ISRAEL
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000-24790
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N/A
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(State or other jurisdiction
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(Commission
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(IRS Employer
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of incorporation or organization)
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File Number)
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Identification No.)
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Ramat Gavriel Industrial Park, P.O. Box 619,
Migdal Haemek, Israel
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2310502
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(Address of principal executive offices)
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(Zip Code)
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☒
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
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Introduction
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Item 1.01 Conflict Minerals Disclosure and Report
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SECTION 2 – EXHIBITS
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Item 2.01 Exhibits
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Tower Semiconductor Ltd.
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(Registrant)
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By:
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/s/ Nati Somekh
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June 1, 2021
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Nati Somekh
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Senior Vice President, Chief Legal Officer and Corporate Secretary
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(i) |
Establish Strong Company Management Systems
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(i) |
a Company code of ethics requiring all employees, officers and directors to comply with all of the laws, rules and regulations of the U.S., Israel and other countries, as applicable (available at: https://towersemi.com/about/corporate-social-responsibility-esg/social/;
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(ii) |
partnership since 2014 in the Responsible Business Alliance (RBA), which provides assessment tools including a self-assessment questionnaire which is designed to help members identify social, environmental and ethical risks in their
supply chains and take action to put in place systems to further improve their social contribution,
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(iii) |
a code of ethics for suppliers requiring suppliers to conduct their business in an ethical manner and act with integrity, including by ensuring that products supplied to Tower do not contain metals derived from minerals or their
derivatives originating from conflict regions that directly or indirectly finance or benefit armed groups,
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(iv) |
a conflict minerals policy as described below, and
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(v) |
a team of Company employees, consisting of senior operations, engineering, QA, regulatory compliance and legal personnel, that oversees implementation of the Company's conflict minerals compliance strategy. In addition, senior management
of the Company, including the Senior Vice President Excellence and Quality and Reliability, VP of Procurement and the Senior Vice President, Chief Legal Officer and Corporate Secretary, are briefed on a regular basis by the Company’s
Corporate Compliance Officer about conflict minerals compliance efforts.
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Avoids the use of conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries;
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Expects its suppliers to have in place policies and due diligence procedures that will ensure that products and components that they supply containing conflict minerals, including conflict minerals from Covered Countries, are in fact
"conflict-free", meaning that they do not directly or indirectly finance or benefit armed groups in Covered Countries;
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Requires the Company's direct suppliers to provide it with annual declarations regarding their use of conflict minerals (utilizing a format described below);
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Reserves the right to take appropriate action to enforce its conflict minerals policy, including discontinuing purchases from suppliers that fail to comply; and
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Is committed to responsible sourcing of conflict minerals throughout its supply chain and to continued compliance with applicable SEC rules and regulations in this area.
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(ii) |
Identify and Assess Risk in the Supply Chain
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(iii)
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Design and Implement a Strategy to Respond to Identified Risks
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engaging with suppliers to obtain current, accurate and complete information about the suppliers’ supply chains; and
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encouraging suppliers to implement responsible sourcing and work with smelters and refiners which have obtained a “conflict-free” designation from a third-party auditor such as under RMAP.
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(iv)
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Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices
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The Template provided to our suppliers requests information on the smelters and refiners used to provide the tungsten and tantalum in our products. We do not typically have a direct
relationship with smelters and refiners of such minerals and are unable to perform or direct audits of these entities within our supply chain. Instead, we compare information regarding refiners and smelters provided by our suppliers in
their Template with lists of refiners and smelters designated by RMI as compliant with RMAP standards
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(v)
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Report Annually on Supply Chain Due Diligence
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Tantalum
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Asaka Riken Co., Ltd.
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Japan
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Changsha South Tantalum Niobium Co., Ltd.
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China
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D Block Metals, LLC
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United States of America
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Exotech Inc.
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United States of America
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F&X Electro-Materials Ltd.
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China
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FIR Metals & Resource Ltd.
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China
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Global Advanced Metals Aizu
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Japan
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Global Advanced Metals Boyertown
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United States of America
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Guangdong Zhiyuan New Material Co., Ltd.
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China
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H.C. Starck Co., Ltd.
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Thailand
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H.C. Starck Hermsdorf GmbH
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Germany
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H.C. Starck Inc.
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United States of America
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H.C. Starck Ltd.
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Japan
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H.C. Starck Smelting GmbH & Co. KG
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Germany
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H.C. Starck Tantalum and Niobium GmbH
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Germany
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Hengyang King Xing Lifeng New Materials Co., Ltd.
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China
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Jiangxi Tuohong New Raw Material
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China
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JiuJiang JinXin Nonferrous Metals Co., Ltd.
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China
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Jiujiang Tanbre Co., Ltd.
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China
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Metallurgical Products India Pvt., Ltd.
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India
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Ningxia Orient Tantalum Industry Co., Ltd.
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China
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Ulba Metallurgical Plant JSC
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Kazakhstan
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Yanling Jincheng Tantalum & Niobium Co., Ltd.
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China
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Tungsten
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Chenzhou Diamond Tungsten Products Co., Ltd.
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China
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Chongyi Zhangyuan Tungsten Co., Ltd.
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China
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Ganzhou Seadragon W & Mo Co., Ltd.
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China
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Global Tungsten & Powders Corp.
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United States of America
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Japan New Metals Co., Ltd.
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Japan
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Jiangwu H.C. Starck Tungsten Products Co., Ltd.
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China
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Xiamen Tungsten (H.C.) Co., Ltd.
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China
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Xiamen Tungsten Co., Ltd.
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China
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