(State or other jurisdiction of Incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) |
_√__ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
• | Inductors |
• | Electrical Coils |
• | Electrical Chokes |
• | Electrical Magnetic Transformers |
• | Electrical Filters |
• | Electronic Control Boards |
Product Category (Dielectric and Termination Configuration) | Tantalum | Tin | Tungsten | Gold |
Tantalum Surface Mount | a | £ | × | £ |
Tantalum Polymer Surface Mount | a | £ | × | £ |
Aluminum Polymer Surface Mount | × | a | × | × |
Tantalum Non-Surface Mount | a | a | × | × |
Ceramic Surface Mount | × | £ | £ | £ |
Ceramic Non-Surface Mount | × | a | × | £ |
Film and Paper Surface Mount | × | a | × | £ |
Film and Paper Non-Surface Mount | × | a | × | × |
Electrolytic Non-Surface Mount | × | a | × | £ |
Electrical Filters | × | a | × | £ |
Electrical Magnetic Transformers | × | a | × | £ |
Electrical Chokes | × | a | × | £ |
Electrical Coils | × | a | × | £ |
Inductors | × | a | × | £ |
Electronic Control Boards | £ | a | £ | £ |
1. | KEMET manufactured or contracted to manufacture products as to which conflict minerals are necessary to the functionality or production; |
2. | Tantalum material was sourced either directly through our Closed Pipe Supply Chain (which refers to our effort, started in fiscal year 2012, to vertically integrate our tantalum business and develop a “closed pipe” source for our conflict-free tantalum material) or through external third party suppliers. All tungsten, tin and gold material was sourced from external third party suppliers; and |
3. | Based on a reasonable country of origin inquiry, KEMET knew or had reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country as defined in the Rule (collectively, sometimes referred to as the “Covered Countries”), and knew or had reason to believe that those necessary conflict minerals may not be from recycle or scrap sources. |
• | For tantalum, tin, and gold, KEMET determined a portion of the material came from recycle or scrap material. |
• | For tantalum, not from recycle or scrap, we determined the country of origin for all materials and confirmed that the country of origin included a Covered Country. |
• | For tin, despite diligent efforts we were not able to determine the country of origin for all materials but did confirm the country of origin included a Covered Country. |
• | For gold, despite diligent efforts we were not able to determine the country of origin for all materials. For those materials where the country of origin was determined, the origins did not include, and KEMET has no reason to believe they were sourced from, a Covered Country. |
• | For tungsten, we were not required to determine the country of origin or otherwise provide information related to tungsten because all tungsten necessary to the functionality or production of KEMET’s products was acquired in 2011 and considered to be “outside the supply chain” (or fully smelted). |
Conflict Mineral | Countries of origin include a Covered Country? |
Tantalum | Yes |
Tin | Yes |
Tungsten | N/A (all tungsten was outside the supply chain prior to January 31, 2013) |
Gold | No reason to believe sourced in those regions |
By: /s/ SUSAN B. BARKAL | Date: May 26, 2016 |
1. | Establish strong company management systems for conflict minerals supply chain due diligence and reporting compliance; |
2. | Identify and assess conflict minerals risks in our supply chain; |
3. | Design and implement strategies to respond to conflict minerals risks identified; |
4. | Contribute to independent third-party audits of the due diligence practices of conflict minerals smelters and refiners by participating in industry organizations; and |
5. | Report on our conflict minerals supply chain due diligence activities, as required by the Rule. |
Step 1: Establish strong company management systems. | |
A) To clearly communicate to suppliers and the public, KEMET maintained a formal company policy avoiding the use of conflict minerals which directly or indirectly finance or benefit armed groups in the DRC or an adjoining country (“Conflict Minerals Policy”). The Conflict Minerals Policy is publicly available on our website and was employed by our KEMET purchase order terms and conditions. The Policy was communicated to conflict mineral raw material suppliers during the reporting period and to new raw material suppliers during our supplier “on boarding” process. | |
