EX-1.01 2 ex102conflictmineralsrepor.htm EXHIBIT 1.01 & 1.02 CONFLICT MINERALS REPORT Ex. 1.02 Conflict Minerals Report of Stanley Black & Decker, Inc. - 2014


EXHIBIT 1.02



STANLEY BLACK & DECKER, INC.
Conflict Minerals Report
For The Year Ended December 31, 2014

This report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“the Rule”).

1.    Overview

Stanley Black & Decker, Inc. ("the Company") is a diversified global provider of power and hand tools, products and services for various industrial applications, mechanical access solutions (i.e. automatic doors and commercial locking systems), and electronic security and monitoring systems. The Company manufactures products for which tin, tantalum, tungsten and gold ( "3TG minerals" or "conflict minerals") are necessary to the functionality or production of those products and which otherwise constitute products under the Rule.

In accordance with the Rule, the Company conducted a reasonable country of origin inquiry ("RCOI") that was reasonably designed to determine whether any of the 3TG minerals in the Company's products originated in the Democratic Republic of the Congo (the "DRC") or Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia ("adjoining countries"), or were from recycled or scrap services. Based on the Company's RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products originated in the DRC or adjoining countries and may not have been from recycled or scrap sources. Accordingly, the Company exercised due diligence to determine the source and chain of custody of these 3TG minerals. The Company's due diligence was designed to materially conform to the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) and the related Supplements for gold and for tin, tantalum and tungsten. A description of the Company's RCOI and due diligence measures is set forth in this report.

Product Description

The Company’s operations are classified into three operating segments: Tools & Storage, Security and Industrial.

Tools & Storage

The Tools & Storage segment is comprised of the Power Tools and Hand Tools & Storage businesses.

The Power Tools business includes professional products, consumer products and power tool accessories. Professional products include professional grade corded and cordless electric power tools and equipment including drills, impact wrenches and drivers, grinders, saws, routers and sanders, as well as pneumatic tools and fasteners including nail guns, nails, staplers and staples, and concrete and masonry anchors. Consumer products include corded and cordless electric power tools sold primarily under the Black & Decker brand, lawn and garden products, including hedge trimmers, string trimmers, lawn mowers, edgers and related accessories, and home products, such as hand held vacuums, paint tools and cleaning appliances. Power tool accessories include drill bits, router bits, abrasives and saw blades.

The Hand Tools & Storage business sells measuring, leveling and layout tools, planes, hammers, demolition tools, knives, saws, chisels and industrial and automotive tools. Storage products include tool boxes, sawhorses, medical cabinets and engineered storage solution products.

Security

The Security segment is comprised of the Convergent Security Solutions ("CSS") and Mechanical Access Solutions ("MAS") businesses.

The CSS business designs, supplies and installs electronic security systems and provides electronic security services, including alarm monitoring, video surveillance, fire alarm monitoring, systems integration and system maintenance. The business also sells healthcare solutions, which includes asset tracking solutions, infant protection, pediatric protection, patient protection, wander management, fall mana

4


gement, and emergency call products.

The MAS business sells automatic doors, commercial hardware, locking mechanisms, electronic keyless entry systems, keying systems, tubular and mortise door locksets.

Industrial

The Industrial segment is comprised of the Engineered Fastening and Infrastructure businesses.

The Engineered Fastening business primarily sells engineered fastening products and systems designed for specific applications. The product lines include stud welding systems, blind rivets and tools, blind inserts and tools, drawn arc weld studs, engineered plastic and mechanical fasteners, self-piercing riveting systems and precision nut running systems, micro fasteners, and high-strength structural fasteners.

The Infrastructure business consists of the Oil & Gas and Hydraulics businesses. The Oil & Gas business sells and rents custom pipe handling, joint welding and coating equipment used in the construction of large and small diameter pipelines, and provides pipeline inspection services. The Hydraulics business sells hydraulic tools and accessories primarily used for demolition and construction of large utilities, railroad and general infrastructure projects.

This report primarily covers the businesses and their products described above except for those which were determined to be out-of-scope of the Rule, primarily CSS and Oil & Gas.

Supply Chain

The Company both manufactures and contracts to manufacture its products described above, as well as components and raw materials for those products. Some of those products may be manufactured using 3TG minerals which are procured globally and from multiple suppliers who are several tiers away from the origin of and smelters of their raw materials. As such, the Company does not typically have a direct relationship with smelters and refiners of 3TG minerals. Additionally, the Company’s size, complexity of its products, and the depth, breadth and constant evolution of its supply chain, make it difficult to identify sub-tier suppliers from its direct suppliers, and therefore, the Company is reliant upon its direct suppliers to provide information on the origin of 3TG minerals contained in components and materials purchased. The Company’s suppliers are similarly reliant upon information provided by their suppliers and therefore face similar challenges to obtaining origin information. Additionally, many of the Company’s suppliers and its suppliers’ suppliers are foreign and not directly subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“the Dodd-Frank Act”).

Conflict Minerals Policy

The Company adopted the following Conflict Minerals Policy:

Stanley Black & Decker is committed to conducting business in an ethical, law abiding manner. This includes our commitment to not only comply with all applicable laws and regulations but also to operating our business on a foundation of integrity, trust and respect throughout our supply chain. Along with governmental and non-governmental organizations, civil society and affected third parties, we are concerned about the potential human rights issues, such as forced labor, inhumane or cruel treatment, and child labor, associated with the mining of Conflict Minerals (defined as tin, tungsten, tantalum and gold) which are occurring in the Democratic Republic of Congo ("DRC") and adjoining countries (“DRC region”).

Stanley Black & Decker is cognizant of our obligations under Section 1502 of the Dodd-Frank Act and is working with our suppliers to meet the due diligence and reporting requirements of Section 1502. As part of this process, we are helping our suppliers understand the due diligence steps they can take to investigate the source of any Conflict Minerals in the products they sell us. If, based on our due diligence, we determine there is a reasonable risk that Conflict Minerals in our products may be directly or indirectly linked to the financing of conflict in the DRC region, we will determine an appropriate course of action based on the facts and circumstances relating to the affected products. Such action may include, but is not limited to, the suspension or termination of our relationship with particular suppliers.

Determining whether all products sold by Stanley Black & Decker are Conflict Free is a time consuming and difficult process. We manufacture and distribute thousands of products, many of which contain, or may contain, the minerals that have been defined as Conflict Minerals. We source the raw materials and component parts for the products we manufacture, as well as finished products, from thousands of other companies around the world. Stanley Black & Decker is and has been working

5


with our suppliers to educate them regarding Stanley Black & Decker’s disclosure obligations under the Dodd-Frank Act and concerning steps they can take to obtain increased transparency regarding the origin of minerals contained in the products they supply to us.

Stanley Black & Decker has the following expectations of its suppliers:

•
suppliers should identify any products sold to Stanley Black & Decker that contain any Conflict Minerals which are not DRC Conflict Free;
•
suppliers should develop Conflict Minerals policies, due diligence frameworks, and management systems that are designed to prevent Conflict Minerals that are not DRC Conflict Free from being included in the products sold to Stanley Black & Decker; and
•
Stanley Black & Decker suppliers should source Conflict Minerals only from sources that are DRC conflict free.

In doing so, suppliers will be expected to:

•
implement and communicate to their personnel and suppliers policies that are consistent with this policy, and require their direct and indirect suppliers to do the same;
•
put in place procedures for the traceability of Conflict Minerals, working with their direct and indirect suppliers as applicable;
•
use reasonable efforts to source Conflict Minerals from smelters and refiners validated as being DRC Conflict Free, and require their direct and indirect suppliers to do the same;
•
advise Stanley Black & Decker of any determination that the supplier either has concluded or has a reasonable basis to believe the products it currently sells or has sold to Stanley Black & Decker are not DRC Conflict Free;
•
maintain reviewable business records supporting the source of Conflict Minerals; and
•
from time to time, at Stanley Black & Decker's request, provide Stanley Black & Decker with information concerning the origin of Conflict Minerals included in products sold to Stanley Black & Decker, which Stanley Black & Decker shall be entitled to use or disclose in satisfying any legal or regulatory requirements or in any customer or marketing communications, notwithstanding the terms of a confidentiality agreement that do not specifically reference this paragraph.

Suppliers also are encouraged to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains.

Consequences of supplier noncompliance

Stanley Black & Decker evaluates its relationships with its suppliers on an ongoing basis. Stanley Black & Decker reserves the right to evaluate the extent to which a supplier has failed to reasonably comply with this policy. Stanley Black & Decker also reserves the right to request additional documentation from suppliers regarding the origin of any Conflict Minerals included in any products sold to Stanley Black & Decker.

Suppliers who do not reasonably comply with this policy shall be reviewed by Stanley Black & Decker’s Global Supply Management ("GSM") organization for future business.

In the event Stanley Black & Decker determines that the supplier’s efforts to comply with this policy have been deficient and the supplier fails to cooperate in developing and implementing reasonable remedial steps, Stanley Black & Decker reserves the right to take appropriate actions up to and including discontinuing purchases from the supplier. Nothing in this policy is intended to in any way grant any additional rights or expectations to any Stanley Black & Decker supplier or in any way modify or otherwise limit in any way any of Stanley Black & Decker's contractual or legal rights.

Grievance mechanism and reporting

Our employees, suppliers and other parties can report concerns and alleged violations of this policy as follows:

(i)
Write us at Stanley Black & Decker: Stanley Black & Decker, Inc., Attn: Conflict Minerals Steering Committee, 1000 Stanley Drive, New Britain, CT 06053
(ii)
e-mail us at: [conflictminerals@sbdinc.com]
(iii)
Call us at: 877-795-2358


6


Reports can be made anonymously and will be kept confidential to the fullest extent practicable and allowed by law. We will not take any retaliatory action against our employees, suppliers or other parties who make a report in good faith. Our suppliers are encouraged to contact [conflictminerals@sbdinc.com] if they wish to seek guidance on the application of this policy.

Conclusion

Stanley Black & Decker fully understands the importance of this issue to its customers and is committed to supply chain initiatives and overall corporate social responsibility and sustainability efforts that work towards a DRC Conflict Free supply chain. We encourage all of our suppliers to likewise support these efforts.

This policy is publicly available at www.stanleyblackanddecker.com/corporategovernance/conflictminerals.

RCOI

Prior to conducting the Company's RCOI, the Company performed a risk-based assessment of its products for components and/or raw materials which were most likely to contain 3TG minerals. The Company required direct suppliers of those components and/or raw materials to complete a supply chain survey using the Conflict-Free Sourcing Initiative's ("CFSI") Conflict Minerals Reporting Template to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.

Suppliers who were delinquent in responding to the Company's survey by the specified date, were contacted, at a minimum, via two non-system generated emails and a phone call or read receipt email, in an effort to obtain responses.

Smelters and refiners identified in the survey responses were aggregated and then validated against the CFSI's Standard Smelter List, and once validated, against the CFSI's Conflict Free Smelter Program ("CFSP") to determine compliance status. CFSP compliant smelters and refiners were than validated against the CFSI's RCOI Data Document to determine country of origin information for the minerals being processed by the smelters and refiners.

Based on the suppliers' responses to the RCOI, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries and may not have been from recycled or scrap sources.

2.    Due Diligence

2.1    Design of Due Diligence

The Company's due diligence measures are designed to materially conform with the Organisation for Economic Co-operation and Development ("the OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (2013) and the related Supplements for gold and for tin, tantalum and tungsten (collectively "the OECD Guidance").

OECD Step 1: Establish Strong Company Management Systems

Company Policy

The Company has a Conflict Mineral Policy which is posted on its website at www.stanleyblackanddecker.com/corporategovernance/conflictminerals.

Internal Team

The Company has a Steering Committee sponsored by the Company’s Chief Financial Officer, as well as a Working Group. Members of the Steering Committee and Working Group are subject matter experts from relevant functions such as Global Supply Management, Sustainability, Finance and Legal. The Steering Committee is responsible for oversight of the Company’s conflict minerals compliance strategy and due diligence process, monitoring the due diligence progress, ensuring communication of critical information reaches employees and suppliers, and ensuring the timely and accurate filing of this report. The Working Group is charged with implementation of the Company's policy, conducting due diligence, communications to suppliers and others, and reporting its progress to the Steering Committee on a regular basis.


7


System of Controls and Transparency Over the Supply Chain

The Company utilizes the Conflict-Free Sourcing Initiative's (“CFSI”) Conflict Minerals Reporting Template (“the CMRT”), a supply chain survey designed to gather information from a company's suppliers to determine whether any of the components and/or raw materials provided to the company originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, to enable the identification of smelters and refiners that process the 3TG minerals.

Supplier Engagement

The Company's Conflict Mineral Policy is posted on its supplier portal for all suppliers to access. Additionally, the Company's supplier Master Purchase Agreements include a Conflict Minerals provision which requires its suppliers to provide information necessary to allow the Company and its customers to comply with the provisions of the Dodd-Frank Act and explicitly gives the Company the rights to audit the supply chain and terminate arrangements with suppliers who are unwilling or unable to comply. As supplier Master Purchase Agreements are generally in force for one to three years, it will take a number of years to ensure that all Master Purchase Agreements contain this provision. While the Company cannot unilaterally impose new contract terms, including those that would compel its suppliers to support the Company's conflict minerals due diligence efforts, existing Master Purchase Agreements contain a compliance with laws clause which provides for the Company’s suppliers to abide by directives from the Company to be in compliance with applicable laws.

Grievance Mechanism

The Company has an established grievance mechanism for reporting violations of the Company’s policies.

Maintain Records

The Company maintains Conflict Mineral related information in accordance with its record retention policy.

