Exhibit 1.01
Syneron Medical Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2015
This report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("Conflict Minerals").
Under the Rule, a registrant whose products contain Conflict Minerals necessary to their functionality or production must perform a reasonable country of origin inquiry ("RCOI") in order to determine whether or not those Conflict Minerals originated from the Democratic Republic of the Congo or an adjoining country (the "Covered Countries"), or from recycled and scrap sources. An issuer with no reason to believe that the Conflict Minerals originated from the Covered Countries is required to complete a Form SD describing the RCOI.
In addition, a registrant with reason to believe that the Conflict Minerals in its supply chain may have originated in the Covered Countries is required to exercise due diligence on the Conflict Minerals’ source and chain of custody that conforms to a nationally or internationally recognized framework (such as the OECD Guidance, defined below), and describe these due diligence measures and the results thereof in a Conflict Minerals Report that is included as an exhibit to the Form SD.
The Conflict Minerals Report presented herein has not been audited by an independent auditor.
In accordance with OECD guidance and the Rule, our Form SD, together with our Conflict Minerals Report describing the due diligence process and the results thereof, is publicly available on our website at http://investors.syneron.com/governance.
The content of any website referred to in this conflict minerals report is included for general information only and is not incorporated by reference into this document.
This report has been prepared by Syneron Medical Ltd. (herein referred to as Syneron, the “Company,” “we,” “us,” or “our”) and includes information regarding the Company and all its consolidated subsidiaries as of December 31, 2015. It does not include information regarding subsidiaries that are not required to be consolidated.
Syneron is a leading global aesthetic device company with a comprehensive product portfolio and a global distribution footprint. The Company's technology enables physicians to provide advanced solutions for a broad range of medical-aesthetic applications including body contouring, hair removal, wrinkle reduction, tattoo removal, improving the skin's appearance through the treatment of superficial benign vascular and pigmented lesions, reduction in thigh and abdomen circumference and fat removal and the treatment of acne, leg veins and cellulite. The Company has a wide portfolio of trusted, leading products including UltraShape, VelaShape, GentleLase, VBeam Perfecta, PicoWay, Profound and elos Plus. Founded in 2000, the corporate, R&D, and manufacturing headquarters for Syneron are located in Israel. Syneron also has R&D and manufacturing operations in the U.S. The company markets, services and supports its products in 86 countries. It has offices in North America, France, Germany, Italy, Portugal, Spain, UK, Australia, China, Japan, and Hong Kong and distributors worldwide.
To comply with the Rule, the Company first determined that most of our products contain Conflict Minerals that are necessary to their functionality or production, including each of tin, tantalum, tungsten, and gold. After this determination was made, we examined the supply chain for our products and components thereof, first as part of an RCOI and then in greater depth as part of due diligence efforts.
In general, the supply chain for Conflict Minerals in the aesthetic medical treatment device industry is complex and lacks an established structure to enable product manufacturers such as Syneron to trace the minerals in its finished products back to their source. Our products contain hundreds of components that are purchased from suppliers and assembled into Company products. As a result, we do not generally make direct purchases of Conflict Minerals, and are many levels removed from the mines, smelters or refiners that produce the metals used in our products.
Further, contracts with our suppliers are frequently in force for long periods of time, and we cannot unilaterally impose new contract terms and requirements. In order to address the challenge of performing supply chain diligence under these circumstances, we relied on our direct suppliers to provide information on the origin of the Conflict Minerals contained in the products and components supplied to us, including the sources of Conflict Minerals that are supplied to them from their suppliers. We engaged a third-party service provider that specializes in RCOI data collection to assist us in the RCOI due diligence process.
| 3. | Reasonable Country of Origin Inquiry (RCOI) |
As part of the RCOI, Syneron examined its products to identify the suppliers of all Syneron products or components that are used in Syneron products. For a variety of reasons, including the large number of direct Company suppliers, we did not believe that it was practicable to conduct a survey of all our direct suppliers. Therefore we concluded that it was reasonable to adopt a risk-based approach that surveyed suppliers which represented the majority of our product and component-related expenditures in 2015.
To determine which direct suppliers to target, we first compiled a list of all of the Company’s suppliers (including those from the Company's principal subsidiaries). Next we removed from this list those suppliers that were neither product-related nor component-related, or were otherwise exempted by the Rule (for example, suppliers that provide product packaging were removed from the list). We then ranked the remaining suppliers in terms of our 2015 expenditures, and selected the largest 72 suppliers representing approximately 91% of those expenditures.
Our RCOI process was reasonably designed to trace the origins of Conflict Minerals in our products, and to attempt to determine whether these minerals came from the Covered Countries. The key steps of the RCOI were as follows: to identify and engage relevant suppliers; to collect general corporate data on those suppliers, as well as information on their supply sourcing and quality assurance processes; and to conduct an assessment to determine whether further due diligence was required. There is significant overlap between our RCOI and our due diligence measures performed.
Identifying and Engaging Relevant Suppliers
Contact information, such as names, telephone numbers and email addresses, for relevant individuals at Syneron’s direct suppliers was assembled to ensure that we engaged with the optimal individual(s) within each supplier organization and to establish effective lines of communication.
Once appropriate points of contact within direct suppliers were identified, Syneron provided each such supplier with background information regarding the SEC's Conflict Minerals regulations, and requested that each supplier complete the Conflict Minerals Reporting Template ("CMRT”) (Version 4.01), which is published by the Conflict-Free Sourcing Initiative (“CFSI”). In notification letters to suppliers, Syneron provided instructions on completing the CMRT and emphasized the importance of receiving timely and accurate information. Internally, Syneron defined an escalation process for non-re-sponsive suppliers, which included sending several follow-up email requests, followed by phone call reminders.
Requested Information
The CMRT used to survey our suppliers was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide minerals as part of a company’s supply chain. We believe that using the CMRT is currently the best way to gather information on the country of origin of the Conflict Minerals use in our products. The CMRT includes questions regarding whether the components from the supplier include Conflict Minerals necessary to the functionality or production of the product, whether the Conflict Minerals originate in Covered Countries, the identity and locations of the smelters and refiners who supplied the Conflict Minerals, as well as the supplier's Conflict Minerals policy and due diligence efforts. Written instructions and examples on the use of the tool are available at www.conflictfreesourcing.org/conflict-minerals-reporting-template/training/. The CMRT is used by many companies in their due diligence efforts related to Conflict Minerals.
Data Collection, Management and Quality Assurance
As part of the RCOI process, Syneron collected data from suppliers as provided in response to the CMRT. For non-responsive suppliers, an escalation process was structured in order to obtain the required information where possible, sometimes requiring multiple telephone and/or email contacts to further the data collection process.
Assessment Regarding Further Due Diligence
Completed CMRTs were reviewed for reasonableness and for missing or incomplete data. Verifying responses and obtaining additional information frequently required several rounds of follow-up with the supplier and revisions by such suppliers to their responses provided in the CMRT. Reporting tools were used to track the answers provided by suppliers to determine which items were finalized and which remained to be addressed. In addition, we engaged a third-party service provider that specializes in RCOI data collection to assist us in the RCOI due diligence process.
The results of the RCOI were inconclusive, and we were unable with reasonable assurance to determine the origin of the Conflict Minerals in our products. As a result, we could not exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries. For this reason, we determined to exercise due diligence on the source and chain of custody of the Conflict Minerals in our products, with our due diligence conforming to a nationally or internationally recognized framework (such as the OECD Guidance), and to submit to the SEC a Conflict Minerals Report describing these due diligence efforts as an exhibit to Form SD for calendar year 2015.
(A) Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework provided in the Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance") and related OECD supplements for gold, tin, tantalum and tungsten.
(B) Due Diligence Measures Undertaken
Management System
Syneron has established a management system for addressing the issue of Conflict Minerals in our products. That management system includes a Conflict Minerals Policy, which is posted on our website at www.investors.syneron.com/governance. Our policy (i) commits the Company to working with its suppliers to increase transparency regarding the origin of Conflict Minerals contained in the products they supply to Syneron, (ii) requests that Company suppliers undertake reasonable steps with their supply chains to determine the origin of any Conflict Minerals contained in Syneron’s products, and (iii) encourages suppliers to support industry efforts to enhance traceability and responsible practices in Conflict Minerals supply chains, including those recommended in the OECD framework. In addition, the policy makes clear that Syneron expects its suppliers to evaluate the source of any conflict minerals contained in components they provide to Syneron.
In addition to the Company's Conflict Minerals Policy and related goals, our management system includes the establishment of a team of Company employees consisting of senior operations, engineering, and legal personnel. The team is responsible for implementing our overall Conflict Minerals compliance strategy, including oversight of RCOI and due diligence efforts. Senior management (including the Company's Audit Committee) is briefed about the team's effort, including results of our due diligence, on a regular basis, and relevant documentation of such efforts is retained by the Company. Suppliers, employees or others may contact the Company regarding the Conflict Minerals Policy by using contact information provided in such policy.
Identify and assess risk in the supply chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. As a result, we chose to focus our efforts on surveying our direct suppliers, who were asked to survey their own suppliers (i.e., our upstream suppliers) in order to receive similar information.
As part of our risk-based approach, we segmented those of our suppliers that constitute approximately the top 91% of our supplier expenses into three levels of risk, based on our dependence on the supplier and based on supplier characteristics, including the reputation and stability of the supplier, whether the supplier is an SEC filer, and the supplier’s quality control systems. We assessed two primary risks in our supply chain relating to our suppliers: (i) not receiving timely and accurate information from a supplier with respect to its sourcing of Conflict Minerals; and (ii) difficulty in replacing a supplier, should we determine that such supplier obtained or appears to have obtained Conflict Minerals from sources that contribute to armed conflict in the Covered Countries.
Strategy to Respond to Supplier Risks
As described in our Conflict Minerals Policy, Syneron expects its suppliers to evaluate the source of any Conflict Minerals contained in products or components they provide to us and to provide us with the results of that evaluation. Numerous efforts are made to obtain this information from our suppliers, including follow-up mails and telephone calls when responses are not received from our suppliers or when supplier responses are identified as incomplete, inconsistent or inaccurate. In addition, we compared smelters and refiners identified in our supply chain against lists of facilities that have received a third-party “conflict free” designation in order to track those that have not received such a designation. Finally, our senior management is updated on the findings of our supply chain risk assessment.
Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain
The CMRT provided to our suppliers requests information on the smelters and refiners used to provide the tantalum, tin, tungsten, and gold in our products. We do not typically have a direct relationship with smelters and refiners of such minerals and are unable to perform or direct audits of these entities within our supply chain. Instead, we compared information regarding refiners and smelters provided by our suppliers in their CMRT with lists of refiners and smelters certified by the CFSI as "conflict free”.
Report Annually on Supply Chain Due Diligence
This Conflict Minerals Report, which constitutes our annual report on our Conflict Minerals due diligence, is available on our website at www.investors.syneron.com/governance and is filed with the SEC.
We believe that following OECD guidelines for our due diligence and using the CMRT to gather information from our suppliers is the best way to gather information on mine and country of origin information regarding the Conflict Minerals used in our products.
By the end of our due diligence efforts, we received CMRT responses from 65 out of 72 suppliers surveyed (representing approximately 90% of the suppliers surveyed). We reviewed the responses for completion and consistency, and worked directly with the suppliers who responded, as necessary, to provide revised responses with corrected information. Approximately 75% of suppliers surveyed reported that they do not source Conflict Minerals from the Covered Countries, approximately 12% reported that they do source Conflict Minerals from the Covered Countries, and approximately 12% reported that they do not know whether the Conflict Minerals were sourced from the Covered Countries. Respondents identified 344 entities listed as smelters or refiners, a list of which is attached hereto as Annex I. Of these, 254 (representing approximately 74% of the total) were identified as "conflict-free" or are in the process of undergoing an audit by CFSI, as follows:
| | 2015 |
| Verified Conflict Free | 221 (64%) |
| Participating in an audit process | 33 (10%) |
| Not Participating | 90 (26%) |
| Total | 344 (100%) |
A breakdown by Conflict Minerals of those smelters and refiners verified as conflict free or undergoing an audit is as follows:
| Tin | 69 of 104 (66%) |
| Tantalum | 45 of 48 (94%) |
| Tungsten | 39 of 50 (78%) |
| Gold | 101 of 142 (71%) |
| Total | 254 of 344 (74%) |
In addition, a portion of our suppliers provided us with information regarding the countries of origin of the Conflict Minerals, a list of which is attached hereto as Annex II. However, other suppliers indicated that they do not source from Covered Countries, but were unable to identify specific smelters or refiners, or country of origin information. On account of this incomplete information, Syneron is unable at this time to determine and describe in this report a complete list of either the facilities used to process the Conflict Minerals used in its products or the countries of origin of such Conflict Minerals.
Information gathered from our suppliers is not done on a continuous, real-time basis, but rather done as part of an annual survey. For this reason, and because we gathered information from others (i.e., direct suppliers and independent third party audit programs that examine smelters and refiners), the Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals.
6. Continuous Improvement Efforts to Mitigate Risk
We will consider taking the following steps to improve the due diligence that we conduct to further mitigate any risk that the Conflict Minerals in our products could benefit armed groups in the Covered Countries:
| a. | Periodically engage with suppliers to attempt to increase the response rate to our inquiries and to improve the content of the supplier responses, including responses that were identified as incomplete, inconsistent or inaccurate. |
| b. | Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals. |
| c. | Request any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict. |
| d. | Compare smelters/refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation. |
| e. | Report to senior management on the findings of our supply chain risk assessment. |
Caution Concerning Forward-Looking Statements
Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Further, any statements that are not statements of historical fact (including statements containing the words "believes," "anticipates," "plans," "expects," "may," "will," "would," "intends," "estimates" and similar expressions) should also be considered to be forward-looking statements. The forward-looking statements included herein are based on current expectations and beliefs that involve a number of known and unknown risks and uncertainties. Examples of forward-looking statements in this document include statements relating to our future plans. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. There are a number of factors that could cause events to differ materially from those indicated by the forward-looking statements in this document, including the risks associated with our suppliers not cooperating fully or at all with our efforts. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.
ANNEX I
Smelters or refiners as identified by responding suppliers
Metal | Smelter Name | Smelter Country |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Singway Technology Co., Ltd. | TAIWAN |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Geib Refining Corporation | UNITED STATES |
| Gold | Faggi Enrico S.p.A. | ITALY |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | Valcambi SA | SWITZERLAND |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | So Accurate Group, Inc. | UNITED STATES |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | SEMPSA Joyería Platería SA | SPAIN |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | PX Précinox SA | SWITZERLAND |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | PAMP SA | SWITZERLAND |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Metalor Technologies SA | SWITZERLAND |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Materion | UNITED STATES |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | Lingbao Gold Company Limited | CHINA |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | Asahi Refining Canada Limited | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Gold | Japan Mint | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Dowa | JAPAN |
| Gold | DODUCO GmbH | GERMANY |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Chugai Mining | JAPAN |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Cendres + Métaux SA | SWITZERLAND |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Caridad | MEXICO |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Boliden AB | SWEDEN |
| Gold | Bauer Walser AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Aurubis AG | GERMANY |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Argor-Heraeus SA | SWITZERLAND |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Acade Noble Metal (Zhao Yuan) Corporation | CHINA |
| Gold | China National Gold Group Corporation | CHINA |
| Gold | Codelco | CHILE |
| Gold | Colt Refining | UNITED STATES |
| Gold | DaeryongENC | KOREA, REPUBLIC OF |
| Gold | Heraeus Ltd. Hong Kong | HONG KONG |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
| Gold | Shandong zhongkuang group co., LTD | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co.,Ltd. | CHINA |
| Gold | Sino-platinum Metals CO.,Ltd | CHINA |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN |
| Gold | THE HUTTI GOLD MINES CO.LTD | INDIA |
| Gold | Zhongshan Public Security Bureau, Guangdong Province ,China | CHINA |
| Gold | ZHUZHOU SMELTER GROUP CO., LTD | CHINA |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | Tranzact, Inc. | UNITED STATES |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | Zhuzhou Cemented Carbide | CHINA |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Telex Metals | UNITED STATES |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | Tantalite Resources | SOUTH AFRICA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | Melt Metais e Ligas S/A | BRAZIL |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Thaisarco | THAILAND |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Seirama Tin investment | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT REFINED BANGKA TIN | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Minsur | PERU |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Fenix Metals | POLAND |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | EM Vinto | BOLIVIA |
| Tin | Dowa | JAPAN |
| Tin | CV United Smelting | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Justindo | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | Alpha | UNITED STATES |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA |
| Tin | Bangka Tin, Mentok, PT Timah | INDONESIA |
| Tin | Brautmeier GmbH | GERMANY |
| Tin | Cooperativa Metalurgica de Rond™nia Ltda. | BRAZIL |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | Gold Bell Group | CHINA |
| Tin | GuangDong Jiatian Stannum Products Co., Ltd | CHINA |
| Tin | Heraeus Group | GERMANY |
| Tin | Hunan Xianghualing Tin Co. ltd | CHINA |
| Tin | Minmetals Ganzhou Tin Co. Ltd | CHINA |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | PT Donna Kembara Jaya | INDONESIA |
| Tin | PT HANJAYA PERKASA METALS | INDONESIA |
| Tin | PT HP Metals Indonesia | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Rajwa International | INDONESIA |
| Tin | PT Singkep Times Utama | INDONESIA |
| Tin | PT Supra Sukses Trinusa | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Tin | Super Ligas | BRAZIL |
| Tin | Wilhelm Westmetall | GERMANY |
| Tin | YunNan GeJiu Jin Ye Mineral Co.,Ltd | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten 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 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Air Products | UNITED STATES |
| Tungsten | Ganzhou Haichuang W Co., Ltd | CHINA |
| Tungsten | Hitachi Metals, Ltd. | JAPAN |
| Tungsten | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. | CHINA |
| Tungsten | Xiamen Golden Egret Special Alloy Co. Ltd. | CHINA |
ANNEX II
Countries of origin of Conflict Minerals as identified by responding suppliers
Australia
Austria
Belgium
Bolivia
Brazil
Canada
Chile
China
Estonia
Germany
Hong Kong
India
Indonesia
Italy
Japan
Kazakhstan
Korea, Republic of
Kyrgyzstan
Malaysia
Mexico
Netherlands
Peru
Philippines
Poland
Portugal
Russia
Rwanda
Saudi Arabia
Singapore
South Africa
Spain
Sweden
Switzerland
Taiwan
Thailand
Turkey
United States
Uzbekistan
Vietnam
Zimbabwe
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