Exhibit 1.01
NOVANTA INC.
Conflict Minerals Report
For the Period January 1 to December 31, 2018
Introduction
This report has been prepared by Novanta Inc. (“Novanta,” the “Company,” “we,” or “our”) for the period from January 1, 2018 to December 31, 2018 (the “Reporting Period”) in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, which was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”).
The term “conflict minerals” is defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are currently limited to tin, tantalum, tungsten, and gold (“the 3TGs”) for the purposes of this report. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain 3TGs that are necessary to the functionality or production of their products.
The Company conducted an analysis of its products and found that 3TGs are present in many of the electronic parts and components included in the Company’s products. Therefore, the Company is subject to the reporting obligations of Rule 13p-1.
The Company’s supply chain is complex. The Company uses a wide variety of raw materials, key components and parts that are purchased from both domestic and international suppliers. The Company also uses contract manufacturers to make certain key components used in the production of the Company’s finished products. As the Company’s manufacturing process consists mostly of final assembly of components and parts that are purchased from suppliers, there are typically several tiers of companies between Novanta and the mines, smelters or refiners of conflict minerals. The Company does not directly source 3TG minerals as raw materials. Therefore, it is difficult to identify the origin of conflict minerals that are present in the Company’s products.
Due to the size and complexity of the Company’s supply chain, Novanta has to rely on its suppliers to provide information on the origin of the conflict minerals contained in the components and materials supplied to Novanta, including sources of conflict minerals present in the materials and components supplied to Novanta’s suppliers themselves.
Company Overview and Products Covered by This Report
Novanta is a global supplier of core technology solutions that give medical and advanced industrial Original Equipment Manufacturers (“OEMs”) a competitive advantage. We combine deep proprietary technology expertise and competencies in photonics, vision and precision motion with a proven ability to solve complex technical challenges. This enables Novanta to engineer core components and sub-systems that deliver extreme precision and performance, tailored to our customers’ demanding applications.
The Company is organized into three reportable segments: Photonics, Vision and Precision Motion. The Photonics segment designs, manufactures and markets photonics-based solutions, including CO2 lasers, solid state and ultrafast lasers, galvanometer and polygon-based optical scanning components and scan heads, and optical light engines. The Vision segment designs, manufactures and markets a wide range of medical grade technologies, including insufflators, pumps, light sources and video couplers, gamma probes and related accessories for minimally invasive surgery, high definition visualization solutions, video processing and streaming products for surgical applications, wireless video signal transmission devices, embedded capacitive and resistive touch panel technology, camera-based machine vision products and solutions, RFID technologies, embedded and handheld data collection products for barcode scanning, rugged thermal chart recorders, and light and color measurement devices. The Precision Motion segment designs, manufactures and markets optical and inductive encoders, direct drive motor components, integrated motion sub-assemblies, high-speed and
precision air bearings and air bearing spindles.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals necessary to the functionality or production of our products. Our RCOI was reasonably designed to determine whether such conflict minerals originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (collectively, the “Covered Countries”) or came from scrap or recycled sources. The Company began the scoping process by compiling a list of all suppliers that provide us with products that may contain any 3TGs. Once this list was populated, we provided the list and the applicable contacts for the suppliers to our third-party service provider (the “Service Provider”). This list was then uploaded to the Service Provider’s software platform that allows us to store and manage supplier requests, documentation, and data.
Our scoping process was then further refined by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed actually provided items to Novanta that were used in the final products in 2018. Using this process, we were able to remove approximately 34% of suppliers from scope for the 2018 reporting period.
Utilizing the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (the “CMRT”) version 3.0 or higher, we surveyed the suppliers on their sourcing of the 3TGs that may have been used in the materials that were supplied to us. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide materials to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.
The RCOI began with an introduction email from Novanta to suppliers describing the Conflict Minerals Compliance Program (CMCP) requirements and identifying the Service Provider as a partner in the process. Following that introduction email, the Service Provider sent a subsequent email to the suppliers containing a registration and survey request link for the on-line data collection platform.
Subsequent engagement steps were as follows:
| • | After the initial introductions to the program and information request, up to eight reminder emails were sent to each non-responsive supplier requesting survey completion. |
| • | Suppliers who remained non-responsive to these email reminders were contacted by telephone and offered assistance. This assistance included, but was not limited to, further information about the Conflict Minerals Compliance Program, an explanation of why the information was being collected, a review of how the information would be used and clarification regarding how the information needed could be provided. |
| • | If, after these efforts, a given supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by Novanta supply chain personnel who contacted these suppliers by email to request their participation in the program. |
Suppliers were asked to provide information regarding the sourcing of their materials with the ultimate goal of identifying the 3TG smelters or refiners (“SORs”) and associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT were asked to upload this document into the Service Provider system or to provide this information in the online survey version. Suppliers were requested to provide an electronic signature before submitting their data to verify that all answers submitted were accurate to the best of the supplier’s knowledge but the suppliers were not required to provide an electronic signature to submit their data.
Supplier responses were evaluated for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were automatically contacted by the Service Provider:
| • | One or more SORs were listed for an unused metal; |
| • | SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor; |
| • | Supplier answered yes to sourcing from the Covered Countries, but none of the SORs listed are known to source from the region; |
| • | Supplier indicated that they have not received conflict minerals data for each metal from all relevant suppliers; |
| • | Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope; |
| • | Supplier indicated they have not provided all applicable SOR information received; and |
| • | Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusively recyclers. |
Design of Due Diligence
The Company’s due diligence process and efforts have been developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-risk Area (second edition) and the related supplements for gold and for tin, tantalum and tungsten (collectively referred to as the “OECD Guidance”). The Company engaged the Service Provider to conduct due diligence and designed the due diligence process and measures to conform with the OECD framework in all material respects.
Due Diligence Performed
1. | Maintain Strong Company Management System |
1.1. | Internal Team |
The Company’s conflict minerals compliance program is sponsored by the Chief Executive Officer and is executed by a global task force that comprises of the Global Sourcing Leader, the Chief Accounting Officer and Corporate Controller, and a project leader from each of the product lines. The product line project leader is typically the director of operations or manager of the procurement function and is supported by procurement and engineering professionals knowledgeable about the products and materials contained in those products.
The Company developed Conflict Minerals Process procedures that are required to be followed to perform the RCOI by all businesses globally. Supply chain leaders are responsible for ensuring compliance with Conflict Minerals Process procedures at the local business level.
1.2. | Control Systems |
The Company developed a global Conflict Minerals policy and Supplier Code of Conduct that are communicated widely both internally and externally and are posted on the Company’s external website. The Company clearly states its commitment to comply with laws and regulations surrounding conflict minerals.
The Company requires all of its suppliers to use materials that have been sourced in a legally responsible manner and to confirm that they have not, and will not, procure conflict minerals from mines that are not DRC conflict free. These expectations are stated in our Conflict Minerals Policy and Supplier Code of Conduct, which can be accessed at: https://www.novanta.com/corporate-citizenship/.
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT versions 3.0 or higher and our Service Provider’s web-based reporting tool for collecting conflict minerals declarations from our suppliers.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in our efforts related to the conflict minerals compliance program. This includes obtaining information to support the chain of custody of the 3TGs identified in our products. We included Conflict Minerals terms and conditions on our purchase orders for raw materials and components used in our production process. (See further details in the section entitled “Reasonable Country of Origin Inquiry” above.)
1.4. | Grievance Mechanism |
The Company maintained an Ethics Hotline, a 24x7 confidential messaging system and an anonymous electronic mailbox managed by a third-party service provider, which provides means for employees, customers and suppliers to report deviations from the Company’s Code of Ethics and Business Conduct.
1.5. | Document Retention |
The Company utilizes a structured electronic database maintained by our Service Provider for documentation and record maintenance.
2. | Identify and Assess Risks in the Supply Chain |
We have relied on supplier responses for information about the source of conflict minerals contained in the parts and components that they supplied to us. Similarly, our direct suppliers also relied on information provided by their suppliers. This chain of information created a level of uncertainty and risk related to the accuracy of the information. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRTs. Our Service Provider compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2018 calendar year.
Each facility that meets the Responsible Minerals Initiative (“RMI”) definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Our Service Provider uses three factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:
| • | Geographic proximity to the DRC and covered countries; |
| • | Responsible Minerals Assurance Process (“RMAP”) audit status; and |
| • | Credible evidence of unethical or conflict sourcing. |
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers in their CMRT. The criteria used to evaluate the strength of the program are:
| • | Has the supplier established a conflict minerals sourcing policy? |
| • | Has the supplier implemented due diligence measures for conflict-free sourcing? |
| • | Does the supplier review due diligence information received from suppliers against its expectations? |
| • | Does the supplier’s review process include corrective action management? |
When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
3. | Design and Implement a Strategy to Respond to Identified Risks |
For those supply chains with SORs that are known or thought to be sourcing from the Covered Countries, additional investigation was undertaken to determine the source and chain-of-custody of the regulated metals. The Service Provider relied on the following internationally accepted audit standards to determine which SORs are considered DRC Conflict Free: the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program, and the Responsible Jewellery Council Chain-of-Custody Certification. The Service Provider is an official vendor member of the Responsible Minerals Initiative (RMI) that aims to further facilitate the exchange of supply chain data and technical information in the quest for global ethical sourcing of materials. This membership provides the Service Provider access to the following working groups: Engage with the CMRT Development Team, Smelter Engagement Team, Smelter Data Management Team, RMI Stakeholders Call, and RMI Plenary.
If the SOR was not certified by these internationally-recognized schemes, the Service Provider attempted to contact the SOR to gain more information about its sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR took to track the chain of custody on the source of its mineral ores. Relevant information to review included: whether the SOR had a documented, effective and communicated conflict-free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. Internet research was also performed to determine whether there were any outside sources of information regarding the SOR’s sourcing practices. Up to three contact attempts were made by the Service Provider to gather information on mine country of origin and sourcing practices.
We have developed a risk management plan to ensure that all identified risks are responded to. This includes communicating any identified risks to upper management and escalating suppliers who do not meet our expectations.
If the Company discovers through its RCOI efforts that any conflict minerals directly or indirectly benefit the armed groups in the Covered Countries, the Company will take steps to work with its suppliers to stop using such conflict minerals and, if not possible, stop purchasing such raw materials or components from the supplier in question.
4. | Carry Out Independent Third-Party Audit |
We do not have any direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain. We rely on industry efforts, such as the RMI, to influence smelters and refiners to become certified as part of RMI’s Responsible Minerals Assurance Process.
5. | Report Annually on Supply Chain Due Diligence |
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at http://www.novanta.com/corporate-citizenship/ and is filed with the SEC.
Results of RCOI and Due Diligence
As of May 10, 2019, the Company had surveyed 861 Tier 1 suppliers that are considered in scope and received responses from approximately 77% of such suppliers. Of these responding suppliers, 43% indicated one or more of the 3TGs as necessary to the functionality or production of the products they supplied to Novanta. These suppliers were also asked to submit smelters or refiners information.
Of the suppliers surveyed, many completed the CMRT at the company, business unit or entity level and were unable to represent that 3TGs from the processing facilities they listed had actually been used in the components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continue to be varied. Many of the responses included the names and locations of the SORs. The CMRTs submitted by suppliers that do not list at least one
SOR for each 3TG claimed on the CMRT are considered invalid and our Service Provider followed up on these invalid responses, urging the suppliers to resubmit the CMRT and include SOR information. There are still suppliers that are unable to provide SOR information as of May 10, 2019.
Appendix A lists the SORs that our suppliers have reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. Appendix B also includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and the RMI.
Additional Steps to Be Taken to Mitigate Risks
The Company will continue to work with those suppliers who have not responded, responded with invalid smelters and refiners information, or responded as “DRC Conflict Undeterminable” to identify the source of such minerals using available tools, such as the CMRT and the related Smelter Reference list that is publicly available. Should a supplier conclude, and report to us, that they have conflict minerals sourced from the Covered Countries and benefited the armed groups, the Company will require such suppliers to implement measures to become DRC conflict free and find alternative suppliers to the extent alternative DRC conflict free sources of supply are available.
Safe Harbor and Forward-Looking Statements
Certain statements in this Conflict Minerals Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 and are based on current expectations and assumptions that are subject to risks and uncertainties. All statements contained in this Conflict Minerals Report that do not relate to matters of historical fact should be considered forward-looking statements, and are generally identified by words such as “will,” “expects,” “intends,” “plans,” “believes,” “anticipates,” and other similar expressions. These forward-looking statements include, but are not limited to, statements regarding expectation or intention relating to our compliance efforts and expected actions. These statements are neither promises nor guarantees, but involve risks and uncertainties that may cause future expectations or actions to be different. Undue reliance should not be placed on these statements, which are only effective as of the date of this report. The Company disclaims any obligation to update any forward-looking statements as a result of developments occurring after the date of this document except as required by law.
The following is a list of identified smelters or refiners for the 2018 reporting period:
Metal | Official Smelter Name | Smelter Country |
Gold | 8853 S.p.A. | Italy |
Gold | Abington Reldan Metals, LLC | United States |
Gold | Advanced Chemical Company | United States |
Gold | African Gold Refinery | Uganda |
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 |
Gold | Asaka Riken Co., Ltd. | Japan |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
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 | Caridad | Mexico |
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 | Daye Non-Ferrous Metals Mining Ltd. | China |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
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 | Fidelity Printers and Refiners Ltd. | Zimbabwe |
Gold | Fujairah Gold FZC | United Arab Emirates |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
Gold | Geib Refining Corporation | United States |
Gold Refinery of Zijin Mining Group Co., Ltd. | China | |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
Gold | Guangdong Jinding Gold Limited | China |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
Gold | HeeSung Metal Ltd. | Korea, Republic of |
Gold | Heimerle + Meule GmbH | Germany |
Gold | Heraeus Metals Hong Kong Ltd. | China |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
Gold | Hunan Chenzhou Mining Co., Ltd. | China |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
Gold | HwaSeong CJ CO., LTD. | Korea, Republic of |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
Gold | International Precious Metal Refiners | United Arab Emirates |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
Gold | Istanbul Gold Refinery | Turkey |
Gold | Italpreziosi | Italy |
Gold | Japan Mint | Japan |
Gold | Jiangxi Copper Co., Ltd. | China |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
Gold | JSC Uralelectromed | Russian Federation |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
Gold | Kaloti Precious Metals | United Arab Emirates |
Gold | Kazakhmys Smelting LLC | Kazakhstan |
Gold | Kazzinc | Kazakhstan |
Gold | Kennecott Utah Copper LLC | United States |
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 | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
Gold | L'azurde Company For Jewelry | Saudi Arabia |
Gold | Lingbao Gold Co., Ltd. | China |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
Gold | L'Orfebre S.A. | Andorra |
Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
Gold | Marsam Metals | Brazil |
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 (Suzhou) Ltd. | China |
Gold | Metalor Technologies S.A. | Switzerland |
Metalor USA Refining Corporation | United States | |
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 | Modeltech Sdn Bhd | Malaysia |
Gold | Morris and Watson | New Zealand |
Gold | Morris and Watson Gold Coast | Australia |
Gold | Moscow Special Alloys Processing Plant | Russian Federation |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
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 | Pease & Curren | United States |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
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 | QG Refining, LLC | United States |
Gold | Rand Refinery (Pty) Ltd. | South Africa |
Gold | Refinery of Seemine Gold Co., Ltd. | China |
Gold | REMONDIS PMR B.V. | Netherlands |
Gold | Royal Canadian Mint | Canada |
Gold | SAAMP | France |
Gold | Sabin Metal Corp. | United States |
Gold | Safimet S.p.A | Italy |
Gold | SAFINA A.S. | Czech Republic |
Gold | Sai Refinery | India |
Gold | Samduck Precious Metals | Korea, Republic of |
Gold | SAMWON METALS Corp. | Korea, Republic of |
Gold | SAXONIA Edelmetalle GmbH | Germany |
Gold | SEMPSA Joyeria Plateria S.A. | Spain |
Gold | Shandong Humon Smelting Co., Ltd. | China |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
Gold | Singway Technology Co., Ltd. | Taiwan |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
Solar Applied Materials Technology Corp. | Taiwan | |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
Gold | Sudan Gold Refinery | Sudan |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of |
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 | Tongling Nonferrous Metals Group Co., Ltd. | China |
Gold | Tony Goetz NV | Belgium |
Gold | TOO Tau-Ken-Altyn | Kazakhstan |
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 |
Gold | Universal Precious Metals Refining Zambia | Zambia |
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 | Yunnan Copper Industry Co., Ltd. | China |
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 |
Tantalum | Exotech Inc. | United States |
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 |
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 |
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 |
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 |
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, The Former Yugoslav Republic Of |
Tantalum | QuantumClean | United States |
Tantalum | Resind Industria e Comercio Ltda. | Brazil |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
Tantalum | Taki Chemical Co., Ltd. | Japan |
Tantalum | Telex Metals | United States |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
Tin | Alpha | United States |
Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
Tin | Dowa | Japan |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
Tin | EM Vinto | Bolivia |
Tin | Estanho de Rondonia S.A. | Brazil |
Tin | Fenix Metals | Poland |
Tin | Gejiu Fengming Metallurgy Chemical Plant | 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 | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
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 |
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 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
Tin | Operaciones Metalurgical S.A. | Bolivia |
Tin | Pongpipat Company Limited | Myanmar |
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 Babel Surya Alam Lestari | 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 |
Tin | PT Karimun Mining | Indonesia |
Tin | PT Kijang Jaya Mandiri | 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 Rajawali Rimba Perkasa | 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 |
PT Sumber Jaya Indah | Indonesia | |
Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
Tin | PT Tinindo Inter Nusa | Indonesia |
Tin | PT Tirus Putra Mandiri | Indonesia |
Tin | PT Tommy Utama | Indonesia |
Tin | Resind Industria e Comercio Ltda. | Brazil |
Tin | Rui Da Hung | Taiwan |
Tin | Soft Metais Ltda. | Brazil |
Tin | Super Ligas | Brazil |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam |
Tin | Thaisarco | Thailand |
Tin | Tin Technology & Refining | United States |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
Tin | Yunnan Tin Company Limited | China |
Tungsten | A.L.M.T. TUNGSTEN 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 |
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 Tungsten Industry 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 Dayu Longxintai Tungsten Co., Ltd. | China |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals 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 |
Kennametal Huntsville | United States | |
Tungsten | KGETS CO., LTD. | Korea, Republic of |
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 |
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 |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
The list below sets out possible countries of origin of 3TGs used in the manufacture of our products containing 3TGs for the 2018 reporting year. The list is based on publicly available information, our reasonable country of origin inquiries, and other due diligence efforts. However, for the reasons described in the CMR, these possible countries of origin cannot be linked to our products with reasonable certainty. Please note that, as of May 10, 2019, all indication of sourcing from the DRC and surrounding countries came from certified conflict-free smelters.
Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Congo (Brazzaville), Czech Republic, Djibouti, DRC- Congo (Kinshasa), Ecuador, Egypt, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hong Kong, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Jersey, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Laos, Luxembourg, Madagascar, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Russian Federation, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, United States, Uzbekistan, Viet Nam, Zambia, Zimbabwe
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