By upholding standards for its suppliers, Radware expresses its commitment to using minerals in its products that do not directly or indirectly finance armed conflict in the DRC or one of the other Covered Countries, or that benefit, directly or indirectly, armed groups in those countries.



1.          
Overview

Company Overview
 
We are a provider of cyber security and application delivery solutions for physical, cloud, and software defined data centers. Our solutions portfolio secures the digital experience by providing infrastructure, application, and corporate IT protection and availability services to enterprises globally. Our solutions are deployed by, among others, enterprises, carriers and cloud service providers. Our solutions are offered in two main categories: products and customer services. Our product offering includes a range of physical, software-based products, product subscriptions and cloud-based subscriptions (or a combination of these) for enterprise and carrier data centers, as part of their IT and application infrastructure. Our customer services offering includes technical support, professional services, managed services and training and certification to our customers. We sell our solutions primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, whereas most of our direct sales are to strategic customers.

For more information about Radware, please visit www.radware.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.

Responsible Sourcing Efforts in Our Supply Chain

We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products that were manufactured or contracted to be manufactured in 2019, and that the 3TG is or could be necessary to the functionality or production of our products.

The products that we manufacture are highly complex, typically containing thousands of parts that are sourced from direct suppliers. In general, as a downstream company (as further explained under Section 2.1 below), we primarily rely on third-party assembly and manufacturing vendors to provide our finished products and, in this respect, these vendors typically receive components and subassemblies included in our products from other suppliers and subcontractors.

We have relationships with a network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we must rely on our direct suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors so that they may provide us with accurate information regarding the origin, or likely origin, of 3TG in the components we purchase from them and that is necessary to the production or functionality of our products. In particular, many of our supplier contracts have fixed durations, and we cannot unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our due diligence efforts with respect to 3TG content. However, as we enter into supplier contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires relevant suppliers to provide us with information on the likely source and chain of custody of 3TG and relevant smelters or refiners. In attempting to determine the source of the 3TG content in our products, i.e., through our supply chain due diligence, we do not seek to eliminate sourcing from the DRC or other Covered Countries, but rather to ensure that our suppliers responsibly source the necessary minerals in a fashion that does not directly or indirectly fund or support the armed conflict ongoing in that region.

2


Reasonable Country of Origin Inquiry (RCOI)
 
We have determined that requesting our direct suppliers to complete the standard Conflict Minerals Reporting Template  (“CMRT”),  as well as following the steps described under Section 2 below (Due Diligence Process), represent our reasonable efforts to determine the mines or locations of origin of 3TG in our supply chain.
 
We developed a risk-based approach (Pareto analysis) that focuses on the suppliers that represented as of December 31, 2019, in aggregate, at least 90% of our spend on the manufacturing costs of our finished products that were shipped in 2019. We identified in total five (5) relevant suppliers (the “In-Scope Suppliers”). We collected all relevant data from our In-Scope Suppliers submitted in the CMRT of at least version 5.10 or higher ("CMRT") published by the Responsible Minerals Initiatives' ("RMI")  in order to monitor the due diligence process and to gather and assess information from all such In-Scope Suppliers in a standardized format that is approved by an independent third party audit body, such as the RMI.
 
We sent letters to our In-Scope Suppliers to explain the Rule and to refer them to online training materials and instructions.
 
We reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. Out of the five In-Scope Suppliers, all of the suppliers (100%) completed and returned to us a CMRT of at least version 5.10 or higher.
 
Based on these efforts, we have reason to believe that some of our products may contain necessary conflict minerals that potentially originated in the DRC or one of the Covered Countries and are not entirely from recycled or scrap sources. Therefore, according to the Rule, we have engaged in the Due Diligence Process described in detail in Section 2 below.
 
2.          Due Diligence Process

2.1        Design of Due Diligence

Our due diligence measures have been designed to conform, in all material respects, with the internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016)" and related Supplements (the “OECD Guidance”). The OECD Guidance distinguishes between the roles of and the corresponding due diligence recommendations addressed to upstream companies and downstream companies in the supply chain, whereby “upstream” generally means the mineral supply chain from the mine to smelters or refineries, and “downstream” generally means the minerals supply chain from smelters/refiners to retailers. We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners as we believe that we are a “downstream” company.

2.2           Due Diligence Performed

2.2.1        Establish Strong Management Systems

3


Corporate Policy

We have adopted a Conflict Minerals Policy (our "Policy" or our "Conflict Minerals Policy") that is aimed at achieving responsible sourcing of the necessary conflict minerals. The Policy is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals.

Internal Team

We have established a management system to support supply chain due diligence related to the necessary 3TG. Our management system includes a steering committee headed by the Company's Legal Department (the “CM Steering Committee”), and a team of subject matter functions such as supplier management, operations and legal.

Supply Chain Control Systems and Transparency

We requested that all In-Scope Suppliers provide information to us regarding 3TG and relevant smelters or refiners using the CMRT of at least version 5.10 or higher. We collect and analyze all relevant data submitted to us through the CMRT to maintain a smelter or refiner database for Radware. This database of records is compared against the list of smelters or refiners that have received 'conformant' or 'active' designation according to the RMI's independent smelter or refiner audit program, namely the Responsible Minerals Assurance Process ("RMAP").

We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the sourcing of minerals originating from conflict-affected and high-risk areas that are under scrutiny for human right abuses, namely from the DRC or other Covered Countries, as per the stipulations of the Rule.

Grievance Mechanism

Our Conflict Minerals Policy is available to the public on our website at https://www.radware.com/corporategovernance/conflictminerals and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof. Suppliers and other external parties are encouraged to contact their regular sourcing channel if they wish to seek guidance on the application of this approach, or if they wish to report a grievance in relation to our Conflict Minerals Policy.

Maintaining Records

We maintain data records relating to our due diligence efforts for the five-year duration recommended by the OECD Guidance. Radware stores current and former CMRTs received from suppliers to maintain traceability and transparency.

Supplier Engagement

We maintain an electronic portal that directs suppliers to resources related to conflict minerals, including FAQs from the SEC.

We established a conflict minerals webpage to host our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs. Our webpage is hosted at https://www.radware.com/corporategovernance/conflictminerals.

4


We also provide guidance on the topic for relevant suppliers and engage in on-going outreach to our suppliers in order to collect, validate and archive supplier responses that relate to our conflict minerals due diligence process and supply chain inquiry.

As we enter into supplies contracts or renew existing supplier contracts, we seek to add, where feasible, a conflict minerals contract clause that requires suppliers to provide us with information on the likely source of the necessary 3TG they provide us, and relevant smelters or refiners.

Our internal controls also include a company-wide Code of Conduct that outlines expected behaviors from all of our employees, contractors and consultants in engaging with suppliers. We have also adopted a Supplier Code of Conduct in which we convey to our suppliers, contractors and relevant third parties our expectations regarding, among other topics, responsible sourcing practices. The full text of our Code of Conduct and Supplier Code of Conduct is available on our website at https://www.radware.com/corporategovernance.

2.2.2         Identify and Assess Risks in the Supply Chain

We approached five In-Scope Suppliers and received responses from all (100%) of the In-Scope Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our In-Scope Suppliers and compared the information provided therein against the Standard Smelter List of Compliant and Active Smelters from the RMAP - a list issued by RMI that aims to identify smelters or refiners that have systems in place to assure the responsible sourcing of conflict minerals, including those conflict minerals originating from the DRC or other Covered Countries. We rely on these In-Scope Suppliers, whose components may contain 3TG, to provide us with information on the likely  source and chain of custody of conflict minerals contained in the components supplied to us that are necessary to the production and/or to the functionality of our products. Our In-Scope Suppliers are similarly reliant upon information provided by their suppliers.

 2.2.3         Design and Implement a Strategy to Respond to Risks

We implemented the following strategy to address the results of our risk assessment described in Section 2.2.2 above. The goal of the design and implementation of our risk management strategy is not to eliminate sourcing from the DRC or other Covered Countries, but rather to encourage participation with the RMI and other relevant third party audit bodies, where possible. The following steps were taken to implement a strategy to help us assess potential risks:


The CM Steering Committee held periodic meetings to review progress and assess the risks identified.

We reviewed the responses that we received from In-Scope Suppliers and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to In-Scope Suppliers that did not respond to our requests for information.

We sent, where applicable, follow up letters to unresponsive In-Scope Suppliers and to In-Scope Suppliers who declared they sourced conflict minerals from the DRC or other Covered Countries, asking them to complete their supply chain due diligence process in order to validate that all smelters or refiners from the DRC or other Covered Countries are compliant with the RMI or other independent conflict-free smelter validation programs, such as the London Bullion Market (LBMA) or the Responsible Jewelry Council (RJC).

