EX-1.01 2 ex1_01.htm EXHIBIT 1.01
Exhibit 1.01

Johnson Outdoors Inc.
Conflict Minerals Report for Calendar Year 2018
May 31, 2019

Exhibit 1.01
to Specialized Disclosure Report Accompanying Form SD
Filed with the SEC on: May 31, 2019

Signed by:
  /s/ David W. Johnson
 
 
Name, Title: David W. Johnson, Chief Financial Officer
 
Date: May 31, 2019
 

Introduction:

Johnson Outdoors Inc. (“JOI,” “we,” “us,” “our”) is a publicly traded U.S. company that recognizes itself as an issuer as defined under section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, referred to in this report as “Dodd-Frank.”  JOI manufactures, and contracts to manufacture, products for which conflict minerals, as defined by Dodd-Frank, are necessary to functionality. Through its due diligence regarding the source and chain of custody of the conflict minerals (tin, tantalum, tungsten and gold) in its supply chain in calendar year 2018, JOI has reason to believe that some of these necessary conflict minerals may have originated from the Democratic Republic of Congo or adjoining countries, and that some of those minerals may not be solely from recycled or scrap sources.

As an issuer under Dodd-Frank, JOI has fully complied with issuer requirements under the law by designing, implementing, executing, and managing its Conflict Minerals Program as mandated by the legislation. This Conflict Minerals Report is filed with our Form SD to comply with the requirements of Rule 13p-1 of the Securities and Exchange Act 1934. This report includes elements, efforts, results, and conclusions of compliance and due diligence activities required by the legislation.

All terms and definitions in this conflict minerals report are as defined by the Final Rules promulgated under Dodd-Frank and by the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

JOI supports the Responsible Minerals Initiative’s (RMI) Responsible Minerals Assurance Process (RMAP) by performing supply chain compliance and due diligence requirements for smelters sourcing from, or believed to source from, or have operations or activities in or through, the Democratic Republic of Congo (DRC) and adjoining countries. The DRC and its nine adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia) are referred to collectively as Covered Countries, or CCs. JOI’s compliance efforts under Dodd-Frank include supporting a clean minerals trade in Covered Countries and maintaining economic relationships with conflict-free smelters in Covered Countries.

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JOI’s Conflict Minerals Program is performed annually and engages JOI’s first-tier and in-scope suppliers under the applicable provisions of Dodd-Frank to perform risk assessments of smelters and refiners (hereafter referred to collectively as smelters or SORs) of tin, tantalum, tungsten, and gold (collectively, “3TG”) that may source from and/or may have operations in Covered Countries. Although JOI’s Conflict Minerals Program directly engages first-tier and in-scope suppliers, the program annually assesses all active suppliers, both in and out of scope of our Conflict Minerals Program, to ensure that we evaluate 100% of the suppliers in our supply chain.

JOI’s Conflict Minerals Program is holistically managed and includes comprehensive supplier evaluations and smelter due diligence in order to identify all the smelters in our global supply chain, as well as the smelter mines and country of origin of 3TG in Covered Countries to the best of our abilities.

JOI mandates participation in our Conflict Minerals Program as a compulsory element of JOI’s Supplier Statement of Basic Standards for all suppliers in our supply chain. Active involvement is required from JOI’s first-tier and in-scope suppliers, and passive evaluation is requested from out of scope suppliers. The supplier evaluation portion of JOI’s Conflict Minerals Program is just part of the entire scope of its comprehensive supply chain transparency program. Other critical elements of this program include cooperation from JOI business group leaders, management, and other supply chain actors. The cornerstone of this project is a strong company management system and dedication from business group leaders, senior management, and senior executives to ensure the completeness, integrity, and evolution of the program.

Communication and training for suppliers and JOI employees is performed throughout the calendar year to promote continued support and understanding of the program as it relates to fulfillment of internal and external obligations under the Dodd-Frank rule. Because JOI’s successful Conflict Minerals Program includes both suppliers and JOI employees, all participants in the program are advised routinely during each calendar year regarding their respective responsibilities associated with their role in JOI’s supply chain, their compliance expectations, and applicable risks associated with the performance of their obligations.

This report may be found on our website at: https://www.johnsonoutdoors.com/sec.  This report is inclusive for all JOI products at a company level, and all covered products in all JOI business groups.

JOI’s Conflict Minerals Program:

JOI has successfully implemented and completed its annual Conflict Minerals Program for the past six years, from the time law first required reporting on due diligence efforts performed in 2013. As in all previous years, JOI has performed required due diligence procedures for evaluating chain of custody of the extraction, through end use, of mineral ores containing tin, tantalum, tungsten and gold (3TG), also referred to as conflict minerals. While JOI’s Conflict Minerals Program is a routine part of its standard Corporate Social Responsibility business practice, JOI continues to improve its processes and annually reporting of additional information that it discloses regarding its sourcing of conflict minerals.

JOI’s Conflict Minerals Program is based on well-established and strong management systems to support all portions and efforts of the program. This foundation creates a comprehensive and robust supply chain transparency and due diligence program that identifies and evaluates smelters of 3TG in JOI’s supply chain relating to the conflict minerals necessary to the functionality or production of products manufactured by JOI, or contracted to be manufactured for JOI.

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Throughout the calendar year, routine and continued communication is made with all first-tier and in-scope suppliers in order to reasonably identify all global 3TG smelters in Covered Countries. Routine communication is also made to all first-tier active, and out of scope suppliers, to ensure they are consistently queried from year to year regarding any changes in their conflict minerals status. All communication from JOI to its first-tier active suppliers encourages ongoing sourcing from conflict-free smelters within the global supply chain in order to support legitimate trade in conflict minerals in Covered Countries.

JOI’s annual Conflict Minerals Program includes, but is not limited, to the following:

Maintenance of a publicly available corporate conflict minerals policy.

Design and implementation of an organization-wide process that ensures awareness, outreach, and training offered to 100% of JOI suppliers, both in and out of scope of the Dodd-Frank conflict minerals rule.

Ensure that 100% of JOI suppliers, both in and out of scope of the Dodd-Frank conflict minerals rule, are made aware of JOI’s policy and standards regarding conflict minerals, as well as internal and supplier obligations to comply with our conflict minerals policy.

