EX-1.01 2 a12312017formsdcmr.htm EXHIBIT 1.01 Exhibit
Exhibit 1.01

Vista Outdoor Inc.
Conflict Minerals Report

For the reporting period from January 1, 2017 to December 31, 2017


This report (the “Report”) of Vista Outdoor Inc. (together with our consolidated subsidiaries, “Vista Outdoor,” “we,” “our,” and “us”), for the year ended December 31, 2017 is presented to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), which require public companies, including Vista Outdoor, to provide certain disclosures about conflict minerals that are necessary to the functionality or production of a product manufactured or contracted to be manufactured by the company. These rules require that, if we have reason to believe that any of the conflict minerals in our supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) and are not solely from scrap or recycled sources, we must conduct due diligence on the source and chain of custody of such conflict minerals. “Conflict minerals,” or “3TG,” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten.

This Conflict Minerals Report describes the measures we have taken to exercise due diligence on the source and chain of custody of the conflict minerals contained in our products manufactured during the 2017 calendar year (the “Reporting Period”).

I.
Company and Product Overview

Vista Outdoor is a leading global designer, manufacturer and marketer of consumer products in the growing outdoor sports and recreation markets with key brands in outdoor recreation and shooting sports products including: centerfire and rimfire rifles, shotguns, range systems, primers, binoculars, golf rangefinders, rifle scopes, trial cameras, gun care products, reloading equipment, tactical accessories, archery accessories, hunting decoys, and game calls. Vista Outdoor is headquartered in Utah and has manufacturing operations and facilities in 13 U.S. States, Canada, Mexico and Puerto Rico along with international sales and sourcing operations in Asia, Australia, Canada and Europe.

Certain Vista Outdoor products (“Covered Products”) contain materials and components that contain 3TG. Due to the depth of the supply chain, we are far removed from the mining of 3TG ores and the smelters/refiners that process those ores; the efforts we undertook to identify the countries of origin of those ores reflect our circumstances and downstream position in the supply chain. Further, the amount of information available globally on the traceability and sourcing of these ores is limited at this time, and this situation is not unique to us. We have taken steps to identify the applicable smelters and refiners of 3TG in our supply chain; however, we believe that the smelters and refiners of the 3TG contained in the Covered Products are best situated to identify the sources and countries of origin of the 3TG metals they use. We rely on our suppliers to provide us with information on the origin of any conflict minerals contained in components and materials supplied to us.

II.
Reasonable Country of Origin Inquiry

Our conflict minerals due diligence process began with a reasonable country of origin inquiry (“RCOI”) for all conflict minerals known to be contained in products that we manufactured or contracted to be manufactured during the Reporting Period. To implement the RCOI, the companies that provide relevant parts, materials and finished goods directly to Vista Outdoor (our “first tier suppliers”) were engaged to collect information regarding the presence and sourcing of conflict minerals used in those products. Information was collected, stored and evaluated largely using an online platform provided by a third party vendor.

Our supplier engagement included the following steps:




An introductory email was sent to all of our first tier suppliers and those of our licensees (hereinafter, collectively referred to as “suppliers”) describing our Conflict Minerals Compliance Program and requesting information concerning the presence of conflict minerals in the supplier’s products.
Following that introductory email, a subsequent email was sent to suppliers containing registration information and a survey request link for the online data collection platform, which utilized the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict Free Sourcing Initiative (the “CFSI”).
Our suppliers also were provided access to a Conflict Minerals Supplier Resource Center (https://conflictmineralsresources.com) sponsored by the third party vendor as an educational tool to facilitate a deeper understanding of our Conflict Minerals Compliance Program, supporting regulation and frequently asked questions concerning conflict minerals tracing.
Up to five additional reminder emails were sent to any non-responsive supplier from whom we requested survey completion.
Suppliers who remained non-responsive to email reminders were contacted by telephone and offered assistance. This assistance included, but was not limited to, providing further information about our Conflict Minerals Compliance Program, explaining why the information was being collected, explaining how the information would be used and clarifying how the needed information could be provided.

The third party vendor assisted in evaluating supplier responses for plausibility, consistency and gaps, both in terms of information on the products that were stated to contain or not contain necessary conflict minerals and information on the origin of those conflict minerals. The third party vendor also followed up with suppliers to address issues including implausible statements regarding the presence of conflict minerals, incomplete data on CMRTs, responses that did not identify smelters or refiners (“SORs”) and responses that indicated sourcing location without complete supporting information from the supply chain.