Engaged relevant senior management, including our Vice President and General Counsel, who were briefed on our due diligence efforts, risk analysis results and mitigation efforts.

We approached In-Scope Suppliers that we identified as possibly sourcing from smelters or refiners located in the DRC or other Covered Countries that did not receive a conformant or active designation from the RMI, and asked for a corrective action plan.

5


2.2.4          Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices

We rely on industry-wide initiatives, such as RMI, to conduct risk assessments at the upstream level.

Since we do not have direct sourcing relationships with conflict mineral smelters or refiners, we did not perform direct audits of these entities within our supply chain.

2.2.5          Report on Supply Chain Due Diligence

Our supply chain conflict mineral due diligence efforts are described in this report. This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals and is filed with the SEC.

3. Results of Assessment

Based on information provided by our In-Scope Suppliers as well as by RMI, the results of our due diligence investigation on the dates covered by this Report, are as follows:


We were successful in approaching all In-Scope Suppliers.


Out of the five (5) In-Scope Suppliers, all (100%) completed and returned the CMRTs to us. Based on the CMRTs we received from these In-Scope Suppliers:


o
100% of the responses received provided data at the following levels.

Category of RMI CMRT Filed
Percentage of Responsive In-Scope Suppliers
Company level
40% (2 out of 5 suppliers)
User defined
20% (1 out of 5 suppliers)
Product list
40% (2 out of 5 suppliers)


o
We identified that 92% of the reported smelters or refiners (“SoRs”), or 254 SoRs, as of the publication of this Report, are conformant or active in the RMI’s RMAP audit program, as detailed below:

SoR RMI Status (Conformant, Active and Undocumented):

Conformant
254 Smelters or Refiners, 92% of Smelters or Refiners
Active
0 Smelters or Refiners, 0% of Smelter or Refiners
Undocumented
23 Smelters or Refiners, 8% of Smelters or Refiners
Total
277 Smelters or Refiners, 100% of Smelters or Refiners

6


Based on the information provided by the In-Scope Suppliers as well as by RMI, as of the date of this Report, Radware believes that the facilities that may have been used to process the conflict minerals in Radware’s products may include the smelters or refiners listed in Annex I below.

Based on the information provided by the In-Scope Suppliers as well as by RMI, as of the date of this Report, Radware believes that the countries of origin of the conflict minerals contained in its products may include the countries listed in Annex II below.

The information gathered from our In-Scope Suppliers is not collected on a continuous, real-time basis.

In addition, Radware can only provide reasonable and good faith, yet not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information arises from direct suppliers as well as from independent third party audit programs such as the RMI and the LBMA.

4. Future Risk Mitigation Efforts

We currently intend to continue working with our global supply chain to achieve the responsible sourcing of minerals from conflict areas and to comply with applicable regulations to the extent that they are required:


Continue implementing risk management measures and follow up processes with regard to non-responsive suppliers or suppliers working with undocumented suppliers according to current information from the RMI’s RMAP program.

As described in our Conflict Minerals Policy, to the extent that we have reason to believe that any of our 3TG suppliers source, or potentially source, such minerals from facilities that may, directly or indirectly, support the on-going conflict in the DRC or the other Covered Countries, we encourage such suppliers to establish an alternative source of 3TG sourcing that does not support such conflict, as outlined in the OECD Guidance. This engagement is important to us as we are committed to discouraging the propagation of human rights abuses in our supply chain. It should be noted, however, that as of December 31, 2019, none of our In-Scope Suppliers sourced from smelters or refiners from the DRC or other Covered Countries, according to the information provided in their CMRT declarations to the Company.

Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts.

Continue to direct our suppliers through our website and direct communications to information and training resources with the goal of maintaining a 100% response rate and improving the content of the supplier’s survey responses.

Request suppliers to procure materials through validated smelters or refiners pursuant to the RMI or other approved resources and request suppliers to take mitigating actions in case they do not.

Continue to validate supplier responses using information collected via independent conflict-free smelter or refiner validation programs, such RMI's RMAP program.

Continue to engage in regular and ongoing risk assessment through our suppliers’ annual data submissions.