B) To structure internal management and support supply chain due diligence, KEMET maintained in its internal Compliance Policy and Procedures, a conflict minerals document formally stating that KEMET’s Sustainability Council (“SC”), which is made up of a cross section of senior management, has oversight and ownership of the Conflict Minerals Policy. The SC met quarterly to address current and future sustainability objectives and concerns. In addition, KEMET maintained a specific conflict minerals team (“Conflict Minerals Team”) that met during the Reporting Period to address the implementation and progress of our due diligence efforts. | |
C) To establish a system of controls and transparency over the conflict minerals supply chain as a downstream company, KEMET maintained in our internal Supplier Quality Procedures a requirement for suppliers to provide information on the smelters or refiners in their supply chain utilizing the EICC/GeSI Conflict Mineral Reporting Template. Records of suppliers’ responses were recorded and maintained. The information was used by KEMET to determine material conflict-free status. The information was also used to provide our customers with conflict mineral smelter or refiner information. | |
D) To strengthen engagement with its suppliers, KEMET performed smelter outreach to encourage EICC/GeSI CFSP participation and participated in supply chain workshops. | |
E) KEMET had available multiple communication channels to serve as grievance mechanisms for early-warning risk awareness. Internally, KEMET offered the “Listen Up” program to its personnel to report anonymously possible violations of KEMET’s Global Code of Conduct and other policies. The “Listen Up” program was administered by an outside firm which was not connected to KEMET. Externally, contact information was made available through KEMET’s public website (www.kemet.com). KEMET also actively participated in the following industry groups which served as an early-warning risk-awareness system. • Organisation for Economic Co-Operation and Development (OECD) • EICC/GeSI Conflict Free Sourcing Initiative (EICC/GeSI CFSI) • International Tin Research Institute (ITRI) • Tantalum-Niobium International Study Center (TIC) | |
Step 2: Identify and assess risk in the supply chain. | |
A) For the purpose of identifying risks, KEMET surveyed our suppliers of raw materials containing a conflict mineral to obtain smelter or refiner information utilizing the EICC/GeSI Conflict Mineral Reporting Template. | |
B) To assess risk, KEMET reviewed the supplier responses for completeness and for reasonableness (i.e., 1. Do not contain contradictions or inconsistencies; 2. The response is consistent with KEMET’s knowledge of the supplier). KEMET followed up with suppliers who were unresponsive or required additional clarification. | |
Step 3: Design and implement a strategy to respond to identified risks. | |
A) KEMET reported findings of supply chain risk to senior management through quarterly and monthly business review meetings. | |
B) The risk management plan adopted by KEMET was in accordance with the Conflict Minerals Policy to discontinue doing business with any supplier found to be purchasing tungsten, tantalum, tin or gold material which directly or indirectly finances or benefits armed groups in the DRC or an adjoining country. KEMET understood the global supply chain of conflict minerals is complex and disclosure of mineral sources is often considered confidential. To reduce the potential supply chain risk, KEMET encouraged smelters and refiners to participate in independent assessments of their own sources through vehicles such as the EICC/GeSI Conflict-Free Smelter Program. | |
C) To monitor and track performance of risk management efforts, KEMET relied on supplier survey updates and supplier EICC/GeSI CFSP updates. The status was communicated internally in Conflict Minerals Team meetings. | |
D) To undertake additional fact and risk assessments for risks requiring mitigation or after a change of circumstances, KEMET will rely on the supplier re-approval process as governed by its Supplier Quality Procedures. |
Step 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain. | |
