NACCO Industries, Inc. | ||
(Exact Name of Registrant as Specified in Charter) | ||
Delaware | 1-9172 | 34-1505819 |
(State or Other Jurisdiction of Incorporation) | (Commission File No.) | (I.R.S. Employer Identification Number) |
5875 Landerbrook Drive, Suite 220, Cleveland, Ohio | 44124-4069 | |
(Address of Principal Executive Offices) | (Zip Code) | |
Elizabeth Loveman (440) 229-5151 | ||
(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: | ||
ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
NACCO Industries, Inc. (Registrant) | |||
Date: | May 26, 2017 | /s/ Elizabeth I. Loveman | |
Elizabeth I. Loveman | |||
Vice President and Controller |
• | Step 1A - Adoption and communication to suppliers and the public of a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. |
◦ | Implemented a conflict minerals policy; |
◦ | Publicized the policy at https://www.hamiltonbeach.com/social-accountability-policy.html; and |
◦ | Communicated the policy directly to suppliers as part of RCOI process. |
• | Step 1B - Structure internal management to support supply chain due diligence. |
◦ | Maintained an internal cross-functional team to support supply chain due diligence; |
◦ | Appointed a member of senior staff with the necessary competence, knowledge and experience to oversee supply chain due diligence; and |
◦ | Invested the resources necessary to support the operation and monitoring of these processes, including internal resources and external consulting support. |
• | Step 1C - Establish a system of transparency, information collection and control over the supply chain. |
◦ | Implemented a process to collect required supplier and smelter RCOI and due diligence data. Full details of the supply chain data-gathering are included in the RCOI and due diligence sections of this CMR. |
• | Step 1D - Enhance company engagement with suppliers. |
◦ | Engaged suppliers directly during RCOI process; |
◦ | Reviewed supplier responses as part of RCOI process; |
◦ | Added conflict minerals compliance to new supplier contracts; and |
◦ | Implemented a plan to improve the quantity and quality of supplier and smelter responses year-over-year. |
• | Step 1E - Establish a company and/or mine level grievance mechanism. |
◦ | Recognized the CFSP’s three audit protocols for gold, tin/tantalum and tungsten as valid sources of smelter or mine level grievances; and |
◦ | Hamilton Beach’s ethics violations reporting system allows employees to voice confidentially without any fear of retribution, any concerns with suspected violations of Hamilton Beach’s conflict minerals policy. |
• | Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance); and |
• | Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance). |
• | Developed a list of suppliers providing 3TG containing components to Hamilton Beach; |
• | Contacted each supplier and requested the industry standard Conflict Minerals Reporting Template (“CMRT”) including smelter information; |
• | Reviewed supplier responses for accuracy and completeness; and |
• | Amalgamated supplier provided smelters into a single, unique list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols. |
• | Identify the scope of the risk assessment of the mineral supply chain (OECD Step 2B); |
• | Assess whether the smelters/refiners have performed all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Step 2C); and |
• | Perform joint spot checks at the mineral smelter/refiner’s own facilities, as necessary, through participation in industry-driven programs (OECD Step 2D). |
• | Direct engagement of the smelter to determine whether the smelter sourced from the DRC or surrounding countries; |
• | For smelters that declared directly (e.g., email correspondence, publicly available conflict minerals policy, or information available on their website) or through their relevant industry association that they did not source from the DRC or surrounding countries, and were not recognized as conflict free by the CFSP, Hamilton Beach reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration. The sources reviewed included: |
◦ | Public internet search (Google) of the facility in combination with each of the Covered Countries; |
◦ | Review of specific non-governmental organizations (“NGO”) publications. NGO publications reviewed included: |
▪ | Enough Project; |
▪ | Global Witness; |
▪ | Southern Africa Resource Watch; |
▪ | Radio Okapi; and |
▪ | The most recent UN Group of Experts report on the DRC. |
• | For smelters that did not respond to direct engagement, Hamilton Beach reviewed publicly available sources to determine if there was “any reason to believe” that the smelter may have sourced from the Covered Countries during the reporting period. |
◦ | Hamilton Beach reviewed the same sources as those used to compare against smelter sourcing declarations. |
• | For high risk smelters (i.e., smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Hamilton Beach requires the smelter be audited and recognized as conflict free by the CFSP. |
• | For high risk smelters that have not been audited and recognized as conflict free by the CFSP, Hamilton Beach communicates the risk to a designated member of senior management (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B. |
• | Including a conflict minerals compliance provision in all new and renewing supplier contracts; |
• | Including conflict minerals compliance to Hamilton Beach’s supplier code of conduct; and |
• | Continuing to encourage suppliers to obtain current, accurate and complete information about the smelters in their supply chains; |
Metal | Smelter |
Tin | Alpha |
Tin | China Tin Group Co., Ltd. |
Tin | CNMC (Guangxi) PGMA Co., Ltd. |
Tin | Cooperativa Metalurgica de Rondônia Ltda. |
Tin | CV Serumpun Sebalai |
Tin | CV United Smelting |
Tin | Dowa |
Tin | EM Vinto |
Tin | Fenix Metals |
Tin | Gejiu Jinye Mineral Company |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
Tin | Huichang Jinshunda Tin Co., Ltd. |
Tin | Malaysia Smelting Corporation (MSC) |
Tin | Metallo-Chimique N.V. |
Tin | Mineração Taboca S.A. |
Tin | Minsur |
Tin | Mitsubishi Materials Corporation |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
Tin | Operaciones Metalurgical S.A. |
Tin | PT Aries Kencana Sejahtera |
Tin | PT Artha Cipta Langgeng |
Tin | PT Babel Inti Perkasa |
Tin | PT Bangka Tin Industry |
Tin | PT Belitung Industri Sejahtera |
Tin | PT Bukit Timah |
Tin | PT DS Jaya Abadi |
Tin | PT Eunindo Usaha Mandiri |
Tin | PT Inti Stania Prima |
Tin | PT Justindo |
Tin | PT Mitra Stania Prima |
Tin | PT Refined Bangka Tin |
Tin | PT Sariwiguna Binasentosa |
Tin | PT Sumber Jaya Indah |
Tin | PT Timah (Persero) Tbk Kundur |
Tin | PT Timah (Persero) Tbk Mentok |
Tin | PT Tinindo Inter Nusa |
Tin | Rui Da Hung |
Tin | Thaisarco |
Tin | White Solder Metalurgia e Mineração Ltda. |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
Tin | Yunnan Tin Company Limited |