Exhibit 1.01
TEXTRON INC.
Conflict Minerals Report
For The Year Ended December 31, 2016
Introduction
Textron Inc. is providing this report for the year ended December 31, 2016 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on SEC registrants that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of those products. The term “conflict mineral” means columbite-tantalite, also known as coltan, cassiterite, gold and wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (collectively, “3TGs”).
On March 6, 2017, Textron acquired Arctic Cat Inc. (“Arctic Cat”), a publicly-held company, pursuant to a cash tender offer followed by a short-form merger. Since Arctic Cat no longer makes filings with the Securities and Exchange Commission, its Conflict Minerals Report for the year ended December 31, 2016 is included as Attachment A hereto.
Company and Product Overview
Textron is a $13.4 billion multi-industry company operating in numerous countries around the world. Our businesses manufacture a variety of complex products including business jets, turboprop and piston aircraft, helicopters and tiltrotor aircraft, unmanned aircraft systems, armored vehicles, advanced marine craft, intelligent battlefield and surveillance systems, intelligence software solutions, piston engines, simulation, training and other defense and aviation mission support products, fuel systems and functional components, specialized vehicles and equipment, turf maintenance equipment, and manual and powered professional tools, testing and measurement equipment. References to “Textron”, “we” and “our” in this Report refer to Textron Inc. and its consolidated subsidiaries.
Covered Products
We conducted a review of the products that we manufacture or contract to be manufactured and found that our products contain 3TGs within numerous components, such as jet engines, circuit boards, electronics, brake components and wiring, and 3TGs generally are required for the products’ functionality or production as specified under the Rule.
Reasonable Country of Origin Inquiry
We conducted a Reasonable Country of Origin Inquiry (“RCOI”) to seek to ascertain whether the 3TGs in our products originated from the Democratic Republic of the Congo or an adjoining country (known collectively as the “Covered Countries”), or are from recycled or scrap sources.
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our worldwide supply chain, it is difficult to identify suppliers in our supply chain which are multiple steps removed from our direct (first-tier) suppliers, and we have no direct relationships with mines, smelters or refiners of 3TGs. Accordingly, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us by them — including sources of 3TGs that are supplied to them from lower tier suppliers.
To implement our RCOI, we established enterprise-wide conflict minerals procedures directing each business unit to take a number of steps to identify suppliers (“in-scope suppliers”) of components or materials potentially containing 3TGs included in products we manufactured or contracted to manufacture during 2016.
Our third party consultant conducted a supply chain survey with the in-scope suppliers using the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template (“CMRT”), version 4.10 or higher. As part of the supplier survey, in-scope suppliers were contacted via a software platform that enables users to complete and track supplier communications and allows suppliers to upload completed CMRT forms directly to the platform for assessment and management. Communications sent to in-scope suppliers through the platform included training and education on the completion of the CMRT form. The survey process and education materials were again enhanced for the 2016 reporting year.
Non-responsive in-scope suppliers were contacted a number of times through the platform and then were also contacted by the consultant’s team in one on one communications. Certain suppliers who continued to be non-responsive were also contacted by a representative of the applicable Textron business unit. The initial group of 2358 suppliers considered to be in-scope was narrowed to 2213 suppliers, due to responses which enabled us to determine that 145 suppliers were in fact not in-scope for the 2016 reporting year for various reasons. These reasons include, for example, being an inactive supplier for that year or providing components or materials which were not included in a final product.
Our program for 2016 continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The survey responses were reviewed for completeness and consistency and our consultant followed up with suppliers who provided incomplete or inconsistent responses. Ultimately, we received complete and validated responses to our supply chain survey from approximately 72% of the in-scope suppliers.
Although approximately 72% of Textron’s in-scope suppliers responded to the RCOI, up from 65% in 2015, there are many suppliers that have not yet provided any smelter or refiner information or have provided incomplete smelter or refiner data. For the suppliers that responded and provided smelter or refiner data, the consultant reviewed all supplier responses that claimed in the declaration section of the CMRT to have known DRC-sourced material.
Because the results of our RCOI indicated that some of our products contain 3TGs which may have originated from the Covered Countries, in an effort to locate mines with the greatest possible specificity, we performed due diligence measures on the source and chain of custody of the 3TGs as described below.
Due Diligence
Design of Our Due Diligence Framework
Our due diligence measures have been designed to conform, in all material respects, with the framework 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 and the related Supplements for gold and for tin, tantalum and tungsten (OECD Guidance).
Due Diligence Process
In conformity with the OECD’s five step process, we conducted the following activities during the 2016 reporting period:
Step 1. Company Management Systems
We have established a management system to support supply chain due diligence related to 3TGs which includes maintaining an internal conflict minerals team with representatives from each of our business units as well as subject matter experts from various internal functions, including legal and environmental health and safety. The team follows our documented procedures for our conflict minerals compliance program. These procedures cover the identification of suppliers to be surveyed and escalation procedures, as described above, records retention, updating supplier lists and integrating acquired businesses into the program. The team leaders report to Textron’s Procurement Council and senior management on the status of our program as appropriate.
In addition, the team has agreed upon a recommended conflict minerals contractual provision which our businesses seek to include in any new or amended contracts with suppliers that may be relevant for our conflict minerals compliance program. This contractual provision requires suppliers to provide us with the necessary 3TG information and to adopt a supply chain policy and procedure to conduct, and require its suppliers to conduct, a reasonable country of origin inquiry and, if necessary, to perform due diligence to identify the facilities used to process the 3TGs and make efforts to identify the location of each mine or location of origin of the 3TGs with the greatest possible specificity.
Textron has adopted a Conflict Minerals Policy Statement which can be found at http://investor.textron.com/investor-relations/corporate-governance/default.aspx.
This year, we improved supplier education and training. To accomplish this, we utilized our third-party consultant’s learning management system and, through our consultant, provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
In addition, we maintain an enterprise-wide grievance mechanism, including an employee helpline, as described in our Business Conduct Guidelines, that enables employees to report suspected or known violations of our Business Conduct Guidelines, law or company policy.
Step 2. Identification and Assessment of Supply Chain Risks
We have worked to identify and assess our supply chain risk through the CMRT survey process. There are a variety of risks identified throughout the survey process, including the risk presented by the lack of sourcing information due to non-responsive suppliers and suppliers providing incomplete or inconsistent responses. The smelter and refiner data collected through the CMRT highlights actual sourcing risk, such as a smelter or refiner sourcing from the Covered Countries and not yet certified as conflict free, or of even higher risk, a smelter or refiner which has not yet begun the audit process to receive certification.
