EX-1.01 2 c495100_ex1-01.htm EXHIBIT 1.01

 

Exhibit 1.01

 

CONMED Corporation

Conflict Minerals Report

For The Year Ended December 31, 2017

 

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, 2017.

 

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 2017.

 

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 and general surgery.  Orthopedic surgery consists of sports medicine instrumentation and small bone, large bone and specialty powered surgical instruments as well as imaging systems for use in minimally invasive surgery procedures including 2DHD and 3DHD vision technologies and service fees related to the promotion and marketing of sports medicine allograft tissue.  General surgery consists of a complete line of endo-mechanical instrumentation for minimally invasive laparoscopic and gastrointestinal procedures, a line of cardiac monitoring products as well as electrosurgical generators and related instruments. 3TGs are in a significant portion of CONMED products due to electronics being a vital component to many of our product offerings. All types of 3TGs may be 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.

 

 E-1 

 

 

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 Responsible Business Alliance’s Conflict Minerals Reporting Template (“CMRT”). This supply chain survey was implemented with the assistance of a third-party service provider, which 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 2017. The total number of suppliers in 2017 was 1,108. This list included many suppliers that did not disclose the use of any 3TGs. 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 15, 2018, we still had 19 invalid supplier submissions that were not yet corrected despite our efforts to secure responses.

 

Over 80% of the CONMED suppliers contacted provided a response. Non-responsive suppliers were contacted numerous times by both our third-party consultant and CONMED personnel. 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 expect and intend to 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 regard 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.

 

 E-2 

 

 

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 expect to seek to 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.

 

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 Responsible Minerals Initiative (“RMI”) pose a significant risk. Where a smelter is not identified as Conflict Free by such sources, we assess them according to red flag indicators defined in the OECD Guidance. This rating is based on various factors, including Responsible Minerals Assurance Process (RMAP) audit status, smelter’s geographic location and including proximity to the Covered Countries and credible evidence of unethical or conflict sourcing.

 

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:

 

·Have you established a conflict minerals sourcing policy?
·Have you implemented due diligence measures for conflict-free sourcing?
·Do you review due diligence information received from your suppliers against your company’s expectations?
·Does your review process include corrective action management?

 

 E-3 

 

 

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 RMI’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 joint industry effort, we made reasonable determinations 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 RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable. 

 

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 RMI. 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 (“RMI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our third-party consultant confirmed that the name was listed by RMI as a “Conflict-Free” smelter. As of May 15, 2018, we have validated 321 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 257 smelters that are deemed “Responsible Minerals Assurance Process (RMAP) Conformant” - this indicates these smelters and refiners are conformant with the RMAP assessment protocols. There are 11 more smelters or refiners that are deemed “RMAP Active” - Smelters and refiners on the Active list have committed to undergo a RMAP audit. The remaining 53 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 RMI.

 

 E-4 

 

 

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 2017, 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, 2017.

 

 E-5 

 

 

Attachment A

 

Metal Standard Smelter Name Smelter Facility Location

RMAP Status

 

Gold Abington Reldan Metals, LLC UNITED STATES Not RMAP Conformant or Active
Gold Advanced Chemical Company UNITED STATES Conformant
Gold African Gold Refinery UGANDA Not RMAP Conformant or Active
Gold Aida Chemical Industries Co., Ltd. JAPAN Conformant
Gold Al Etihad Gold LLC UNITED ARAB EMIRATES Conformant
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY Conformant
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN Conformant
Gold AngloGold Ashanti Córrego do Sítio Mineração BRAZIL Conformant
Gold Argor-Heraeus S.A. SWITZERLAND Conformant
Gold Asahi Pretec Corp. JAPAN Conformant
Gold Asahi Refining Canada Ltd. CANADA Conformant
Gold Asahi Refining USA Inc. UNITED STATES Conformant
Gold Asaka Riken Co., Ltd. JAPAN Conformant
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY Not RMAP Conformant or Active
Gold AU Traders and Refiners SOUTH AFRICA Conformant
Gold Aurubis AG GERMANY Conformant
Gold Bangalore Refinery INDIA Active
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES Conformant
Gold Boliden AB SWEDEN Conformant
Gold C. Hafner GmbH + Co. KG GERMANY Conformant
Gold Caridad MEXICO Not RMAP Conformant or Active
Gold CCR Refinery - Glencore Canada Corporation CANADA Conformant
Gold Cendres + Métaux S.A. SWITZERLAND Conformant
Gold Chimet S.p.A. ITALY Conformant
Gold Chugai Mining JAPAN Not RMAP Conformant or Active
Gold Daejin Indus Co., Ltd. KOREA, REPUBLIC OF Conformant
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA Not RMAP Conformant or Active
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY Not RMAP Conformant or Active