Maintenance of internal protocols that ensure conflict minerals supply chain due diligence and obligations are clearly presented and understood by JOI employees, including senior executives, senior management, business group leaders, and support staff, who have responsibility for the SEC disclosure requirements under the Dodd-Frank conflict minerals rule.

Survey and analysis of all suppliers and identifiable sources of 3TG, including distributors and original equipment manufacturers (OEMs).

Annual implementation of a supply chain communication plan that includes requests, and repeated requests where necessary, for the completed and current RMI Conflict Minerals Reporting Template (CMRT) from suppliers in order to facilitate supply chain transparency by gathering, surveying, and evaluating suppliers and sources of 3TG, and identifying 3TG smelters in JOI’s supply chain.

Annual internal audit of all first-tier suppliers regarding their understanding of the conflict minerals rule, their obligations regarding the rule, and JOI’s expectations of them regarding their compliance with the rule.

Identification of priority first-tier suppliers that supply electrical and electronic equipment (EEE) and electrical and electronic parts (EEP).

Escalation of Reasonable Country of Origin Inquiry (RCOI) efforts to JOI business group leaders, including identifying smelters from priority suppliers of EEE and EEP.

Collection of conflict minerals information to identify 3TG in our supply chain, and identification and mitigation of risk that our products may contain conflict minerals that could finance or benefit armed groups in Covered Countries.

Identification of global 3TG smelters in order to determine the locations, country of origin, and mines of these ores, as well as the processing facilities, operations, or trade routes of 3TG from extraction to end use.

Reliance on the RMAP and other industry approved mechanisms to validate smelter supply chain due diligence and perform independent third-party audits of smelter due diligence practices.

Internal research and due diligence to evaluate and validate smelters not participating in the RMAP or other industry approved mechanisms.

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Review and due diligence of RMAP smelters to ensure the validity and current state of RMI information.

Perform due diligence on RMAP smelters to determine and/or confirm presence in Covered Countries.

Make annual requests that first-tier and subsequent tier suppliers only source from RMAP participating smelters and/or validated conflict-free smelters of 3TG.

Direct contact with smelters that are not participating in the RMAP to encourage them to participate in the RMAP, wherever possible.

Public disclosure and reporting of the results of our due diligence.

Secure maintenance of all records relating to our due diligence efforts for a minimum of five years.

Multi-tiered assessment and performance of risk mitigation efforts throughout our supply chain including review, evaluation and escalation to, and by, business group leaders and senior management.

Maintenance of an annual improvement plan based on previous reporting years and annual lessons learned.

Maintenance of an online grievance mechanism that allows JOI, its suppliers, and any concerned parties to communicate concerns regarding our Conflict Minerals Program.

Due Diligence:

Design of Due Diligence:

Per the SEC requirements that due diligence measures must conform to a nationally or internationally recognized due diligence framework, JOI’s Conflict Minerals Program is designed and implemented based on the “Five Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” (Annex I) and the “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas” (Annex II) included in the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition).

Due Diligence Performed:

The table below details JOI’s due diligence measures performed according to each of the Five Steps in the OECD Framework Guidance. These steps are specific to the due diligence regarding the source and chain of custody of conflict minerals identified in our supply chain, and regarding the smelters identified with 3TG in our supply chain. These activities include, but are not limited to, the following:

OECD Steps:

JOI Due Diligence Measures Performed:
Step 1:
Establish strong company management systems.

        Assign and implement multi-disciplinary responsibilities to internal JOI senior executives, senior management, business group leaders, support staff, and our third-party consultant to carry out all elements of JOI’s Conflict Minerals Program.
         Maintain a detailed project plan and hold semi-monthly meetings for JOI employees, business group leaders, and senior management who have responsibility for the SEC disclosure requirements for Dodd-Frank regarding conflict minerals, and regularly publish this project plan on JOI’s intranet.

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         Annual review of JOI’s Conflict Minerals Program and results by senior management, senior executives, and legal counsel.
        Annual discussion and conclusions made by business group leaders, senior management and senior executives regarding decisions that are determined in the Conflict Minerals Report and Form SD.
          Maintain records in a secure computerized database repository for a minimum of five years.
Step 2:
Identify and assess risk in the supply chain.
 

          Evaluate 100% of JOI first-tier suppliers across all business groups as being in or out of scope of the Conflict Minerals Program.
          Review and verify supplier commodity class and status.
          Review and update of affected and priority suppliers.
          Review new suppliers and changes in supplier status and commodity class.
          Assess risk in our supply chain according to commodity class, supplier status and supplier responses.
         Engage suppliers by performing multi-tiered survey of 100% of JOI in-scope and first-tier conflict minerals suppliers by requesting current, complete, and accurate CMRTs in order to identify 3TG smelters in the supply chain and set expectations for compliance.
          Annually redistribute copies of our conflict minerals policy and basic standards to all active first-tier suppliers, regardless of commodity class or in-scope status of conflict minerals.
         Analyze smelter information from suppliers with the information available from the RMI, the London Market Bullion Association (LBMA), the Responsible Jewellery Council (RJC), and other accredited industry mechanisms.
         Analyze smelter information from suppliers via other sources, including but not limited to information from: the United States Department of Commerce; United Nations publications; iTSCi (ITRI Tin Supply Chain Initiative); extensive internet research including smelter websites and company profiles; non-governmental organization (NGO) websites; in-region sourcing programs; industry leader CMRTs and reports; specialized SEC research reports; public news articles and publications.
          Identify smelters of 3TG that appear to have facilities, or likelihood of facilities, operations or trade routes, in Covered Countries.
          Report identified and/or potential supply chain risks to business group leaders and senior management.
          Report potential supply chain risks to applicable suppliers and request further supplier due diligence where needed.
Step 3:
Design and implement a strategy to respond to identified risks.

          Perform internal audit of the distribution of our conflict minerals policy to evaluate and ensure supplier understanding, acknowledgment, and adherence to this policy and our basic standards.
         Perform internal multi-tiered analysis of our suppliers’ CMRTs including: completeness; reasonable response based on commodity class and scope; consistency with previous reporting year(s) information; and identification of smelters.