Step 3. Strategy to Respond to Identified Risks
While many risks exist in the search for the origin of the conflict minerals used in components and materials supplied to Textron, as noted above, one of our identified risks is the inability to obtain complete and accurate information from our suppliers in order to make determinations about our products. There are numerous initiatives working to improve transparency and accountability at the smelter and refinery levels of the supply chain, however, we can only benefit from the information being developed by these initiatives if our suppliers are able to trace back the conflict minerals in their products to a specific smelter or refiner.
In our new or amended contractual agreements with our direct suppliers, we have requested the inclusion of a contractual provision which requires suppliers to provide us with the necessary 3TG information and to adopt a supply chain policy and procedure to conduct, and require its suppliers to conduct, a reasonable country of origin inquiry and, if necessary, to perform due diligence to identify the facilities used to process the 3TGs and make efforts to identify the location of each mine or location of origin of the 3TGs with the greatest possible specificity. This objective also is reflected in our Conflict Minerals Policy Statement, which indicates that we encourage our suppliers to undertake reasonable due diligence with their supply chains in an effort to assure their conflict minerals are being sourced from mines and smelters/refiners which have been certified by an independent third party as “conflict free” if sourced within the Covered Countries. Our Policy Statement further states that “if we determine that any of our products or components contain 3TG from a mine or facility in a Covered Country that is not “conflict free”, we will evaluate our options, including but not limited to reassessment of the supplier relationship.”
As our program matures and we obtain more detailed information from our suppliers with regard to the origin of the 3TGs contained in components and materials supplied to us by them, we intend to establish a process to respond to identified risks in our supply chain, including escalating identified risks to management for consideration of appropriate action. During 2016, we did not identify any instances where it was necessary to escalate identified risks to management for further action.
Step 4. Independent Third Party Audit of Facilities’ Due Diligence Practices
As discussed above, we do not have direct relationships with smelters or refiners, and we do not perform direct audits of these entities’ supply chains. We intend to rely on the development and implementation of independent third party audits of smelters’ and refiners’ sourcing, such as the CFSI’s Conflict-Free Smelter Program.
Step 5. Report on Supply Chain Due Diligence
This Report is submitted to the SEC annually and is publicly available at http://investor.textron.com/investor-relations/corporate-governance/default.aspx.
Due Diligence Results
Many of the responses received from suppliers which indicated that they source 3TGs from a Covered Country provided data at the company or divisional level, rather than at the part or component level. As a result, we have been unable to determine whether the 3TGs reported by these suppliers were contained in components supplied to us (as opposed to other components supplied by our suppliers but not purchased by us). We are therefore unable to directly link, based on the due diligence measures described in this Report, 3TGs contained in Textron products to 3TGs originating from a Covered Country.
Facilities Used to Process the 3TGs
Certain of the supplier responses in the CMRT included the names of facilities listed as smelters or refiners. We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Our consultant compared the facilities listed in the responses in the CMRT to the list of smelters maintained by the Conflict-Free Sourcing Initiative (“CFSI”) and confirmed that the name was listed by CFSI. As of May 9, 2017, we have validated in this manner that 317 smelters or refiners provided in our supplier CMRTs are included on these lists.
If a supplier indicated that a facility was certified as “Conflict-Free” our consultant confirmed that it was listed as such by CFSI. Of the smelters and refiners listed by suppliers via the CMRTs which have been validated as described, 250 have been confirmed as “Conflict-Free” and 13 have begun the process to be validated as Conflict-Free. The CMRTs in the aggregate claim that 6 of the Conflict-Free smelters source 3TGs from the Covered Countries, however we cannot confirm this information. Many of the CMRTs did not provide information regarding the country of origin of 3TGs, and such information is generally not available through public information sources related to the smelters and refiners.
Despite the additional smelter information obtained from these suppliers, in most cases information has been provided on the company or divisional level, rather than on the part or component level. Therefore, we cannot yet ascertain whether the smelters identified by our suppliers are related to any parts or components actually provided to us by the suppliers. Schedule A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains, along with the facility location, and an aggregate country list of known smelter or refiner sourcing countries. We have not included in Schedule A any smelters or refiners that we have not been able to validate.
Many suppliers are still unable to provide the smelters or refiners used for components supplied by them to us and, even where facilities were identified, the suppliers did not always provide complete information on the facility, including smelter identification numbers, so that we were unable to immediately validate the smelter as described above and, as previously noted, many of the responses indicated an “unknown” status in terms of determining the origin of 3TGs.
Efforts to Determine Mine or Location of Origin
For the reasons explained above, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials they supply to us. As noted above, our program has initially focused on gathering smelter and refiner information via the CMRT survey process and, as the program progresses, we intend to work toward obtaining from our suppliers all necessary smelter and refiner identification information. This information will facilitate the validation and disclosure of the smelters and refiners as well as the tracing of the 3TGs to their location of origin. However, to date we only have smelter and facility information and no information with regard to the mine or specific location of origin of the 3TGs in our products or whether they come from recycled or scrap sources, as we understand that generally that information is kept confidential by the refiners and smelters.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Covered Products, including seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT and verifying those smelters and refiners with the expanding CFSI lists to the extent possible.
Steps to be Taken to Mitigate Risk
We intend to take and continue the following actions to mitigate the risk that our necessary 3TGs benefit armed groups:
· Direct each of our business units to request our recommended contractual provision requiring our suppliers to conduct due diligence on their supply chains and to provide information to us about the source of their 3TGs, as described above. This provision is intended to be included in new and renewed supplier contracts on a going forward basis.
· Establish a screening process for new suppliers to our businesses so that new suppliers will be added to our in-scope supplier list if appropriate as they begin a relationship with the business.
· Direct suppliers to training resources to attempt to increase the response rate and improve the content of the supplier survey responses.
· Work toward obtaining from our suppliers additional smelter and refiner identification information.