 

 E-6 

 

 

Gold DODUCO Contacts and Refining GmbH GERMANY Conformant
Gold Dowa JAPAN Conformant
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF Active
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF Conformant
Gold Eco-System Recycling Co., Ltd. JAPAN Conformant
Gold Elemetal Refining, LLC UNITED STATES Not RMAP Conformant or Active
Gold Emirates Gold DMCC UNITED ARAB EMIRATES Conformant
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE Not RMAP Conformant or Active
Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA Not RMAP Conformant or Active
Gold Geib Refining Corporation UNITED STATES Conformant
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA Conformant
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA Not RMAP Conformant or Active
Gold Guangdong Jinding Gold Limited CHINA Not RMAP Conformant or Active
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA Not RMAP Conformant or Active
Gold HeeSung KOREA, REPUBLIC OF Conformant
Gold Heimerle + Meule GmbH GERMANY Conformant
Gold Heraeus Metals Hong Kong Ltd. CHINA Conformant
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY Conformant
Gold Hunan Chenzhou Mining Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Hwasung CJ Co., Ltd. KOREA, REPUBLIC OF Not RMAP Conformant or Active
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA Conformant
Gold Ishifuku Metal Industry Co., Ltd. JAPAN Conformant
Gold Istanbul Gold Refinery TURKEY Conformant
Gold Italpreziosi ITALY Conformant
Gold Japan Mint JAPAN Conformant
Gold Jiangxi Copper Co., Ltd. CHINA Conformant
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION Conformant

 

 E-7 

 

 

Gold JSC Uralelectromed RUSSIAN FEDERATION Conformant
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN Conformant
Gold Kaloti Precious Metals UNITED ARAB EMIRATES Not RMAP Conformant or Active
Gold Kazakhmys Smelting LLC KAZAKHSTAN Not RMAP Conformant or Active
Gold Kazzinc KAZAKHSTAN Conformant
Gold Kennecott Utah Copper LLC UNITED STATES Conformant
Gold KGHM Polska Miedz Spolka Akcyjna POLAND Active
Gold Kojima Chemicals Co., Ltd. JAPAN Conformant
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF Conformant
Gold Kyrgyzaltyn JSC KYRGYZSTAN Conformant
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION Not RMAP Conformant or Active
Gold L'azurde Company For Jewelry SAUDI ARABIA Not RMAP Conformant or Active
Gold Lingbao Gold Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA Not RMAP Conformant or Active
Gold L'Orfebre S.A. ANDORRA Active
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF Conformant
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Marsam Metals BRAZIL Conformant
Gold Materion UNITED STATES Conformant
Gold Matsuda Sangyo Co., Ltd. JAPAN Conformant
Gold Metalor Technologies (Hong Kong) Ltd. CHINA Conformant
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE Conformant
Gold Metalor Technologies (Suzhou) Ltd. CHINA Conformant
Gold Metalor Technologies S.A. SWITZERLAND Conformant
Gold Metalor USA Refining Corporation UNITED STATES Conformant
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V. MEXICO Conformant
Gold Mitsubishi Materials Corporation JAPAN Conformant
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN Conformant
Gold MMTC-PAMP India Pvt., Ltd. INDIA Conformant
Gold Modeltech Sdn Bhd MALAYSIA Active

 

 E-8 

 

 

