COLORADO | 1-12551 | 84-1250533 |
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (I.R.S. Employer Identification No.) |
200 FIRST STAMFORD PLACE | ||
STAMFORD, CT | 06902 | |
(Address of principal executive offices) | (Zip Code) | |
Scott J. Goodwin, (203) 595-3000 | ||
(Name and telephone number, including area code, of the person to contact in connection with this report) |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015. |
Date: | May 26, 2016 | CENVEO, INC. |
s/ Scott J. Goodwin | ||
Scott J. Goodwin | ||
Chief Financial Officer |
• | Establishing a Conflict Minerals Policy (published at www.cenveo.com), incorporating the standards set forth in the OECD Framework. Each year this policy is reviewed by the individuals who administer Cenveo’s conflict minerals program to ensure any changes made by governing bodies and/or Cenveo are reflected. |
• | Expanding and improving education and training to company personnel. Cenveo personnel who have influence over sourcing decisions are required to participate in annual training sessions. These sessions are offered in multiple formats including live training and user self-guided training. The annual training requirement allows Cenveo personnel to keep current with Cenveo’s conflict minerals program and enables any new personnel to be properly introduced to Cenveo’s program. At the conclusion of the training, such personnel are required to submit an attestation form indicting they have taken the course and understand the material. |
• | Incorporating conflict minerals due diligence procedures into assigned roles and responsibilities. Cenveo has a dedicated group, Supplier Information Management (SIM), who is responsible for administering our conflict minerals program. SIM is part of Central Purchasing Services who reports directly to the Executive Vice President of Global Supply Chain. SIM is governed by standard operating procedures that are reviewed at a minimum of two times per year. The first review takes place following the annual filing of Cenveo’s Form SD with the SEC to incorporate any lessons learned during the reporting period and/or process improvements. The second review takes place at the end of each calendar year. In addition, Cenveo has dedicated legal counsel (internal and external) who provide regular guidance regarding the program. |
• | Conducting an internal assessment to identify materials that could contain 3TG metals and suppliers who sourced those materials to Cenveo. The SIM team and Operations leadership review changes in the business to determine if material changes have been made in the way we produce our products and/or if changes have been made in the materials used in our products. The SIM team controls every new supplier added to Cenveo’s supplier base. As such, we are able to scrutinize new suppliers for their potential to introduce 3TG into our products and processes, both at the time they are added as a supplier and during the annual assessment. |
• | Conducting a survey on our supply chain to obtain country of origin information for the necessary 3TG metals in our products using a slightly modified version of the CMRT as a basis to identify the applicable smelters and refiners and countries of origin of the 3TG metals in our products. On an annual basis SIM conducts an assessment of suppliers using a supply-chain survey. Every survey response is subjected to two separate reviews to assess responses for logic and completeness. This year we surveyed 641 suppliers of which 596 responded. Survey responses collectively identified 14 suppliers as having 3TG in the products they supply to Cenveo. |
• | Comparing the smelters and refiners identified in the supply-chain survey against the list of smelter facilities which have been identified as "conflict free" by programs such as the EICC/GeSI Conflict Free Smelter (CFS) program for 3TG metals. As a result of our annual survey, we identified 14 suppliers as having 3TG in the products they supply to Cenveo. There were 4 suppliers who collectively identified 13 common smelters, all of which were on the EICC/GeSI Conflict Free Smelters List. There were 10 suppliers who submitted statements from three second tier suppliers (common to all of the 10 first tier suppliers) that based on due diligence from their supply chains, the 3TG contained in their products did not originate from the Covered Countries. |
• | Finding alternative suppliers for vendors not responding timely or sufficiently. On an ongoing basis and during the annual survey process, SIM gathers evidence from existing suppliers and/or those who are being recommended as a new supplier to Cenveo to determine if their products contain 3TG and, if so, the source of those minerals. Those suppliers who fail to produce adequate evidence or refuse to provide evidence are removed from our supply base and/or not approved for use. SIM also works with Operations to identify alternative sources for products containing conflict minerals, as necessary. |
Metal | Smelter Name | Smelter Country | Smelter Identification | |
1 | Tin | Mineração Taboca S.A. | BRAZIL | CID001173 |
2 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
3 | Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 |
4 | Tin | Metallo-Chimique N.V. | BELGIUM | CID002773 |
5 | Tin | EM Vinto | BOLIVIA | CID000438 |
6 | Tin | Minsur | PERU | CID001182 |
7 | Tin | Operaciones Metalurgical S.A. | BOLIVIA | CID001337 |
8 | Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 |
9 | Tin | Thaisarco | THAILAND | CID001898 |
10 | Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | CID000295 |
11 | Tin | CV United Smelting | INDONESIA | CID000315 |
12 | Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
13 | Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |