EXHIBIT 1.01
Halyard Health, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2015
This Conflict Minerals Report (“Report”) by Halyard Health, Inc., is for the period from January 1, 2015 to December 31, 2015 (“Reporting Period”). Unless the context otherwise indicates, “Halyard,” “Company,” “we,” “us,” and “our” mean Halyard Health, Inc. and its consolidated and combined subsidiaries.
This Report is intended to comply with Rule 13p-1 of the Securities Exchange Act of 1934, as amended (“Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TGs”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this report, Halyard has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries, and we proceeded to conduct due diligence on our supplier base. The results of our due diligence are discussed below.
Halyard is a global company that seeks to advance health and healthcare by preventing infection, eliminating pain and speeding recovery. Our products and solutions are designed to address some of today’s most important healthcare needs; namely, preventing infection and reducing the use of narcotics while helping patients move from surgery to recovery. We sell our products in more than 100 countries. We market and support the efficacy, safety and economic benefit of our products with a significant body of clinical evidence.
On October 31, 2014, Kimberly-Clark Corporation distributed all of our capital stock to its shareholders and completed the previously announced spin-off of its healthcare division (“Spin-off”). Halyard was incorporated as a Delaware corporation in February 2014 in anticipation of that Spin-off. The address of our principal executive office is 5405 Windward Parkway, Suite 100 South, Alpharetta, Georgia 30004, and our telephone number is (678) 425-9273.
Halyard is organized into two operating segments based on product groupings: Surgical and Infection Prevention (“S&IP”) and Medical Devices. These operating segments, which are also our reportable global business segments, were determined in accordance with how our executive managers develop and execute global strategies to drive growth and profitability. These strategies include global plans for branding and product positioning, technology, research and development programs, cost reductions including supply chain management, and capacity and capital investments for each of these businesses.
The principal sources of revenue in each global business segment are described below:
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| • | S&IP provides healthcare supplies and solutions that target the prevention of healthcare-associated infections. This segment has recognized brands across its portfolio of product offerings, including sterilization wrap, surgical drapes and gowns, facial protection, protective apparel and medical exam gloves. This business is also a global leader in education to prevent healthcare-associated infections. Products in this segment are sold under HALYARD or KIMGUARD ONE-STEP, QUICK CHECK, SMART-FOLD, POWERGUARD, MICROCOOL, FLUIDSHIELD, PURPLE NITRILE, LAVENDER, STERLING and other brand names. |
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| • | Medical Devices provides a portfolio of innovative product offerings focused on pain management and respiratory and digestive health to improve patient outcomes and reduce the cost of care. These products include post-operative pain management solutions, minimally invasive interventional (or chronic) pain therapies, closed airway suction systems and |
enteral feeding tubes. Products in this segment are sold under ON-Q, COOLIEF, MICROCUFF, MIC-KEY, QUIKBLOC, HOMEPUMP and other brand names.
We conducted an analysis of our products to determine which, if any, were likely to contain 3TGs. The analysis identified that 3TGs were necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period. This was the case especially for the electrical components of such products.
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| III. | Description of Reasonable Country of Origin Inquiry (“RCOI”) |
We began our scoping process by developing a list of our suppliers that provide us with products that may contain one or more of the 3TGs. We then populated the list with contact information and provided it to our third-party service provider (“Service Provider”). The supplier list was then uploaded to our Service Provider’s software tool that allows us to store and manage supplier requests and documentation.
From there, we removed from the list service providers, indirect materials suppliers, and other suppliers who are inactive. This helped ensure that all suppliers surveyed provided items to Halyard that were used in final products in 2015. Through this process, we removed 3 suppliers from the list.
Our Service Provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (“CMRT”), version 4.01b, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, the suppliers on the final supplier list were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, due diligence process, and supply chain, including such supply chain information as the names and locations of smelters and refiners.
As part of the supplier survey, suppliers were asked to complete the CMRT. All communications were tracked and monitored in the Service Provider’s software tool. Non-responsive suppliers were contacted a minimum of three times. If they remained non-responsive, the Service Provider’s Supply Chain Team conducted at least two follow-ups in order to encourage responses. To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we and our Service Provider offered training to them though webinars, videos, documents, and one-on-one discussions.
The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions. All submitted CMRTs were classified as valid or invalid. All suppliers who submitted CMRTs that were classified as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our Service Provider’s software system. As of May 2, 2016, there were 26 invalid submissions that had not been corrected by suppliers.
Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we then conducted due diligence on our supplier base.
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| A. | Design of Due Diligence |
We designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, and the related Supplements for gold, tin, tantalum and tungsten.
Halyard’s conflict minerals due diligence process includes the five steps described in the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of our due diligence measures is outlined below.
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| B. | Performance of Due Diligence |
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| 1. | Establish Strong Company Management Systems |
We organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments, namely Legal, Finance, and Procurement. The Committee members are the (1) Vice President, Deputy General Counsel and Corporate Secretary, (2) Vice President, Global Sourcing and Supply Management, and (3) Business Services Leader in Health
Care Finance. The Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and for overseeing the program.
We have applicable policies and statements such as a Code of Conduct that outlines expected behaviors for all Halyard employees, a Supplier Social Compliance Standard that outlines expected behaviors for all Halyard vendors, and a Conflict Minerals Policy Statement (“Statement”). All three items are available on our website. The Statement, in particular, can be found in the Investor Relations section of our website, under Corporate Governance, at https://halyardhealth.investorroom.com/corporate-governance/conflict-minerals-policy-statement.
We utilized the CMRT version 4.01b and our Service Provider’s software reporting tool for collecting Conflict Minerals declarations from our supply base. Using these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. We have also communicated with relevant suppliers our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information from them to support the chain of custody of the 3TGs identified in our products.
We have several mechanisms that allow people to alert Company management about any concerns they may have about our compliance or ethics. Our Code of Conduct sets out ways to report concerns, including a Code of Conduct Hotline and Online Reporting tool, which both allow reports, in any language, to be made confidentially and anonymously at the election of the person making the report. We also have made publicly available on our website policies for communicating with our Board of Directors and with our compliance-oversight Committees of the Board, namely the Audit Committee and the Compliance Committee. These mechanisms are available to people who may be concerned about compliance with our conflict minerals program or with any other compliance matter.
We maintain a company-wide document retention policy. The policy extends to the documents accumulated in performing our due diligence for this Report and requires that the documents be retained for a period of ten years.
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| 2. | Identify and Assess Risks in the Supply Chain |
Due to the complexity of our products and supply chain, it is difficult for us to identify indirect suppliers. We have relied on responses from our direct suppliers to provide us with information about the source of conflict minerals contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided to them by their suppliers. This chain of information creates a level of uncertainty and risk about the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to recognized industry best practices.
In accordance with the Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. In the Service Provider’s software tool, risk levels are classified as High, Medium and Low. This risk rating is based on three scoring criteria, described below:
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| ◦ | Level 1 Country: Countries with known active ore production for tin or tantalum that are not identified as conflict regions or plausible countries of smuggling or export of tin or tantalum containing materials. This Level includes countries located in North or South America, Australia or Europe. |
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| ◦ | Level 2 Country: Countries that are identified as known or plausible countries for smuggling, export out of Level 3 countries, or transit of materials containing tin or tantalum. This Level currently includes the countries of Kenya, Mozambique, and South Africa. |
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| ◦ | Level 3 Country: The DRC and its nine adjoining countries as outlined in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. This Level includes the countries of Angola, Burundi, Central African Republic, DRC, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. |
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| ◦ | This assesses whether the smelter has an associated regulated body number. Using a smelter CID Number is the primary method. |
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| ◦ | If the smelter is certified as conflict-free via the Conflict Free Sourcing initiative (“CFSI”) or the London Bullion Market Association Responsible Gold Programme. |
We also calculated supplier risk based on the likelihood that the supplier provides 3TG that may originate from Non-Conflict Free sources. The likelihood of this risk is based on the risk ratings of the smelters that the supplier declares on its CMRT.
Additionally, we evaluated suppliers on their conflict minerals program strength. Many companies continue to develop their programs and still provide an answer of “unknown” in response to our survey questions. We used the following criteria to evaluate the strength of their programs, with the capital letters, below, corresponding to the ones in the CMRT declaration tab:
A. Do they have a policy in place that includes DRC conflict-free sourcing?
E. Have they implemented due diligence measures for conflict-free sourcing?
H. Do they verify due diligence information received from their suppliers?
I. Do their verification process include corrective action management?
Our identification and risk assessment process also involves: (1) seeking information about 3TG smelters and refiners in our supply chain by requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable. We believe that the inquiries and analysis described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products.
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| 3. | Design and Implement a Strategy to Respond to Identified Risks |
Our Supplier Social Compliance Standards and Conflict Minerals Policy Statement set out our expectations for our suppliers. If these expectations are not met, the business relationship between us and the supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, we will encourage the applicable supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not we can replace the supplier. We have found no instance to date where we believed it was necessary to implement such risk mitigation efforts.
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| 4. | Utilize Independent Third Party Audits |
We do not have a direct relationship with smelters and refiners (“SORs”) and do not perform or direct audits of these entities. Instead, we rely on third party assurances and certifications such as from the CFSI’s Conflict-Free Smelter Program.
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| 5. | Publicly Report on Supply Chain Due Diligence |
This Report, which constitutes our annual report on our due diligence efforts, is available on our website in the Investor Relations section, under SEC Filings, at https://halyardhealth.investorroom.com/financial-information. This Report also is filed with the SEC.
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| V. | Results of Due Diligence |
As of May 2, 2016, we received responses from 74% of our 385 surveyed suppliers. Of those, 216 claimed no 3TGs, in their products, and 69 claimed that they did have 3TGs. Of the 69 claiming to have 3TGs, 27 indicated that they had tantalum, 56 indicated tin, 40 indicated gold, and 33 indicated tungsten. (The numbers do not sum to 69 because some of the suppliers claimed to have multiple 3TGs in their products.)
As described above, we surveyed our supply chain and reviewed the responses to determine whether further engagement with them was required. The determination to further engage with them was based on criteria such as untimely responses, incomplete responses, and inconsistencies within the data reported. Suppliers who provided a CMRT were asked to submit SOR information. The results are discussed the Smelters and Refiners section below.
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| B. | Efforts to Determine Mine or Location of Origin |
Because we do not have relationships with the smelters and refiners, we relied on requests to our suppliers that they complete the CFSI template. We believe that process suffices as a good faith effort to determine the identity of the mines or the locations of origin of 3TGs in our supply chain.
Of the suppliers we surveyed, many completed the CFSI template at the company or business unit level, and they were unable to represent that 3TGs from the processing facilities they listed were in components they supplied to us. The quality of the responses we received from suppliers varied. Many responses provided via the CMRT included the names of facilities listed by the suppliers as SORs. The CMRT responses that did not list at least one smelter for each 3TG were considered invalid, and our Service Provider followed up on these responses, urging suppliers to resubmit the form and include the smelter information. There are still suppliers that were unable to provide SORs used for the materials supplied to us.
For all the CMRT responses that indicated a smelter, our Service Provider compared them to the list of smelters maintained by the CFSI. As May 2, 2016, we validated 310 SORs, and we are working to validate the additional SOR entries. Appendix A lists only the SORs that our suppliers reported as being in their supply chains and that we validated. Appendix B is a compilation of countries of origin, setting out the countries from which the reported facilities source their conflict minerals.
As our suppliers have been largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional SOR names or country of origin information at this time. We will continue to work with our suppliers to obtain smelter information at the product level.
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| VI. | Future Steps to be Taken |
We are committed to complying with the provisions of the Rule and expect to continue our efforts to improve our conflict minerals program. As we further develop our program, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to, the following:
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| • | Further engage with suppliers and direct them to training resources to increase our survey response rate and improve the content of the responses; |
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| • | Further encourage suppliers to provide responses at the product level; |
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| • | Continue to invest in due diligence tools for our conflict minerals program; |
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| • | Continue to respond to industry trends and legal requirements to improve the traceability of 3TGs in our supply chain; and, |
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| • | If applicable, engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict. |
APPENDIX A
The table below lists, as of May 2, 2016, the smelters or refiners (“SORs”) identified by our direct suppliers that may have been used to process 3TGs necessary to the functionality or production of our products in 2015. Facilities that have been certified as conflict-free by an internationally-recognized validation organization for 3TG SORs are designated in the column furthest to the right, where the word “Yes” indicates that such an organization validated them as conflict-free.
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| Metal | Standard Smelter Name | Smelter Facility Location | Conflict Free? |
| Gold | Advanced Chemical Company | UNITED STATES | Unknown |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Unknown |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Unknown |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Unknown |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes |
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes |
| Gold | Asahi Pretec Corporation | JAPAN | Yes |
| Gold | Asahi Refining Canada Limited | CANADA | Yes |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Yes |
| Gold | Aurubis AG | GERMANY | Yes |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes |
| Gold | Bauer Walser AG | GERMANY | Unknown |
| Gold | Boliden AB | SWEDEN | Yes |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes |
| Gold | Caridad | MEXICO | Unknown |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes |
| Gold | Cendres + Métaux SA | SWITZERLAND | Unknown |
| Gold | Chimet S.p.A. | ITALY | Yes |
| Gold | Chugai Mining | JAPAN | Unknown |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Unknown |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Unknown |
| Gold | DODUCO GmbH | GERMANY | Yes |
| Gold | Dowa | JAPAN | Yes |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes |
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes |
| Gold | Faggi Enrico S.p.A. | ITALY | Unknown |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unknown |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Unknown |
| Gold | Geib Refining Corporation | UNITED STATES | Unknown |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unknown |
| Gold | Guangdong Jinding Gold Limited | CHINA | Unknown |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unknown |
| Gold | Heimerle + Meule GmbH | GERMANY | Yes |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Unknown |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Unknown |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes |
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| Gold | Istanbul Gold Refinery | TURKEY | Yes |
| Gold | Japan Mint | JAPAN | Yes |
| Gold | Jiangxi Copper Company Limited | CHINA | Yes |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Unknown |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unknown |
| Gold | Kazzinc | KAZAKHSTAN | Yes |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes |
| Gold | KGHM Polska MiedŸ Spó³ka Akcyjna | POLAND | Unknown |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Unknown |
| Gold | L’ azurde Company For Jewelry | SAUDI ARABIA | Unknown |
| Gold | Lingbao Gold Company Limited | CHINA | Unknown |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Unknown |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown |
| Gold | Materion | UNITED STATES | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Unknown |
| Gold | Metalor Technologies SA | SWITZERLAND | Yes |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes |
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes |
| Gold | Morris and Watson | NEW ZEALAND | Unknown |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Yes |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Unknown |
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Unknown |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes |
| Gold | PAMP SA | SWITZERLAND | Yes |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unknown |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes |
| Gold | PX Précinox SA | SWITZERLAND | Yes |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes |
| Gold | Republic Metals Corporation | UNITED STATES | Yes |
| Gold | Royal Canadian Mint | CANADA | Yes |
| Gold | Sabin Metal Corp. | UNITED STATES | Unknown |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Unknown |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unknown |
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| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Unknown |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes |
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes |
| Gold | So Accurate Group, Inc. | UNITED STATES | Unknown |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes |
| Gold | Sudan Gold Refinery | SUDAN | Unknown |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes |
| Gold | T.C.A S.p.A | ITALY | Yes |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unknown |
| Gold | Torecom | KOREA, REPUBLIC OF | Unknown |
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes |
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes |
| Gold | Valcambi SA | SWITZERLAND | Yes |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Unknown |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | Unknown |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes |
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes |
| Tantalum | Duoluoshan | CHINA | Yes |
| Tantalum | Exotech Inc. | UNITED STATES | Yes |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Unknown |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes |
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes |
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| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes |
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes |
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes |
| Tantalum | QuantumClean | UNITED STATES | Yes |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes |
| Tantalum | Taki Chemicals | JAPAN | Yes |
| Tantalum | Telex Metals | UNITED STATES | Yes |
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes |
| Tin | Alpha | UNITED STATES | Yes |
| Tin | An Thai Minerals Company Limited | VIET NAM | Unknown |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Unknown |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | Unknown |
| Tin | China Tin Group Co., Ltd. | CHINA | Yes |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes |
| Tin | CV Ayi Jaya | INDONESIA | Yes |
| Tin | CV Dua Sekawan | INDONESIA | Unknown |
| Tin | CV Gita Pesona | INDONESIA | Yes |
| Tin | CV Serumpun Sebalai | INDONESIA | Yes |
| Tin | CV Tiga Sekawan | INDONESIA | Unknown |
| Tin | CV United Smelting | INDONESIA | Yes |
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes |
| Tin | Dowa | JAPAN | Yes |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Unknown |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes |
| Tin | EM Vinto | BOLIVIA | Yes |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Unknown |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | Unknown |
| Tin | Fenix Metals | POLAND | Yes |
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Unknown |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Unknown |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Unknown |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown |
|
| | | |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Unknown |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Unknown |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Unknown |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Unknown |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes |
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes |
| Tin | Mineração Taboca S.A. | BRAZIL | Yes |
| Tin | Minsur | PERU | Yes |
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Unknown |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes |
| Tin | Phoenix Metal Ltd. | RWANDA | Unknown |
| Tin | PT Alam Lestari Kencana | INDONESIA | Unknown |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes |
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes |
| Tin | PT Bangka Kudai Tin | INDONESIA | Unknown |
| Tin | PT Bangka Prima Tin | INDONESIA | Yes |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Unknown |
| Tin | PT Bangka Tin Industry | INDONESIA | Yes |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes |
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes |
| Tin | PT Bukit Timah | INDONESIA | Yes |
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes |
| Tin | PT DS Jaya Abadi | INDONESIA | Yes |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes |
| Tin | PT Fang Di MulTindo | INDONESIA | Unknown |
| Tin | PT Inti Stania Prima | INDONESIA | Yes |
| Tin | PT Justindo | INDONESIA | Yes |
| Tin | PT Karimun Mining | INDONESIA | Unknown |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Unknown |
| Tin | PT Mitra Stania Prima | INDONESIA | Yes |
| Tin | PT Panca Mega Persada | INDONESIA | Yes |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Unknown |
| Tin | PT Prima Timah Utama | INDONESIA | Yes |
| Tin | PT Refined Bangka Tin | INDONESIA | Yes |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes |
| Tin | PT Seirama Tin Investment | INDONESIA | Unknown |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes |
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes |
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes |
| Tin | PT Tirus Putra Mandiri | INDONESIA | Unknown |
|
| | | |
| Tin | PT Tommy Utama | INDONESIA | Yes |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tin | Rui Da Hung | TAIWAN | Yes |
| Tin | Soft Metais Ltda. | BRAZIL | Yes |
| Tin | Thaisarco | THAILAND | Yes |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Unknown |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Unknown |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Unknown |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Unknown |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | H.C. Starck GmbH | GERMANY | Yes |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Unknown |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | Unknown |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Unknown |
| Tungsten | Kennametal Fallon | UNITED STATES | Unknown |
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Unknown |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | Unknown |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
|
| | | |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
APPENDIX B
This list below sets out possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in the Report, however, these possible countries of origin cannot necessarily be linked to our products.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