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          Communicate supplier expectations for return of the most current CMRT including identifying all valid and current smelters.
          Communicate supplier expectation that they notify us of any risks and red flags identified by their own due diligence activities for smelters.
         Communicate supplier expectation that they notify us immediately of any smelters that may be suspected of supporting armed groups in Covered Countries.
          Request supplier confirmation for the validity of questionable and high-risk smelter presence in the supply chain.
          Inform suppliers not to source from smelters associated with U.S. sanctioned entities.
          Perform ongoing internal and external training of the conflict minerals rule and risks to JOI employees and all suppliers in the supply chain.
          Engage JOI business group leaders, support staff, and our third-party consultant in multi-tiered follow ups and escalations with suppliers in an effort to obtain higher quantity and quality of smelter information, particularly from suppliers of EEE and EEP.
          Use JOI level of influence to encourage suppliers to source from RMI audited and compliant smelter lists and communicate the expectation that they source only from smelters participating in the RMAP or other industry approved mechanism.
          Encourage identified smelters to participate in the RMAP and obtain RMAP Conformant certification if they have not already done so.
          Continue to improve on efficiencies and effectiveness of our Conflict Minerals Program to close gaps and mitigate risks for each subsequent reporting year.
          Perform risk mitigation efforts to ensure suppliers are in conformance with our conflict minerals policy and expectations.
          Execute a risk mitigation plan that improves supply chain due diligence and mitigates the risk that any conflict minerals identified in our supply chain may benefit any armed groups in Covered Countries.
          Communicate risks to business group leaders, our internal conflict minerals senior management team, and senior executives.
          Request that business group leaders evaluate and identify any additional risks throughout the due diligence process.
          Perform gap analysis and communicate these gaps and issues to our conflict minerals senior management team, and senior executives.
          Review and discuss supplier and smelter gaps with business group leaders, conflict minerals senior management team and senior executives.
Step 4:
Carry out independent third-party audit of smelter due diligence practices.

          Identify smelters in Covered Countries that are conflict-free, or participating in a conflict-free program as defined by the RMI.
          Rely on the due diligence performed by the RMI, LBMA and RJC regarding smelter conflict-free status.

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          Review RMI smelter information for timeliness, accuracy, and changes.
          Review RMAP corrective action plans and schedules for relevant smelters.
          Directly contact smelters in the form of an RCOI regarding chain of custody of conflict minerals and evidence of due diligence for whom we were unable to confirm conflict-free status via the sources above.
          Conduct screening of smelters against the current Office of Foreign Assets Control (OFAC) list.
Step 5:
Report on supply chain due diligence.

         In compliance with Dodd-Frank and the SEC Final Rule, on or before May 31, 2019, JOI will file Form SD and Conflict Minerals Report (this report) with the SEC, as well as publish this information on its website.

Results of Due Diligence:

JOI identified 314 unique and validated 3TG smelters in its supply chain in calendar year/reporting year 2018 (RY2018). These are associated with the following 3TG as follows:


Gold: 143

Tantalum: 41

Tin: 88

Tungsten: 42

Out of these 314 smelters, JOI identified 96 unique smelters that we have reason to believe either source 3TG from the DRC and/or surrounding countries (Covered Countries) or have some type of facility, operation, or trade route in Covered Countries anywhere from extraction to end use. JOI exercised due diligence on the conflict mineral (CM) source and chain of custody for these 96 smelters who we believe may have a presence in Covered Countries.

Conflict-free (CF) status and believed Covered Country facility location for these 96 smelters are summarized in the table below. The conflict-free status is based on due diligence research performed starting from January 23rd, 2019 and concluded on March 26th, 2019.  Details regarding specific smelter names, countries, and believed facility locations of 3TG, in and out of Covered Countries, may be shared upon request.

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Smelter Table:

3TG; # of Smelters:
96 Smelters with 346 Possible Locations in Covered Countries (CCs):
Gold:
24 Smelters
56 possible presences located in 9 CCs:
  21 RMI RMAP SORs include 47 possible presences in the following CCs: DRC (12); Angola (1); Burundi (3); Central African Republic (1); Republic of the Congo (2); Rwanda (12); S. Sudan (1); Tanzania (7); Uganda (4); Zambia (4)
  1 CF self-declared and believed to be CF SOR include 4 possible presences in the following CCs: DRC (1); Angola (0); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda (1); S. Sudan (1); Tanzania (0); Uganda (1); Zambia (0)
  2 unknown CM Compliant SORs include 5 possible presences in the following CCs: DRC (1); Angola (2); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda; (1) S. Sudan (0); Tanzania (0); Uganda (0); Zambia (1)
Tantalum:
24 Smelters
167 possible presences located in 10 CCs:
   24 RMI RMAP SORs include 167 possible presences in the following CCs: DRC (23); Angola (14); Burundi (19); Central African Republic (14); Republic of the Congo (16); Rwanda (21); S. Sudan (14); Tanzania (16); Uganda (16); Zambia (14)
Tin:
26 Smelters
69 possible presences located in 10 CCs:
   26 RMI RMAP SORs include 69 possible presences in the following CCs: DRC (22); Angola (5); Burundi (4); Central African Republic (3); Republic of the Congo (6); Rwanda (16); S. Sudan (3); Tanzania (3); Uganda (3); Zambia (4)
Tungsten:
22 Smelters
54 possible presences located in 10 CCs:
   21 RMI RMAP SORs include 52 possible  presences in the following CCs: DRC (14); Angola (1); Burundi (10); Central African Republic (1); Republic of the Congo (1); Rwanda (14); S. Sudan (2); Tanzania (3); Uganda (5); Zambia (1)
  1 unknown CM Compliant SORs include 2 possible presences in the following CCs: DRC (1); Angola (0); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda; (0) S. Sudan (0); Tanzania (0); Uganda (0); Zambia (1)

3TG Conflict-Free Due Diligence Summary:

The conflict-free (CF) status for all 3TG smelters that may have facilities located in Covered Countries is as follows:


Gold appears to be 92% CF

Tantalum appears to be 100% CF

Tin appears to be 100% CF

Tungsten appears to be 95% CF

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RMAP Participation Summary:

The conflict-free status of the 96 smelters listed as a having a possible presence in Covered Countries is as follows:


92 (96%) are RMI RMAP Conformant

1 (1%) are believed to be CF due to self-declaration or other accreditation(s)

3 (3%) are unknown CF status, as no information was available from public sources and the smelters were not able to be confirmed as CF via direct RCOI

Due Diligence Conclusion:


97%  of all 3TG smelters that may be in Covered Countries appear to be conflict-free (93 out of 96 smelters)

3%  of all 3TG smelters that may be in Covered Countries are unknown CF status (3 out of 96)

96%  of all 3TG  smelters that may be in Covered Countries were participating in an RMAP program

99% of the 3TG smelters in JOI’s entire supply chain, either believed to source in or out of Covered Countries, are conflict-free

Improvements:

The total number of smelters identified in RY2018 is 33.33% more than were identified in RY2017.  Despite the notable increase in the number of smelters identified, only three smelters were identified as conflict-free unknown status, which is consistent with RY2017. This is likely due to a 40% increase in the number of RMI RMAP smelters from RY2017 to RY2018.

Smelters that had possible presences in Covered Countries increased significantly, by over 33%, from 72 to 96, demonstrating an improvement in the information being provided by JOI’s suppliers regarding their smelters and increased supply chain transparency.

The supplier RCOI response rate also increased in RY2018, by 6%, and there was a 4% increase in number suppliers who furnished smelter names.

JOI experienced a decrease in the number of invalid smelters provided by supplier CMRTs in RY2018 while the percentage of duplicate smelters remained the same. This demonstrates that JOI’s suppliers have gained a higher level of consistency in the smelters they report, meaning they may have performed a higher level of smelter due diligence in their own supply chains.

The number of potential presences in Covered Countries rose significantly by 45%, from 238 in RY2017 to 346 in RY2018. This demonstrates the evolution of supply chain transparency, not only for JOI, but for industry, as much of this information is available from public sources.

For the second year in a row, JOI is able to reasonably determine that the tin and tantalum in our supply chain that are believed to be sourced from Covered Countries appear to be 100% conflict-free. The conflict-free status for gold rose significantly from 80% in RY2017 to 92% in RY2018.  The conflict-free status for the tungsten in our supply chain was evaluated at 95% conflict–free.

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Despite the 33% increase in the number of smelters believed to have some kind of presence in Covered Countries, the number of conflict-free unknown smelters remained at only three, the same number for RY2017. This reflects a conflict-free status of 97% of 3TG smelters in Covered Counties, compared to 96% in RY2017. The overall evaluation of JOI’s entire 3TG supply chain, both in and out of Covered Countries, remained consistent with RY2017, at 99% conflict-free.

Year after year JOI has consistently improved its due diligence results by identifying more smelters involved in the sourcing and chain of custody of conflict minerals in our supply chain.  This improvement is reflective not only of our due diligence performed, but reflective of the maturing of supply chains across industry as a whole, and the commitment to supporting clean minerals trade in Covered Countries and conflict-affected and high-risk areas (CAHRA) worldwide.

Additional information regarding statistical improvements may be shared upon request.

Determination:

JOI has made a reasonable good faith effort to collect and evaluate all information regarding 3TG smelters in our supply chain as provided by our first-tier and in-scope suppliers, and original equipment manufacturers (OEMs).

JOI performed due diligence on smelters, and their source and chain of custody of conflict minerals, that were identified by JOI first-tier suppliers in scope of Dodd-Frank and applicable OEMs. Additionally, JOI  conducted a direct smelter RCOI program to further demonstrate due diligence regarding applicable smelters. Based on these due diligence efforts, JOI has concluded in good faith that certain smelters in our supply chain either do have, or may have, facilities that source 3TG from Covered Countries or may have some type of operations or trade routes, from extraction to end use, in Covered Countries.

Based on these due diligence efforts, JOI has concluded that it does not have sufficient information to conclusively confirm that 100% of the 3TG smelters in our supply chain that may have presences in Covered Countries are conflict-free, or that all 3TGs in our supply chain are sourced exclusively from recycled or scrap sources.

Although we have not been able to confirm the identification and conflict-free status (as defined by the RMI) for 100% of the smelters identified by our first-tier suppliers and OEMs, we can confirm that none of the smelters identified by our first-tier suppliers or OEMs have confirmed to us as sourcing 3TG that directly or indirectly finance or benefit armed groups in Covered Countries.

JOI can reasonably conclude after its due diligence efforts that 100% of the tin and tantalum in its supply chain is sourced from smelters that are either conflict-free or that the tin and tantalum tungsten are from recycled or scrap sources. 100% of all smelter information is based on research from smelter identification by JOI first-tier suppliers and/or original equipment manufacturers.

Planned Risk Mitigation and Future Due Diligence Measures:

JOI’s annual Conflict Minerals program includes routine tasks for planned risk mitigation to identify and remove possible sources of smelters that may support or benefit armed groups in Covered Countries. JOI’s due diligence process is designed to identify legitimate sources of 3TG in our supply chain and eliminate smelters that are not validated as being in our supply chain. Continued awareness, education, and outreach to our first-tier suppliers, both in and out of scope of the Conflict Minerals law, has proven an effective method to identify and reduce risks, as well as improve the overall supplier RCOI response rate.

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These activities include but are not limited to the following:
Engage internal business group leaders and support staff at a deep level for review, analysis, evaluation, and recommendation for both supplier and smelter risks in each business group.
Impose direct responsibility and action items on business group leaders for supplier escalations and risk assessment for their respective business groups.
Leverage multi-tiered influence from JOI internal and external resources in order to compel its first-tier and in-scope suppliers to deliver more current, accurate, timely, and complete information to correctly identify smelters of conflict minerals, and increase both response level and quality of responses.
Leverage multi-tiered influence from JOI internal and external resources to increase response level from in-scope and first-tier distributors regarding JOI supply chain procedures and increase their participation in supply chain transparency of conflict minerals, including furnishing CMRTs for their OEMs.
Emphasize the high probability of 3TG in EEE and EEP, and maintain pressure, specifically on suppliers of EEE/EEP, to provide current, correct, and more comprehensive smelter information, including CMRTs from their OEMs as applicable.
Continue to review commodity classes with business group leaders for veracity and inclusion of EEE/EEP criteria.
Repeat, and continue to enhance, our annual pro-active supplier communication plan to further assist 100% of JOI active suppliers, regardless of scope, regarding the need for correct and complete conflict minerals information to satisfy the SEC requirements, including annual updates, reminders, and ongoing training.
Use our level of influence to encourage all suppliers to source only from smelters validated as compliant to an RMAP assessment protocol using the most recent version of the RMI RMAP Conformant Smelter List or other accredited independent validation scheme or institutional mechanism.
Use our level of influence to encourage all suppliers to source away from un-validated conflict-free smelters, unknown status smelters, and to identify the sources of conflict minerals in their supply chains.
Use our level of influence to have suppliers re-evaluate and confirm or refute the actual presence of questionable smelters as identified in their supply chains, including providing updated CMRTs.
Instruct suppliers to advise JOI if they have reason to believe that any person or entity in their supply chain is directly or indirectly financing or benefiting armed groups in the Covered Countries and provide a discrete mechanism to do so.
Pressure smelters with undeterminable conflict-free status to become verified as having conflict-free sourcing practices and encourage participation in the RMAP audit process; this is done through direct and repeat smelter RCOIs and other electronic communication where available.
Review smelter red flags for locations of gold origin and transit and remind suppliers to notify JOI of any smelters where risks and red flags may be identified in their diligence activities for all 3TG.
Review RMAP corrective actions plans and schedules for relevant smelters.
Review all smelters against the current Office of Foreign Asset Control (OFAC) list.

