0001178913-18-001819.txt : 20180531 0001178913-18-001819.hdr.sgml : 20180531 20180531160243 ACCESSION NUMBER: 0001178913-18-001819 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20171231 1.02 20171231 FILED AS OF DATE: 20180531 DATE AS OF CHANGE: 20180531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MAZOR ROBOTICS LTD. CENTRAL INDEX KEY: 0001566844 STANDARD INDUSTRIAL CLASSIFICATION: SURGICAL & MEDICAL INSTRUMENTS & APPARATUS [3841] IRS NUMBER: 000000000 STATE OF INCORPORATION: L3 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-35920 FILM NUMBER: 18871548 BUSINESS ADDRESS: STREET 1: 5 SHACHAM ST. STREET 2: PO BOX 3104 CITY: CAESAREA NORTH INDUSTRIAL PARK STATE: L3 ZIP: 3088900 BUSINESS PHONE: 97246187101 MAIL ADDRESS: STREET 1: 5 SHACHAM ST. STREET 2: PO BOX 3104 CITY: CAESAREA NORTH INDUSTRIAL PARK STATE: L3 ZIP: 3088900 SD 1 zk1821750.htm SD


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
Form SD
 
SPECIALIZED DISCLOSURE REPORT
 
Mazor Robotics Ltd.
(Exact Name of Registrant as Specified in Charter)

State of Israel
 
001-35920
 
Not Applicable
(State or Other Jurisdiction of Incorporation)
 
(Commission File Number)
 
(IRS Employer Identification Number)

 
5 Shacham Street
North Industrial Park, Caesarea 3088900, Israel
 
 
(Address of Principal Executive Offices)
 
  (Zip Code)  
    
Ran Grinshtein
 
(972)4-6187131
 (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, 2017.
 

 
Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Mazor Robotics Ltd. (“Mazor”) has evaluated its current product lines and determined that certain products it manufactures or contracts to manufacture contains tin, tungsten, tantalum and/or gold ("Conflict Minerals"). Mazor does not directly source Conflict Minerals, and is many levels removed from mines, smelters or refiners that mine the metals used in Mazor’s products.  Mazor is unable at this time to determine and describe in this report a complete list of either the facilities used to process the Conflict Minerals used in its products or the countries of origin of such Conflict Minerals.

Item 1.02 Exhibit
A copy of Mazor Robotics Ltd.’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: https://www.mazorrobotics.com/index.php/en-us/investors/investor-documents/corporate-governance. The contents of such website are not a part of this report.
 
Section 2 - Exhibits

Item 2.01 Exhibits

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



SIGNATURES

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

Mazor Robotics Ltd.
(Registrant)

By: /s/ Joshua Belkar
Joshua Belkar
Vice President Operations and Global Service
May 31, 2018
 
 

EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01


Exhibit 1.01

Mazor Robotics Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2017

This report for the year ended December 31, 2017 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (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. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. "Conflict Minerals" are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”) for the purposes of this assessment.

If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, it must disclose its determination, provide a brief description of the inquiry it undertook and the results of the inquiry on a Form SD.

If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report (the “CMR”), to the SEC that includes a description of those due diligence measures.

1. Overview

This report has been prepared by management of Mazor Robotics Ltd. (herein referred to as “Mazor”, "Mazor Robotics", "Company", “we”, “us”, or “our”). The information includes the activities of Mazor's wholly owned subsidiaries.
 
We are a leading innovator that has pioneered robotic guidance systems and complementary products in the spine and brain surgical markets which we believe may provide a safer surgical environment for patients, surgeons and operating room staff. We engage in the development, production and marketing of innovative medical devices for supporting surgical procedures in the fields of orthopedics and neurosurgery. We operate in the fields of image guided surgery and computer-assisted surgery enabling the use of surgical instruments with high precision and minimal invasiveness, aiming to simplify complex and minimally-invasive surgical procedures. We believe that our Mazor Core technology - the collaboration of four key technologies in Mazor's systems - provides predictable, efficient and precise surgical procedures. We believe that our portfolio of products, based on our proprietary Mazor Core technology and including the Mazor XTM Robotic Guidance System (“Mazor X), and the Renaissance® Surgical -Guidance System (“Renaissance” and together with the Mazor X, the “Products”), are transforming spine surgery from freehand procedures to highly accurate, state-of-the-art, guided procedures that raise the standard of care with better clinical results. We believe in evidence-based medicine, with more than fifty-five peer-reviewed studies validating the clinical value proposition of our products. The Mazor X, Renaissance and SpineAssist (our predecessor to the Renaissance) systems have been used to perform a wide variety of spine procedures on over 32,000 patients worldwide (with over 220,000 implants placed). We believe in ongoing innovation. In 2014, we introduced the Renaissance for brain surgery and in 2015 we introduced the PRO (Predictable Renaissance Operation) product line, which currently includes three solutions designed to support brain procedures, as well as, trauma and lateral spine procedures. We are continuing the development of the Renaissance platform for trajectory guidance in spine and brain surgery procedures. In July 2016, we unveiled the Mazor X system, a transformative robotic guidance platform for spine surgeries and in October 2016, we commercially launched the Mazor X system. The Mazor X system was developed with the goal of enhancing predictability and patient benefit, through the combination of analytical tools, multiple-source data, precision guidance, optical tracking, intra-op verification, and connectivity technologies. The Mazor X system was designed to expand the field of precision guided spine surgery beyond trajectory guidance. In April 2017, we received 510(k) clearance from the FDA for the Mazor X Align™ software, a spinal deformity correction planning software for the Mazor X system. The Mazor X Align is the first advanced application being integrated onto the Mazor X platform. We are continuing the development of the Mazor X platform for additional spine surgery procedures. On May 16, 2016, we entered into a strategic, two-phase Exclusive Lead Sharing and Distribution Agreement and a Purchase Agreement with Medtronic plc and certain of its affiliates (“Medtronic”). Under the first phase of this agreement, Medtronic was charged to generate sales leads for the Mazor X system. Mazor was stipulated as Medtronic’s sole strategic partner for development and commercialization of the Mazor X for robotic-based spine applications. In addition, Medtronic made certain investments in Mazor in 2016 and 2017. On August 30, 2017, we entered into the next phase of our strategic partnership with Medtronic, whereby Medtronic assumed exclusive global commercial responsibility for the Mazor X system for spine applications.


Our customers are mainly comprised of hospitals, medical centers, academic centers and medical device distributors.
 
Mazor is committed to high ethical standards and to conducting its business with a high level of integrity, as defined in our Code of Business Conduct and Ethics. We strive to source materials from companies that share our values regarding human rights, ethics and environmental responsibility.

We conducted an analysis of our Products and found the presence of 3TG materials. Therefore, the Products that we manufacture are subject to the reporting obligations of the Rule.

2. Supply Chain Overview

Mazor does not purchase Conflict Minerals directly from mines, smelters or refiners, and tracing these minerals to their sources is a challenge that requires us to rely on suppliers in the efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals. In order to manage the scope of this task, we integrated a responsible sourcing of minerals requirement within our Conflict Minerals Policy. Our suppliers are expected to provide the 3TG sourcing information to us per our Conflict Minerals Policy.

3. Reasonable Country of Origin Inquiry (RCOI)

We performed an internal assessment and prioritized the list of suppliers to approach. In the first step, we conducted a comprehensive analysis of our Products' components and identified potential 3TG Suppliers ("Potential 3TG Suppliers"). We contacted the identified Potential 3TG Suppliers to further investigate the possibility that 3TG minerals are present within our Products. We identified 164 Potential 3TG Suppliers whose products could potentially include 3TG.
 
We believe that implementing the OECD guidelines and using the Responsible Minerals Initiative ("RMI") (formerly the Conflict-Free Sourcing Initiative (CFSI)) Conflict Minerals Reporting Template (“CMRT”) to gather information from smelters and refiners are currently the best possible efforts to obtain mine and country of origin information.


Due to the size of the company, the breadth and complexity of our Products, and the dynamic nature of our supply chain, it is challenging to identify the source and origin of the 3TG incorporated in our Products. The manufacturing process for Mazor's Products is significantly removed from the mining, smelting and refining of Conflict Minerals, therefore, we must rely on our direct suppliers to assist us in obtaining information regarding the origin of the Conflict Minerals.

We reached out to those suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters using the most recent CMRT developed by the RMI.

We engaged a global third-party service provider to compile the survey results, and 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. We received responses from 80 suppliers that represent 49% of our Potential 3TG Suppliers.

Based on information obtained, and taking into account the complexities of our supply chain, we do not have sufficient information from our suppliers to determine the country of origin of the Conflict Minerals used in our Products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries and are not from recycled or scrap sources.

Based on this result, Mazor undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its Products during 2017. There is significant overlap between our RCOI efforts and our due diligence measures performed.

4.  Due Diligence Program

4.1. Design of Our Due Diligence and Description of the Due Diligence Process
Our due diligence processes and efforts have been designed and developed based on the Organization for Economic Co-operation and Development's ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance") and the related supplements for gold and for tin, tantalum and tungsten. This aforementioned guidance includes the following measures:

Step 1: Establish Strong Company Management Systems;
Step 2: Identify and Assess Risk in the Supply Chain;
Step 3: Design and Implement Strategy to Respond to Risks;
Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain; and
Step 5: Report Annually on Supply Chain Due Diligence.


 
4.2. Due Diligence Process

4.2.1. Establish Strong Company Management Systems 
Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy; establishment of governance structures with cross functional team members and senior executives; communication to, and engagement with suppliers; due diligence compliance processes and measurement; record keeping and escalation procedures.

4.2.1.1. Conflict Minerals Policy
Mazor believes that ethical business conduct is critical to its operations and therefore has established a Code of Business Conduct and Ethics. Mazor is concerned that the trade of Conflict Minerals mined in the Covered Countries may be fueling human rights atrocities in the region. Therefore, Mazor has adopted a Conflict Minerals Policy. As described in the policy, Mazor strives to source materials from companies that share our values around human rights, ethics and environmental responsibility. We do not aim to eliminate sourcing from the Covered Countries, but to encourage suppliers to engage in ethical sourcing of the Conflict Minerals from the Covered Countries. We expect our suppliers to comply with our Conflict Mineral Policy. The Policy is available on the Company's website at https://www.mazorrobotics.com/index.php/en-us/investors/investor-documents/corporate-governance.

4.2.1.2. Management Systems and Internal Team
Mazor has created a Conflict Minerals taskforce and engaged with an external consultant to ensure compliance with the Rule. Our taskforce led by our Vice President Operations and Global Service ("VP Operations & Service") who joined the Company in 2017, and a team of subject matter experts from relevant functions such as supply chain, engineering and finance departments. The taskforce oversees ongoing communication with the Potential 3TG Suppliers, to obtain Conflict Minerals evaluation results, to perform the required procedures to ensure that the responses received from our suppliers meet the requirements of the Rule and to deal with all issues arising from the RCOI findings and the due diligence program.

4.2.1.3 Control Systems
We utilize the RMI’s CMRT to collect data and information from our suppliers in order to identify the origin of 3TG in our supply chain. We also engage a global third-party service provider to assist us with the identification of the smelters and refiners that process the 3TG in our Products.

Mazor has an established due diligence compliance process and has set forth documentation and record maintenance mechanisms to ensure that relevant documentation is retained in a structured electronic database for a period of at least 5 years.

