Exhibit 1.01
Multi-Fineline Electronix, Inc.
Conflict Minerals Report
for the Year Ended December 31, 2015
Conflict Minerals Report
| I. | Introduction |
Multi-Fineline Electronix, Inc. (“MFLEX” or “we,” “our” or “us”) is a global manufacturer and assembler of flexible printed circuit boards and assemblies. Certain of the products that we manufacture or contract to manufacture contain materials or components containing tin, tantalum, tungsten and/or gold (“3TG”) that are necessary to the functionality of those products.
As a result, we are obligated to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). If a company is subject to the Rule, the company must generally investigate the origin of the 3TG in its products. If it appears the company’s 3TG may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and is not from scrap or recycled sources, the company must then exercise due diligence over the source and chain of custody of such 3TG and disclose certain information about its due diligence efforts in this separate Conflict Minerals Report.
Due to the depth of our supply chain, MFLEX is far removed from the sources of ore from which these 3TG are produced and the smelters/refiners that process those ores; our efforts undertaken to identify the country(ies) or origin of those ores as described in this Conflict Minerals Report reflect our circumstances and position in the supply chain. We believe the amount of information that is available globally on the traceability and sourcing of these ores remains limited at this time. We also believe this situation is not unique to MFLEX.
Our efforts to comply with the Rule were undertaken on the products manufactured directly by MFLEX as well as those manufactured for MFLEX by third parties in 2015.
| II. | Reasonable Country of Origin Inquiry |
MFLEX understands that there are many layers between itself and a smelter or refiner. The number of tiers depends on the components provided to us by our suppliers. We continue to make efforts to fully understand our supply chain and our relationships to the smelters, refiners and countries of origin of our 3TG. Therefore, it is inherently difficult to ascertain the ultimate source of 3TG contained in the products we manufacture or contract to manufacture.
We rely on our direct suppliers to provide information on the origin of 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower-tier suppliers. We asked our direct suppliers to provide answers to the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (the “Template”) to reflect MFLEX’s position on the supply chain. The Template is generally regarded as the most common reporting tool for conflict minerals content and sourcing information worldwide.
We reviewed the responses to the questionnaires that we received from our direct suppliers both for completeness and internal consistency of the responses contained in each questionnaire. Where necessary, we required our suppliers to provide corrections and clarifications to correct any internal inconsistencies in the responses contained in their respective questionnaires. For non-responsive suppliers, we made multiple follow-up requests by telephone and email.
Overall, we ultimately received responses from 99% of the 334 direct suppliers that we identified as being within the scope of our reasonable country of origin inquiry. As such, we believe our reasonable country of origin inquiry and process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate and confirm the information.
After reviewing the results of our reasonable country of origin inquiry, we determined that we had reason to believe that some of the 3TG necessary for the functionality or production of our products may have originated in a Covered Country during calendar year 2015, all within the meaning of the Rule. Therefore, we determined that the Rule required that we exercise due diligence on the source and chain of custody of such 3TG. We also identified scrap and recycled minerals as sources of materials in our supply chain.
| III. | Design of Due Diligence Framework |
We designed our overall conflict minerals due diligence framework to conform in all material respects with theOECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (the “Guidance”).
| IV. | Due Diligence Measures Performed by MFLEX |
The following are due diligence measures that were performed by MFLEX on the source and chain of custody of the necessary 3TG contained in our products that we had reason to believe may have originated from the Covered Countries:
| • | Reported to senior management on direct suppliers’ responses to our conflict minerals information requests, including updates on monitoring and tracking corrective action and risk mitigation efforts (where applicable). |
| • | Maintained a company policy on Conflict Minerals (our “Conflict Minerals Policy”), which can be located on our website at http://www.mflex.com/Content/PDF/Conflict%20Minerals%20Policy.pdf, and communicated our Conflict Minerals Policy to our direct suppliers. |
| • | Communicated the commitments and requirements expected of MFLEX suppliers via our Supplier Code of Conduct, supported by email and phone dialogues. |
| • | Through a third-party service provider, compared smelters and refiners identified by the supply chain survey against the U.S. Department of Commerce’s list of all known mineral processing facilities worldwide, published in September 2014, current (as of April 2016) lists of smelters and refiners certified as conflict-free by the Conflict-Free Sourcing Initiative, the London Bullion Market Association and the Responsible Jewellery Council and independent research performed by the third-party service provider. |
| • | Supported the development and implementation of independent third-party audits of smelters’ and refiners’ sourcing through our policy and procurement practices that encourage suppliers to purchase materials from audited smelters or refiners. |
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| • | Pursued risk mitigation efforts for a limited number of our direct suppliers who have indicated that a portion of the 3TG originated from sources in the Covered Countries not verified as conflict free. |
| V. | Due Diligence Results |
Our due diligence results are inherently limited. As a downstream purchaser of 3TG, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary 3TG. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary 3TG. We also rely, to a large extent, on information collected and provided by independent third-party audit programs such as the Conflict-Free Sourcing Initiative. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
We received inconclusive information from some of our direct suppliers. We also received information from a number of our direct suppliers indicating that some of the 3TG originated from verified conflict-free sources in the Covered Countries. In addition, one of our direct suppliers reported sourcing a portion of its 3TG from a smelter that obtains its ore from sources in the Covered Countries not verified as conflict free. Upon conducting further due diligence, however, we determined that the smelter in question suspended operations prior to 2015, and we do not reasonably believe 3TG from that smelter to have been present in our supply chain in 2015. Overall, sourcing information about our products in their entirety is not yet available. However, after reviewing the results of our due diligence, we did not find evidence to suggest that any of the 3TG in our supply chain funded or benefited armed groups in the Covered Countries.
Based on the information provided by our suppliers and our own due diligence efforts, we believe that, to the best of our knowledge, the facilities that may have been used to process the 3TG in our products that were manufactured or contracted to be manufactured in 2015 include the smelters and refiners listed in Table 1 below. As many of the responses received from our suppliers were at a level higher than only those products procured to us, it is possible that the list includes smelters and refiners which do not provide 3TG utilized in our manufactured products. Although we do not have sufficient information to conclusively determine the countries of origin of the 3TG in our products, based on the information provided by our suppliers and other publicly available information, we believe that the countries of origin of the 3TG in our products that were manufactured or contracted to be manufactured in 2015 include the countries listed in Table 2 below.
Additionally, we cross-checked the list of smelters and refiners in Table 1 with the list of smelters and refiners who are compliant with the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program, the London Bullion Market Association’s Good Delivery Program and the Responsible Jewellery Council’s Chain-of-Custody Certification.
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Table 1: Smelters and Refiners
Mineral | Smelter Name | Smelter Location | ||
| Gold | Metalor Technologies (Suzhou) Co Ltd | China | ||
| Gold | Faggi Enrico S.p.A. | Italy | ||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||
| Gold | Cendres + Métaux SA | Switzerland | ||
| Gold | Advanced Chemical Company | United States | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||
| Gold | Daejin Indus Co., Ltd. | South Korea | ||
| Gold | DSC (Do Sung Corporation) | South Korea | ||
| Gold | Samduck Precious Metals | South Korea | ||
| Gold | Torecom | South Korea | ||
| Gold | Argor-Heraeus SA | Switzerland | ||
| Gold | Asahi Refining USA Inc. | United States | ||
| Gold | Heraeus Ltd. Hong Kong | China | ||
| Gold | Metalor Technologies SA | Switzerland | ||
| Gold | PAMP SA | Switzerland | ||
| Gold | Rand Refinery (Pty) Ltd. | South Africa | ||
| Gold | Valcambi SA | Switzerland | ||
| Gold | Western Australian Mint trading as The Perth Mint | Australia | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | ||
| Gold | CCR Refinery - Glencore Canada Corporation | Canada | ||
| Gold | Materion | United States | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | ||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China | ||
| Gold | Aida Chemical Industries Co., Ltd. | Japan | ||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | ||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil | ||
| Gold | Asahi Pretec Corporation | Japan | ||
| Gold | Asahi Refining Canada Limited | Canada | ||
| Gold | Asaka Riken Co., Ltd. | Japan | ||
| Gold | Aurubis AG | Germany | ||
| Gold | Chimet S.p.A. | Italy | ||
| Gold | Dowa | Japan | ||
| Gold | Eco-System Recycling Co., Ltd. | Japan | ||
| Gold | Elemetal Refining, LLC | United States | ||
| Gold | Heimerle + Meule GmbH | Germany | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | ||
| Gold | Kennecott Utah Copper LLC | United States | ||
| Gold | Kojima Chemicals Co., Ltd. | Japan |
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Mineral | Smelter Name | Smelter Location | ||
| Gold | LS-NIKKO Copper Inc. | South Korea | ||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | China | ||
| Gold | Metalor USA Refining Corporation | United States | ||
| Gold | Mitsubishi Materials Corporation | Japan | ||
| Gold | Mitsui Mining & Smelting | Japan | ||
| Gold | Nihon Material Co., Ltd. | Japan | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | ||
| Gold | Republic Metals Corporation | United States | ||
| Gold | Royal Canadian Mint | Canada | ||
| Gold | SEMPSA Joyería Platería SA | Spain | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | ||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | ||
| Gold | Tokuriki Honten Co., Ltd. | Japan | ||
| Gold | Umicore SA Business Unit Precious Metals Refining | Belgium | ||
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | ||
| Gold | Yokohama Metal Co., Ltd. | Japan | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | ||
| Gold | Boliden AB | Sweden | ||
| Gold | C. Hafner GmbH + Co. KG | Germany | ||
| Gold | Istanbul Gold Refinery | Turkey | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | ||
| Gold | PX PrŽcinox SA | Switzerland | ||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China | ||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | Mexico | ||
| Gold | Umicore Precious Metals Thailand | Thailand | ||
| Gold | Jiangxi Copper Company Limited | China | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | ||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | ||
| Gold | Umicore Brasil Ltda. | Brazil | ||
| Gold | DODUCO GmbH | Germany | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Gold | Japan Mint | Japan | ||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
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Mineral | Smelter Name | Smelter Location | ||
| Gold | JSC Uralelectromed | Russian Federation | ||
| Gold | Kazzinc | Kazakhstan | ||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | Russian Federation | ||
| Gold | OJSC Novosibirsk Refinery | Russian Federation | ||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | ||
| Gold | Schone Edelmetaal B.V. | Netherlands | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China | ||
| Gold | MMTC-PAMP India Pvt., Ltd. | India | ||
| Gold | Singway Technology Co., Ltd. | Taiwan | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | ||
| Gold | United Precious Metal Refining, Inc. | United States | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||
| Gold | Chugai Mining | Japan | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | ||
| Gold | Bauer Walser AG | Germany | ||
| Gold | Caridad | Mexico | ||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | ||
| Gold | Gansu Seemine Material Hi-Tech Co Ltd | China | ||
| Gold | Guangdong Jinding Gold Limited | China | ||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | ||
| Gold | Hwasung CJ Co. Ltd | South Korea | ||
| Gold | Korea Metal Co. Ltd | South Korea | ||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||
| Gold | L’ azurde Company For Jewelry | Saudi Arabia | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | ||
| Gold | Luo yang Zijin Yinhui Metal Smelt Co Ltd | China | ||
| Gold | OJSC Kolyma Refinery | Russia | ||
| Gold | Penglai Penggang Gold Industry Co Ltd | China | ||
| Gold | Sabin Metal Corp. | United States | ||
| Gold | SAMWON METALS Corp. | South Korea | ||
| Gold | So Accurate Group, Inc. | United States | ||
| Gold | The Great Wall Gold and Silver Refinery of China | China | ||
| Gold | TongLing Nonferrous Metals Group Holdings Co., Ltd. | China | ||
| Gold | Yunnan Copper Industry Co Ltd | China |
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Mineral | Smelter Name | Smelter Location | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tantalum | F&X Electro-Materials Ltd. | China | ||
| Tantalum | Global Advanced Metals Boyertown | United States | ||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | ||
| Tantalum | H.C. Starck GmbH Goslar | Germany | ||
| Tantalum | H.C. Starck GmbH Laufenburg | Germany | ||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | ||
| Tantalum | H.C. Starck Inc. | United States | ||
| Tantalum | H.C. Starck Ltd. | Japan | ||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | Germany | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | China | ||
| Tantalum | Mitsui Mining & Smelting | Japan | ||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | ||
| Tantalum | Plansee SE Liezen | Austria | ||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | ||
| Tantalum | Taki Chemicals | Japan | ||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | ||
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | ||
| Tantalum | Plansee SE Reutte | Austria | ||
| Tantalum | Zhuzhou Cemented Carbide | China | ||
| Tantalum | Duoluoshan | China | ||
| Tantalum | Exotech Inc. | United States | ||
| Tantalum | Global Advanced Metals Aizu | Japan | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | ||
| Tantalum | Hi-Temp Specialty Metals, Inc. | United States | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | ||
| Tantalum | LSM Brasil S.A. | Brazil | ||
| Tantalum | Mineração Taboca S.A. | Brazil | ||
| Tantalum | Molycorp Silmet A.S. | Estonia | ||
| Tantalum | Telex Metals | United States | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd | China | ||
| Tantalum | KEMET Blue Metals | Mexico | ||
| Tantalum | Kemet Blue Powder | United States | ||
| Tantalum | King-Tan Tantalum Industry Ltd. | China | ||
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
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Mineral | Smelter Name | Smelter Location | ||
| Tantalum | QuantumClean | United States | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | China | ||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | ||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | China | ||
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam | ||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | ||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam | ||
| Tin | Phoenix Metal Ltd | Rwanda | ||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam | ||
| Tin | PT Karimun Mining | Indonesia | ||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | ||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | ||
| Tin | PT Timah (Persero) Tbk Mentok | Indonesia | ||
| Tin | Thaisarco | Thailand | ||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China | ||
| Tin | Mitsubishi Materials Corporation | Japan | ||
| Tin | PT Bukit Timah | Indonesia | ||
| Tin | PT DS Jaya Abadi | Indonesia | ||
| Tin | PT Refined Bangka Tin | Indonesia | ||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||
| Tin | Yunnan Tin Group (Holding) Company Limited | China | ||
| Tin | CV United Smelting | Indonesia | ||
| Tin | EM Vinto | Bolivia | ||
| Tin | Metallo-Chimique N.V. | Belgium | ||
| Tin | Mineração Taboca S.A. | Brazil | ||
| Tin | Minsur | Peru | ||
| Tin | Operaciones Metalurgical S.A. | Bolivia | ||
| Tin | PT Timah (Persero) Tbk Kundur | Indonesia | ||
| Tin | Alpha | United States | ||
| Tin | China Tin Group Co., Ltd. | China | ||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | Brazil | ||
| Tin | CV Serumpun Sebalai | Indonesia | ||
| Tin | Dowa | Japan |
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Mineral | Smelter Name | Smelter Location | ||
| Tin | Fenix Metals | Poland | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | Brazil | ||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | ||
| Tin | PT Aries Kencana Sejahtera | Indonesia | ||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||
| Tin | PT Babel Inti Perkasa | Indonesia | ||
| Tin | PT Bangka Tin Industry | Indonesia | ||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||
| Tin | PT BilliTin Makmur Lestari | Indonesia | ||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | ||
| Tin | PT Inti Stania Prima | Indonesia | ||
| Tin | PT Justindo | Indonesia | ||
| Tin | PT Mitra Stania Prima | Indonesia | ||
| Tin | PT Panca Mega Persada | Indonesia | ||
| Tin | PT Prima Timah Utama | Indonesia | ||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||
| Tin | PT WAHANA PERKIT JAYA | Indonesia | ||
| Tin | Rui Da Hung | Taiwan | ||
| Tin | Soft Metais Ltda. | Brazil | ||
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | ||
| Tin | Elmet S.L.U. (Metallo Group) | Spain | ||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | ||
| Tin | CV Ayi Jaya | Indonesia | ||
| Tin | CV Gita Pesona | Indonesia | ||
| Tin | Melt Metais e Ligas S/A | Brazil | ||
| Tin | Metallic Resources, Inc. | United States | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | ||
| Tin | PT Bangka Prima Tin | Indonesia | ||
| Tin | PT Cipta Persada Mulia | Indonesia | ||
| Tin | Resind Indústria e Comércio Ltda. | Brazil | ||
| Tin | VQB Mineral and Trading Group JSC | Vietnam | ||
| Tin | CV Venus Inti Perkasa | Indonesia | ||
| Tin | PT Sumber Jaya Indah | Indonesia | ||
| Tin | Dowa | Japan | ||
| Tin | Mineração Taboca S.A. | Brazil |
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Mineral | Smelter Name | Smelter Location | ||
| Tin | Mitsubishi Materials Corporation | Japan | ||
| Tin | Resind Indústria e Comércio Ltda. | Brazil | ||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China | ||
| Tin | Estanho de Rondônia S.A. | Brazil | ||
| Tin | Gejiu Zi-Li | China | ||
| Tin | Huichang Jinshunda Tin Co. Ltd | China | ||
| Tin | Linwu Xianggui Smelter Co | China | ||
| Tin | Novosibirsk Integrated Tin Works | Russia | ||
| Tin | PT Alam Lestari Kencana | Indonesia | ||
| Tin | PT Bangka Kudai Tin | Indonesia | ||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | ||
| Tin | PT Fang Di MulTindo | Indonesia | ||
| Tin | PT Seirama Tin investment | Indonesia | ||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | China | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | ||
| Tungsten | Kennametal Fallon | United States | ||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | ||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | ||
| Tungsten | Global Tungsten & Powders Corp. | United States | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China | ||
| Tungsten | H.C. Starck GmbH | Germany | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | ||
| Tungsten | Japan New Metals Co., Ltd. | Japan | ||
| Tungsten | Kennametal Huntsville | United States | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | ||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | ||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany |
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Mineral | Smelter Name | Smelter Location | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China | ||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | ||
| Tungsten | Niagara Refining LLC | United States | ||
| Tungsten | Hydrometallurg, JSC | Russian Federation | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | ||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | ||
| Tungsten | Yichun Jin Yang Rare Metal Co., Ltd. | China | ||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | ||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | ||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China | ||
| Tungsten | Pobedit, JSC | Russian Federation | ||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | ||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China |
Table 2: Countries of Origin for 3TG
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bolivia
Brazil
Burundi
Canada
Chile
China
Democratic Republic of Congo
Estonia
Ethiopia
France
Germany
Ghana
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Guinea
Guyana
India
Indonesia
Italy
Japan
Kazakhstan
Kyrgyzstan
Laos
Malaysia
Mali
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
Niger
Nigeria
Papua New Guinea
Peru
Philippines
Poland
Portugal
Russian Federation
Rwanda
Saudi Arabia
Sierra Leone
Singapore
South Africa
South Korea
Spain
Suriname
Sweden
Switzerland
Taiwan
Tajikistan
Tanzania
Thailand
Turkey
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United Arab Emirates
United Kingdom
United States
Uzbekistan
Vietnam
Zambia
Zimbabwe
| VI. | Process Considerations |
We will continue to communicate our expectations regarding compliance with our Conflict Minerals Policy to our direct suppliers. We will continue to make inquiries to our direct suppliers and provide training and guidance to them regarding our Conflict Minerals Policy when appropriate. We will also continue to undertake additional fact and risk assessments where necessary, and monitor changes in supplier circumstances that may impact their compliance with our Conflict Minerals Policy, which in turn may impact our continued engagement of and relationship with certain suppliers. As part of our risk mitigation efforts, we expect our suppliers who do not currently comply with our Conflict Minerals Policy, particularly those using smelters or refiners that are not verified as conflict free and who have not begun the audit process, to publicly demonstrate progress toward a conflict-free supply chain. If we become aware of suppliers whose sourcing of 3TG or ability to comply with our Conflict Minerals Policy does not improve, we may suspend orders or terminate the business relationship with those suppliers. We expect our suppliers to take similar measures with their suppliers to ensure alignment with our sourcing philosophy throughout the supply chain.
| VII. | Independent Private Sector Audit |
Pursuant to current guidance issued by the U.S. Securities and Exchange Commission, an independent private sector audit is not required for this Conflict Minerals Report.
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This Form SD (“Form”) contains forward-looking statements that involve a number of risks and uncertainties. These forward-looking statements include, but are not limited to, statements and predictions as to our expectations regarding our conflict mineral compliance plans, our customers’ requirements and the impact of compliance, including any statement which is preceded by the word “may,” “might,” “will,” “intend,” “should,” “could,” “can,” “would,” “expect,” “believe,” “anticipate,” “estimate,” “predict,” “aim,” “potential,” “plan,” or similar words. For all of the foregoing forward-looking statements, we claim the protection of the Private Securities Litigation Reform Act of 1995. Actual events or results may differ materially from our expectations. Important factors that could cause actual results to differ materially from those stated or implied by our forward-looking statements include, but are not limited to, our ability to successfully meet our customers’ demands, our effectiveness in managing the conflict minerals RCOI and due diligence processes, costs of our compliance, the degree to which we are able to determine our vendors’ use of conflict-free smelters and refiners, and the impact of industry wide initiatives such as the Conflict-Free Smelter Program. These forward-looking statements represent our judgment as of the date hereof. We disclaim any intent or obligation to update these forward-looking statements.
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