UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Woodward, Inc.
(Exact name of registrant as specified in its charter)
Delaware | 0-8408 | 36-1984010 | ||
(State or other jurisdiction of | (Commission | (IRS Employer | ||
incorporation or organization) | File Number) | Identification No.) |
1000 East Drake Road, Fort Collins, Colorado | 80525 | |
(Address of principal executive offices) | (Zip Code) |
A. Christopher Fawzy (970) 482-5811
(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:
x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Woodward, Inc. (the Company, Woodward, we, us or our) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2015 to December 31, 2015 (the Reporting Period).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD and as used herein, conflict minerals means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country as defined in Form SD (collectively, the Covered Countries). Our operations, including the operations of our consolidated subsidiaries, may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. Woodward primarily serves the aerospace market and industrial market. Products we manufacture or contract to manufacture in the aerospace market include fuel pumps, metering units, actuators, air valves, specialty valves, fuel nozzles, and thrust reverser actuation systems for turbine engines and nacelles; as well as flight deck controls (auto throttles, rudder pedal assembles, flight control assemblies), actuators, servocontrols, motors and sensors for aircraft. Products we manufacture or contract to manufacture in the industrial market include power converters, actuators, valves, pumps, injectors, solenoids, ignition systems, governors, electronics and devices that measure, communicate and protect low and medium voltage electrical distribution systems. Some of these products contain one or more conflict minerals, in particular:
| All of the product families listed, except for valves, nozzles, injectors and some pumps, contain (or physically are) electronics, motors and/or sensors. These product families will contain, at a minimum, tin in the lead/tin solder that fastens electronic components to printed circuit boards and tantalum in certain families of capacitors used in printed circuit board assemblies within those product families. |
| Gold is used in the plating of connectors and contacts in many of the electronics within our product families. |
| Finally, items in all of Woodward product families use a variety of steels, which contain tiny amounts of tungsten as part of their material recipe. |
These determinations lead to Woodwards requirement to conduct a reasonable country of origin inquiry (RCOI) in accordance with Rule 13p-1.
Woodward developed its initial good faith RCOI process in calendar year 2013 to support our 2013 SEC reporting requirement in May 2014 (references to whole years refer to calendar years). The RCOI process, while highly manual, was designed to conform to the Organisation for Economic Co-operation and Developments (OECD) framework, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (OECD Guidelines). We further refined our RCOI process during the second half of 2014 and throughout 2015 by focusing on the elimination of duplicate supplier records and grouping multiple business groups within a common corporation. We also enhanced our RCOI process through a supplier record selection process based on spend during a specified calendar interval and by joining the Conflict Free Sourcing Initiative (CSFI) in December 2015, gaining access to their extensive database of smelters or refiners (SOR), SOR audit records, and the mine of origin data that CFSI has been able to acquire during their SOR audits. We added additional resources in mid-2015 and again at the start of 2016 to support our manual RCOI process for the 2015 reporting period. We have engaged and are in the process of implementing a product material compliance application platform to automate our RCOI efforts in the future.
RCOI
As noted above, some of the products Woodward manufactures contain one or more conflict minerals. Woodward does not purchase conflict minerals directly from mines, smelters or refiners. Rather, the Company sources products containing conflict minerals from its suppliers. In accordance with the OECD Guidelines, the Company relies on its suppliers to provide information regarding the origin of conflict minerals included in supplied products, including, where possible, the smelters or refiners of the conflict minerals.
Supplier Categorization
In connection with the preparation of the Form SD and associated Conflict Minerals Report, we create a master supplier list of direct suppliers who provide items or services directly used in items that Woodward manufactures or contracts to manufacture. Such suppliers are classified as either direct non-distribution suppliers, who fabricate custom designed items to either Woodward specification or supplier-engineered specifications, or direct distribution suppliers, who source items from multiple Original Equipment Manufacturers (OEMs), typically in the nature of a commercial item or items manufactured to standard government
2
specifications. Direct distribution suppliers do not manufacture or contract to manufacture, nor do they influence the functionality or content of the items they obtain from OEMs and provide to their customers. Woodward relies on the efforts and activities of professional societies such as IPC Association Connecting Electronics Industries, which provides a leading role in the conflict minerals efforts of the electronics and electronics distribution industries, to establish and maintain the principal mechanisms for obtaining OEM distribution component conflict minerals status from our first tier distribution suppliers.
Suppliers that contribute items or services only for Woodwards internal operations and infrastructure, and are not incorporated into items that Woodward manufactures or contracts to manufacture, are not included in the Companys conflict minerals reporting.
Relevant Supplier Identification
In 2015, Woodward used a single SAP application, Business Objects (BObj), to filter and extract relevant supplier records from both of our business systems. The BObj report allowed us to specifically select direct suppliers with spend during a specified time interval, in this case, November 1, 2014 through October 31, 2015. Since one SEC Final Rule reporting requirement is to consider only items introduced into the stream of commerce during a given calendar year, we determined a setback interval for supplier parts receipts. More specifically, a certain minimum time interval is required from receipt of supplier parts to their use in the assembly of an end item, internal testing of that end item, and customer acceptance tests or inspections of the end item prior to its shipment. While those assembly and test durations vary with the complexity of the end item and customer requirements, Woodward is using 2 months to reflect a typical duration and is basing this standard setback interval from its more than 140 years of business experience. Therefore, November 1, 2014 through October 31, 2015 defines the interval for receipt of new supplier parts that can be incorporated into Woodwards calendar year 2015 shipments. We also include suppliers of our existing inventory at the start of the calendar year.
Woodward generated its first supplier inquiry list for 2015 in early June, 2015, covering the period November 1, 2014 through May 31, 2015, which resulted in 2623 relevant supplier records.
Woodward Conflict Minerals Data Requests and Supplier Responses
Woodward sent its initial 2015 data request to these 2623 suppliers on June 10, 2015, requesting both Conflict Minerals Reporting Templates (CMRTs) and the contact data for both their Conflict Minerals point of contact (POC) and their overall materials compliance POC. We also requested that suppliers identify if they had a parent company, their parent company contact data if applicable, and whether their conflict minerals reporting was from a corporate or business group level. Follow-up inquiries were sent to current non-respondents in August, 2015, November, 2015, and March, 2016. Three other sets of inquiries were sent during March, 2016 to confirm and complete subsidiary relationships for previous CMRT receipts indicating such relationships, and to target suppliers that returned unrecognized e-mail address flag responses to our initial inquiry. As of April 1, 2016, Woodward had received responses from 1,571 out of 2623 suppliers (59.9%), 1230 (46.7%) of which provided a CMRT. Of the CMRTs provided, 1090 (41.6% of total responses) were valid (valid indicates Excel file CMRT with no checker-tab-indicated errors) and 438 (16.7% of total responses) were version 4.0 or higher.
Woodward generated a follow-up supplier inquiry list covering the period June 1, 2015 through October 31, 2015 to cover its entire calendar year 2015 reporting interval. We sent initial CMRT requires to the resulting 40 additional suppliers in early April, 2016.
Supplier Response Assessment
Using a highly manual due diligence process conforming to the 5-step due diligence process specified in the OECD guidelines, and as discussed in Exhibit 1.01 to this form SD, Woodward categorized, verified and identified supplier CMRTs for consideration in our company roll-up CMRT and those CMRTs indicating that additional supplier follow-up was required. We continue to research tin usage in non-obvious materials, which in 2015 enabled us to flag and question several supplier assertions of no tin usage in the components or materials they provide us. The CMRTs that passed the assessment process were manually combined into a preliminary Woodward company level CMRT.
Based reasonable country of origin inquiry, Woodward has reason to believe that necessary conflict minerals in its products may have originated in the Democratic Republic of the Congo or an adjoining country and has reason to believe that they may not be from recycled or scrap sources. Therefore Woodward has undertaken a due diligence process to determine the source and chain of custody of its conflict minerals. As a result of this due diligence process, the Company has determined that it is required to file a Conflicts Minerals Report, a copy of which is filed as Exhibit 1.01 to this Form SD. Our Conflict Minerals Report is also publicly available as a document link at http://www.woodward.com/SocialResponsibility.aspx. The content on any web site referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.
3
RCOI IMPROVEMENT ACTIONS CONTINUING OR PLANNED
Woodward has begun implementation, or intends to begin implementation in 2016 or 2017, of the following improvement actions:
| We plan to implement and begin using our selected product material compliance application platform to automate our RCOI efforts |
| We intend to continue researching the extensive use of tin as a component in a wide variety of non-obvious materials, to further assess if such materials are contained within Woodward products, and using this information to facilitate and/or validate the correctness of supplier sourcing information. |
| We will begin assessing and determining any infrastructure updates and process modifications required to support initial part level CMRT requests. Our goal is to provide each supplier a complete list of those parts Woodward purchased from them in a specified November through October 12-month interval, so as to eliminate any ambiguity in the request / response process. |
4
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
5
Section 2 Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD.
Exhibit 1.01 Conflict Minerals Report of Woodward, Inc., for the year ended December 31, 2015.
6
SIGNATURES
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.
Woodward, Inc. |
(Registrant) |
/s/ A. Christopher Fawzy | May 31, 2016 | |||||||
By: | A. Christopher Fawzy Corporate Vice President, General Counsel, Corporate Secretary and Chief Compliance Officer |
(Date) |
7
EXHIBIT INDEX
Exhibit No. |
Description | |
1.01 | Conflict Minerals Report of Woodward, Inc., for the year ended December 31, 2015. |
8
Exhibit 1.01
Conflict Minerals Report of Woodward, Inc.
For the reporting period from January 1, 2015 to December 31, 2015
This Conflict Minerals Report (the Report) of Woodward, Inc. (the Company, Woodward, we, us or our) has been prepared pursuant to Rule 13p-1 and Form SD (Form SD) promulgated under the Securities Exchange Act of 1934 (the Exchange Act) for the reporting period January 1, 2015 to December 31, 2015 (the Reporting Period).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD, and as used herein, conflict minerals means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country as defined in Form SD (collectively, the Covered Countries).
Woodwards Manufactured and Contracted-to-Manufacture Products
Woodward, including our consolidated subsidiaries, manufactures, or contracts to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. We provide energy control and optimization solutions for the aerospace and industrial markets through the precise and efficient control of fluid and electrical energy, combustion, and motion. Our key focus areas within the aerospace market are propulsion system control solutions for turbine powered aircraft, actuation systems and motion control solutions. Specific products include fuel pumps, metering units, actuators, air valves, specialty valves, fuel nozzles, and thrust reverser actuation systems for turbine engines and nacelles; as well as flight deck controls (auto throttles, rudder pedal assembles, flight control assemblies), actuators, servocontrols, motors and sensors for aircraft. Within the industrial market, our key focus areas are control solutions for equipment that produce electricity using conventional or renewable energy sources; solutions for the control of power quality, distribution and storage on the electrical grid; and control solutions for power equipment used in the extraction, distribution and conversion of renewable and fossil fuels in marine, mobile, and industrial equipment applications. Specific products include power converters, actuators, valves, pumps, injectors, solenoids, ignition systems, governors, electronics and devices that measure, communicate and protect low and medium voltage electrical distribution systems.
The Companys Due Diligence Process
The Companys due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Developments (OECD), OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas, Second Edition, including applicable supplements thereto (the OECD Guidelines).
Woodward has implemented or is addressing each of the steps in the OECD 5-step due diligence framework as discussed or referenced below:
1. | Establish strong company management systems |
A. | Company conflict minerals policy |
Woodward has developed and adopted a conflict minerals policy, Policy 9-14, Conflict Minerals (the Conflict Minerals Policy). The Conflict Minerals Policy affirms that the Company takes our corporate responsibility with respect to responsible sourcing seriously and that it is the Companys goal only to use in our products conflict minerals that are sourced responsibly. The Conflict Minerals Policy provides that Woodward will take appropriate measures to ensure participants in our global supply chain exercise due diligence and comply with reporting and other compliance requirements with respect to the items Woodward procures from them. The policy is publicly available as a document link at http://www.woodward.com/SocialResponsibility.aspx. The policy is formally reviewed at least annually per corporate policy requirements to determine if any revisions or enhancements are required to maintain compliance with the letter and the intent of the law. No changes were made to Woodwards Conflict Minerals Policy as the result of its review in 2015.
B. | Internal management structure |
The Conflict Minerals Policy designates the Corporate Vice President of Global Supply Chain as responsible for ensuring our compliance with conflict minerals reporting requirements. Woodwards Corporate Director, Global Trade Compliance & Associate General Counsel, serves as an advisor on conflict minerals compliance. Conflict minerals have also been a topic of discussion and review at Board of Directors meetings since September 2012.
The Company has established an internal team to manage conflict minerals engagement with our suppliers. Woodward assigned our Global Supply Chain (GSC) with the responsibility for conflict minerals compliance. The GSCs Business Integration Group has been designated as the focal point for the compliance efforts, as that group has responsibility for GSC business systems, procedures, and compliance with government regulations. Woodward is subject to numerous product material compliance (PMC) regulations, including conflict minerals, which require enterprise-wide system and compliance processes and integrated process teams to achieve regulatory compliance requirements and social responsibility goals. The project manager and a product material compliance core team (together the Core Team), with other members assigned from the GSCs Business Integration Group, and with counsel from the Legal & Compliance Department, are the Companys team of subject matter experts and implementers. The GSC is responsible for reaching out to the Companys supply base on an ongoing basis to collect information, including EICC / GeSI Conflict Minerals Reporting Templates (CMRT), regarding the presence and sourcing of conflict minerals in the products supplied to the Company. The Global Supplier Managers (commodity managers) within the GSC have also provided focused support as required. These actions have aligned existing strategic and organizational structures to address the due diligence and reporting requirements of the SEC Final Rule.
In addition, Woodwards product material compliance activity, including conflict minerals, is chartered as a formal project to provide an established framework for the continuing evolution of an enterprise-wide set of material compliance processes and standard work. The project is under the sponsorship of an Executive Committee comprised of the Corporate Vice President of Global Supply Chain, Corporate Vice President of Information Technology, and the Corporate Vice President, General Counsel, Corporate Secretary and Chief Compliance Officer. The product material compliance project manager provides status updates and receives executive project guidance on a once per quarter basis. The project also has a Steering Committee, which serves as a liaison between the core team and Woodwards business groups. The Steering Committee consists of a Vice-President from each Woodward business group and a director from each of Woodwards Global Support Services organizations. This additional structure enhances the guidance, awareness and execution of compliance and compliance support requirements throughout the enterprise. The Core Team met with the Executive Committee three times and the Steering Committee twice in 2015 to provide project status and obtain strategic guidance. The Core Team, along with our PMC software application solution provider, will transform our existing capabilities into the required PMC capabilities and oversight to achieve our goals.
C. | System of controls and transparency over the mineral supply chain |
Our existing business systems, WISE and SAP, provide controls over our supply chain. They currently provide:
| Identification of the end item products we provide to each of our customers; |
| Shipping transaction history, to assist in bounding our sales/shipments by calendar year as required by the SEC Final Rule; |
| A bill of material (BOM) identifying all of the components and materials in each of our end item products; |
| A purchasing history of each of our purchased components and raw materials and the identification of the suppliers used for these purchases; |
| A receiving inspection function that accepts or rejects purchased components and raw materials based upon whether the purchased items meet or do not meet the specification requirements (including specified material requirements) of the associated drawing or other specification documents. This is accomplished by a combination of direct measurements / inspections of the actual parts, or by reviewing the existence and completeness of formal supplier certifications to selected specifications, such as certifying proper use of specified aluminum or steel specifications. |
We are currently working to implement a software application to automate much of the Companys product materials compliance efforts. In addition, Woodward continues to maintain full membership with the Aerospace Industries Association (AIA), and the IPC the Association Connecting Electronics Industries. We also became a member of the Conflict Free Sourcing Initiative (CFSI) in late 2015.
D. | Strengthen Company engagement with suppliers |
The Company is committed to conducting business in a socially responsible manner and is determined to partner with suppliers who are similarly committed. Woodward has and continues to significantly enhance its engagement with its suppliers regarding conflict minerals requirements. Our purchase order and supplier agreement terms and conditions were modified in mid-2013 to require our suppliers to support our conflict minerals reporting. Woodward continued to revise supplier contract terms and conditions in 2015 with the goal of obtaining full material disclosure (substance, content-by-weight, raw material smelter sources) to increase the traceability of materials from each supplier.
By accepting a Woodward purchase order or a purchase release to a supplier agreement, a seller to Woodward:
warrants and certifies that it complies with Section 1502 of the Dodd Frank Act and the Conflict Minerals Regulations and Final Rules issued by the U.S. Securities and Exchange Commission, and any subsequent rules and regulations related thereto (Conflict Minerals Regulations), and has implemented compliant processes to ensure its suppliers are in compliance with the Conflict Minerals Regulations.
Where Seller does not have direct and formal reporting requirements under the Conflict Minerals Regulations, and upon request by Buyer, Seller agrees to provide due diligence and Responsible Country of Origin Inquiry (RCOI) information under this Agreement to Buyer in support of Buyers reporting requirements (the RCOI Requirements). Further, Seller shall promptly comply with all requests by Buyer to provide documentation, and other substantiating data and assurances with respect to its compliance with Conflict Minerals Regulations and the RCOI Requirements as Buyer may deem necessary from time to time. In the event: (a) Buyer deems Seller is not in compliance with the Conflict Minerals Regulations or the RCOI Requirements, (b) Buyer is not satisfied with the outcome of any review of Seller documentation and/or data or otherwise, or (c) Seller does not provide the documentation, other data and/or other further assurances to Buyer as requested by Buyer, Buyer shall have the right to terminate this any Order or any portion thereof without penalty or further liability to Seller.
In 2015, Woodward conducted numerous one-on-one contact sessions with suppliers to address their inquiries and provide guidance where needed. Development of formal supplier training courses continues and determination of appropriate Woodward course delivery methods are under discussion.
E. | Establish a company level, or industry-wide, grievance mechanism as an early warning risk-awareness system |
Woodward has a comprehensive ethics awareness compliance policy, annual training and contact mechanisms for members concerns or ethics grievances. This allows and encourages members to either contact their leader, or anyone in a leadership position, Human Resources, the Companys Chief Compliance Officer, any other Company Officer, any member of the Companys Board of Directors, or a hotline / ethics help line (both telephonic and web based) that is managed by an externally contracted agency, which allows for anonymous input if a reporting member so chooses. The details are described in Woodward Policy 01-14 Woodward Code of Business Conduct and Ethics and in the annual member and leader ethics trainings. Investigations of alleged violations are handled by a Company level Business Conduct Oversight Committee and by the Audit Committee of the Board of Directors.
Direct suppliers to Woodward may contact their Global Supplier Manager at Woodward for resolution if they believe elements of Woodward direction may cause them to be noncompliant with Woodwards stated social responsibility goals and compliance requirements. Woodward GSC members are also available to help our direct suppliers with compliance issues they may have with their suppliers regarding our flow down contract requirements. Suppliers conflict minerals representatives may also contact Woodwards product material compliance project manager, who will facilitate the appropriate guidance or resolution regarding such issues. In late 2015, the Woodward Core Team began to consider the feasibility of incorporating social responsibility matters such as conflict minerals compliance into our existing ethics and compliance infrastructure.
2. | Identify and assess risks in the supply chain |
Woodward is a downstream manufacturer. As such, Woodward does not control the origin or composition of many of the materials provided by our suppliers. Consequently, we ask our suppliers to inquire, identify, and conduct data collection and due diligence activities, which in turn are fundamental elements of our due diligence activities. Woodward conducts analyses of the data collected from our first-tier suppliers for accuracy and completeness in order to identify and assess of risks in the Woodward supply chain. This includes:
| The initial smelter checklist analysis contained in the CMRT |
| The comparison of supplier smelter identities to the current Conflict-Free Sourcing Initiative (CFSI) smelter database, which is available via Woodwards membership in the CFSI |
| The indirect analysis support Woodward has acquired as a result of submitting interim roll-up CMRTs to our customers and receiving analysis results from the various software applications they use |
In 2015, Woodward started (on a manual basis) to use both the publicly available CFSI smelter and refiner list, and the CFSI compliance and country of origin databases available through our CFSI membership. Woodward intends to compare RCOI results to information collected via independent smelter identification and conflict free smelter validation programs such as the Department of Commerce smelter identification list, the EICC / GeSI CFSI program, sources certified to the Fairtrade Standard for Gold and Precious Metals and source assessment information from the London Bullion Market Association.
For suppliers smelter inputs that are still undetermined (i.e., the source has not been confirmed as a smelter, or its conflict-free sourcing status has not been identified through the above validation programs), Woodward, in 2015, obtained additional validation data from select customers who have software applications in place and who receive our interim roll-up CMRTs. We are also acquiring independent input on our suppliers non-CFSI-identified smelters from a software applications solution provider that has compiled an extensive SOR database.
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our RCOI process is described in our Form SD.
3. | Design and implement a strategy to respond to identified risks |
A. | Report findings of the supply chain risk assessment, including conflict minerals compliance, to the designated senior management of the Company |
In addition to the product material compliance project core team quarterly reporting to its Executive and Steering Committees as identified in 1B above, in 2015 Woodward conducted numerous one-on-one supplier contacts and performing several assessments on supplier-provided SOR data as described in the Woodward Calendar Year 2015 Due Diligence Results section of this Conflict Minerals Report.
| Woodward conducts monthly supplier reviews by commodity grouping with the Corporate Vice President of Global Supply Chain and the commodity directors. |
| The periodic reviews conducted by each business group president include a review of supply chain issues for that business group. |
| A strategic planning review and a mid-year review are presented by the corporate executive staff to the Companys Chief Executive Officer and the Companys Chief Financial Officer to provide, at the highest level of management, strategic oversight of our supply chain strategies and performance. |
B. | Devise and adopt a risk management plan |
Woodward has several formal procedures and tools relative to risk management that form a solid foundation for our planned improvement actions to incorporate specific conflict minerals aspects of risk management. These existing procedures include but are not limited to our supplier approval process, our purchasing procedures, our purchase order and supplier agreement terms and conditions (described in Due Diligence section 1D above), our supplier registration portal and our Parts Transition Process, and possible software solutions.
C. | Implement the risk mitigation plan |
Woodward is continuing to develop a risk management and mitigation plan providing for actions to be taken should Woodward determine if any conflict minerals are sourced from conflict-affected areas of Covered Countries.
D. | Undertake additional fact finding and risk assessments for risks requiring mitigation, or after a change in circumstances |
In 2015, Woodward engaged in additional fact finding and risk assessments to identify risks requiring mitigation or after a change in circumstances. These activities are described above. The enhanced inquiry and assessment activities discussed for RCOI in our Form SD also provide additional and refined findings for risk identification and assessment. These activities are discussed in the RCOI Improvement Actions Continuing or Planned section, item 2.
4. | Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain |
Woodward is significantly downstream in the supply chain from smelters and refiners. In order to obtain smelter and refiner information, Woodward seeks information from our upstream suppliers and from third party data aggregating services. Woodward joined the EICC/ GeSI CFSI in late 2015 to leverage the CFSI Conflict Free Smelter audit program and the resulting audit data from that program. We will also leverage any equivalent audit data that may be obtained through Woodwards memberships in the AIA and IPC.
5. | Report annually on supply chain due diligence |
The Form SD is posted as one of our many required SEC filings as a document link at http://www.woodward.com/secfilings.aspx. The Conflict Minerals Report, when required, is also posted as a document link at http://www.woodward.com/SocialResponsibility.aspx. These postings are completed within one business week of the filing of these documents with the SEC. Also in compliance with the SEC Final Rule, Woodwards Conflict Minerals Policy, Policy 09-14, is posted as a document link at http://www.woodward.com/SocialResponsibility.aspx. Woodward has published a Sustainability Report, which summarizes our Conflict Minerals Policy and provides the context of conflict minerals compliance and objectives within our overall sustainability goals, initiatives and practices. The Sustainability Report is available as a document link at http://www.woodward.com/SocialResponsibility.aspx.
Woodward Calendar Year 2015 Due Diligence Results
Woodward Conflict Minerals Data Requests and Supplier Responses (the Due Diligence in Acquiring Supplier Data)
Woodward sent its initial 2015 data request to 2623 suppliers on June 10, 2015, requesting CMRTs and the contact data for both their Conflict Minerals point of contact (POC) and their overall materials compliance POC. These represented Woodwards direct suppliers with spend between November 1, 2014 and May 31, 2015. We also requested that suppliers identify if they had a parent company, their parent company contact data if applicable, and whether their conflict minerals reporting was from a corporate or business group level. Follow-up inquiries were sent to current non-respondents in August, 2015, November 2015 and March 2016. Three other sets of inquiries were sent during March 2016 to confirm and complete subsidiary relationships for previous CMRT receipts indicating such relationships, and to target suppliers that returned unrecognized e-mail address flag responses to our initial inquiry.
Woodwards supplier CMRT response status as of April 1, 2016 was:
Total # of Supplier records 2623
Total # of emails sent 6242 (includes initial inquiry and all follow-ups to non-respondents)
Total # of supplier responses 1571 (59.9%)
Total # of CMRTs received 1230 (46.7%)
Total # of valid CMRTs received 1090 (valid indicates Excel file CMRT with no checker-tab-indicated errors) (41.6%)
Total # of CMRTs received at version 4.0 or higher 438 (16.7%)
Woodward generated a supplier report in November 2015 to collect data on any new suppliers with spend since the May 31st cutoff of the prior report, thereby completing our supplier inquiry database for calendar year 2015. Forty additional suppliers identified by that report were sent their initial CMRT requests in early April, 2016.
We also sent requests in early April, 2016 to the 900 suppliers who provided us pre-version 4.0 CMRTs, requesting them to update their information to the version 4.01b template.
Supplier Response Assessment (Smelter Determination Due Diligence)
Using the publicly available CFSI smelter and refiner reference list contained in the CMRT template, Woodward manually generated an integrated roll-up CMRT from a subset of the received supplier company level CMRTs. This resulted in the 267 smelters or refiners (SOR) with CFSI identification numbers listed in the table below who provide through our supply chain conflict minerals used in Woodwards products:
Metal (*) |
Smelter Name (*) |
Smelter Country (*) |
Smelter | |||
Tungsten |
Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | |||
Tin |
Elmet S.L.U. (Metallo Group) | SPAIN | CID002774 | |||
Tin |
Metallo-Chimique N.V. | BELGIUM | CID002773 | |||
Tungsten |
Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | |||
Tantalum |
KEMET Blue Powder | UNITED STATES | CID002568 | |||
Tantalum |
Global Advanced Metals Aizu | JAPAN | CID002558 | |||
Tantalum |
Global Advanced Metals Boyertown | UNITED STATES | CID002557 | |||
Tantalum |
Plansee SE Reutte | AUSTRIA | CID002556 | |||
Tantalum |
H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002550 | |||
Tantalum |
H.C. Starck Ltd. | JAPAN | CID002549 | |||
Tantalum |
H.C. Starck Inc. | UNITED STATES | CID002548 | |||
Tantalum |
H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | |||
Tantalum |
H.C. Starck GmbH Laufenburg | GERMANY | CID002546 | |||
Tantalum |
H.C. Starck GmbH Goslar | GERMANY | CID002545 | |||
Tantalum |
H.C. Starck Co., Ltd. | THAILAND | CID002544 | |||
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 | |||
Tungsten |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | |||
Tungsten |
H.C. Starck GmbH | GERMANY | CID002541 | |||
Tantalum |
Plansee SE Liezen | AUSTRIA | CID002540 | |||
Tantalum |
KEMET Blue Metals | MEXICO | CID002539 | |||
Tungsten |
Pobedit, JSC | RUSSIAN FEDERATION | CID002532 |
Tungsten |
Ganxian Shirui New Material Co., Ltd. | CHINA | CID002531 | |||
Tin |
PT Inti Stania Prima | INDONESIA | CID002530 | |||
Tin |
O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | |||
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | |||
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | |||
Tantalum |
FIR Metals & Resource Ltd. | CHINA | CID002505 | |||
Tin |
PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | |||
Tin |
Melt Metais e Ligas S/A | BRAZIL | CID002500 | |||
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | |||
Tungsten |
Jiangxi Richsea New Materials Co., Ltd. | CHINA | CID002493 | |||
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | |||
Tin |
Magnus Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | |||
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | |||
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | |||
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | |||
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | |||
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | |||
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | |||
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | |||
Gold |
Umicore Precious Metals Thailand | THAILAND | CID002314 | |||
Tungsten |
Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | |||
Gold |
Guangdong Jinding Gold Limited | CHINA | CID002312 | |||
Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 | |||
Gold |
Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | CID002243 | |||
Tungsten |
Zhuzhou Cemented Carbide Group Co Ltd | CHINA | CID002236 | |||
Tantalum |
Zhuzhou Cemented Carbide | CHINA | CID002232 | |||
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | |||
Tin |
Yunnan Tin Group (Holding) Company Limited | CHINA | CID002180 | |||
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | |||
Gold |
Yokohama Metal Co., Ltd. | JAPAN | CID002129 | |||
Gold |
Yamamoto Precious Metal Co., Ltd. | JAPAN | CID002100 | |||
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | |||
Tungsten |
Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | |||
Tungsten |
Wolfram Company CJSC | RUSSIAN FEDERATION | CID002047 | |||
Tungsten |
Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 | |||
Tin |
White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 | |||
Gold |
Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | |||
Gold |
Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | |||
Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 | |||
Gold |
Valcambi SA | SWITZERLAND | CID002003 | |||
Gold |
United Precious Metal Refining, Inc. | UNITED STATES | CID001993 | |||
Gold |
Umicore SA Business Unit Precious Metals Refining | BELGIUM | CID001980 | |||
Gold |
Umicore Brasil Ltda. | BRAZIL | CID001977 | |||
Tantalum |
Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | |||
Gold |
Torecom | KOREA, REPUBLIC OF | CID001955 | |||
Gold |
Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | |||
Gold |
Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | |||
Gold |
The Refinery of Shandong Gold Mining Co. Ltd | CHINA | CID001916 | |||
Gold |
The Great Wall Gold and Silver Refinery of China | CHINA | CID001909 | |||
Tin |
Thaisarco | THAILAND | CID001898 | |||
Tantalum |
Telex Metals | UNITED STATES | CID001891 | |||
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | |||
Gold |
Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | |||
Tantalum |
Taki Chemicals | JAPAN | CID001869 | |||
Gold |
Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | |||
Tantalum |
Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | |||
Gold |
Solar Applied Materials Technology Corp. | TAIWAN | CID001761 |
Tin |
Soft Metais Ltda. | BRAZIL | CID001758 | |||
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | |||
Gold |
So Accurate Group, Inc. | UNITED STATES | CID001754 | |||
Gold |
Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | |||
Tantalum |
Shanghai Jiangxi Metals Co. Ltd | CHINA | CID001634 | |||
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | |||
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | |||
Gold |
SEMPSA Joyería Platería SA | SPAIN | CID001585 | |||
Gold |
Schone Edelmetaal B.V. | NETHERLANDS | CID001573 | |||
Gold |
SAMWON METALS corp. | KOREA, REPUBLIC OF | CID001562 | |||
Gold |
Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | |||
Gold |
Sabin Metal Corp. | UNITED STATES | CID001546 | |||
Tin |
Rui Da Hung | TAIWAN | CID001539 | |||
Gold |
Royal Canadian Mint | CANADA | CID001534 | |||
Tantalum |
RFH Tantalum Smeltry Co., Ltd. | CHINA | CID001522 | |||
Gold |
Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | |||
Tantalum |
QuantumClean | UNITED STATES | CID001508 | |||
Gold |
PX Précinox SA | SWITZERLAND | CID001498 | |||
Tin |
PT Yinchendo Mining Industry | INDONESIA | CID001494 | |||
Tin |
PT Tinindo Inter Nusa | INDONESIA | CID001490 | |||
Tin |
PT Pelat Timah Nusantara Tbk | INDONESIA | CID001486 | |||
Tin |
PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 | |||
Tin |
PT Tambang Timah | INDONESIA | CID001477 | |||
Tin |
PT Supra Sukses Trinusa | INDONESIA | CID001476 | |||
Tin |
PT Sumber Jaya Indah | INDONESIA | CID001471 | |||
Tin |
PT Stanindo Inti Perkasa | INDONESIA | CID001468 | |||
Tin |
PT Seirama Tin Investment | INDONESIA | CID001466 | |||
Tin |
PT Sariwiguna Binasentosa | INDONESIA | CID001463 | |||
Tin |
PT Refined Bangka Tin | INDONESIA | CID001460 | |||
Tin |
PT Prima Timah Utama | INDONESIA | CID001458 | |||
Tin |
PT Panca Mega Persada | INDONESIA | CID001457 | |||
Tin |
PT Mitra Stania Prima | INDONESIA | CID001453 | |||
Tin |
PT Koba Tin | INDONESIA | CID001449 | |||
Tin |
PT Karimun Mining | INDONESIA | CID001448 | |||
Tin |
PT HP Metals Indonesia | INDONESIA | CID001445 | |||
Tin |
PT Fang Di MulTindo | INDONESIA | CID001442 | |||
Tin |
PT Eunindo Usaha Mandiri | INDONESIA | CID001438 | |||
Tin |
PT DS Jaya Abadi | INDONESIA | CID001434 | |||
Tin |
PT Bukit Timah | INDONESIA | CID001428 | |||
Tin |
PT BilliTin Makmur Lestari | INDONESIA | CID001424 | |||
Tin |
PT Belitung Industri Sejahtera | INDONESIA | CID001421 | |||
Tin |
PT Bangka Tin Industry | INDONESIA | CID001419 | |||
Tin |
PT Bangka Timah Utama Sejahtera | INDONESIA | CID001416 | |||
Tin |
PT Bangka Putra Karya | INDONESIA | CID001412 | |||
Tin |
PT Bangka Kudai Tin | INDONESIA | CID001409 | |||
Tin |
PT Babel Surya Alam Lestari | INDONESIA | CID001406 | |||
Tin |
PT Babel Inti Perkasa | INDONESIA | CID001402 | |||
Tin |
PT Artha Cipta Langgeng | INDONESIA | CID001399 | |||
Gold |
PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | |||
Tin |
PT Alam Lestari Kencana | INDONESIA | CID001393 | |||
Gold |
Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | |||
Tantalum |
Plansee | AUSTRIA | CID001368 | |||
Gold |
Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | |||
Gold |
PAMP SA | SWITZERLAND | CID001352 | |||
Tin |
Operaciones Metalurgical S.A. | BOLIVIA | CID001337 | |||
Gold |
OJSC Kolyma Refinery | RUSSIAN FEDERATION | CID001328 | |||
Gold |
OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) |
RUSSIAN FEDERATION | CID001326 |
Gold |
Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | |||
Gold |
Ohio Precious Metals, LLC | UNITED STATES | CID001322 | |||
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | |||
Tin |
Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION | CID001305 | |||
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | |||
Gold |
Nihon Material Co., Ltd. | JAPAN | CID001259 | |||
Gold |
Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | |||
Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 | |||
Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | CID001220 | |||
Gold |
Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | |||
Tantalum |
Molycorp Silmet A.S. | ESTONIA | CID001200 | |||
Gold |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | |||
Tantalum |
Mitsui Mining & Smelting | JAPAN | CID001192 | |||
Tin |
Mitsubishi Materials Corporation | JAPAN | CID001191 | |||
Gold |
Mitsubishi Materials Corporation | JAPAN | CID001188 | |||
Tin |
Minsur | PERU | CID001182 | |||
Tantalum |
Mineração Taboca S.A. | BRAZIL | CID001175 | |||
Tin |
Mineração Taboca S.A. | BRAZIL | CID001173 | |||
Tantalum |
Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | |||
Gold |
Metalor USA Refining Corporation | UNITED STATES | CID001157 | |||
Gold |
Metalor Technologies | SWITZERLAND | CID001153 | |||
Gold |
Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | |||
Gold |
Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | |||
Tin |
Metallo Chimique | BELGIUM | CID001143 | |||
Gold |
Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | |||
Gold |
Materion | UNITED STATES | CID001113 | |||
Tin |
Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | |||
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | |||
Gold |
LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | |||
Tantalum |
LSM Brasil S.A. | BRAZIL | CID001076 | |||
Tin |
Liuzhou China Tin | CHINA | CID001070 | |||
Tin |
Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | CID001063 | |||
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | |||
Gold |
Lingbao Gold Company Limited | CHINA | CID001056 | |||
Gold |
Lazurde Company For Jewelry | SAUDI ARABIA | CID001032 | |||
Gold |
Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | |||
Gold |
Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | CID000988 | |||
Gold |
Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | |||
Tantalum |
King-Tan Tantalum Industry Ltd. | CHINA | CID000973 | |||
Gold |
Kennecott Utah Copper LLC | UNITED STATES | CID000969 | |||
Tungsten |
Kennametal Fallon | UNITED STATES | CID000966 | |||
Gold |
Kazzinc | KAZAKHSTAN | CID000957 | |||
Tin |
Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | |||
Gold |
JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | |||
Gold |
JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | |||
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | |||
Gold |
Johnson Matthey Limited | CANADA | CID000924 | |||
Gold |
Asahi Refining USA Inc. | UNITED STATES | CID000920 | |||
Tantalum |
Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | |||
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | |||
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | |||
Tungsten |
Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | CID000868 | |||
Tin |
Jiangxi Nanshan | CHINA | CID000864 | |||
Gold |
Jiangxi Copper Company Limited | CHINA | CID000855 | |||
Tungsten |
Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Gold |
Japan Mint | JAPAN | CID000823 | |||
Gold |
Istanbul Gold Refinery | TURKEY | CID000814 | |||
Gold |
Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | |||
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | CID000801 | |||
Gold |
Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 | |||
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | |||
Gold |
Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | |||
Tungsten |
Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | |||
Tin |
Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | |||
Tantalum |
Hi-Temp Specialty Metals, Inc. | UNITED STATES | CID000731 | |||
Gold |
Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | |||
Tin |
Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | |||
Gold |
Heraeus Ltd. Hong Kong | HONG KONG | CID000707 | |||
Gold |
Heimerle + Meule GmbH | GERMANY | CID000694 | |||
Tungsten |
HC Starck GmbH | GERMANY | CID000683 | |||
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | |||
Tantalum |
H.C. Starck Group | GERMANY | CID000654 | |||
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | |||
Tungsten |
Global Tungsten & Powders Corp | UNITED STATES | CID000568 | |||
Tantalum |
Global Advanced Metals | UNITED STATES | CID000564 | |||
Tin |
Gejiu Zi-Li | CHINA | CID000555 | |||
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | |||
Gold |
Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | CID000522 | |||
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | |||
Gold |
OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | |||
Tin |
Fenix Metals | POLAND | CID000468 | |||
Tin |
Feinhütte Halsbrücke GmbH | GERMANY | CID000466 | |||
Tantalum |
F&X Electro-Materials Ltd. | CHINA | CID000460 | |||
Tantalum |
Exotech Inc. | UNITED STATES | CID000456 | |||
Tin |
Estanho de Rondônia S.A. | BRAZIL | CID000448 | |||
Tin |
EM Vinto | BOLIVIA | CID000438 | |||
Tantalum |
Duoluoshan | CHINA | CID000410 | |||
Tin |
Dowa | JAPAN | CID000402 | |||
Gold |
Dowa | JAPAN | CID000401 | |||
Gold |
DODUCO GmbH | GERMANY | CID000362 | |||
Gold |
DO SUNG CORPORATION | KOREA, REPUBLIC OF | CID000359 | |||
Tungsten |
Dayu Weiliang Tungsten Co., Ltd. | CHINA | CID000345 | |||
Gold |
Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | |||
Gold |
Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | |||
Tin |
CV United Smelting | INDONESIA | CID000315 | |||
Tin |
CV Serumpun Sebalai | INDONESIA | CID000313 | |||
Tin |
CV Nurjanah | INDONESIA | CID000309 | |||
Tin |
CV Makmur Jaya | INDONESIA | CID000308 | |||
Tin |
CV JusTindo | INDONESIA | CID000307 | |||
Tin |
PT Justindo | INDONESIA | CID000307 | |||
Tin |
CV Gita Pesona | INDONESIA | CID000306 | |||
Tin |
Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | CID000295 | |||
Tin |
Alpha | UNITED STATES | CID000292 | |||
Tantalum |
Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 | |||
Tin |
CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 | |||
Gold |
Chugai Mining | JAPAN | CID000264 | |||
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | |||
Tin |
Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 | |||
Gold |
China National Gold Group Corporation | CHINA | CID000242 | |||
Gold |
Chimet S.p.A. | ITALY | CID000233 | |||
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | |||
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
Gold |
Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | |||
Gold |
Cendres + Métaux SA | SWITZERLAND | CID000189 | |||
Gold |
CCR Refinery Glencore Canada Corporation | CANADA | CID000185 | |||
Gold |
Caridad | MEXICO | CID000180 | |||
Gold |
C. Hafner GmbH + Co. KG | GERMANY | CID000176 | |||
Gold |
Boliden AB | SWEDEN | CID000157 | |||
Gold |
Bauer Walser AG | GERMANY | CID000141 | |||
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | |||
Gold |
Aurubis AG | GERMANY | CID000113 | |||
Tungsten |
Kennametal Huntsville | UNITED STATES | CID000105 | |||
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | |||
Gold |
Asaka Riken Co., Ltd. | JAPAN | CID000090 | |||
Gold |
Asahi Pretec Corporation | JAPAN | CID000082 | |||
Gold |
Argor-Heraeus SA | SWITZERLAND | CID000077 | |||
Gold |
AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 | |||
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | |||
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | |||
Gold |
Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | |||
Gold |
Advanced Chemical Company | UNITED STATES | CID000015 | |||
Tungsten |
A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
We then used CFSIs SOR compliance status and mine country of origin data available to Woodward as a CFSI member with the following summary results: as of May 10, 2016, of the 267 identified SORs, 239 were eligible for CFSI audit. Another 193 of the SORs were determined by CFSI to be Compliant (DRC Conflict Free by audit or by a specific membership), and 12 other SORs are in communication with CFSI for audits. Mine country of origin data is available for only 121 of the 193 Compliant SORs and for 4 other SORs designated as Active. Twelve other Compliant SORs were determined to deal only in scrap or recycled material. Sixty Compliant SORs were audited by either the Responsible Jewelry Network or the London Bullion Market Association; mine country of origin data was not provided to CFSI.
In addition, the supplier CMRTs incorporated into the Woodward roll-up listed 1046 entities as smelters but which do not have a current CFSI ID number. This list is being reviewed and submitted to a conflict minerals solution provider with an extensive SOR database for a validity determination and conflict-free status indication, if available.
Smelter or Refiner Mine Country of Origin Results
Collectively, the 121 Compliant and 4 Active SORs source their minerals from the following mine countries of origin:
Argentina |
Madagascar | |
Australia |
Malaysia | |
Austria |
Mongolia | |
Belgium |
Myanmar | |
Bolivia |
Namibia | |
Brazil |
Netherlands | |
Cambodia |
Nigeria | |
Canada |
Peru | |
Chile |
Portugal | |
China |
Russia | |
Colombia |
Sierra Leone | |
Côte DIvoire |
Singapore | |
Czech Republic |
Slovakia | |
Djibouti |
South Korea | |
Ecuador |
Spain | |
Egypt |
Suriname | |
Estonia |
Switzerland |
Ethiopia |
Taiwan | |
France |
Thailand | |
Germany |
United Kingdom | |
Guyana |
United States of America | |
Hungary |
Vietnam | |
India |
Zimbabwe | |
Indonesia |
||
Ireland |
||
Israel |
||
Japan |
||
Kazakhstan |
||
Laos |
||
Luxembourg |
Concluding Statement
Woodward continues to make significant year-over-year progress relative to supplier conflict minerals response rates and with data analysis, SOR identification and mine COI through improvements in our due diligence activity and our association memberships. However, since Woodward has not yet achieved a 100% supplier response rate, as virtually all of our supplier responses are at a company level and not yet focused on Woodward specific parts, and because complete SOR conflict status and mine COI data is not yet available from centralized sources specializing in the collection and assessment of such data, Woodward does not have sufficiently complete or discriminating data at this time to confirm the conflict-free or may-not-be-conflict-free status of any of its product families or individual products. Woodward is continuing efforts and progress in 2016 on improvement actions described above, as well as conducting implementation activity on its product material compliance software application.