UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
SUPREME INDUSTRIES, INC.
(Exact name of registrant as specified in its charter)
Delaware |
|
1-8183 |
|
75-1670945 |
(State or other jurisdiction of incorporation) |
|
(Commission File Number) |
|
(IRS Employer Identification No.) |
2581 E. Kercher Road Goshen, Indiana |
|
|
(Address of principal executive offices) |
|
(Zip Code) |
John W. Dorbin, Jr. (574) 642-4889
(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, 2016.
Company Profile:
Supreme Industries, Inc., a Delaware corporation (we, our, us, Supreme, or the Company), is one of the nations leading manufacturers of specialized vehicles including truck bodies and specialty vehicles. Supreme manufactures specialized commercial vehicles that are attached to a truck chassis. The truck chassis, which consists of an engine, drivetrain, a frame with wheels, and in some cases a cab, is manufactured by third parties who are major automotive or truck companies.
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with the disclosure requirements promulgated by the U.S. Securities and Exchange Commission (SEC), we have undertaken efforts to determine the source of conflict minerals(1) necessary to the functionality or production of our products for the period from January 1 to December 31, 2016.
As is required, we have conducted a good faith reasonable country of origin inquiry (RCOI) to determine whether the necessary conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively the Covered Countries) or came from recycled or scrap sources.
Supreme Industries Inc.s RCOI process included conducting an inquiry of our direct suppliers using the Conflict-Free Sourcing Initiatives Conflict Minerals Reporting Template. We relied upon our suppliers representations, in the format provided by the suppliers, regarding the origin of their minerals and their smelter data to determine the source of the conflict minerals within our supply chain, and we performed due diligence on the source and chain of custody of the conflict minerals.
The Company has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report, which appears as Exhibit 1.01 hereto and is publicly available on the Companys website at www.supremecorp.com.
Item 1.02 Exhibit
The Companys Conflict Minerals Report is provided as Exhibit 1.01 hereto.
Section 2 Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report.
Exhibit 1.01 Supreme Industries Inc.s Conflict Minerals Report for the period January 1 to December 31, 2016 as required by Items 1.01 and 1.02 of this Form.
*****
(1) The term conflict mineral is defined in Form SD as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries).
Exhibit 1.01
CONFLICT MINERALS REPORT OF
SUPREME INDUSTRIES, INC.
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2016
I. Introduction
This is the Conflict Minerals(1) Report of Supreme Industries, Inc. (we, our, us, Supreme, or the Company) prepared for calendar year 2016 in accordance with Rule 13p-1 (Rule 13p-1) under the Securities Exchange Act of 1934 (the Act). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Release No. 34-67716 (August 22, 2012) (the Adopting Release) for such definitions.
In accordance with Rule 13p-1, we undertook efforts to determine whether the necessary conflict minerals in our products were or were not DRC conflict-free. The Company designed its efforts in conformity, with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas(2) (OECD Due Diligence Guidance) and related Supplements.
The statements below are based on the reasonable country of origin inquiry (RCOI) and due diligence performed, in good faith, by Supreme and on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier or smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the Securities and Exchange Commission (SEC) final rules, all instances of conflict minerals necessary to the functionality or manufacturing of Supremes products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the relevant protocols, oversights or errors in conflict free smelter audits, Covered Countries sourced materials being declared secondary materials, companies going out of business in 2016, certification programs being not equally advanced for all industry segments and metals, and smuggling of conflict minerals from the Covered Countries to countries beyond the Covered Countries.
(1) The term conflict mineral is defined in Form SD as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries).
(2) OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264252479-en
II. Overview
Company Profile
We are subject to this rule as we have determined that, during 2016, conflict minerals were likely necessary to the functionality or production of products we manufactured or contracted to manufacture. The Company, as purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we conduct no purchasing activities directly in the Covered Countries.
