EX-1.01 2 ex1-01.htm EX-1.01

Exhibit 1.01

 

CONMED Corporation

Conflict Minerals Report

For The Year Ended December 31, 2016

 

We have made statements in this Conflict Minerals Report that may constitute forward-looking statements about our plans to take additional actions or to implement additional procedures with respect to our due diligence efforts to determine the origin of conflict minerals included in our products. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. Our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report.

 

 

1. Introduction

 

CONMED Corporation (“CONMED”, the “Company”, “we”, “our” or “us”) is filing this Conflict Minerals Report (“CMR”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the year ended December 31, 2016.

 

This Conflict Minerals Report describes our reasonable country of origin inquiry (“RCOI”), the results thereof, and the design of our due diligence measures to determine whether 3TGs in products that CONMED manufactures or contracts to manufacture originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”). The Covered Countries include Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. The term “Conflict Minerals” is defined as: columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. For purposes of this CMR, tin, tungsten, tantalum and gold will collectively be referred to as the 3TGs. This report also provides an account of how these due diligence measures were implemented in 2016.

 

This report is available on our website at http://www.conmed.com/en/about-us/investors/investor-relations in the SEC Filings section.

 

 

2. Company Overview

 

CONMED is a medical technology company that provides surgical devices and equipment for minimally invasive procedures. The Company’s products are used by surgeons and physicians in a variety of specialties including orthopedics, general surgery, gynecology, neurosurgery, and gastroenterology.

 

Products

 

Our product lines consist of orthopedic surgery, general surgery and surgical visualization. Orthopedic surgery consists of sports medicine instrumentation and small bone, large bone and specialty powered surgical instruments and service fees related to the promotion and marketing of sports medicine allograft tissue. General surgery consists of a complete line of endomechanical instrumentation for minimally invasive laparoscopic and gastrointestinal procedures, a line of cardiac monitoring products as well as electrosurgical generators and related instruments. Surgical visualization consists of imaging

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systems for use in minimally invasive orthopedic and general surgery procedures including vision technologies. 3TGs are in a significant portion of CONMED products due to electronics being a vital component to many of our product offerings. All four 3TGs are found within various electrical components that make up CONMED products, such as capacitors, rectifiers, relays, and electrical connectors.

 

 

Conflict Minerals Policy

 

In addition to the measures described above, we have adopted a conflict minerals supply policy. This policy is available on our website at http://www.conmed.com/en/about-us/investors/investor-relations in the Corporate Governance section.

 

3. Reasonable Country of Origin Inquiry

 

Because conflict minerals are necessary to the functionality or production of products that we manufacture, we are required to conduct in good faith a reasonable country of origin inquiry regarding those conflict minerals. The RCOI is reasonably designed to determine whether any of the conflict minerals originated in the DRC, or the Covered Countries, or are from recycled or scrap sources.

 

Our RCOI employed a combination of measures to determine whether the 3TGs necessary for the functionality or production of CONMED products originated from the DRC or any of the Covered Countries. The company’s primary means of determining country of origin of the necessary 3TGs was by conducting a supply chain survey with direct suppliers using the Electronic Industry Citizenship Coalition® (“EICC”®) and the Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”). This supply chain survey was implemented with the assistance of a third-party service provider, who is also assisting us with the development and implementation of additional steps that we are undertaking with suppliers in regards to conflict minerals.

 

As an initial step, we identified all first-tier suppliers that provided items to CONMED that were used in final products in 2016. The total number of suppliers in 2016 was 1,460. This list included many suppliers that did not provide any 3TGs. After excluding suppliers that did not provide any 3TGs to CONMED, the list totaled 784 suppliers. Any suppliers that appeared on this initial list could be placed out of scope during the supplier survey process. For example, if they were included on the initial list in error and they did not in fact provide components or 3TG components used in our products or, as the CMRT allows, because any 3TGs in those components are unnecessary to the functionality or production of the supplier’s products, they were listed as out of scope.

 

The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide 3TG materials 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 used in products provided to CONMED. In addition, the template contains questions about the origin of 3TGs included in the supplier’s products, as well as supplier due diligence. To ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have provided training to our suppliers through webinars, videos and substantial one-on-one discussions.

 

This year’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of May 4, 2017, we still had 40 invalid supplier submissions that were not yet corrected.

 

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Over 81% of the CONMED suppliers contacted provided a response. Non-responsive suppliers were contacted numerous times by both our third-party consultant and CONMED personnel. Of the 1,175 suppliers that provided a response, approximately 26% reported that their products contained 3TGs necessary to the functionality or production of their products. The majority of CMRTs provided by CONMED suppliers are at the company level and therefore cannot be definitively linked to any specific CONMED product.

 

On the basis of the responses to our RCOI, CONMED is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the DRC or any of the Covered Countries. Accordingly, CONMED engaged in the due diligence measures on the source and chain of custody of those 3TGs, as described in the next section of this Conflict Minerals Report.

 

4.0 Design of Due Diligence Measures

 

Our due diligence measures have been designed to conform, in all material respects, with the framework established in The Organisation for Economic Co-operation and Development (“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, tin, tantalum and tungsten.

 

4.1 Management Systems

 

As described above, CONMED has adopted a conflict minerals policy, which is located in the Corporate Governance section of the CONMED Corporation website (http://www.conmed.com/en/about-us/investors/investor-relations).

 

Internal Team

 

CONMED has established a management system regarding the sourcing of 3TGs. Our management system includes both internal and external resources led by a project manager and subject matter experts at each of our manufacturing locations. This group is responsible for implementing our conflict minerals strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis. We also use a third-party service provider to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regard to conflict minerals.

 

Control Systems

 

As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we are engaged and actively cooperate with other major manufacturers in the medical device industry regarding 3TG sourcing matters.

 

With regards to our suppliers, controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all CONMED employees; our supplier approval and review process, as well as contractual protections, as described further below; and business relationships with our suppliers.

 

Supply Chain Due Diligence

 

We obtain various component products from suppliers that we use in manufacturing our products. Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, among other reasons, it is difficult for us to identify actors upstream from our direct suppliers. As part of our supply chain procedures, we require in our supply contracts that our direct suppliers provide information on the origin of the 3TGs contained in components and materials supplied to us – including sources of 3TGs that are supplied to them from all applicable lower tier suppliers. Contracts with our direct suppliers are frequently multi-year term contracts. In those cases, although we generally are unable to unilaterally impose new contract terms and flow-down requirements prior to expiration of the contract, we work individually with key selected suppliers to insure they provide 3TG sourcing information for all current contracts, and in all new contracts in the future. We have approached existing suppliers to adopt amendments regarding 3TGs, and as we renew contracts or enter into new ones, we will add a clause that requires all applicable suppliers to provide information about the source of 3TGs and information about the smelters from which 3TGs are sourced. In light of existing contract term durations, it will take some time to ensure that all supplier contracts contain what we believe are appropriate “flow-down” clauses. In the meantime, and in parallel, all purchase orders for direct materials used in the composition of our products require that suppliers provide CONMED with Conflict Minerals information on the current Conflict Minerals Reporting Template, or CMRT (as described further below), and that components must be free of Conflict Minerals.

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Supplier Engagement

 

With respect to the OECD requirement to strengthen engagement with suppliers, we use a Supplier Approval Process that evaluates our suppliers based on their quality systems and their readiness to provide CONMED all of the required services and support documents. In addition, key suppliers are evaluated on the “Supplier Report Card” as to their performance in all aspects of the supply contract. This review includes, but is not limited to: product quality, supplier performance and ensuring conflict mineral avoidance.

 

This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party consultant’s learning management system and provided all in-scope suppliers access to Conflict Minerals training courses. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within these courses.

 

Grievance Mechanism

 

Various communication channels exist to serve as grievance mechanisms for early-warning risk awareness. We have multiple longstanding grievance mechanisms whereby employees (internal) and suppliers (external) can report violations of CONMED’s policies. This includes, but is not limited to our whistleblower hotline that is part of our Code of Business Conduct and Ethics policy located in the Corporate Governance section of our website at http://www.conmed.com/en/about-us/investors/investor-relations in the Corporate Governance section.

 

Maintain Records

 

We have adopted a policy to retain relevant documentation, including the records of our due diligence process, for a minimum period of five years.

 

4.2 Risk Identification, Assessment and Response

 

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-Conflict Free by third party sources such as the Conflict-Free Sourcing Initiative (“CFSI”) or the London Bullion Market Association

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(“LBMA”) Responsible Gold Programme, pose a significant risk. Where a smelter is not identified as Conflict Free by such sources, we rate the risk as High, Medium or Low. This rating is based on various factors, including whether the smelter/refiner has been identified as a valid smelter/refiner and has an associated Smelter Identification Number (under the CFSI, this is known as a CID), and the smelter’s geographic location, including proximity to the Covered Countries.

 

We calculate supplier risk based on the chances that a supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

 

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:

 

·Do you have a policy in place that includes DRC conflict-free sourcing?
·Have you implemented due diligence measures for conflict-free sourcing?
·Do you verify due diligence information received from your suppliers?
·Does your verification process include corrective action management?

 

When suppliers answer yes, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

 

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through a third party, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.

 

As described in our Conflict Minerals Policy, we engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. If we are not satisfied with the results, we will then take steps to terminate a contract and find replacement suppliers.

 

Additionally, in designing and implementing our strategy to respond to the supply chain risks that we identified, CONMED analyzed various industry approaches and consulted with other companies in our industry.

 

Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.

 

We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products. This includes: (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.

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4.3 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

 

We support independent third-party audits through our participation in the Conflict Free Smelter Initiative (“CFSI”). We do not typically have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.

 

4.4 Report Annually on Supply Chain Due Diligence

 

CONMED reports annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. CONMED’s Form SD and Conflict Minerals Report can be found in the SEC Filings section of the CONMED site at http://www.conmed.com/en/about-us/investors/investor-relations.

 

5. Due Diligence Results

 

As described above, as part of our supply chain due diligence process, we identified suppliers likely to utilize 3TGs in the products that they provide to us. We utilized the CMRT to facilitate disclosure and communication of information regarding smelters that provide 3TGs used in products supplied to us by those suppliers for incorporation into our products.

 

The quality of the responses that we received from our surveyed suppliers also continue to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit with increased smelter information. There are still suppliers unable to provide the smelters or refiners used for materials supplied to us.

 

For all responses that indicated a smelter, our third-party consultant compared the facilities listed to the list of smelters maintained by the Conflict-Free Sourcing Initiative (“CFSI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our third-party consultant confirmed that the name was listed by CFSI as a “Conflict-Free” smelter. As of May 4, 2017, we have validated 317 legitimate smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 246 smelters that are deemed “Conflict Free Smelter Program (CFSP) Compliant” – this indicates these smelters and refiners are compliant with the CFSP assessment protocols. There are 13 more smelters or refiners that are deemed “CFSP Active” - Smelters and refiners on the Active list have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 58 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Attachment A any smelters or refiners that we have not been able to validate. Attachment A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI.

 

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Many responses received either provided data at a company or subsidiary level and chose not to provide information at the component level, or did not specify the smelters or refiners used for components supplied to CONMED. Accordingly, we are unable to determine, in those cases, whether any of the 3TGs reported by the suppliers were contained in components or parts supplied to us, or to validate that any of the smelters or refiners identified are actually in our supply chain.

 

We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During 2016, we have found no instances where it was necessary to terminate a contract or find a replacement supplier. 

 

6. Steps to Improve Future Due Diligence and Supply Chain Risk Mitigation

 

We are taking the following steps to improve our due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC or Covered Countries:

 

a.Continue to include a conflict minerals clause in all new or renewed supplier contracts.

 

b.Continue to engage with suppliers and direct them to training resources as mentioned in Section 4.1, Supplier Engagement, to attempt to increase the response rate and improve the content of the supplier survey responses.

 

·All suppliers that were non-responsive will be further contacted to encourage reply.

 

·All suppliers that did not know the origin of the 3TGs in products will be further encouraged to examine their supply chain and enact due diligence measures as per the OECD Due Diligence Guidelines.

 

c.Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the DRC or any of the Covered Countries to establish an alternative source of 3TGs that do not support such conflict.

 

d.Monitor industry best practices, and continue to work with a third-party service provider to enhance our due diligence and supply chain management process, as appropriate. This includes requesting Conflict Free sourcing by our suppliers as further described in our Conflicts Mineral Policy and in the contractual provisions described above in our Supply Chain section under Management Systems.

 

e.Consider replacing suppliers that remain non-responsive, or that are unable to enact due diligence measures as per the OECD Due Diligence Guidelines.

 

f.Work with suppliers to move to the latest CMRT where new smelter IDs are constantly being added.

 

g.Require the use of smelter identification numbers. Supplier responses will not be considered complete without identification numbers.

 

h.Suppliers will also be requested to inform CONMED of the correlation between these smelters and the products and parts they supply to CONMED.

 

7. Independent Audit

 

In accordance with guidance issued by the SEC staff, we are not required to obtain an independent private sector audit of this Conflict Minerals Report for the year ended December 31, 2016.

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Attachment A

 

Metal Standard Smelter Name Smelter Facility Location Conflict
Free?
Gold Abington Reldan Metals, LLC UNITED STATES Unknown
Gold Advanced Chemical Company UNITED STATES Yes
Gold Aida Chemical Industries Co., Ltd. JAPAN Yes
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES Yes
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY Yes
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN Yes
Gold AngloGold Ashanti Córrego do Sítio Mineração BRAZIL Yes
Gold Argor-Heraeus S.A. SWITZERLAND Yes
Gold Asahi Pretec Corp. JAPAN Yes
Gold Asahi Refining Canada Ltd. CANADA Yes
Gold Asahi Refining USA Inc. UNITED STATES Yes
Gold Asaka Riken Co., Ltd. JAPAN Yes
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY Unknown
Gold AU Traders and Refiners SOUTH AFRICA Yes
Gold AURA-II UNITED STATES Unknown
Gold Aurubis AG GERMANY Yes
Gold Bangalore Refinery INDIA Unknown
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES Yes
Gold Boliden AB SWEDEN Yes
Gold C. Hafner GmbH + Co. KG GERMANY Yes
Gold Caridad MEXICO Unknown
Gold CCR Refinery - Glencore Canada Corporation CANADA Yes
Gold Cendres + Métaux S.A. SWITZERLAND Unknown
Gold Chimet S.p.A. ITALY Yes
Gold Chugai Mining JAPAN Unknown
Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF Yes
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA Yes
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY Unknown
Gold DODUCO GmbH GERMANY Yes
Gold Dowa JAPAN Yes

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Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF Yes
Gold Eco-System Recycling Co., Ltd. JAPAN Yes
Gold Elemetal Refining, LLC UNITED STATES Yes
Gold Emirates Gold DMCC UNITED ARAB EMIRATES Yes
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE Unknown
Gold Gansu Seemine Material Hi-Tech Co., Ltd. CHINA Unknown
Gold Geib Refining Corporation UNITED STATES Unknown
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA Unknown
Gold Guangdong Jinding Gold Limited CHINA Unknown
Gold Gujarat Gold Centre INDIA Unknown
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA Unknown
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA Unknown
Gold Heimerle + Meule GmbH GERMANY Yes
Gold Heraeus Ltd. Hong Kong CHINA Yes
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY Yes
Gold Hunan Chenzhou Mining Co., Ltd. CHINA Unknown
Gold Hwasung CJ Co., Ltd. KOREA, REPUBLIC OF Unknown
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA Yes
Gold Ishifuku Metal Industry Co., Ltd. JAPAN Yes
Gold Istanbul Gold Refinery TURKEY Yes
Gold Japan Mint JAPAN Yes
Gold Jiangxi Copper Co., Ltd. CHINA Yes
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION Yes
Gold JSC Uralelectromed RUSSIAN FEDERATION Yes
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN Yes
Gold Kaloti Precious Metals UNITED ARAB EMIRATES Unknown
Gold Kazakhmys Smelting LLC KAZAKHSTAN Unknown
Gold Kazzinc KAZAKHSTAN Yes
Gold Kennecott Utah Copper LLC UNITED STATES Yes
Gold KGHM Polska Miedź Spółka Akcyjna POLAND Unknown
Gold Kojima Chemicals Co., Ltd. JAPAN Yes
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF Yes
Gold Kyrgyzaltyn JSC KYRGYZSTAN Yes

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Gold L'azurde Company For Jewelry SAUDI ARABIA Unknown
Gold Lingbao Gold Co., Ltd. CHINA Unknown
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA Unknown
Gold L'Orfebre S.A. ANDORRA Unknown
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF Yes
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA Unknown
Gold Materion UNITED STATES Yes
Gold Matsuda Sangyo Co., Ltd. JAPAN Yes
Gold Metalor Technologies (Hong Kong) Ltd. CHINA Yes
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE Yes
Gold Metalor Technologies (Suzhou) Ltd. CHINA Yes
Gold Metalor Technologies S.A. SWITZERLAND Yes
Gold Metalor USA Refining Corporation UNITED STATES Yes
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO Yes
Gold Mitsubishi Materials Corporation JAPAN Yes
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN Yes
Gold MMTC-PAMP India Pvt., Ltd. INDIA Yes
Gold Modeltech Sdn Bhd MALAYSIA Unknown
Gold Morris and Watson NEW ZEALAND Unknown
Gold Morris and Watson Gold Coast AUSTRALIA Unknown
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION Yes
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY Yes
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN Unknown
Gold Nihon Material Co., Ltd. JAPAN Yes
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA Yes
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN Yes
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION Yes
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION Yes
Gold PAMP S.A. SWITZERLAND Yes
Gold Pease & Curren UNITED STATES Unknown
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA Unknown

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Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION Yes
Gold PT Aneka Tambang (Persero) Tbk INDONESIA Yes
Gold PX Précinox S.A. SWITZERLAND Yes
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA Yes
Gold Remondis Argentia B.V. NETHERLANDS Unknown
Gold Republic Metals Corporation UNITED STATES Yes
Gold Royal Canadian Mint CANADA Yes
Gold SAAMP FRANCE Unknown
Gold Sabin Metal Corp. UNITED STATES Unknown
Gold SAFINA A.S. CZECH REPUBLIC Unknown
Gold Sai Refinery INDIA Unknown
Gold Samduck Precious Metals KOREA, REPUBLIC OF Yes
Gold SAMWON Metals Corp. KOREA, REPUBLIC OF Unknown
Gold SAXONIA Edelmetalle GmbH GERMANY Yes
Gold Schone Edelmetaal B.V. NETHERLANDS Yes
Gold SEMPSA Joyería Platería S.A. SPAIN Yes
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA Unknown
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA Yes
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA Yes
Gold Singway Technology Co., Ltd. TAIWAN Yes
Gold So Accurate Group, Inc. UNITED STATES Unknown
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION Yes
Gold Solar Applied Materials Technology Corp. TAIWAN Yes
Gold Sudan Gold Refinery SUDAN Unknown
Gold Sumitomo Metal Mining Co., Ltd. JAPAN Yes
Gold SungEel HiTech KOREA, REPUBLIC OF Unknown
Gold T.C.A S.p.A ITALY Yes
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN Yes
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA Yes
Gold Tokuriki Honten Co., Ltd. JAPAN Yes
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA Unknown
Gold Tony Goetz NV BELGIUM Unknown

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Gold TOO Tau-Ken-Altyn KAZAKHSTAN Unknown
Gold Torecom KOREA, REPUBLIC OF Yes
Gold Umicore Brasil Ltda. BRAZIL Yes
Gold Umicore Precious Metals Thailand THAILAND Yes
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM Yes
Gold United Precious Metal Refining, Inc. UNITED STATES Yes
Gold Universal Precious Metals Refining Zambia ZAMBIA Unknown
Gold Valcambi S.A. SWITZERLAND Yes
Gold Western Australian Mint trading as The Perth Mint AUSTRALIA Yes
Gold WIELAND Edelmetalle GmbH GERMANY Yes
Gold Yamamoto Precious Metal Co., Ltd. JAPAN Yes
Gold Yokohama Metal Co., Ltd. JAPAN Yes
Gold Yunnan Copper Industry Co., Ltd. CHINA Unknown
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA Yes
Gold Zijin Mining Group Co., Ltd. Gold Refinery CHINA Yes
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA Yes
Tantalum Conghua Tantalum and Niobium Smeltry CHINA Yes
Tantalum D Block Metals, LLC UNITED STATES Yes
Tantalum Duoluoshan CHINA Yes
Tantalum Exotech Inc. UNITED STATES Yes
Tantalum F&X Electro-Materials Ltd. CHINA Yes
Tantalum FIR Metals & Resource Ltd. CHINA Yes
Tantalum Global Advanced Metals Aizu JAPAN Yes
Tantalum Global Advanced Metals Boyertown UNITED STATES Yes
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA Yes
Tantalum H.C. Starck Co., Ltd. THAILAND Yes
Tantalum H.C. Starck GmbH Goslar GERMANY Yes
Tantalum H.C. Starck GmbH Laufenburg GERMANY Yes
Tantalum H.C. Starck Hermsdorf GmbH GERMANY Yes
Tantalum H.C. Starck Inc. UNITED STATES Yes
Tantalum H.C. Starck Ltd. JAPAN Yes
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY Yes

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Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA Yes
Tantalum Hi-Temp Specialty Metals, Inc. UNITED STATES Yes
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA Yes
Tantalum Jiangxi Tuohong New Raw Material CHINA Yes
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA Yes
Tantalum Jiujiang Tanbre Co., Ltd. CHINA Yes
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA Yes
Tantalum KEMET Blue Metals MEXICO Yes
Tantalum KEMET Blue Powder UNITED STATES Yes
Tantalum King-Tan Tantalum Industry Ltd. CHINA Yes
Tantalum LSM Brasil S.A. BRAZIL Yes
Tantalum Metallurgical Products India Pvt., Ltd. INDIA Yes
Tantalum Mineração Taboca S.A. BRAZIL Yes
Tantalum Mitsui Mining & Smelting JAPAN Yes
Tantalum Molycorp Silmet A.S. ESTONIA Yes
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA Yes
Tantalum Plansee SE Liezen AUSTRIA Yes
Tantalum Plansee SE Reutte AUSTRIA Yes
Tantalum Power Resources Ltd. MACEDONIA Yes
Tantalum QuantumClean UNITED STATES Yes
Tantalum Resind Indústria e Comércio Ltda. BRAZIL Yes
Tantalum RFH Tantalum Smeltry Co., Ltd. CHINA Yes
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION Yes
Tantalum Taki Chemicals JAPAN Yes
Tantalum Telex Metals UNITED STATES Yes
Tantalum Tranzact, Inc. UNITED STATES Yes
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN Yes
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA Yes
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA Yes
Tantalum Zhuzhou Cemented Carbide Group Co., Ltd. CHINA Yes
Tin Alpha UNITED STATES Yes
Tin An Thai Minerals Co., Ltd. VIETNAM Unknown

E-13 

 

 

 

Tin An Vinh Joint Stock Mineral Processing Company VIETNAM Unknown
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA Yes
Tin China Tin Group Co., Ltd. CHINA Yes
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA Unknown
Tin Cooperativa Metalurgica de Rondônia Ltda. BRAZIL Yes
Tin CV Ayi Jaya INDONESIA Yes
Tin CV Dua Sekawan INDONESIA Yes
Tin CV Gita Pesona INDONESIA Yes
Tin CV Serumpun Sebalai INDONESIA Yes
Tin CV Tiga Sekawan INDONESIA Yes
Tin CV United Smelting INDONESIA Yes
Tin CV Venus Inti Perkasa INDONESIA Yes
Tin Dowa JAPAN Yes
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIETNAM Unknown
Tin Elmet S.L.U. SPAIN Yes
Tin EM Vinto BOLIVIA Yes
Tin Estanho de Rondônia S.A. BRAZIL Unknown
Tin Fenix Metals POLAND Yes
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA Yes
Tin Gejiu Jinye Mineral Company CHINA Yes
Tin Gejiu Kai Meng Industry and Trade LLC CHINA Unknown
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA Yes
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA Unknown
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA Unknown
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA Yes
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA Yes
Tin Huichang Jinshunda Tin Co., Ltd. CHINA Unknown
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA Yes
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL Yes
Tin Malaysia Smelting Corporation (MSC) MALAYSIA Yes

E-14 

 

 

 

Tin Melt Metais e Ligas S.A. BRAZIL Yes
Tin Metallic Resources, Inc. UNITED STATES Yes
Tin Metallo-Chimique N.V. BELGIUM Yes
Tin Mineração Taboca S.A. BRAZIL Yes
Tin Minsur PERU Yes
Tin Mitsubishi Materials Corporation JAPAN Yes
Tin Modeltech Sdn Bhd MALAYSIA Unknown
Tin Nankang Nanshan Tin Manufactory Co., Ltd. CHINA Unknown
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIETNAM Unknown
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND Yes
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES Yes
Tin Operaciones Metalurgical S.A. BOLIVIA Yes
Tin Phoenix Metal Ltd. RWANDA Unknown
Tin PT Aries Kencana Sejahtera INDONESIA Yes
Tin PT Artha Cipta Langgeng INDONESIA Yes
Tin PT ATD Makmur Mandiri Jaya INDONESIA Yes
Tin PT Babel Inti Perkasa INDONESIA Yes
Tin PT Bangka Prima Tin INDONESIA Yes
Tin PT Bangka Tin Industry INDONESIA Yes
Tin PT Belitung Industri Sejahtera INDONESIA Yes
Tin PT Bukit Timah INDONESIA Yes
Tin PT Cipta Persada Mulia INDONESIA Yes
Tin PT DS Jaya Abadi INDONESIA Yes
Tin PT Eunindo Usaha Mandiri INDONESIA Yes
Tin PT Inti Stania Prima INDONESIA Yes
Tin PT Justindo INDONESIA Yes
Tin PT Karimun Mining INDONESIA Yes
Tin PT Kijang Jaya Mandiri INDONESIA Yes
Tin PT Lautan Harmonis Sejahtera INDONESIA Yes
Tin PT Mitra Stania Prima INDONESIA Yes
Tin PT O.M. Indonesia INDONESIA Yes
Tin PT Panca Mega Persada INDONESIA Yes
Tin PT Prima Timah Utama INDONESIA Yes
Tin PT Refined Bangka Tin INDONESIA Yes

E-15 

 

 

 

Tin PT Sariwiguna Binasentosa INDONESIA Yes
Tin PT Stanindo Inti Perkasa INDONESIA Yes
Tin PT Sukses Inti Makmur INDONESIA Yes
Tin PT Sumber Jaya Indah INDONESIA Yes
Tin PT Timah (Persero) Tbk Kundur INDONESIA Yes
Tin PT Timah (Persero) Tbk Mentok INDONESIA Yes
Tin PT Tinindo Inter Nusa INDONESIA Yes
Tin PT Tommy Utama INDONESIA Yes
Tin PT Wahana Perkit Jaya INDONESIA Yes
Tin Resind Indústria e Comércio Ltda. BRAZIL Yes
Tin Rui Da Hung TAIWAN Yes
Tin Soft Metais Ltda. BRAZIL Yes
Tin Thaisarco THAILAND Yes
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIETNAM Unknown
Tin VQB Mineral and Trading Group JSC VIETNAM Yes
Tin White Solder Metalurgia e Mineração Ltda. BRAZIL Yes
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA Unknown
Tin Yunnan Tin Company Limited CHINA Yes
Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN Yes
Tungsten ACL Metais Eireli BRAZIL Unknown
Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM Yes
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA Yes
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA Yes
Tungsten Dayu Weiliang Tungsten Co., Ltd. CHINA Unknown
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA Yes
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA Yes
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA Yes
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA Yes
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA Unknown
Tungsten Global Tungsten & Powders Corp. UNITED STATES Yes
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA Yes
Tungsten H.C. Starck GmbH GERMANY Yes
Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY Yes

E-16 

 

 

 

Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA Yes
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA Yes
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA Yes
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION Yes
Tungsten Japan New Metals Co., Ltd. JAPAN Yes
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA Yes
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA Unknown
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA Yes
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA Unknown
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA Yes
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA Yes
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA Yes
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA Yes
Tungsten Kennametal Fallon UNITED STATES Yes
Tungsten Kennametal Huntsville UNITED STATES Yes
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA Yes
Tungsten Moliren Ltd RUSSIAN FEDERATION Yes
Tungsten Niagara Refining LLC UNITED STATES Yes
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIETNAM Yes
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES Yes
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA Yes
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIETNAM Yes
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION Yes
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIETNAM Yes
Tungsten Wolfram Bergbau und Hütten AG AUSTRIA Yes
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF Yes
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA Yes
Tungsten Xiamen Tungsten Co., Ltd. CHINA Yes
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA Yes
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA Yes

 

E-17 

 

Appendix B:

 

Based upon the RCOI data made available from the CFSI, the countries of origin of the conflict minerals sourced and processed by the CFS-compliant smelters and refiners identified as potentially being in CONMED’s product supply chains may include, but are not necessarily limited to, the following:

Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, DRC, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Luxembourg, Macedonia, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe.

 

E-18