EX-1.01 2 ex1-01.htm EXHIBIT 1.01 ex1-01.htm

Exhibit 1.01

 

Spartan Motors, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2013

 

This report for the calendar year ended December 31, 2013, is presented to pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals, which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to Tin, Tantalum, Tungsten, and Gold (“3TG”).

 

If a registrant can establish that the conflict minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country, as defined by the SEC (the “Covered Countries”), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry (“RCOI”) that the registrant completed.

 

If a 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 Conflict Minerals Report (“CMR”) to the SEC that includes a description of those due diligence measures.

 

We are filing this CMR because, after completing a RCOI and due diligence, the Company is unable to conclude whether any of the conflict minerals contained in Company products originated in the Covered Countries.

 

Company Overview

 

Spartan Motors, Inc. was organized as a Michigan corporation on September 18, 1975, and is headquartered in Charlotte, Michigan. We began development of our first product that same year and shipped our first fire truck chassis in October 1975.

 

We are known as a leading niche-market engineer and manufacturer in the heavy-duty, Specialty Chassis and Vehicles marketplace. We have five wholly-owned operating subsidiaries: Spartan Motors Chassis, Inc., located at our corporate headquarters in Charlotte, Michigan (“Spartan Chassis”); Crimson Fire, Inc., located in Brandon, South Dakota (“Crimson”); Crimson Fire Aerials, Inc., located in Ephrata, Pennsylvania (“Crimson Aerials”); Utilimaster Corporation, located in Bristol and Wakarusa, Indiana (“Utilimaster”); and Classic Fire, LLC (“Classic Fire”), located in Ocala, Florida. We are also a participant in Spartan-Gimaex Innovations, LLC (“Spartan-Gimaex”) a joint venture between Crimson and Gimaex Holding, Inc. Our brand names, Spartan Chassis™, Spartan ERV™, and Utilimaster™ are known for quality, value, service and innovation.

 

Spartan Chassis is a leader in the designing, engineering and manufacturing of specialty heavy-duty chassis. The chassis consists of a frame assembly, engine, transmission, electrical system, running gear (wheels, tires, axles, suspension and brakes) and, for emergency response chassis and some specialty chassis applications, a cab. Spartan Chassis customers are original equipment manufacturers (“OEMs”) who manufacture the body or apparatus of the vehicle which is mounted on our chassis. Crimson specializes in the engineering and manufacturing of emergency response vehicles built on chassis platforms purchased from either Spartan Chassis or outside sources. Crimson Aerials engineers and manufactures aerial ladder components for fire trucks. Classic Fire specializes in manufacturing emergency response vehicles built on chassis from outside sources and provides strategic sourcing of pump modules. Collectively, Crimson, Crimson Aerials and Classic Fire operate under the Spartan ERV brand. Spartan-Gimaex is a 50/50 joint venture that was formed to leverage the complementary footprints, capabilities, brands, technologies and product portfolios of both companies. Utilimaster is a leading manufacturer of vehicles made to customer specifications in the delivery and service market, including walk-in and hi-cube vans and truck bodies.

 

 

 
 

 

 

Conflict Minerals Policy

 

Spartan Motors and its subsidiaries endeavor to maintain the highest standards of ethical conduct and integrity in all areas of their business activities.

 

On August 22, 2012, the U.S. Securities and Exchange Commission adopted final rules to implement reporting and disclosure requirements related to “conflict minerals,” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank).

 

The term “Conflict Minerals” is defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, tantalum, tin, tungsten, and 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 (DRC) or an adjoining country. The term “3TG” is defined as tantalum, tin, tungsten and gold and their compounds.

 

We are committed to working closely with our supply chain to ensure we fully comply with the requirements set forth in Section 1502 of the Dodd-Frank. We have implemented the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and are utilizing the conflict minerals reporting template developed by the Electronic Industry Citizenship Coalition® (“EICC”) and the Global e-Sustainability Initiative, known as the EICC/GeSI Conflict Minerals Reporting Template (“EICC/GeSI Template”), for exercising due diligence within our supply chain.

