EX-1.01 2 novt-ex101_6.htm EX-1.01 novt-ex101_6.htm

 

Exhibit 1.01

NOVANTA INC.

Conflict Minerals Report

For the Period January 1 to December 31, 2015

 

Introduction

 

This report has been prepared by management of Novanta Inc. (“Novanta”, the “Company”, “we”, “our”) for the period of January 1, 2015 to December 31, 2015 (the “Reporting Period”) and is presented to comply with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934 (the “Act”), which was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”).

 

Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“the 3TGs”) for the purposes of this assessment. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain 3TGs which are necessary to the functionality or production of their products.

 

If a registrant can establish that the 3TGs originated from sources other than the Democratic Republic of the Congo (the “DRC”) or any of the adjoining countries (collectively, the “Covered Countries”), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry completed. If a registrant has reason to believe that any of the 3TGs in their supply chain may have originated from the Covered Countries, or if a registrant is unable to determine the country of origin of its 3TGs, the registrant must exercise due diligence on the source and chain of custody of the 3TGs.  The registrant must annually submit a Conflict Minerals Report (the “CMR”) to the SEC that includes a description of the Company’s due diligence measures.

 

Company Overview

 

Novanta is a leading global supplier of core technology solutions that give advanced industrial and healthcare OEMs a competitive advantage. We combine deep expertise at the intersection of photonics and motion with a proven ability to solve complex technical challenges. This enables Novanta to engineer core components and sub-systems that deliver extreme precision and performance, tailored to our customers’ demanding applications. We deliver highly engineered laser, vision and precision motion solutions to customers around the world. The driving force behind our growth is the team of innovative professionals who share a commitment to innovation and customer success.

 

The Company is organized into three reportable segments: Laser Products, Vision Technologies and Precision Motion. The Laser Products segment designs, manufactures and markets photonics-based solutions to customers worldwide. The segment serves highly demanding photonics-based applications such as industrial material processing, and medical and life science imaging and laser procedures. The Vision Technologies segment designs, manufactures and markets a range of medical grade technologies, including visualization solutions, imaging informatics products, optical data collection and machine vision technologies, frequency identification (“RFID”) technologies, thermal printers, and light and color measurement instrumentation, to customers worldwide. The Precision Motion segment designs, manufactures and markets optical encoders, precision motor and motion control technology, air bearing spindles and precision machined components to customers worldwide.

 

The Company conducted an analysis of its products and found that 3TGs are present in many of the electronic parts and components included in the Company’s products. Therefore, the Company is subject to the reporting obligations of Rule 13p-1.

 

The Company’s supply chain is complex.  The Company uses a wide variety of raw materials, key components and parts that are purchased from both domestic and international suppliers.  The Company also uses contract manufacturers to make certain key components used in the production of the Company’s finished products. As the Company’s manufacturing process consists mostly of final

 


 

assembly of components and parts that are purchased from suppliers, there are typically several tiers of companies between Novanta and the mines, smelters or refiners of conflict minerals.  The Company does not directly source 3TG minerals as raw materials.  Therefore, it is difficult to identify the origin of conflict minerals that are present in the Company’s products.

 

Due to the size and complexity of the Company’s supply chain, it will take time for many of our suppliers to verify the source and origin of conflict minerals in their manufacturing process.  Novanta has to rely on its suppliers to provide information on the origin of the conflict minerals contained in the components and materials supplied to Novanta, including sources of conflict minerals present in the materials and components supplied to Novanta’s suppliers themselves.

 

Reasonable Country of Origin Inquiry (RCOI)

 

The Company began the scoping process by compiling a list of all suppliers that provide us with products that may contain any 3TGs. Once this list was populated, we provided this list, as well as applicable contacts for those suppliers, to our third-party service provider. This list was then uploaded to our service provider’s software platform that allows us to store and manage supplier requests, documentation, and data.

 

Our scoping process was then defined further by removing service providers, indirect materials suppliers, and suppliers who are now inactive. This ensures that all suppliers surveyed actually provided items to Novanta that were used in final products in 2015. Using this process, we were able to remove approximately 7% of suppliers from scope for the 2015 reporting period.

 

Our service provider then conducted the supplier survey portion of the RCOI on our behalf. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 4.01b, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, the suppliers identified through the procedures above were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide materials to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.

 

During the supplier survey process, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform of the service provider. Non-responsive suppliers were contacted a minimum of three times and then were also contacted by our service provider’s Supply Chain Team in one on one communications. This included at least two follow-ups in order to encourage their response via CMRTs. Members of Novanta supply chain teams contacted the remaining non-responding suppliers via email and telephone follow-ups. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party consultant have offered training to suppliers through webinars, videos, documentation, and one-on-one discussions.

 

The RCOI also included 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. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 4, 2016, approximately 5% of our surveyed suppliers had yet to correct their invalid submissions.

 

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.

 

Design of Due Diligence

 

The Company’s due diligence process and efforts have been developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for

 


 

Responsible Supply Chain of Minerals from Conflict-Affected and High-risk Area (second edition) and the related supplements for gold and for tin, tantalum and tungsten (collectively referred to as the “OECD Guidance”).  The Company designed its due diligence process and measures to conform in all material respects with the OECD framework.

 

Due Diligence Performed

 

1.

Maintain Strong Company Management System

 

1.1.

Internal Team

 

The Company’s conflict minerals compliance program is sponsored by the Chief Operating Officer and is executed by a global task force that comprises of the Global Sourcing Leader, the Corporate Controller and Chief Accounting Officer, and a project leader for each of the product lines.  The product line project leader is typically the director of operations or manager of the procurement function and is supported by procurement and engineering professionals knowledgeable about the products and materials contained in those products.

 

The Company developed Conflict Minerals Process procedures that are required to be followed to perform the RCOI by all businesses globally. Supply chain leaders are responsible for ensuring compliance with Conflict Minerals Process procedures at the local business level and for reporting status and results of RCOI at periodic task force meetings.

 

1.2.

Control Systems

 

The Company developed a global Conflict Minerals policy and Supplier Code of Conduct that are communicated widely both internally and externally and are posted on the Company’s external website. The Company clearly states its commitment to compliance with laws and regulations surrounding conflict minerals and to taking steps to ensure that none of the 3TGs used in its products directly or indirectly finances or benefits armed groups in the Covered Countries.  

 

The Company requires all of its suppliers to use materials that have been sourced in a legally responsible manner and to confirm that they have not, and will not, procure conflict minerals from mines that are not DRC conflict free. These expectations are stated in our Conflict Minerals Policy and Supplier Code of Conduct, which can be accessed at this direct link: http://gsig.investorroom.com/code-of-ethics

 

1.3.

Supplier Engagement

 

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4 and a third-party service provider’s software reporting tool for collecting conflict minerals declarations from our suppliers.

 

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process, our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TGs identified in our products.

 

1.4.

Grievance Mechanism

 

The Company maintains an Ethics Hotline, a 24x7 confidential messaging system and an anonymous electronic mailbox managed by a third-party service provider, which provides means for employees, customers and suppliers to report deviations from the Company’s Code of Ethics and Business Conduct.

 

1.5.

Document Retention

 

As part of the Conflict Minerals Process procedures, the Company established documentation and record maintenance mechanism to ensure that relevant documentation is retained in a structured electronic database.

 

2.

Identify and Assess Risks in the Supply Chain

 


 

 

We have relied on supplier responses for information about the source of conflict minerals contained in the parts and components that they supply to us. Similarly, our direct suppliers also relied on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.

 

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified as DRC-Conflict Free pose a significant risk to the supply chain. We have classified risks as High, Medium and Low. This risk rating is generated based on three scoring criteria:

 

 

·

Regulated Body:

 

o

This assesses whether the smelter is a member of a regulated body and has an associated regulated body number (Smelter CID Number is the primary method).

 

·

Geographic Proximity:

 

o

Level 1 Country: Countries with known active ore production for tin or tantalum that are not identified as conflict regions or plausible countries of smuggling or export of tin or tantalum containing materials. These include smelter countries that are located in North or South America, Australia or Europe.

 

o

Level 2 Country: Known or plausible countries for smuggling, export out of Level 3 countries, or transit of materials containing tin or tantalum. This currently includes Kenya, Mozambique, and South Africa.

 

o

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

 

·

Certification:

 

o

If the smelter is certified conflict-free via the CFSI or the London Bullion Market Association (LBMA) Responsible Gold Programme.

 

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers in their CMRT. The criteria used to evaluate the strength of the program are:

 

A. Do you have a policy in place that includes DRC conflict-free sourcing?

E. Have you implemented due diligence measures for conflict-free sourcing?

H. Do you verify due diligence information received from your suppliers?

I. Does your verification process include corrective action management?

 

When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

 

3.

