Exhibit 1.01
ANALOGIC CORPORATION
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2016
Introduction
This Conflict Minerals Report of Analogic Corporation (herein referred to as “we”, “us”, “Analogic”, or the “Company”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2016 to December 31, 2016.
The term “conflict minerals” is defined in Section 13(p) of the Rule as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (“3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which tin, tantalum, tungsten or gold are necessary to the functionality or the production of the company’s products. For the purposes of this report, tin, tantalum, tungsten and gold will collectively be referred to herein as the 3TGs.
Company Overview
Analogic Corporation designs, manufactures, and commercializes innovative real-time guidance, diagnostic imaging and threat detection technologies to advance the practice of medicine and save lives. We operate and report along three business segments: Medical Imaging, Ultrasound and Security and Detection. Our Medical Imaging segment provides critical enabling medical imaging systems and subsystems for computed tomography, or CT, magnetic resonance imaging, or MRI and high-resolution digital mammography. We sell our Medical Imaging products primarily through longstanding relationships with well-known multinational medical original equipment manufacturers, or OEMs, and new entrants in emerging markets. Our Ultrasound business provides real-time ultrasound procedure guidance systems for the urology, surgery and point of care markets. We sell our ultrasound products, under the BK Ultrasound brand, through our direct sales force in North America and Europe, as well as through a network of distributors to clinical practitioners throughout the world. Our Security and Detection segment designs and manufactures automated threat detection systems for aviation baggage inspection applications utilizing advanced medical CT technology and systems used for DNA analysis for law enforcement and government agencies. We sell our aviation threat detection and DNA systems through multinational partners. We were incorporated in the Commonwealth of Massachusetts in November 1967 and are headquartered in Peabody, Massachusetts.
Products Covered by this Report
This report relates to products (i) for which conflict minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which manufacture was completed during calendar year 2016.
We evaluated our product lines to identify the Covered Products, as defined below. We also evaluated our purchased material categories to identify those purchased items that contain, or are reasonably likely to contain, conflict minerals.
These products (which we refer to as the “Covered Products”) consist of products in the areas of medical imaging, medical ultrasound, security technology, and motion control. Our medical imaging products comprise systems and subsystems used in computed tomography (“CT”), magnetic resonance imaging (“MRI”), and digital mammography. Our ultrasound products comprise medical ultrasound systems and probes. Our security technology products comprise threat detection systems for use in aviation security. Our motion control products comprise drives and controllers deployed in semiconductor, life sciences, automotive assembly, and other industries.
Our Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) regarding the 3TGs in our products to determine whether any of the 3TGs necessary to our products originated in the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (which we refer to herein as the “Covered Countries”) and whether any of the 3TGs were from recycled or scrap sources.
As part of our RCOI, we surveyed our principal suppliers of 3TGs in Covered Products using the Electronic Industry Citizenship Coalition (EICC) GESI Conflict Minerals reporting template (“CMRT”). This year we partnered with a third-party service provider, Assent Compliance (“Assent”) to assist us in reviewing our supply chain. We provided a list of suppliers associated with the Covered Products for Assent to upload into the Assent Compliance Manager Tool (the “ACM”). We contacted suppliers through the ACM, a SaaS platform provided by Assent that allows us to complete and track supplier communications and also allows suppliers to upload their completed CMRTs directly into the tool for review. Assent engaged in follow up communications with those suppliers that did not respond to the survey or that provided information that was incomplete as determined by Assent’s automated data validation. We then reviewed the survey responses to identify the facilities used to process, and the countries of origin of, the Covered Products. At the end of this process, the Company had received a response rate of reasonably acceptable and complete surveys from over 79% of its suppliers surveyed, compared to over 75% of suppliers surveyed the prior year.
We believe the inquiry was reasonably designed to determine whether any of the 3TGs in the Covered Products originated in a Covered Country. Annex A lists the smelters and refiners identified by our suppliers and Annex B lists the countries of origin identified by our suppliers.
Due Diligence Process
We conducted due diligence on the source and chain of custody of the 3TGs in our products, and are reporting on the results of that due diligence in this Conflict Minerals Report.
Design of Due Diligence
Our due diligence measures were designed to conform to 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, Third Edition (2016), including the related supplements on gold, tungsten, and tantalum (which we refer to as the OECD guidance), in all material respects.