 

We do not knowingly source any product containing Conflict Minerals and we continue work on our due diligence process in order to verify that the components we source do not contain Conflict Minerals. We have requested that our suppliers commit to responsible sourcing of 3TG used in the production of components supplied to us. We expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing 3TG are DRC conflict free. Our suppliers will be requested to perform due diligence to determine the source of any 3TG that are contained in the components that they supply to us. Our suppliers due diligence must include, where applicable, completion of the EICC/GeSI Conflict Minerals reporting template.

 

Our conflict minerals policy is posted on our website at www.Spartanmotors.com.

 

 

RCOI & Due Diligence

 

Our due diligence measures have been designed to conform with the framework in 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 and the related Supplements for Gold and for Tin, Tantalum and Tungsten ("OECD Guidance").

 

 

Supply Chain

 

We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower tier suppliers. We have requested that our suppliers commit to responsible sourcing of conflict minerals used in the production of components supplied to us. Our suppliers have been requested to perform due diligence to determine the source of any conflict minerals that are contained in the components that they supply to us. Our suppliers' due diligence must include, where applicable, completion of the EICC/GeSI Conflict Minerals Reporting Template (the "Template"). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters 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 EICC’s website. As we enter into new contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of conflict minerals and smelters. It will take a number of years to ensure that all of our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.

 

 

 
 

 

 

For the 2013 reporting year, all of our direct suppliers were asked to complete the Template. Going forward, we currently expect we will only disseminate the Template to those suppliers who supply components likely to contain 3TG. We believe this approach is reasonable in light of the nature and number of our suppliers, as well as industry standards and practices of peer companies.

 

 

Due Diligence Process

 

We reviewed the components that are included in the specialty vehicles and chassis that we manufacture to determine if 3TG is necessary to the functionality or production of our products. Our specialty vehicles and chassis contain a large number of components, including such components as wiring, instruments and electronic controls that are generally believed to contain 3TG. As a result of this review, we determined that, due to the complexity of and the number of components contained in the specialty vehicles and chassis that we produce, all of our products contain one or more components for which 3TG is necessary for the functionality or production.

 

Our due diligence measures have been designed to conform with the framework in 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 for Gold and for Tin, Tantalum and Tungsten.

 

 

Step One: Establish Strong Company Management Systems

 

Internal Team

 

We are in the process of establishing a complete management system for conflict minerals due diligence. At our corporate level, we have a cross functional team and a third-party consulting subject matter expert working collaboratively to develop our program. This team is responsible for the corporate conflict minerals policy and providing support and instructions on the due diligence measures required to be implemented for each of our division.

 

 

Supplier Engagement

 

With respect to the OECD requirement to strengthen engagement with suppliers, we have developed a training program for our suppliers for the 2014 reporting year. It was found that many suppliers in 2013 were not aware of or did not understand the Dodd-Frank 1502 requirements. As a result of this finding, we developed an instructional document that will be provided to all of our suppliers by the second quarter of 2014. We will encourage our suppliers to share this information throughout the whole supply chain, all the way to the smelter level. Suppliers will continue to receive education and support from our business unit champions during the RCOI process on an annual basis.

 

 

Grievance Mechanism

 

Our website (www.Spartanmotors.com) contains a prominent link to our conflict minerals policy page. Included with our conflict minerals policy on our website is a link that can be utilized to contact our Compliance Officer with concerns regarding our conflict minerals policy or our use of conflict minerals. It is the policy of Spartan Motors that any communications regarding our Code of Business Conduct and Compliance or Conflict Minerals received by our Chief Compliance Officer is submitted for review to our Board of Directors.

 

 

Step Two: Identify and Assess Risk in the Supply Chain

 

All of our direct suppliers were identified for inclusion in our 2013 RCOI. We rely on these suppliers, whose components we believe may contain 3TG, to provide us with information about the source of conflict minerals, if any, contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.

