EX-1.01 2 exhibit_1-01.htm EXHIBIT 1.01

 
Exhibit 1.01
 
Conflict Minerals Report

This is the Conflict Minerals Report for Magal Security Systems Ltd. (“Magal”, “we” or “our”), filed with the SEC pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2018 to December 31, 2018. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on Securities and Exchange Commission (theSEC”) registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG") for the purposes of this assessment.
 
If a registrant cannot establish with complete certainty that the Conflict Minerals that are necessary to the manufacture or functionality of its products originated from sources other than the Democratic Republic of the Congo ("DRC") or an adjoining countries (together referred to as the "Covered Countries), or originate from wholly recycled or scrap sources, the registrant must submit a specialized disclosure report under the Form SD that describes the steps that the registrant took to determine the origin of the Conflict Minerals in its products.

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

As permitted by the Rule and the SEC, this report has not been subject to an independent private sector audit.
 
1.
Company Overview

Magal, incorporated under the laws of the State of Israel on March 27, 1984, develops, manufactures, markets and sells comprehensive computerized physical and cyber security products and systems to high profile customers.  Our systems are used in more than 80 countries to protect sensitive facilities, including national borders, military bases, power plants, airports, seaports, prisons, industrial sites, oil and gas facilities, Olympic villages and stadiums and municipalities from intrusion, crime, sabotage or vandalism to infrastructure, assets and personnel.

Our goal in designing and implementing our Conflict Minerals risk management strategy is not to eliminate sourcing from the DRC and Covered Countries, but to encourage participation with the Responsible Minerals Initiative ("RMI") and other relevant independent third party auditing bodies, where possible.
 
2.
Supply Chain and Products Overview

 
Our products are categorized into different technologies, consisting of physical and cyber security solutions:

-
Perimeter Intrusion Detection Systems (PIDS);
 
-
Video Management Systems (VMS);
 
-
CCTV systems, including a perimeter security Robot;
 
-
Cyber security systems;
 
-
Command and control systems; and
 
-
Miscellaneous systems tailored for specific vertical market needs.
 


Our products often require the use of tin, tantalum and gold, which fall under the definition of Conflict Minerals:

·
Gold – after being melted and applied to a component part in a thin coating, forms part of Magal’s sensors.

·
Tin – used in electronic circuit cards while soldering components into the cards.

·
Gold plating – contact pins as part of connectors that Magal purchases as strictly off-the-shelf product and are soldered or attached to wire harnesses or electronic circuit cards.
 
·
Tantalum - forms part of capacitors that Magal purchases as strictly off-the-shelf product and is soldered or attached to the electronic cards.
 
Our supply chain is complex. There are multiple tiers between our company and the sources of the Conflict Minerals.  Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components that are included in our products.
 
3.
Reasonable Country of Origin Inquiry

In order to conduct a Reasonable Country of Origin Inquiry on the source or origin of conflict minerals that are necessary to the functionality or production of our products, we developed a risk-based approach that focuses on all suppliers involved in the manufacture of the relevant abovementioned products that contain or use the necessary conflict minerals. We identified 55 relevant suppliers that we concluded provide us with products and components that do or may contain 3TG that are necessary to functionality or production of our products and which accounted for 90% of all applicable materials purchased by Magal in 2018.

Utilizing the Responsible Minerals Initiative's ("RMI"), formerly the Conflict Free Sourcing Initiative ("CFSI"), standard Conflict Minerals Reporting Template (“CMRT”) of at a minimum version 5.01 or higher, and the services of a third-party data management provider (“Service Provider”), we surveyed the relevant suppliers. Additionally, we sent letters to our relevant suppliers, informing them of the Rule and the Company's Conflict Minerals Policy. We reviewed the responses and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. We received responses from 87% of the suppliers we approached.

The majority of suppliers from which we requested information indicated in their response that the information provided was at a company level (69%). Thus, the majority of the manufacturers were unable to accurately report which specific smelters or refiners (“SORs”) were part of the supply chain applicable to the components that were sold to us in 2018.

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

In accordance with the Rule, Magal undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its products during 2018. There is significant overlap between our RCOI efforts and the due diligence measures performed.
 

4.
Design of Our Due Diligence

Based on the findings of our RCOI, we designed our due-diligence process in reference to the Organization 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 its related Supplements for 3TG.
 
Magal has processes in place for the purpose of exercising due diligence on its supply chain. The design of the due diligences processes conforms with the OECD Guidance as it relates to “downstream” purchasers of products and components. The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
 
5.
Due Diligence Performance
 
Step 1 - Establish strong company management systems:

-
Our Conflict Minerals Policy is publicly available on our website at https://magalsecurity.com/about-magal/corporate-governance, and describes our commitment towards responsible sourcing.
 
-
We structured a team of individuals from various functions (Operations, Legal and Finance) within the organization to support the process of supply chain due diligence. The team meets to assess identified risks and determine follow up actions.
 
-
Magal maintains a system of controls and transparency over the mineral supply chain through use of the RMI's CMRT reporting template of, at a minimum, version 5.01 or higher. Due to the large size of our supply chain, we have also contracted a Service Provider to enhance the supplier data collection process and to help minimize sourcing risks.
 
-
We maintain records relating to our Conflict Minerals program for 5 years.
 
-
We provide training to assist our suppliers to meet our requirements.
 
-
We enable employees, suppliers and other stakeholders to report any concerns relating to our Conflict Minerals program through our grievance mechanism. Contact details for concerns or questions are provided in our Conflict Mineral Policy that is publically available at our website under the heading “Corporate Governance” and at the following link: https://magalsecurity.com/about-magal/corporate-governance.
 
Step 2 - Identify and assess risk in the supply chain:
 
-
We mapped and evaluated our family of products. Magal mapped the relevant agents and suppliers, as well as the manufacturers that sell to these agents and suppliers in order to identify relevant suppliers for the supply chain inquiry.
 
-
We surveyed our suppliers using, at a minimum, version 5.01 of the CMRT (as detailed above in "Reasonable Country of Origin" section). We compared the SORs identified by our suppliers against the lists of facilities that have received a conformant or active designation by the RMI's Responsible Minerals Assurance Process (RMAP) smelter and refiner validation program or other independent third party audit programs. We contacted suppliers that did not respond or provided inadequate responses.
 
-
Due to our size, the breadth and complexity of our products and the constant evolution of our supply chain, it is difficult to identify SORs in our supply chain. We do not purchase Conflict Minerals directly from mines or the SORs, and there are many tiers in the supply chain between us and the original source of the Conflict Minerals.  As a result, we rely on our direct suppliers and manufacturers to provide information regarding the origin of any Conflict Minerals. This challenge brings us to engage a  Service Provider to assist in certain aspects of the process.
 
Step 3 - Design and implementation of a strategy to respond to identified risks:

-
We reviewed the survey responses, assessed the risks identified and implemented a strategy to respond to those risks.
 
o
We followed up on inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information.
 
o
Relevant senior management was briefed about our due diligence efforts, risk analysis results and mitigation efforts.
 
o
Our team, led by our CFO, assessed identified risks and determined follow up actions, as needed.
 
o
Suppliers that source from uncertified SORs from the Covered Countries were contacted and were asked to submit more information about their sourcing practices, including a corrective action plan.

-
Supply chain due diligence is a dynamic process and requires on-going risk monitoring. To ensure the effectiveness of risk management, after implementation of our strategy, we review the identified risks on a regular basis.


Step 4 - Carry Out Independent Third Party Audit of SORs’ Due Diligence Practices:
 
Magal does not have a direct relationship with 3TG SORs. As such, we do not perform direct audits of SORs in our supply chain, but rather rely on due diligence performed by organizations such as the RMI and compare SOR data received with the RMI's Standard Smelter List of SORs compliant with the RMAP program.
 
Step 5 - Report Annually on Supply Chain Due Diligence:

We currently, subject to SEC guidelines, report annually on our supply chain due diligence through Form SD. Our reports on Form SD are publicly available at https://magalsecurity.com/about-magal/corporate-governance.
 
6.
Results for the 2018 Calendar Year

The following factors materially affect the results of our assessment:

 
 
We are dependent on information received from our direct suppliers to conduct our good faith RCOI process;

 
 
 
We do not have a direct relationship with 3TG SORs, nor do we perform direct audits of the other entities in our supply chain;
 
We have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to the Rule;
 
 
 
The information our suppliers provide us with is sometimes incomplete and requires significant follow-up;
 
 
 
Most suppliers provided responses at a company or divisional level, and not at a product level specific to the materials and components we use in the subject products;
 
 
 
Certain suppliers were unable or unwilling to specify the SORs used for materials and components supplied to us;
 
 
 
 
Our ability to influence cooperation from certain suppliers was limited as we were multiple tiers away from the SORs in the supply chain; and
 
The information gathered from our suppliers is not obtained on a continuous, real-time basis.

We conducted a supply-chain survey of 55 of our direct suppliers that we identified may contribute necessary Conflict Minerals to our products. The overall response rate to this survey was 87%.

Response analysis:

Out of the total responses received, 48 responses were defined as complete responses and 7 responses were incomplete or inconsistent.


Declaration scope:
 
Based on the responses that we received, most of our suppliers delivered declaration in company level as shown below:

Company level
69%
User-defined
15%
Products list
16%
 
As such, Magal was unable to identify with complete certainty the country of origin of the Conflict Minerals used in the Company’s products in 2018.
 
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the Conflict Minerals in our products include the SORs listed in Exhibit A below. Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in our products or whether the Conflict Minerals in our products are from entirely recycled or scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.
 
7.
Conclusion

Due to the breadth and scope of our product categories, the resulting complexity of our supply chain, and the human and financial resources available to us, we acknowledge that the process of successfully tracing all of the Conflict Minerals used in our manufactured or contracted to manufacture products to their country of origin will take additional time and resources. Moving forward, subject to the legal requirements and any changes to the Rule, we will continue to implement commercially reasonable processes to improve the quantity and quality of supplier responses.
 
The failure to obtain reliable information from any level of our supply chain could have a material impact on our future ability to report on the presence of Conflict Minerals with any degree of certainty. There can be no assurance that our suppliers will continue to cooperate with diligence inquiries and requests for certifications or provide documentation or other evidence that we consider reliable or provided to us within a time frame sufficient to allow us to make our own assessment following appropriate further diligence measures, if any. The information provided in this Conflict Mineral Report speaks only as of its date. Subsequent events, including future guidelines by the SEC, and the inability or unwillingness of participants in our supply chain to provide complete and accurate information requested, may affect our future determinations under the Rule.
 
Cautionary Statement about Forward-Looking Statements
 
Statements in this Conflict Minerals Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our Conflict Minerals program and our ability to identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the SEC, including our Annual Report on Form 20-F for the year ended December 31, 2018. We caution that undue reliance should not be placed on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
 

Exhibit A
 
List of identified certified SORs
 
Metal
Smelter or Refiner (SOR) Name
Smelter or Refiner (SOR) Country
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Kazzinc
KAZAKHSTAN
Gold
Boliden AB
SWEDEN
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
T.C.A S.p.A
ITALY
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
Japan Mint
JAPAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
Aurubis AG
GERMANY
Gold
Chimet S.p.A.
ITALY
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Chugai Mining
JAPAN
 

Gold
Bauer Walser AG
GERMANY
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Dowa
JAPAN
Gold
L'Orfebre S.A.
ANDORRA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Asahi Pretec Corp.
JAPAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
Materion
UNITED STATES OF AMERICA
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Gold
8853 S.p.A.
ITALY
Gold
Royal Canadian Mint
CANADA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Metalor Technologies S.A.
SWITZERLAND
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Bangalore Refinery
INDIA
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
 

Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Istanbul Gold Refinery
TURKEY
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
SAAMP
FRANCE
Gold
Italpreziosi
ITALY
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Marsam Metals
BRAZIL
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Safimet S.p.A
ITALY
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Yamakin Co., Ltd.
JAPAN
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
Valcambi S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
 

Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Thaisarco
THAILAND
Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Melt Metais e Ligas S.A.
BRAZIL
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
PT Babel Surya Alam Lestari
INDONESIA
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Tin Company Limited
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
 

Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
PT Babel Inti Perkasa
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
Minsur
PERU
Tin
Fenix Metals
POLAND
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
CV Gita Pesona
INDONESIA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
PT Bangka Prima Tin
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Metallo Belgium N.V.
BELGIUM
Tin
PT REFINED BANGKA TIN
INDONESIA
Tin
Dowa
JAPAN
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
CV Dua Sekawan
INDONESIA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
CV Tiga Sekawan
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
China Tin Group Co., Ltd.
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
PT Artha Cipta Langgeng
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
 

Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
PT Bangka Serumpun
INDONESIA
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA

 

 
Exhibit B
 
Countries of origin of the Conflict Minerals
 
Based on Magal's due diligence, the above SOR may process conflict minerals from one or more of the following countries of origin:
 
All 3TG metals
ANDORRA
AUSTRALIA
AUSTRIA
BELGIUM
BOLIVIA (PLURINATIONAL STATE OF)
BRAZIL
CANADA
CHILE
CHINA
CZECH REPUBLIC
ESTONIA
FRANCE
GERMANY
INDIA
INDONESIA
ITALY
JAPAN
KAZAKHSTAN
KOREA, REPUBLIC OF
KYRGYZSTAN
LITHUANIA
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
MALAYSIA
MEXICO
MYANMAR
NETHERLANDS
NEW ZEALAND
NORWAY
PERU
PHILIPPINES
POLAND
RUSSIAN FEDERATION
SAUDI ARABIA
SINGAPORE
SOUTH AFRICA
SPAIN
SUDAN
SWEDEN
SWITZERLAND
TAIWAN, PROVINCE OF CHINA
THAILAND
TURKEY
UGANDA
UNITED ARAB EMIRATES
UNITED STATES OF AMERICA
UZBEKISTAN
VIET NAM
ZAMBIA
ZIMBABWE