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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
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OMB APPROVAL OMB Number: 3235-0697 Expires: May 31, 2016 |
FORM SD
Specialized Disclosure Report
Spartan Motors, Inc
(Exact name of registrant as specified in its charter)
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Michigan |
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000-13611 |
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38-2078923 |
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(State or other jurisdiction |
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(Commission |
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(IRS Employer |
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of incorporation or organization) |
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File Number) |
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Identification No.) |
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1541 Reynolds Road |
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Charlotte, Michigan |
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48813 |
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(Address of principal executive offices) |
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(Zip Code) |
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| Lori L. Wade (517) 543-6400 |
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2013
SECTION 1 – CONFLICT MINERALS DISCLOSURE
Item 1.01 Conflict Minerals Disclosure and Report
A copy of Spartan Motors, Inc.’s Conflict Minerals Report for the period from January 1 to December 31, 2013 is filed as Exhibit 1.01 and is incorporated herein by reference. The Conflict Minerals Report is available on our website at www.Spartanmotors.com under the heading “Conflict Minerals”.
Item 1.02 Exhibits
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
SECTION 2 – EXHIBITS
Item 2.01 Exhibits
1.01 Conflict Minerals Report for Spartan Motors, Inc. for the period January 1 to December 31, 2013.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Spartan Motors, Inc.
(Registrant)
| /s/ Lori L. Wade | May 29, 2014 | ||||
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By: Lori L. Wade |
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| Its: Chief Financial Officer | Date | ||||
Exhibit 1.01
Spartan Motors, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2013
This report for the calendar year ended December 31, 2013, 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 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”).
If a registrant can establish that the conflict minerals 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 conflict minerals 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.
We are filing this CMR because, after completing a RCOI and due diligence, the Company is unable to conclude whether any of the conflict minerals contained in Company products originated in the Covered Countries.
Company Overview
Spartan Motors, Inc. was organized as a Michigan corporation on September 18, 1975, and is headquartered in Charlotte, Michigan. We began development of our first product that same year and shipped our first fire truck chassis in October 1975.
We are known as a leading niche-market engineer and manufacturer in the heavy-duty, Specialty Chassis and Vehicles marketplace. We have five wholly-owned operating subsidiaries: Spartan Motors Chassis, Inc., located at our corporate headquarters in Charlotte, Michigan (“Spartan Chassis”); Crimson Fire, Inc., located in Brandon, South Dakota (“Crimson”); Crimson Fire Aerials, Inc., located in Ephrata, Pennsylvania (“Crimson Aerials”); Utilimaster Corporation, located in Bristol and Wakarusa, Indiana (“Utilimaster”); and Classic Fire, LLC (“Classic Fire”), located in Ocala, Florida. We are also a participant in Spartan-Gimaex Innovations, LLC (“Spartan-Gimaex”) a joint venture between Crimson and Gimaex Holding, Inc. Our brand names, Spartan Chassis™, Spartan ERV™, and Utilimaster™ are known for quality, value, service and innovation.
Spartan Chassis is a leader in the designing, engineering and manufacturing of specialty heavy-duty chassis. The chassis consists of a frame assembly, engine, transmission, electrical system, running gear (wheels, tires, axles, suspension and brakes) and, for emergency response chassis and some specialty chassis applications, a cab. Spartan Chassis customers are original equipment manufacturers (“OEMs”) who manufacture the body or apparatus of the vehicle which is mounted on our chassis. Crimson specializes in the engineering and manufacturing of emergency response vehicles built on chassis platforms purchased from either Spartan Chassis or outside sources. Crimson Aerials engineers and manufactures aerial ladder components for fire trucks. Classic Fire specializes in manufacturing emergency response vehicles built on chassis from outside sources and provides strategic sourcing of pump modules. Collectively, Crimson, Crimson Aerials and Classic Fire operate under the Spartan ERV brand. Spartan-Gimaex is a 50/50 joint venture that was formed to leverage the complementary footprints, capabilities, brands, technologies and product portfolios of both companies. Utilimaster is a leading manufacturer of vehicles made to customer specifications in the delivery and service market, including walk-in and hi-cube vans and truck bodies.
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 Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank).
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.