A total of 333 suppliers were contacted as part of our RCOI process. The response rate among these suppliers was 55%. Of these responding suppliers, 15% indicated that certain components they produce contain one or more conflict minerals.

We believe our RCOI process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate and confirm the information. The Company does not purchase conflict minerals directly from SORs and, therefore, must rely on its suppliers to provide information regarding the origin of the conflict minerals that are included in the Covered Products. Based on the results of our RCOI, which indicated that one or more of our product components contained conflict minerals that may have originated in the Covered Countries and may not be from recycled or scrap sources, we exercised due diligence on the source and chain of custody of those conflict minerals as described below.

III.
Due Diligence Measures Performed by Vista Outdoor

We designed our conflict minerals due diligence process to conform, in all material respects, with the Organization for Economic Cooperation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum and Tungsten and on Gold (the “OECD Guidance”). The design of our due diligence process took into account the recommendations of the OECD Guidance for “downstream” companies (those entities in the minerals supply chain from the SORs to retailers).

In accordance with the OECD Guidance, our due diligence measures included the following:

Establishing Strong Company Management Systems
We maintain a multi-disciplinary internal team to implement our due diligence measures. Our Conflict Minerals project team is headed by our Supply Chain Council, consisting of supply chain leadership, and



includes other members of our supply chain, engineering, finance and legal departments. The team met regularly to discuss the due diligence process and progress. We also engaged a third party vendor to support our Conflict Minerals Program.
We have adopted a Conflict Minerals Policy, which details the standards by which our supply chain due diligence will be conducted. We communicated the Conflict Minerals Policy to our direct suppliers.
We employ a system of controls and transparency over our mineral supply chain through the use of the due diligence tools developed by the CFSI, including the CMRT, which is designed to identify the smelters and refiners that process the conflict minerals in a company’s supply chain.
We maintain a company-level grievance mechanism, as described in our Code of Business Ethics, which enables employees and others to report concerns.

Identifying and Assessing Risk in Our Supply Chain
For the Reporting Period, we identified and assessed risks in our supply chain through engagement with suppliers as discussed in Section II of this Report, including through the CMRT survey process and by evaluating suppliers’ responses to the CMRT.

Designing and Implementing a Strategy to Respond to Supply Chain Risks
In order to assess the due diligence practices of the SORs reported to us by suppliers that were known or reasonably believed to have sourced from a Covered Country or that had unknown sourcing, the third party vendor attempted to match each SOR on the list to available lists of SORs that have been certified, or are in the process of being certified, by internationally recognized third party audit programs, such as the CFSI’s Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain of Custody Certification program.
If the SOR is not certified by any of these internationally recognized programs, the third party vendor attempted to contact the SOR to gain more information about the SOR’s sourcing practices, including countries of origin, as well as whether the SOR uses any internal due diligence procedures or other processes to track the chain of custody of its mineral ores. In addition, Internet research was also performed to determine whether there are any additional sources of information regarding the SOR’s sourcing practices.
We are in the process of developing a risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries.
The Conflict Minerals project team reports to senior management on the status of our survey and due diligence processes.

Carrying out Independent Third-Party Audits of Supply Chain Due Diligence
We do not have direct relationships with SORs and we do not perform direct audits of SORs’ supply chains for conflict minerals. However, we support the development and implementation of, and SORs’ participation in, independent third-party audits of SORs’ sourcing practices, such as the CFSI’s Conflict-Free Smelter Program.

Reporting on Supply Chain Due Diligence
We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission.
Our Conflict Minerals Report is publicly available on our website at http://vistaoutdoor.com/social-responsibility/.

IV.
Smelters or Refiners and Country of Origin of Conflict Minerals

Based on our due diligence efforts, we do not have conclusive information regarding the country of origin of, or SORs used to process, the necessary conflict minerals in the Covered Products for the Reporting Period. Annex A below includes a list of the SORs that our suppliers reported as being in their supply chains, as well as an aggregated list of the countries of origin from which we believe the reported SORs collectively source conflict minerals, based on our review data from several sources, including information provided by suppliers and information the third party



vendor has obtained through engagement with SORs. In many cases, the SOR information provided to us by our suppliers was produced at a company or divisional level based on all of their products as a whole, rather than being limited to the specific products supplied to Vista Outdoor. In addition, many of the supplier responses were incomplete as all minerals supply chain participants continue to map their upstream supply chains. As a result, we are unable to determine whether all of the SORs listed below actually processed conflict minerals used in the Covered Products for the Reporting Period.

Our efforts to determine the mine or location of origin of the conflict minerals in the Covered Products with the greatest possible specificity consisted of the due diligence measures described in this Report, including our efforts to seek information from suppliers using the CMRT.

V.
Future Measures to Mitigate Risk
We continue to evaluate our supplier relationships to promote compliance with our Conflict Minerals Policy and mitigate the risk that the conflict minerals contained in our products could benefit armed groups in the Covered Countries. We are committed to continuously improving our supply chain due diligence efforts using the following measures:

Continuing to assess the presence of conflict minerals in our supply chain;
Continuing to communicate expectations to our suppliers with regard to sourcing of conflict minerals, supplier performance, and transparency;
Continuing engagement with suppliers and working to increase the response rate to the CMRT;
Continuing to develop our risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries;
Working to establish a system of controls and transparency over our mineral supply chain through our work with our third party vendor;
Implementing internal measures to strengthen our engagement with suppliers on these issues; and
Continuing to compare RCOI results to information collected through independent conflict free smelter validation programs such as the CFSI Conflict Free Smelter Program.





Annex A
Tungsten
A.L.M.T. TUNGSTEN Corp.*
Tungsten
ACL Metais Eireli*
Gold
Advanced Chemical Company*
Gold
Aida Chemical Industries Co., Ltd.*
Gold
Al Etihad Gold LLC*
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.*
Gold
Almalyk Mining and Metallurgical Complex (AMMC)*
Tin
Alpha*
Gold
AngloGold Ashanti Corrego do Sitio Mineracao*
Gold
Argor-Heraeus S.A.*
Gold
Asahi Pretec Corp.*
Gold
Asahi Refining Canada Ltd.*
Gold
Asahi Refining USA Inc.*
Gold, Tungsten
Asaka Riken Co., Ltd.*
Tungsten
Asia Tungsten Products Vietnam Ltd.*
Gold
AU Traders and Refiners*
Gold
Aurubis AG*
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*
Gold
Boliden AB*
Gold
C. Hafner GmbH + Co. KG*
Gold
Caridad
Gold
CCR Refinery - Glencore Canada Corporation*
Gold
Cendres + Metaux S.A.*
Tantalum
Changsha South Tantalum Niobium Co., Ltd.*
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.*
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*
Gold
Chimet S.p.A.*
Tin
China Tin Group Co., Ltd.*
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.*
Gold
Chugai Mining
Tin
CNMC (Guangxi) PGMA Co., Ltd.
Tin
CV Ayi Jaya*
Tin
CV Dua Sekawan*
Tin
CV Gita Pesona*
Tin
CV Tiga Sekawan*
Tin
CV United Smelting*
Tin
CV Venus Inti Perkasa*
Tantalum
D Block Metals, LLC*
Gold
Daejin Indus Co., Ltd.*
Gold
DODUCO Contacts and Refining GmbH*
Gold, Tin
Dowa*
Gold
DSC (Do Sung Corporation)*
Gold
Eco-System Recycling Co., Ltd.*
Gold
Elemetal Refining, LLC



