UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
INTERNATIONAL RECTIFIER CORPORATION
(Exact name of the registrant as specified in its charter)
Delaware |
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1-7935 |
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95-1528961 |
(State or other jurisdiction of |
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(Commission File Number) |
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(IRS Employer Identification No.) |
101 N. Sepulveda Blvd., El Segundo, California |
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90245 |
(Address of principal executive offices) |
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(Zip code) |
Tim Bixler (310) 726-8000 |
(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, 2013
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
CONFLICT MINERALS DISCLOSURE
The registrant International Rectifier Corporation (the Company) provides this specialized disclosure report (Report) for the calendar year ended December 31, 2013 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule), adopted by the Securities and Exchange Commission (SEC) to implement certain reporting and disclosure requirements related to conflict minerals as provided for by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Act). Certain terms in this Report not otherwise defined herein are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the SEC on August 22, 2012 (the Release) for such definitions. The summary descriptions of aspects of the Rule set out in this Report do not purport to be complete and are qualified in their entirety by reference to the full text of the Rule.
The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals (as defined below) which are necessary to the functionality or production of the registrants products, and excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain (as defined by the Rule) (together Covered Products). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict. Conflict minerals as that term is used under the Rule and in this Report include cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold.
If an SEC registrant can establish through a reasonable country of origin inquiry (as defined by the Rule, RCOI) completed by the registrant that the applicable conflict minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, they must file with the SEC a report on Form SD which describes the RCOI and its results.
If an SEC registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those conflict minerals, then the issuer must exercise due diligence on the conflict minerals source and chain of custody. The registrant must annually submit a report, referred to as a Conflict Minerals Report (CMR), to the SEC that includes a description of those due diligence measures.
The Company has manufactured and has contracted with third parties to manufacture Covered Products. The Company has conducted what it believes to be an RCOI and related due diligence as a result of its findings. Based on its RCOI, the Company knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Covered Countries and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources. Accordingly, the Company is filing with this Form SD the Companys CMR, attached hereto as Exhibit 1.02.
A copy of the Companys CMR is available at the Companys website under the heading CONFLICT MINERALS REPORT (at http://www.irf.com/aboutir-info/csr/conflict-minerals-report.pdf).
The Report presented herein is based on the Companys RCOI and related due diligence measures for the calendar year 2013 and is not audited. While the Company believes it has conducted an RCOI and related due diligence measures consistent with the Rule, the conclusions of its RCOI and due diligence are not free from doubt. As set out below, the conclusions reached by the Company are based on information available at the time and on representations and information provided by third parties, as well as publically available information, all of which is invariably subject to change and potentially inaccurate and/or incomplete. The Company reserves the right to modify or amend this Report from time to time should it believe circumstances warrant but undertakes no obligation to amend this Report except to the extent required under applicable law.
Item 1.02 Exhibit
Exhibit 1.02 is hereby incorporated into this item by reference.
Section 2 Exhibits
Item 2.01 Exhibits
Exhibit No. |
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Exhibit Description |
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Exhibit 1.02 |
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Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD. |
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 undersigned hereunto duly authorized.
Date: June 2, 2014 |
INTERNATIONAL RECTIFIER CORPORATION | ||
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By: |
/s/ Timothy E. Bixler | |
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Name: |
Timothy E. Bixler |
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Title: |
Vice President, General Counsel & Secretary |
Exhibit 1.02
International Rectifier Corporation
June 2, 2014
CONFLICT MINERALS REPORT
For the Year Ended December 31, 2013
in accord with Rule 13p-1 under the Securities Exchange Act of 1934
International Rectifier Corporation (the Company) provides this Conflict Minerals Report (Report) for the calendar year ended December 31, 2013 pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule), adopted by the Securities and Exchange Commission (SEC) to implement certain reporting and disclosure requirements related to conflict minerals as provided for by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Act). Certain terms in this Report not otherwise defined herein are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the SEC on August 22, 2012 (the Release) for such definitions. The summary descriptions of aspects of the Rule set out in this Report do not purport to be complete and are qualified in their entirety by reference to the full text of the Rule.