 

 

 
 

 

 

Our conflict minerals team is developing a process to evaluate risk in the supply chain. We will assess risk by reviewing the suppliers’ answers provided in the EICC/GeSI Template for risk indicators. These risk indicators are based on common industry practices. When risk indicators are found, corrective action measures will be required of the supplier(s).

 

 

Step Three: Design and Implement a Strategy to Respond to Risks

 

We are currently developing our Risk Management Plan. As part of our Risk Management Plan, we have developed a training program to ensure suppliers understand our expectations for them. Training will be provided annually to all of our suppliers.

 

 

Step Four: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

 

We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. We do track all smelters that have been audited via the Conflict Free Sourcing Initiative (“CFSI”).

 

 

Step Five: Report on Supply Chain Due Diligence

 

We conducted a survey of those suppliers described above using the EICC/GeSI Conflict Minerals Reporting Template (the “Template”). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters 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 EICC’s website. The Template is being used by many companies in their due diligence processes related to conflict minerals.

 

We received responses from 39 percent of the relevant suppliers surveyed. Responses included the names of 231 entities listed by our suppliers as smelters or refiners. 45 of these entities were identified as certified Conflict-Free using the CFSI Reporting Template Revision 2.03a. We compared these facilities to the CFSI list of smelters and where a supplier indicated that the facility was certified as Conflict-Free, we ensured that the name was listed by CFSI. The large majority of the responses received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used. With the exception of the supplier(s) described above, we are unable to determine whether any of the conflict minerals reported by the suppliers were contained in components or parts supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Requesting that our suppliers complete the Template regarding information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.

 

As a result of our due diligence efforts, we have concluded in good faith that the result of our efforts is “DRC Conflict Undeterminable”. We are committed to this process and will continue to implement and improve our conflict minerals due diligence program.

 

Based on the information obtained pursuant to our RCOI and the due diligence process, we do not have sufficient information to determine the country of origin of all of the 3TG used in our products; however, based on the information that was provided by the responding suppliers and otherwise obtained through our due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the 3TG contained in our products included the smelters and refiners listed below:

 

Smelter Name

Conflict Free Certification

Metal

Country

A.L.M.T corp

Listed on the EICC-GeSI list

Tungsten (W)

Japan

AcademyPreciousMetals(China)Co.,Ltd

Unknown

Tin (Sn)

China

Aida Chemical Industries Co. Ltd.

Listed on the EICC-GeSI list

Gold (Au)

Japan

Allgemeine Gold- und Silberscheideanstalt A.G.

Listed on the CFS list

Gold (Au)

Germany

 

 

 
 

 

 

Almalyk Mining and Metallurgical Complex (AMMC)

Listed on the EICC-GeSI list

Gold (Au)

Uzbekistan

Altlantic Metals

Unknown

Tungsten (W)

United States

Amalgamet

Unknown

Tin (Sn)

United States

American Iron and Metal

Unknown

Tin (Sn)

Canada

AngloGold Ashanti Mineração Ltda

Listed on the EICC-GeSI list

Gold (Au)

Brazil

Argor-Heraeus SA

Listed on the CFS list

Gold (Au)

Switzerland

Asahi Pretec Corporation

Listed on the CFS list

Gold (Au)

Japan

Asaka Riken Co Ltd

Listed on the EICC-GeSI list

Gold (Au)

Japan

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

Listed on the EICC-GeSI list

Gold (Au)

Turkey

ATI Tungsten Materials

Listed on the EICC-GeSI list

Tungsten (W)

United States

Atlantic Metals

Unknown

Tin (Sn)

United States

Aurubis AG

Listed on the EICC-GeSI list

Gold (Au)

Germany

Ausmelt Limited

Unknown

Tin (Sn)

Australia

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

Listed on the EICC-GeSI list

Gold (Au)

Philippines

Boliden AB

Listed on the EICC-GeSI list

Gold (Au)

Sweden

Britannia Refined Metals Ltd.