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Remind all JOI suppliers that they must not directly or indirectly have dealings with an entity that appears on the U.S. Office of Foreign Assets Control’s lists of Specially Designated Nationals (SDN) and Blocked Persons as these are U.S. sanctioned entities.
Remind all JOI suppliers to perform their own risk mitigation actions regarding high-risk smelters.

Description of Products:

Conflict minerals may be found in products that JOI manufactures, or contracts to manufacture. Accessories are included in all groups. The descriptions of product families by business group are as follows:

Fishing Group:

Trolling motors

Shallow water anchors

Battery chargers

Fishfinders

Downriggers

Dive Group:

Dive computers, instruments and gauges

Dive watches

Scuba dive equipment

Buoyancy compensators

Camping Group:

Camping tents, sleeping bags and furniture

Camping stoves

Military, party, and event tents

Watercraft Recreation Group:

Canoes

Kayaks

Personal flotation devices

Paddles

In Conclusion:

JOI has performed smelter due diligence in good faith and has followed the “OECD Five Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” (Annex I) and the “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas” (Annex II) to ensure a strong and effective Conflict Minerals Program designed to identify the source and chain of custody regarding conflict minerals necessary to the production of JOI products where applicable. The information in this Conflict Minerals report is represented with the most accuracy to our knowledge. The results are based on and the information represented by our first-tier and in-scope suppliers and OEMs, as well as information from the RMI’s website, during the window of research and due diligence performed.

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Errors or omissions may be inherent in these results due to errors or omissions in supplier and smelter RCOIs, supplier and OEM CMRTs, the RMI definition of a smelter at the time of the research, and subsequent updates to RMI smelter status and information.

In order for JOI to receive any additional relevant information that may not have been uncovered through our due diligence process in supply chain transparency as it relates to conflict minerals, JOI  maintains an early warning risk-awareness conflict minerals grievance mechanism. Any information found to be contradictory to this CMR may be communicated to JOI through this grievance mechanism which may be found at the following URL: https://www.johnsonoutdoors.com/legal.

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Appendix A:

Below is a list of the 3TG smelters with one or more worldwide facilities that JOI suppliers identified to potentially be in our supply chain and that were participating at some level with the Responsible Minerals Initiative (RMI) Responsible Minerals Assurance Process (RMAP) in RY2018. The presence of a smelter on the list below does not indicate that JOI products necessarily contained conflict minerals sourced or processed by that smelter. The identity and location information for each entity was reported by the RMI as of January 23rd, 2019.

  3TG:   Smelter Name:   Location:
           
 
Gold
 
Advanced Chemical Company
 
UNITED STATES OF AMERICA
 
Gold
 
Aida Chemical Industries Co., Ltd.
 
JAPAN
 
Gold
 
Al Etihad Gold Refinery DMCC
 
UNITED ARAB EMIRATES
 
Gold
 
Allgemeine Gold-und Silberscheideanstalt A.G.
 
GERMANY
 
Gold
 
Almalyk Mining and Metallurgical Complex (AMMC)
 
UZBEKISTAN
 
Gold
 
AngloGold Ashanti Corrego do Sitio Mineracao
 
BRAZIL
 
Gold
 
Argor-Heraeus S.A.
 
SWITZERLAND
 
Gold
 
Asahi Pretec Corp.
 
JAPAN
 
Gold
 
Asahi Refining Canada Ltd.
 
CANADA
 
Gold
 
Asahi Refining USA Inc.
 
UNITED STATES OF AMERICA
 
Gold
 
Asaka Riken Co., Ltd.
 
JAPAN
 
Gold
 
AU Traders and Refiners
 
SOUTH AFRICA
 
Gold
 
Aurubis AG
 
GERMANY
 
Gold
 
Bangalore Refinery
 
INDIA
 
Gold
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
 
PHILIPPINES
 
Gold
 
Boliden AB
 
SWEDEN
 
Gold
 
C. Hafner GmbH + Co. KG
 
GERMANY
 
Gold
 
CCR Refinery - Glencore Canada Corporation
 
CANADA
 
Gold
 
Cendres + Metaux S.A.
 
SWITZERLAND
 
Gold
 
Chimet S.p.A.
 
ITALY
 
Gold
 
Chugai Mining
 
JAPAN
 
Gold
 
Daejin Indus Co., Ltd.
 
KOREA, REPUBLIC OF
 
Gold
 
DODUCO Contacts and Refining GmbH
 
GERMANY
 
Gold
 
Dowa
 
JAPAN
 
Gold
 
DS PRETECH Co., Ltd.
 
KOREA, REPUBLIC OF
 
Gold
 
DSC (Do Sung Corporation)
 
KOREA, REPUBLIC OF
 
Gold
 
Eco-System Recycling Co., Ltd.
 
JAPAN
 
Gold
 
Emirates Gold DMCC
 
UNITED ARAB EMIRATES
 
Gold
 
Geib Refining Corporation
 
UNITED STATES OF AMERICA
 
Gold
 
Gold Refinery of Zijin Mining Group Co., Ltd.
 
CHINA
 
Gold
 
HeeSung Metal Ltd.
 