Gold Morris and Watson NEW ZEALAND Not RMAP Conformant or Active
Gold Morris and Watson Gold Coast AUSTRALIA Not RMAP Conformant or Active
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION Conformant
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. TURKEY Conformant
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN Not RMAP Conformant or Active
Gold NH Recytech Company KOREA, REPUBLIC OF Active
Gold Nihon Material Co., Ltd. JAPAN Conformant
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA Conformant
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN Conformant
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION Conformant
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION Conformant
Gold PAMP S.A. SWITZERLAND Conformant
Gold Pease & Curren UNITED STATES Not RMAP Conformant or Active
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Planta Recuperadora de Metales SpA CHILE Conformant
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION Conformant
Gold PT Aneka Tambang (Persero) Tbk INDONESIA Conformant
Gold PX Précinox S.A. SWITZERLAND Conformant
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA Conformant
Gold Refinery of Seemine Gold Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Remondis Argentia B.V. NETHERLANDS Active
Gold Republic Metals Corporation UNITED STATES Conformant
Gold Royal Canadian Mint CANADA Conformant
Gold SAAMP FRANCE Conformant
Gold Sabin Metal Corp. UNITED STATES Not RMAP Conformant or Active
Gold Safimet S.p.A ITALY Conformant
Gold SAFINA A.S. CZECH REPUBLIC Active
Gold Sai Refinery INDIA Not RMAP Conformant or Active
Gold Samduck Precious Metals KOREA, REPUBLIC OF Conformant

 

 E-9 

 

 

Gold SAMWON Metals Corp. KOREA, REPUBLIC OF Not RMAP Conformant or Active
Gold SAXONIA Edelmetalle GmbH GERMANY Conformant
Gold Schone Edelmetaal B.V. NETHERLANDS Conformant
Gold SEMPSA Joyería Platería S.A. SPAIN Conformant
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA Conformant
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA Conformant
Gold Singway Technology Co., Ltd. TAIWAN Conformant
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION Conformant
Gold Solar Applied Materials Technology Corp. TAIWAN Conformant
Gold State Research Institute Center for Physical Sciences and Technology LITHUANIA Not RMAP Conformant or Active
Gold Sudan Gold Refinery SUDAN Not RMAP Conformant or Active
Gold Sumitomo Metal Mining Co., Ltd. JAPAN Conformant
Gold SungEel HiTech KOREA, REPUBLIC OF Conformant
Gold T.C.A S.p.A ITALY Conformant
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN Conformant
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA Conformant
Gold Tokuriki Honten Co., Ltd. JAPAN Conformant
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Tony Goetz NV BELGIUM Not RMAP Conformant or Active
Gold TOO Tau-Ken-Altyn KAZAKHSTAN Not RMAP Conformant or Active
Gold Torecom KOREA, REPUBLIC OF Conformant
Gold Umicore Brasil Ltda. BRAZIL Conformant
Gold Umicore Precious Metals Thailand THAILAND Conformant
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM Conformant
Gold United Precious Metal Refining, Inc. UNITED STATES Conformant
Gold Universal Precious Metals Refining Zambia ZAMBIA Not RMAP Conformant or Active
Gold Valcambi S.A. SWITZERLAND Conformant
Gold Western Australian Mint trading as The Perth Mint AUSTRALIA Conformant

 

 E-10 

 

 

Gold WIELAND Edelmetalle GmbH GERMANY Conformant
Gold Yamamoto Precious Metal Co., Ltd. JAPAN Conformant
Gold Yokohama Metal Co., Ltd. JAPAN Conformant
Gold Yunnan Copper Industry Co., Ltd. CHINA Not RMAP Conformant or Active
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA Conformant
Tantalum Asaka Riken Co., Ltd. JAPAN Conformant
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA Conformant
Tantalum D Block Metals, LLC UNITED STATES Conformant
Tantalum Duoluoshan CHINA Not RMAP Conformant or Active
Tantalum Exotech Inc. UNITED STATES Conformant
Tantalum F&X Electro-Materials Ltd. CHINA Conformant
Tantalum FIR Metals & Resource Ltd. CHINA Conformant
Tantalum Global Advanced Metals Aizu JAPAN Conformant
Tantalum Global Advanced Metals Boyertown UNITED STATES Conformant
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd. CHINA Conformant
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA Conformant
Tantalum H.C. Starck Co., Ltd. THAILAND Conformant
Tantalum H.C. Starck Hermsdorf GmbH GERMANY Conformant
Tantalum H.C. Starck Inc. UNITED STATES Conformant
Tantalum H.C. Starck Ltd. JAPAN Conformant
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY Conformant
Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY Conformant
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA Conformant
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA Conformant
Tantalum Jiangxi Tuohong New Raw Material CHINA Conformant
Tantalum Jiujiang Janny New Material Co., Ltd. CHINA Conformant
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA Conformant
Tantalum Jiujiang Tanbre Co., Ltd. CHINA Conformant
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA Conformant
Tantalum KEMET Blue Metals MEXICO Conformant
Tantalum KEMET Blue Powder UNITED STATES Conformant
Tantalum King-Tan Tantalum Industry Ltd. CHINA Conformant

 

 E-11 

 

 

Tantalum LSM Brasil S.A. BRAZIL Conformant
Tantalum Metallurgical Products India Pvt., Ltd. INDIA Conformant
Tantalum Mineracao Taboca S.A. BRAZIL Conformant
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN Conformant
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA Conformant
Tantalum NPM Silmet AS ESTONIA Conformant
Tantalum Power Resources Ltd. MACEDONIA Conformant
Tantalum QuantumClean UNITED STATES Conformant
Tantalum Resind Industria e Comercio Ltda. BRAZIL Conformant
Tantalum RFH Tantalum Smeltry Co., Ltd. CHINA Conformant
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION Conformant
Tantalum Taki Chemicals JAPAN Conformant
Tantalum Telex Metals UNITED STATES Conformant
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN Conformant
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA Conformant
Tantalum Yichun Jin Yang Rare Metal Co., Ltd. CHINA Conformant
Tin Alpha UNITED STATES Conformant
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM Not RMAP Conformant or Active
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA Conformant
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA Active
Tin China Tin Group Co., Ltd. CHINA Conformant
Tin CNMC (Guangxi) PGMA Co., Ltd. CHINA Not RMAP Conformant or Active
Tin CV Ayi Jaya INDONESIA Conformant
Tin CV Dua Sekawan INDONESIA Conformant
Tin CV Gita Pesona INDONESIA Conformant
Tin CV Tiga Sekawan INDONESIA Conformant
Tin CV United Smelting INDONESIA Conformant
Tin CV Venus Inti Perkasa INDONESIA Conformant
Tin Dowa JAPAN Conformant
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM Not RMAP Conformant or Active
Tin EM Vinto BOLIVIA Conformant
Tin Estanho de Rondônia S.A. BRAZIL Not RMAP Conformant or Active

 

 E-12 

 

 

Tin Fenix Metals POLAND Conformant
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA Conformant
Tin Gejiu Jinye Mineral Company CHINA Conformant
Tin Gejiu Kai Meng Industry and Trade LLC CHINA Conformant
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA Conformant
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA Conformant
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA Not RMAP Conformant or Active
Tin Guangdong Hanhe Non-ferrous Metal Limited Company CHINA Conformant
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA Conformant
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA Conformant
Tin Huichang Jinshunda Tin Co., Ltd. CHINA Conformant
Tin Jiangxi Ketai Advanced Material Co., Ltd. CHINA Conformant
Tin Jiangxi New Nanshan Technology Ltd. CHINA Conformant
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL Conformant
Tin Malaysia Smelting Corporation (MSC) MALAYSIA Conformant
Tin Melt Metais e Ligas S.A. BRAZIL Conformant
Tin Metallic Resources, Inc. UNITED STATES Conformant
Tin Metallo Belgium N.V. BELGIUM Conformant
Tin Metallo Spain S.L.U. SPAIN Conformant
Tin Mineracao Taboca S.A. BRAZIL Conformant
Tin Minsur PERU Conformant
Tin Mitsubishi Materials Corporation JAPAN Conformant
Tin Modeltech Sdn Bhd MALAYSIA Active
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM Not RMAP Conformant or Active
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND Conformant
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES Conformant
Tin Operaciones Metalurgical S.A. BOLIVIA Conformant
Tin Pongpipat Company Limited MYANMAR Not RMAP Conformant or Active
Tin PT Aries Kencana Sejahtera INDONESIA Conformant
Tin PT Artha Cipta Langgeng INDONESIA Conformant
Tin PT ATD Makmur Mandiri Jaya INDONESIA Conformant
Tin PT Babel Inti Perkasa INDONESIA Conformant

 

 E-13 

 

 

Tin PT Bangka Prima Tin INDONESIA Conformant
Tin PT Bangka Serumpun INDONESIA Conformant
Tin PT Bangka Tin Industry INDONESIA Conformant
Tin PT Belitung Industri Sejahtera INDONESIA Conformant
Tin PT Bukit Timah INDONESIA Conformant
Tin PT DS Jaya Abadi INDONESIA Conformant
Tin PT Eunindo Usaha Mandiri INDONESIA Conformant
Tin PT Inti Stania Prima INDONESIA Conformant
Tin PT Karimun Mining INDONESIA Conformant
Tin PT Kijang Jaya Mandiri INDONESIA Conformant
Tin PT Lautan Harmonis Sejahtera INDONESIA Conformant
Tin PT Menara Cipta Mulia INDONESIA Conformant
Tin PT Mitra Stania Prima INDONESIA Conformant
Tin PT O.M. Indonesia INDONESIA Conformant
Tin PT Panca Mega Persada INDONESIA Conformant
Tin PT Premium Tin Indonesia INDONESIA Conformant
Tin PT Prima Timah Utama INDONESIA Conformant
Tin PT Refined Bangka Tin INDONESIA Conformant
Tin PT Sariwiguna Binasentosa INDONESIA Conformant
Tin PT Stanindo Inti Perkasa INDONESIA Conformant
Tin PT Sukses Inti Makmur INDONESIA Conformant
Tin PT Sumber Jaya Indah INDONESIA Conformant
Tin PT Timah (Persero) Tbk Kundur INDONESIA Conformant
Tin PT Timah (Persero) Tbk Mentok INDONESIA Conformant
Tin PT Tinindo Inter Nusa INDONESIA Conformant
Tin PT Tommy Utama INDONESIA Conformant
Tin Resind Industria e Comercio Ltda. BRAZIL Conformant
Tin Rui Da Hung TAIWAN Conformant
Tin Soft Metais Ltda. BRAZIL Conformant
Tin Super Ligas BRAZIL Not RMAP Conformant or Active
Tin Thaisarco THAILAND Conformant
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM Not RMAP Conformant or Active
Tin White Solder Metalurgia e Mineração Ltda. BRAZIL Conformant
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA Conformant

 

 E-14 

 

 

Tin Yunnan Tin Company Limited CHINA Conformant
Tungsten A.L.M.T. TUNGSTEN Corp. JAPAN Conformant
Tungsten ACL Metais Eireli BRAZIL Conformant
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM Conformant
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA Conformant
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA Conformant
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA Conformant
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA Active
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA Conformant
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA Conformant
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA Conformant
Tungsten Ganzhou Yatai Tungsten Co., Ltd. CHINA Not RMAP Conformant or Active
Tungsten Global Tungsten & Powders Corp. UNITED STATES Conformant
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA Conformant
Tungsten H.C. Starck Smelting GmbH & Co.KG GERMANY Conformant
Tungsten H.C. Starck Tungsten GmbH GERMANY Conformant
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA Conformant
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA Conformant
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA Conformant
Tungsten Hunan Litian Tungsten Industry Co., Ltd. CHINA Conformant
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION Conformant
Tungsten Japan New Metals Co., Ltd. JAPAN Conformant
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA Conformant
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd. CHINA Not RMAP Conformant or Active
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA Conformant
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA Not RMAP Conformant or Active
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA Conformant
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA Conformant
Tungsten Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. CHINA Conformant
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA Conformant
Tungsten Kennametal Fallon UNITED STATES Conformant

 

 E-15 

 

 

Tungsten Kennametal Huntsville UNITED STATES Conformant
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA Conformant
Tungsten Moliren Ltd RUSSIAN FEDERATION Conformant
Tungsten Niagara Refining LLC UNITED STATES Conformant
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC VIET NAM Conformant
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES Conformant
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City CHINA Conformant
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM Conformant
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION Conformant
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd. VIET NAM Conformant
Tungsten Wolfram Bergbau und Hütten AG AUSTRIA Conformant
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF Conformant
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA Conformant
Tungsten Xiamen Tungsten Co., Ltd. CHINA Conformant
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA Conformant
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA Conformant

 

 E-16 

 

 

Appendix B:

 

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

 

Andorra, Australia, Austria, Bolivia (Plurinational State of), Belgium, Brazil, Canada, Chile, China, Czech Republic, Estonia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Republic of, Kyrgyzstan, Lithuania, Macedonia, Malaysia, Mexico, Myanmar, Netherlands, New Zealand, Peru, Philippines, Poland, Russian Federation, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United States of America, Uzbekistan, Viet Nam, Zambia, Zimbabwe
 

 E-17