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. We have implemented the 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 developed by the Electronic Industry Citizenship Coalition® (“EICC”) and the Global e-Sustainability Initiative, known as the EICC/GeSI Conflict Minerals Reporting Template (“EICC/GeSI Template”), 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 EICC/GeSI Conflict Minerals reporting template.
Our conflict minerals policy is posted on our website at www.Spartanmotors.com.
RCOI & Due Diligence
Our due diligence measures have been designed to conform with the framework in 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 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 EICC/GeSI Conflict Minerals Reporting Template (the "Template"). The Template 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 Template 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 EICC’s website. As we enter into new contracts, or our contracts renew, we are adding a clause to require suppliers to provide information about the source of conflict minerals and smelters. It will take a number of years to ensure that all of our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information until the contracts can be amended.
For the 2013 reporting year, all of our direct suppliers were asked to complete the Template. Going forward, we currently expect we will only disseminate the Template to those suppliers who supply components likely to contain 3TG. We believe this approach is reasonable in light of the nature and number of our suppliers, as well as industry standards and practices of peer companies.
Due Diligence Process
We reviewed the components that are included in the specialty vehicles and chassis that we manufacture to determine if 3TG is necessary to the functionality or production of our products. Our specialty vehicles and chassis contain a large number of components, including such components as wiring, instruments and electronic controls that are generally believed to contain 3TG. As a result of this review, we determined that, due to the complexity of and the number of components contained in the specialty vehicles and chassis that we produce, all of our products contain one or more components for which 3TG is necessary for the functionality or production.
Our due diligence measures have been designed to conform with the framework in 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 (“OECD Guidance”) and the related Supplements for Gold and for Tin, Tantalum and Tungsten.
Step One: Establish Strong Company Management Systems
Internal Team
We are in the process of establishing a complete management system for conflict minerals due diligence. At our corporate level, we have a cross functional team and a third-party consulting subject matter expert working collaboratively to develop 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 implemented for each of our division.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have developed a training program for our suppliers for the 2014 reporting year. It was found that many suppliers in 2013 were not aware of or did not understand the Dodd-Frank 1502 requirements. As a result of this finding, we developed an instructional document that will be provided to all of our suppliers by the second quarter of 2014. 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 on an annual basis.
Grievance Mechanism
Our website (www.Spartanmotors.com) contains a prominent 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 direct suppliers were identified for inclusion in our 2013 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.
Our conflict minerals team is developing a process to evaluate risk in the supply chain. We will assess risk by reviewing the suppliers’ answers provided in the EICC/GeSI Template for risk indicators. These risk indicators are based on common industry practices. When risk indicators are found, corrective action measures will be required of the supplier(s).
Step Three: Design and Implement a Strategy to Respond to Risks
We are currently developing our Risk Management Plan. As part of our Risk Management Plan, we have developed a training program to ensure suppliers understand our expectations for them. Training will be provided annually to all of our suppliers.
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 EICC/GeSI Conflict Minerals Reporting Template (the “Template”). The Template 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 Template 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 EICC’s website. The Template is being used by many companies in their due diligence processes related to conflict minerals.
We received responses from 39 percent of the relevant suppliers surveyed. Responses included the names of 231 entities listed by our suppliers as smelters or refiners. 45 of these entities were identified as certified Conflict-Free using the CFSI Reporting Template Revision 2.03a. 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, as described above, were unable to specify the smelters or refiners used. With the exception of the supplier(s) described above, we are unable to determine whether any of the conflict minerals reported by the 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 Template 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.
As a result of our due diligence efforts, we have concluded in good faith that the result of our efforts is “DRC Conflict Undeterminable”. 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 all of the 3TG used in our products; however, based on the information that was provided by the responding suppliers and otherwise obtained through our due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the 3TG contained in our products included the smelters and refiners listed below:
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Smelter Name |
Conflict Free Certification |
Metal |
Country |
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A.L.M.T corp |
Listed on the EICC-GeSI list |
Tungsten (W) |
Japan |
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AcademyPreciousMetals(China)Co.,Ltd |
Unknown |
Tin (Sn) |
China |
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Aida Chemical Industries Co. Ltd. |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
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Allgemeine Gold- und Silberscheideanstalt A.G. |
Listed on the CFS list |
Gold (Au) |
Germany |
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Almalyk Mining and Metallurgical Complex (AMMC) |
Listed on the EICC-GeSI list |
Gold (Au) |
Uzbekistan |
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Altlantic Metals |
Unknown |
Tungsten (W) |
United States |
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Amalgamet |
Unknown |
Tin (Sn) |
United States |
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American Iron and Metal |
Unknown |
Tin (Sn) |
Canada |
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AngloGold Ashanti Mineração Ltda |
Listed on the EICC-GeSI list |
Gold (Au) |
Brazil |
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Argor-Heraeus SA |
Listed on the CFS list |
Gold (Au) |
Switzerland |
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Asahi Pretec Corporation |
Listed on the CFS list |
Gold (Au) |
Japan |
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Asaka Riken Co Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Listed on the EICC-GeSI list |
Gold (Au) |
Turkey |
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ATI Tungsten Materials |
Listed on the EICC-GeSI list |
Tungsten (W) |
United States |
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Atlantic Metals |
Unknown |
Tin (Sn) |
United States |
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Aurubis AG |
Listed on the EICC-GeSI list |
Gold (Au) |
Germany |
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Ausmelt Limited |
Unknown |
Tin (Sn) |
Australia |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Listed on the EICC-GeSI list |
Gold (Au) |
Philippines |
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Boliden AB |
Listed on the EICC-GeSI list |
Gold (Au) |
Sweden |
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Britannia Refined Metals Ltd. |
Unknown |
Tin (Sn) |
United Kingdon |
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Buffalo Tungsten |
Unknown |
Tungsten (W) |
China |
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Butterworth Smelter |
may be part of the Malaysia Smelting Corp |
Tin (Sn) |
Malaysia |
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Caridad |
Listed on the EICC-GeSI list |
Gold (Au) |
Mexico |
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Cendres & Métaux SA |
Listed on the EICC-GeSI list |
Gold (Au) |
Switzerland |
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Central Bank of the DPR of Korea |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
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Chaozhou Xianglu Tungsten Industry Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
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Chimet SpA |
Listed on the EICC-GeSI list |
Gold (Au) |
Italy |
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China Hongqiao |
Unknown |
Tin (Sn) |
China |
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China Tin Group Co., Ltd. |
Unknown |
Tin (Sn) |
China |
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Chongyi Zhangyuan Tungsten Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