KOREA, REPUBLIC OF
 
Gold
 
Heimerle + Meule GmbH
 
GERMANY
 
Gold
 
Heraeus Metals Hong Kong Ltd.
 
Hong Kong
 
Gold
 
Heraeus Precious Metals GmbH & Co. KG
 
GERMANY
 
Gold
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
 
CHINA
 
Gold
 
Ishifuku Metal Industry Co., Ltd.
 
JAPAN
 
Gold
 
Istanbul Gold Refinery
 
TURKEY
 
Gold
 
Italpreziosi
 
ITALY
 
Gold
 
Japan Mint
 
JAPAN

14

 
Gold
 
Jiangxi Copper Co., Ltd.
 
CHINA
 
Gold
 
JSC Uralelectromed
 
RUSSIAN FEDERATION
 
Gold
 
JX Nippon Mining & Metals Co., Ltd.
 
JAPAN
 
Gold
 
Kazzinc
 
KAZAKHSTAN
 
Gold
 
Kennecott Utah Copper LLC
 
UNITED STATES OF AMERICA
 
Gold
 
KGHM Polska Miedz Spolka Akcyjna
 
POLAND
 
Gold
 
Kojima Chemicals Co., Ltd.
 
JAPAN
 
Gold
 
Korea Zinc Co., Ltd.
 
KOREA, REPUBLIC OF
 
Gold
 
Kyrgyzaltyn JSC
 
KYRGYZSTAN
 
Gold
 
L'Orfebre S.A.
 
ANDORRA
 
Gold
 
LS-NIKKO Copper Inc.
 
KOREA, REPUBLIC OF
 
Gold
 
Marsam Metals
 
BRAZIL
 
Gold
 
Materion
 
UNITED STATES OF AMERICA
 
Gold
 
Matsuda Sangyo Co., Ltd.
 
JAPAN
 
Gold
 
Metalor Technologies (Hong Kong) Ltd.
 
CHINA
 
Gold
 
Metalor Technologies (Singapore) Pte., Ltd.
 
SINGAPORE
 
Gold
 
Metalor Technologies (Suzhou) Ltd.
 
CHINA
 
Gold
 
Metalor Technologies S.A.
 
SWITZERLAND
 
Gold
 
Metalor USA Refining Corporation
 
UNITED STATES OF AMERICA
 
Gold
 
Metalurgica Met-Mex Penoles S.A. De C.V.
 
MEXICO
 
Gold
 
Mitsubishi Materials Corporation
 
JAPAN
 
Gold
 
Mitsui Mining and Smelting Co., Ltd.
 
JAPAN
 
Gold
 
MMTC-PAMP India Pvt., Ltd.
 
INDIA
 
Gold
 
Moscow Special Alloys Processing Plant
 
RUSSIAN FEDERATION
 
Gold
 
Nadir Metal Rafineri San. Ve Tic. A.S.
 
TURKEY
 
Gold
 
NH Recytech Company
 
KOREA, REPUBLIC OF
 
Gold
 
Nihon Material Co., Ltd.
 
JAPAN
 
Gold
 
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
 
AUSTRIA
 
Gold
 
Ohura Precious Metal Industry Co., Ltd.
 
JAPAN
 
Gold
 
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
 
RUSSIAN FEDERATION
 
Gold
 
OJSC Novosibirsk Refinery
 
RUSSIAN FEDERATION
 
Gold
 
PAMP S.A.
 
SWITZERLAND
 
Gold
 
Planta Recuperadora de Metales SpA
 
CHILE
 
Gold
 
Prioksky Plant of Non-Ferrous Metals
 
RUSSIAN FEDERATION
 
Gold
 
PT Aneka Tambang (Persero) Tbk
 
INDONESIA
 
Gold
 
PX Precinox S.A.
 
SWITZERLAND
 
Gold
 
Rand Refinery (Pty) Ltd.
 
SOUTH AFRICA
 
Gold
 
REMONDIS PMR B.V.
 
NETHERLANDS
 
Gold
 
Royal Canadian Mint
 
CANADA
 
Gold
 
SAAMP
 
FRANCE
 
Gold
 
Safimet S.p.A
 
ITALY
 
Gold
 
Samduck Precious Metals
 
KOREA, REPUBLIC OF
 
Gold
 
SAXONIA Edelmetalle GmbH
 
GERMANY
 
Gold
 
SEMPSA Joyeria Plateria S.A.
 
SPAIN
 
Gold
 
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
 
CHINA
 
Gold
 
Sichuan Tianze Precious Metals Co., Ltd.
 
CHINA
 
Gold
 
Singway Technology Co., Ltd.
 
TAIWAN, PROVINCE OF CHINA
 
Gold
 
SOE Shyolkovsky Factory of Secondary Precious Metals
 
RUSSIAN FEDERATION
 
Gold
 
Solar Applied Materials Technology Corp.
 
TAIWAN, PROVINCE OF CHINA
 
Gold
 
Sumitomo Metal Mining Co., Ltd.
 
JAPAN
 
Gold
 
SungEel HiMetal Co., Ltd.
 
KOREA, REPUBLIC OF

15

 
Gold
 
T.C.A S.p.A
 
ITALY
 
Gold
 
Tanaka Kikinzoku Kogyo K.K.
 
JAPAN
 
Gold
 
The Refinery of Shandong Gold Mining Co., Ltd.
 
CHINA
 
Gold
 
Tokuriki Honten Co., Ltd.
 
JAPAN
 
Gold
 
Torecom
 
KOREA, REPUBLIC OF
 
Gold
 
Umicore Brasil Ltda.
 
BRAZIL
 
Gold
 
Umicore Precious Metals Thailand
 
THAILAND
 
Gold
 
Umicore S.A. Business Unit Precious Metals Refining
 
BELGIUM
 
Gold
 
United Precious Metal Refining, Inc.
 
UNITED STATES OF AMERICA
 
Gold
 
Valcambi S.A.
 
SWITZERLAND
 
Gold
 
Western Australian Mint (T/a The Perth Mint)
 
AUSTRALIA
 
Gold
 
WIELAND Edelmetalle GmbH
 
GERMANY
 
Gold
 
Yamakin Co., Ltd.
 
JAPAN
 
Gold
 
Yokohama Metal Co., Ltd.
 
JAPAN
 
Gold
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
 
CHINA
 
Tantalum
 
Asaka Riken Co., Ltd.
 
JAPAN
 
Tantalum
 
Changsha South Tantalum Niobium Co., Ltd.
 
CHINA
 
Tantalum
 
D Block Metals, LLC
 
UNITED STATES OF AMERICA
 
Tantalum
 
Exotech Inc.
 
UNITED STATES OF AMERICA
 
Tantalum
 
F&X Electro-Materials Ltd.
 
CHINA
 
Tantalum
 
FIR Metals & Resource Ltd.
 
CHINA
 
Tantalum
 
Global Advanced Metals Aizu
 
JAPAN
 
Tantalum
 
Global Advanced Metals Boyertown
 
UNITED STATES OF AMERICA
 
Tantalum
 
Guangdong Rising Rare Metals-EO Materials Ltd.
 
CHINA
 
Tantalum
 
Guangdong Zhiyuan New Material Co., Ltd.
 
CHINA
 
Tantalum
 
H.C. Starck Co., Ltd.
 
THAILAND
 
Tantalum
 
H.C. Starck Hermsdorf GmbH
 
GERMANY
 
Tantalum
 
H.C. Starck Inc.
 
UNITED STATES OF AMERICA
 
Tantalum
 
H.C. Starck Ltd.
 
JAPAN
 
Tantalum
 
H.C. Starck Smelting GmbH & Co. KG
 
GERMANY
 
Tantalum
 
H.C. Starck Tantalum and Niobium GmbH
 
GERMANY
 
Tantalum
 
Hengyang King Xing Lifeng New Materials Co., Ltd.
 
CHINA
 
Tantalum
 
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
 
CHINA
 
Tantalum
 
Jiangxi Tuohong New Raw Material
 
CHINA
 
Tantalum
 
Jiujiang Janny New Material Co., Ltd.
 
CHINA
 
Tantalum
 
JiuJiang JinXin Nonferrous Metals Co., Ltd.
 
CHINA
 
Tantalum
 
Jiujiang Tanbre Co., Ltd.
 
CHINA
 
Tantalum
 
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
 
CHINA
 
Tantalum
 
KEMET Blue Metals
 
MEXICO
 
Tantalum
 
KEMET Blue Powder
 
UNITED STATES OF AMERICA
 
Tantalum
 
LSM Brasil S.A.
 
BRAZIL
 
Tantalum
 
Metallurgical Products India Pvt., Ltd.
 
INDIA
 
Tantalum
 
Mineracao Taboca S.A.
 
BRAZIL
 
Tantalum
 
Mitsui Mining and Smelting Co., Ltd.
 
JAPAN
 
Tantalum
 
Ningxia Orient Tantalum Industry Co., Ltd.
 
CHINA
 
Tantalum
 
NPM Silmet AS
 
ESTONIA
 
Tantalum
 
Power Resources Ltd.
 
MACEDONIA
 
Tantalum
 
QuantumClean
 
UNITED STATES OF AMERICA
 
Tantalum
 
Resind Industria e Comercio Ltda.
 
BRAZIL
 
Tantalum
 
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
 
CHINA
 
Tantalum
 
Solikamsk Magnesium Works OAO
 
RUSSIAN FEDERATION

16

 
Tantalum
 
Taki Chemical Co., Ltd.
 
JAPAN
 
Tantalum
 
Telex Metals
 
UNITED STATES OF AMERICA
 
Tantalum
 
Ulba Metallurgical Plant JSC
 
KAZAKHSTAN
 
Tantalum
 
XinXing HaoRong Electronic Material Co., Ltd.
 
CHINA
 
Tin
 
Alpha
 
UNITED STATES OF AMERICA
 
Tin
 
Gejiu Zili Mining And Metallurgy Co., Ltd.
 
CHINA
 
Tin
 
PT Tirus Putra Mandiri
 
INDONESIA
 
Tin
 
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
 
CHINA
 
Tin
 
Chifeng Dajingzi Tin Industry Co., Ltd.
 
CHINA
 
Tin
 
China Tin Group Co., Ltd.
 
CHINA
 
Tin
 
CV Ayi Jaya
 
INDONESIA
 
Tin
 
CV Dua Sekawan
 
INDONESIA
 
Tin
 
CV Gita Pesona
 
INDONESIA
 
Tin
 
CV United Smelting
 
INDONESIA
 
Tin
 
CV Venus Inti Perkasa
 
INDONESIA
 
Tin
 
Dowa
 
JAPAN
 
Tin
 
EM Vinto
 
BOLIVIA
 
Tin
 
Fenix Metals
 
POLAND
 
Tin
 
Gejiu Fengming Metallurgy Chemical Plant
 
CHINA
 
Tin
 
Gejiu Jinye Mineral Company
 
CHINA
 
Tin
 
Gejiu Kai Meng Industry and Trade LLC
 
CHINA
 
Tin
 
Gejiu Non-Ferrous Metal Processing Co., Ltd.
 
CHINA
 
Tin
 
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
 
CHINA
 
Tin
 
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
 
CHINA
 
Tin
 
Guanyang Guida Nonferrous Metal Smelting Plant
 
CHINA
 
Tin
 
HuiChang Hill Tin Industry Co., Ltd.
 
CHINA
 
Tin
 
Huichang Jinshunda Tin Co., Ltd.
 
CHINA
 
Tin
 
Jiangxi New Nanshan Technology Ltd.
 
CHINA
 
Tin
 
Magnu's Minerais Metais e Ligas Ltda.
 
BRAZIL
 
Tin
 
Malaysia Smelting Corporation (MSC)
 
MALAYSIA
 
Tin
 
Melt Metais e Ligas S.A.
 
BRAZIL
 
Tin
 
Metallic Resources, Inc.
 
UNITED STATES OF AMERICA
 
Tin
 
Metallo Belgium N.V.
 
BELGIUM
 
Tin
 
Metallo Spain S.L.U.
 
SPAIN
 
Tin
 
Mineracao Taboca S.A.
 
BRAZIL
 
Tin
 
Minsur
 
PERU
 
Tin
 
Mitsubishi Materials Corporation
 
JAPAN
 
Tin
 
Modeltech Sdn Bhd
 
MALAYSIA
 
Tin
 
O.M. Manufacturing (Thailand) Co., Ltd.
 
