Exhibit 1.02
Cameron International Corporation
Conflict Minerals Report
For the Year Ended December 31, 2013
This Conflict Mineral Report ("CMR") of Cameron International Corporation (the "Company" or "Cameron") for calendar year 2013 is presented pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 ("the Rule "). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG").
Cameron is a Fortune 500 company with annual revenues of $9.8 billion and a workforce of over 29,000 employees, and with legal entities in more than 50 countries worldwide. Cameron provides flow equipment products, systems and services to worldwide oil, gas and process industries through three business segments, Drilling and Production Systems (DPS), Valves & Measurement (V&M) and Process & Compression Systems (PCS). Cameron works with drilling contractors, oil & gas producers, pipeline operators, refiners and other process owners to control, direct, adjust, process, measure and compress pressures and flows. Cameron purchases and contracts to manufacture products that contain 3TG, but does not purchase 3TG directly from smelters or refineries. Therefore, we have requested that our suppliers identify and disclose to us the source of the 3TG in the products they supply to us.
Reasonable Country of Origin Inquiry
We initiated our conflict minerals compliance program with an evaluation of our product portfolio. This evaluation resulted in a determination that many of our products contained 3TG. We then compiled a list of our direct suppliers and applied a set of filtering criteria to the supplier listing to arrive at the final list of impacted suppliers for calendar 2013. A total of 5,008 direct suppliers were identified as in-scope, and we initiated the supplier engagement process for those suppliers.
The total survey completion rate among our direct supplier population was 28.2%. Of the survey responses received, 38% indicated the use of one or more of the 3TG as necessary to the functionality or production of the products they supply to Cameron. Based on the information gathered through the supplier engagement process, we were unable to determine whether some of the 3TG in our products originated from the Democratic Republic of Congo or an adjoining country ("the Covered Countries"). As a result and as required by the Rule, we performed the due diligence procedures noted below.
Conflict Minerals Policy
Cameron has adopted the following conflict minerals policy ("Policy"):
Cameron is fully committed to compliance with the "conflicts minerals" provision of Dodd-Frank and the implementing SEC regulations. In furtherance of this commitment, Cameron will work with its suppliers to develop due diligence practices to enable full compliance with this law and these regulations. Cameron also expects its suppliers to adopt a similar policy, to respond to annual inquiries related to "conflict minerals" and to undertake reasonable due diligence with their supply chain to understand the source of origin of the minerals contained in the parts, components, and products they provide to Cameron in order to allow for proper disclosure and compliance with the SEC "conflict minerals" final rule. In the event that a supplier cannot or will not adhere to the above requirements, it is Cameron's intent to take appropriate actions to seek sources of supply that can and do comply with the rule.
Our Policy can be found at http://investors.c-a-m.com/compliance.
Design of Due Diligence
Cameron's due diligence process is designed to conform with The Organisation for Economic Co-operation and Development's (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and accompanying Supplements1 (OECD Guidance).
Due Diligence Measures Performed
Internal team
Cameron established a Conflict Minerals Steering Committee comprised of executive-level representatives responsible for providing governance and oversight over the execution of the conflict minerals compliance program. During the calendar year of 2013, the Steering Committee met on a regular basis and was supported by the Conflict Minerals project team, led by a program manager.
Grievance Mechanism
Customers, suppliers, stakeholders, and other external parties can report concerns with and violations of the Conflict Minerals Policy through Cameron's ethics and compliance channel via www.cameronethics.com or via email at compliance@c-a-m.com.
Execution of Due Diligence
For calendar year 2013, Cameron engaged a third-party data collection and aggregation partner to capture and analyze information about the presence and sourcing of 3TG used in the products and components supplied to Cameron. The Electronic Industry Citizenship Coalition (EICC) and Global e-Sustainability Initiative (GeSI) Conflict Minerals Due Diligence Template (EICC-GeSI Template) was utilized to obtain specific visibility into our suppliers' sourcing activities and, as a result of the information obtained, served to focus our due diligence efforts. Further, we provided instructions and access to the third-party data collection conflict minerals resource center through direct email with the objective of educating our suppliers on Cameron's expectations and promoting the likelihood and quality of the suppliers' responses.
Following is a summary of the due diligence measures:
| ● | For those suppliers who responded indicating that 3TG was necessary to the functionality or production of the products they supply to Cameron, we evaluated the survey responses for consistency of data provided, including whether those responses were complete and whether they contained any contradictions or inconsistencies. Follow-up communications were initiated with these suppliers as needed to clarify their responses to questions contained in the survey. |
| ● | For those suppliers who provided smelter or refiner information for 3TG, information was compared against available lists of metal processors that have been certified by internationally-recognized industry validation schemes, such as the Conflict Free Sourcing Initiative's (CFSI) Conflict-Free Smelter (CFS) Program, the London Bullion Market Association Good Delivery Program, and the Responsible Jewelry Council Chain-of-Custody Certification. |
| | ● If smelter or refiner information was not certified by an internationally-recognized scheme, additional research was conducted of those smelter and refiners regarding their sourcing practices. |
| ● | Standard operating procedures were developed to guide and sustain our conflict minerals compliance program. |
| III. | Risk Mitigation and Future Due Diligence Measures |
Cameron will undertake the following steps during the next compliance period to improve the completion rate to our survey, completeness and accuracy of responses received, and our follow-up due diligence:
| ● | Include a conflict minerals flow-down clause requiring suppliers to identify their 3TG sourcing in new or renewed direct supplier contracts. We will be working closely with our supply chain leadership to develop an effective approach to integrate the flow-down provision |
| ● | Implement an annual re-certification process for in-scope suppliers |
| ● | Assess the need for identifying alternative 3TG suppliers for non-reporting suppliers |
Cameron's in-scope products include the following:
The DPS segment includes businesses that provide systems and equipment used to drill, control pressures and direct flows of oil and gas wells. Its products are employed in a wide variety of operating environments including basic onshore fields, highly complex onshore and offshore environments, deepwater subsea applications and ultra-high temperature geothermal operations. The products within this segment include drilling equipment packages, blowout preventers (BOPs), drilling risers, top drives, draw works, complete wellhead and Christmas tree systems for onshore and offshore applications, subsea production systems and manifolds and aftermarket parts and services.
The V&M segment includes businesses that provide valves and measurement systems primarily used to control, direct and measure the flow of oil and gas as they are moved from individual wellheads through flow lines, gathering lines and transmission systems to refineries, petrochemical plants and industrial centers for processing. Products include gate valves, ball valves, butterfly valves, Orbit® valves, double block & bleed valves, plug valves, globe valves, check valves, actuators, chokes and aftermarket parts and services, as well as measurement products such as totalizers, turbine meters, flow computers, chart recorders, ultrasonic flow meters and sampling systems.
The PCS segment includes businesses that provide standard and custom-engineered process packages for separation and treatment of impurities within oil and gas and compression equipment and aftermarket parts and services to the oil, gas and process industries. Products include oil and gas separation equipment, heaters, dehydration and desalting units, gas conditioning units, membrane separation systems, water processing systems, integral engine-compressors, separable reciprocating compressors, two and four-stroke cycle gas engines, turbochargers, integrally-geared centrifugal compressors, compressor systems and controls. Aftermarket services include spare parts, technical services, repairs, overhauls and upgrades.
Based on the information provided by our direct suppliers and due diligence efforts with known smelters and refiners through December 31, 2013, Cameron reasonably believes that the facilities used to process the 3TG contained in our products, include the smelters and refiners listed below:
| SOR / Facility Name | Conflict-Free Status |
| Gold |
| Aida Chemical Industries Co. Ltd. | Unknown |
| Allgemeine Gold- und Silberscheideanstalt A.G. | CFSP; LBMA; RJC |
| Almalyk Mining and Metallurgical Complex (AMMC) | LBMA |
| AngloGold Ashanti Mineração Ltda | CFSP; LBMA |
| Argor-Heraeus SA | CFSP; LBMA |
| Asahi Pretec Corporation | CFSP; LBMA |
| Asaka Riken Co Ltd | Unknown |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | LBMA |
| Aurubis AG | LBMA |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | LBMA |
| Boliden AB | LBMA |
| Caridad | Unknown |
| Cendres & Métaux SA | LBMA |
| Central Bank of the DPR of Korea | Unknown |
| Chimet SpA | CFSP; LBMA |
| Chugai Mining | Unknown |
| Codelco | Unknown |
| Daejin Indus Co. Ltd | Unknown |
| DaeryongENC | Unknown |
| Do Sung Corporation | Unknown |
| Dowa | CFSP |
| FSE Novosibirsk Refinery | Unknown |
| Heimerle + Meule GmbH | Unknown |
| Heraeus Ltd Hong Kong | CFSP; LBMA |
| Heraeus Precious Metals GmbH & Co. KG | CFSP; LBMA |
| Hwasung CJ Co. Ltd | Unknown |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | LBMA |
| Ishifuku Metal Industry Co., Ltd. | CFSP; LBMA |
| Istanbul Gold Refinery | CFSP; LBMA |
| Japan Mint | LBMA |
| Jiangxi Copper Company Limited | LBMA |
| Johnson Matthey Limited | CFSP; LBMA |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant | LBMA |
| JSC Uralectromed | LBMA |
| JX Nippon Mining & Metals Co., Ltd | CFSP; LBMA |
| Kazzinc Ltd | LBMA |
| Kojima Chemicals Co. Ltd | CFSP |
| Korea Metal Co. Ltd | Unknown |
| Kyrgyzaltyn JSC | LBMA |
| L' azurde Company For Jewelry | LBMA |
| Materion | CFSP |
| Matsuda Sangyo Co. Ltd | CFSP; LBMA |
| Met-Mex Peñoles, S.A. | LBMA |
| Metalor Technologies (Hong Kong) Ltd | CFSP; LBMA; RJC |
| Metalor Technologies SA | CFSP; LBMA; RJC |
| Mitsui Mining and Smelting Co., Ltd. | CFSP; LBMA |
| Moscow Special Alloys Processing Plant | LBMA |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. | LBMA |
| Navoi Mining and Metallurgical Combinat | LBMA |
| Nihon Material Co. LTD | CFSP; LBMA |
| Ohio Precious Metals LLC. | CFSP; LBMA |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet) | LBMA |
| OJSC Kolyma Refinery | LBMA |
| OMSA | CFSP |
| PAMP SA | CFSP; LBMA |
| Pan Pacific Copper Co. LTD | Unknown |
| Prioksky Plant of Non-Ferrous Metals | LBMA |
| PT Aneka Tambang (Persero) Tbk | LBMA |
| PX Précinox SA | LBMA |
| Royal Canadian Mint | CFSP; LBMA |
| Sabin Metal Corp. | Unknown |
| SAMWON METALS Corp. | Unknown |
| Schone Edelmetaal | LBMA |
| SEMPSA Joyeria Plateria SA | CFSP; LBMA |
| Shandong Zhaojin Gold & Silver Refinery Co. Ltd | LBMA |
| SOE Shyolkovsky Factory of Secondary Precious Metals | LBMA |
| Solar Applied Materials Technology Corp. | CFSP; LBMA |
| Suzhou Xingrui Noble | Unknown |
| Tanaka Kikinzoku Kogyo K.K. | CFSP; LBMA |
| The Great Wall Gold and Silver Refinery of China | LBMA |
| Torecom | Unknown |
| Umicore Brasil Ltda | LBMA |
| Umicore SA Business Unit Precious Metals Refining | CFSP; LBMA |
| United Precious Metal Refining, Inc. | CFSP |
| Western Australian Mint trading as The Perth Mint | CFSP; LBMA |
| Xstrata Canada Corporation | Unknown |
| Yokohama Metal Co Ltd | Unknown |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation | LBMA |
| Zijin Mining Group Co. Ltd | LBMA |
|
| SOR / Facility Name | Conflict-Free Status |
| Tin |
| Chongyi Zhangyuan Tungsten Co Ltd | Unknown |
| CNMC (Guangxi) PGMA Co. Ltd. | Unknown |
| Cookson | CFSP |
| Cooper Santa | Unknown |
| CV JusTindo | Unknown |
| CV Makmur Jaya | Unknown |
| CV Nurjanah | Unknown |
| CV Prima Timah Utama | Unknown |
| CV Serumpun Sebalai | Unknown |
| CV United Smelting | Unknown |
| EM Vinto | Unknown |
| Fenix Metals | Unknown |
| Geiju Non-Ferrous Metal Processing Co. Ltd. | CFSP |
| Gejiu Zi-Li | Unknown |
| Huichang Jinshunda Tin Co. Ltd | Unknown |
| Jiangxi Nanshan | Unknown |
| Kai Unita Trade Limited Liability Company | Unknown |
| Linwu Xianggui Smelter Co | Unknown |
| Metallo Chimique | Unknown |
| Mineração Taboca S.A. | CFSP |
| Minmetals Ganzhou Tin Co. Ltd. | Unknown |
| Minmetals Ganzhou Tin Co. Ltd. | Unknown |
| Novosibirsk Integrated Tin Works | Unknown |
| PT Alam Lestari Kencana | Unknown |
| PT Artha Cipta Langgeng | Unknown |
| PT Babel Inti Perkasa | Unknown |
| PT Babel Surya Alam Lestari | Unknown |
| PT Bangka Kudai Tin | Unknown |
| PT Bangka Putra Karya | LBMA |
| PT Bangka Timah Utama Sejahtera | Unknown |
| PT Belitung Industri Sejahtera | Unknown |
| PT BilliTin Makmur Lestari | Unknown |
| PT Bukit Timah | CFSP |
| PT Fang Di MulTindo | Unknown |
| PT HP Metals Indonesia | Unknown |
| PT Mitra Stania Prima | Unknown |
| PT Refined Banka Tin | Unknown |
| PT Sariwiguna Binasentosa | Unknown |
| PT Stanindo Inti Perkasa | Unknown |
| PT Sumber Jaya Indah | Unknown |
| PT Tambang Timah | LBMA |
| PT Timah Nusantara | Unknown |
| PT Tinindo Inter Nusa | Unknown |
| PT Yinchendo Mining Industry | Unknown |
| PT Yinchendo Mining Industry | Unknown |
| Thaisarco | CFSP |
| White Solder Metalurgia | CFSP |
| Yunnan Tin Company Limited | CFSP |
|
| SOR / Facility Name | Conflict-Free Status |
| Tungsten | |
| A.L.M.T. Corp. | Unknown |
| ATI Tungsten Materials | Unknown |
| Chaozhou Xianglu Tungsten Industry Co Ltd | Unknown |
| Dayu Weiliang Tungsten Co., Ltd. | Unknown |
| Fujian Jinxin Tungsten Co., Ltd. | TI-CMC |
| Ganzhou Grand Sea W & Mo Group Co Ltd | Unknown |
| Global Tungsten & Powders Corp | TI-CMC |
| Hunan Chenzhou Mining Group Co | Unknown |
| Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | Unknown |
| Japan New Metals Co Ltd | Unknown |
| Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Unknown |
| Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | Unknown |
| Jiangxi Tungsten Industry Group Co Ltd | Unknown |
| Kennametal Inc. | TI-CMC |
| Tejing (Vietnam) Tungsten Co Ltd | TI-CMC |
| Wolfram Bergbau und Hütten AG | TI-CMC |
| Wolfram Company CJSC | TI-CMC |
| Xiamen Tungsten Co Ltd | TI-CMC |
|
| SOR / Facility Name | Conflict-Free Status |
| Tantalum |
| China Minmetals Nonferrous Metals Co Ltd | Unknown |
| Conghua Tantalum and Niobium Smeltry | CFSP |
| Duoluoshan | CFSP |
| Exotech Inc. | CFSP |
| F&X | CFSP |
| Gannon & Scott | Unknown |
| Global Advanced Metals | CFSP |
| Hi-Temp | CFSP |
| JiuJiang JinXin Nonferrous Metals Co. Ltd. | Unknown |
| JiuJiang Tambre Co. Ltd. | CFSP |
| King-Tan Tantalum Industry Ltd | Unknown |
| LMS Brasil S.A. | CFSP |
| Mitsui Mining & Smelting | CFSP |
| Molycorp Silmet | CFSP |
| Ningxia Orient Tantalum Industry Co., Ltd. | CFSP |
| Plansee | CFSP |
| QuantumClean | CFSP |
| RFH | CFSP |
| Solikamsk Metal Works | CFSP |
| Taki Chemicals | CFSP |
| Tantalite Resources | CFSP |
| Telex | CFSP |
| Ulba | CFSP |
| Zhuzhou Cement Carbide | CFSP |
Countries of Origin for these SORs are believed to include: Australia, Argentina, Brazil, Bolivia, Burundi, Canada, Chile, China, DRC- Congo, Ghana, Ethiopia, Guinea, Hong Kong, India, Indonesia, Japan, Kazakhstan, Laos, Malaysia, Mali, Mexico, Mozambique, Namibia, Niger, Nigeria, Peru, Philippines, Portugal, Russia, Rwanda, South Africa, South Korea, Spain, Switzerland, Tajikistan, Tanzania, Thailand, United States, Uzbekistan, Zambia |
Conflict Free Status Legend: recognized certification protocols · CFSP: Conflict Free Smelter Program of the Conflict-Free Sourcing Initiative (CFSI) which offers companies and their suppliers an independent, third-party audit that determines which smelters and refiners can be validated as "conflict-free," in line with current global standards. · LBMA: the London Bullion Market Association is the international trade association that represents the market for gold and silver bullion. The LBMA Responsible Gold Guidance focuses on demonstrating that gold outputs from LBMA-accredited refiners are conflict-free. · RJC: Responsible Jewellery Council is a standards setting and certification organization with a focus on the jewelry supply chain from mine to retail. The RJC Chain-of-Custody (CoC) Standard aims to support claims for responsibly-sourced jewelry materials (known as CoC Material) produced, processed and traded through the jewelry supply chain. · TI-CMC: Tungsten Industry—Conflict Minerals Council provides industry stakeholders downstream tungsten consumers with conflict mineral reporting and disclosure obligations, and the public at large with assurances that tungsten products originating from TI-CMC-compliant companies are conflict free · Unknown: smelters or refiners that are known facilities but have not yet received a conflict free certification from any of the recognized certification initiatives. |
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Supplement on Tin, Tantalum and Tungsten and Supplement on Gold, 2013; http://www.oecd.org/daf/inv/mne/GuidanceEdition2.pdf.