OECD Step 2: Identify and Assess Risk in the Supply Chain

The Company performs a risk-based assessment of its products for components and/or raw materials which are most likely to contain 3TG minerals and surveys suppliers of those components and/or raw materials using the CMRT to determine whether any of those components and/or raw materials originated in the DRC or adjoining countries, or were from recycled or scrap sources, and, if applicable, identify smelters and refiners in the Company's supply chain. Identified smelters and refiners are aggregated and validated against the CFSI's Standard Smelter List, and once validated, against the CFSI's Conflict Free Smelter Program ("CFSP") to determine compliance status.

The Company reviews responses to the survey for red flags in order to identify areas of potential risk such as incomplete responses, insufficient due diligence or potentially higher risk sourcing based upon criteria internally defined.

OECD Step 3: Design and Implement a Strategy to Respond to Identified Risks

Results of the supply chain assessment are reported to the Steering Committee which is responsible for monitoring any actual or potential risks identified in the supply chain and reporting findings to the Company's Chief Financial Officer.

The Company has a risk mitigation plan to manage its non-compliant suppliers towards conformity with the Company's Conflict Mineral policy. GSM is responsible for taking appropriate actions up to and including suspension or termination of the Company's relationship with non-compliant suppliers.

The Company supports the CFSI's Conflict Free Smelter Program ("CFSP") which audits smelters' and refiners' due diligence activities. The data on which the Company relies for certain statements in this report is obtained through the Company's membership (member "SBDI") in the CFSI, using the reasonable country of origin inquiry report for the Company, or based upon the information publicly available on the CFSI's website.

The Company's new product introduction process includes a step to ensure information on the presence of 3TG minerals in new products is provided to the Working Group for integration into the Company's due diligence procedures. The Company has also revised its new product specifications to ensure that the use of 3TG is limited solely to the product's functionality.


8


OECD Step 4: Carry Out Independent Third Party Audit of Smelter/Refiner's Due Diligence Practices

The Company supports the CFSP's efforts to audit the due diligence practices of the smelters and refiners, through its active membership in the CFSI. The Company utilizes information on the CFSI's website (www.conflictfreesmelter.org) to determine which smelters and refiners are CFSP compliant.

OECD Step 5: Report Annually on Supply Chain Due Diligence

This report is the Company’s annual report on its due diligence, is filed along with Form SD with the Securities and Exchange Commission, and is publicly available on the Company’s website.

2.2    Due Diligence Performed

The Company performed the following due diligence for the reporting period:

•
Identified suppliers of components and/or raw materials which were most likely to contain 3TG minerals and surveyed those suppliers using the latest published CMRT. Those suppliers were engaged through direct electronic communication from the Vice President of GSM, followed by an electronic communication through the Company’s supplier relationship management tool.
•
Identified suppliers providing 3TG minerals from the DRC or adjoining countries and compiled an aggregate list of smelters and refiners identified by those suppliers.
•
Compared those identified smelters and refiners against those smelters and refiners as validated by the CFSI.
•
Compared those validated smelters and refiners against those identified by the CFSI's CFSP as CFSP compliant or CFSP active and for those that are CFSP compliant, against the CFSI's RCOI Data Document to determine country of origin for the 3TG minerals processed by those smelters and refiners.
•
Provided non-responsive suppliers and red flag suppliers to GSM for follow-up.
•
Reported status of due diligence progress, including identification of red flag suppliers, to the Company's Steering Committee and to the Company's Chief Financial Officer.
•
Supported the CFSP through maintenance of an active membership in the CFSI.

3.    Due diligence Results

The Company received responses from 58% of its suppliers surveyed. The Company’s suppliers are generally several tiers away from the origin of and smelters of their raw materials, and are therefore faced with similar challenges in performing their due diligence. In some instances, the information provided by the Company's suppliers is incomplete or not verified, and the Company is therefore unable to verify with certainty the source and chain of custody of all the 3TG minerals in the Company's supply chain.

The Company identified 254 smelters and refiners, as reported by the Company's suppliers, as potentially having processed the 3TG minerals contained in the Company's products for the reporting period. Some of the Company's suppliers responded at a company-level rather than product-level; therefore, there may be more smelters and refiners included in the Company's results than those that actually processed the 3TG minerals contained in the Company's products. The Company has only included in its results those smelters and refiners that have been validated as smelters and refiners appearing on the CFSI Standard Smelter List as of November 7, 2014. Other processing facilities were reported in the Company's supply chain; however, are not included in its results, as they have not yet been validated by the CFSI. The identified smelters and refiners are further broken out as follows:
Smelters and Refiners
Gold
Tantalum
Tin
Tungsten
Number of CFSI validated
96
40
86
32
Number of CFSP compliant
50
31
28
19*
% CFSP compliant
52%
78%
33%
59%
*Includes 10 smelters and refiners that are active in the CFSP as of April 29, 2015.

The following tables list smelters and refiners identified by the Company's suppliers' survey responses.





9


Table 1. CFSP Compliant Smelters and Refiners

The following table lists smelters and refiners identified by the Company's suppliers' survey responses that have been validated as compliant according to the CFSP as of April 29, 2015 for gold, tantalum and tungsten, and May 1, 2015 for tin.
Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Gold
Aida Chemical Industries Co. Ltd.
CID000019
Japan
Gold
Argor-Heraeus SA
CID000077
Switzerland
Gold
Atasay Kuyumculuk Sanayi ve Ticaret A.S.
CID000103
Turkey
Gold
Aurubis AG
CID000113
Germany
Gold
Boliden AB
CID000157
Sweden
Gold
C. Hafner GmbH + Co. KG
CID000176
Germany
Gold
Dowa
CID000401
Japan
Gold
Eco-System Recycling Co., Ltd.
CID000425
Japan
Gold
Heimerle + Meule GmbH
CID000694
Germany
Gold
Heraeus Ltd. Hong Kong
CID000707
China
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Germany
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Japan
Gold
Istanbul Gold Refinery
CID000814
Turkey
Gold
Japan Mint
CID000823
Japan
Gold
Johnson Matthey Inc
CID000920
United States
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Russia
Gold
Kazzinc Ltd
CID000957
Kazakhstan
Gold
Kennecott Utah Copper LLC
CID000969
United States
Gold
L'azurde Company For Jewelry
CID001032
Saudi Arabia
Gold
Materion
CID001113
United States
Gold
Metalor Technologies (Hong Kong) Ltd
CID001149
Hong Kong
Gold
Metalor Technologies (Singapore) Pte. Ltd.
CID001152
Singapore
Gold
Metalor Technologies SA
CID001153
Switzerland
Gold
Metalor USA Refining Corporation
CID001157
United States
Gold
METALURGICA MET-MEX PENOLES, S.A. DE C.V.
CID001161
Mexico
Gold
Mitsubishi Materials Corporation
CID001188
Japan
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Japan
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
CID001220
Turkey
Gold
Nihon Material Co. LTD
CID001259
Japan
Gold
Ohura Precious Metal Industry Co., Ltd
CID001325
Japan
Gold
OJSC Krastvetmet
CID001326
Russia
Gold
PAMP SA
CID001352
Switzerland
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Indonesia
Gold
PX Précinox SA
CID001498
Switzerland
Gold
Rand Refinery (Pty) Ltd
CID001512
South Africa
Gold
Republic Metals Corporation
CID002510
United States
Gold
Royal Canadian Mint
CID001534
Canada
Gold
Schöne Edelmetaal B.V.
CID001573
Netherlands
Gold
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
CID001622
China
Gold
Solar Applied Materials Technology Corp.
CID001761
Taiwan
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Japan
Gold
The Refinery of ShandongGold Mining Co. Ltd
CID001916
China
Gold
Umicore Brasil Ltda
CID001977
Brazil
Gold
Umicore Precious Metals Thailand
CID002314
Thailand
Gold
Umicore SA Business Unit Precious Metals Refining
CID001980
Belgium
Gold
Valcambi SA
CID002003
Switzerland
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Australia
Gold
YAMAMOTO PRECIOUS METAL CO., LTD.
CID002100
Japan
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
China