Conflict Minerals Policy
Supreme developed a policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights Supremes commitment to complying with the reporting and due diligence obligations required by the SEC rule and Supremes expectations from its suppliers. The policy resides on our corporate website (http://investor.supremecorp.com)
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (RCOI) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
Supremes RCOI process included conducting an inquiry of our direct suppliers using the Conflict-Free Sourcing Initiatives (CFSI) Conflict Minerals Reporting Template (CMRT). Based on the results of our RCOI which indicated sourcing from the Covered Countries, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD framework. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a downstream company:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refinery due diligence practices
Step 5: Report annually on supply chain due diligence.
III. Due Diligence Measures Performed by Supreme Industries, Inc.
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management systems
a. Conflict minerals team Supreme established a conflict minerals team that includes individuals from the appropriate business departments, including legal, accounting, and procurement. The team was structured to ensure critical information, including the Company policy, reached relevant employees and suppliers.
b. Conflict minerals policy Supreme adopted and published a policy establishing the expectations of our suppliers. The policy can be found at www.supremecorp.com. It is periodically reviewed and will be updated, if necessary.
c. Internal engagement We held internal meetings to educate relevant employees on our conflict minerals program and reporting obligations.
d. Supplier engagement Supreme provided educational information to our queried suppliers. Suppliers were provided information on the conflict minerals disclosure requirements as well as our internal process for developing, implementing, and documenting a conflict minerals compliance program.
e. Company level grievance mechanism As recommended by the OECD Due Diligence Guidance, Supreme established a grievance mechanism as a risk-awareness system for conflict minerals issues. All Supreme employees and suppliers can communicate directly and confidentially with our general counsels office.
f. Records management Supreme maintains records relating to our conflict minerals program in accordance with the recommended record retention guidelines.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a. Identified products in scope Our conflict minerals team conducted a review of the products manufactured or contracted to be manufactured during the period from January 1 to December 31, 2016 to identify products that should be deemed in-scope as described by the Adopting Release.
b. Conducted RCOI Supreme utilized the industry-developed CMRT to query for conflict minerals information the suppliers who provide material and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI.
c. Completed additional follow-up Supreme contacted direct suppliers that did not respond to our request for conflict minerals information by the requested date. We also worked to clarify and validate the information provided by our suppliers.
d. Identify smelters/processors Supreme collected a list of smelters/processors that are in our supply chain by utilizing the CMRT.
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a. Designed and implemented a plan Supreme established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT as well as any additional documentation furnished to support those responses. The resulting risk ratings were used to develop specific supplier outreach and education to address the identified risks.
b. Verify smelters As part of the risk mitigation process, the Company reconciled the list of smelters collected from suppliers to the list of smelter facilities designated as conflict-free by the Conflict-Free Sourcing Initiatives (CFSI) Conflict-Free Smelter Program. We have provided a list of our smelters and their designation according to the CFSIs Conflict-Free Smelter Program under Processing Facilities.
Step 4: Carry out independent third-party audit of smelter / refiners due diligence practices
The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals, as well as the smelters and refiners who provide minerals and ore. The Company does not purchase raw ore or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries. The Company relies upon the smelter or refiner information compiled by the CFSI.
Step 5: Report on supply chain due diligence
The Company reports on our supply chain due diligence policies and practices by filing a Form SD and Conflict Minerals Report, if necessary, with the SEC, as required. Accordingly, this Conflict Minerals Report has been filed with the SEC and has been made publicly available on our website at www.supremecorp.com.
IV. Product Description
Supreme manufactures specialized commercial vehicles that are attached to a truck chassis, including truck bodies, trolleys, and specialty vehicles. The truck chassis, which consists of an engine, drivetrain, a frame with wheels, and in some cases a cab, is manufactured by third parties who are major automotive or truck companies. Supreme integrates a wide range of options into its products including liftgates, back-up cameras, security systems, remote locks, lighting, and refrigeration equipment, and other custom equipment at the request of customers. Both the chassis and various components of Supremes products may contain conflict minerals.