7


Annex I – List of Smelters and/or Refiners
 
Metal
Smelter Look-Up
Smelter Country
Gold
8853 S.p.A.
ITALY
Gold
Advanced Chemical Company
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
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
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
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
Do Sung Corporation
KOREA, REPUBLIC OF
Gold
Doduco
GERMANY
Gold
Dowa
JAPAN
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
FSE Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Henan Zhongyuan Gold Smelter of Zhongjin Gold Co. Ltd.
CHINA
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
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
JCC
CHINA

8



Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
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
Lingbao Gold Co., Ltd.
CHINA
Gold
L'Orfebre S.A.
ANDORRA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
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
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
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohio Precious Metals, LLC
UNITED STATES
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
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 PMR B.V.
NETHERLANDS
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE

9



Gold
Safimet S.p.A
ITALY
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Gold
Shandong Gold Mine(Laizhou) Smelter Co., Ltd.
CHINA
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
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Tokuriki Honten Co., Ltd.
JAPAN
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
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zijin Mining Industry Corporation
CHINA
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
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 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

10



Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
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
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineração Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining & Smelting
JAPAN
Tantalum
Molycorp Silmet A.S.
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
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
Tranzact, Inc.
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES
Tin
An Vinh Joint Stock Mineral Processing Company
VIETNAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
Cooper Santa
BRAZIL
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV Serumpun Sebalai
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
VIETNAM
Tin
Elmet S.L.U.
SPAIN
Tin
EM Vinto
BOLIVIA
Tin
Fenix Metals
POLAND

11



Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
GuangXi China Tin
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 Nanshan
CHINA
Tin
Kai Unita Trade Limited Liability Company
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-Chimique N.V.
BELGIUM
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA
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 Cipta Persada Mulia
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Justindo
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Rajehan Ariq
INDONESIA

12



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 Indústria e Comércio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIETNAM
Tin
Thaisarco
THAILAND
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIETNAM
Tin
VQB Mineral and Trading Group JSC
VIETNAM
Tin
White Solder Metalurgica
BRAZIL
Tin
Yunnan Chengfeng
CHINA
Tin
Yunnan Geiju Zili Metallurgy Co. Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
ALMT Corp
JAPAN
Tungsten
Asia Tungsten Products Vietnam Ltd
VIETNAM
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
Global Tungsten & Powders Corp.
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck GmbH
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
Hunan Chenzhou Mining Group 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 Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA

13



Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES
Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
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
VIETNAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIETNAM
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
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

14

 
Annex II – Country of Origin Inquiry (COO)
 
Gold
Tantalum
Tin
Tungsten
ANDORRA
BRAZIL
BELGIUM
AUSTRIA
AUSTRALIA
CHINA
BOLIVIA
BRAZIL
AUSTRIA
ESTONIA
BRAZIL
CHINA
BELGIUM
GERMANY
CHINA
GERMANY
BRAZIL
INDIA
INDONESIA
JAPAN
CANADA
JAPAN
JAPAN
KOREA, REPUBLIC OF
CHILE
KAZAKHSTAN
MALAYSIA
PHILIPPINES
CHINA
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
PERU
RUSSIAN FEDERATION
FRANCE
MEXICO
PHILIPPINES
UNITED STATES OF AMERICA
GERMANY
RUSSIAN FEDERATION
POLAND
VIETNAM
INDIA
THAILAND
SPAIN
 
INDONESIA
UNITED STATES OF AMERICA
TAIWAN
 
ITALY
 
THAILAND
 
JAPAN
 
UNITED STATES OF AMERICA
 
KAZAKHSTAN
 
VIETNAM
 
KOREA, REPUBLIC OF
 
 
 
KYRGYZSTAN
 
 
 
MEXICO
 
 
 
NETHERLANDS
 
 
 
PHILIPPINES
 
 
 
POLAND
 
 
 
RUSSIAN FEDERATION
 
 
 
SINGAPORE
 
 
 
SOUTH AFRICA
 
 
 
SPAIN
 
 
 
SWEDEN
 
 
 
SWITZERLAND
 
 
 
TAIWAN
 
 
 
THAILAND
 
 
 
TURKEY
 
 
 
UNITED ARAB EMIRATES
 
 
 
UNITED STATES OF AMERICA
 
 
 
UZBEKISTAN
 
 
 

 15