4.2.1.4 Supplier Engagement
We sent letters to Potential 3TG Suppliers informing these direct suppliers that Mazor is subject to the Rule, advised them of Mazor's commitment to responsible sourcing of minerals, and indicated that their cooperation in the due diligence process is expected, including completion of the CMRT.
 
We have also engaged a global third-party service provider to facilitate training and outreach to suppliers, as well as to communicate, collect, validate and archive supplier responses.
 
In addition, a conflict minerals clause that requires suppliers to provide us with information about the source of 3TG and relevant smelters or refiners was added to our standard contracts.

4.2.1.5 Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or further guidance regarding our Conflict Minerals program.


4.2.2. Identify and Assess Risk in the Supply Chain
As described above, we identified through a comprehensive analysis of our Products 164 Potential 3TG Suppliers. We reached out to those suppliers through letters and questionnaires designed to explain the relevant SEC requirements and Mazor's due diligence expectations as well as to refer them to online training materials and instructions. Suppliers were asked to provide us with information regarding 3TG and smelters or refiners using the CMRT developed by the RMI. We received responses from 80 suppliers.
We compared the information provided therein with the RMI's standard smelter list.

4.2.3. Design and Implement Strategy to Respond to Risks
Each CMRT received from our suppliers was entered into a database maintained by a global third-party service provider and was reviewed. For non-responsive suppliers or suppliers that provided unclear or incomplete responses, an escalation process was implemented to obtain complete and accurate required information, sometimes requiring multiple telephone and/or email contacts to further the data collection process. We communicate to all our suppliers the importance of compliance and have a Conflict Minerals management program in place to collect, analyze, store and monitor the results of our inquires. We also request any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. Our VP Operations & Service is briefed on an on-going basis and as required on the results of our due diligence efforts. In addition, the status of the Conflict Mineral Program and relevant updates are shared with the team on an on-going basis and as required.

4.2.4. Carry Out Independent Third Party Audit of Supply Chain Due Diligence
Mazor does not have direct sourcing relationships with Conflict Mineral smelters or refiners. Where possible, we have relied on third-party assurances and certifications, such as the RMI's Responsible Mineral Assurance Process (“RMAP”).

4.2.5. Report Annually on Supply Chain Due Diligence
Our Conflict Mineral annual report is available on the Company's website at https://www.mazorrobotics.com/index.php/en-us/investors/investor-documents/corporate-governance and is filed with the SEC.


5. Results of Assessment:

5.1. Survey Responses
 
As indicated above, the Products that we manufacture, or contract to manufacture, are highly complex, and typically contain thousands of components from many suppliers. Since there are generally multiple tiers between the mines that extract Conflict Minerals and our suppliers, we relied on our suppliers to provide information on the origin of the Conflict Minerals contained in components supplied to us.
 
We did not receive information at the product level from all of our suppliers, and therefore the Company cannot clearly identify the source of origin of all 3TG included in its products.

Based on information provided by our Potential 3TG Suppliers as well as by RMI, the results of our due diligence investigations as of the date of this Report are as follows:

Out of 164 Potential 3TG Suppliers:
17% of our Potential 3TG Suppliers were determined to be 3TG free.
32% of our Potential 3TG Suppliers were determined to supply 3TG.

Based on the information we received from Potential 3TG Suppliers, we identified 322 smelters or refiners, categorized by 3TG: (Gold 150, Tantalum 43, Tin 83, Tungsten 46), of which 266 smelters or refiners, or 83%, have been certified as Conflict Free by the RMI, or are currently engaged in an audit process ("Active"), as of the date of publication of this report. We have identified 12 smelters or refiners, or 4% that provided conflict minerals from recycled or scrap sources.  318 of the smelters or refiners in our supply chain survey, or 99%, are not from the Covered Countries. We identified 3 smelters that were not designated as conflict free by the RMI, and are from the Covered Countries. We are in on-going communication with the relevant Suppliers sourcing from the aforementioned smelters or refiners to manage risks, and their responses are still under evaluation by the Company, as of the date of publication of this Report.