10


Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Gold
Zijin Mining Group Co. Ltd
CID002243
China
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
China
Tantalum
Conghua Tantalum and Niobium Smeltry
CID000291
China
Tantalum
Duoluoshan
CID000410
China
Tantalum
Exotech Inc.
CID000456
United States
Tantalum
Global Advanced Metals Boyertown
CID002557
United States
Tantalum
Global Advanced Metals Aizu
CID002558
Japan
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
China
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
CID002501
China
Tantalum
H.C. Starck Co., Ltd.
CID002544
Thailand
Tantalum
H.C. Starck GmbH Goslar
CID002545
Germany
Tantalum
H.C. Starck GmbH Laufenburg
CID002546
Germany
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Germany
Tantalum
H.C. Starck Inc.
CID002548
United States
Tantalum
H.C. Starck Ltd.
CID002549
Japan
Tantalum
H.C. Starck Smelting GmbH & Co.KG
CID002550
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
China
Tantalum
Hi-Temp Specialty Metals, Inc.
CID000731
United States
Tantalum
Kemet Blue Powder
CID002568
United States
Tantalum
KEMET Blue Metals
CID002539
Mexico
Tantalum
King-Tan Tantalum Industry Ltd
CID000973
China
Tantalum
Metallurgical Products India (Pvt.) Ltd.
CID001163
India
Tantalum
Mineração Taboca S.A.
CID001175
Brazil
Tantalum
Mitsui Mining & Smelting
CID001192
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
China
Tantalum
Plansee SE Liezen
CID002540
Austria
Tantalum
Plansee SE Reutte
CID002556
Austria
Tantalum
QuantumClean
CID001508
United States
Tantalum
Taki Chemicals
CID001869
Japan
Tantalum
Telex
CID001891
United States
Tantalum
Ulba
CID001969
Kazakstan
Tantalum
Zhuzhou Cement Carbide
CID002232
China
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
China
Tin
Cooper Santa
CID000295
Brazil
Tin
CV United Smelting
CID000315
Indonesia
Tin
Dowa
CID000402
Japan
Tin
EM Vinto
CID000438
Bolivia
Tin
Minsur
CID001182
Peru
Tin
Magnu's Minerais Metais e Ligas LTDA
CID002468
Brazil
Tin
Melt Metais e Ligas S/A
CID002500
Brazil
Tin
Mineração Taboca S.A.
CID001173
Brazil
Tin
Mitsubishi Materials Corporation
CID001191
Japan
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Malaysia
Tin
Operaciones Metalurgical S.A. (OMSA)
CID001337
Bolivia
Tin
PT Artha Cipta Langgeng
CID001399
Indonesia
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Indonesia
Tin
PT Babel Inti Perkasa
CID001402
Indonesia
Tin
PT Bangka Putra Karya
CID001412
Indonesia
Tin
PT Bangka Tin Industry
CID001419
Indonesia
Tin
PT Belitung Industri Sejahtera
CID001421
Indonesia
Tin
PT Bukit Timah
CID001428
Indonesia
Tin
PT DS Jaya Abadi
CID001434
Indonesia
Tin
PT Eunindo Usaha Mandiri
CID001438
Indonesia

11


Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Tin
PT Mitra Stania Prima
CID001453
Indonesia
Tin
PT Sariwiguna Binasentosa
CID001463
Indonesia
Tin
PT Stanindo Inti Perkasa
CID001468
Indonesia
Tin
PT Tambang Timah
CID001477
Indonesia
Tin
PT Tinindo Inter Nusa
CID001490
Indonesia
Tin
PT Wahana Perkit Jaya
CID002479
Indonesia
Tin
Thaisarco
CID001898
Thailand
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
China
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
China
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
China
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
China
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
China
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
China
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd
CID002011
Vietnam
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Austria
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
China

The Company requested both country of origin information and mine or location of origin information from its suppliers for purposes of determining the source and chain of custody of the 3TG minerals in the Company's supply chain. The Company relied on country of origin information provided by its suppliers (if known), as well as by the CFSI's CFSP and RCOI Data Document. Some of the Company's suppliers provided mine or location of origin information, but many were unable to obtain such information for their 3TG minerals.

Eight of the CFSP compliant gold smelters and refiners included in Table 1 have disclosed mineral sources as originating from recycled and scrap sources and/or from the following countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Côte d'Ivoire, Czech Republic, Djibouti, 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 and Zimbabwe. The remaining gold smelters and refiners' mineral sources is not available as of March 31, 2015.

CFSP compliant tantalum, tin and tungsten smelters and refiners included in Table 1 have disclosed mineral sources as originating from Kenya, Mozambique, South Africa, and the DRC and adjoining countries, in addition to the countries listed above and recycled and scrap sources.

Based on this country of origin information, the Company has reason to believe that some of the 3TG minerals used in the Company's products may have originated in the DRC or adjoining countries.

Table 2. CFSP Participating Smelters and Refiners

The following table lists smelters and refiners identified by the Company's suppliers ' survey responses that have agreed to participate in the CFSP but have not yet completed the program as of April 29, 2015.
Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Tungsten
A.L.M.T. Corp.
CID000004
Japan
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CID000345
China
Tungsten
H.C. Starck GmbH
CID002541
Germany
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Germany
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
China
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Vietnam
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
China


12


Mineral sources for CFSP participating smelters and refiners are not available.