Unknown

Tin (Sn)

United Kingdon

Buffalo Tungsten

Unknown

Tungsten (W)

China

Butterworth Smelter

may be part of the Malaysia Smelting Corp

Tin (Sn)

Malaysia

Caridad

Listed on the EICC-GeSI list

Gold (Au)

Mexico

Cendres & Métaux SA

Listed on the EICC-GeSI list

Gold (Au)

Switzerland

Central Bank of the DPR of Korea

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Chaozhou Xianglu Tungsten Industry Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Chimet SpA

Listed on the EICC-GeSI list

Gold (Au)

Italy

China Hongqiao

Unknown

Tin (Sn)

China

China Tin Group Co., Ltd.

Unknown

Tin (Sn)

China

Chongyi Zhangyuan Tungsten Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Chugai Mining

Listed on the EICC-GeSI list

Gold (Au)

Japan

CHUGAI MINING CO.,LTD

Unknown

Gold (Au)

Japan

CNMC (Guangxi) PGMA Co. Ltd.

Listed on the EICC-GeSI list

Tin (Sn)

China

Codelco

Listed on the EICC-GeSI list

Gold (Au)

CHILE

Complejo Metalurgico Vinto S.A.

Unknown

Tin (Sn)

Bolivia

Conghua Tantalum and Niobium Smeltry

Listed on the CFS list

Tantalum (Ta)

China

Cookson

Listed on the EICC-GeSI list

Tin (Sn)

United States

Cookson Sempsa

Unknown

Gold (Au)

SPAIN

Cooper Santa

Listed on the EICC-GeSI list

Tin (Sn)

Brazil

Corporation Berhad (MSC)

Unknown

Tin (Sn)

Malaysia

CSC Pure Technologies

Unknown

Tin (Sn)

Russian Federation

CV Duta Putra Bangka

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CV JusTindo

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CV Makmur Jaya

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CV Nurjanah

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CV Prima Timah Utama

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CV Serumpun Sebalai

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

 

 

 
 

 

 

CV United Smelting

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

CWB Materials

Unknown

Tungsten (W)

United States

DAE CHANG IND CO LTD

Unknown

Tin (Sn)

Korea, Republic of

DAECHANG Co. LTD.

Unknown

Tin (Sn)

Korea, Republic of

DaeryongENC

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Dayu Weiliang Tungsten Co., Ltd.

Listed on the EICC-GeSI list

Tungsten (W)

China

TANAKA KIKINZOKU KOGYO K.K.

Listed on the EICC-GeSI list

Gold (Au)

Japan

Do Sung Corporation

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Dowa

Listed on the CFS list

Gold (Au)

Japan

Duoluoshan Sapphire Rare Metel Co. Ltd. Of Zhaoqing

Listed on the EICC-GeSI list

 

China

EM Vinto

Listed on the EICC-GeSI list

Tin (Sn)

Bolivia

ESG Edelmetallservice GmbH & Co. KG

Unknown

Gold (Au)

Germany

Ethiopian Minerals Development Share Company

Unknown

Tantalum (Ta)

Ethiopia

Exotech Inc.

Listed on the CFS list

Tantalum (Ta)

United States

F&X

Listed on the CFS list

Tantalum (Ta)

China

Feinhütte Halsbrücke GmbH

Unknown

Tin (Sn)

Germany

Fenix Metals

Listed on the EICC-GeSI list

Tin (Sn)

Poland

FSE Novosibirsk Refinery

Listed on the EICC-GeSI list

Gold (Au)

Russian Federation

Fujian Jinxin Tungsten Co., Ltd.

Listed on the EICC-GeSI list

Tungsten (W)

China

Gannon & Scott

Listed on the CFS list

Tantalum (Ta)

United States

Gansu-based Baiyin Nonferrous Metals Corporation (BNMC)

Unknown

Gold (Au)

China

Ganzhou Grand Sea W & Mo Group Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Ganzhou Hongfei Tungsten & Molybdenum Materials Co., Ltd.