KEMET relied on the EICC/GeSI Conflict-Free Sourcing Program audits to validate that its due diligence is in conformance with the OECD Guidance. As an EICC/GeSI CFSI member, KEMET worked with other members to identify smelters in the supply chain, and encouraged suppliers and customers to participate in the program through direct communication and smelter outreach communication. The data on which we relied for certain statements in this declaration was obtained through our membership in the CFSI, using the Reasonable Country of Origin Inquiry report for member KMET. | |
Step 5: Report on supply chain due diligence. | |
KEMET has publicly made available the Conflict Minerals Policy outlining its due diligence objectives and documented our “closed pipe” conflict-free tantalum supply chain with our Partnership for Social and Economic Sustainability program. As required under Section 13(p) of the Securities and Exchange Act of 1934 and the Rule, and in consultation with internal and external counsel, KEMET has filed our Form SD - Special Disclosure Report, which includes this Conflict Minerals Report as Exhibit 1.01, with the Securities and Exchange Commission for the Reporting Period and made such disclosure available on its website at www.kemet.com. |
1. | KEMET surveyed all identified conflict minerals suppliers to ascertain for each of these conflict minerals (a) the smelter or refiner where it was processed, (b) its country of origin and (c) its mine of origin. The survey was conducted using the EICC/GeSI Conflict Minerals Reporting Template. KEMET accepted supplier data up to March 31, 2016 for the Reporting Period. |
2. | KEMET maintained our upstream “closed pipe” vertically integrated conflict-free tantalum supply chain. All of our upstream facilities were audited and validated as EICC/GeSI CFSP compliant. In addition, KEMET only sourced its downstream externally supplied tantalum material from EICC/GeSI CFSP compliant smelters. |
3. | As a member company of the EICC/GeSI Conflict Free Sourcing Initiative (the “CFSI”), we leveraged the due diligence conducted on smelters and refiners by the CFSI’s Conflict-Free Smelter Program (the “CFSP”). The CFS Program, developed by the EICC and |
• | Tantalum Surface Mount Capacitors (MnO2) |
• | Tantalum Polymer Surface Mount Capacitors (KO) |
• | Ceramic Surface Mount Capacitors (MLCC) |
• | Electrolytic Non-Surface Mount Capacitors |
• | Aluminum Polymer Surface Mount Capacitors (AO) |
• | Tantalum Non-Surface Mount Capacitors |
List of Known Facilities processing conflict minerals for KEMET Other Product Categories: • Ceramic Non-Surface Mount Capacitors• Film and Paper Surface Mount Capacitors• Film and Paper Non-Surface Mount Capacitors• Electrical Filters• Electrical Magnetic Transformers• Electrical Chokes• Electrical Coils• Inductors• Electronic Control Boards | ||
Mineral | Smelter or Refiner Facility Name† | Location of Facility† |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd.* | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração* | BRAZIL |
Gold | Argor-Heraeus SA* | SWITZERLAND |
Gold | Asahi Pretec Corporation* | JAPAN |
Gold | Asaka Riken Co., Ltd.* | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S.* | TURKEY |
Gold | Aurubis AG* | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | PHILIPPINES |
Gold | Bauer Walser AG | GERMANY |
Gold | Boliden AB* | SWEDEN |
Gold | C. Hafner GmbH + Co. KG* | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
Gold | Cendres + Métaux SA | SWITZERLAND |
Gold | Chimet S.p.A.* | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Dowa* | JAPAN |
Gold | Eco-System Recycling Co., Ltd.* | JAPAN |
Gold | OJSC Novosibirsk Refinery* | RUSSIAN FEDERATION |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH* | GERMANY |
Gold | Heraeus Ltd. Hong Kong* | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
Gold | Istanbul Gold Refinery* | TURKEY |
Gold | Japan Mint* | JAPAN |
Gold | Jiangxi Copper Co., Ltd.* | CHINA |
Gold | Asahi Refining USA Inc.* | UNITED STATES |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant* | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed* | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd.* | JAPAN |
Gold | Kazzinc* | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC* | UNITED STATES |
Gold | Kojima Chemicals Co., Ltd.* | JAPAN |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L' azurde Company For Jewelry* | SAUDI ARABIA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc.* | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion* | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd.* | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd.* | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
Gold | Metalor Technologies SA* | SWITZERLAND |
Gold | Metalor USA Refining Corporation* | UNITED STATES |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V.* | MEXICO |
Gold | Mitsubishi Materials Corporation* | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
Gold | Moscow Special Alloys Processing Plant* | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª.* | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd.* | UZBEKISTAN |
Gold | Elemetal Refining, LLC* | UNITED STATES |
Gold | Ohura Precious Metal Industry Co., Ltd.* | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | RUSSIAN FEDERATION |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
Gold | PAMP SA* | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals* | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
Gold | PX Précinox SA* | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd.* | SOUTH AFRICA |
Gold | Royal Canadian Mint* | CANADA |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
Gold | Schone Edelmetaal B.V.* | NETHERLANDS |
Gold | SEMPSA Joyería Platería SA* | SPAIN |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CHINA |
Gold | So Accurate Group, Inc. | UNITED STATES |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
Gold | Tanaka Kikinzoku Kogyo K.K.* | JAPAN |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | The Refinery of Shandong Gold Mining Co., Ltd.* | CHINA |
Gold | Tokuriki Honten Co., Ltd.* | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda.* | BRAZIL |
Gold | Umicore SA Business Unit Precious Metals Refining* | BELGIUM |
Gold | United Precious Metal Refining, Inc.* | UNITED STATES |
Gold | Valcambi SA* | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint* | AUSTRALIA |
Gold | Yamamoto Precious Metal Co., Ltd.* | JAPAN |
Gold | Yokohama Metal Co., Ltd.* | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery* | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Umicore Precious Metals Thailand* | THAILAND |
Tantalum | Duoluoshan* | CHINA |
Tantalum | F&X Electro-Materials Ltd.* | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc.* | UNITED STATES |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
Tantalum | Zhuzhou Cemented Carbide* | CHINA |
Tantalum | FIR Metals & Resource Ltd.* | CHINA |
Tantalum | Plansee SE Liezen* | AUSTRIA |
Tantalum | H.C. Starck Co., Ltd.* | THAILAND |
Tantalum | H.C. Starck GmbH Goslar* | GERMANY |
Tantalum | H.C. Starck GmbH Laufenburg* | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
Tantalum | H.C. Starck Inc.* | UNITED STATES |
Tantalum | H.C. Starck Ltd.* | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG* | GERMANY |
Tantalum | Plansee SE Reutte* | AUSTRIA |
Tantalum | Global Advanced Metals Boyertown* | UNITED STATES |
Tantalum | Global Advanced Metals Aizu* | JAPAN |
Tantalum | KEMET Blue Powder* | UNITED STATES |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA |
Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd.* | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | Alpha* | UNITED STATES |
Tin | Cooperativa Metalurgica de Rondônia Ltda.* | BRAZIL |
Tin | CV Gita Pesona* | INDONESIA |
Tin | PT Justindo* | INDONESIA |
Tin | PT Aries Kencana Sejahtera* | INDONESIA |
Tin | CV Serumpun Sebalai* | INDONESIA |
Tin | CV United Smelting* | INDONESIA |
Tin | Dowa* | JAPAN |
Tin | EM Vinto* | BOLIVIA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Fenix Metals* | POLAND |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd.* | CHINA |
Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
Tin | Metallic Resources, Inc.* | UNITED STATES |
Tin | Metallum Group Holding NV | BELGIUM |
Tin | Mineração Taboca S.A.* | BRAZIL |
Tin | Minsur* | PERU |
Tin | Mitsubishi Materials Corporation* | JAPAN |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
Tin | Operaciones Metalurgical S.A.* | BOLIVIA |
Tin | PT Artha Cipta Langgeng* | INDONESIA |
Tin | PT Babel Inti Perkasa* | INDONESIA |
Tin | PT Bangka Kudai Tin | INDONESIA |
Tin | PT Bangka Putra Karya | INDONESIA |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
Tin | PT Bangka Tin Industry* | INDONESIA |
Tin | PT Belitung Industri Sejahtera* | INDONESIA |
Tin | PT BilliTin Makmur Lestari* | INDONESIA |
Tin | PT Bukit Timah* | INDONESIA |
Tin | PT DS Jaya Abadi* | INDONESIA |
Tin | PT Eunindo Usaha Mandiri* | INDONESIA |
Tin | PT Fang Di MulTindo | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Mitra Stania Prima* | INDONESIA |
Tin | PT Panca Mega Persada* | INDONESIA |
Tin | PT Prima Timah Utama* | INDONESIA |
Tin | PT Refined Bangka Tin* | INDONESIA |
Tin | PT Sariwiguna Binasentosa* | INDONESIA |
Tin | PT Seirama Tin Investment | INDONESIA |
Tin | PT Stanindo Inti Perkasa* | INDONESIA |
Tin | PT Supra Sukses Trinusa | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur* | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok* | INDONESIA |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
Tin | PT Tinindo Inter Nusa* | INDONESIA |
Tin | Rui Da Hung* | TAIWAN |
Tin | Soft Metais Ltda.* | BRAZIL |
Tin | Thaisarco* | THAILAND |
Tin | VQB Mineral and Trading Group JSC* | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda.* | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited* | CHINA |
Tin | CV Venus Inti Perkasa* | INDONESIA |
Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
Tin | PT Wahana Perkit Jaya* | INDONESIA |
Tin | Melt Metais e Ligas S.A.* | BRAZIL |
Tin | PT ATD Makmur Mandiri Jaya* | INDONESIA |
Tin | Phoenix Metal Ltd. | RWANDA |
Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
Tin | PT Inti Stania Prima* | INDONESIA |
Tin | CV Ayi Jaya* | INDONESIA |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | PT Cipta Persada Mulia* | INDONESIA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Resind Indústria e Comércio Ltda.* | BRAZIL |
Tin | Metallo-Chimique N.V.* | BELGIUM |
Tin | Elmet S.L.U.* | SPAIN |
Tin | PT Bangka Prima Tin* | INDONESIA |
Country of Origin May Include | Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States of America, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia, The Democratic Republic of Congo (DRC) |
• | Engaging suppliers of 3TG to improve the content of their responses. This includes a conflict-minerals flow down clause as well as new supplier or new material conflict minerals provisions as part of our “on boarding process.” |
• | Working through the EICC CFSI to expand the smelters and refiners participating in the EICC Conflict Free Smelter Program. |
• | Working with the OECD and relevant trade associations to define and improve best practices. |
• | Sourcing our upstream materials from conflict free validated mines which utilize traceability schemes to ensure complete chain of custody and maintain our EICC CFSP. |
• | whether the design of the Company’s due diligence framework as set forth in the Conflict Minerals Report for the reporting period from January 1 to December 31, 2015, is in conformity with, in all material respects, the criteria set forth in the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 (“OECD Due Diligence Guidance”) (“Objective #1”), and |
• | whether the Company’s description of the due diligence measures it performed, as set forth in the “Due Diligence Measures” section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2015, is consistent with the due diligence process that the Company undertook (“Objective #2”). |
• | the completeness, accuracy, or support of the process the Company uses to determine the scope of what products they manufacture or contract to manufacture are subject to the SEC Rule, or to due diligence; |
• | the consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance, other than as required to fulfill a stated audit objective; |
• | the completeness of the Company’s description of the due diligence measures performed; |
• | the suitability of the design or operating effectiveness of the Company’s due diligence process, |
• | whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance; |
• | the Company’s reasonable country of origin inquiry (“RCOI”), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof; or |
• | the Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products. |
• | reviewed documents and records provided by the Company in response to our requests; |
• | interviewed individuals involved in the due diligence steps described in the Conflict Minerals Report; and |
• | tested selected steps. |
• | the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2015, as set forth in the Due Diligence Measures section of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and |
• | the Company’s description of the due diligence measures it performed as set forth in the “Due Diligence Measures” section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2015, is consistent with the due diligence process that the Company undertook. |