Tin
EM Vinto*
Gold
Emirates Gold DMCC*
Tantalum
Exotech Inc.*
Tantalum
F&X Electro-Materials Ltd.*
Tin
Fenix Metals*
Tantalum
FIR Metals & Resource Ltd.*
Tungsten
Fujian Jinxin Tungsten Co., Ltd.*
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.*
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.*
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.*
Gold
Geib Refining Corporation*
Tin
Gejiu Fengming Metallurgy Chemical Plant*
Tin
Gejiu Jinye Mineral Company*
Tin
Gejiu Kai Meng Industry and Trade LLC*
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.*
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.*
Tantalum
Global Advanced Metals Aizu*
Tantalum
Global Advanced Metals Boyertown*
Tungsten
Global Tungsten & Powders Corp.*
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.*
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.*
Gold
Guangdong Jinding Gold Limited
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.*
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.*
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.*
Tin
Guanyang Guida Nonferrous Metal Smelting Plant*
Tantalum
H.C. Starck Co., Ltd.*
Tantalum
H.C. Starck Hermsdorf GmbH*
Tantalum
H.C. Starck Inc.*
Tantalum
H.C. Starck Ltd.*
Tantalum, Tungsten
H.C. Starck Smelting GmbH & Co. KG*
Tantalum
H.C. Starck Tantalum and Niobium GmbH*
Tungsten
H.C. Starck Tungsten GmbH*
Gold
HeeSung Metal Ltd.*
Gold
Heimerle + Meule GmbH*
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.*
Gold
Heraeus Metals Hong Kong Ltd.*
Gold
Heraeus Precious Metals GmbH & Co. KG*
Tin
HuiChang Hill Tin Industry Co., Ltd.*
Tin
Huichang Jinshunda Tin Co., Ltd.*
Tungsten
Hunan Chenzhou Mining Co., Ltd.*
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji*
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.*
Tungsten
Hydrometallurg, JSC*
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.*



Gold
Ishifuku Metal Industry Co., Ltd.*
Gold
Istanbul Gold Refinery*
Gold
Italpreziosi*
Gold
Japan Mint*
Tungsten
Japan New Metals Co., Ltd.*
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.*
Gold
Jiangxi Copper Co., Ltd.*
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.*
Tin
Jiangxi Ketai Advanced Material Co., Ltd.*
Tin
Jiangxi New Nanshan Technology Ltd.*
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.*
Tantalum
Jiangxi Tuohong New Raw Material*
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.*
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.*
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.*
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.*
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited*
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.*
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant*
Gold
JSC Uralelectromed*
Gold
JX Nippon Mining & Metals Co., Ltd.*
Gold
Kazzinc*
Tantalum
KEMET Blue Metals*
Tantalum
Kemet Blue Powder*
Tungsten
Kennametal Fallon*
Tungsten
Kennametal Huntsville*
Gold
Kennecott Utah Copper LLC*
Gold
Kojima Chemicals Co., Ltd.*
Gold
Korea Zinc Co., Ltd.*
Gold
Kyrgyzaltyn JSC*
Tantalum
LSM Brasil S.A.*
Gold
LS-NIKKO Copper Inc.*
Tin
Magnu's Minerais Metais e Ligas Ltda.*
Tin
Malaysia Smelting Corporation (MSC)*
Tungsten
Malipo Haiyu Tungsten Co., Ltd.*
Gold
Marsam Metals*
Gold
Materion*
Gold
Matsuda Sangyo Co., Ltd.*
Tin
Melt Metais e Ligas S.A.*
Tin
Metallic Resources, Inc.*
Tin
Metallo Belgium N.V.*
Tin
Metallo Spain S.L.U.*
Tantalum
Metallurgical Products India Pvt., Ltd.*
Gold
Metalor Technologies (Hong Kong) Ltd.*
Gold
Metalor Technologies (Singapore) Pte., Ltd.*



Gold
Metalor Technologies (Suzhou) Ltd.*
Gold
Metalor Technologies S.A.*
Gold
Metalor USA Refining Corporation*
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.*
Tantalum, Tin
Mineracao Taboca S.A.*
Tin
Minsur*
Gold, Tin
Mitsubishi Materials Corporation*
Gold, Tantalum
Mitsui Mining and Smelting Co., Ltd.*
Gold
MMTC-PAMP India Pvt., Ltd.*
Tungsten
Moliren Ltd.*
Gold
Moscow Special Alloys Processing Plant*
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.*
Tungsten
Niagara Refining LLC*
Gold
Nihon Material Co., Ltd.*
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.*
Tantalum
NPM Silmet AS*
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC*
Tin
O.M. Manufacturing (Thailand) Co., Ltd.*
Tin
O.M. Manufacturing Philippines, Inc.*
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH*
Gold
Ohura Precious Metal Industry Co., Ltd.*
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)*
Gold
OJSC Novosibirsk Refinery*
Tin
Operaciones Metalurgical S.A.*
Gold
PAMP S.A.*
Tungsten
Philippine Chuangxin Industrial Co., Inc.*
Gold
Planta Recuperadora de Metales SpA*
Tantalum
Power Resources Ltd.*
Gold
Prioksky Plant of Non-Ferrous Metals*
Gold
PT Aneka Tambang (Persero) Tbk*
Tin
PT Aries Kencana Sejahtera*
Tin
PT Artha Cipta Langgeng*
Tin
PT ATD Makmur Mandiri Jaya*
Tin
PT Babel Inti Perkasa*
Tin
PT Bangka Prima Tin*
Tin
PT Bangka Tin Industry*
Tin
PT Belitung Industri Sejahtera*
Tin
PT Bukit Timah*
Tin
PT DS Jaya Abadi*
Tin
PT Eunindo Usaha Mandiri*
Tin
PT Inti Stania Prima*
Tin
PT Karimun Mining*
Tin
PT Kijang Jaya Mandiri*
Tin
PT Lautan Harmonis Sejahtera*
Tin
PT Menara Cipta Mulia*
Tin
PT Mitra Stania Prima*



Tin
PT Panca Mega Persada*
Tin
PT Premium Tin Indonesia*
Tin
PT Prima Timah Utama*
Tin
PT Refined Bangka Tin*
Tin
PT Sariwiguna Binasentosa*
Tin
PT Stanindo Inti Perkasa*
Tin
PT Sukses Inti Makmur*
Tin
PT Sumber Jaya Indah*
Tin
PT Timah (Persero) Tbk Kundur*
Tin
PT Timah (Persero) Tbk Mentok*
Tin
PT Tinindo Inter Nusa*
Tin
PT Tommy Utama*
Gold
PX Precinox S.A.*
Tantalum
QuantumClean*
Gold
Rand Refinery (Pty) Ltd.*
Gold
Republic Metals Corporation*
Tantalum, Tin
Resind Industria e Comercio Ltda.*
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.*
Gold
Royal Canadian Mint*
Tin
Rui Da Hung*
Gold
SAAMP*
Gold
Safimet S.p.A*
Gold
Samduck Precious Metals*
Gold
SAXONIA Edelmetalle GmbH*
Gold
Schone Edelmetaal B.V.*
Gold
SEMPSA Joyeria Plateria S.A.*
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*
Gold
Sichuan Tianze Precious Metals Co., Ltd.*
Gold
Singway Technology Co., Ltd.*
Gold
So Accurate Group, Inc.
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals*
Tin
Soft Metais Ltda.*
Gold
Solar Applied Materials Technology Corp.*
Tantalum
Solikamsk Magnesium Works OAO*
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City*
Gold
Sumitomo Metal Mining Co., Ltd.*
Gold
SungEel HiMetal Co., Ltd.*
Gold
T.C.A S.p.A*
Tantalum
Taki Chemical Co., Ltd.*
Gold
Tanaka Kikinzoku Kogyo K.K.*
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.*
Tantalum
Telex Metals*
Tin
Thaisarco*
Gold
The Refinery of Shandong Gold Mining Co., Ltd.*
Gold
Tokuriki Honten Co., Ltd.*
Gold
Torecom*



Tantalum
Ulba Metallurgical Plant JSC*
Gold
Umicore Brasil Ltda.*
Gold
Umicore Precious Metals Thailand*
Gold
Umicore S.A. Business Unit Precious Metals Refining*
Tungsten
Unecha Refractory Metals Plant*
Gold
United Precious Metal Refining, Inc.*
Gold
Valcambi S.A.*
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.*
Gold
Western Australian Mint (T/a The Perth Mint)*
Tin
White Solder Metalurgia e Mineracao Ltda.*
Gold
WIELAND Edelmetalle GmbH*
Tungsten
Wolfram Bergbau und Hutten AG*
Tungsten
Woltech Korea Co., Ltd.*
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.*
Tungsten
Xiamen Tungsten Co., Ltd.*
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.*
Tantalum
XinXing Haorong Electronic Material Co., Ltd.*
Gold
Yamakin Co., Ltd.*
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.*
Gold
Yokohama Metal Co., Ltd.*
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*
Tin
Yunnan Tin Company Limited*
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation*

*Denotes SORs that have received a “conflict free” designation from an independent third party audit program as of April 15, 2018.

We believe that the countries of origin for the conflict minerals processed by these SORs include Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo (Brazzaville), Czech Republic, Djibouti, DRC- Congo (Kinshasa), Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Korea, Republic of, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, and Zimbabwe.