Schedule A
Smelter and Refiner List
Metal |
| Standard Smelter Name |
| Smelter Facility Location |
Gold |
| Abington Reldan Metals, LLC |
| UNITED STATES |
Gold |
| Advanced Chemical Company |
| UNITED STATES |
Gold |
| Aida Chemical Industries Co., Ltd. |
| JAPAN |
Gold |
| Al Etihad Gold Refinery DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| GERMANY |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| UZBEKISTAN |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| BRAZIL |
Gold |
| Argor-Heraeus S.A. |
| SWITZERLAND |
Gold |
| Asahi Pretec Corp. |
| JAPAN |
Gold |
| Asahi Refining Canada Ltd. |
| CANADA |
Gold |
| Asahi Refining USA Inc. |
| UNITED STATES |
Gold |
| Asaka Riken Co., Ltd. |
| JAPAN |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
Gold |
| AU Traders and Refiners |
| SOUTH AFRICA |
Gold |
| AURA-II |
| UNITED STATES |
Gold |
| Aurubis AG |
| GERMANY |
Gold |
| Bangalore Refinery |
| INDIA |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| PHILIPPINES |
Gold |
| Boliden AB |
| SWEDEN |
Gold |
| C. Hafner GmbH + Co. KG |
| GERMANY |
Gold |
| Caridad |
| MEXICO |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
Gold |
| Cendres + Métaux S.A. |
| SWITZERLAND |
Gold |
| Chimet S.p.A. |
| ITALY |
Gold |
| Chugai Mining |
| JAPAN |
Gold |
| Daejin Indus Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
Gold |
| Degussa Sonne / Mond Goldhandel GmbH |
| GERMANY |
Gold |
| DODUCO GmbH |
| GERMANY |
Gold |
| Dowa |
| JAPAN |
Gold |
| DSC (Do Sung Corporation) |
| KOREA, REPUBLIC OF |
Gold |
| Eco-System Recycling Co., Ltd. |
| JAPAN |
Gold |
| Elemetal Refining, LLC |
| UNITED STATES |
Gold |
| Emirates Gold DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Fidelity Printers and Refiners Ltd. |
| ZIMBABWE |
Gold |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CHINA |
Gold |
| Geib Refining Corporation |
| UNITED STATES |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
Gold |
| Guangdong Jinding Gold Limited |
| CHINA |
Gold |
| Gujarat Gold Centre |
| INDIA |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
Gold |
| Heimerle + Meule GmbH |
| GERMANY |
Gold |
| Heraeus Ltd. Hong Kong |
| CHINA |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Gold |
| Hwasung CJ Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CHINA |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| JAPAN |
Gold |
| Istanbul Gold Refinery |
| TURKEY |
Gold |
| Japan Mint |
| JAPAN |
Gold |
| Jiangxi Copper Co., Ltd. |
| CHINA |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| JSC Uralelectromed |
| RUSSIAN FEDERATION |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
Gold |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
Gold |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
Gold |
| Kazzinc |
| KAZAKHSTAN |
Gold |
| Kennecott Utah Copper LLC |
| UNITED STATES |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| POLAND |
Gold |
| Kojima Chemicals Co., Ltd. |
| JAPAN |
Gold |
| Korea Zinc Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Kyrgyzaltyn JSC |
| KYRGYZSTAN |
Gold |
| L’azurde Company For Jewelry |
| SAUDI ARABIA |
Gold |
| Lingbao Gold Co., Ltd. |
| CHINA |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
Gold |
| L’Orfebre S.A. |
| ANDORRA |
Gold |
| LS-NIKKO Copper Inc. |
| KOREA, REPUBLIC OF |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
Gold |
| Materion |
| UNITED STATES |
Gold |
| Matsuda Sangyo Co., Ltd. |
| JAPAN |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| SINGAPORE |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CHINA |
Gold |
| Metalor Technologies S.A. |
| SWITZERLAND |
Gold |
| Metalor USA Refining Corporation |
| UNITED STATES |
Gold |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| MEXICO |
Gold |
| Mitsubishi Materials Corporation |
| JAPAN |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| INDIA |
Gold |
| Modeltech Sdn Bhd |
| MALAYSIA |
Gold |
| Morris and Watson |
| NEW ZEALAND |
Gold |
| Morris and Watson Gold Coast |
| AUSTRALIA |
Gold |
| Moscow Special Alloys Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| TURKEY |
Gold |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
Gold |
| Nihon Material Co., Ltd. |
| JAPAN |
Gold |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| AUSTRIA |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| JAPAN |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| RUSSIAN FEDERATION |
Gold |
| OJSC Novosibirsk Refinery |
| RUSSIAN FEDERATION |
Gold |
| PAMP S.A. |
| SWITZERLAND |
Gold |
| Pease & Curren |
| UNITED STATES |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| RUSSIAN FEDERATION |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| INDONESIA |
Gold |
| PX Précinox S.A. |
| SWITZERLAND |
Gold |
| Rand Refinery (Pty) Ltd. |
| SOUTH AFRICA |
Gold |
| Remondis Argentia B.V. |
| NETHERLANDS |
Gold |
| Republic Metals Corporation |
| UNITED STATES |
Gold |
| Royal Canadian Mint |
| CANADA |
Gold |
| SAAMP |
| FRANCE |
Gold |
| Sabin Metal Corp. |
| UNITED STATES |
Gold |
| SAFINA A.S. |
| CZECH REPUBLIC |
Gold |
| Sai Refinery |
| INDIA |
Gold |
| Samduck Precious Metals |
| KOREA, REPUBLIC OF |
Gold |
| SAMWON Metals Corp. |
| KOREA, REPUBLIC OF |
Gold |
| SAXONIA Edelmetalle GmbH |
| GERMANY |
Gold |
| Schone Edelmetaal B.V. |
| NETHERLANDS |
Gold |
| SEMPSA Joyería Platería S.A. |
| SPAIN |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CHINA |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CHINA |
Gold |
| Singway Technology Co., Ltd. |
| TAIWAN |
Gold |
| So Accurate Group, Inc. |
| UNITED STATES |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RUSSIAN FEDERATION |
Gold |
| Solar Applied Materials Technology Corp. |
| TAIWAN |
Gold |
| Sudan Gold Refinery |
| SUDAN |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| JAPAN |
Gold |
| SungEel HiTech |
| KOREA, REPUBLIC OF |
Gold |
| T.C.A S.p.A |
| ITALY |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| JAPAN |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
Gold |
| Tokuriki Honten Co., Ltd. |
| JAPAN |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
Gold |
| Tony Goetz NV |
| BELGIUM |
Gold |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
Gold |
| Torecom |
| KOREA, REPUBLIC OF |
Gold |
| Umicore Brasil Ltda. |
| BRAZIL |
Gold |
| Umicore Precious Metals Thailand |
| THAILAND |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| BELGIUM |
Gold |
| United Precious Metal Refining, Inc. |
| UNITED STATES |
Gold |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
Gold |
| Valcambi S.A. |
| SWITZERLAND |
Gold |
| Western Australian Mint trading as The Perth Mint |
| AUSTRALIA |
Gold |
| WIELAND Edelmetalle GmbH |
| GERMANY |
Gold |
| Yamamoto Precious Metal Co., Ltd. |
| JAPAN |
Gold |
| Yokohama Metal Co., Ltd. |
| JAPAN |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CHINA |
Gold |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CHINA |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CHINA |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| CHINA |
Tantalum |
| D Block Metals, LLC |
| UNITED STATES |
Tantalum |
| Duoluoshan |
| CHINA |
Tantalum |
| Exotech Inc. |
| UNITED STATES |
Tantalum |
| F&X Electro-Materials Ltd. |
| CHINA |
Tantalum |
| FIR Metals & Resource Ltd. |
| CHINA |
Tantalum |
| Global Advanced Metals Aizu |
| JAPAN |
Tantalum |
| Global Advanced Metals Boyertown |
| UNITED STATES |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CHINA |
Tantalum |
| H.C. Starck Co., Ltd. |
| THAILAND |
Tantalum |
| H.C. Starck GmbH Goslar |
| GERMANY |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| GERMANY |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| GERMANY |
Tantalum |
| H.C. Starck Inc. |
| UNITED STATES |
Tantalum |
| H.C. Starck Ltd. |
| JAPAN |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CHINA |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| UNITED STATES |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| CHINA |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| KEMET Blue Metals |
| MEXICO |
Tantalum |
| KEMET Blue Powder |
| UNITED STATES |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| CHINA |
Tantalum |
| LSM Brasil S.A. |
| BRAZIL |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| INDIA |
Tantalum |
| Mineração Taboca S.A. |
| BRAZIL |
Tantalum |
| Mitsui Mining & Smelting |
| JAPAN |
Tantalum |
| Molycorp Silmet A.S. |
| ESTONIA |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CHINA |
Tantalum |
| Plansee SE Liezen |
| AUSTRIA |
Tantalum |
| Plansee SE Reutte |
| AUSTRIA |
Tantalum |
| Power Resources Ltd. |
| MACEDONIA |
Tantalum |
| QuantumClean |
| UNITED STATES |
Tantalum |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd. |
| CHINA |
Tantalum |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
Tantalum |
| Taki Chemicals |
| JAPAN |
Tantalum |
| Telex Metals |
| UNITED STATES |
Tantalum |
| Tranzact, Inc. |
| UNITED STATES |
Tantalum |
| Ulba Metallurgical Plant JSC |
| KAZAKHSTAN |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CHINA |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CHINA |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CHINA |
Tin |
| Alpha |
| UNITED STATES |
Tin |
| An Thai Minerals Co., Ltd. |
| VIET NAM |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CHINA |
Tin |
| China Tin Group Co., Ltd. |
| CHINA |
Tin |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CHINA |
Tin |
| Cooperativa Metalurgica de Rondônia Ltda. |
| BRAZIL |
Tin |
| CV Ayi Jaya |
| INDONESIA |
Tin |
| CV Dua Sekawan |
| INDONESIA |
Tin |
| CV Gita Pesona |
| INDONESIA |
Tin |
| CV Serumpun Sebalai |
| INDONESIA |
Tin |
| CV Tiga Sekawan |
| INDONESIA |
Tin |
| CV United Smelting |
| INDONESIA |
Tin |
| CV Venus Inti Perkasa |
| INDONESIA |
Tin |
| Dowa |
| JAPAN |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
Tin |
| Elmet S.L.U. |
| SPAIN |
Tin |
| EM Vinto |
| BOLIVIA |
Tin |
| Estanho de Rondônia S.A. |
| BRAZIL |
Tin |
| Fenix Metals |
| POLAND |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| CHINA |
Tin |
| Gejiu Jinye Mineral Company |
| CHINA |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CHINA |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CHINA |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| CHINA |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| CHINA |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| BRAZIL |
Tin |
| Malaysia Smelting Corporation (MSC) |
| MALAYSIA |
Tin |
| Melt Metais e Ligas S.A. |
| BRAZIL |
Tin |
| Metallic Resources, Inc. |
| UNITED STATES |
Tin |
| Metallo-Chimique N.V. |
| BELGIUM |
Tin |
| Mineração Taboca S.A. |
| BRAZIL |
Tin |
| Minsur |
| PERU |
Tin |
| Mitsubishi Materials Corporation |
| JAPAN |
Tin |
| Modeltech Sdn Bhd |
| MALAYSIA |
Tin |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CHINA |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| THAILAND |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| PHILIPPINES |
Tin |
| Operaciones Metalurgical S.A. |
| BOLIVIA |
Tin |
| Phoenix Metal Ltd. |
| RWANDA |
Tin |
| PT Aries Kencana Sejahtera |
| INDONESIA |
Tin |
| PT Artha Cipta Langgeng |
| INDONESIA |
Tin |
| PT ATD Makmur Mandiri Jaya |
| INDONESIA |
Tin |
| PT Babel Inti Perkasa |
| INDONESIA |
Tin |
| PT Bangka Prima Tin |
| INDONESIA |
Tin |
| PT Bangka Tin Industry |
| INDONESIA |
Tin |
| PT Belitung Industri Sejahtera |
| INDONESIA |
Tin |
| PT Bukit Timah |
| INDONESIA |
Tin |
| PT Cipta Persada Mulia |
| INDONESIA |
Tin |
| PT DS Jaya Abadi |
| INDONESIA |
Tin |
| PT Eunindo Usaha Mandiri |
| INDONESIA |
Tin |
| PT Inti Stania Prima |
| INDONESIA |
Tin |
| PT Justindo |
| INDONESIA |
Tin |
| PT Karimun Mining |
| INDONESIA |
Tin |
| PT Kijang Jaya Mandiri |
| INDONESIA |
Tin |
| PT Lautan Harmonis Sejahtera |
| INDONESIA |
Tin |
| PT Mitra Stania Prima |
| INDONESIA |
Tin |
| PT O.M. Indonesia |
| INDONESIA |
Tin |
| PT Panca Mega Persada |
| INDONESIA |
Tin |
| PT Prima Timah Utama |
| INDONESIA |
Tin |
| PT Refined Bangka Tin |
| INDONESIA |
Tin |
| PT Sariwiguna Binasentosa |
| INDONESIA |
Tin |
| PT Stanindo Inti Perkasa |
| INDONESIA |
Tin |
| PT Sukses Inti Makmur |
| INDONESIA |
Tin |
| PT Sumber Jaya Indah |
| INDONESIA |
Tin |
| PT Timah (Persero) Tbk Kundur |
| INDONESIA |
Tin |
| PT Timah (Persero) Tbk Mentok |
| INDONESIA |
Tin |
| PT Tinindo Inter Nusa |
| INDONESIA |
Tin |
| PT Tommy Utama |
| INDONESIA |
Tin |
| PT Wahana Perkit Jaya |
| INDONESIA |
Tin |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Tin |
| Rui Da Hung |
| TAIWAN |
Tin |
| Soft Metais Ltda. |
| BRAZIL |
Tin |
| Thaisarco |
| THAILAND |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| VQB Mineral and Trading Group JSC |
| VIET NAM |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| BRAZIL |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
Tin |
| Yunnan Tin Company Limited |
| CHINA |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| JAPAN |
Tungsten |
| ACL Metais Eireli |
| BRAZIL |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| VIET NAM |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Global Tungsten & Powders Corp. |
| UNITED STATES |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| H.C. Starck GmbH |
| GERMANY |
Tungsten |
| H.C. Starck Smelting GmbH & Co.KG |
| GERMANY |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CHINA |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Hydrometallurg, JSC |
| RUSSIAN FEDERATION |
Tungsten |
| Japan New Metals Co., Ltd. |
| JAPAN |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Kennametal Fallon |
| UNITED STATES |
Tungsten |
| Kennametal Huntsville |
| UNITED STATES |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Moliren Ltd |
| RUSSIAN FEDERATION |
Tungsten |
| Niagara Refining LLC |
| UNITED STATES |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| VIET NAM |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| PHILIPPINES |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CHINA |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| VIET NAM |
Tungsten |
| Unecha Refractory metals plant |
| RUSSIAN FEDERATION |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| VIET NAM |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| AUSTRIA |
Tungsten |
| Woltech Korea Co., Ltd. |
| KOREA, REPUBLIC OF |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CHINA |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CHINA |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CHINA |
Country of Origin List:
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.
Attachment A
Arctic Cat Inc.
Conflict Minerals Report
For the year ended December 31, 2016
Introduction
This report for the year ended December 31, 2016 has been prepared and is presented to comply with Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 (the “Rule”). The Rule imposes certain reporting obligations on SEC registrants that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of those products. The term “conflict mineral” means columbite-tantalite, also known as coltan, cassiterite, gold and wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (collectively, “3TGs”).
Arctic Cat Inc. determined that 3TGs were necessary to the functionality or production of some of the products that we manufactured or contracted to be manufactured during the 2016 year. Therefore, Arctic Cat conducted a reasonable country of origin inquiry (RCOI) in good faith to determine whether any of the Conflict Minerals in its products originated from the Democratic Republic of the Congo or an adjoining country (known collectively as the “Covered Countries”), or are from recycled or scrap sources. Based on the RCOI, the Company has reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the 3TGs in question.
Company Information
Arctic Cat Inc. (the “Company” or “Arctic Cat,” or “we,” “our” or “us”) is a Minnesota corporation with principal executive offices in Minneapolis, Minnesota. We design, engineer, manufacture and market snowmobiles, all-terrain vehicles and recreational off-highway vehicles, as well as related parts, garments and accessories under the Arctic Cat® and Motorfist® brand names. Our common stock traded on the NASDAQ Global Select Market under the symbol ACAT until our acquisition by Textron Inc. on March 6, 2017.
Description of Products
Arctic Cat is a manufacturer of sport and recreational off-highway vehicles, such as snowmobiles and all-terrain vehicles, as well as related parts, lubricants, garments and accessories. Only certain goods that Arctic Cat manufactures require procurement of components that use 3TGs. While certain Arctic Cat products incorporate parts and/or assemblies fabricated from any of the 3TGs, Arctic Cat does not source 3TGs directly from mines or from smelters or refiners. The materials, subassemblies and other items incorporated into these products that we have reason to believe may contain 3TGs are acquired from a large number of unaffiliated suppliers.
Management Systems
Internal Team:
Arctic Cat’s Internal Conflict Minerals Team involves a cross-functional team that provides oversight and guides the business team concerning the Conflict Minerals Program requirements. This team includes representatives from Supply Chain, Engineering, Accounting & Finance, Legal and Trade Compliance.
The Conflict Minerals Team reports its findings to senior management. These findings include direct suppliers’ responses to conflict minerals information requests, updates on monitoring and tracking, corrective action and risk mitigation efforts where applicable.
Arctic Cat has also implemented an outside management system through the use of a third-party service provider. Through this tool we are able to collect and store supplier data and compliance documents, communicate with suppliers, provide education, and monitor risks in our supply.
Control Systems:
Since we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our business sector and other sectors, through our own efforts and those organized by trade associations. We also participate in or actively monitor the following industry-wide initiatives to disclose upstream actors in the supply chain: Monitor the actions of the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict Free Sourcing Initiative (CFSI), as well as other manufacturing industry consortiums including the National Association of Manufacturers (NAM), and participates in Twin Cities Conflict Minerals Task Force.
Supplier Engagement:
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.10 or higher and a third-party service provider’s web-based reporting tool for collecting Conflict Minerals declarations from our direct suppliers. These tools have allowed us to educate our suppliers to help them understand our expectations and requirements, as well as increase the rate of responses we have received from our suppliers to our survey requests. We continue to follow-up with suppliers to educate them on the Rule, the use of the CMRT, and Arctic Cat’s expectations for their supply chain due diligence and reporting.
This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party vendor’s learning management system and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
Reasonable Country of Origin Inquiry (RCOI)
Arctic Cat identified and assessed the risk in the supply chain and made a good faith effort to perform its RCOI. The scope of review for 2016 included 97% of Arctic Cat’s largest direct suppliers based upon spend and continued to include the supply chain under the Motorfist® brand. Within its supplier group, Arctic Cat also scoped according to risk by identifying those suppliers that provide components (including materials, subassemblies or other items) that possibly contain 3TGs.
We defined the scoping process further by removing service providers, indirect materials suppliers, and suppliers that are no longer active as they have not provided us products in the 2016 year. Once this was complete, Arctic Cat and our third party service provider began the supplier survey portion of the RCOI.
Suppliers were surveyed via an automated platform that enables its users to complete and track supplier communications. Suppliers received this communication describing the compliance requirements and were asked to provide answers to the Electronic Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI) Conflict Minerals Common Reporting Template (CMRT) version 4.10 or higher. The CMRT is regarded as the most common reporting tool for conflict minerals content and sourcing information worldwide, developed by several of the world’s leading consumer electronics companies. To ensure our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party service provider have provided training to our suppliers through webinars, videos and substantial one-on-one discussions. If suppliers did not provide a response, they were contacted a minimum of three times and were also managed by our service provider in one on one communications for escalation purposes.
Our program continues to include automated data validation on all submitted CMRTs. The goal of this validation is to increase the accuracy of submissions and identify any contradictory answers. All submitted forms are accepted and classified as valid or invalid so that data is still retained. All suppliers who submitted CMRTs that were flagged
as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All communications were monitored and tracked in our service provider’s system for future reporting and transparency.
At the time of this report, Arctic Cat has received responses from 82% of the suppliers surveyed.
Arctic Cat believes the risk assessment and RCOI process were reasonably designed and performed in good faith. Accordingly, Arctic Cat engaged in the due diligence measures on the source and chain of custody of the 3TGs that were claimed by our suppliers. These measures are described in the next section of this Conflict Minerals Report.
Design of Due Diligence
Arctic Cat designed its due diligence framework in conformity with nationally and internationally recognized due diligence frameworks, specifically, the five step framework established by the Organisation for Economic Cooperation and Development (“OECD”). This was outlined in the OECD 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 (the “Guidance”). The design of our due diligence process conforms to the Guidance as applicable to our circumstances and position in the supply chain as a “downstream” company with little to no direct influence on smelters/refiners.
Due Diligence Measures Undertaken
The design of our due diligence process conforms to Step 3 and (to the extent necessary at this time) Step 4 of the OECD Guidance as applicable to our circumstances and position in the supply chain as a “downstream” company with little to no direct influence on smelters/refiners.
1. Identify and Assess Risks:
We have relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
A comparison of smelters and/or refiners (“SORs”) identified by suppliers was conducted. Validated SORs were matched against available lists of processors that have been certified by internationally-recognized industry organizations, particularly the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program. If the SOR was not certified by an internationally-recognized organization, further outreach and research was conducted as necessary.
2. Design and Implement a Strategy to Respond to Risks
When high concern facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Arctic Cat, and escalating up to removal of these high-risk smelters from their supply chain.
3. Utilize Independent Third Party Audits
The Company does not have any direct relationship with SORs and does not perform or direct audits on SORs identified by our supply chain. Instead, Arctic Cat relies on publicly available third-party audits performed by an internationally-recognized validation organization, such as the Conflict Free Sourcing Initiative.
4. Report on Supply Chain Due Diligence
Arctic Cat has filed conflict minerals disclosure with the SEC annually. Because Arctic Cat is no longer an SEC filer, this 2016 report will be filed with the SEC as Exhibit 1.02 to Textron Inc.’s Form SD and is publicly available at http://investor.textron.com/investors/financial-reports/sec-filings/2017/default.aspx.
Results of Due Diligence
Survey Results
As of April 5th 2017, we received responses from 82% of our 104 surveyed suppliers for the 2016 Reporting Year. Based on those responses we have identified 311 legitimate smelters and refiners reported by our suppliers as being in their supply chains. Of those, 250 have been certified by the CFSI as conflict-free and 61 have not yet been confirmed as conflict-free. The majority of the facilities listed have been deemed as low or medium risk.
Facilities Used to Process 3TG & Countries of Origin
Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which SORs listed below reported by our suppliers actually processed the 3TGs contained in our products. The following list of processing SORs may contain more facilities than those that actually processed the 3TGs contained in our products. The following list also identifies those SORs that Arctic Cat identified as achieving Conflict Free designation by the Conflict Free Sourcing Initiative (“CFSI”):
Metal |
| Standard Smelter Name |
| Smelter Facility |
Gold |
| Advanced Chemical Company |
| UNITED STATES |
Gold | �� | Aida Chemical Industries Co., Ltd. |
| JAPAN |
Gold |
| Al Etihad Gold Refinery DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| GERMANY |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| UZBEKISTAN |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| BRAZIL |
Gold |
| Argor-Heraeus S.A. |
| SWITZERLAND |
Gold |
| Asahi Pretec Corp. |
| JAPAN |
Gold |
| Asahi Refining Canada Ltd. |
| CANADA |
Gold |
| Asahi Refining USA Inc. |
| UNITED STATES |
Gold |
| Asaka Riken Co., Ltd. |
| JAPAN |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
Gold |
| AU Traders and Refiners |
| SOUTH AFRICA |
Gold |
| AURA-II |
| UNITED STATES |
Gold |
| Aurubis AG |
| GERMANY |
Gold |
| Bangalore Refinery |
| INDIA |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| PHILIPPINES |
Gold |
| Boliden AB |
| SWEDEN |
Gold |
| C. Hafner GmbH + Co. KG |
| GERMANY |
Gold |
| Caridad |
| MEXICO |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
Gold |
| Cendres + Métaux S.A. |
| SWITZERLAND |
Gold |
| Chimet S.p.A. |
| ITALY |
Gold |
| Chugai Mining |
| JAPAN |
Gold |
| Daejin Indus Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
Gold |
| DODUCO GmbH |
| GERMANY |
Gold |
| Dowa |
| JAPAN |
Gold |
| DSC (Do Sung Corporation) |
| KOREA, REPUBLIC OF |
Gold |
| Eco-System Recycling Co., Ltd. |
| JAPAN |
Gold |
| Elemetal Refining, LLC |
| UNITED STATES |
Gold |
| Emirates Gold DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Fidelity Printers and Refiners Ltd. |
| ZIMBABWE |
Gold |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CHINA |
Gold |
| Geib Refining Corporation |
| UNITED STATES |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
Gold |
| Guangdong Jinding Gold Limited |
| CHINA |
Gold |
| Gujarat Gold Centre |
| INDIA |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
Gold |
| Heimerle + Meule GmbH |
| GERMANY |
Gold |
| Heraeus Ltd. Hong Kong |
| CHINA |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Gold |
| Hwasung CJ Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CHINA |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| JAPAN |
Gold |
| Istanbul Gold Refinery |
| TURKEY |
Gold |
| Japan Mint |
| JAPAN |
Gold |
| Jiangxi Copper Co., Ltd. |
| CHINA |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| JSC Uralelectromed |
| RUSSIAN FEDERATION |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
Gold |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
Gold |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
Gold |
| Kazzinc |
| KAZAKHSTAN |
Gold |
| Kennecott Utah Copper LLC |
| UNITED STATES |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| POLAND |
Gold |
| Kojima Chemicals Co., Ltd. |
| JAPAN |
Gold |
| Korea Zinc Co., Ltd. |
| KOREA, REPUBLIC OF |
Gold |
| Kyrgyzaltyn JSC |
| KYRGYZSTAN |
Gold |
| L’azurde Company For Jewelry |
| SAUDI ARABIA |
Gold |
| Lingbao Gold Co., Ltd. |
| CHINA |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
Gold |
| LS-NIKKO Copper Inc. |
| KOREA, REPUBLIC OF |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
Gold |
| Materion |
| UNITED STATES |
Gold |
| Matsuda Sangyo Co., Ltd. |
| JAPAN |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| SINGAPORE |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CHINA |
Gold |
| Metalor Technologies S.A. |
| SWITZERLAND |
Gold |
| Metalor USA Refining Corporation |
| UNITED STATES |
Gold |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| MEXICO |
Gold |
| Mitsubishi Materials Corporation |
| JAPAN |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| INDIA |
Gold |
| Modeltech Sdn Bhd |
| MALAYSIA |
Gold |
| Morris and Watson |
| NEW ZEALAND |
Gold |
| Moscow Special Alloys Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| TURKEY |
Gold |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
Gold |
| Nihon Material Co., Ltd. |
| JAPAN |
Gold |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| AUSTRIA |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| JAPAN |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| RUSSIAN FEDERATION |
Gold |
| OJSC Novosibirsk Refinery |
| RUSSIAN FEDERATION |
Gold |
| PAMP S.A. |
| SWITZERLAND |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| RUSSIAN FEDERATION |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| INDONESIA |
Gold |
| PX Précinox S.A. |
| SWITZERLAND |
Gold |
| Rand Refinery (Pty) Ltd. |
| SOUTH AFRICA |
Gold |
| Remondis Argentia B.V. |
| NETHERLANDS |
Gold |
| Republic Metals Corporation |
| UNITED STATES |
Gold |
| Royal Canadian Mint |
| CANADA |
Gold |
| SAAMP |
| FRANCE |
Gold |
| Sabin Metal Corp. |
| UNITED STATES |
Gold |
| SAFINA A.S. |
| CZECH REPUBLIC |
Gold |
| Sai Refinery |
| INDIA |
Gold |
| Samduck Precious Metals |
| KOREA, REPUBLIC OF |
Gold |
| SAMWON Metals Corp. |
| KOREA, REPUBLIC OF |
Gold |
| SAXONIA Edelmetalle GmbH |
| GERMANY |
Gold |
| Schone Edelmetaal B.V. |
| NETHERLANDS |
Gold |
| SEMPSA Joyería Platería S.A. |
| SPAIN |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CHINA |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CHINA |
Gold |
| Singway Technology Co., Ltd. |
| TAIWAN |
Gold |
| So Accurate Group, Inc. |
| UNITED STATES |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RUSSIAN FEDERATION |
Gold |
| Solar Applied Materials Technology Corp. |
| TAIWAN |
Gold |
| Sudan Gold Refinery |
| SUDAN |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| JAPAN |
Gold |
| T.C.A S.p.A |
| ITALY |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| JAPAN |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
Gold |
| Tokuriki Honten Co., Ltd. |
| JAPAN |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
Gold |
| Tony Goetz NV |
| BELGIUM |
Gold |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
Gold |
| Torecom |
| KOREA, REPUBLIC OF |
Gold |
| Umicore Brasil Ltda. |
| BRAZIL |
Gold |
| Umicore Precious Metals Thailand |
| THAILAND |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| BELGIUM |
Gold |
| United Precious Metal Refining, Inc. |
| UNITED STATES |
Gold |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
Gold |
| Valcambi S.A. |
| SWITZERLAND |
Gold |
| Western Australian Mint trading as The Perth Mint |
| AUSTRALIA |
Gold |
| WIELAND Edelmetalle GmbH |
| GERMANY |
Gold |
| Yamamoto Precious Metal Co., Ltd. |
| JAPAN |
Gold |
| Yokohama Metal Co., Ltd. |
| JAPAN |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CHINA |
Gold |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CHINA |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CHINA |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| CHINA |
Tantalum |
| D Block Metals, LLC |
| UNITED STATES |
Tantalum |
| Duoluoshan |
| CHINA |
Tantalum |
| Exotech Inc. |
| UNITED STATES |
Tantalum |
| F&X Electro-Materials Ltd. |
| CHINA |
Tantalum |
| FIR Metals & Resource Ltd. |
| CHINA |
Tantalum |
| Global Advanced Metals Aizu |
| JAPAN |
Tantalum |
| Global Advanced Metals Boyertown |
| UNITED STATES |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CHINA |
Tantalum |
| H.C. Starck Co., Ltd. |
| THAILAND |
Tantalum |
| H.C. Starck GmbH Goslar |
| GERMANY |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| GERMANY |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| GERMANY |
Tantalum |
| H.C. Starck Inc. |
| UNITED STATES |
Tantalum |
| H.C. Starck Ltd. |
| JAPAN |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CHINA |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| UNITED STATES |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| CHINA |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| KEMET Blue Metals |
| MEXICO |
Tantalum |
| KEMET Blue Powder |
| UNITED STATES |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| CHINA |
Tantalum |
| LSM Brasil S.A. |
| BRAZIL |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| INDIA |
Tantalum |
| Mineração Taboca S.A. |
| BRAZIL |
Tantalum |
| Mitsui Mining & Smelting |
| JAPAN |
Tantalum |
| Molycorp Silmet A.S. |
| ESTONIA |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CHINA |
Tantalum |
| Plansee SE Liezen |
| AUSTRIA |
Tantalum |
| Plansee SE Reutte |
| AUSTRIA |
Tantalum |
| Power Resources Ltd. |
| MACEDONIA |
Tantalum |
| QuantumClean |
| UNITED STATES |
Tantalum |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd. |
| CHINA |
Tantalum |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
Tantalum |
| Taki Chemicals |
| JAPAN |
Tantalum |
| Telex Metals |
| UNITED STATES |
Tantalum |
| Tranzact, Inc. |
| UNITED STATES |
Tantalum |
| Ulba Metallurgical Plant JSC |
| KAZAKHSTAN |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CHINA |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CHINA |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CHINA |
Tin |
| Alpha |
| UNITED STATES |
Tin |
| An Thai Minerals Co., Ltd. |
| VIET NAM |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CHINA |
Tin |
| China Tin Group Co., Ltd. |
| CHINA |
Tin |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CHINA |
Tin |
| Cooperativa Metalurgica de Rondônia Ltda. |
| BRAZIL |
Tin |
| CV Ayi Jaya |
| INDONESIA |
Tin |
| CV Dua Sekawan |
| INDONESIA |
Tin |
| CV Gita Pesona |
| INDONESIA |
Tin |
| CV Serumpun Sebalai |
| INDONESIA |
Tin |
| CV Tiga Sekawan |
| INDONESIA |
Tin |
| CV United Smelting |
| INDONESIA |
Tin |
| CV Venus Inti Perkasa |
| INDONESIA |
Tin |
| Dowa |
| JAPAN |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
Tin |
| Elmet S.L.U. |
| SPAIN |
Tin |
| EM Vinto |
| BOLIVIA |
Tin |
| Estanho de Rondônia S.A. |
| BRAZIL |
Tin |
| Fenix Metals |
| POLAND |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| CHINA |
Tin |
| Gejiu Jinye Mineral Company |
| CHINA |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CHINA |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CHINA |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| CHINA |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| CHINA |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| BRAZIL |
Tin |
| Malaysia Smelting Corporation (MSC) |
| MALAYSIA |
Tin |
| Melt Metais e Ligas S.A. |
| BRAZIL |
Tin |
| Metallic Resources, Inc. |
| UNITED STATES |
Tin |
| Metallo-Chimique N.V. |
| BELGIUM |
Tin |
| Mineração Taboca S.A. |
| BRAZIL |
Tin |
| Minsur |
| PERU |
Tin |
| Mitsubishi Materials Corporation |
| JAPAN |
Tin |
| Modeltech Sdn Bhd |
| MALAYSIA |
Tin |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CHINA |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| THAILAND |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| PHILIPPINES |
Tin |
| Operaciones Metalurgical S.A. |
| BOLIVIA |
Tin |
| Phoenix Metal Ltd. |
| RWANDA |
Tin |
| PT Aries Kencana Sejahtera |
| INDONESIA |
Tin |
| PT Artha Cipta Langgeng |
| INDONESIA |
Tin |
| PT ATD Makmur Mandiri Jaya |
| INDONESIA |
Tin |
| PT Babel Inti Perkasa |
| INDONESIA |
Tin |
| PT Bangka Prima Tin |
| INDONESIA |
Tin |
| PT Bangka Tin Industry |
| INDONESIA |
Tin |
| PT Belitung Industri Sejahtera |
| INDONESIA |
Tin |
| PT Bukit Timah |
| INDONESIA |
Tin |
| PT Cipta Persada Mulia |
| INDONESIA |
Tin |
| PT DS Jaya Abadi |
| INDONESIA |
Tin |
| PT Eunindo Usaha Mandiri |
| INDONESIA |
Tin |
| PT Inti Stania Prima |
| INDONESIA |
Tin |
| PT Justindo |
| INDONESIA |
Tin |
| PT Karimun Mining |
| INDONESIA |
Tin |
| PT Kijang Jaya Mandiri |
| INDONESIA |
Tin |
| PT Lautan Harmonis Sejahtera |
| INDONESIA |
Tin |
| PT Mitra Stania Prima |
| INDONESIA |
Tin |
| PT O.M. Indonesia |
| INDONESIA |
Tin |
| PT Panca Mega Persada |
| INDONESIA |
Tin |
| PT Prima Timah Utama |
| INDONESIA |
Tin |
| PT Refined Bangka Tin |
| INDONESIA |
Tin |
| PT Sariwiguna Binasentosa |
| INDONESIA |
Tin |
| PT Stanindo Inti Perkasa |
| INDONESIA |
Tin |
| PT Sukses Inti Makmur |
| INDONESIA |
Tin |
| PT Sumber Jaya Indah |
| INDONESIA |
Tin |
| PT Timah (Persero) Tbk Kundur |
| INDONESIA |
Tin |
| PT Timah (Persero) Tbk Mentok |
| INDONESIA |
Tin |
| PT Tinindo Inter Nusa |
| INDONESIA |
Tin |
| PT Tommy Utama |
| INDONESIA |
Tin |
| PT Wahana Perkit Jaya |
| INDONESIA |
Tin |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Tin |
| Rui Da Hung |
| TAIWAN |
Tin |
| Soft Metais Ltda. |
| BRAZIL |
Tin |
| Thaisarco |
| THAILAND |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| VQB Mineral and Trading Group JSC |
| VIET NAM |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| BRAZIL |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
Tin |
| Yunnan Tin Company Limited |
| CHINA |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| JAPAN |
Tungsten |
| ACL Metais Eireli |
| BRAZIL |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| VIET NAM |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Global Tungsten & Powders Corp. |
| UNITED STATES |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| H.C. Starck GmbH |
| GERMANY |
Tungsten |
| H.C. Starck Smelting GmbH & Co.KG |
| GERMANY |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CHINA |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Hydrometallurg, JSC |
| RUSSIAN FEDERATION |
Tungsten |
| Japan New Metals Co., Ltd. |
| JAPAN |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Kennametal Fallon |
| UNITED STATES |
Tungsten |
| Kennametal Huntsville |
| UNITED STATES |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Moliren Ltd |
| RUSSIAN FEDERATION |
Tungsten |
| Niagara Refining LLC |
| UNITED STATES |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| VIET NAM |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| PHILIPPINES |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CHINA |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| VIET NAM |
Tungsten |
| Unecha Refractory metals plant |
| RUSSIAN FEDERATION |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| VIET NAM |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| AUSTRIA |
Tungsten |
| Woltech Korea Co., Ltd. |
| KOREA, REPUBLIC OF |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CHINA |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CHINA |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CHINA |