Unknown

Tungsten (W)

China

Ganzhou Sinda W&Mo Co., Ltd.

Unknown

Tungsten (W)

China

Geiju Non-Ferrous Metal Processing Co. Ltd.

Listed on the CFS list

Tin (Sn)

China

Gejiu Yunxi Group Corp.

Unknown

Tin (Sn)

China

Gejiu Zi-Li

Listed on the EICC-GeSI list

Tin (Sn)

China

Global Advanced Metals

Listed on the CFS list

Tantalum (Ta)

United States

Global Tungsten & Powders Corp

Listed on the EICC-GeSI list

Tungsten (W)

United States

Gold Bell Group

Listed on the EICC-GeSI list

Tin (Sn)

China

Gold Mining in Shandong (Laizhou) Limited Company

Unknown

Gold (Au)

China

Golden Egret

Unknown

Tungsten (W)

China

Grant Manufacturing and Alloying

Unknown

Tin (Sn)

United States

Guangdong MingFa Precious Metal Co.,Ltd

Unknown

Gold (Au)

China

GuanXi China Tin Group Co.,LTD

Unknown

Tin (Sn)

China

H.C. Starck GmbH

Listed on the CFS list

Tantalum (Ta)

Germany

H.J.Enthoven & Sons is a division of H.J.Enthoven Ltd - Registered in the UK - Reg. No. 2821551 - Registered Address: Darley Dale Smelter, South Darley, Matlock, DE4 2LP

Unknown

Tin (Sn)

United Kingdon

Harima Smelter

Unknown

Gold (Au)

Japan

HC Starck GmbH

Listed on the EICC-GeSI list

Tungsten (W)

Germany

Heesung Metal

Unknown

Gold (Au)

Korea, Republic of

 

 

 
 

 

 

Heimerle + Meule GmbH

Listed on the EICC-GeSI list

Gold (Au)

Germany

Henan Sanmenxia Lingbao Jinyuan Mining Co., Ltd.

Unknown

Gold (Au)

China

Henan zhongyuan gold smelter

Unknown

Gold (Au)

China

Heraeus Ltd Hong Kong

Listed on the CFS list

Gold (Au)

Hong Kong

Heraeus Precious Metals GmbH & Co. KG

Listed on the CFS list

Gold (Au)

Germany

Hi-Temp

Listed on the CFS list

Tantalum (Ta)

United States

Huichang Jinshunda Tin Co. Ltd

Listed on the EICC-GeSI list

Tin (Sn)

China

Hunan Chenzhou Mining Group Co

Listed on the EICC-GeSI list

Tungsten (W)

China

Hwasung CJ Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Imperial Zinc Corportion

Unknown

Tin (Sn)

United States

Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited

Listed on the EICC-GeSI list

Gold (Au)

China

Ishifuku Metal Industry Co., Ltd.

Listed on the EICC-GeSI list

Gold (Au)

Japan

Istanbul Gold Refinery

Listed on the EICC-GeSI list

Gold (Au)

Turkey

Izawa Metal Co., Ltd

Unknown

Tungsten (W)

Japan

Japan Mint

Listed on the EICC-GeSI list

Gold (Au)

Japan

Japan New Metals Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

Japan

Japan Pure Chemical

Unknown

Gold (Au)

Japan

Jean Goldschmidt International

Unknown

Tin (Sn)

Belgium

Jhonson Mattehey Inc

Listed on the CFS list

Gold (Au)

United States

Jiangxi Copper Company Limited

Listed on the EICC-GeSI list

Gold (Au)

China

Jiangxi Nanshan

Listed on the EICC-GeSI list

Tin (Sn)

China

Jiangxi Rare Earth & Rare Metals Tungsten Group Corp

Listed on the EICC-GeSI list

Tungsten (W)

China

Jiangxi Tungsten Industry Group Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Jinlong Copper Co., Ltd.

Unknown

Gold (Au)

China

JiuJiang JinXin Nonferrous Metals Co. Ltd.

Listed on the EICC-GeSI list

Tantalum (Ta)

China

JiuJiang Tambre Co. Ltd.

Listed on the CFS list

Tantalum (Ta)

China

Johnson Matthey Limited

Listed on the EICC-GeSI list

Gold (Au)

Canada

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

Listed on the EICC-GeSI list

Gold (Au)

Russian Federation

JX Nippon Mining & Metals Co., Ltd

Listed on the CFS list

Gold (Au)

Japan

Kanfort Industrial (Yantai) Co. Ltd.

Unknown

Gold (Au)

China

Kazzinc Ltd

Listed on the EICC-GeSI list

Gold (Au)

Kazakhstan

Kemet Blue Powder

Listed on the CFS list

Tantalum (Ta)

United States

Kennametal Inc.

Listed on the EICC-GeSI list

Tungsten (W)

United States

Kihong T&G

Unknown

Tin (Sn)

Indonesia

King-Tan Tantalum Industry Ltd

Listed on the EICC-GeSI list

Tantalum (Ta)

China

KOBA

Unknown

Tin (Sn)

Indonesia

Kojima Chemicals Co,Ltd

Unknown

Gold (Au)

Japan

Korea Metal Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Kundur Smelter

Unknown

Tin (Sn)

Indonesia

Kupol

Unknown

Tin (Sn)

Russian Federation

Kyrgyzaltyn JSC

Listed on the EICC-GeSI list

Gold (Au)

Kyrgyzstan

L' azurde Company For Jewelry

Listed on the EICC-GeSI list

Gold (Au)

Saudi Arabia

 

 

 
 

 

 

Linwu Xianggui Smelter Co

Listed on the EICC-GeSI list

Tin (Sn)

China

Liuzhou China Tin

Listed on the EICC-GeSI list

Tin (Sn)

China

LS-Nikko Copper Inc

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Malaysia Smelting Corporation (MSC)

Listed on the CFS list

Tin (Sn)

Malaysia

Materion

Listed on the CFS list

Gold (Au)

United States

Matsuda Sangyo Co. Ltd

Listed on the CFS list

Gold (Au)

Japan

Mentok Smelter

Unknown

Tin (Sn)

Indonesia

Metal Do

Unknown

Tantalum (Ta)

Japan

METALLIC MATERIALS BRANCHL OF GUANGXI CHINA TIN GROUP CO.,LTD

Unknown

Tin (Sn)

China

Metallo Chimique

Listed on the EICC-GeSI list

Tin (Sn)

Belgium

Metalor Technologies (Hong Kong) Ltd

Listed on the CFS list

Gold (Au)

Hong Kong

Met-Mex Peñoles, S.A.

Listed on the EICC-GeSI list

Gold (Au)

Mexico

Mineração Taboca S.A.

Listed on the EICC-GeSI list

Tin (Sn)

Brazil

Minmetals Ganzhou Tin Co. Ltd.

Listed on the EICC-GeSI list

Tin (Sn)

China

Minsur

Listed on the CFS list

Tin (Sn)

PERU

Mistubishi Materials Corporation

Unknown

Gold (Au)

Japan

Mitsubishi Materials Corporation

Listed on the EICC-GeSI list

Tin (Sn)

Japan

Mitsui Mining & Smelting

Listed on the CFS list

Tantalum (Ta)

Japan

Mitsui Mining and Smelting Co., Ltd.

Listed on the CFS list

Gold (Au)

Japan

Moscow Special Alloys Processing Plant

Listed on the EICC-GeSI list

Gold (Au)

Russian Federation

MSC Croporation Berhad

Unknown

Tin (Sn)

Malaysia

Nadir Metal Rafineri San. Ve Tic. A.☒.