V. Product Determination
On the basis of the due diligence process described above, the suppliers surveyed identified certain smelters and processors whose sourcing of conflict minerals remains undetermined, as reflected in the list under Processing Facilities. Not all of our products contain conflict minerals, nor do all of our products which contain conflict minerals use conflict minerals processed from facilities categorized as undetermined in the list.
Processing Facilities Based on our due diligence process and the information received from our suppliers, the following facilities may have been used to process conflict minerals used in our products.
Metal |
|
Smelter Name |
|
Country |
|
Status |
Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Abington Reldan Metals, LLC |
|
UNITED STATES OF AMERICA |
|
Not Determined |
Tungsten |
|
ACL Metais Eireli |
|
BRAZIL |
|
Not Determined |
Gold |
|
Advanced Chemical Company |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Aida Chemical Industries Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Al Etihad Gold Refinery DMCC |
|
UNITED ARAB EMIRATES |
|
Conflict-Free |
Gold |
|
Allgemeine Gold-und Silberscheideanstalt A.G. |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Almalyk Mining and Metallurgical Complex (AMMC) |
|
UZBEKISTAN |
|
Conflict-Free |
Tin |
|
Alpha |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
An Thai Minerals Co., Ltd. |
|
VIET NAM |
|
Not Determined |
Tin |
|
An Vinh Joint Stock Mineral Processing Company |
|
VIET NAM |
|
Not Determined |
Gold |
|
Argor-Heraeus S.A. |
|
SWITZERLAND |
|
Conflict-Free |
Gold |
|
Asaka Riken Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
VIET NAM |
|
Conflict-Free |
Gold |
|
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
|
TURKEY |
|
Not Determined |
Gold |
|
AU Traders and Refiners |
|
SOUTH AFRICA |
|
Conflict-Free |
Gold |
|
Aurubis AG |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Bangalore Refinery |
|
INDIA |
|
Not Determined |
Gold |
|
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
|
PHILIPPINES |
|
Conflict-Free |
Gold |
|
Boliden AB |
|
SWEDEN |
|
Conflict-Free |
Gold |
|
C. Hafner GmbH + Co. KG |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Caridad |
|
MEXICO |
|
Not Determined |
Gold |
|
CCR Refinery - Glencore Canada Corporation |
|
CANADA |
|
Conflict-Free |
Gold |
|
Cendres + Métaux S.A. |
|
SWITZERLAND |
|
Not Determined |
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Chimet S.p.A. |
|
ITALY |
|
Conflict-Free |
Tin |
|
China Tin Group Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Chugai Mining |
|
JAPAN |
|
Not Determined |
Tin |
|
CNMC (Guangxi) PGMA Co., Ltd. |
|
CHINA |
|
Not Determined |
Tantalum |
|
Conghua Tantalum and Niobium Smeltry |
|
CHINA |
|
Conflict-Free |
Tin |
|
Cooperativa Metalurgica de Rondônia Ltda. |
|
BRAZIL |
|
Conflict-Free |
Tin |
|
CV Ayi Jaya |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV Dua Sekawan |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV Gita Pesona |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV Serumpun Sebalai |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV Tiga Sekawan |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV United Smelting |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
CV Venus Inti Perkasa |
|
INDONESIA |
|
Conflict-Free |
Tantalum |
|
D Block Metals, LLC |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Daejin Indus Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Gold |
|
Daye Non-Ferrous Metals Mining Ltd. |
|
CHINA |
|
Not Determined |
Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
DODUCO GmbH |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Dowa |
|
JAPAN |
|
Conflict-Free |
Gold |
|
DSC (Do Sung Corporation) |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Tantalum |
|
Duoluoshan |
|
CHINA |
|
Conflict-Free |
Gold |
|
Eco-System Recycling Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tin |
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
|
VIET NAM |
|
Not Determined |
Tin |
|
EM Vinto |
|
BOLIVIA |
|
Conflict-Free |
Gold |
|
Emirates Gold DMCC |
|
UNITED ARAB EMIRATES |
|
Conflict-Free |
Tin |
|
Estanho de Rondônia S.A. |
|
BRAZIL |
|
Not Determined |
Tantalum |
|
Exotech Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tantalum |
|
F&X Electro-Materials Ltd. |
|
CHINA |
|
Conflict-Free |
Tin |
|
Fenix Metals |
|
POLAND |
|
Conflict-Free |
Tantalum |
|
FIR Metals & Resource Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Gansu Seemine Material Hi-Tech Co., Ltd. |
|
CHINA |
|
Not Determined |
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Ganzhou Yatai Tungsten Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Geib Refining Corporation |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
Gejiu Fengming Metallurgy Chemical Plant |
|
CHINA |
|
Conflict-Free |
Tin |
|
Gejiu Jinye Mineral Company |
|
CHINA |
|
Conflict-Free |
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
CHINA |
|
Not Determined |
Tin |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tin |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
CHINA |
|
Not Determined |
Tin |
|
Gejiu Zili Mining And Metallurgy Co., Ltd. |
|
CHINA |
|
Not Determined |
Tantalum |
|
Global Advanced Metals Aizu |
|
JAPAN |
|
Conflict-Free |
Tantalum |
|
Global Advanced Metals Boyertown |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tungsten |
|
Global Tungsten & Powders Corp. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Great Wall Precious Metals Co., Ltd. of CBPM |
|
CHINA |
|
Not Determined |
Gold |
|
Guangdong Jinding Gold Limited |
|
CHINA |
|
Not Determined |
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tin |
|
Guanyang Guida Nonferrous Metal Smelting Plant |
|
CHINA |
|
Conflict-Free |
Gold |
|
Gujarat Gold Centre |
|
INDIA |
|
Not Determined |
Gold |
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
|
CHINA |
|
Not Determined |
Tantalum |
|
H.C. Starck Co., Ltd. |
|
THAILAND |
|
Conflict-Free |
Tantalum |
|
H.C. Starck Hermsdorf GmbH |
|
GERMANY |
|
Conflict-Free |
Tantalum |
|
H.C. Starck Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tantalum |
|
H.C. Starck Ltd. |
|
JAPAN |
|
Conflict-Free |
Tantalum |
|
H.C. Starck Smelting GmbH & Co. KG |
|
GERMANY |
|
Conflict-Free |
Tantalum |
|
H.C. Starck Tantalum and Niobium GmbH |
|
GERMANY |
|
Conflict-Free |
Tungsten |
|
H.C. Starck Tungsten GmbH |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Hangzhou Fuchunjiang Smelting Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Heimerle + Meule GmbH |
|
GERMANY |
|
Conflict-Free |
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Heraeus Metals Hong Kong Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Heraeus Precious Metals GmbH & Co. KG |
|
GERMANY |
|
Conflict-Free |
Tantalum |
|
Hi-Temp Specialty Metals, Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
HuiChang Hill Tin Industry Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tin |
|
Huichang Jinshunda Tin Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
HwaSeong CJ Co., Ltd. |
|
KOREA (REPUBLIC OF) |
|
Not Determined |
Tungsten |
|
Hydrometallurg, JSC |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Ishifuku Metal Industry Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Istanbul Gold Refinery |
|
TURKEY |
|
Conflict-Free |
Gold |
|
Japan Mint |
|
JAPAN |
|
Conflict-Free |
Tungsten |
|
Japan New Metals Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Jiangxi Copper Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
|
CHINA |
|
Not Determined |
Tantalum |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tin |
|
Jiangxi Ketai Advanced Material Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Not Determined |
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Jiangxi Tuohong New Raw Material |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
JSC Uralelectromed |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
JX Nippon Mining & Metals Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Kazakhmys Smelting LLC |
|
KAZAKHSTAN |
|
Not Determined |
Gold |
|
Kazzinc |
|
KAZAKHSTAN |
|
Conflict-Free |
Tantalum |
|
KEMET Blue Metals |
|
MEXICO |
|
Conflict-Free |
Tantalum |
|
KEMET Blue Powder |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tungsten |
|
Kennametal Fallon |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tungsten |
|
Kennametal Huntsville |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Kennecott Utah Copper LLC |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
KGHM Polska Miedź Spółka Akcyjna |
|
POLAND |
|
Not Determined |
Tantalum |
|
King-Tan Tantalum Industry Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Kojima Chemicals Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Korea Zinc Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Gold |
|
Kyrgyzaltyn JSC |
|
KYRGYZSTAN |
|
Conflict-Free |
Gold |
|
Lingbao Gold Company Limited |
|
CHINA |
|
Not Determined |
Gold |
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
|
CHINA |
|
Not Determined |
Tantalum |
|
LSM Brasil S.A. |
|
BRAZIL |
|
Conflict-Free |
Gold |
|
LS-NIKKO Copper Inc. |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Gold |
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
|
CHINA |
|
Not Determined |
Tin |
|
Magnus Minerais Metais e Ligas Ltda. |
|
BRAZIL |
|
Conflict-Free |
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
MALAYSIA |
|
Conflict-Free |
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Materion |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Matsuda Sangyo Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tin |
|
Melt Metais e Ligas S.A. |
|
BRAZIL |
|
Conflict-Free |
Tin |
|
Metallic Resources, Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
Metallo Belgium N.V. |
|
BELGIUM |
|
Conflict-Free |
Tantalum |
|
Metallurgical Products India Pvt., Ltd. |
|
INDIA |
|
Conflict-Free |
Gold |
|
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
|
Mexico |
|
Conflict-Free |
Tin |
|
Mineração Taboca S.A. |
|
BRAZIL |
|
Conflict-Free |
Tin |
|
Minsur |
|
PERU |
|
Conflict-Free |
Gold |
|
Mitsubishi Materials Corporation |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Mitsui Mining and Smelting Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
MMTC-PAMP India Pvt., Ltd. |
|
INDIA |
|
Conflict-Free |
Gold |
|
Modeltech Sdn Bhd |
|
MALAYSIA |
|
Not Determined |
Tungsten |
|
Moliren Ltd |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
Morris and Watson |
|
NEW ZEALAND |
|
Not Determined |
Gold |
|
Moscow Special Alloys Processing Plant |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
|
TURKEY |
|
Conflict-Free |
Tin |
|
Nankang Nanshan Tin Manufactory Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Navoi Mining and Metallurgical Combinat |
|
UZBEKISTAN |
|
Not Determined |
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
Not Determined |
Tungsten |
|
Niagara Refining LLC |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Nihon Material Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
NPM Silmet AS |
|
ESTONIA |
|
Conflict-Free |
Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
|
VIET NAM |
|
Conflict-Free |
Tin |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
THAILAND |
|
Conflict-Free |
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
PHILIPPINES |
|
Conflict-Free |
Gold |
|
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
|
AUSTRIA |
|
Conflict-Free |
Gold |
|
Ohura Precious Metal Industry Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
OJSC Novosibirsk Refinery |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Tin |
|
Operaciones Metalurgical S.A. |
|
BOLIVIA |
|
Conflict-Free |
Gold |
|
PAMP S.A. |
|
SWITZERLAND |
|
Conflict-Free |
Gold |
|
Penglai Penggang Gold Industry Co., Ltd. |
|
CHINA |
|
Not Determined |
Tungsten |
|
Philippine Chuangxin Industrial Co., Inc. |
|
PHILIPPINES |
|
Conflict-Free |
Gold |
|
Prioksky Plant of Non-Ferrous Metals |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
