Exhibit 1.01
Spartan Motors, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2017
This report for the calendar year ended December 31, 2017, is presented to pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain tantalum, tin, tungsten or gold, which are necessary to the functionality or production of their products. The term "Conflict Minerals" is defined as columbite-tantalite (coltan), cassiterite, gold, wolframite, tantalum, tin, tungsten, and any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo (DRC) or an adjoining country. The term "3TG" is defined as tantalum, tin, tungsten and gold and their compounds.
If a registrant can establish that the 3TG in their supply chain originated from sources other than the Democratic Republic of the Congo or an adjoining country, as defined by the SEC (the "Covered Countries"), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry ("RCOI") that the registrant completed.
If a registrant has reason to believe that any of the 3TG in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those conflict minerals, then the issuer must exercise due diligence on the conflict minerals' source and chain of custody. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures.
Company Overview
Spartan Motors, Inc. is a leading, niche market engineer and manufacturer in the heavy-duty, custom vehicles marketplace. Our operating activities are conducted through our wholly owned operating subsidiary, Spartan Motors USA, Inc. (“Spartan USA”), with locations in Charlotte, Michigan; Brandon, South Dakota; Ephrata, Pennsylvania; Bristol, Indiana; Snyder and Neligh, Nebraska; Delavan, Wisconsin; Kansas City, Missouri; and Saltillo, Mexico. Spartan USA was formerly known as Crimson Fire, Inc.
Our Charlotte, Michigan location manufactures heavy duty chassis and vehicles and supplies aftermarket parts and assemblies under the Spartan Chassis and Spartan brand names. Our Brandon, South Dakota, Snyder and Neligh, Nebraska, Delavan, Wisconsin and Ephrata, Pennsylvania locations manufacture emergency response vehicles under the Spartan and Smeal brand names. Our Bristol Indiana location manufactures delivery and service vehicles and supplies related aftermarket parts and services under the Utilimaster brand name, while our Kansas City, Missouri and Saltillo, Mexico locations sell and install equipment used in delivery vehicles.
Conflict Minerals Policy
Spartan Motors and its subsidiaries endeavor to maintain the highest standards of ethical conduct and integrity in all areas of their business activities.
On August 22, 2012, the U.S. Securities and Exchange Commission adopted final rules to implement reporting and disclosure requirements related to "conflict minerals," as directed by the Dodd-Frank.
We are committed to working closely with our supply chain to ensure we fully comply with the requirements set forth in Section 1502 of the Dodd-Frank Act. We have implemented the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and are utilizing the conflict minerals reporting template (CMRT) owned by the Conflict Free Sourcing Initiative (CFSI), for exercising due diligence within our supply chain.
We do not knowingly source any product containing Conflict Minerals and we continue work on our due diligence process in order to verify that the components we source do not contain Conflict Minerals. We have requested that our suppliers commit to responsible sourcing of 3TG used in the production of components supplied to us. We expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing 3TG are DRC conflict free. Our suppliers will be requested to perform due diligence to determine the source of any 3TG that are contained in the components that they supply to us. Our suppliers due diligence must include, where applicable, completion of the CFSI Conflict Minerals reporting CMRT.
Our conflict minerals policy is posted on our website at http://www.spartanmotors.com/about-us/supplier-info/
RCOI & Due Diligence
Our due diligence measures have been designed to conform with the framework from the 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").
Supply Chain
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower tier suppliers. We have requested that our suppliers commit to responsible sourcing of conflict minerals used in the production of components supplied to us. Our suppliers have been requested to perform due diligence to determine the source of any conflict minerals that are contained in the components that they supply to us. Our suppliers' due diligence must include, where applicable, completion of the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a company's conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSI's website.
For the 2017 reporting year, all of our relevant suppliers were asked to complete the CMRT. This is a requirement set forth in all of our supplier contract agreements.
Due Diligence Process
We reviewed the components that are included in the specialty vehicles and chassis that we manufacture that could contain 3TG that is necessary to the functionality or production of our products. Our due diligence measures have been designed to conform with the framework in the OECD Guidance.
Step One: Establish Strong Company Management Systems
Internal Team
At our corporate level, we have a cross functional team and a third-party consulting subject matter expert working collaboratively to administer our program. This team is responsible for the corporate conflict minerals policy and providing support and instructions on the due diligence measures required to be followed for each of our divisions.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have continued with our training program for our suppliers for the 2017 reporting by developing an instructional document that was provided to all of our suppliers. We will encourage our suppliers to share this information throughout the whole supply chain, all the way to the smelter level. Suppliers will continue to receive education and support from our business unit champions during the RCOI process and on an annual basis.
We have a robust supplier management plan for new and existing suppliers for Conflict Minerals. Existing suppliers must comply with Spartan’s quality manual and Spartan Terms and Conditions which includes Conflict Minerals reporting requirements. In addition, we provide annual education materials, supplier CMRT invitations and utilize a third-party software & consulting Conflict Minerals platform. Internal supplier management processes have also been updated to ensure supplier conformance and communication that include Conflict Minerals reporting requirements when a new supplier is selected. As part of the supplier approval process, new suppliers, unless exempt from Conflict Minerals reporting requirements, must provide a completed CMRT prior to being approved as a Spartan Motors supplier.
Spartan Motors provides education materials for suppliers on an annual basis to assist them with their conflict minerals reporting compliance. Compliance with all the criteria is dictated in the contract for all Spartan Motors suppliers.
Grievance Mechanism
Our website (http://www.spartanmotors.com/about-us/supplier-info/) contains a link to our conflict minerals policy page. Included with our conflict minerals policy on our website is a link that can be utilized to contact our Compliance Officer with concerns regarding our conflict minerals policy or our use of conflict minerals. It is the policy of Spartan Motors that any communications regarding our Code of Business Conduct and Compliance or Conflict Minerals received by our Chief Compliance Officer is submitted for review to our Board of Directors.
Step Two: Identify and Assess Risk in the Supply Chain
All of our relevant suppliers were identified for inclusion in our 2017 RCOI. We rely on these suppliers, whose components we believe may contain 3TG, to provide us with information about the source of Conflict Minerals, if any, contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.
We will assess risk by reviewing the suppliers' answers provided in the CMRT for risk indicators that are identified though our third-party Conflict Minerals platform. Risk indicators identified from the CMRT reports are then communicated back to our suppliers for awareness and continuous improvement for future Conflict Minerals reporting requirements.
Step Three: Design and Implement a Strategy to Respond to Risks
Relevant suppliers are mandated to provide a CMRT for each reporting year. Supplier CMRTs are evaluated against a set list of data quality standards. Any discrepancies identified are logged in an online tool and sent back to the supplier for further investigation and corrective action.
Step Four: Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
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. We do track all smelters that have been audited via the Conflict Free Sourcing Initiative ("CFSI").
Step Five: Report on Supply Chain Due Diligence
We conducted a survey of those suppliers described above using the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a company's conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT contains questions about the origin of 3TG included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on CFSI's website. The CMRT is being used by many companies in their due diligence processes related to conflict minerals.
It is our goal to continue to work with our suppliers to educate them on all the requirements so that we can have a marked improvement in response rate. For the 2017 reporting year, we received responses from 22 percent of all the suppliers surveyed. The 2017 data collected included the names of 211 entities listed by our suppliers as smelters or refiners. 160 of these entities were identified as validated to be Conflict-Free by the CFSI. We compared these facilities to the CFSI list of smelters and where a supplier indicated that the facility was certified as Conflict-Free, we ensured that the name was listed by CFSI.
The large majority of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used. We are unable to determine whether any of the 3TG reported by our suppliers were contained in components or parts supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. Requesting that our suppliers complete the CMRT regarding information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
We are committed to this process and will continue to implement and improve our conflict minerals due diligence program. Based on the information obtained pursuant to our RCOI and the due diligence process, we do not have sufficient information to determine the country of origin of the 3TG used in our products.
Based on the information that was provided by the responding suppliers and otherwise obtained through our due diligence process; below is the list of smelters and refiners that were provided by our supply chain. Since reporting was completed at a company level we are not able to determine with certainty that these are used in our supply chain.
Smelter Look-up (*) | Smelter Country (*) | Smelter Identification |
Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Al Etihad Gold LLC | UNITED ARAB EMIRATES | CID002560 |
Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
Asahi Pretec Corp. | JAPAN | CID000082 |
Asahi Refining Canada Ltd. | CANADA | CID000924 |
Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
AU Traders and Refiners | SOUTH AFRICA | CID002850 |
Aurubis AG | GERMANY | CID000113 |
Bangalore Refinery | INDIA | CID002863 |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
Boliden AB | SWEDEN | CID000157 |
C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
Caridad | MEXICO | CID000180 |
CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Chimet S.p.A. | ITALY | CID000233 |
Chugai Mining | JAPAN | CID000264 |
Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
Dowa | JAPAN | CID000401 |
DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
Elemetal Refining, LLC | UNITED STATES OF AMERICA | CID001322 |
Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
Guangdong Jinding Gold Limited | CHINA | CID002312 |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Heimerle + Meule GmbH | GERMANY | CID000694 |
Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Istanbul Gold Refinery | TURKEY | CID000814 |
Italpreziosi | ITALY | CID002765 |
Japan Mint | JAPAN | CID000823 |
Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
Kazzinc | KAZAKHSTAN | CID000957 |
Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
Lingbao Gold Co., Ltd. | CHINA | CID001056 |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
L'Orfebre S.A. | ANDORRA | CID002762 |
LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Marsam Metals | BRAZIL | CID002606 |
Materion | UNITED STATES OF AMERICA | CID001113 |
Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
Mitsubishi Materials Corporation | JAPAN | CID001188 |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
Modeltech Sdn Bhd | MALAYSIA | CID002857 |
Morris and Watson | NEW ZEALAND | CID002282 |
Morris and Watson Gold Coast | AUSTRALIA | CID002866 |
Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
Nihon Material Co., Ltd. | JAPAN | CID001259 |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
PAMP S.A. | SWITZERLAND | CID001352 |
Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
Planta Recuperadora de Metales SpA | CHILE | CID002919 |
Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
Asaka Riken Co., Ltd. | JAPAN | CID000092 |
Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Duoluoshan | CHINA | CID000410 |
Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
F&X Electro-Materials Ltd. | CHINA | CID000460 |
FIR Metals & Resource Ltd. | CHINA | CID002505 |
Global Advanced Metals Aizu | JAPAN | CID002558 |
Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
H.C. Starck Co., Ltd. | THAILAND | CID002544 |
H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
H.C. Starck Ltd. | JAPAN | CID002549 |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
KEMET Blue Metals | MEXICO | CID002539 |
KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
LSM Brasil S.A. | BRAZIL | CID001076 |
Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
Mineracao Taboca S.A. | BRAZIL | CID001175 |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
NPM Silmet AS | ESTONIA | CID001200 |
Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
Alpha | UNITED STATES OF AMERICA | CID000292 |
An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
China Tin Group Co., Ltd. | CHINA | CID001070 |
CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 |
CV Ayi Jaya | INDONESIA | CID002570 |
CV Dua Sekawan | INDONESIA | CID002592 |
CV Gita Pesona | INDONESIA | CID000306 |
CV United Smelting | INDONESIA | CID000315 |
CV Venus Inti Perkasa | INDONESIA | CID002455 |
Dowa | JAPAN | CID000402 |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
Estanho de Rondonia S.A. | BRAZIL | CID000448 |
Fenix Metals | POLAND | CID000468 |
Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
Gejiu Jinye Mineral Company | CHINA | CID002859 |
Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 |
Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
Metallo Belgium N.V. | BELGIUM | CID002773 |
Metallo Spain S.L.U. | SPAIN | CID002774 |
Mineracao Taboca S.A. | BRAZIL | CID001173 |
Minsur | PERU | CID001182 |
Mitsubishi Materials Corporation | JAPAN | CID001191 |
Modeltech Sdn Bhd | MALAYSIA | CID002858 |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
ACL Metais Eireli | BRAZIL | CID002833 |
Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 |
Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 |
Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 |
Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Our efforts to determine the mine or location of origin of the 3TG used in our products consisted of the due diligence measures described in this report. In particular, because independent third party audit programs validate whether sufficient evidence exists regarding country, mine and/or location of origin of the 3TG that the audited smelter or refiner facilities have processed, we relied on the information made available by such programs for the smelters and refiners in our supply chain. We were unable to ascertain the country of origin and/or chain of custody of all necessary 3TG processed by these facilities because, for this reporting period.
2017 Improvement Review
Supplier education is a priority for Spartan Motors. We are committed to continuing to educate and support our suppliers and internal staff.
Planned Steps to Improve Due Diligence
We intend to take the following steps to improve our due diligence program:
1. | Continue to work with suppliers to collect a complete list of smelters within Spartan Motor’s supply chain by providing direction to reference the CFSI list of smelters when completing their CMRT report. |
2. | Provide education materials to suppliers annually that include instructions and any updates when completing their CMRT reports. |
3. | Review more efficient ways to accept and review excel version of CMRT |
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