Listed on the EICC-GeSI list

Gold (Au)

Turkey

Nancang Metal Material Co.,Ltd

Unknown

Tin (Sn)

China

Nanchang Cemented Carbide Limited Liability Company

Unknown

Tungsten (W)

China

Nankang Nanshan Tin Manufactory Co., Ltd.

Unknown

Tin (Sn)

China

Nathan Trotter

Unknown

Tin (Sn)

United States

Navoi Mining and Metallurgical Combinat

Listed on the EICC-GeSI list

Gold (Au)

Uzbekistan

Nihon Material Co. LTD

Listed on the CFS list

Gold (Au)

Japan

NIHON MATERIAL CO.,LTD

Listed on the CFS list

Gold (Au)

Japan

Niihama Nickel Refinery

Unknown

Gold (Au)

Japan

Ningxia, OTIC

Unknown

Tantalum (Ta)

China

Nippon Micrometal Cop

Unknown

Tungsten (W)

Japan

Novosibirsk Integrated Tin Works

Listed on the EICC-GeSI list

Tin (Sn)

Russian Federation

Ohio Precious Metals LLC.

Listed on the CFS list

Gold (Au)

United States

OJSC Kolyma Refinery

Listed on the EICC-GeSI list

Gold (Au)

Russian Federation

OM Manufacturing Phils. Inc.

Unknown

Tin (Sn)

Philippines

OMSA

Listed on the CFS list

Tin (Sn)

Bolivia

PT Tambang Timah

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

PAMP SA

Listed on the CFS list

Gold (Au)

Switzerland

Pan Pacific Copper Co Ltd.,

Listed on the EICC-GeSI list

Gold (Au)

Japan

Plansee

Listed on the CFS list

Tantalum (Ta)

Austria

POONGSAN CORPORATION

Unknown

Tin (Sn)

Korea, Republic of

Posco

Unknown

Tin (Sn)

Korea, Republic of

 

 

 
 

 

 

Prioksky Plant of Non-Ferrous Metals

Listed on the EICC-GeSI list

Gold (Au)

Russian Federation

PT Alam Lestari Kencana

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

PT Aneka Tambang (Persero) Tbk

Listed on the EICC-GeSI list

Gold (Au)

Indonesia

PT Timah

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

PT.DS JAYA ABADI

Listed on the EICC-GeSI list

Tin (Sn)

Indonesia

PT.Indra Eramulti Logam Industri

Unknown

Tin (Sn)

Indonesia

PX Précinox SA

Listed on the EICC-GeSI list

Gold (Au)

Switzerland

Rahman Hydrulic Tin Sdn Bhd

Unknown

Tin (Sn)

Malaysia

Rand Refinery (Pty) Ltd

Listed on the EICC-GeSI list

Gold (Au)

South Africa

RFH

Listed on the CFS list

Tantalum (Ta)

China

Royal Canadian Mint

Listed on the CFS list

Gold (Au)

Canada

Rui Da Hung

Unknown

Tin (Sn)

Taiwan

Sabin

Listed on the EICC-GeSI list

Gold (Au)

United States

Schone Edelmetaal

Listed on the EICC-GeSI list

Gold (Au)

Netherlands

Shandong Zhaojin Gold & Silver Refinery Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

China

Shyolkovsky

Listed on the EICC-GeSI list

 

Russian Federation

Sincemat Co, Ltd

Unknown

Tungsten (W)

China

So Accurate Refing Group

Unknown

Gold (Au)

United States

Solar Applied Materials Technology Corp.

Listed on the EICC-GeSI list

Gold (Au)

Taiwan

Solikamsk Metal Works

Listed on the CFS list

Tantalum (Ta)

Russian Federation

Sumitomo Metal Mining Co. Ltd.

Listed on the CFS list

Gold (Au)

Japan

Suzhou Xingrui Noble

Listed on the EICC-GeSI list

 

China

Tanaka Kikinzoku Kogyo K.K.