PT Aneka Tambang (Persero) Tbk |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Aries Kencana Sejahtera |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Artha Cipta Langgeng |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Babel Inti Perkasa |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Bangka Prima Tin |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Bangka Tin Industry |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Belitung Industri Sejahtera |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Bukit Timah |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT DS Jaya Abadi |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Eunindo Usaha Mandiri |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Inti Stania Prima |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Karimun Mining |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Kijang Jaya Mandiri |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Mitra Stania Prima |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT O.M. Indonesia |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Panca Mega Persada |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Prima Timah Utama |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Refined Bangka Tin |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Sariwiguna Binasentosa |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Stanindo Inti Perkasa |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Sukses Inti Makmur |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Sumber Jaya Indah |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Timah (Persero) Tbk Kundur |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Timah (Persero) Tbk Mentok |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Tinindo Inter Nusa |
|
INDONESIA |
|
Conflict-Free |
Tin |
|
PT Tommy Utama |
|
INDONESIA |
|
Conflict-Free |
Gold |
|
PX Précinox S.A. |
|
SWITZERLAND |
|
Conflict-Free |
Tantalum |
|
QuantumClean |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Rand Refinery (Pty) Ltd. |
|
SOUTH AFRICA |
|
Conflict-Free |
Gold |
|
Remondis Argentia B.V. |
|
NETHERLANDS |
|
Not Determined |
Gold |
|
Republic Metals Corporation |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
Resind Indústria e Comércio Ltda. |
|
BRAZIL |
|
Conflict-Free |
Gold |
|
Royal Canadian Mint |
|
CANADA |
|
Conflict-Free |
Tin |
|
Rui Da Hung |
|
TAIWAN |
|
Conflict-Free |
Gold |
|
SAAMP |
|
FRANCE |
|
Not Determined |
Gold |
|
Sabin Metal Corp. |
|
UNITED STATES OF AMERICA |
|
Not Determined |
Gold |
|
SAFINA A.S. |
|
CZECH REPUBLIC |
|
Not Determined |
Gold |
|
Sai Refinery |
|
INDIA |
|
Not Determined |
Gold |
|
Samduck Precious Metals |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Gold |
|
Samwon Metals Corp. |
|
KOREA (REPUBLIC OF) |
|
Not Determined |
Gold |
|
SAXONIA Edelmetalle GmbH |
|
GERMANY |
|
Conflict-Free |
Gold |
|
Schone Edelmetaal B.V. |
|
NETHERLANDS |
|
Conflict-Free |
Gold |
|
SEMPSA Joyería Platería S.A. |
|
SPAIN |
|
Conflict-Free |
Gold |
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Sichuan Tianze Precious Metals Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Singway Technology Co., Ltd. |
|
TAIWAN |
|
Conflict-Free |
Gold |
|
So Accurate Group, Inc. |
|
UNITED STATES OF AMERICA |
|
Not Determined |
Gold |
|
SOE Shyolkovsky Factory of Secondary Precious Metals |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Tin |
|
Soft Metais Ltda. |
|
BRAZIL |
|
Conflict-Free |
Gold |
|
Solar Applied Materials Technology Corp. |
|
TAIWAN |
|
Conflict-Free |
Tantalum |
|
Solikamsk Magnesium Works OAO |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Tungsten |
|
South-East Nonferrous Metal Company Limited of Hengyang City |
|
CHINA |
|
Conflict-Free |
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
T.C.A S.p.A |
|
ITALY |
|
Conflict-Free |
Tantalum |
|
Taki Chemical Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Tanaka Kikinzoku Kogyo K.K. |
|
JAPAN |
|
Conflict-Free |
Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
VIET NAM |
|
Conflict-Free |
Tantalum |
|
Telex Metals |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
