Exhibit 1.01
Nortek, Inc.
Conflict Minerals Report
For the Reporting Period Ended December 31, 2015
This Conflict Minerals Report for the calendar-year reporting period beginning January 1, 2015 and ending December 31, 2015 (the “reporting period”) has been prepared and filed with the Securities and Exchange Commission (“SEC” or “Commission”) under cover of Form SD by Nortek, Inc. (together with all consolidated subsidiaries, “Nortek,” “Company,” “we” or “us”) to comply with Section 13(p) of the Securities Exchange Act of 1934, as amended (“Exchange Act Section 13(p)”) and the SEC’s implementing rule and form adopted thereunder, Rule 13p-1 (17 CFR 240.13p-1) and Form SD (17 CFR 249b.400). The term “conflict minerals” is defined by Section 13(p), Rule 13p-1 and Item 1.01(d)(3) of Form SD to mean tin, tantalum, tungsten and gold, commonly referred to as the “3TG,” without regard to their country or countries of origin.
As certain of the Company’s businesses manufactured, or contracted with third parties to manufacture, products during the reporting period that contain conflict minerals that are necessary to the functionality or production of these products (“necessary conflict minerals”), we have prepared and filed, with the SEC, this particular Conflict Minerals Report (“CMR” or “Report”) and accompanying Form SD. We have also posted both our Form SD and CMR on our Company’s website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website. After conducting our good-faith, reasonable country of origin inquiry (“RCOI”) for the reporting period, we were unable to rule out the possibility that some of our necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country (together, “Covered Countries”), and/or may not be derived solely from recycled or scrap sources. Accordingly, we performed due diligence pursuant to a process designed to conform to the framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High- Risk Areas: Second Edition: 2013, including the supplements thereto for gold, tin, tantalum and tungsten (together, “OECD Due Diligence Guidance”).
Company Overview and Description of Nortek Products Covered by this CMR
We are a global, diversified company whose many market-leading brands deliver broad capabilities and a wide array of innovative, technology-driven products and solutions for lifestyle improvement at home and at work. A description of our reporting segments and their products is set forth below.
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| • | Air Quality & Home Solutions (“AQH”) segment primarily manufactures and distributes room and whole house ventilation products for the professional remodeling and replacement markets, residential new construction market, and do-it-yourself market. The principal products of the segment are kitchen range hoods, exhaust fans (such as bath fans and fan, heater and light combination units), indoor air quality products (such as air exchangers and heat or energy recovery ventilators) and central vacuum systems. The following products contain, or may contain, necessary conflict minerals: range hoods, bath and ventilation fans, trash compactors, air exchangers, intercoms, central vacuum cleaners and ceiling fans. |
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| • | Security & Control Solutions (“SCS”) segment manufactures and distributes a broad array of products designed to provide convenience and security primarily for residential applications. The principal product categories in this segment include security, automation, health and wellness and access control equipment and systems. The following products contain, or may contain, necessary conflict minerals: gate and garage door openers, radio controls, residential and commercial access controls, intercoms, personal emergency transmitters and thermostat control panels. |
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| • | Ergonomic & Productivity Solutions (“ERG”) segment manufactures and distributes a broad array of innovative products that are designed to improve ergonomic and productivity for users of computers and digital displays. Products in this segment include computer workstations with ergonomic features including wall mounts, carts, arms, desk mounts, desks, and stands that attach to or support a variety of display devices such as notebook computers, computer monitors, and flat panel displays. The following products contain, or may contain, necessary conflict minerals: charging carts and medical carts. |
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| • | Residential & Commercial HVAC (“RCH”) segment principally manufactures and sells split-system and packaged air conditioners and heat pumps, furnaces, air handlers and parts for the residential replacement and new construction markets. In addition, this segment produces unit heaters, radiant heaters and rooftop HVAC products primarily for industrial and commercial applications. The following products contain, or may contain, necessary conflict minerals: radiant heaters, destratification fans, packaged air conditioners, air handlers and duct furnaces. |
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| • | Custom & Commercial Air Solutions (“CAS”) segment designs, manufactures and sells custom HVAC products and systems, primarily in North America, for commercial and industrial applications for markets that include healthcare and educational facilities, offices and retail, manufacturing facilities, clean rooms, data centers, and government buildings. The principal products sold by this segment are custom air handlers, energy recovery systems, integrated operating room systems, and large rooftop cooling and heating products. The following products contain, or may contain, necessary conflict minerals: commercial air handlers, data room cooling units, CLEANSUITE® air filtration system, fan retrofits, and packaged rooftop HVAC units. |
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| • | Audio, Video & Control Solutions (“AVC”) segments manufacture and market a broad array of products and solutions primarily for the residential audio, video automation and control, as well as for commercial power management, control and signal management markets. The principal product categories in these segments are smart home control and automation equipment, residential distributed audio and video equipment (including amplifiers, architectural speakers and power conditioners, among other products), and commercial power sequencing and video signal distribution and management solutions. The following products contain, or may contain, necessary conflict minerals: audio adapters, speakers, and residential and commercial control products. |
Through these segments, we manufacture and sell primarily in the United States, Canada, and Europe, with additional manufacturing in China and Mexico, a wide variety of products principally for the remodeling and replacement markets, the residential and commercial new construction markets, and the personal and enterprise computer markets. Some of these products, which in some cases include other products (including component parts) that are manufactured by unaffiliated third-party suppliers we contract with, contain necessary conflict minerals (“Covered Products”), as discussed further below. These materials and components include, among others, steel, copper, aluminum, electronics, motors, plastics, compressors, printed circuit boards, electrical components, microprocessors, batteries, and paint, as well as standard nuts, bolts and fasteners, all of which we purchase from third parties and some of which may contain one or more necessary conflict minerals.
The manufacture of products during any specified time period likely includes raw materials and component parts sourced before, as well as during, the reporting period. In particular, some necessary 3TGs used during the current reporting period may have been smelted, refined and/or manufactured by a supplier (pursuant to a contract with us to manufacture) prior to January 1, 2015. The reasonable country of origin (“RCOI”) and supply chain due diligence we conducted for this reporting cycle similarly did not exclude such materials. Our due diligence and, as a consequence, this CMR, also may include products and/or components containing necessary conflict minerals whose manufacture (and/or smelting/refining in the case of unprocessed materials) may have occurred prior to January 1, 2015 (the beginning of the reporting period), even though the statutory and SEC conflict minerals disclosure requirements require only that we report on such products whose manufacture was completed in 2015.
Nortek’s Supply Chain
We are dependent upon raw materials and components, and in some cases finished products, purchased from other manufacturers or suppliers. As a result of the broad array of products and components/materials manufactured by third parties per our specifications for inclusion in our products, as explained above, we have a large supply base, with many suppliers unique to each of our individual business segment’s requirements. Due to the complex nature of our business, our segments may manufacture in-house or contract with third parties to manufacture specific components that we then incorporate into our end products. Due to our size, the complexity of our products, and the depth and breadth of our supply chain, it has proven difficult to identify the smelters/refiners of the numerous levels of suppliers to our immediate, direct suppliers. For the same reasons, our communications with entities in our supply chain have been limited to our direct suppliers, on which we rely on for information regarding themselves and their upstream suppliers. As a downstream purchaser of conflict minerals and/or products (including components) containing such conflict minerals, we are many steps removed from the smelters or refiners (“SOR”) that originally processed the ores or other materials containing the necessary 3TGs ultimately included in our final products.
In light of the foregoing, all references made in this CMR -- and the accompanying Form SD -- to our communications with, and/or receipt of information from, our “suppliers” are intended to refer solely to our direct, or first-tier, suppliers.
1. RCOI
To conduct our RCOI and obtain sourcing information from our suppliers, we used the Conflict-Free Sourcing Initiative's ("CFSI") Conflict Minerals Reporting Template (“CMRT”) to collect information on the necessary conflict minerals. We requested this information from 615 suppliers that we believed may have used the necessary conflict minerals contained in our products, including components thereof, to determine whether any of these minerals originated in the DRC or an adjoining country or were from recycled or scrap sources. We received responses from 55% of the surveyed suppliers. Based on these survey responses, Nortek determined that it had reason to believe that some of the necessary conflict minerals contained in our products (including components) may have originated in the DRC or another Covered Country, or may not have been derived solely from recycled or scrap sources. Accordingly, we proceeded to perform the OECD-prescribed due diligence as described further below.
2. Due Diligence (DD) Process
Design of Our Due Diligence Framework
We have designed our due diligence framework - which we refer to in this Report as Nortek’s Conflict Minerals Strategic Framework - to conform to the criteria set forth in the “OECD Due Diligence Guidance”, as applicable to downstream companies. Summarized below are the design components of our conflicts mineral program in effect for calendar-year 2015, as it relates to the five-step framework reflected in the OECD Due Diligence Guidance:
Establish strong company management systems:
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| • | Our Conflict Mineral Policy (“CM Policy”), is publicly available on our website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website. |
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| • | Operate an internal Conflict Minerals Steering Committee, consisting of executive-level representatives, which reports directly to the Company’s Chief Executive Officer (“Steering Committee”), as well as a select team of Nortek employees from procurement, legal, and finance. This select team is tasked to ensure that there is a clear understanding on the part of all responsible personnel with respect to the background and policy underpinnings of the statutory and SEC conflict minerals disclosure requirements, provide that personnel with an understanding of these requirements, and set the foundation to enable us to manage the complexities of compliance with these requirements on an ongoing basis. |
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| • | Use the CFSI CMRT, which was developed under the OECD Due Diligence Guidance, to request from selected suppliers relevant source information (i.e., 3TG content, country of origin, and SOR facilities) regarding products (including components) or materials manufactured and/or purchased by Nortek that may contain necessary conflict minerals. |
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| • | Conducted internal training through the implementation of a Conflict Mineral Playbook, which provides an overview of the regulations and our Conflict Mineral Strategic Framework, and establishes roles and responsibilities for compliance to ensure accountability. |
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| • | Incorporate requirements related to conflict minerals compliance in our standard supplier agreement to ensure that our suppliers (and sub-tier suppliers) comply with our Conflict Minerals Strategic Framework requirements and participate in the annual survey process. |
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| • | Maintain appropriate records pertaining to design and implementation of our Conflict Minerals Strategic Framework in accordance with our corporate records retention policy. |
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| • | As referenced in our Supply Partners’ Code of Conduct which is publicly available on our website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website, we provide suppliers access to the established grievance mechanism at: ethics@nortek.com or our hotline at 888-475-6620. Our employees may report concerns directly to nortek.silentwhistle.com. |
Identify & Assess Risk in the Supply Chain
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| • | Conduct a supply chain survey of those suppliers identified in the 2015 Supplier Population (as this term is defined in Section 2, below) using the CMRT. |
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| • | Follow up with suppliers that did not respond to the survey request to obtain sourcing and smelter information for Nortek’s products, as part of our risk management plan. As noted below, we also have developed guidelines for making further inquiries of individual first-tier suppliers when we receive survey responses that are either incomplete or raise “red flags.” |
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| • | Compare SORs identified in supplier responses against the list of facilities that are participating in the CFSI’s Conflict Free Smelter Program (“CFSP”). |
Design & Implement a Strategy to Respond to Risks
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| • | Implement the risk mitigation process defined in our Conflict Minerals Strategic Framework to identify and follow up with suppliers that are not meeting the CM Policy, as discussed further below in Section 3 of this CMR. |
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| • | Provide metrics to the Steering Committee summarizing our program’s progress on a monthly basis. Meet with the Steering Committee throughout the year or on an as-needed basis to provide information on risk mitigation efforts as well as other program highlights. |
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| • | Negotiate new supply agreements or contracts up for renewal with our known 3TG suppliers to ensure alignment with our CM Policy. In addition, direct material contracts up for renewal or amendment are modified to include the requirements pertaining to the statutory and SEC conflict minerals disclosure requirements. |
Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
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| • | Rely on the publicly-available results of the CFSI’s CFSP third-party audits to validate the responsible sourcing practices of processing facilities in our supply chain. |
Report on Supply Chain Due Diligence
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| • | Post our CM Policy on our company website at www.nortek.com under “Corporate Governance” on the “Investors” portion of our website. |
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| • | Publicly report on Nortek’s due diligence efforts in the annual SEC filing of our Form SD and CMR. Post the Form SD and Conflict Minerals Report on our website. |
3. Due Diligence Measures Performed in 2015
For this third year of compliance with the conflict minerals disclosure requirements set forth in Exchange Act Section 13(p), and SEC Rule 13p-1 and Form SD thereunder, we expanded our supplier population from 111 suppliers (the “2014 Supplier Population”) to 615 suppliers (the “2015 Supplier Population”). The following measures were performed during the reporting period to satisfy both our RCOI and due diligence obligations relating to the source and chain of custody of the necessary conflict minerals contained in our products, in an effort to determine whether they may have originated from the Covered Countries and/or came (or did not come) from recycled or scrap sources:
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| • | Surveyed 615 suppliers within our supply chain, as noted above, which we defined as Nortek’s “2015 Supplier Population” for survey purposes. |
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| • | Compared supplier responses against certain “red flags” and other criteria we developed internally in order to identify areas of risk of noncompliance with Nortek’s Conflict Minerals Strategic Framework. These criteria allowed us to determine incomplete responses as well as inconsistencies within the data reported in the supplier declarations that raised red flags and required further inquiry. |
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| • | Followed up with the suppliers who either did not respond to our survey request or, based upon the results identified in our review, provided incomplete or inconsistent information, to seek additional clarifying information to compare against Nortek’s Conflict Minerals Strategic Framework. |
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| • | Compared smelters and refiners identified in the supplier survey responses against the lists of facilities that have received a “Compliant” or “Active” designation from the CFSP. |
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| • | Negotiated new supply agreements or contracts up for renewal with our known 3TG suppliers to ensure alignment with our CM Policy. In addition, direct material contracts up for renewal or amendment were modified to include the requirements relating to compliance with Exchange Act Section 13(p), SEC Rule 13p-1 and Form SD. The conflict minerals provisions/requirements are imposed on all direct material suppliers regardless of whether we believe their products/components contain 3TGs. |
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| • | Monitored and tracked suppliers that actually or partially did not meet the requirements set forth in our CM Policy and/or reporting requirements. |
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| • | Continued to utilize our specific conflict minerals supplier training package that provides our suppliers with an overview of Nortek’s Conflict Mineral Strategic Framework and outlines the commitments they must make, and the requirements and expectations they must satisfy, to help us meet our due diligence and related disclosure obligations under Exchange Act Section 13(p), and SEC Rule 13p-1 and Form SD. |
Supply Chain Survey Responses
We received some level of response from 55% (342 responses) of the Supplier Population surveyed for calendar year 2015, which represents a decrease of 28% from the prior year’s response rate of 75%. However, we believe that this drop is largely due to the fact that we surveyed 494 more suppliers in 2015 than in the prior year. With that increase in the supplier survey sample, we surveyed smaller suppliers and/or suppliers outside the United States who are not subject to the U.S. conflict minerals disclosure requirements and obligations. Of the total pool surveyed, there were 262 suppliers who did not respond at all, even after multiple email reminders from us that their survey response was required. We followed up with a majority of those suppliers who did respond if we believed that they may have provided a specific response in error, requesting that they provide revised responses. If these suppliers had additional information or were able to correct discrepancies, they provided us with updated information.
Based on our suppliers’ responses to our survey, as confirmed during our follow-up inquiries as described above, we have reason to believe that some of the necessary conflict minerals used in our products may have originated in one or more of the Covered Countries and otherwise may not have been derived solely from recycled or scrap sources, but we have not identified any instances in which our sourcing of necessary conflict minerals directly or indirectly financed or benefitted armed groups in any of these countries.
Some of the necessary conflict minerals contained in our Covered Products could be traced to various smelters and refineries designated as “Compliant” or “Active” by a well-respected industry group, CFSI, whose lists were compiled on the basis of the application of a third-party supply chain audit process developed under the auspices of the OECD Due Diligence Guidance, CFSP. These lists are maintained and published on the CFSI website (at http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/), with oversight by the CFSI.
The table below provides a summary of the smelters/refiners disclosed by our suppliers that we were able to determine were included in the CFSI’s CFSP lists as of March 18, 2016. We are identifying the individual processing facilities included in these CFSP lists in the tables at the end of this CMR (in Appendix I).
Supplier Survey Smelter/Refiner Results:
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| Metal | Identified by Suppliers | Listed by CFSI as “Compliant”* | Listed by CFSI as Active*+ |
| Tin | 76 | 54 | 8 |
| Tantalum | 45 | 45 | 0 |
| Tungsten | 43 | 28 | 12 |
| Gold | 120 | 79 | 9 |
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| * | The Compliant and Active Smelters and Refiners as identified per the lists posted on the CFSI website, at http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/, as of March 18, 2016. |
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| + | Active Smelters & Refiners that have committed to undergo a CFSP audit. Smelters and refiners are identified as Active in the Conflict-Free Smelter Program once they submit signed an Agreement for the Exchange of Confidential Information (AECI) and an Auditee Agreement. This is the first step of the audit process. |
The data regarding smelters and refiners provided in the foregoing table, as noted, is based solely on those facilities identified by our suppliers that were included in the CFSI CFSP lists as of March 18, 2016.
4. Risk Mitigation - Efforts to Improve Due Diligence for 2016 and Beyond
We intend to continue taking the following steps in 2016 (and beyond, as necessary or appropriate) to improve upon and enhance the due diligence conducted for 2015, to further mitigate any risk that the necessary conflict minerals in our Covered Products could benefit armed groups in the Covered Countries:
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| • | Continue to include a conflict mineral flow-down requirement in all new or renewed supplier agreements, which requires our suppliers to maintain a written Conflict Minerals policy that is consistent with Nortek’s Conflict Minerals Policy (which shall include appropriate provisions requiring sub-suppliers to comply with Supplier’s Conflict Minerals policy) and develop appropriate internal procedures regarding compliance with Exchange Act Section 13(p), Rule 13p-1 and Form SD and Supplier’s Conflict Minerals policy. |
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| • | Continue to expand our supplier population surveyed to increase our response rate and gather more smelter and refinery data. |
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| • | With respect to the OECD Due Diligence Guidance requirement to strengthen engagement with suppliers, we will continue to utilize our specific conflict minerals supplier training package that provides our suppliers with an overview of our Conflict Mineral Strategic Framework, and to outline the commitments they must make and the requirements and expectations they must satisfy, to help us meet our due diligence and related disclosure obligations under the conflict minerals disclosure provisions of Exchange Act Section 13(p), Rule 13p-1 and Form SD. |
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| • | In 2016, we have contracted with a third party provider who will assist us in surveying Nortek suppliers. While we disclosed in our 2014 CMR our plan to implement a supplier portal to assist us with supplier conflict mineral information collection (as well as to capture other supplier information) in 2015, we were unable to implement this as a workable solution and therefore chose another third party provider to assist us with satisfying our conflict minerals compliance obligations. The new provider will deliver a conflict mineral software solution and support services (“Turnkey Provider”). The Turnkey Provider will be responsible for surveying Nortek suppliers, collecting their conflict mineral declarations and providing red flag analysis to responsible Company personnel. In addition, it will provide us with real-time dashboard reporting, additional training resources and documentation to support an independent third party audit (when that requirement of the statute becomes applicable). This addition will allow us to increase the coverage of our supplier population and result in a more efficient collection of data. |
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| • | We plan to become a member of one or more of the well-known private-sector conflict-free initiatives, to help us further define and incorporate best practices into our conflict minerals compliance program. |
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| • | As part of our Conflict Mineral Strategic Framework, we will continue to follow our “potential escalation procedures” framework to determine, based on severity of action (i.e., no response, incomplete response, poor due diligence, etc.), what escalation procedure is required with respect to a particular supplier. Escalation procedures range from emails to supplier points of contact to reduction in spend and selecting an alternative source, depending on the type/severity of the problem(s) detected and priority-level of supplier (depending for example, on the amount of products purchased, etc.). |
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| • | Continue to enhance scoping analysis to further refine the suppliers’ survey by performing product level scoping within each of the Company’s six business segments. This continuous effort will allow us to identify more effectively the products that fall within the scope of reporting, and to further refine the list of suppliers to include in the RCOI survey activities. |
Forward-Looking Disclosure
This Conflict Minerals Report contains forward-looking statements regarding our business, products and conflict minerals compliance efforts, including steps we intend to take to mitigate the risk that conflict minerals in our products may directly or indirectly finance or benefit “armed groups” (as defined in Item 1.01(d)(2) of Form SD), and our industry’s conflict minerals efforts. Words such as “expects,” “anticipates,” “intends,” “believes” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this CMR. Additionally, statements concerning future matters that are not historical are forward-looking statements.
APPENDIX I
Most of our supplier responses described their relevant supply chains at a company-level, and therefore are not product-specific. As such, our list of processing facilities disclosed in this CMR may contain more facilities than those that actually processed the necessary conflict minerals contained in our Covered Products.
We requested country of origin information (if known) from each of our suppliers included in our 2015 survey, most of which do not source directly from processing facilities, for the purposes of determining the source and chain of custody of the necessary conflict minerals in our supply chain.
At this time, we are listing only those processing facilities in the tables to follow that have been included in publicly available lists prepared by the CFSI under the auspices of its CFSP (“CFSI-Listed Facilities”). Although some suppliers in our 2015 Supplier Population who responded to our survey identified what they designated as smelters or refiners, these facilities did not appear among the CFSI Listed Facilities, and we were otherwise unable to confirm independently that these entities in fact were operating conflict minerals processing facilities during calendar year 2015. Accordingly, there is no reasonable basis in our view for concluding that these additional entities are “known” within the meaning of the SEC’s conflict minerals disclosure requirements, and therefore subject to identification in this Report. For the same reasons, we believe that identification of these entities as smelters or refiners of necessary conflict minerals contained in our products (including components) would be materially misleading to investors.
With respect to the table below, those rows identified with an asterisk (“*”) reflect Compliant Smelters and Refiners identified on the CFSI website as of March 18, 2016, respectively, while the rows identified with a plus (“+”) below reflect smelters and refiners which have committed to undergo an audit sponsored by CFSI, and are listed by CFSI as “Active”.
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| Metal | Smelter Name | Smelter Country | Smelter Identification |
| Gold | Advanced Chemical Company + | UNITED STATES | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. * | JAPAN | CID000019 |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | CID000028 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. * | GERMANY | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) + | UZBEKISTAN | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração * | BRAZIL | CID000058 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
| Gold | Argor-Heraeus SA * | SWITZERLAND | CID000077 |
| Gold | Asahi Pretec Corporation * | JAPAN | CID000082 |
| Gold | Asahi Refining Canada Limited * | CANADA | CID000924 |
| Gold | Asahi Refining USA Inc. * | UNITED STATES | CID000920 |
| Gold | Asaka Riken Co., Ltd. * | JAPAN | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. * | TURKEY | CID000103 |
| Gold | Aurubis AG * | GERMANY | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) * | PHILIPPINES | CID000128 |
| Gold | Bauer Walser AG | GERMANY | CID000141 |
| 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 + Métaux SA + | SWITZERLAND | CID000189 |
| 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 | Doduco * | GERMANY | CID000362 |
| Gold | Do Sung Corporation + | KOREA, REPUBLIC OF | CID000359 |
| Gold | Dowa * | JAPAN | CID000401 |
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| Gold | Eco-System Recycling Co., Ltd. * | JAPAN | CID000425 |
| Gold | Elemetal Refining, LLC * | UNITED STATES | CID001323 |
| Gold | Faggi Enrico S.p.A. + | ITALY | CID002355 |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | CID000522 |
| Gold | Geib Refining Corporation | UNITED STATES | CID002459 |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
| Gold | Heimerle + Meule GmbH * | GERMANY | CID000694 |
| Gold | Heraeus Ltd. Hong Kong * | CHINA | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG * | GERMANY | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. * | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery * | TURKEY | CID000814 |
| Gold | Japan Mint * | JAPAN | CID000823 |
| Gold | Jiangxi Copper Company Limited * | CHINA | CID000855 |
| 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 |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
| Gold | Kazzinc * | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC * | UNITED STATES | CID000969 |
| Gold | Kojima Chemicals Co., Ltd. * | JAPAN | CID000981 |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | CID000988 |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| Gold | L' azurde Company For Jewelry * | SAUDI ARABIA | CID001032 |
| Gold | Lingbao Gold Company Limited | 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 Smelting Co. Ltd. | CHINA | CID001093 |
| Gold | Materion * | UNITED STATES | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. * | JAPAN | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. * | CHINA | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. * | SINGAPORE | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. + | CHINA | CID001147 |
| Gold | Metalor Technologies SA * | SWITZERLAND | CID001153 |
| Gold | Metalor USA Refining Corporation * | UNITED STATES | CID001157 |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V * | MEXICO | CID001161 |
| Gold | Mitsubishi Materials Corporation * | JAPAN | CID001188 |
| Gold | Mitsui & Co. Precious Metals Inc * | CHINA | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. * | INDIA | CID002509 |
| Gold | Morris and Watson | NEW ZEALAND | CID002282 |
| Gold | Moscow Special Alloys Processing Plant * | RUSSIAN FEDERATION | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. * | TURKEY | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | Nihon Material Co., Ltd. * | JAPAN | CID001259 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH * | AUSTRIA | CID002779 |
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| | | |
| Gold | Elemetal Refining, LLC | UNITED STATES | CID001322 |
| Gold | Ohura Precious Metal Industry Co., Ltd. * | JAPAN | CID001325 |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) * | RUSSIAN FEDERATION | CID001326 |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | CID001328 |
| Gold | OJSC Novosibirsk Refinery * | RUSSIAN FEDERATION | CID000493 |
| Gold | PAMP SA * | 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 Précinox SA * | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. * | SOUTH AFRICA | CID001512 |
| Gold | Republic Metals Corporation * | UNITED STATES | CID002510 |
| Gold | Royal Canadian Mint * | CANADA | CID001534 |
| Gold | Sabin Metal Corp. | UNITED STATES | 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 Joyería Platería SA * | 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 | Singway Technology Co., Ltd. * | TAIWAN | CID002516 |
| Gold | So Accurate Group, Inc. | UNITED STATES | CID001754 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals * | RUSSIAN FEDERATION | CID001756 |
| Gold | Solar Applied Materials Technology Corp. * | TAIWAN | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. * | JAPAN | CID001798 |
| Gold | Tanaka Kikinzoku Kogyo K.K. * | JAPAN | CID001875 |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA | CID001909 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. * | CHINA | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. * | JAPAN | CID001938 |
| Gold | Torecom + | KOREA, REPUBLIC OF | CID001955 |
| Gold | Umicore Brasil Ltda. * | BRAZIL | CID001977 |
| Gold | Umicore Precious Metals Thailand * | THAILAND | CID002314 |
| Gold | Umicore SA Business Unit Precious Metals Refining * | BELGIUM | CID001980 |
| Gold | United Precious Metal Refining, Inc. * | UNITED STATES | CID001993 |
| Gold | Valcambi SA * | SWITZERLAND | CID002003 |
| Gold | Western Australian Mint trading as The Perth Mint * | AUSTRALIA | CID002030 |
| Gold | Yamamoto Precious Metal Co., Ltd. * | JAPAN | CID002100 |
| Gold | Yokohama Metal Co., Ltd. * | JAPAN | CID002129 |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation * | CHINA | CID002224 |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery * | CHINA | CID002243 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. * | CHINA | CID000211 |
| Tantalum | Conghua Tantalum & Niobium Smeltery * | CHINA | CID000291 |
| Tantalum | D Block Metals, LLC * | UNITED STATES | CID002504 |
| Tantalum | Duoluoshan * | CHINA | CID000410 |
| Tantalum | Exotech Inc. * | UNITED STATES | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. * | CHINA | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. * | CHINA | CID002505 |
|
| | | |
| Tantalum | Global Advanced Metals Aizu * | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown * | UNITED STATES | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. * | CHINA | CID000616 |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch * | CHINA | CID002501 |
| Tantalum | H.C. Starck Co., Ltd. * | THAILAND | CID002544 |
| Tantalum | H.C. Starck GmbH Goslar * | GERMANY | CID002545 |
| Tantalum | H.C. Starck GmbH Laufenburg * | GERMANY | CID002546 |
| Tantalum | H.C. Starck Hermsdorf GmbH * | GERMANY | CID002547 |
| Tantalum | H.C. Starck Inc. * | UNITED STATES | CID002548 |
| Tantalum | H.C. Starck Ltd. * | JAPAN | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG * | GERMANY | CID002550 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. * | CHINA | CID002492 |
| Tantalum | Hi-Temp Specialty Metals, Inc. * | UNITED STATES | CID000731 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. * | CHINA | CID002512 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. * | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. * | CHINA | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. * | CHINA | CID002506 |
| Tantalum | KEMET Blue Metals * | MEXICO | CID002539 |
| Tantalum | KEMET Blue Powder * | UNITED STATES | CID002568 |
| Tantalum | King-Tan Tantalum Industry Ltd. * | CHINA | CID000973 |
| Tantalum | LSM Brasil S.A. * | BRAZIL | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. * | INDIA | CID001163 |
| Tantalum | Mineração Taboca S.A. * | BRAZIL | CID001175 |
| Tantalum | Mitsui Mining & Smelting * | JAPAN | CID001192 |
| Tantalum | Molycorp Silmet A.S. * | ESTONIA | CID001200 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. * | CHINA | CID001277 |
| Tantalum | Plansee SE Liezen * | AUSTRIA | CID002540 |
| Tantalum | Plansee SE Reutte * | AUSTRIA | CID002556 |
| Tantalum | QuantumClean * | UNITED STATES | CID001508 |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. * | CHINA | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO * | RUSSIAN FEDERATION | CID001769 |
| Tantalum | Taki Chemicals * | JAPAN | CID001869 |
| Tantalum | Telex Metals * | UNITED STATES | CID001891 |
| Tantalum | Tranzact, Inc. * | UNITED STATES | CID002571 |
| Tantalum | Ulba Metallurgical Plant JSC * | KAZAKHSTAN | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. * | CHINA | CID002508 |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. * | CHINA | CID002307 |
| Tantalum | Zhuzhou Cemented Carbide * | CHINA | CID002232 |
| Tin | Alpha * | UNITED STATES | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company + | VIET NAM | CID002703 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. + | CHINA | CID002158 |
| Tin | China Tin Group Co., Ltd. * | CHINA | CID001070 |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. * | BRAZIL | CID000295 |
| Tin | CV Ayi Jaya * | INDONESIA | CID002570 |
| Tin | CV Gita Pesona * | INDONESIA | CID000306 |
| Tin | CV Serumpun Sebalai * | INDONESIA | CID000313 |
| Tin | CV United Smelting * | INDONESIA | CID000315 |
| Tin | Dowa * | JAPAN | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company + | VIET NAM | CID002572 |
|
| | | |
| Tin | Elmet S.L.U. (Metallo Group) * | SPAIN | CID002774 |
| Tin | EM Vinto * | BOLIVIA | CID000438 |
| Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 |
| Tin | Feinhütte Halsbrücke GmbH + | GERMANY | CID000466 |
| Tin | Fenix Metals * | POLAND | CID000468 |
| Tin | Gejiu Kai Meng Industry and Trade LLC + | CHINA | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. * | CHINA | CID000538 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. * | CHINA | CID000244 |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | CID001063 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. * | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) * | MALAYSIA | CID001105 |
| Tin | Melt Metais e Ligas S/A * | BRAZIL | CID002500 |
| Tin | Metallic Resources, Inc. * | UNITED STATES | CID001142 |
| Tin | Metallo-Chimique N.V. * | BELGIUM | CID002773 |
| Tin | Mineração Taboca S.A. * | BRAZIL | CID001173 |
| Tin | Minsur * | PERU | CID001182 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. * | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. * | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgical S.A. * | BOLIVIA | CID001337 |
| Tin | Phoenix Metal Ltd. + | RWANDA | CID002507 |
| Tin | PT Alam Lestari Kencana | INDONESIA | CID001393 |
| Tin | PT Aries Kencana Sejahtera * | INDONESIA | CID000309 |
| Tin | PT Artha Cipta Langgeng * | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya * | INDONESIA | CID002503 |
| Tin | PT Babel Inti Perkasa * | INDONESIA | CID001402 |
| Tin | PT Bangka Kudai Tin | INDONESIA | CID001409 |
| Tin | PT Bangka Prima Tin * | INDONESIA | CID002776 |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | CID001416 |
| Tin | PT Bangka Tin Industry * | INDONESIA | CID001419 |
| Tin | PT Belitung Industri Sejahtera * | INDONESIA | CID001421 |
| Tin | PT BilliTin Makmur Lestari * | INDONESIA | CID001424 |
| Tin | PT Bukit Timah * | INDONESIA | CID001428 |
| Tin | PT Cipta Persada Mulia * | INDONESIA | CID002696 |
| Tin | PT DS Jaya Abadi * | INDONESIA | CID001434 |
| Tin | PT Eunindo Usaha Mandiri * | INDONESIA | CID001438 |
| Tin | PT Fang Di MulTindo | INDONESIA | CID001442 |
| Tin | PT Inti Stania Prima * | INDONESIA | CID002530 |
| Tin | PT JusTindo * | INDONESIA | CID000307 |
| Tin | PT Karimun Mining + | INDONESIA | CID001448 |
| Tin | PT Mitra Stania Prima * | INDONESIA | CID001453 |
| Tin | PT Panca Mega Persada * | INDONESIA | CID001457 |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | CID001486 |
| Tin | PT Prima Timah Utama * | INDONESIA | CID001458 |
| Tin | PT Refined Bangka Tin * | INDONESIA | CID001460 |
| Tin | PT Sariwiguna Binasentosa * | INDONESIA | CID001463 |
| Tin | PT Seirama Tin Investment | INDONESIA | CID001466 |
|
| | | |
| Tin | PT Stanindo Inti Perkasa * | INDONESIA | CID001468 |
| Tin | PT Sumber Jaya Indah * | INDONESIA | CID001471 |
| Tin | PT Timah (Persero) Tbk Kundur * | INDONESIA | CID001477 |
| Tin | PT Timah (Persero) Tbk Mentok * | INDONESIA | CID001482 |
| Tin | PT Tinindo Inter Nusa * | INDONESIA | CID001490 |
| Tin | PT Wahana Perkit Jaya * | INDONESIA | CID002479 |
| Tin | Resind Indústria e Comércio Ltda * | BRAZIL | CID002706 |
| Tin | Rui Da Hung * | TAIWAN | CID001539 |
| Tin | Soft Metais Ltda. * | BRAZIL | CID001758 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company + | VIET NAM | CID002574 |
| Tin | VQB Mineral and Trading Group JSC * | VIET NAM | CID002015 |
| Tin | White Solder Metalurgia e Mineração Ltda. * | BRAZIL | CID002036 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Tin | Yunnan Tin Group (Holding) Company Limited * | CHINA | CID002180 |
| Tungsten | A.L.M.T. TUNGSTEN Corp. * | JAPAN | CID000004 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. * | VIET NAM | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. * | CHINA | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. * | CHINA | CID000258 |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. + | CHINA | CID002518 |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. + | CHINA | CID000345 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. * | CHINA | CID000499 |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | CID002531 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. * | CHINA | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. * | CHINA | CID002315 |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. + | CHINA | CID000868 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. * | CHINA | CID002494 |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. * | CHINA | CID002536 |
| Tungsten | Global Tungsten & Powders Corp. * | UNITED STATES | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. * | CHINA | CID000218 |
| Tungsten | H.C. Starck GmbH * | GERMANY | CID002541 |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG * | GERMANY | CID002542 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. * | CHINA | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji + | CHINA | CID002579 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin + | CHINA | CID002578 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. * | CHINA | CID000769 |
| Tungsten | Hydrometallurg, JSC * | RUSSIAN FEDERATION | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. * | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. + | CHINA | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. * | CHINA | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. + | CHINA | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. + | CHINA | CID002317 |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. * | CHINA | CID002535 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. + | CHINA | CID002316 |
| Tungsten | Kennametal Fallon + | UNITED STATES | CID000966 |
| Tungsten | Kennametal Huntsville * | UNITED STATES | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. * | CHINA | CID002319 |
| Tungsten | Niagara Refining LLC * | UNITED STATES | CID002589 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC * | VIET NAM | CID002543 |
|
| | | |
| Tungsten | Pobedit, JSC + | RUSSIAN FEDERATION | CID002532 |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. + | VIET NAM | CID002538 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. * | VIET NAM | CID001889 |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. * | VIET NAM | CID002011 |
| Tungsten | Wolfram Bergbau und Hütten AG * | AUSTRIA | CID002044 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. * | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. * | CHINA | CID002082 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
______________________________________________________________________________________________________
Notes to the above table:
During the 2015 reporting period, Fidelity Printers and Refiners Ltd. (CID002515) (“Fidelity”) was identified by CFSI as an “Active” Gold Refiner as of March 18, 2016. It has come to our attention, through one of our customers that certain senior personnel of Fidelity had allegedly been charged in Nigeria with fraud. Accordingly, Nortek now considers Fidelity to be a “high risk smelter”. As of the date of filing of this CMR, we could not determine with any degree of confidence that any parts or components in any of our Covered Products came from Fidelity. Nor were we able to determine whether this refiner in fact is a source of our necessary conflict minerals and, if so, whether any of such minerals may have originated from the Covered Countries.
On August 24, 2015, CFSI updated its website (www.conflictfreesourcing.org). They have revised the Active Smelters list and have added the sub-category “Reaudit in Progress”. This category is defined as a smelter or refiner that is actively engaged in the reaudit process and has committed to complete a CFSP validation audit.
On June 24, 2015, based on its readuit, the CFSI Audit Review Committee made the determination to remove Yunnan Tin Company (CID002180) (“YTC”) from the CFSI Compliant list effective July 29 2015 due to non-compliance. This non-compliance was due to the fact that certain of YTC’s suppliers and related partners may not have been involved in the CFSI CFSP. The YTC has since been reinstated by CFSI and is undergoing the reaudit process. The purpose of this Note is to disclose that there may have been a “gap” during the reporting period (calendar year 2015) during which this supplier was not compliant with the relevant CFSP assessment protocols.