Our Conflict Minerals program followed the following five-step framework described in the OECD guidance, including, as applicable, with regard to our due diligence process:
| • | Step 1 – Establish strong management systems; |
| • | Step 2 – Assess risk in the supply chain; |
| • | Step 3 – Design and implement a strategy to respond to identified risk; |
| • | Step 4 – Carry out independent third-party audit of supply chain; and |
| • | Step 5 – Report on supply chain due diligence. |
Due Diligence Performed
Step 1 – Establish strong management systems
Internal Team
In connection with our due diligence efforts, we established a management team that includes subject matter experts from relevant functions including operations, regulatory, finance and legal that is responsible for implementing our conflict minerals compliance strategy. Senior management was briefed on the results of our due diligence efforts on a regular basis.
As mentioned above, we also use Assent to assist us with evaluating supply chain information regarding 3TGs and in the development and implementation of the due diligence steps that we take with suppliers.
Control Systems
We also established a corporate policy emphasizing our commitment to compliance with the Rule, including our intention to conduct a reasonable country of origin inquiry and due diligence as required by the Rule. This corporate policy is available at our website, www.analogic.com/compliance.,
Supplier Engagement
Analogic strongly encourages our suppliers to implement responsible sourcing and to have them encourage smelters and refiners to obtain a ‘conflict-free’ designation from an independent, third-party auditor.
Grievance Mechanisms
We also maintain a mechanism through which concerns and questions about our conflict minerals policy and use (and other compliance concerns) may be raised. Such questions and concerns may be directed to +1 770-810-1147.
Maintain Records
Analogic retains all conflict minerals related materials received by its suppliers. In addition, all CMRTs collected from our suppliers are maintained in Assent’s database.
Step 2 – Assess risk in the supply chain
We do not purchase 3TGs directly from mines, smelters or refiners. We must therefore rely on our suppliers to provide information regarding the origin of 3TGs that are included in the Covered Products. We surveyed our principal suppliers of materials that include conflict minerals using the Electronic Industry Citizenship Coalition (EICC) GESI Conflict Minerals reporting template. Risks are identified automatically in the ACM based on criteria established for supplier responses in the CMRT form. The primary risk we identified for the 2016 reporting year was due to the fact that most of the responses received were provided at a company or divisional level. In some cases, our suppliers were unable to specify the smelters or refiners used for the 3TGs that they supply to us.
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. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the Conflict-Free Sourcing Initiative (“CFSI”) and, if a supplier indicated that the facility was certified as “Conflict-Free,” confirmed that the name was listed by CFSI. Due to the provision of primarily supplier-level CMRTs, we cannot definitively determine their connection to the Covered Products
Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
| 1. | Geographic proximity to the DRC and covered countries; |
| 2. | Conflict-Free Smelter Program (CFSP) audit status; |
| 3. | Known or plausible evidence of unethical or conflict sourcing. |
When any facilities that have been deemed to be high-risk based on the above noted criteria appear on a CMRT submitted by one of our suppliers, Assent immediately instructs the supplier to take risk mitigation actions, including submission of a product-level CMRT to better identify if there is a connection between the products they supply to us and the high-risk smelters or refiners. In addition, suppliers are guided to Assent University, a learning management system, where they have access to educational materials on mitigating the risk of smelters or refiners in the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
When suppliers meet or exceed those criteria (Yes to at least A, E, H, I), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
Step 3 – Design and implement a strategy to respond to identified risk
The design of our due diligence process conforms to Step 3 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. We provide our supply chain risk assessment to members of our senior management team and, to the extent that we can influence our direct suppliers to provide minerals from conflict-free smelters or refiners, we seek to do so.
Step 4 – Carry out independent third-party audit of supply chain
We do not have direct relationships with smelters or refiners and, accordingly, we do not perform direct audits of these entities in our supply chain. Rather, we rely on the efforts of industry associations that administer independent third-party smelter and refiner audit programs. In this regard, we relied on the CSFP listing of conflict-free compliant sources.
Step 5 - Report on supply chain due diligence
We have prepared and filed a Form SD and this Conflict Minerals Report, and posted the required content on our website at www.analogic.com/compliance.
Due Diligence Results
After conducting the due diligence described above, we have been unable to determine whether our necessary conflict minerals finance or otherwise benefit armed groups in the covered countries, as defined in the Rule.
Our efforts to determine the mine or location of origin of the necessary conflict minerals consisted of the due diligence measures described above in this report. Based on the information provided by our suppliers, we determined that some, but not all, of the smelters that processed the necessary conflict minerals were included in the CFSI CFSP listing of conflict-free compliant sources.
We surveyed all of our principal suppliers of the Covered Products and received responses from over 84% of suppliers surveyed, with over 79% of the responses being deemed reasonably acceptable and complete. All final CMRT submissions were reviewed and validated to ensure that no inaccuracies or gaps were found. Five suppliers were unable to correct their CMRT and as such are still listed as invalid submissions. identifying approximately 317 legitimate smelters or refiners (after elimination of duplicates) processing conflict minerals, of which approximately 246 have been designated conflict-free by the CFSI. Annex A lists these legitimate smelters and refiners. In addition, Annex B lists the countries of origin identified by our suppliers. Some suppliers did not respond to our survey request, and some returned incomplete responses. In addition, some of those suppliers that responded to our survey returned company-level rather than product-level information. Some of our suppliers indicated that the smelters used to process, or the country of origin of, the conflict minerals contained in products supplied by them are currently undetermined pending the receipt of additional information from their suppliers. Therefore, we are unable to identify with certainty all of the smelters used to process, or all of the countries of origin of, the necessary conflict minerals.
Efforts to Mitigate Risk
The Company has taken, or expects to take in reporting year 2017, the following steps, to mitigate the risk that the necessary conflict minerals contained in the Company’s products finance or benefit armed groups in the covered countries:
| 1) | Continuing to engage with our suppliers to obtain current, accurate and complete information about the supply chain relevant to 3TGs. |
| 2) | Strongly encouraging our direct suppliers to implement responsible sourcing and to have them encourage smelters and refiners to obtain a “conflict-free” designation from an independent, third-party auditor; and |
| 3) | Engaging in industry initiatives encouraging “conflict-free” supply chains. |
This Conflict Minerals Report contains forward-looking statements relating to actions that we may take in the future. The forward-looking statements included in this report release represent Analogic management’s views and expectations as of the date of this report. Analogic anticipates that subsequent events and developments may cause its views and expectations to change. Although Analogic may elect to update these forward-looking statements at some point in the future, it specifically disclaims any obligation to do so. These forward-looking statements should not be relied upon as representing Analogic’s views and expectations as of any date subsequent to the date of this report.
Annex A
Subject Mineral | Smelter or Refiner Facility Name | Country Location of Smelter or Refiner | Compliance (per CFSI) | |||
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Active | |||
| Gold | Advanced Chemical Company | UNITED STATES | Compliant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Compliant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Compliant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Enrolled | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant | |||
| Gold | AURA-II | UNITED STATES | Not Enrolled | |||
| Gold | Aurubis AG | GERMANY | Compliant | |||
| Gold | Bangalore Refinery | INDIA | Active | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
| Gold | Boliden AB | SWEDEN | Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
| Gold | Caridad | MEXICO | Not Enrolled | |||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant | |||
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Active | |||
| Gold | Chimet S.p.A. | ITALY | Compliant | |||
| Gold | Chugai Mining | JAPAN | Not Enrolled | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Enrolled | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not Enrolled | |||
| Gold | DODUCO GmbH | GERMANY | Compliant | |||
| Gold | Dowa | JAPAN | Compliant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant | |||
| Gold | Elemetal Refining, LLC | UNITED STATES | Compliant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Enrolled | |||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Geib Refining Corporation | UNITED STATES | Active |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not Enrolled | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Not Enrolled | |||
| Gold | Gujarat Gold Centre | INDIA | Not Enrolled | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Enrolled | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Compliant | |||
| Gold | Japan Mint | JAPAN | Compliant | |||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Compliant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not Enrolled | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Enrolled | |||
| Gold | Kazzinc | KAZAKHSTAN | Compliant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant | |||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Not Enrolled | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | L’Orfebre S.A. | ANDORRA | Not Enrolled | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Materion | UNITED STATES | Compliant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Compliant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant | |||
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Compliant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant | |||
| Gold | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled | |||
| Gold | Morris and Watson | NEW ZEALAND | Not Enrolled | |||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | Not Enrolled | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Compliant | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant | |||
| Gold | PAMP S.A. | SWITZERLAND | Compliant | |||
| Gold | Pease & Curren | UNITED STATES | Not Enrolled | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
| Gold | PX Précinox S.A. | SWITZERLAND | Compliant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant | |||
| Gold | Remondis Argentia B.V. | NETHERLANDS | Not Enrolled | |||
| Gold | Republic Metals Corporation | UNITED STATES | Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Compliant | |||
| Gold | SAAMP | FRANCE | Not Enrolled | |||
| Gold | Sabin Metal Corp. | UNITED STATES | Not Enrolled | |||
| Gold | SAFINA A.S. | CZECH REPUBLIC | Not Enrolled | |||
| Gold | Sai Refinery | INDIA | Not Enrolled | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant | |||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Enrolled | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant | |||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Compliant | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Enrolled |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | Not Enrolled | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant | |||
| Gold | Sudan Gold Refinery | SUDAN | Not Enrolled | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | Active | |||
| Gold | T.C.A S.p.A | ITALY | Compliant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Tony Goetz NV | BELGIUM | Active | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not Enrolled | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Compliant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Compliant | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant | |||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Not Enrolled | |||
| Gold | Valcambi S.A. | SWITZERLAND | Compliant | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Enrolled | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Compliant | |||
| Tantalum | Duoluoshan | CHINA | Compliant | |||
| Tantalum | Exotech Inc. | UNITED STATES | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Not Enrolled | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Compliant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Compliant | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Not Enrolled | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Compliant | |||
| Tantalum | Power Resources Ltd. | MACEDONIA | Compliant | |||
| Tantalum | QuantumClean | UNITED STATES | Compliant | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant | |||
| Tantalum | Taki Chemicals | JAPAN | Compliant | |||
| Tantalum | Telex Metals | UNITED STATES | Compliant | |||
| Tantalum | Tranzact, Inc. | UNITED STATES | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant | |||
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Compliant | |||
| Tin | Alpha | UNITED STATES | Compliant | |||
| Tin | An Thai Minerals Co., Ltd. | VIETNAM | Not Enrolled | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | Not Enrolled | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Compliant | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Enrolled | |||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant | |||
| Tin | CV Ayi Jaya | INDONESIA | Compliant | |||
| Tin | CV Dua Sekawan | INDONESIA | Compliant | |||
| Tin | CV Gita Pesona | INDONESIA | Compliant | |||
| Tin | CV Serumpun Sebalai | INDONESIA | Compliant | |||
| Tin | CV Tiga Sekawan | INDONESIA | Compliant | |||
| Tin | CV United Smelting | INDONESIA | Compliant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Compliant | |||
| Tin | Dowa | JAPAN | Compliant | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | Active | |||
| Tin | Elmet S.L.U. | SPAIN | Compliant | |||
| Tin | EM Vinto | BOLIVIA | Compliant | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | Not Enrolled | |||
| Tin | Fenix Metals | POLAND | Compliant | |||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Compliant | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Compliant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Enrolled | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Not Enrolled | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Compliant |
| Tin | Metallic Resources, Inc. | UNITED STATES | Compliant | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Compliant | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tin | Minsur | PERU | Compliant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | Not Enrolled | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant | |||
| Tin | Phoenix Metal Ltd. | RWANDA | Not Enrolled | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Compliant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Compliant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Compliant | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant | |||
| Tin | PT Bukit Timah | INDONESIA | Compliant | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Compliant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Compliant | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant | |||
| Tin | PT Inti Stania Prima | INDONESIA | Compliant | |||
| Tin | PT Justindo | INDONESIA | Not Enrolled | |||
| Tin | PT Karimun Mining | INDONESIA | Compliant | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Compliant | |||
| Tin | PT O.M. Indonesia | INDONESIA | Compliant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Compliant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Compliant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Compliant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Compliant | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Compliant | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant | |||
| Tin | PT Tommy Utama | INDONESIA | Compliant | |||
| Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
| Tin | Rui Da Hung | TAIWAN | Compliant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Compliant | |||
| Tin | Thaisarco | THAILAND | Compliant | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | Not Enrolled | |||
| Tin | VQB Mineral and Trading Group JSC | VIETNAM | Compliant | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active | |||
| Tin | Yunnan Tin Company Limited | CHINA | Compliant | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Not Enrolled | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Compliant | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Not Enrolled | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not Enrolled | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Compliant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not Enrolled | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Kennametal Fallon | UNITED STATES | Compliant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES | Compliant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES | Compliant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Compliant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Compliant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Compliant | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
Annex B
The list below sets out possible countries of origin of 3TGs used in the manufacture of our products containing 3TGs. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. However, for the reasons described in the CMR, these possible countries of origin cannot be linked to our products with reasonable certainty.
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.