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Chugai Mining |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
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CHUGAI MINING CO.,LTD |
Unknown |
Gold (Au) |
Japan |
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CNMC (Guangxi) PGMA Co. Ltd. |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
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Codelco |
Listed on the EICC-GeSI list |
Gold (Au) |
CHILE |
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Complejo Metalurgico Vinto S.A. |
Unknown |
Tin (Sn) |
Bolivia |
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Conghua Tantalum and Niobium Smeltry |
Listed on the CFS list |
Tantalum (Ta) |
China |
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Cookson |
Listed on the EICC-GeSI list |
Tin (Sn) |
United States |
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Cookson Sempsa |
Unknown |
Gold (Au) |
SPAIN |
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Cooper Santa |
Listed on the EICC-GeSI list |
Tin (Sn) |
Brazil |
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Corporation Berhad (MSC) |
Unknown |
Tin (Sn) |
Malaysia |
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CSC Pure Technologies |
Unknown |
Tin (Sn) |
Russian Federation |
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CV Duta Putra Bangka |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV JusTindo |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV Makmur Jaya |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV Nurjanah |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV Prima Timah Utama |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV Serumpun Sebalai |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CV United Smelting |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
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CWB Materials |
Unknown |
Tungsten (W) |
United States |
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DAE CHANG IND CO LTD |
Unknown |
Tin (Sn) |
Korea, Republic of |
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DAECHANG Co. LTD. |
Unknown |
Tin (Sn) |
Korea, Republic of |
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DaeryongENC |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
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Dayu Weiliang Tungsten Co., Ltd. |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
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TANAKA KIKINZOKU KOGYO K.K. |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
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Do Sung Corporation |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
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Dowa |
Listed on the CFS list |
Gold (Au) |
Japan |
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Duoluoshan Sapphire Rare Metel Co. Ltd. Of Zhaoqing |
Listed on the EICC-GeSI list |
|
China |
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EM Vinto |
Listed on the EICC-GeSI list |
Tin (Sn) |
Bolivia |
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ESG Edelmetallservice GmbH & Co. KG |
Unknown |
Gold (Au) |
Germany |
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Ethiopian Minerals Development Share Company |
Unknown |
Tantalum (Ta) |
Ethiopia |
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Exotech Inc. |
Listed on the CFS list |
Tantalum (Ta) |
United States |
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F&X |
Listed on the CFS list |
Tantalum (Ta) |
China |
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Feinhütte Halsbrücke GmbH |
Unknown |
Tin (Sn) |
Germany |
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Fenix Metals |
Listed on the EICC-GeSI list |
Tin (Sn) |
Poland |
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FSE Novosibirsk Refinery |
Listed on the EICC-GeSI list |
Gold (Au) |
Russian Federation |
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Fujian Jinxin Tungsten Co., Ltd. |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
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Gannon & Scott |
Listed on the CFS list |
Tantalum (Ta) |
United States |
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Gansu-based Baiyin Nonferrous Metals Corporation (BNMC) |