THAILAND
 
Tin
 
O.M. Manufacturing Philippines, Inc.
 
PHILIPPINES
 
Tin
 
Operaciones Metalurgical S.A.
 
BOLIVIA
 
Tin
 
PT Aries Kencana Sejahtera
 
INDONESIA
 
Tin
 
PT Artha Cipta Langgeng
 
INDONESIA
 
Tin
 
PT ATD Makmur Mandiri Jaya
 
INDONESIA
 
Tin
 
PT Babel Inti Perkasa
 
INDONESIA
 
Tin
 
PT Bangka Prima Tin
 
INDONESIA
 
Tin
 
PT Bangka Serumpun
 
INDONESIA
 
Tin
 
PT Bangka Tin Industry
 
INDONESIA
 
Tin
 
PT Belitung Industri Sejahtera
 
INDONESIA
 
Tin
 
PT Bukit Timah
 
INDONESIA
 
Tin
 
PT DS Jaya Abadi
 
INDONESIA
 
Tin
 
PT Inti Stania Prima
 
INDONESIA

17

 
Tin
 
PT Karimun Mining
 
INDONESIA
 
Tin
 
PT Kijang Jaya Mandiri
 
INDONESIA
 
Tin
 
PT Lautan Harmonis Sejahtera
 
INDONESIA
 
Tin
 
PT Menara Cipta Mulia
 
INDONESIA
 
Tin
 
PT Mitra Stania Prima
 
INDONESIA
 
Tin
 
PT Panca Mega Persada
 
INDONESIA
 
Tin
 
PT Premium Tin Indonesia
 
INDONESIA
 
Tin
 
PT Prima Timah Utama
 
INDONESIA
 
Tin
 
PT Rajehan Ariq
 
INDONESIA
 
Tin
 
PT Refined Bangka Tin
 
INDONESIA
 
Tin
 
PT Sariwiguna Binasentosa
 
INDONESIA
 
Tin
 
PT Stanindo Inti Perkasa
 
INDONESIA
 
Tin
 
PT Sukses Inti Makmur
 
INDONESIA
 
Tin
 
PT Sumber Jaya Indah
 
INDONESIA
 
Tin
 
PT Timah Tbk Kundur
 
INDONESIA
 
Tin
 
PT Timah Tbk Mentok
 
INDONESIA
 
Tin
 
PT Tinindo Inter Nusa
 
INDONESIA
 
Tin
 
PT Tommy Utama
 
INDONESIA
 
Tin
 
Resind Industria e Comercio Ltda.
 
BRAZIL
 
Tin
 
Rui Da Hung
 
TAIWAN, PROVINCE OF CHINA
 
Tin
 
Soft Metais Ltda.
 
BRAZIL
 
Tin
 
Thaisarco
 
THAILAND
 
Tin
 
Tin Technology & Refining
 
UNITED STATES OF AMERICA
 
Tin
 
White Solder Metlagurgia
 
BRAZIL
 
Tin
 
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
 
CHINA
 
Tin
 
Yunnan Tin Company Limited
 
CHINA
 
Tungsten
 
A.L.M.T. Corp.
 
JAPAN
 
Tungsten
 
ACL Metais Eireli
 
BRAZIL
 
Tungsten
 
Chenzhou Diamond Tungsten Products Co., Ltd.
 
CHINA
 
Tungsten
 
Chongyi Zhangyuan Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Fujian Jinxin Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Ganzhou Haichuang Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Ganzhou Huaxing Tungsten Products Co., Ltd.
 
CHINA
 
Tungsten
 
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Ganzhou Seadragon W & Mo Co., Ltd.
 
CHINA
 
Tungsten
 
Global Tungsten & Powders Corp.
 
UNITED STATES OF AMERICA
 
Tungsten
 
Guangdong Xianglu Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
H.C. Starck Smelting GmbH & Co. KG
 
GERMANY
 
Tungsten
 
H.C. Starck Tungsten GmbH
 
GERMANY
 
Tungsten
 
Hunan Chenzhou Mining Co., Ltd.
 
CHINA
 
Tungsten
 
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
 
CHINA
 
Tungsten
 
Hunan Chunchang Nonferrous Metals Co., Ltd.
 
CHINA
 
Tungsten
 
Hunan Litian High-tech Materials Co.,Ltd.
 
CHINA
 
Tungsten
 
Hydrometallurg, JSC
 
RUSSIAN FEDERATION
 
Tungsten
 
Japan New Metals Co., Ltd.
 
JAPAN
 
Tungsten
 
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
 
CHINA
 
Tungsten
 
Jiangxi Gan Bei Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
 
CHINA
 
Tungsten
 
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
 
CHINA
 
Tungsten
 
Jiangxi Yaosheng Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Kennametal Fallon
 
UNITED STATES OF AMERICA
 
Tungsten
 
Kennametal Huntsville
 
UNITED STATES OF AMERICA

18

 
Tungsten
 
Malipo Haiyu Tungsten Co., Ltd.
 
CHINA
 
Tungsten
 
Masan Tungsten Chemical LLC (MTC)
 
VIET NAM
 
Tungsten
 
Moliren Ltd.
 
RUSSIAN FEDERATION
 
Tungsten
 
Niagara Refining LLC
 
UNITED STATES OF AMERICA
 
Tungsten
 
Philippine Chuangxin Industrial Co., Inc.
 
PHILIPPINES
 
Tungsten
 
South-East Nonferrous Metal Company Limited of Hengyang City
 
CHINA
 
Tungsten
 
Tejing (Vietnam) Tungsten Co., Ltd.
 
VIET NAM
 
Tungsten
 
Unecha Refractory metals plant
 
RUSSIAN FEDERATION
 
Tungsten
 
Wolfram Bergbau und Hutten AG
 
AUSTRIA
 
Tungsten
 
Woltech Korea Co., Ltd.
 
KOREA, REPUBLIC OF
 
Tungsten
 
Xiamen Tungsten (H.C.) Co., Ltd.
 
CHINA
 
Tungsten
 
Xiamen Tungsten Co., Ltd.
 
CHINA

JOI suppliers and OEMs identified at least 56 additional entities which are not listed here because they were either not identified by the RMI or Department of Commerce as valid smelters and/or were not participating in any RMAP program at the time of the report. Consequently, these additional entities are not included in the list above. The names of these smelters may be provided upon request.


19