Based on the information provided by the relevant suppliers as well as by RMI, as of the date of this Report, the facilities that may have been used to process the Conflict Minerals in our Products may include to the best of our knowledge the smelters and refiners listed in Annex I below.

Based on the information provided by the relevant suppliers as well as by RMI, as of the date of this Report, the mine countries of origin of the Conflict Minerals contained in our Products may include the countries listed in Annex II below.

Please note that information is not gathered on a continuous, real-time basis from Mazor's suppliers, and that, since the information comes from direct and secondary suppliers and independent third-party audit programs, Mazor can only provide reasonable (not absolute) assurance regarding the source and chain of custody of the necessary Conflict Minerals.


6. Continuous Improvement Efforts to Mitigate Risk

As we move forward with our due diligence program, we will continue working with our global supply chain to ensure responsible sourcing and assure compliance with international regulations, and will consider taking the following steps to improve the due diligence that we conduct to further mitigate any risk that the Conflict Minerals in our Products could benefit armed groups in the Covered Countries:
 
 
a.
Periodically engage with suppliers to attempt to increase the response rate to our inquiries and to improve the content of the supplier responses, including responses that were identified as incomplete, inconsistent or inaccurate.

 
b.
Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals.
 
 
c.
Request of any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. We do not aim to eliminate sourcing from the Covered Countries, but to encourage suppliers to engage in ethical sourcing of the Conflict Minerals from the Covered Countries.

 
d.
Validate supplier responses regarding smelters and refiners using information collected from reliable industry certification programs.
 
 
e.
Continue to compare smelters and refiners identified by our supply chain survey against lists of facilities that have received a third-party “conflict free” designation and to track those that have not received such a designation.
 
 
f.
Continue to report to management on the findings of our supply chain risk assessment.

Caution Concerning Forward-Looking Statements

Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Further, any statements that are not statements of historical fact (including statements containing the words "believes," "anticipates," "plans," "expects," "may," "will," "would," "intends," "estimates" and similar expressions) should also be considered to be forward-looking statements. The forward-looking statements included herein are based on current expectations and beliefs that involve a number of known and unknown risks and uncertainties. Examples of forward-looking statements in this document include statements relating to our future plans. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. There are a number of factors that could cause events to differ materially from those indicated by the forward-looking statements in this document, including the risks associated with our suppliers not cooperating fully or at all with our efforts.  Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.


Annex I - List of smelters or refiners

Metal
Smelter Name
Smelter Country
Gold
Metalor Switzerland
SWITZERLAND
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
Gold Mining in Shandong (Laizhou) Limited Company
CHINA
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
LS-NIKKO Copper Inc.
KOREA (REPUBLIC OF)
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Shonan Plant Tanaka Kikinzoku
JAPAN
Gold
AGR Mathey
AUSTRALIA
Gold
Amagasaki Factory, Hyogo Prefecture, Japan
JAPAN
Gold
Dowa
JAPAN
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Mitsubishi Materials Corporation
JAPAN
Gold
Mitsui Kinzoku Co., Ltd.
JAPAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
MEM(Sumitomo Group)
JAPAN
 

Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Valcambi S.A.
SWITZERLAND
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Fujian Zijin mining stock company gold smelter
CHINA
Gold
China Henan Zhongyuan Gold Smelter
CHINA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
Royal Canadian Mint
CANADA
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Aurubis AG
GERMANY
Gold
JCC
CHINA
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Materion
UNITED STATES OF AMERICA
Gold
CCR
CANADA
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Gold
Boliden AB
SWEDEN
 

Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Chimet S.p.A.
ITALY
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Elemetal Refining, LLC
UNITED STATES OF AMERICA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Istanbul Gold Refinery
TURKEY
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Gold
PAMP S.A.
SWITZERLAND
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners
SOUTH AFRICA
 

Gold
Bangalore Refinery
INDIA
Gold
Caridad
MEXICO
Gold
Cendres + Metaux S.A.
SWITZERLAND
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 GmbH
GERMANY
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
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 Metal Ltd.
KOREA, REPUBLIC OF
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Japan Mint
JAPAN
 

Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
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
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Modeltech Sdn Bhd
MALAYSIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
 

Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
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
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
So Accurate Group, Inc.
UNITED STATES OF AMERICA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
T.C.A S.p.A
ITALY
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
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
L'Orfebre S.A.
ANDORRA
Gold
Morris and Watson Gold Coast
AUSTRALIA
Gold
Pease & Curren
UNITED STATES OF AMERICA
Gold
SungEel HiTech
KOREA, REPUBLIC OF
Gold
Italpreziosi
ITALY
Gold
Marsam Metals
BRAZIL
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Safimet S.p.A
ITALY
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
African Gold Refinery
UGANDA
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
H.C. Starck GmbH Goslar
GERMANY
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
 

Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
ULBA
KAZAKHSTAN
Tantalum
F & X
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Solikamsk
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
Duoluoshan
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
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 JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
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
NPM Silmet AS
ESTONIA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tin
China Tin (Hechi)
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
China Yunnan Tin Co Ltd.
CHINA
 

Tin
Funsur Smelter
PERU
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
INDONESIAN STATE TIN CORPORATION MENTOK SMELTER
INDONESIA
Tin
Chengfeng Metals Co Pte Ltd
CHINA
Tin
Brand RBT
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
Mineração Taboca S.A.
BRAZIL
Tin
OMSA
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Brand IMLI
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
Kundur Smelter
INDONESIA
Tin
Thai Solder Industry Corp., Ltd.
THAILAND
Tin
Metallo-Chimique N.V.
BELGIUM
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Jiangxi Nanshan
CHINA
Tin
China Rare Metal Material Co., Ltd.
CHINA
Tin
Alent plc
UNITED STATES OF AMERICA
Tin
Fenix Metals
POLAND
 

Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV Serumpun Sebalai
INDONESIA
Tin
CV Tiga Sekawan
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
Estanho de Rondonia S.A.
BRAZIL
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Jinye Mineral Company
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
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
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
 

Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Elmet S.L.U.
SPAIN
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
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 DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
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 Prima Timah Utama
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
PT Bangka Serumpun
INDONESIA
Tin
Pongpipat Company Limited
MYANMAR
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd.
CHINA
Tungsten
China National Non Ferrous
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Xiamen H.C.
CHINA
Tungsten
H.C. Starck GmbH
GERMANY
 

Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Industry Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
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
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 OF AMERICA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
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 Hutten AG
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA



Annex II - List of possible countries of origin of Conflict Minerals

ANGOLA
ARGENTINA
ARMENIA
AUSTRALIA
AUSTRIA
BELGIUM
BOLIVIA
BRAZIL
BURUNDI
CAMBODIA
CANADA
CENTRAL AFRICAN REPUBLIC
CHILE
CHINA
COLOMBIA
CZECH REPUBLIC
DEMOCRATIC REPUBLIC OF CONGO
DJIBOUTI
ECUADOR
EGYPT
ESTONIA
ETHIOPIA
FRANCE
GERMANY
GHANA
GUYANA
HUNGARY
INDIA
INDONESIA
IRELAND
ISRAEL
ITALY
IVORY COAST
JAPAN
JERSEY
KAZAKHSTAN
KENYA
LAOS
LUXEMBOURG
MADAGASCAR
MALAYSIA
MALI
 

MEXICO
MONGOLIA
MOZAMBIQUE
MYANMAR
NAMIBIA
NIGER
NIGERIA
PAPUA NEW GUINEA
PERU