Exhibit 1.01
MOOG INC.
Conflict Minerals Report
For the reporting period from January 1, 2019 to December 31, 2019
This Conflict Minerals Report of Moog Inc. (“Moog”) has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period referenced above.
In August 2012, the Securities and Exchange Commission ("SEC") adopted the Rule 13p-1 pursuant to the mandate of Section 1502 of the Wall Street Reform and Consumer Protection Act. This rule requires all U.S. publicly traded companies that manufacture, or contract to manufacture, products to annually disclose whether columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives of tantalum, tin and tungsten (“conflict minerals”) are necessary to the functionality or production of these products and whether the conflict minerals 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 (the “covered countries”). These products, which may include conflict minerals, are referred to in this report collectively as the "covered products" and listed below under the heading "Covered Products." As a result, Moog designed due diligence procedures in order to gather and report this required information.
This Report has not been subject to an independent private sector audit as allowed under Rule 13p-1, which provides a temporary accommodation for the first two reporting periods following November 13, 2012 and extended for the current reporting period based on the U.S. Court of Appeals for the D.C. Circuit ruling dated August 18, 2015.
Executive Summary
Moog performed a Reasonable Country of Origin Inquiry (RCOI) on suppliers believed to provide Moog with materials or components containing 3TGs necessary to the manufacturing of Moog’s products. Moog’s suppliers identified 303 valid smelters and refineries (“smelters”). Of these 303 smelters, Moog identified 41 as sourcing (or there was a reason to believe they may be sourcing) from the DRC or adjoining countries (collectively called the ‘Covered Countries’). Moog’s due diligence review indicated that 33 of these smelters have been audited and recognized as conflict free by the Responsible Minerals Assurance Process (“RMAP”). The remaining 8 smelters sourcing from the Covered Countries were subject to Moog’s risk mitigation process according to the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas (OECD Due Diligence Guidance). Moog has a complex supply chain that does not source conflict minerals directly from mines, smelters or refiners. In turn, Moog relies on supplier information regarding sourcing of materials, and works with these suppliers to identify, where possible, the smelters and/or refiners and countries of origin for conflict minerals.
Company Management Systems
Moog established management systems according to Step 1 of the OECD Due Diligence Guidance. Moog’s systems included:
Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas.
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• | Implemented a conflict minerals policy. |
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• | Policy made publicly available. |
https://www.moog.com/investors/corporate-governance-guidelines/policy-statement---regarding-conflict-minerals.html
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• | Policy communicated directly to suppliers as part of RCOI process. |
Step 1B - Structure internal management to support supply chain due diligence.
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• | Maintained an internal cross functional team to support supply chain due diligence. |
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• | Appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence. |
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• | Applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support. |
Step 1C - Establish a system of transparency, information collection and control over the supply chain.
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• | Implemented a process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report. |
Step 1D - Strengthen company engagement with suppliers.
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• | Directly engaged suppliers during RCOI process. |
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• | Reviewed supplier responses as part of RCOI process. |
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• | Added conflict minerals compliance to new supplier contracts and Moog’s supplier code of conduct. |
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• | Implemented a plan to improve the quantity and quality of supplier and smelter responses year over year. |
Step 1E - Establish a company and/or mine level grievance mechanism.
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• | Recognized the RMAP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances. |
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• | Moog’s ethics violations reporting system allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Moog’s conflict minerals policy. |
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• | Moog’s internal policy and procedure outlines the issuance of requests for corrective action of suppliers in order to remove non-conformant and/or high-risk smelters from the supply chain. |
Reasonable Country of Origin Inquiry (RCOI)
Moog designed its RCOI process in accordance with Step 2A and 2B of the OECD Due Diligence Guidance. Moog’s RCOI process involved two stages:
Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance)
Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance)
Supplier RCOI
Moog designed its supplier RCOI process to identify, to the best of Moog’s efforts, the smelters in Moog’s supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Moog’s supplier RCOI process for the 2019 reporting period included the following:
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• | Developing a list of suppliers providing 3TG containing components to Moog. |
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• | Contacting each supplier and requesting the industry standard Conflict Minerals Reporting Template (“CMRT”) including smelter information. |
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• | Reviewing supplier responses for accuracy and completeness. |
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• | Amalgamating supplier provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols. |
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• | Reviewing the final smelter list (and compared it to industry peers) to determine if Moog identified reasonably all of the smelters in their supply chain. |
For the 2019 reporting period, Moog’s RCOI process was executed by Claigan Environmental Inc. (“Claigan”). The design of Claigan’s process was independently audited in 2015 against the requirements of Step 2 of the OECD Due Diligence Guidance.
With a 90% response rate, Moog’s suppliers identified 303 smelters within their supply chain. The specific list of smelters is included in the Smelter and Refineries section at the end of this report.
Smelter RCOI
Due to the overlap between supplier RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.
Due Diligence
Moog’s Due Diligence Process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance.
Smelter RCOI and Due Diligence
Moog’s smelter RCOI and due diligence process were designed to:
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• | Identify the scope of the risk assessment of the mineral supply chain (OECD Step 2B). |
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• | Assess whether the smelters/refiners have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Step 2C). |
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• | Where necessary, carry out, including through participation in industry-driven programs, joint spot checks at the mineral smelter/refiner’s own facilities (OECD Step 2D). |
Moog’s smelter RCOI and Due Diligence Process included the following:
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• | For each smelter identified in Moog’s supply chain: |
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• | Direct engagement attempted of the smelter to obtain whether or not the smelter sources from the DRC or surrounding countries. |
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• | For smelters that declared directly or through their relevant industry association that they did not source from the DRC or surrounding countries, and were not recognized as conflict free by the RMAP, Moog reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration. The sources reviewed included: |
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• | Public internet search (Google) of the facility in combination with each of the covered countries |
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• | Review of specific NGO publications. NGO publications reviewed included: |
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• | Southern Africa Resource Watch |
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• | The most recent UN Group of Experts report on the DRC. |
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• | For smelters that did not respond to direct engagement, Moog reviewed publicly available sources to determine if there was ‘any reason to believe’ that the smelter may have sourced from the Covered Countries during the reporting period. |
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• | Moog reviewed the same sources as those used to compare against smelter sourcing declarations. |
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• | For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Moog requires the smelter be audited and recognized as conflict free by the RMAP. |
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• | For high risk smelters that have not been audited and recognized as conflict free by the RMAP, Moog communicates the risk to a designated member of senior management (OECD Step 3A) and conducts risk mitigation on the smelter according to OECD Step 3B. |
For the 2019 reporting period, Moog’s smelter RCOI and Due Diligence process was executed by Claigan Environmental Inc. (Claigan). Claigan was independently audited in 2015 against the requirements of Step 2 of the OECD Due Diligence Guidance.
Moog’s suppliers identified 303 smelters. Moog identified 41 smelters that source, or there is a reason to believe they source, from the Covered Countries.
Moog determined that 33 of these 41 smelters have been audited and recognized as conflict free by the RMAP. Moog conducted risk mitigation on the remaining 8 smelters.
Risk Mitigation
Moog conducted risk mitigation on 8 smelters that were not recognized as conflict free by the RMAP and were sourcing from the DRC or surrounding countries. Moog’s risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance. Moog’s risk mitigation process included the following:
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• | Additional due diligence to determine if there was any reason to believe the smelter directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. |
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• | Verifying with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Moog’s supply chain in the 2019 reporting period. |
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• | Direct engagement with each high risk smelter to verify risk and to encourage the smelter to become conflict free. |
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• | Additional inquiry into each supplier as to whether or not the materials provided to Moog contain 3TGs from the named smelter. |
Moog did not require the removal of smelters subject to Moog’s risk mitigation process if there was no reason to believe they were directly or indirectly financing or benefiting armed groups in the DRC or adjoining countries. These smelters are scheduled to be re-visited in the 2020 reporting period. This process is consistent with Step 3B of the OECD Due Diligence Guidance and helps prevent unnecessary boycotts of the DRC or adjoining countries.
Risk mitigation was required for 9 smelters verified by suppliers potentially to be in Moog’s supply chain.
Gold Smelter – African Gold Refinery
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• | Reports published in 2018 allege that African Gold Refinery is linked to gold smuggled from the DRC. AGR denies these allegations and are seeking 3rd party confirmation of their sourcing practices. |
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• | AGR has been connected to smuggled gold from the DRC in the past and has never been transparent about its supply chain. This is reiterated in the 2019 UN Group of Experts Report on the DRC which states AGR is still refusing to convey supplier information. |
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• | African Gold Refinery was identified on 95 supplier CMRTs, 9 of 95 have declared no known impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Dijllah Gold Refinery
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• | Moog does not currently have a reason to believe that Dijlah Gold Refinery is benefiting or financing the armed groups in the covered countries. |
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• | Dijilah Gold Refinery was identified on 83 supplier CMRT. 9 of 83 have declared no known impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Fidelity Printers and Refiners Ltd.
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• | Moog does not currently have a reason to believe that Fidelity Printers and Refiners Ltd. is benefiting or financing the armed groups in the covered countries. |
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• | Fidelity Printers and Refiners Ltd. was identified on 98 supplier CMRTs, 9 of 98 have declared no known impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Fujairah Gold FZC
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• | Moog does not currently have a reason to believe that Fujairah Gold FZC is benefiting or financing the armed groups in the covered countries. |
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• | Fujairah Gold FZC was identified on 74 supplier CMRT. 9 of 74 suppliers have declared they cannot determine the impact to Moog. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – International Precious Metal Refiners
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• | Moog does not currently have a reason to believe that International Precious Metals Refiners is benefiting or financing the armed groups in the covered countries. |
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• | International Precious Metal Refiners was identified on 83 supplier CMRT. 9 of 83 suppliers have declared they cannot determine the impact to Moog. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Kaloti Precious Metals
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• | Moog does not currently have a reason to believe that Kaloti Precious Metals is benefiting or financing the armed groups in the covered countries. |
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• | Kaloti Precious Metals was identified on 103 supplier CMRTs, of 9 of 103 have declared no impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Sudan Gold Refinery
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• | Moog does not currently have a reason to believe that Sudan Gold Refinery is benefiting or financing the armed groups in the covered countries. |
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• | Sudan Gold Refinery was identified on 99 supplier CMRTs, of 9 of 99 have declared no known impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Gold Smelter – Tony Goetz NV
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• | Moog does not currently have a reason to believe that Tony Goetz NV is benefiting or financing the armed groups in the covered countries. |
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• | Tony Goetz NV was identified on 104 supplier CMRTs, of 9 of 104 have declared no known impact to Moog, the remaining suppliers have not responded. |
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• | At this time, this smelter has no known impact to Moog. |
Improvement Plan
Moog is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary conflict minerals in Moog’s products could directly or indirectly benefit or finance armed groups in the covered countries:
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a. | Including a conflict minerals clause in all new and renewing supplier contracts. |
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b. | Continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain. |
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c. | Engaging smelters sourcing from the covered countries to become audited and certified to a protocol recognized by the RMAP. |
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d. | Follow up in 2020 on smelters requiring risk mitigation, but not removal from Moog’s supply chain. |
e. Continue to provide further training and awareness of the Conflict Minerals Program to Supply Chain Managers across the organization to greater enhance due diligence efforts.
Smelters and Refineries
Below are the smelters reported to Moog as likely in Moog’s supply chain in the 2019 reporting period.
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Metal | Smelter Name | Smelter Country |
Gold | 8853 S.p.A. | ITALY |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | African Gold Refinery | UGANDA |
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 OF AMERICA |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | AU Traders and Refiners | SOUTH AFRICA |
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 | CGR Metalloys Pvt Ltd. | INDIA |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Smelter not listed | JAPAN |
Gold | Smelter not listed | JAPAN |
Gold | Smelter not listed | JAPAN |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
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Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
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 | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Smelter not listed | CHINA |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
Gold | HwaSeong CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Italpreziosi | ITALY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | 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 OF AMERICA |
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 | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | L'Orfebre S.A. | ANDORRA |
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 | Marsam Metals | BRAZIL |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
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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 OF AMERICA |
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 | NH Recytech Company | KOREA, REPUBLIC OF |
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 | PAMP S.A. | SWITZERLAND |
Gold | Pease & Curren | UNITED STATES OF AMERICA |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Planta Recuperadora de Metales SpA | CHILE |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox S.A. | SWITZERLAND |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
Gold | REMONDIS PMR B.V. | NETHERLANDS |
Gold | Royal Canadian Mint | CANADA |
Gold | SAAMP | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
Gold | Safimet S.p.A | ITALY |
Gold | SAFINA A.S. | CZECHIA |
Gold | Sai Refinery | INDIA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | SEMPSA Joyería Platería S.A. | SPAIN |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
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Gold | Smelter not listed | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Sovereign Metals | INDIA |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | Sudan Gold Refinery | SUDAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Smelter not listed | TAIWAN, PROVINCE OF CHINA |
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 OF AMERICA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Yamakin Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Smelter not listed | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
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 OF AMERICA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
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Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
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 OF AMERICA |
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 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
Tin | Dowa | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Fenix Metals | POLAND |
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Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
Tin | Gejiu Fengming Metallurgy Chemical Plant | 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 | Guangdong Hanhe Non-Ferrous Metal 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 New Nanshan Technology Ltd. | CHINA |
Tin | Ma'anshan Weitai Tin 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 OF AMERICA |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
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 Metalúrgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | Precious Minerals and Smelting Limited | INDIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Timah Tbk Kundur | INDONESIA |
Tin | PT Timah Tbk Mentok | INDONESIA |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Super Ligas | BRAZIL |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM |
Tin | Thaisarco | THAILAND |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
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Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Smelter not listed | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | China Molybdenum Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Haichuang 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 | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH | 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 | Hunan Litian Tungsten Industry 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 Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
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Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Unecha Refractory Metals Plant | RUSSIAN FEDERATION |
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 |
Forty-one of the smelters above declared to be sourcing or there was reason to believe are sourcing from the covered countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the covered countries and there is no requirement to identify the specific covered country by the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified covered countries are The Democratic Republic of the Congo, Rwanda, Burundi, Uganda, and Tanzania.
Product Descriptions
For the reporting period of this Conflict Minerals Report, our manufactured products by segment are as follows:
Aircraft Controls
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• | Aircraft Actuation Systems |
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• | Flight Control Actuation |
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• | Engine Control Actuation |
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• | Permanent Magnet Alternators |
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• | Aircraft Flight Controllers and Software |
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• | Aircraft Engine Controls Valves |
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• | Tactical Air Navigation (TACAN) |
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• | Distance Measuring Equipment (DME) |
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• | Doppler VHF Omni-Directional Range (DVOR) |
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• | Non-Directional Beacon (NDB) |
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• | Aerospace/Military Resolvers |
Space and Defense Controls
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• | Gun Aiming Actuation and Controls |
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• | Vibration Control Actuation |
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• | Military Ground Vehicle Actuation |
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• | Military Ground Vehicle Electronics |
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• | Spacecraft Mechanical Actuators |
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• | Test Controllers and Software |
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• | Space Platform Electronics |
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• | Launch Vehicles Propulsion Controls |
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• | Propulsion Controls for Spacecraft |
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• | Propulsion Controls for Tactical Missiles |
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• | ESPA: EELV Secondary Payload Adapter |
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• | Softride Vibration Isolation Devices |
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• | Commercial Surveillance Systems |
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• | Industrial Surveillance Systems |
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• | Military Surveillance Systems |
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• | Apogee/Upper Stage Thrusters |
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• | Monopropellant Thrusters |
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• | Active Vibration Control Systems |
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• | Tuned Dampers and Absorbers |
Industrial Systems
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• | Industrial Actuation Systems |
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• | Electric Linear Servoactuation Packages |
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• | Hydraulic Servo Actuators |
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• | 2 and 3-way Servo Cartridge Valves |
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• | 2-way Proportional Cartridge Valves |
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• | Industrial Controllers and Software |
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• | Servovalves and Servo-Proportional Valves |
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• | Ball Screws and Planetary Roller Screws |
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• | Programmable Single-Axis Servo Drive |
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• | Wind Turbine Controls and Actuation |
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• | Electric Simulation Table |
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• | Hydraulic Simulation Table |
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• | Haptic Rehabilitation Unit |
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• | Electric Linear Control Load Actuators |
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• | Electric Rotary Control Loader Actuators |
Components
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• | Fiber Optic Rotary Joints |
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• | Fluid Rotary Union - Model 70 |
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• | Rigid and Flexible Circuit Boards |
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• | Rotary Variable Differential Transformers (RVDT) |
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• | Industrial and Medical Solenoids |
Medical Devices
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• | Post-Operative Pain Management Pumps |
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• | Pump Administration Sets |
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• | Ultrasonic Air Bubble Detectors |
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• | Ultrasonic Level Sensors |
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• | Optical Blood Leak Detectors |