Table 3. Smelters and Refiners with No Known CFSP Participation

The following table lists smelters and refiners identified by the Company's suppliers ' survey responses that have not been validated as compliant according to the CFSP as of April 29, 2015 for gold, tantalum and tungsten, and May 1, 2015 for tin.
Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Gold
Advanced Chemical Company
CID000015
United States
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Uzbekistan
Gold
Asaka Riken Co Ltd
CID000090
Japan
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Philippines
Gold
Bauer Walser AG
CID000141
Germany
Gold
Caridad
CID000180
Mexico
Gold
China National Gold Group Corporation
CID000242
China
Gold
Chugai Mining
CID000264
Japan
Gold
Colt Refining
CID000288
United States
Gold
Daejin Indus Co. Ltd
CID000328
Korea
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
China
Gold
Do Sung Corporation
CID000359
Korea
Gold
Doduco
CID000362
Germany
Gold
EM Vinto
CID000438
Bolivia
Gold
FSE Novosibirsk Refinery
CID000493
Russia
Gold
Gansu Seemine Material Hi-Tech Co Ltd
CID000522
China
Gold
Guangdong Jinding Gold Limited
CID002312
China
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
China
Gold
Hunan Chenzhou Mining Group Co., Ltd.
CID000767
China
Gold
Hwasung CJ Co. Ltd
CID000778
Korea
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CID000801
China
Gold
Jiangxi Copper Company Limited
CID000855
China
Gold
Korea Metal Co. Ltd
CID000988
Korea
Gold
Kyrgyzaltyn JSC
CID001029
Kyrgyzstan
Gold
Lingbao Gold Company Limited
CID001056
China
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
CID001058
China
Gold
Luoyang Zijin Yinhui Metal Smelt Co Ltd
CID001093
China
Gold
Metallo Chimique
CID001143
Belgium
Gold
Minsur
CID001182
Peru
Gold
Moscow Special Alloys Processing Plant
CID001204
Russia
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Uzbekistan
Gold
OJSC Kolyma Refinery
CID001328
Russia
Gold
OMSA
CID001337
Bolivia
Gold
Penglai Penggang Gold Industry Co Ltd
CID001362
China
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Russia
Gold
PT Babel Surya Alam Lestari
CID001406
Indonesia
Gold
Sabin Metal Corp.
CID001546
United States
Gold
Samduck Precious Metals
CID001555
Korea
Gold
SAMWON METALS Corp.
CID001562
Korea
Gold
So Accurate Group, Inc.
CID001754
United States
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Russia
Gold
The Great Wall Gold and Silver Refinery of China
CID001909
China
Gold
Tongling nonferrous Metals Group Co.,Ltd
CID001947
China
Gold
Torecom
CID001955
Korea
Gold
Yokohama Metal Co Ltd
CID002129
Japan
Gold
Yunnan Copper Industry Co Ltd
CID000197
China
Tantalum
A.L.M.T. Corp.
CID000004
Japan

13


Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Tantalum
H.C. Starck GmbH
CID002541
Germany
Tantalum
Hunan Chenzhou Mining Group Co., Ltd.
CID000767
China
Tantalum
PT Bangka Timah Utama Sejahtera
CID001416
Indonesia
Tantalum
Rui Da Hung
CID001539
Taiwan
Tantalum
Shanghai Jiangxi Metals Co. Ltd
CID001634
China
Tantalum
Wolfram Bergbau und Hütten AG
CID002044
Austria
Tantalum
Wolfram Company CJSC
CID002047
Russia
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd
CID002307
China
Tin
PT Koba Tin
CID001449
Indonesia
Tin
Fenix Metals
CID000468
Poland
Tin
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Germany
Tin
C. Hafner GmbH + Co. KG
CID000176
Germany
Tin
CNMC (Guangxi) PGMA Co. Ltd.
CID000278
China
Tin
CV Gita Pesona
CID000306
Indonesia
Tin
CV JusTindo
CID000307
Indonesia
Tin
CV Makmur Jaya
CID000308
Indonesia
Tin
CV Nurjanah
CID000309
Indonesia
Tin
CV Serumpun Sebalai
CID000313
Indonesia
Tin
CV Venus Inti Perkasa
CID002455
Indonesia
Tin
Dowa
CID000401
Japan
Tin
Estanho de Rondônia S.A.
CID000448
Brazil
Tin
FSE Novosibirsk Refinery
CID000493
Russia
Tin
Gejiu Zi-Li
CID000555
China
Tin
Heimerle + Meule GmbH
CID000694
Germany
Tin
Heraeus Precious Metals GmbH & Co. KG
CID000711
Germany
Tin
Huichang Jinshunda Tin Co. Ltd
CID000760
China
Tin
Ishifuku Metal Industry Co., Ltd.
CID000807
Japan
Tin
Japan Mint
CID000823
Japan
Tin
Japan New Metals Co., Ltd.
CID000825
Japan
Tin
Jiangxi Nanshan
CID000864
China
Tin
Johnson Matthey Inc
CID000920
United States
Tin
Linwu Xianggui Smelter Co
CID001063
China
Tin
Metallo Chemique
CID001143
Belgium, Spain
Tin
Mineração Taboca S.A.
CID001175
Brazil
Tin
Mitsubishi Materials Corporation
CID001188
Japan
Tin
Mitsui Mining and Smelting Co., Ltd.
CID001193
Japan
Tin
Novosibirsk Integrated Tin Works
CID001305
Russia
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Thailand
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Philippines
Tin
PT Alam Lestari Kencana
CID001393
Indonesia
Tin
PT Aneka Tambang (Persero) Tbk
CID001397
Indonesia
Tin
PT Babel Surya Alam Lestari
CID001406
Indonesia
Tin
PT Bangka Kudai Tin
CID001409
Indonesia
Tin
PT Bangka Timah Utama Sejahtera
CID001416
Indonesia
Tin
PT BilliTin Makmur Lestari
CID001424
Indonesia
Tin
PT Donna Kembara Jaya
CID002473
Indonesia
Tin
PT Fang Di MulTindo
CID001442
Indonesia
Tin
PT HANJAYA PERKASA METALS
CID002287
Indonesia
Tin
PT HP Metals Indonesia
CID001445
Indonesia
Tin
PT Inti Stania Prima
CID002530
Indonesia
Tin
PT Karimun Mining
CID001448
Indonesia
Tin
PT Rajwa International
CID002475
Indonesia
Tin
PT Seirama Tin investment
CID001466
Indonesia