Listed on the CFS list

Gold (Au)

Japan

Tantalite Resources

Listed on the CFS list

Tantalum (Ta)

South Africa

Tejing (Vietnam) Tungsten Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

Vietnam

Telex

Listed on the CFS list

Tantalum (Ta)

United States

Thailand Smelting & Refining Co Ltd

Unknown

Tin (Sn)

Thailand

Thaisarco

Listed on the CFS list

Tin (Sn)

Thailand

The Great Wall Gold and Silver Refinery of China

Listed on the EICC-GeSI list

Gold (Au)

China

The Refinery of Shandong Gold Mining Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

China

Tokuriki Honten Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

Japan

TongLing Nonferrous Metals Group Holdings Co;Ltd

Unknown

Gold (Au)

China

Torecom

Listed on the EICC-GeSI list

Gold (Au)

Korea, Republic of

Traxys

Unknown

Tin (Sn)

France

Ulba

Listed on the CFS list

Tantalum (Ta)

Kazakhstan

Umicore Haboken

Unknown

Tin (Sn)

Belgium

Umicore SA Business Unit Precious Metals Refining

Listed on the CFS list

Gold (Au)

Belgium

United Precious Metal Refining, Inc.

Listed on the CFS list

Gold (Au)

United States

Valcambi SA

Listed on the EICC-GeSI list

Gold (Au)

Switzerland

Voss Metals Company, Inc.

Unknown

Tungsten (W)

United States

Western Australian Mint trading as The Perth Mint

Listed on the CFS list

Gold (Au)

Australia

White Solder Metalurgia

Listed on the EICC-GeSI list

Tin (Sn)

Brazil

WILLIAMS GOLD REFINING CO INC

Unknown

Gold (Au)

United States

 

 

 
 

 

 

Williams Gold Refining Company

Unknown

Gold (Au)

Canada

Wolfram Bergbau und Hütten AG

Listed on the EICC-GeSI list

Tungsten (W)

Austria

Wuxi Middle Treasure Materials

Unknown

Gold (Au)

China

Xiamen Honglu Tungsten Molybdenum Co., Ltd.

Unknown

Tungsten (W)

China

Xiamen Tungsten Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Xstrata Canada Corporation

Listed on the EICC-GeSI list

Gold (Au)

Canada

Yamamoto Precious Metal Co., Ltd.

Unknown

Gold (Au)

Japan

Yifeng Tin Industry (Chenzhou) Co Ltd

Unknown

Tin (Sn)

China

Yokohama Metal Co Ltd

Listed on the EICC-GeSI list

Gold (Au)

Japan

Yunnan Chengfeng

Listed on the EICC-GeSI list

Tin (Sn)

China

Yunnan Tin Company Limited

Listed on the CFS list

Tin (Sn)

China

Zhongjin Gold Corporation

Unknown

Gold (Au)

China

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

Listed on the EICC-GeSI list

Gold (Au)

China

Zhuzhou Cement Carbide

Listed on the CFS list

Tantalum (Ta)

China

Zhuzhou Cemented Carbide Group Co Ltd

Listed on the EICC-GeSI list

Tungsten (W)

China

Zijin Mining Group Co. Ltd

Listed on the EICC-GeSI list

Gold (Au)

China

 

 

Our efforts to determine the mine or location of origin of the 3TG used in our products consisted of the due diligence measures described in this report. In particular, because independent third party audit programs validate whether sufficient evidence exists regarding country, mine and/or location of origin of the 3TG that the audited smelter or refiner facilities have processed, we relied on the information made available by such programs for the smelters and refiners in our supply chain. We were unable to ascertain the country of origin and/or chain of custody of all necessary 3TG processed by these facilities because, for this reporting period, certain smelter and refiner facilities (1) had not yet received a “conflict free” designation from an independent third party audit program and (2) did not respond to our requests for country of origin or chain of custody information.

 

 

Planned Steps to Improve Due Diligence

 

We intend to take the following steps to improve our due diligence program:

 

1.

Include a conflict minerals flow-down clause in new or renewed supplier contracts.

 

2.

Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses.