EX-1.01 2 d937221dex101.htm EX-1.01 EX-1.01

Exhibit 1.01

H.B. FULLER COMPANY

Conflict Minerals Report

For the reporting period from January 1, 2014 to December 31, 2014

This Conflict Minerals Report (the “Report”) of H.B. Fuller Company (the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule) promulgated under the Securities and Exchange Act of 1934, as amended, for the reporting period from January 1, 2014 to December 31, 2014.

The rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, certain of the Company’s operations manufacture, or contract to manufacture, products, and the Conflict Minerals are necessary to the functionality of those products.

If a registrant has reason to believe that any of the Conflict Minerals necessary to the functionality or production of their products 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 source of the Conflict Minerals. The registrant must annually submit a report, Conflict Minerals Report (a “CMR”), to the SEC that includes a description of those due diligence measures.

Pursuant to SEC guidance, this Report is not audited as none of the Company’s products have been found to be “DRC conflict free”.

 

1. Introduction

 

a. Company Overview. The Company is a leading worldwide formulator, manufacturer and marketer of adhesives, sealants and other specialty chemical products. Sales operations span 40 countries in North America, Europe, Latin America, the Asia Pacific region, India, the Middle East and Africa. Industrial adhesives represent our core product offering. Customers use our adhesives products in manufacturing common consumer and industrial goods, including food and beverage containers, disposable diapers, windows, doors, flooring, appliances, sportswear, footwear, multi-wall bags, water filtration products, insulation, textiles and electronics. Our adhesives help improve the performance of our customers’ products or improve their manufacturing processes. We also provide our customers with technical support and unique solutions designed to address their specific needs. We have established a variety of product offerings for residential construction markets, such as tile-setting adhesives, grout, sealants and related products. These products are sold primarily in our Construction Products operating segment.


b. Product Overview. This report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2014. These products (referred to collectively as “Covered Products” in this Report) are the following:

Certain equipment used or sold in our Adhesives Coated Products business, which the Company manufactures or contracts to manufacture, may contain Conflict Minerals in the electronic components of such equipment.

Certain products manufactured or assembled by Engent, Inc., a wholly owned subsidiary of the Company, for its customers which contain electronic components and materials. Engent, Inc. was acquired by the Company in 2012 and is a provider of manufacturing, research and development services to the electronics industry.

In our Conflict Minerals Report for calendar year 2013, we noted that certain specialty adhesives products, which the Company manufactures or contracts to manufacture might contain tin or tin-related compounds, which we believed at the time were within the scope of the Conflict Minerals Rule. For that subset of our adhesives products, the only potential Conflict Minerals that were potentially present were tin-related. In that subset of products, tin is used solely as a catalyst and, therefore, appears only in very small percentages of the finished product. Subsequent to the filing of our Conflict Minerals Report for calendar year 2013, we determined that these chemical compounds derived from tin were not in scope of the Conflict Minerals Rule and therefore no reasonable country of origin inquiry needs to be made with regard to these chemical compounds. This determination was made as a result of: (i) analysis of the products containing these chemical compounds and (ii) published correspondence from representatives of trade groups regarding the SEC Staff’s position that certain chemical compounds (e.g., catalysts, stabilizers and polymerization aids) are not within the scope of the Conflict Minerals Rule as well as our confirmation from the SEC Staff last fall that the correspondence accurately reflected its position.

We acquired several companies that were not included in our report for last year. None of the acquired companies had been obligated to provide a specialized disclosure report with respect to its use of conflict minerals. The Company did not include any of these businesses in our reporting on Form SD and the Conflict Minerals Report for calendar year 2013 as we completed the acquisitions less than eight months prior to January 1, 2013. These acquired companies are included in our report for calendar year 2014, as applicable.

On September 3, 2014 we acquired the ProSpec® construction products business, a provider of tile and stone installation products. The company from which we acquired this business was obligated to provide a specialized disclosure report with respect to its use of conflict minerals for calendar year 2013. However, the ProSpec construction products business does not use conflict minerals in the products it manufactures or contracts to manufacture and therefore was not described on that report. We acquired another adhesives related company in Brazil in calendar year 2013, Plexbond Quimica, S.A. Based upon our inquiry and belief, this subsidiary also does not use conflict minerals in the products it manufactures or contracts to manufacture.

2. Reasonable Country of Origin Inquiry (RCOI). The Company has conducted a good faith reasonable country of origin inquiry regarding the Conflict Minerals. This good faith reasonable country of origin inquiry was reasonably designed to determine whether any of the Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap resources. In response to our RCOI, a few suppliers indicated that any components or products provided to us that contained 3TG came from scrap or recycled sources. Additionally, other suppliers confirmed that their products originated from countries other than Covered Countries. A few suppliers indicated that their products included Conflict Minerals which originated from the Covered Countries and most of those were from smelters that were on the compliant refiners or smelters list or the active smelters or refiners list as set forth on the lists published by the Conflict Free Smelters Initiative website, www.conflictfreesourcing.org.


3. Design of Due Diligence Framework. The Company’s due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”) in all material respects.

4. Due Diligence Measures Performed. The Company has adopted a policy relating to the Conflict Minerals (the “Company Policy”), incorporating the standards set forth in the OECD Guidance. The policy generally states that the Company is committed to ethical practices and compliance with applicable laws and regulations, including the SEC’s regulations and the Conflict Minerals Rules. It states that the Company does not generally source Conflict Minerals directly from the source of supply (mines, smelters, refiners) and that the Company is therefore generally removed by several levels from sources of supply of Conflict Minerals. The policy commits the Company to use reasonable due diligence to identify the source of any Conflict Minerals, realizing that this will entail the cooperation of its suppliers. The Company is committed to compliance with the Conflict Minerals Rules, including understanding the Conflict Minerals Rules, communicating and educating our personnel, suppliers and customers regarding the Conflict Minerals Rules and to create processes and procedures to conduct supply chain due diligence and comply with reporting requirements. The Company values its supplier and customer relationships and will work with our suppliers over time to ensure our compliance with the Conflict Minerals Rules.

The Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and has therefore asked its suppliers to identify the applicable smelters and refiners of Conflict Minerals in the Company’s supply chain. Most of the suppliers who provided information regarding smelters provided this information on a company level versus a product level. Therefore, we do not know if the materials from the smelters we have included in this Conflict Minerals Report are in our products. It will likely take additional time before we are able to obtain information at a product level and it is possible that we may not get product level information.

The Company has a steering committee which oversee the activities of a multi-functional group of personnel who have worked on due diligence and compliance related to Conflict Minerals. The composition of the steering committee includes several executive level officers. The multi-functional group includes employees from the Company covering areas such as regulatory, sourcing, finance, legal and operations.

In general, a review of products and raw materials contained therein (including chemical composition) or components (for equipment) was completed and a list of suppliers of raw materials or components where Conflict Minerals were determined to be potentially present was assembled. The initial focus has been on top-tier suppliers of these raw materials or components. For these top-tier suppliers, the Company sent out questionnaires including the EICC®-GeSI form (“Supplier Questionnaire”) to inquire about the country of origin of Conflict Minerals potentially included in the Company’s Covered Products. This template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a supplier’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the supplier and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on EICC’s website. Responses to these questionnaires were monitored and follow up communication was sent if a response was not received. The Company has not had any direct contact with mines, smelters or refiners. The Company will continue to follow up with its suppliers related to incomplete responses or any responses deemed to be questionable or potentially not trustworthy. We also compared the smelters that were disclosed on the surveys to the lists of compliant smelters and refiners and active smelters and refiners on the Conflict Free Sourcing Initiative’s website.


The Company has undertaken an internal education process to ensure that relevant personnel are aware of the Conflict Minerals Rules and it has conducted training of several employee groups since the inception of due diligence efforts. In addition, it has designated personnel to respond to customer and supplier inquiries regarding the Conflict Minerals Rules. These personnel are part of the multi-functional group working on due diligence and compliance efforts. Ongoing supplier communication and follow up will occur during calendar year 2015.

The Company’s initial goal was to focus its efforts on top-tier suppliers of goods that may contain Conflict Minerals. Over time, the Company expects to extend its focus to the suppliers of those suppliers, and deeper into the supply chain, by urging its direct suppliers to make similar inquiries of their suppliers. The Company will review any suppliers who are materially non-compliant with our Conflict Minerals Policy for future business purposes. The Company will make reasonable efforts to find suppliers who comply with our Conflict Minerals Policy and who will meet our needs.

In response to the survey, many of our direct suppliers indicated that they were still in the process of completing their own due diligence.

Facilities That May Have Been Used to Process Necessary Conflict Minerals, if Known, for H.B. Fuller Products.

Schedule 1 to this Conflict Minerals Report includes a list of facilities that may have been used to process necessary conflict minerals for H.B. Fuller Company products. This list is based on our due diligence for 2014. Most of the information was provided to us on a company level versus a product level, and the suppliers did not generally limit their responses to facility information for Conflict Minerals in products they supply to us specifically.

Countries of Origin of the Conflict Minerals processed by these facilities are believed to include:

The suppliers and manufacturers we surveyed who identified the countries of origin of Conflict Minerals in their products identified the countries or the country categories (from the Conflict Free Sourcing Initiative (“CFSI”)) listed on Schedule 2 to this Conflict Minerals Report. Conflict Minerals contained in our Covered Products did not necessarily originate in the countries listed on Schedule 2. This is because our suppliers and manufacturers generally provided country of origin information in the survey responses at the company level, representing the suppliers’ and manufacturers’ entire product lines, and generally did not limit their responses to countries of origin for products they supply to us specifically.

5. Future Steps to Mitigate Risk. We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TG in our products finance or benefit armed groups in the Covered Countries:

 

  a. Continue to engage with our direct suppliers to increase the response rate to our survey and to improve the content and quality of their responses;

 

  b. Continue to work to add language to applicable contracts and purchase orders stating our compliance requirements for our suppliers related to Conflict Minerals Rules; and

 

  c. Continue to engage with our direct suppliers to receive more information from upstream in their supply chain of any 3TG in the components and raw materials they supply to us.


Conclusion

After exercising the due diligence described above, the Company was unable to determine whether or not its products contain conflict minerals: (1) from recycled or scrap sources as defined in the Conflict Minerals Rule, (2) that did not originate in the Covered Countries, or (3) that did not directly or indirectly finance or benefit armed groups, as defined in the Conflict Minerals Rule, in the Covered Countries.

As set forth above, the Company will continue to engage with its suppliers to obtain complete and accurate information about its supply chain as it relates to Conflict Minerals and their origins.

Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements, which are based on our current expectations and involve numerous risks and uncertainties that may cause these forward-looking statements to be inaccurate. These statements include statements regarding our goals for future improvements to our due diligence process and to mitigate the risk about the sourcing of our conflict minerals. All forward-looking statements involve risk and uncertainty. Risks that may cause these forward-looking statements to be inaccurate include: failure to carry out these plans in a timely manner or at all; lack of cooperation or progress by our suppliers, their respective suppliers and smelters; or lack of progress by smelter or refiner validation programs for conflict minerals (including the possibility of inaccurate information, fraud and other irregularities). In addition, you should also consider the important factors described in reports and documents that we file from time to time with the SEC, including the factors described under the sections titled “Risk Factors” in our most recently submitted Annual and Quarterly Reports on Form 10-K and Form 10-Q, respectively. Except as required by law, we disclaim any obligation to update information contained in these forward-looking statements whether as a result of new information, future events, or otherwise.


Schedule 1

 

Metal

  

Facility Name

   Status
Gold    Aida Chemical Industries Co. Ltd.    *
Gold    Allgemeine Gold-und Silberscheideanstalt A.G.    *
Gold    Almalyk Mining and Metallurgical Complex (AMMC)   
Gold    AngloGold Ashanti Córrego do Sítio Minerção    *
Gold    Argor-Heraeus SA    *
Gold    Asahi Pretec Corporation    *
Gold    Asaka Riken Co Ltd    **
Gold    Atasay Kuyumculuk Sanayi Ve Ticaret A.S.    *
Gold    Aurubis AG    *
Gold    Bangko Sentral ng Pilipinas (Central Bank of the Philippines)   
Gold    Bauer Walser AG   
Gold    Boliden AB    *
Gold    C. Hafner GmbH + Co. KG    *
Gold    Caridad   
Gold    CCR Refinery – Glencore Canada Corporation    *
Gold    Cendres + Métaux SA    **
Gold    Chimet S.p.A.    *
Gold    China National Gold Group Corporation   
Gold    Chugai Mining   
Gold    Colt Refining   
Gold    Daejin Indus Co. Ltd   
Gold    DaeryongENC   
Gold    Daye Non-Ferrous Metals Mining Ltd.   
Gold    Do Sung Corporation   
Gold    Doduco    **
Gold    Dowa    *
Gold    Eco-System Recycling Co., Ltd.    *
Gold    FSE Novosibirsk Refinery   
Gold    Gansu Seemine Material Hi-Tech Co Ltd   
Gold    Guangdong Jinding Gold Limited   
Gold    Hangzhou Fuchunjiang Smelting Co., Ltd.   
Gold    Heimerle + Meule GmbH    *
Gold    Heraeus Ltd Hong Kong    *
Gold    Heraeus Precious Metals GmbH & Co. KG    *
Gold    Hunan Chenzhou Mining Group Co., Ltd.   
Gold    Hwasung CJ Co. Ltd   
Gold    Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited   
Gold    Ishifuku Metal Industry Co., Ltd.    *
Gold    Istanbul Gold Refinery    *


Metal   

Facility Name

   Status
Gold    Japan Mint    *
Gold    Jiangxi Copper Company Limited   
Gold    Johnson Matthey Inc    *
Gold    Johnson Matthey Ltd    *
Gold    JSC Ekaterinburg Non-Ferrous Metal Processing Plant    *
Gold    JSC Uralelectromed    *
Gold    JX Nippon Mining & Metals Co., Ltd    *
Gold    Kazzinc Ltd    *
Gold    Kennecott Utah Copper LLC    *
Gold    Kojima Chemicals Co., Ltd    *
Gold    Korea Metal Co. Ltd   
Gold    Kyrgyzaltyn JSC   
Gold    L’azurde Company For Jewelry    *
Gold    Lingbao Jinyuan Tonghui Refinery Co. Ltd.   
Gold    LS-NIKKO Copper Inc.    *
Gold    Luoyang Zijin Yinhui Metal Smelt Co Ltd   
Gold    Materion    *
Gold    Matsuda Sangyo Co. Ltd    *
Gold    Metalor Technologies (Hong Kong) Ltd    *
Gold    Metalor Technologies (Singapore) Pte. Ltd.    *
Gold    Metalor Technologies SA    *
Gold    Metalor USA Refining Corporation    *
Gold    Met-Mex Peñoles, S.A.    *
Gold    Mitsubishi Materials Corporation    *
Gold    Mitsui Mining and Smelting Co., Ltd.    *
Gold    Moscow Special Alloys Processing Plant   
Gold    Nadir Metal Rafineri San. Ve Tic. A.Ş.    *
Gold    Navoi Mining and Metallurgical Combinat   
Gold    Nihon Material Co. LTD    *
Gold    Ohio Precious Metals, LLC    *
Gold    Ohura Precious Metal Industry Co., Ltd    *
Gold    OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)    *
Gold    OJSC Kolyma Refinery   
Gold    PAMP SA    *
Gold    Prioksky Plant of Non-Ferrous Metals   
Gold    PT Aneka Tambang (Persero) Tbk    *
Gold    PX Précinox SA    *
Gold    Rand Refinery (Pty) Ltd    *
Gold    Royal Canadian Mint    *
Gold    Sabin Metal Corp.   
Gold    SAMWON METALS Corp.   
Gold    Schone Edelmetaal    *
Gold    SEMPSA Joyería Platería SA    *
Gold    Shandong Zhaojin Gold & Silver Refinery Co. Ltd    *


Metal   

Facility Name

   Status
Gold    So Accurate Group, Inc.   
Gold    SOE Shyolkovsky Factory of Secondary Precious Metals    **
Gold    Solar Applied Materials Technology Corp.    *
Gold    Sumitomo Metal Mining Co., Ltd.    *
Gold    Tanaka Kikinzoku Kogyo K.K.    *
Gold    The Great Wall Gold and Silver Refinery of China   
Gold    The Refinery of Shandong Gold Mining Co. Ltd    *
Gold    Tokuriki Honten Co., Ltd    *
Gold    Tongling nonferrous Metals Group Co.,Ltd   
Gold    Torecom    **
Gold    Umicore Brasil Ltda    *
Gold    Umicore Precious Metals Thailand    *
Gold    Umicore SA Business Unit Precious Metals Refining    *
Gold    United Precious Metal Refining, Inc.    *
Gold    Valcambi SA    *
Gold    Western Australian Mint trading as The Perth Mint    *
Gold    Xstrata Canada Corporation   
Gold    YAMAMOTO PRECIOUS METAL CO., LTD.    *
Gold    Yokohama Metal Co Ltd    **
Gold    Yunnan Copper Industry Co Ltd   
Gold    Zhongyuan Gold Smelter of Zhongjin Gold Corporation    *
Gold    Zijin Mining Group Co. Ltd    *
Tantalum    Changsha South Tantalum Niobium Co., Ltd.    *
Tantalum    Conghua Tantalum and Niobium Smeltry    *
Tantalum    Duoluoshan    *
Tantalum    Exotech Inc.    *
Tantalum    F&X Electro-Materials Ltd.    *
Tantalum    Global Advanced Metals   
Tantalum    Guangdong Zhiyuan New Material Co., Ltd.    *
Tantalum    H.C. Starck Group   
Tantalum    Hengyang King Xing Lifeng New Materials Co., Ltd.    *
Tantalum    Hi-Temp    *
Tantalum    JiuJiang JinXin Nonferrous Metals Co., Ltd.    *
Tantalum    Jiujiang Tanbre Co., Ltd.    *
Tantalum    Kemet Blue Powder   
Tantalum    King-Tan Tantalum Industry Ltd    *
Tantalum    LSM Brasil S.A.    *
Tantalum    Metallurgical Products India (Pvt.) Ltd.    *
Tantalum    Mineração Taboca S.A.    *
Tantalum    Mitsui Mining & Smelting    *
Tantalum    Molycorp Silmet A.S.   
Tantalum    Ningxia Orient Tantalum Industry Co., Ltd.    *
Tantalum    Plansee   
Tantalum    QuantumClean    *


Metal   

Facility Name

   Status
Tantalum    RFH Tantalum Smeltry Co., Ltd    *
Tantalum    Shanghai Jiangxi Metals Co. Ltd   
Tantalum    Solikamsk Magnesium Works OAO    *
Tantalum    Taki Chemicals    *
Tantalum    Tantalite Resources   
Tantalum    Telex    *
Tantalum    Ulba    *
Tantalum    Yichun Jin Yang Rare Metal Co., Ltd    *
Tantalum    Zhuzhou Cement Carbide    *
Tin    Alpha    *
Tin    China Rare Metal Materials Company    *
Tin    China Tin Group Co., Ltd.    **
Tin    CNMC (Guangxi) PGMA Co. Ltd.   
Tin    Cooper Santa    *
Tin    CV Serumpun Sebalai   
Tin    CV United Smelting    *
Tin    EM Vinto    *
Tin    Estanho de Rondônia S.A.   
Tin    Fenix Metals    **
Tin    Gejiu Kai Meng Industry and Trade LLC   
Tin    Gejiu Non-Ferrous Metal Processing Co. Ltd.    *
Tin    Gejiu Zi-Li   
Tin    Huichang Jinshunda Tin Co. Ltd   
Tin    Jiangxi Nanshan   
Tin    Kai Unita Trade Limited Liability Company   
Tin    Linwu Xianggui Smelter Co   
Tin    Magnu’s Minerais Metais e Ligas LTDA    *
Tin    Malaysia Smelting Corp    *
Tin    Melt Metais e Ligas S/A    *
Tin    Metallo Chimique   
Tin    Mineração Taboca S.A.    *
Tin    Minmetals Ganzhou Tin Co. Ltd.   
Tin    Minsur    *
Tin    Mitsubishi Materials Corporation    *
Tin    Novosibirsk Integrated Tin Works   
Tin    O.M. Manufacturing (Thailand) Co., Ltd.    **
Tin    OMSA    *
Tin    PT Artha Cipta Langgeng    *
Tin    PT Babel Inti Perkasa    *
Tin    PT Bangka Kudai Tin   
Tin    PT Bangka Putra Karya    *
Tin    PT Bangka Timah Utama Sejahtera   
Tin    PT Bangka Tin Industry    *
Tin    PT Belitung Industri Sejahtera    *
Tin    PT BilliTin Makmur Lestari    **


Metal   

Facility Name

   Status
Tin    PT Bukit Timah    *
Tin    PT DS Jaya Abadi    *
Tin    PT Eunindo Usaha Mandiri    *
Tin    PT Karimun Mining   
Tin    PT Koba Tin   
Tin    PT Mitra Stania Prima    *
Tin    PT Prima Timah Utama    *
Tin    PT REFINED BANGKA TIN    *
Tin    PT Sariwiguna Binasentosa    *
Tin    PT Stanindo Inti Perkasa    *
Tin    PT Tambang Timah    *
Tin    PT Timah (Persero), Tbk    *
Tin    PT Tinindo Inter Nusa    *
Tin    Rui Da Hung    **
Tin    Soft Metais, Ltda.    *
Tin    Thaisarco    *
Tin    White Solder Metalurgia e Mineração Ltda.    *
Tin    Yunnan Chengfeng    **
Tin    Yunnan Tin Company, Ltd.    *
Tungsten    A.L.M.T. Corp.    **
Tungsten    Chenzhou Diamond Tungsten Products Co., Ltd.    *
Tungsten    Chongyi Zhangyuan Tungsten Co., Ltd.    **
Tungsten    Dayu Weiliang Tungsten Co., Ltd.    **
Tungsten    Fujian Jinxin Tungsten Co., Ltd.    *
Tungsten    Ganzhou Huaxing Tungsten Products Co., Ltd.    *
Tungsten    Ganzhou Jiangwu Ferrotungsten Co., Ltd.    *
Tungsten    Ganzhou Non-ferrous Metals Smelting Co., Ltd.    **
Tungsten    Ganzhou Seadragon W & Mo Co., Ltd.    *
Tungsten    Global Tungsten & Powders Corp    *
Tungsten    Guangdong Xianglu Tungsten Co., Ltd.    **
Tungsten    H.C. Starck   
Tungsten    H.C. Starck GmbH    **
Tungsten    Hunan Chenzhou Mining Group Co., Ltd.    **
Tungsten    Hunan Chunchang Nonferrous Metals Co., Ltd.    *
Tungsten    Japan New Metals Co., Ltd.    *
Tungsten    Jiangxi Gan Bei Tungsten Co., Ltd.    *
Tungsten    Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.   
Tungsten    Jiangxi Richsea New Materials Co., Ltd.   
Tungsten    Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.    **
Tungsten    Jiangxi Xinsheng Tungsten Industry Co., Ltd.    **
Tungsten    Jiangxi Yaosheng Tungsten Co., Ltd.    **
Tungsten    Kennametal Huntsville    **
Tungsten    Kennametal Inc.    **
Tungsten    Malipo Haiyu Tungsten Co., Ltd.    *


Metal   

Facility Name

   Status
Tungsten    Plansee   
Tungsten    Tejing (Vietnam) Tungsten Co., Ltd.    **
Tungsten    Vietnam Youngsun Tungsten Industry Co., Ltd    *
Tungsten    Wolfram Bergbau und Hütten AG    *
Tungsten    Wolfram Company CJSC   
Tungsten    Xiamen Tungsten (H.C.) Co., Ltd.    *
Tungsten    Xiamen Tungsten Co., Ltd.    *
Tungsten    Xianglu Tungsten Industry Co. Ltd.   
Tungsten    Xinhai Rendan Shaoguan Tungsten Co., Ltd.    **
Tungsten    Zhuzhou Cemented Carbide Group Co Ltd   

*Smelter name is included on the Conflict Free Sourcing Initiative’s Compliant Conflict Free Smelter and Refiner List.

**Smelter name is included on the Conflict Free Sourcing Initiative’s Active Smelters and Refiners List. This is a list of smelters that are currently pursuing an audit by the Conflict Free Smelter Program developed by EICC and the Global e-Sustainability Initiative (GeSI) to aid in the effort to verify the source of metals. Smelters and refiners on the Active list are at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase.

A blank space in the status column indicates that the smelter or refiner was not on the CFSI lists or we were unable to ascertain the status.


Schedule 2

Level 1 Country (L1): Countries that are not identified as conflict regions or plausible areas or smuggling or export of or from these regions of Conflict Minerals: Australia, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Côte d’Ivoire, Ethiopia, Germany, Guyana, Hong Kong, India, Indonesia, Japan, Kazakhstan, Malaysia, Mexico, Namibia, Nigeria, Peru, Philippines, Poland, Portugal, Russian Federation, Sierra Leone, Spain, Suriname, Switzerland, unidentified countries in South America, Taiwan, Thailand, United States, Viet Nam, West Africa and Zimbabwe.

Level 2 Country (L2): Countries that are known or plausible countries for smuggling, export out of or transit of materials containing Conflict Minerals from Level 3 countries: currently includes Kenya, Mozambique, and South Africa.

Level 3 Country (L3): The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act: includes Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. These are also commonly referred to as “covered countries”

Alternatively, or in addition, some of the Compliant smelters and refiners may have sourced from recycled or scrap sources.