14


Mineral
Smelter or Refiner Facility Name
CFSI Smelter Identification
Facility Location
Tin
PT Singkep Times Utama
CID002476
Indonesia
Tin
PT Sumber Jaya Indah
CID001471
Indonesia
Tin
PT Supra Sukses Trinusa
CID001476
Indonesia
Tin
PT Tirus Putra Mandiri
CID002478
Indonesia
Tin
PT Tommy Utama
CID001493
Indonesia
Tin
PT Yinchendo Mining Industry
CID001494
Indonesia
Tin
Rui Da Hung
CID001539
Taiwan
Tin
Sumitomo Metal Mining Co., Ltd.
CID001798
Japan
Tin
Tanaka Kikinzoku Kogyo K.K.
CID001875
Japan
Tin
Torecom
CID001955
Korea
Tin
Western Australian Mint trading as The Perth Mint
CID002030
Australia
Tin
Yokohama Metal Co Ltd
CID002129
Japan
Tin
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
China
Tungsten
Ganxian Shirui New Material Co., Ltd.
CID002531
China
Tungsten
Hi-Temp
CID000731
United States
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
China
Tungsten
Jiangxi Richsea New Materials Co., Ltd.
CID002493
China
Tungsten
JX Nippon Mining & Metals Co., Ltd.
CID000937
Japan
Tungsten
Materion
CID001113
United States
Tungsten
Metallo Chimique
CID001143
Belgium
Tungsten
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
China
Tungsten
Solar Applied Materials Technology Corp.
CID001761
Taiwan
Tungsten
Sumitomo Metal Mining Co., Ltd.
CID001798
Japan
Tungsten
Thaisarco
CID001898
Thailand
Tungsten
Wolfram Company CJSC
CID002047
Russia
Tungsten
Zhuzhou Cement Carbide
CID002232
China

4.    Steps to be Taken to Mitigate Risk

The Company intends to take the following steps to mitigate the risk that 3TG minerals contained in the Company’s products could benefit armed groups in the DRC or adjoining countries:

•
Engage further with the Company's suppliers to improve response rates and the content of responses, including names, country of origin and mine or location of origin. Continue to use and encourage the Company's suppliers to use the Conflict Minerals Resources Center and other publicly available tools from the CFSI. Engage suppliers to request their smelters and refiners participate in the CFSP or other independent third party audit programs.
•
Provide non-validated processing facilities to the CFSI for validation and potential participation in the CFSP.
•
Continue to support the CFSI's efforts to support the responsible sourcing of minerals.
•
Encourage the Company's suppliers to consider alternative sources for the 3TG minerals.
•
Continue to integrate Conflict Minerals contractual language in the Company’s new or renewed supplier contracts.
•
Determine an appropriate course of action which may include, but is not limited to, the suspension or termination of the Company's relationship with a non-compliant supplier.

The Company recognizes that due diligence is a dynamic process and requires on-going risk monitoring. After implementing these risk mitigation strategies, the Company will reassess the effectiveness of its risk management plan, and may adapt further strategies or refine existing strategies to ensure effective risk mitigation. Furthermore, future acquisitions will be integrated into the Company's due diligence processes.





15