Design and Implement a Strategy to Respond to Identified Risks

 

We have developed a risk management plan to ensure that all identified risks are responded to. This includes communicating any identified risks to upper management, escalating suppliers who do not meet our expectations, and increased supplier education.

 

If the Company discovers through its RCOI efforts that any conflict minerals directly or indirectly benefit the armed groups in the Covered Countries, the Company will take steps to work with its suppliers to stop using such conflict minerals and, if not possible, stop purchasing such raw materials or components from the supplier in question.

 

4.

Carry Out Independent Third-Party Audit

 

We do not have any direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.

 


 

 

5.

Report Annually on Supply Chain Due Diligence

 

This Report, which constitutes our annual report on our due diligence efforts, is available on our website at http://gsig.investorroom.com/code-of-ethics and is filed with the SEC.

 

Results of Due Diligence

 

As of May 4, 2016, the Company had surveyed 952 suppliers that are considered in scope and received responses from approximately 74% of such suppliers. The suppliers that provided us with a CMRT were also asked to submit smelters or refiners (“SOR”) information.

 

Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and are unable to represent that 3TGs from the processing facilities they listed had actually been used in the components that they supplied to us.  The quality of the responses that we received from our surveyed suppliers continue to be varied. Many of the responses included the names and locations of 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 service provider followed up on these invalid responses, urging the suppliers to resubmit the CMRT and include smelter or refiner information. There are still suppliers that are unable to provide smelters and refiner information.

 

For all responses that indicated a smelter or a refiner, our third party service provider 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 service provider confirmed that the name was listed by CFSI as a certified smelter.

 

Appendix A lists the smelters and refiners that our suppliers have reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix B also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and CFSI.

 

Additional Steps to Be Taken to Mitigate Risks

 

The Company will continue to work with those suppliers who have not responded, responded with invalid smelters and refiners information, or responded as “DRC Conflict Undeterminable” to identify the source of such minerals using available tools, such as the CMRT and the related Smelter Reference list that is publicly available.  Should a supplier conclude, and report to us, that they have conflict minerals sourced from the Covered Countries and benefited armed groups, the Company will require such suppliers to implement measures to become DRC conflict free and find alternative suppliers to the extent alternative DRC conflict free sources of supply are available.

 

Safe Harbor and Forward-Looking Statements

 

Certain statements in this Conflict Minerals Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 and are based on current expectations and assumptions that are subject to risks and uncertainties. All statements contained in this Conflict Minerals Report that do not relate to matters of historical fact should be considered forward-looking statements, and are generally identified by words such as “will,”“expects,” “intends,” “plans,” “believes,” “anticipates,” and other similar expressions.  These forward-looking statements include, but are not limited to, statements regarding expectation or intention relating to our compliance efforts and expected actions.  These statements are neither promises nor guarantees, but involve risks and uncertainties that may cause future expectations or actions to be different. Undue reliance should not be placed on these statements, which are only effective as of the date of this report. The Company disclaims any obligation to update any forward-looking statements as a result of developments occurring after the date of this document except as required by law.


 


 

Appendix A

 

The following is a list of identified smelters or refiners for the 2015 reporting period:

 

Metal

Standard Smelter Name

Smelter or Refiner Country

Conflict Free?

Gold

Advanced Chemical Company

UNITED STATES

Unknown

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

Yes

Gold

Aktyubinsk Copper Company TOO

KAZAKHSTAN

Unknown

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

Unknown

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Yes

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Unknown

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

Yes

Gold

Argor-Heraeus SA

SWITZERLAND

Yes

Gold

Asahi Pretec Corporation

JAPAN

Yes

Gold

Asahi Refining Canada Limited

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

Yes

Gold

Aurubis AG

GERMANY

Yes

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Yes

Gold

Bauer Walser AG

GERMANY

Unknown

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 SA

SWITZERLAND

Unknown

Gold

Chimet S.p.A.

ITALY

Yes

Gold

Chugai Mining

JAPAN

Unknown

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

Unknown

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Unknown

Gold

Do Sung Corporation

KOREA, REPUBLIC OF

Unknown

Gold

DODUCO GmbH

GERMANY

Yes

Gold

Dowa

JAPAN

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

Faggi Enrico S.p.A.