The Report presented herein is not audited as provided for under the Rule.
Introduction/Background. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals (as defined below) which are necessary to the functionality or production of the registrants products, and excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain (as defined by the Rule) (together Covered Products). These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict. Conflict minerals as that term is used under the Rule and in this report include cassiterite, columbite-tantalite (coltan), gold, wolframite, or their derivatives, which are limited to tin, tantalum, tungsten, and gold.
If an SEC registrant can establish through a reasonable country of origin inquiry (as defined by the Rule, RCOI) completed by the registrant that the applicable conflict minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, they must file with the SEC a report on Form SD which describes the RCOI and its results.
If an SEC registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in Covered Countries, or if they are unable to determine the country of origin of those conflict minerals, then the issuer must exercise due diligence on the conflict minerals source and chain of custody. The registrant must annually submit a report, referred to as a Conflict Minerals Report, to the SEC that includes a description of those due diligence measures.
The Company designs, manufactures and markets power management semiconductor products for a wide variety of applications. The Companys products include, among others, power metal oxide semiconductor field effect transistors (MOSFETs), high voltage analog and mixed signal integrated circuits, low voltage analog and mixed signal integrated circuits, digital integrated circuits, radiation-resistant power MOSFETs, insulated gate bipolar transistors, Gallium Nitride based power devices, high reliability DC-DC converters, digital controllers, integrated power modules, and automotive product packages. The Company has manufactured and has contracted with third parties to manufacture Covered Products. The Company has conducted what it believes to be an RCOI under the Rule. Set forth herein are the results of the Companys RCOI and related due diligences measures.
The report presented herein is based on the Companys RCOI for the calendar year 2013 and is not audited. While the Company believes it has conducted an RCOI and related due diligence measures consistent with the Rule, the conclusions of its RCOI and due diligence are not free from doubt. As set out below, the conclusions reached by the Company are based on information available at the time and on representations and information provided by third parties, as well as publically available information, all of which is invariably subject to change and potentially inaccurate and/or incomplete. The Company reserves the right to modify or amend this Report from time to time should it believe circumstances warrant but undertakes no obligation to amend this Report except to the extent required under applicable law.
RCOI and Due Diligence Program.
Design and Description of the Due Diligence Process for RCOI. The Company has designed its RCOI and related due diligence processes to conform materially with the framework of The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related supplements.
The Companys conflict minerals due diligence process includes: the establishment of strong company management systems, the identification and assessment of risks in the supply chain, designing and implementing a strategy to identified risks, the support of the use of independent audits of at smelters and refiners in the supply chain primarily through participation in industry groups and the reporting on supply chain due diligence.
Conflict Minerals Policy. The Company has adopted a company policy in respect of conflict minerals which is publically available at the Companys website at: http://www.irf.com/social-responsibility/conflict-minerals.
The Company believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if the Company determines that any supplier is, or a reasonable risk exists that it may be, violating this policy, then the Company intends to require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source (as defined by the Rule). If suitable action is not taken, the Company intends to look to alternative sources for the product and towards transitioning to alternative sources to the extent reasonably practical. The time frame for any such transition would depend on the criticality of the specific part and the availability of alternative suppliers. The Companys efforts are not to ban procurement of minerals from the Covered Countries, but to assure procurement from responsible sources.
Management and Controls. The Company has established a management system for complying with the Rule, which is part of the Companys overall corporate social responsibility program (CSRP). The Companys management system includes a team of subject matter experts from relevant functions such as purchasing, quality assurance, manufacturing and environmental health and safety. The team of subject matter experts is responsible for implementing the Companys conflict minerals compliance strategy, and the Companys CSRP manager also serves as the Companys conflict minerals program manager. Senior management is briefed about the results of the Companys due diligence efforts on a regular basis.
The Companys controls include its Code of Conduct which outlines expected behaviors for all Company employees. The Company has disseminated its Code of conduct to all its tier one suppliers and advised all such suppliers of the Companys expectation that they will abide by it.
The Company has established a mechanism to ensure the retention of relevant documentation related to its conflicts minerals program and RCOI.
Supplier Engagement and Reliance on Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain. Through the Companys procurement department, the Company has engaged with applicable suppliers to make them aware of the Companys conflicts minerals policy and to conduct outreach and communication with suppliers as part of the Companys RCOI.
As the Company typically does not have a direct relationship with conflict minerals smelters and refiners, the Company relies on its relationship with its direct suppliers, as well as its participation in industry-wide initiatives, such as the Electronic Industry Citizenship Coalition (EICC) e-Sustainability Initiatives (EICC-GeSI) Conflict Free Sourcing (CFS) Initiative (CFSI). IR joined the EICC in 2010 and remains an active member and participant. As an EICC member, the Company adopted and implemented the EICC Code of Conduct, which provides standards for labor, ethics, environmental, safety and health management systems, including those associated with conflict minerals. In addition, the Company is an active participant in the CFSI, and participated/benchmarked with other members in the initiative.
The Company does not perform direct audits of smelters or refiners that are the source of conflict minerals in its supply chain. However, the Company does rely upon the industry efforts (for example, through EICC and CFSI) to influence smelters and refineries to become audited and certified through CFSIs CFS program. As indicated below (under the caption RCOI Survey Responses) the Company often relies on the results of such third party audits.
Identification and Assessment of Risk in Supply Chain. Because of the size of the Company, the breath and complexity of its products and supply chain, it is often difficult to identify actors upstream from the Companys direct suppliers.
We also do not believe it practical to conduct a survey of all the Companys suppliers. Therefore, we conducted a survey based on a methodology we believed to be reasonably calculated to cover applicable suppliers for the purpose of the Rule. In order to compile the group of suppliers for a survey, the Company initially established a pool based on suppliers that together reached a certain threshold of the Companys aggregate purchases by its manufacturing locations. For its RCOI analysis, the Company used a threshold of 80% of such supplier purchases having taken place during the Companys fiscal year ending June 30, 2013 (FY13) (and using the Companys expenditure on the basis of the applicable product manufacturer in certain instances where product was purchased through distribution). The Company believes the 80% threshold level to be reasonable under the circumstances. While this pool of suppliers would be based on some purchases made earlier than January 1, 2013, the Company believed that the suppliers would be representative of supply for the applicable January 1 through December 31, 2013 reporting period under the Rule.
This initial supplier pool yielded 71 suppliers. The Company added an additional 26 suppliers to this pool following a qualitative review of the remaining 20% of supplier purchases by the Companys manufacturing sites during FY13, based on the strategic importance of the nature or materials of the supply and/or the supplier itself. From this pool of 97 suppliers, 42 suppliers were removed for various reasons as not coming within the scope of the Rule, such as (i) confirmation that no metal of any kind was included in the supply, or (ii) the supply being in the nature of manufacturing equipment and not materials of production, yielding a total of 55 suppliers who were subject to the Companys RCOI.
RCOI Survey. The Company conducted a survey of the 55 suppliers described above (under the caption Identification and Assessment of Risk in Supply Chain) using the template developed jointly by the companies of Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the CFSI Reporting Template (the Template). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a companys supply chain. It includes questions regarding a companys conflict-free policy, engagement with its direct suppliers, and a listing of the smelters or refiners (which for ease of reference we refer to as smelters in our discussion) the Company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSIs website. The Template is being adopted by many companies in their due diligence processes related to conflict minerals. In addition to the Template, in some circumstances, the Company also obtained smelter or conflict minerals information from the original manufacturer by means of the manufacturers form of documentation, letters from the manufacturer or other public documentation issued by the manufacturer. The Company relied on the responses and other information from these 55 suppliers for information about the source of conflict minerals contained in the Companys supply chain. In many cases, the Companys direct suppliers are likely similarly reliant upon information provided to them by their suppliers. In addition to information provided by suppliers, as noted below, the Company has been able to obtain information in respect of applicable smelters from industry and other sources.
RCOI Survey Responses. The Company received responses or other information in respect of all 55 suppliers that were part of the Companys inquiry. 33 of the suppliers self-certified that conflict minerals were not being supplied to the Company from Covered Countries, and the remaining 22 suppliers (Non-certifying Suppliers) provided smelter information for the relevant conflict minerals applicable to their supply to the Company. A summary of the results is set forth below:
# of |
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Suppliers Self-Certified |
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Suppliers Supplying Named |
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55 |
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33 |
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22 |
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The 22 Non-certifying Suppliers provided the Company with the names and locations of 156 smelters potentially applicable to their supply to the Company. Because some suppliers did not provide traceability for the specific materials provided to the Company, the group of 156 smelters invariably includes smelters not related to the Companys supply; however, the Company extended its due diligence to the entire group of smelters. A summary of the Companys due diligence in respect of these 156 smelters is set forth in the following table and the discussion that follows:
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Total Smelters from Non- certifying Suppliers |
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Number of Smelters CFSI Certified |
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Number of Smelters |
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Number of Smelters |
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Number of Smelters Located Outside Covered Countries and in Low Risk Area |
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All Other Smelters (All Outside Covered Countries) |
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No. of Smelters |
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156 |
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70 |
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10 |
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2 |
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54 |
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20 |
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Category % of Total |
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45 |
% |
6 |
% |
1 |
% |
35 |
% |
13 |
% |
Cumulative % of Total |
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45 |
% |
51 |
% |
53 |
% |
87 |
% |
100 |
% |
Of these 156 smelters, on the basis of the Companys due diligence, the Company believes (i) 70 are identified on the published list of CFS program certified smelters by CFSI; and (ii) 10 are identified on CFSIs published list of smelters currently undergoing certification (or having agreed to a CFSI or independent audit) and not located in Covered Countries (and of these 10 smelters, 8 smelters are located in what the U.S. Geological Survey, Mineral Commodity Summaries 2013 noted below indicates are countries with high reserves of the applicable conflict mineral). The Company believes that the risk associated with these 80 smelters is low due to their certification by CFSI or voluntary involvement in the CFSI certification process (in the latter case coupled with their location being outside of any Covered Country). Although certain of the smelters that are identified by CFSI as being certified source or may source Conflict Minerals from Covered Countries, additional diligence is needed to determine the specific smelters applicable to the Companys products and whether the source was recycled or scrap.
An additional 2 smelters are publicly identified as having passed a third party audit conducted by an industry leader in the CFSI initiative.
Of the remaining 74 smelters, the Companys research indicates none are located in Covered Countries. Moreover, the Company has reviewed public information from the U.S. Geological Survey, Mineral Commodity Summaries 2013 (http://minerals.usgs.gov/minerals/pubs/mcs/2013/mcs2013.pdf) indicating that the location country for 54 of the 74 smelters contain a high reserve of the applicable conflict mineral, which the Company believes further reduces the risk that the applicable smelter may be importing conflict mineral from Covered Countries for use in their supply to the Company. For the 20 smelters not located in such high reserve countries, the Company estimates that the Companys purchases in respect of applicable suppliers represented less than 5% of the Companys aggregate FY13 purchases by its manufacturing locations.
The Company believes that the RCOI process it undertook was a good faith and reasonable effort. We note that the guidance included in the Release promulgated by the SEC states, among other things, as follows:
· The issuer is not required to receive representations from all of its suppliers. The standard focuses on reasonable design and good faith inquiry (at page 149).
· The reasonable country of origin inquiry standard does not require an issuer to determine to a certainty that all its conflict minerals did not originate in the Covered Countries because the standard required is a reasonable inquiry, and requiring a certainty in this setting would not be reasonable and may impose undue costs (at page 151).
CFSI Certified Smelter List. Based on the Companys RCOI and follow-on due diligence, set forth below is what the Company believes to be the list of 70 CFSI certified smelters referenced above:
Metal |
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Standard Smelter Names |
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Smelter Facility |
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Smelter ID |
Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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GERMANY |
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CID000035 |
Gold |
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AngloGold Ashanti Córrego do Sítio Minerção |
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BRAZIL |
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CID000058 |
Gold |
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Argor-Heraeus SA |
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SWITZERLAND |
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CID000077 |
Gold |
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Asahi Pretec Corporation |
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JAPAN |
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CID000082 |
Gold |
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Chimet S.p.A. |
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ITALY |
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CID000233 |
Gold |
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Dowa |
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JAPAN |
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CID000401 |
Gold |
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Heimerle + Meule GmbH |
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GERMANY |
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CID000694 |
Gold |
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Heraeus Ltd. Hong Kong |
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HONG KONG |
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CID000707 |
Gold |
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Heraeus Precious Metals GmbH & Co. KG |
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GERMANY |
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CID000711 |
Gold |
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Ishifuku Metal Industry Co., Ltd. |
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JAPAN |
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CID000807 |
Gold |
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Johnson Matthey Inc |
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UNITED STATES |
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CID000920 |
Gold |
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Johnson Matthey Ltd |
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CANADA |
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CID000924 |
Gold |
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JX Nippon Mining & Metals Co., Ltd. |
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JAPAN |
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CID000937 |
Gold |
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Kennecott Utah Copper LLC |
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UNITED STATES |
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CID000969 |
Gold |
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Kojima Chemicals Co., Ltd |
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JAPAN |
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CID000981 |
Gold |
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LS-NIKKO Copper Inc. |
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KOREA, REPUBLIC OF |
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CID001078 |
Gold |
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Materion |
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UNITED STATES |
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CID001113 |
Gold |
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Matsuda Sangyo Co., Ltd. |
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JAPAN |
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CID001119 |
Gold |
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Metalor Technologies (Hong Kong) Ltd |
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HONG KONG |
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CID001149 |
Gold |
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Metalor Technologies SA |
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SWITZERLAND |
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CID001153 |
Gold |
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Metalor USA Refining Corporation |
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UNITED STATES |
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CID001157 |
Gold |
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Mitsubishi Materials Corporation |
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JAPAN |
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CID001188 |
Gold |
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Mitsui Mining and Smelting Co., Ltd. |
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JAPAN |
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CID001193 |
Gold |
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Nihon Material Co. LTD |
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JAPAN |
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CID001259 |
Gold |
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Ohio Precious Metals, LLC |
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UNITED STATES |
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CID001322 |
Gold |
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Rand Refinery (Pty) Ltd |
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SOUTH AFRICA |
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CID001512 |
Gold |
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Royal Canadian Mint |
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CANADA |
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CID001534 |
Gold |
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SEMPSA Joyería Platería SA |
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SPAIN |
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CID001585 |
Gold |
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Solar Applied Materials Technology Corp. |
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TAIWAN |
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CID001761 |
Gold |
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Sumitomo Metal Mining Co., Ltd. |
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JAPAN |
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CID001798 |
Gold |
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Tanaka Kikinzoku Kogyo K.K. |
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JAPAN |
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CID001875 |
Gold |
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Tokuriki Honten Co., Ltd |
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JAPAN |
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CID001938 |
Gold |
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Umicore SA Business Unit Precious Metals Refining |
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BELGIUM |
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CID001980 |
Gold |
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United Precious Metal Refining, Inc. |
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UNITED STATES |
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CID001993 |
Gold |
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Valcambi SA |
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SWITZERLAND |
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CID002003 |
Gold |
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Western Australian Mint trading as The Perth Mint |
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AUSTRALIA |
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CID002030 |
Tantalum |
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Duoluoshan |
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CHINA |
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CID000410 |
Tantalum |
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Exotech Inc. |
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UNITED STATES |
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CID000456 |
Tantalum |
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F&X Electro-Materials Ltd. |
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CHINA |
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CID000460 |
Tantalum |
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Global Advanced Metals |
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UNITED STATES |
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CID000564 |
Tantalum |
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H.C. Starck Group |
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UNITED STATES |
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CID000654 |
Tantalum |
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H.C. Starck Group |
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JAPAN |
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CID000654 |
Tantalum |
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H.C. Starck Group |
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THAILAND |
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CID000654 |
Tantalum |
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H.C. Starck Group |
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GERMANY |
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CID000654 |
Tantalum |
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Hi-Temp |
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UNITED STATES |
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CID000731 |
Tantalum |
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Kemet Blue Powder |
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UNITED STATES |
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CID000963 |
Tantalum |
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Mitsui Mining & Smelting |
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JAPAN |
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CID001192 |
Tantalum |
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Ningxia Orient Tantalum Industry Co., Ltd. |
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CHINA |
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CID001277 |
Tantalum |
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Plansee |
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AUSTRIA |
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CID001368 |
Tantalum |
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RFH Tantalum Smeltry Co., Ltd |
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CHINA |
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CID001522 |
Tantalum |
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Solikamsk Metal Works |
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RUSSIAN FEDERATION |
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CID001769 |
Tantalum |
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Taki Chemicals |
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JAPAN |
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CID001869 |
Tantalum |
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Tantalite Resources |
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SOUTH AFRICA |
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CID001879 |
Tantalum |
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Telex |
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UNITED STATES |
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CID001891 |
Tantalum |
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Ulba |
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KAZAKHSTAN |
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CID001969 |
Tantalum |
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Zhuzhou Cement Carbide |
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CHINA |
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CID002232 |
Tin |
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Alpha |
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UNITED STATES |
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CID000292 |
Tin |
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Gejiu Non-Ferrous Metal Processing Co. Ltd. |
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CHINA |
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CID000538 |
Tin |
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Malaysia Smelting Corporation (MSC) |
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MALAYSIA |
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CID001105 |
Tin |
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Mineração Taboca S.A. |
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BRAZIL |
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CID001173 |
Tin |
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Minsur |
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PERU |
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CID001182 |
Tin |
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Mitsubishi Materials Corporation |
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JAPAN |
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CID001191 |
Tin |
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OMSA |
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BOLIVIA |
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CID001337 |
Tin |
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PT Bukit Timah |
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INDONESIA |
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CID001428 |
Tin |
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PT Tambang Timah |
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INDONESIA |
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CID001477 |
Tin |
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PT Timah |
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INDONESIA |
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CID001482 |
Tin |
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Thaisarco |
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THAILAND |
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CID001898 |
Tin |
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White Solder Metalurgia e Mineração Ltda. |
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BRAZIL |
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CID002036 |
Tin |
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Yunnan Tin Company, Ltd. |
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CHINA |
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CID002180 |
Tungsten |
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Global Tungsten & Powders Corp. |
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UNITED STATES |
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CID000568 |
Continuing Due Diligence and Risk Mitigation Measures. The Company considers its due diligence an ongoing process and intends to continue its due diligence program for conflict minerals, including its involvement in industry groups, like the EICC, to monitor improvements in data visibility and changes that may develop from time to time, including an increased level of smelter certification and visibility as to the specific products supplied to the Company. Also, the Company intends to continue its contacts with its supplier base in order to monitor developments with their due diligence programs and efforts to secure additional documentation and/or validation of their supply chains for the products the Company purchases from them.