Exhibit 1.01
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Camtek Ltd.
Conflict Minerals Report
For the year Ended December 31, 2017
Introduction
This is the Conflict Minerals Report of Camtek Ltd. (“CAMT”) (herein referred to as "Camtek", the "Company", "we" or "our"), for calendar year 2017 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “1934 Act”). Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for the definition of terms used in this report.
In conducting its due diligence, Camtek implemented the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("The OECD Framework"), an internationally recognized due diligence framework. Prior to due diligence, we addressed the “Reasonable Country of Origin Inquiry” process and commenced the due diligence process accordingly.
Company Overview
Camtek provides automated and technologically advanced solutions dedicated to enhancing production processes, increasing products yield and reliability, enabling and supporting customers’ latest technologies in the semiconductor fabrication industry. In September 2017, the Company completed the sale of its PCB inspection and metrology business unit. For more details, refer to Camtek’s website at http://www.camtek.com.
Camtek’s production site, is located in Migdal Haemek, Israel.
Camtek’s products are comprised of components which may contain conflict minerals that require an inquiry under Section 1502 of the Dodd-Frank Act, the SEC’s final rule and OECD guidelines.
Camtek’s Efforts for meeting Conflict-Free Mineral Requirements
Camtek continued to implement and communicate its policy and methodology that is in accordance with Annex I, Five steps Framework for Risk-Based Due Diligence in the Mineral Supply Chain from the OECD Framework. Camtek has been addressing the following 5 OECD steps:
· | Establishing a strong company management system |
Camtek established a management team from the following departments: Engineering, QA, Purchasing, R&D, Logistics, Legal and Finance. The team is sponsored by the Chief Financial Officer. The team passed training related the Conflict Minerals framework, policy, etc.
Camtek has adopted a Company policy which reflects an all-inclusive understanding of required rules and guidelines in addition to knowledge sharing with other companies in the industry. This policy can be found at the website http://www.camtek.com
· | Identifying and assessing risk in the supply chain |
Camtek held meetings with Management from various departments to discuss the applicable definitions of “manufacturer” and/or “contract to manufacture”. Through this process, Camtek identified products that are affected by the 3TG minerals and mapped them to their respective vendors.
Camtek evaluated approximately 4 private branded products, sourced from approximately 85 vendors subject to the RCOI survey process (note that the number of relevant vendors of Camtek’s private brand products was reduced compared to last year due to the sale of the PCB business unit as described above).
We then sent official letters to suppliers ("Letter to Supplier") conducting a supply-chain survey using the RMI Conflict Minerals Reporting Template to identify the smelters and refiners.
· | Designing and implementing a strategy to respond to identified risks |
In situations where it was determined that a “conflict mineral” is necessary for the functionality or production of at least one of our products, we carried out a reasonable country of origin inquiry (“RCOI").
We have implemented a risk management procedure designed, among other things, to identify products which may include conflict minerals, updated the purchasing process and included in a new supplier approval FORM relevant questions related to Conflict Minerals, monitored all potential risk suppliers, and engaged in knowledge sharing for meeting requirements.
· | Carrying out independent third-party audits of supply chain due diligence at identified points along the supply chain |
Camtek does not have a direct relationship with the smelters and refiners in our supply chain, nor do we perform direct audits of the entities that provide our supply chain the 3TG. However, we do rely upon industry (for example, EiCC and RMI) efforts to influence smelters and refineries to get audited and certified through CFS program.
· | Reporting on supply chain due diligence |
The conflict minerals report is filed with the SEC and is also available on our website http://www.camtek.com
Results for the 2017 Calendar Year
The Conflict Mineral Process, as described above, allowed Camtek to identify in-scope products and the corresponding suppliers. These identified suppliers were surveyed through the RCOI Survey process using the Conflict Minerals Reporting Template. The survey population included approximately 4 products across 85 vendors. Camtek received survey responses from 53 of the population of suppliers surveyed. Approximately 50% of responding suppliers indicated that their products may contain one or more of the named 3TG minerals. However, the results from the surveys did not allow Camtek to reach a reportable conclusion as to the source of any potential conflict minerals.
The table below lists the facilities which, to the extent known, processed necessary conflict minerals in certain of our products.
Company policy
Camtek’s conflict minerals policy and steps taken are available on our website http://www.camtek.com.
Future steps to be taken
We intend to maintain our approach for responsible sourcing of the minerals used in our products, and to continue to comply with any applicable regulations related to the sourcing of, and disclosure concerning, the Conflict Minerals that may be contained in our products:
1. | Include a conflict mineral clause in new or updated supplier contracts, where available. |
2. | Expand supplier's list considering the OECD framework. |
3. | Manage follow up table with all relevant details from supplier for evaluation and tracking inputs in the supply system. |
4. | Continue to identify Conflict Minerals associated with new product launches |
5. | Continue to encourage our suppliers to purchase materials from smelters listed in the Conflict Free Smelter List |
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Metal | Standard Smelter Names | Smelter Facility Location: Country | Smelter ID |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
Gold | Boliden AB | SWEDEN | CID000157 |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
Gold | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
Gold | Dowa | JAPAN | CID000401 |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Japan Mint | JAPAN | CID000823 |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
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Metal | Standard Smelter Names | Smelter Facility Location: Country | Smelter ID |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
Gold | Kazzinc | KAZAKHSTAN | CID000957 |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
Gold | Minsur | PERU | CID001182 |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | CID001322 |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
Gold | PAMP S.A. | SWITZERLAND | CID001352 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Royal Canadian Mint | CANADA | CID001534 |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA | CID001754 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
This Conflict Minerals Report was not subjected to an independent private sector audit as not required by paragraph (c)(1)(iv) of the instructions to Item 1.01.
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