ITALY

Unknown

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

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 Company Limited

CHINA

Unknown

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

Yes

Gold

Istanbul Gold Refinery

TURKEY

Yes

Gold

Japan Mint

JAPAN

Yes

Gold

Jiangxi Copper Company Limited

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 Metal Co., Ltd.

KOREA, REPUBLIC OF

Unknown

Gold

Korea Zinc Co. Ltd.

KOREA, REPUBLIC OF

Unknown

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Unknown

Gold

L' azurde Company For Jewelry

SAUDI ARABIA

Unknown

Gold

Lingbao Gold Company Limited

CHINA

Unknown

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

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

Metahub Industries Sdn. Bhd.

MALAYSIA

Unknown

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Yes

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Yes

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Unknown

Gold

Metalor Technologies SA

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

Morris and Watson

NEW ZEALAND

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 Kolyma Refinery

RUSSIAN FEDERATION

Unknown

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

Yes

Gold

PAMP SA

SWITZERLAND

Yes

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Unknown

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

Yes

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

Yes

Gold

PX Précinox SA

SWITZERLAND

Yes

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Yes

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

Samduck Precious Metals

KOREA, REPUBLIC OF

Unknown

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

Unknown

Gold

SAXONIA Edelmetalle GmbH

GERMANY

Unknown

Gold

Schone Edelmetaal B.V.

NETHERLANDS

Yes

Gold

SEMPSA Joyería Platería SA

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

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

Gold

Torecom

KOREA, REPUBLIC OF

Unknown

Gold

Umicore Brasil Ltda.

BRAZIL

Yes

Gold

Umicore Precious Metals Thailand

THAILAND

Yes

Gold

Umicore SA Business Unit Precious Metals Refining

BELGIUM

Yes

Gold

United Precious Metal Refining, Inc.

UNITED STATES

Yes

Gold

Valcambi SA

SWITZERLAND

Yes

Gold

Western Australian Mint trading as The Perth Mint

AUSTRALIA

Yes

Gold

WIELAND Edelmetalle GmbH

GERMANY

Unknown

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

Avon Specialty Metals Ltd

UNITED KINGDOM

Unknown

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

E.S.R. Electronics

UNITED STATES

Unknown

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

Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch

CHINA

Unknown

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

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

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

CHINA

Yes

Tin

Alpha

UNITED STATES

Yes

Tin

An Thai Minerals Company Limited

VIET NAM

Unknown

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

Unknown

Tin

Chenzhou Yun Xiang mining limited liability company

CHINA

Unknown

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

Unknown

Tin

CV Gita Pesona

INDONESIA

Yes

Tin

CV Serumpun Sebalai

INDONESIA

Yes

Tin

CV Tiga Sekawan

INDONESIA

Unknown

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

VIET NAM

Unknown

Tin

Elmet S.L.U. (Metallo Group)

SPAIN

Yes

Tin

EM Vinto

BOLIVIA

Yes

Tin

Estanho de Rondônia S.A.

BRAZIL

Unknown

Tin

Feinhütte Halsbrücke GmbH

GERMANY

Unknown

 


 

Tin

Fenix Metals

POLAND

Yes

Tin

Gejiu Fengming Metalurgy Chemical Plant

CHINA

Unknown

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

Unknown

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Unknown

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

Unknown

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

CHINA

Yes

Tin

Linwu Xianggui Ore Smelting Co., Ltd.

CHINA

Unknown

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Yes

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Yes

Tin

Melt Metais e Ligas S/A

BRAZIL

Yes

Tin

Metahub Industries Sdn. Bhd.

MALAYSIA

Unknown

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

Nankang Nanshan Tin Manufactory Co., Ltd.

CHINA

Unknown

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

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 Alam Lestari Kencana

INDONESIA

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 Kudai Tin

INDONESIA

Unknown

Tin

PT Bangka Prima Tin

INDONESIA

Yes

Tin

PT Bangka Timah Utama Sejahtera

INDONESIA

Unknown

Tin

PT Bangka Tin Industry

INDONESIA

Yes

Tin

PT Belitung Industri Sejahtera

INDONESIA

Yes

Tin

PT BilliTin Makmur Lestari

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 Fang Di MulTindo

INDONESIA

Unknown

Tin

PT Inti Stania Prima

INDONESIA

Yes

Tin

PT Justindo

INDONESIA

Yes

Tin

PT Karimun Mining

INDONESIA

Unknown

Tin

PT Kijang Jaya Mandiri

INDONESIA

Unknown

Tin

PT Mitra Stania Prima

INDONESIA

Yes

 


 

Tin

PT Panca Mega Persada

INDONESIA

Yes

Tin

PT Pelat Timah Nusantara Tbk

INDONESIA

Unknown

Tin

PT Prima Timah Utama

INDONESIA

Yes

Tin

PT Refined Bangka Tin

INDONESIA

Yes

Tin

PT Sariwiguna Binasentosa

INDONESIA

Yes

Tin

PT Seirama Tin Investment

INDONESIA

Unknown

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 Tirus Putra Mandiri

INDONESIA

Unknown

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

VIET NAM

Unknown

Tin

VQB Mineral and Trading Group JSC

VIET NAM

Yes

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

Yes

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Unknown

Tin

Yunnan Tin Group (Holding) 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.

VIET NAM

Yes

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Yes

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Yes

Tungsten

Dayu Jincheng Tungsten Industry Co., Ltd.

CHINA

Unknown

Tungsten

Dayu Weiliang Tungsten Co., Ltd.

CHINA

Unknown

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

Yes

Tungsten

Ganxian Shirui New Material Co., Ltd.

CHINA

Unknown

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Yes

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Yes

Tungsten

Ganzhou Non-ferrous Metals Smelting Co., Ltd.

CHINA

Unknown

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Yes

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

Yes

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

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

Yes

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

Unknown

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin

CHINA

Unknown

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

Unknown

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

Unknown

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Unknown

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

Yes

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Unknown

Tungsten

Kennametal Fallon

UNITED STATES

Unknown

Tungsten

Kennametal Huntsville

UNITED STATES

Yes

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Yes

Tungsten

Moliren Ltd

RUSSIAN FEDERATION

Unknown

Tungsten

Niagara Refining LLC

UNITED STATES

Yes

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

Yes

Tungsten

Philippine Chuangin Industrial Co., Inc.

PHILIPPINES

Unknown

Tungsten

Pobedit, JSC

RUSSIAN FEDERATION

Unknown

Tungsten

Sanher Tungsten Vietnam Co., Ltd.

VIET NAM

Unknown

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Yes

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

VIET NAM

Yes

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

Yes

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

Unknown

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

Unknown

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

Yes

 


 


 

Appendix B

 

The following is a list of the Countries of Origin identified for the 2015 reporting period:

 

Gold

Tantalum

Tin

Tungsten

AUSTRALIA

AUSTRIA

BELGIUM

AUSTRIA

AUSTRIA

BRAZIL

BOLIVIA

BRAZIL

BELGIUM

CHINA

BRAZIL

CHINA

BRAZIL

ESTONIA

CHINA

GERMANY

CANADA

GERMANY

GERMANY

JAPAN

CHINA

INDIA

INDONESIA

KOREA, REPUBLIC OF

FRANCE

JAPAN

JAPAN

PHILIPPINES

GERMANY

KAZAKHSTAN

MALAYSIA

RUSSIAN FEDERATION

INDIA

MEXICO

PERU

UNITED STATES

INDONESIA

RUSSIAN FEDERATION

PHILIPPINES

VIET NAM

ITALY

THAILAND

POLAND

 

JAPAN

UNITED KINGDOM

RWANDA

 

KAZAKHSTAN

UNITED STATES

SPAIN

 

KOREA, REPUBLIC OF

 

TAIWAN

 

KYRGYZSTAN

 

THAILAND

 

MALAYSIA

 

UNITED STATES

 

MEXICO

 

VIET NAM

 

NETHERLANDS

 

 

 

NEW ZEALAND

 

 

 

PHILIPPINES

 

 

 

POLAND

 

 

 

RUSSIAN FEDERATION

 

 

 

SAUDI ARABIA

 

 

 

SINGAPORE

 

 

 

SOUTH AFRICA

 

 

 

SPAIN

 

 

 

SUDAN

 

 

 

SWEDEN

 

 

 

SWITZERLAND

 

 

 

TAIWAN

 

 

 

THAILAND

 

 

 

TURKEY

 

 

 

UNITED ARAB EMIRATES

 

 

 

UNITED STATES

 

 

 

UZBEKISTAN

 

 

 

ZIMBABWE

 

 

 

***