Unknown |
Gold (Au) |
China |
|
Ganzhou Grand Sea W & Mo Group Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
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Ganzhou Hongfei Tungsten & Molybdenum Materials Co., Ltd. |
Unknown |
Tungsten (W) |
China |
|
Ganzhou Sinda W&Mo Co., Ltd. |
Unknown |
Tungsten (W) |
China |
|
Geiju Non-Ferrous Metal Processing Co. Ltd. |
Listed on the CFS list |
Tin (Sn) |
China |
|
Gejiu Yunxi Group Corp. |
Unknown |
Tin (Sn) |
China |
|
Gejiu Zi-Li |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Global Advanced Metals |
Listed on the CFS list |
Tantalum (Ta) |
United States |
|
Global Tungsten & Powders Corp |
Listed on the EICC-GeSI list |
Tungsten (W) |
United States |
|
Gold Bell Group |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Gold Mining in Shandong (Laizhou) Limited Company |
Unknown |
Gold (Au) |
China |
|
Golden Egret |
Unknown |
Tungsten (W) |
China |
|
Grant Manufacturing and Alloying |
Unknown |
Tin (Sn) |
United States |
|
Guangdong MingFa Precious Metal Co.,Ltd |
Unknown |
Gold (Au) |
China |
|
GuanXi China Tin Group Co.,LTD |
Unknown |
Tin (Sn) |
China |
|
H.C. Starck GmbH |
Listed on the CFS list |
Tantalum (Ta) |
Germany |
|
H.J.Enthoven & Sons is a division of H.J.Enthoven Ltd - Registered in the UK - Reg. No. 2821551 - Registered Address: Darley Dale Smelter, South Darley, Matlock, DE4 2LP |
Unknown |
Tin (Sn) |
United Kingdon |
|
Harima Smelter |
Unknown |
Gold (Au) |
Japan |
|
HC Starck GmbH |
Listed on the EICC-GeSI list |
Tungsten (W) |
Germany |
|
Heesung Metal |
Unknown |
Gold (Au) |
Korea, Republic of |
|
Heimerle + Meule GmbH |
Listed on the EICC-GeSI list |
Gold (Au) |
Germany |
|
Henan Sanmenxia Lingbao Jinyuan Mining Co., Ltd. |
Unknown |
Gold (Au) |
China |
|
Henan zhongyuan gold smelter |
Unknown |
Gold (Au) |
China |
|
Heraeus Ltd Hong Kong |
Listed on the CFS list |
Gold (Au) |
Hong Kong |
|
Heraeus Precious Metals GmbH & Co. KG |
Listed on the CFS list |
Gold (Au) |
Germany |
|
Hi-Temp |
Listed on the CFS list |
Tantalum (Ta) |
United States |
|
Huichang Jinshunda Tin Co. Ltd |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Hunan Chenzhou Mining Group Co |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
|
Hwasung CJ Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
|
Imperial Zinc Corportion |
Unknown |
Tin (Sn) |
United States |
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
Ishifuku Metal Industry Co., Ltd. |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
|
Istanbul Gold Refinery |
Listed on the EICC-GeSI list |
Gold (Au) |
Turkey |
|
Izawa Metal Co., Ltd |
Unknown |
Tungsten (W) |
Japan |
|
Japan Mint |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
|
Japan New Metals Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
Japan |
|
Japan Pure Chemical |
Unknown |
Gold (Au) |
Japan |
|
Jean Goldschmidt International |
Unknown |
Tin (Sn) |
Belgium |
|
Jhonson Mattehey Inc |
Listed on the CFS list |
Gold (Au) |
United States |
|
Jiangxi Copper Company Limited |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
Jiangxi Nanshan |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
|
Jiangxi Tungsten Industry Group Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
|
Jinlong Copper Co., Ltd. |
Unknown |
Gold (Au) |
China |
|
JiuJiang JinXin Nonferrous Metals Co. Ltd. |
Listed on the EICC-GeSI list |
Tantalum (Ta) |
China |
|
JiuJiang Tambre Co. Ltd. |
Listed on the CFS list |
Tantalum (Ta) |
China |
|
Johnson Matthey Limited |
Listed on the EICC-GeSI list |
Gold (Au) |
Canada |
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Listed on the EICC-GeSI list |
Gold (Au) |
Russian Federation |
|
JX Nippon Mining & Metals Co., Ltd |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Kanfort Industrial (Yantai) Co. Ltd. |
Unknown |
Gold (Au) |
China |
|
Kazzinc Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Kazakhstan |
|
Kemet Blue Powder |
Listed on the CFS list |
Tantalum (Ta) |
United States |
|
Kennametal Inc. |
Listed on the EICC-GeSI list |
Tungsten (W) |
United States |
|
Kihong T&G |
Unknown |
Tin (Sn) |
Indonesia |
|
King-Tan Tantalum Industry Ltd |
Listed on the EICC-GeSI list |
Tantalum (Ta) |
China |
|
KOBA |
Unknown |
Tin (Sn) |
Indonesia |
|
Kojima Chemicals Co,Ltd |
Unknown |
Gold (Au) |
Japan |
|
Korea Metal Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
|
Kundur Smelter |
Unknown |
Tin (Sn) |
Indonesia |
|
Kupol |
Unknown |
Tin (Sn) |
Russian Federation |
|
Kyrgyzaltyn JSC |
Listed on the EICC-GeSI list |
Gold (Au) |
Kyrgyzstan |
|
L' azurde Company For Jewelry |
Listed on the EICC-GeSI list |
Gold (Au) |
Saudi Arabia |
|
Linwu Xianggui Smelter Co |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Liuzhou China Tin |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
LS-Nikko Copper Inc |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
|
Malaysia Smelting Corporation (MSC) |
Listed on the CFS list |
Tin (Sn) |
Malaysia |
|
Materion |
Listed on the CFS list |
Gold (Au) |
United States |
|
Matsuda Sangyo Co. Ltd |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Mentok Smelter |
Unknown |
Tin (Sn) |
Indonesia |
|
Metal Do |
Unknown |
Tantalum (Ta) |
Japan |
|
METALLIC MATERIALS BRANCHL OF GUANGXI CHINA TIN GROUP CO.,LTD |
Unknown |
Tin (Sn) |
China |
|
Metallo Chimique |
Listed on the EICC-GeSI list |
Tin (Sn) |
Belgium |
|
Metalor Technologies (Hong Kong) Ltd |
Listed on the CFS list |
Gold (Au) |
Hong Kong |
|
Met-Mex Peñoles, S.A. |
Listed on the EICC-GeSI list |
Gold (Au) |
Mexico |
|
Mineração Taboca S.A. |
Listed on the EICC-GeSI list |
Tin (Sn) |
Brazil |
|
Minmetals Ganzhou Tin Co. Ltd. |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Minsur |
Listed on the CFS list |
Tin (Sn) |
PERU |
|
Mistubishi Materials Corporation |
Unknown |
Gold (Au) |
Japan |
|
Mitsubishi Materials Corporation |
Listed on the EICC-GeSI list |
Tin (Sn) |
Japan |
|
Mitsui Mining & Smelting |
Listed on the CFS list |
Tantalum (Ta) |
Japan |
|
Mitsui Mining and Smelting Co., Ltd. |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Moscow Special Alloys Processing Plant |
Listed on the EICC-GeSI list |
Gold (Au) |
Russian Federation |
|
MSC Croporation Berhad |
Unknown |
Tin (Sn) |
Malaysia |
|
Nadir Metal Rafineri San. Ve Tic. A.☒. |
Listed on the EICC-GeSI list |
Gold (Au) |
Turkey |
|
Nancang Metal Material Co.,Ltd |
Unknown |
Tin (Sn) |
China |
|
Nanchang Cemented Carbide Limited Liability Company |
Unknown |
Tungsten (W) |
China |
|
Nankang Nanshan Tin Manufactory Co., Ltd. |
Unknown |
Tin (Sn) |
China |
|
Nathan Trotter |
Unknown |
Tin (Sn) |
United States |
|
Navoi Mining and Metallurgical Combinat |
Listed on the EICC-GeSI list |
Gold (Au) |
Uzbekistan |
|
Nihon Material Co. LTD |
Listed on the CFS list |
Gold (Au) |
Japan |
|
NIHON MATERIAL CO.,LTD |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Niihama Nickel Refinery |
Unknown |
Gold (Au) |
Japan |
|
Ningxia, OTIC |
Unknown |
Tantalum (Ta) |
China |
|
Nippon Micrometal Cop |
Unknown |
Tungsten (W) |
Japan |
|
Novosibirsk Integrated Tin Works |
Listed on the EICC-GeSI list |
Tin (Sn) |
Russian Federation |
|
Ohio Precious Metals LLC. |
Listed on the CFS list |
Gold (Au) |
United States |
|
OJSC Kolyma Refinery |
Listed on the EICC-GeSI list |
Gold (Au) |
Russian Federation |
|
OM Manufacturing Phils. Inc. |
Unknown |
Tin (Sn) |
Philippines |
|
OMSA |
Listed on the CFS list |
Tin (Sn) |
Bolivia |
|
PT Tambang Timah |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
|
PAMP SA |
Listed on the CFS list |
Gold (Au) |
Switzerland |
|
Pan Pacific Copper Co Ltd., |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
|
Plansee |
Listed on the CFS list |
Tantalum (Ta) |
Austria |
|
POONGSAN CORPORATION |
Unknown |
Tin (Sn) |
Korea, Republic of |
|
Posco |
Unknown |
Tin (Sn) |
Korea, Republic of |
|
Prioksky Plant of Non-Ferrous Metals |
Listed on the EICC-GeSI list |
Gold (Au) |
Russian Federation |
|
PT Alam Lestari Kencana |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
|
PT Aneka Tambang (Persero) Tbk |
Listed on the EICC-GeSI list |
Gold (Au) |
Indonesia |
|
PT Timah |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
|
PT.DS JAYA ABADI |
Listed on the EICC-GeSI list |
Tin (Sn) |
Indonesia |
|
PT.Indra Eramulti Logam Industri |
Unknown |
Tin (Sn) |
Indonesia |
|
PX Précinox SA |
Listed on the EICC-GeSI list |
Gold (Au) |
Switzerland |
|
Rahman Hydrulic Tin Sdn Bhd |
Unknown |
Tin (Sn) |
Malaysia |
|
Rand Refinery (Pty) Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
South Africa |
|
RFH |
Listed on the CFS list |
Tantalum (Ta) |
China |
|
Royal Canadian Mint |
Listed on the CFS list |
Gold (Au) |
Canada |
|
Rui Da Hung |
Unknown |
Tin (Sn) |
Taiwan |
|
Sabin |
Listed on the EICC-GeSI list |
Gold (Au) |
United States |
|
Schone Edelmetaal |
Listed on the EICC-GeSI list |
Gold (Au) |
Netherlands |
|
Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
Shyolkovsky |
Listed on the EICC-GeSI list |
|
Russian Federation |
|
Sincemat Co, Ltd |
Unknown |
Tungsten (W) |
China |
|
So Accurate Refing Group |
Unknown |
Gold (Au) |
United States |
|
Solar Applied Materials Technology Corp. |
Listed on the EICC-GeSI list |
Gold (Au) |
Taiwan |
|
Solikamsk Metal Works |
Listed on the CFS list |
Tantalum (Ta) |
Russian Federation |
|
Sumitomo Metal Mining Co. Ltd. |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Suzhou Xingrui Noble |
Listed on the EICC-GeSI list |
|
China |
|
Tanaka Kikinzoku Kogyo K.K. |
Listed on the CFS list |
Gold (Au) |
Japan |
|
Tantalite Resources |
Listed on the CFS list |
Tantalum (Ta) |
South Africa |
|
Tejing (Vietnam) Tungsten Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
Vietnam |
|
Telex |
Listed on the CFS list |
Tantalum (Ta) |
United States |
|
Thailand Smelting & Refining Co Ltd |
Unknown |
Tin (Sn) |
Thailand |
|
Thaisarco |
Listed on the CFS list |
Tin (Sn) |
Thailand |
|
The Great Wall Gold and Silver Refinery of China |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
The Refinery of Shandong Gold Mining Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
Tokuriki Honten Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
|
TongLing Nonferrous Metals Group Holdings Co;Ltd |
Unknown |
Gold (Au) |
China |
|
Torecom |
Listed on the EICC-GeSI list |
Gold (Au) |
Korea, Republic of |
|
Traxys |
Unknown |
Tin (Sn) |
France |
|
Ulba |
Listed on the CFS list |
Tantalum (Ta) |
Kazakhstan |
|
Umicore Haboken |
Unknown |
Tin (Sn) |
Belgium |
|
Umicore SA Business Unit Precious Metals Refining |
Listed on the CFS list |
Gold (Au) |
Belgium |
|
United Precious Metal Refining, Inc. |
Listed on the CFS list |
Gold (Au) |
United States |
|
Valcambi SA |
Listed on the EICC-GeSI list |
Gold (Au) |
Switzerland |
|
Voss Metals Company, Inc. |
Unknown |
Tungsten (W) |
United States |
|
Western Australian Mint trading as The Perth Mint |
Listed on the CFS list |
Gold (Au) |
Australia |
|
White Solder Metalurgia |
Listed on the EICC-GeSI list |
Tin (Sn) |
Brazil |
|
WILLIAMS GOLD REFINING CO INC |
Unknown |
Gold (Au) |
United States |
|
Williams Gold Refining Company |
Unknown |
Gold (Au) |
Canada |
|
Wolfram Bergbau und Hütten AG |
Listed on the EICC-GeSI list |
Tungsten (W) |
Austria |
|
Wuxi Middle Treasure Materials |
Unknown |
Gold (Au) |
China |
|
Xiamen Honglu Tungsten Molybdenum Co., Ltd. |
Unknown |
Tungsten (W) |
China |
|
Xiamen Tungsten Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
|
Xstrata Canada Corporation |
Listed on the EICC-GeSI list |
Gold (Au) |
Canada |
|
Yamamoto Precious Metal Co., Ltd. |
Unknown |
Gold (Au) |
Japan |
|
Yifeng Tin Industry (Chenzhou) Co Ltd |
Unknown |
Tin (Sn) |
China |
|
Yokohama Metal Co Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
Japan |
|
Yunnan Chengfeng |
Listed on the EICC-GeSI list |
Tin (Sn) |
China |
|
Yunnan Tin Company Limited |
Listed on the CFS list |
Tin (Sn) |
China |
|
Zhongjin Gold Corporation |
Unknown |
Gold (Au) |
China |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
|
Zhuzhou Cement Carbide |
Listed on the CFS list |
Tantalum (Ta) |
China |
|
Zhuzhou Cemented Carbide Group Co Ltd |
Listed on the EICC-GeSI list |
Tungsten (W) |
China |
|
Zijin Mining Group Co. Ltd |
Listed on the EICC-GeSI list |
Gold (Au) |
China |
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, certain smelter and refiner facilities (1) had not yet received a “conflict free” designation from an independent third party audit program and (2) did not respond to our requests for country of origin or chain of custody information.
Planned Steps to Improve Due Diligence
We intend to take the following steps to improve our due diligence program:
|
1. |
Include a conflict minerals flow-down clause in new or renewed supplier contracts. |
|
2. |
Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |