UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
NOVANTA INC.
(Exact name of registrant as specified in its charter)
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New Brunswick, Canada |
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001-35083 |
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98-0110412 |
(State or other jurisdiction of incorporation) |
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(Commission File Number) |
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(IRS Employer Identification No.) |
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125 Middlesex Turnpike Bedford, Massachusetts, USA |
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01730 |
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(Address of principal executive offices) |
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(Zip Code) |
Matthijs Glastra, Chief Executive Officer, (781) 266-5700
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period January 1 to December 31, 2016 |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Novanta Inc. has filed a Conflict Minerals Report herewith as Exhibit 1.01 to this Form SD pursuant to Rule 13p-1 for the period January 1 to December 31, 2016.
A copy of the Company’s Conflict Minerals Report for the period January 1 to December 31, 2016 is also publicly available at www.novanta.com/about-us/corporate-citizenship/.
Item 1.02 Exhibit
The Company has filed, as Exhibit 1.01 to this Form SD, the Conflict Minerals Report as required by Item 1.01 of this Form.
Section 2 - Exhibits
Item 2.01 Exhibits
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Exhibit 1.01 |
Conflict Minerals Report for the reporting period January 1 to December 31, 2016, as required by Item 1.01 and 1.02 of this Form SD. |
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Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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Novanta Inc. |
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(Registrant) |
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Date: May 31, 2017 |
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By: |
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/s/ Matthijs Glastra |
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Matthijs Glastra |
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Chief Executive Officer |
Exhibit 1.01
NOVANTA INC.
Conflict Minerals Report
For the Period January 1 to December 31, 2016
Introduction
This report has been prepared by Novanta Inc. (“Novanta”, the “Company”, “we”, “our”) for the period from January 1, 2016 to December 31, 2016 (the “Reporting Period”) in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, 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”).
The term “conflict minerals” is defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are currently 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.
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, 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.
Company Overview and Products Covered by This Report
Novanta is a leading global supplier of core technology solutions that give healthcare and advanced industrial OEMs a competitive advantage. We combine deep proprietary technology expertise at the intersection of photonics and motion with a proven ability to solve complex technical challenges. This
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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 photonics, vision and precision motion solutions to customers around the world.
The Company is organized into three reportable segments: Phontonics, Vision and Precision Motion. The Photonics segment designs, manufactures and markets photonics-based solutions, including CO2 laser sources, galvanometer and polygon-based optical scanning components and scan heads. The Vision segment designs, manufactures and markets a wide range of medical grade technologies, including high definition visualization solutions, imaging informatics products, wireless video signal transmission devices, embedded capacitive and resistive touch panel technology, camera-based machine vision products and solutions, RFID technologies, embedded and handheld data collection products for barcode scanning, rugged thermal chart recorders, and light and color measurement devices. The Precision Motion segment designs, manufactures and markets optical encoders, precision motor and motion control products, air bearing spindles and precision machined components. The vast majority of the Company’s product offerings are sold to OEM customers.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals necessary to the functionality or production of its products. Our RCOI was reasonably designed to determine whether such conflict minerals originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (collectively, the “Covered Countries”) or came from scrap or recycled sources. 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 the list and the applicable contacts for the suppliers to our third-party service provider (the “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 further refined 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 2016. Using this process, we were able to remove approximately 11% of suppliers from scope for the 2016 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 4.20, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, the suppliers 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.
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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-responsive suppliers via email and telephone follow-ups. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our Service Provider 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 through our Service Provider. 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 5, 2017, 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
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Maintain Strong Company Management System |
1.1. |
Internal Team |
The Company’s conflict minerals compliance program is sponsored by the Chief Executive 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.
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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.
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 comply with laws and regulations surrounding conflict minerals.
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: www.novanta.com/about-us/corporate-citizenship/.
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Supplier Engagement |
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.20 and our 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 the conflict minerals program. This includes obtaining information to support the chain of custody of the 3TGs identified in our products. We included Conflict Minerals terms and conditions on our purchase orders for raw materials and components used in our production process.
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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.
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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 maintained by our Service Provider.
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Identify and Assess Risks in the Supply Chain |
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We have relied on supplier responses for information about the source of conflict minerals contained in the parts and components that they supplied to us. Similarly, our direct suppliers also relied on information provided by their suppliers. This chain of information created 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.
Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:
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Geographic proximity to the DRC and covered countries; |
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Conflict-Free Smelter Program (CFSP) audit status; and |
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Known or plausible evidence of unethical or conflict sourcing. |
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:
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Does the supplier have a policy in place that includes DRC conflict-free sourcing? |
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Has the supplier implemented due diligence measures for conflict-free sourcing? |
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Does the supplier verify due diligence information received from its suppliers? |
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Does the supplier’s 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
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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.