Thaisarco |
|
THAILAND |
|
Conflict-Free |
Gold |
|
The Refinery of Shandong Gold Mining Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Tokuriki Honten Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Gold |
|
Tongling Nonferrous Metals Group Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
TOO Tau-Ken-Altyn |
|
KAZAKHSTAN |
|
Not Determined |
Gold |
|
Torecom |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Tantalum |
|
Tranzact, Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Tin |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
Not Determined |
Tantalum |
|
Ulba Metallurgical Plant JSC |
|
KAZAKHSTAN |
|
Conflict-Free |
Gold |
|
Umicore Brasil Ltda. |
|
BRAZIL |
|
Conflict-Free |
Gold |
|
Umicore Precious Metals Thailand |
|
THAILAND |
|
Conflict-Free |
Gold |
|
Umicore S.A. Business Unit Precious Metals Refining |
|
BELGIUM |
|
Conflict-Free |
Tungsten |
|
Unecha Refractory metals plant |
|
RUSSIAN FEDERATION |
|
Conflict-Free |
Gold |
|
United Precious Metal Refining, Inc. |
|
UNITED STATES OF AMERICA |
|
Conflict-Free |
Gold |
|
Valcambi S.A. |
|
SWITZERLAND |
|
Conflict-Free |
Tungsten |
|
Vietnam Youngsun Tungsten Industry Co., Ltd. |
|
VIET NAM |
|
Conflict-Free |
Tin |
|
VQB Mineral and Trading Group JSC |
|
VIET NAM |
|
Conflict-Free |
Gold |
|
Western Australian Mint (T/a The Perth Mint) |
|
AUSTRALIA |
|
Conflict-Free |
Tin |
|
White Solder Metalurgia e Mineração Ltda. |
|
BRAZIL |
|
Conflict-Free |
Gold |
|
WIELAND Edelmetalle GmbH |
|
GERMANY |
|
Conflict-Free |
Tungsten |
|
Wolfram Bergbau und Hütten AG |
|
AUSTRIA |
|
Conflict-Free |
Tungsten |
|
Woltech Korea Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Conflict-Free |
Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Yamamoto Precious Metal Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tantalum |
|
Yanling Jincheng Tantalum Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Yichun Jin Yang Rare Metal Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Yokohama Metal Co., Ltd. |
|
JAPAN |
|
Conflict-Free |
Tin |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Not Determined |
Gold |
|
Yunnan Copper Industry Co., Ltd. |
|
CHINA |
|
Not Determined |
Tin |
|
Yunnan Tin Company Limited |
|
CHINA |
|
Conflict-Free |
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CHINA |
|
Conflict-Free |
Tantalum |
|
Zhuzhou Cemented Carbide Group Co., Ltd. |
|
CHINA |
|
Conflict-Free |
Gold |
|
Gold Refinery of Zijin Mining Group Co., Ltd. |
|
CHINA |
|
Conflict-Free |
VI. Future Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we intend to continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In addition to those above, the Company will undertake the following steps during the next compliance period:
· Review the Companys conflict minerals policy statement and update if necessary. Continue to collect responses from suppliers using the most recent version of the CMRT.
· Engage with suppliers that provided incomplete responses in 2016, to enhance our data collection for 2017.
· Monitor and track performance of risk mitigation efforts.
· Compare and validate RCOI results to information collected via independent conflict-free smelter validation programs such as the CFSI.
· Continue to allow verified conflict-free material from the region to enter our supply chain.
VII. Independent Private Sector Audit
Not required for calendar year 2016.
VIII. Forward-Looking Statements
This report contains forward looking statements as defined by the Private Securities Litigation Reform Act of 1995 regarding Supremes plans to take additional actions as set forth in this report, including, but not limited to, under Future Due Diligence. Supremes reporting obligations under the Dodd-Frank Act may change in the future, and its ability to implement certain processes may differ materially from those anticipated or implied in this report. Supreme undertakes no obligation to update any forward looking statement or statements to reflect events or circumstances after the date on which such statement is made.