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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. We rely on industry efforts, such as the CFSI, to influence smelters and refiners to become certified as part of CFSI’s Conflict Free Smelter Program.
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Report Annually on Supply Chain Due Diligence |
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This Report, which constitutes our annual report on our due diligence efforts, is available on our website at www.novanta.com/about-us/corporate-citizenship/ and is filed with the SEC.
Results of Due Diligence
As of May 5, 2017, the Company had surveyed 1,020 suppliers that are considered in scope and received responses from approximately 80% 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 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 Service Provider compared the facilities reported on the CMRTs 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 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 aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and CFSI.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 246 smelters that are deemed CFSP Compliant, namely, they are compliant with the Conflict Free Smelter Program assessment protocols. There are 13 more smelters or refiners that are deemed CFSP Active, which means that these facilities have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.
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.
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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.
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Appendix A
The following is a list of identified smelters or refiners for the 2016 reporting period:
Metal |
Standard Smelter Name |
Smelter or Refiner Country |
Gold |
Abington Reldan Metals, LLC |
UNITED STATES |
Gold |
Advanced Chemical Company |
UNITED STATES |
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
Gold |
AngloGold Ashanti Córrego do Sítio Mineração |
BRAZIL |
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
Gold |
Asahi Pretec Corp. |
JAPAN |
Gold |
Asahi Refining Canada Ltd. |
CANADA |
Gold |
Asahi Refining USA Inc. |
UNITED STATES |
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
Gold |
AU Traders and Refiners |
SOUTH AFRICA |
Gold |
AURA-II |
UNITED STATES |
Gold |
Aurubis AG |
GERMANY |
Gold |
Bangalore Refinery |
INDIA |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
Gold |
Boliden AB |
SWEDEN |
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
Gold |
Caridad |
MEXICO |
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
Gold |
Cendres + Métaux S.A. |
SWITZERLAND |
Gold |
Chimet S.p.A. |
ITALY |
Gold |
Chugai Mining |
JAPAN |
Gold |
Daejin Indus Co., Ltd. |
KOREA, REPUBLIC OF |
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
GERMANY |
Gold |
DODUCO GmbH |
GERMANY |
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Dowa |
JAPAN |
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Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
Gold |
Eco-System Recycling Co., Ltd. |
JAPAN |
Gold |
Elemetal Refining, LLC |
UNITED STATES |
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
Gold |
Gansu Seemine Material Hi-Tech Co., Ltd. |
CHINA |
Gold |
Geib Refining Corporation |
UNITED STATES |
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
Gold |
Guangdong Jinding Gold Limited |
CHINA |
Gold |
Gujarat Gold Centre |
INDIA |
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA |
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
Gold |
Heimerle + Meule GmbH |
GERMANY |
Gold |
Heraeus Ltd. Hong Kong |
CHINA |
Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY |
Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
Gold |
Hwasung CJ Co., Ltd. |
KOREA, REPUBLIC OF |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
Gold |
Istanbul Gold Refinery |
TURKEY |
Gold |
Japan Mint |
JAPAN |
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
Gold |
Kazzinc |
KAZAKHSTAN |
Gold |
Kennecott Utah Copper LLC |
UNITED STATES |
Gold |
KGHM Polska Miedź Spółka Akcyjna |
POLAND |
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
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Kyrgyzaltyn JSC |
KYRGYZSTAN |
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Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
Gold |
Lingbao Gold Co., Ltd. |
CHINA |
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
Gold |
L'Orfebre S.A. |
ANDORRA |
Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
Gold |
Materion |
UNITED STATES |
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
Gold |
Metalor USA Refining Corporation |
UNITED STATES |
Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
MEXICO |
Gold |
Mitsubishi Materials Corporation |
JAPAN |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
Gold |
Modeltech Sdn Bhd |
MALAYSIA |
Gold |
Morris and Watson |
NEW ZEALAND |
Gold |
Morris and Watson Gold Coast |
AUSTRALIA |
Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
TURKEY |
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
Gold |
Nihon Material Co., Ltd. |
JAPAN |
Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
Gold |
PAMP S.A. |
SWITZERLAND |
Gold |
Pease & Curren |
UNITED STATES |
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
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PT Aneka Tambang (Persero) Tbk |
INDONESIA |
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Gold |
PX Précinox S.A. |
SWITZERLAND |
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
Gold |
Remondis Argentia B.V. |
NETHERLANDS |
Gold |
Republic Metals Corporation |
UNITED STATES |
Gold |
Royal Canadian Mint |
CANADA |
Gold |
SAAMP |
FRANCE |
Gold |
Sabin Metal Corp. |
UNITED STATES |
Gold |
SAFINA A.S. |
CZECH REPUBLIC |
Gold |
Sai Refinery |
INDIA |
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
Gold |
SAMWON Metals Corp. |
KOREA, REPUBLIC OF |
Gold |
SAXONIA Edelmetalle GmbH |
GERMANY |
Gold |
Schone Edelmetaal B.V. |
NETHERLANDS |
Gold |
SEMPSA Joyería Platería S.A. |
SPAIN |
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
Gold |
Singway Technology Co., Ltd. |
TAIWAN |
Gold |
So Accurate Group, Inc. |
UNITED STATES |
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN |
Gold |
Sudan Gold Refinery |
SUDAN |
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
Gold |
SungEel HiTech |
KOREA, REPUBLIC OF |
Gold |
T.C.A S.p.A |
ITALY |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
CHINA |
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA |
Gold |
Tony Goetz NV |
BELGIUM |
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
Gold |
Torecom |
KOREA, REPUBLIC OF |
Gold |
Umicore Brasil Ltda. |
BRAZIL |
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Umicore Precious Metals Thailand |
THAILAND |
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Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES |
Gold |
Universal Precious Metals Refining Zambia |
ZAMBIA |
Gold |
Valcambi S.A. |
SWITZERLAND |
Gold |
Western Australian Mint trading as The Perth Mint |
AUSTRALIA |
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
Gold |
Yamamoto Precious Metal Co., Ltd. |
JAPAN |
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
Gold |
Zijin Mining Group Co., Ltd. Gold Refinery |
CHINA |
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
Tantalum |
Conghua Tantalum and Niobium Smeltry |
CHINA |
Tantalum |
D Block Metals, LLC |
UNITED STATES |
Tantalum |
Duoluoshan |
CHINA |
Tantalum |
Exotech Inc. |
UNITED STATES |
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES |
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA |
Tantalum |
H.C. Starck Co., Ltd. |
THAILAND |
Tantalum |
H.C. Starck GmbH Goslar |
GERMANY |
Tantalum |
H.C. Starck GmbH Laufenburg |
GERMANY |
Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY |
Tantalum |
H.C. Starck Inc. |
UNITED STATES |
Tantalum |
H.C. Starck Ltd. |
JAPAN |
Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
Tantalum |
Hi-Temp Specialty Metals, Inc. |
UNITED STATES |
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
12
Jiujiang Tanbre Co., Ltd. |
CHINA |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
Tantalum |
KEMET Blue Metals |
MEXICO |
Tantalum |
KEMET Blue Powder |
UNITED STATES |
Tantalum |
King-Tan Tantalum Industry Ltd. |
CHINA |
Tantalum |
LSM Brasil S.A. |
BRAZIL |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
Tantalum |
Mineração Taboca S.A. |
BRAZIL |
Tantalum |
Mitsui Mining & Smelting |
JAPAN |
Tantalum |
Molycorp Silmet A.S. |
ESTONIA |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
Tantalum |
Plansee SE Liezen |
AUSTRIA |
Tantalum |
Plansee SE Reutte |
AUSTRIA |
Tantalum |
Power Resources Ltd. |
MACEDONIA |
Tantalum |
QuantumClean |
UNITED STATES |
Tantalum |
Resind Indústria e Comércio Ltda. |
BRAZIL |
Tantalum |
RFH Tantalum Smeltry Co., Ltd. |
CHINA |
Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
Tantalum |
Taki Chemicals |
JAPAN |
Tantalum |
Telex Metals |
UNITED STATES |
Tantalum |
Tranzact, Inc. |
UNITED STATES |
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. |
CHINA |
Tantalum |
Zhuzhou Cemented Carbide Group Co., Ltd. |
CHINA |
Tin |
Alpha |
UNITED STATES |
Tin |
An Thai Minerals Co., Ltd. |
VIET NAM |
Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
Tin |
China Tin Group Co., Ltd. |
CHINA |
Tin |
CNMC (Guangxi) PGMA Co., Ltd. |
CHINA |
Tin |
Cooperativa Metalurgica de Rondônia Ltda. |
BRAZIL |
Tin |
CV Ayi Jaya |
INDONESIA |
Tin |
CV Dua Sekawan |
INDONESIA |
13
CV Gita Pesona |
INDONESIA |
|
Tin |
CV Serumpun Sebalai |
INDONESIA |
Tin |
CV Tiga Sekawan |
INDONESIA |
Tin |
CV United Smelting |
INDONESIA |
Tin |
CV Venus Inti Perkasa |
INDONESIA |
Tin |
Dowa |
JAPAN |
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
Tin |
Elmet S.L.U. |
SPAIN |
Tin |
EM Vinto |
BOLIVIA |
Tin |
Estanho de Rondônia S.A. |
BRAZIL |
Tin |
Fenix Metals |
POLAND |
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA |
Tin |
Gejiu Jinye Mineral Company |
CHINA |
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CHINA |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
Tin |
Huichang Jinshunda Tin Co., Ltd. |
CHINA |
Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
CHINA |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
Tin |
Metallic Resources, Inc. |
UNITED STATES |
Tin |
Metallo-Chimique N.V. |
BELGIUM |
Tin |
Mineração Taboca S.A. |
BRAZIL |
Tin |
Minsur |
PERU |
Tin |
Mitsubishi Materials Corporation |
JAPAN |
Tin |
Modeltech Sdn Bhd |
MALAYSIA |
Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. |
CHINA |
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
14
Operaciones Metalurgical S.A. |
BOLIVIA |
|
Tin |
Phoenix Metal Ltd. |
RWANDA |
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
Tin |
PT Babel Inti Perkasa |
INDONESIA |
Tin |
PT Bangka Prima Tin |
INDONESIA |
Tin |
PT Bangka Tin Industry |
INDONESIA |
Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
Tin |
PT Bukit Timah |
INDONESIA |
Tin |
PT Cipta Persada Mulia |
INDONESIA |
Tin |
PT DS Jaya Abadi |
INDONESIA |
Tin |
PT Eunindo Usaha Mandiri |
INDONESIA |
Tin |
PT Inti Stania Prima |
INDONESIA |
Tin |
PT Justindo |
INDONESIA |
Tin |
PT Karimun Mining |
INDONESIA |
Tin |
PT Kijang Jaya Mandiri |
INDONESIA |
Tin |
PT Lautan Harmonis Sejahtera |
INDONESIA |
Tin |
PT Mitra Stania Prima |
INDONESIA |
Tin |
PT O.M. Indonesia |
INDONESIA |
Tin |
PT Panca Mega Persada |
INDONESIA |
Tin |
PT Prima Timah Utama |
INDONESIA |
Tin |
PT Refined Bangka Tin |
INDONESIA |
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
Tin |
PT Sukses Inti Makmur |
INDONESIA |
Tin |
PT Sumber Jaya Indah |
INDONESIA |
Tin |
PT Timah (Persero) Tbk Kundur |
INDONESIA |
Tin |
PT Timah (Persero) Tbk Mentok |
INDONESIA |
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
Tin |
PT Tommy Utama |
INDONESIA |
Tin |
PT Wahana Perkit Jaya |
INDONESIA |
Tin |
Resind Indústria e Comércio Ltda. |
BRAZIL |
Tin |
Rui Da Hung |
TAIWAN |
Tin |
Soft Metais Ltda. |
BRAZIL |
15
Thaisarco |
THAILAND |
|
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Tin |
VQB Mineral and Trading Group JSC |
VIET NAM |
Tin |
White Solder Metalurgia e Mineração Ltda. |
BRAZIL |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
Tin |
Yunnan Tin Company Limited |
CHINA |
Tungsten |
A.L.M.T. TUNGSTEN Corp. |
JAPAN |
Tungsten |
ACL Metais Eireli |
BRAZIL |
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
Tungsten |
Dayu Weiliang Tungsten Co., Ltd. |
CHINA |
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. |
CHINA |
Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
Tungsten |
H.C. Starck GmbH |
GERMANY |
Tungsten |
H.C. Starck Smelting GmbH & Co.KG |
GERMANY |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA |
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA |
Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
CHINA |
16
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
|
Tungsten |
Kennametal Fallon |
UNITED STATES |
Tungsten |
Kennametal Huntsville |
UNITED STATES |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
Tungsten |
Moliren Ltd |
RUSSIAN FEDERATION |
Tungsten |
Niagara Refining LLC |
UNITED STATES |
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIET NAM |
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City |
CHINA |
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIET NAM |
Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION |
Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. |
VIET NAM |
Tungsten |
Wolfram Bergbau und Hütten AG |
AUSTRIA |
Tungsten |
Woltech Korea Co., Ltd. |
KOREA, REPUBLIC OF |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CHINA |
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA |
17
The list below sets out possible countries of origin of 3TGs used in the manufacture of our products containing 3TGs for the 2016 reporting year. The list is based on publicly available information, our reasonable country of origin inquiries, and other due diligence efforts. However, for the reasons described in the CMR, these possible countries of origin cannot be linked to our products with reasonable certainty.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
***
18