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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
FORM SD |
OMB APPROVAL OMB Number: 3235-0697 Expires: May 31, 2016 |
Specialized Disclosure Report
Spartan Motors, Inc
(Exact name of registrant as specified in its charter)
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Michigan |
000-13611 |
38-2078923 |
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(State or other jurisdiction |
(Commission |
(IRS Employer |
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of incorporation or organization) |
File Number) |
Identification No.) |
| 1541 Reynolds Road | ||
| Charlotte, Michigan | 48813 | |
| (Address of principal executive offices) | (Zip Code) |
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Frederick J. Sohm (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, 2016
SECTION 1 – CONFLICT MINERALS DISCLOSURE
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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, 2016 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/investor-relations-old/sec-filings/.
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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
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Item 2.01 |
Exhibits |
1.01 Conflict Minerals Report for Spartan Motors, Inc. for the period January 1 to December 31, 2016.
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.
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Spartan Motors, Inc. |
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(Registrant) |
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/s/Frederick J. Sohm |
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May 30, 2017 |
| By: Frederick J. Sohm | Date | ||
| Its: Chief Financial Officer | |||
EX-1.01 2 ex1-01.htm EXHIBIT 1.01
Exhibit 1.01
Spartan Motors, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016
This report for the calendar year ended December 31, 2016, 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; Kansas City, Missouri; and Saltillo, Mexico. Spartan USA was formerly known as Crimson Fire, Inc. As a result of a recent acquisition described below, we now also have facilities in Snyder and Neligh, Nebraska; Delavan, Wisconsin; and a second location in Ephrata, Pennsylvania.
Our Charlotte, Michigan location manufactures heavy duty chassis and vehicles and supplies aftermarket parts and assemblies under the Spartan Chassis and Spartan ERV brand names. Our Brandon, South Dakota, Snyder, Nebraska, Delavan, Wisconsin and Ephrata, Pennsylvania locations manufacture emergency response vehicles under the Spartan ER brand name. Our Bristol, Indiana location manufactures delivery 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 2016 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 2016 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 (I-Point). 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 2016 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 consulting Conflict Minerals platform (IPoint). 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.
The number of supplier responses has decreased from the last reporting year due to our attempt to require software only reporting. Many suppliers refused to work in chosen software or experienced difficulty in navigating the software. It is our intention 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 2016 reporting year, we received responses from 13 percent of all of the suppliers surveyed. The 2016 data collected included the names of 243 entities listed by our suppliers as smelters or refiners. 186 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.
Below is the list of smelters and refiners was provided by the responding suppliers and otherwise obtained through our due diligence process. Since reporting was completed at a company level, we are not able to determine with certainty that these are actually used in our supply chain.
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Metal (*) |
Smelter Name (*) |
Smelter Country (*) |
Smelter Identification |
CFSI Validated as Conflict Free |
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Tungsten |
A.L.M.T. TUNGSTEN Corp. |
JAPAN |
CID000004 |
YES |
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Gold |
Advanced Chemical Company |
UNITED STATES OF AMERICA |
CID000015 |
YES |
|
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
CID000019 |
YES |
|
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY |
CID000035 |
YES |
|
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
CID000041 |
YES |
|
Gold |
AngloGold Ashanti Córrego do Sítio Mineração |
BRAZIL |
CID000058 |
YES |
|
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
CID000077 |
YES |
|
Gold |
Asahi Pretec Corp. |
JAPAN |
CID000082 |
YES |
|
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
CID000090 |
YES |
|
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
CID000103 |
NO |
|
Tungsten |
Kennametal Huntsville |
UNITED STATES OF AMERICA |
CID000105 |
YES |
|
Gold |
Aurubis AG |
GERMANY |
CID000113 |
YES |
|
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
CID000128 |
YES |
|
Gold |
Boliden AB |
SWEDEN |
CID000157 |
YES |
|
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
CID000176 |
YES |
|
Gold |
Caridad |
MEXICO |
CID000180 |
NO |
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Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
CID000185 |
YES |
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Gold |
Cendres + Métaux S.A. |
SWITZERLAND |
CID000189 |
NO |
|
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
CID000211 |
YES |
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Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
CID000218 |
YES |
|
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
CID000228 |
YES |
|
Gold |
Chimet S.p.A. |
ITALY |
CID000233 |
YES |
|
Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
CHINA |
CID000244 |
YES |
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
CID000258 |
YES |
|
Gold |
Chugai Mining |
JAPAN |
CID000264 |
NO |
|
Tin |
CNMC (Guangxi) PGMA Co., Ltd. |
CHINA |
CID000278 |
NO |
|
Tantalum |
Conghua Tantalum and Niobium Smeltry |
CHINA |
CID000291 |
YES |
|
Tin |
Alpha |
UNITED STATES OF AMERICA |
CID000292 |
YES |
|
Tin |
Cooperativa Metalurgica de Rondônia Ltda. |
BRAZIL |
CID000295 |
YES |
|
Tin |
CV Gita Pesona |
INDONESIA |
CID000306 |
YES |
|
Tin |
PT Justindo |
INDONESIA |
CID000307 |
NO |
|
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
CID000309 |
YES |
|
Tin |
CV Serumpun Sebalai |
INDONESIA |
CID000313 |
YES |
|
Tin |
CV United Smelting |
INDONESIA |
CID000315 |
YES |
|
Gold |
Daejin Indus Co., Ltd. |
KOREA (REPUBLIC OF) |
CID000328 |
YES |
|
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
CID000343 |
NO |
|
Tungsten |
Dayu Weiliang Tungsten Co., Ltd. |
CHINA |
CID000345 |
NO |
|
Gold |
DSC (Do Sung Corporation) |
KOREA (REPUBLIC OF) |
CID000359 |
YES |
|
Gold |
DODUCO GmbH |
GERMANY |
CID000362 |
YES |
|
Gold |
Dowa |
JAPAN |
CID000401 |
YES |
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Tin |
Dowa |
JAPAN |
CID000402 |
YES |
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Tantalum |
Duoluoshan |
CHINA |
CID000410 |
YES |
|
Gold |
Eco-System Recycling Co., Ltd. |
JAPAN |
CID000425 |
YES |
|
Tin |
EM Vinto |
BOLIVIA (PLURINATIONAL STATE OF) |
CID000438 |
YES |
|
Tin |
Estanho de Rondônia S.A. |
BRAZIL |
CID000448 |
NO |
|
Tantalum |
Exotech Inc. |
UNITED STATES OF AMERICA |
CID000456 |
YES |
|
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
CID000460 |
YES |
|
Tin |
Fenix Metals |
POLAND |
CID000468 |
YES |
|
Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
CID000493 |
YES |
|
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
CID000499 |
YES |
|
Gold |
Gansu Seemine Material Hi-Tech Co., Ltd. |
CHINA |
CID000522 |
NO |
|
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
CID000538 |
YES |
|
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
CID000555 |
NO |
|
Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES OF AMERICA |
CID000568 |
YES |
|
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA |
CID000616 |
YES |
|
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
CID000671 |
NO |
|
Gold |
Heimerle + Meule GmbH |
GERMANY |
CID000694 |
YES |
|
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
CID000707 |
YES |
|
Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY |
CID000711 |
YES |
|
Tantalum |
Hi-Temp Specialty Metals, Inc. |
UNITED STATES OF AMERICA |
CID000731 |
YES |
|
Tin |
Huichang Jinshunda Tin Co., Ltd. |
CHINA |
CID000760 |
NO |
|
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
CID000766 |
YES |
|
Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
CID000767 |
NO |
|
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA |
CID000769 |
YES |
|
Gold |
Hwasung CJ Co., Ltd. |
KOREA (REPUBLIC OF) |
CID000778 |
NO |
|
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
CID000801 |
YES |
|
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
CID000807 |
YES |
|
Gold |
Istanbul Gold Refinery |
TURKEY |
CID000814 |
YES |
|
Gold |
Japan Mint |
JAPAN |
CID000823 |
YES |
|
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
CID000825 |
YES |
|
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
CID000855 |
YES |
|
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
CID000875 |
YES |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
CID000914 |
YES |
|
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
CID000917 |
YES |
|
Gold |
Asahi Refining USA Inc. |
UNITED STATES OF AMERICA |
CID000920 |
YES |
|
Gold |
Asahi Refining Canada Ltd. |
CANADA |
CID000924 |
YES |
|
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
CID000927 |
YES |
|
Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
CID000929 |
YES |
|
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
CID000937 |
YES |
|
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
CID000942 |
NO |
|
Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
CID000956 |
NO |
|
Gold |
Kazzinc |
KAZAKHSTAN |
CID000957 |
YES |
|
Tungsten |
Kennametal Fallon |
UNITED STATES OF AMERICA |
CID000966 |
YES |
|
Gold |
Kennecott Utah Copper LLC |
UNITED STATES OF AMERICA |
CID000969 |
YES |
|
Tantalum |
King-Tan Tantalum Industry Ltd. |
CHINA |
CID000973 |
YES |
|
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
CID000981 |
YES |
|
Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
CID001029 |
YES |
|
Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
CID001032 |
NO |
|
Gold |
Lingbao Gold Co., Ltd. |
CHINA |
CID001056 |
NO |
|
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
CID001058 |
NO |
|
Tin |
China Tin Group Co., Ltd. |
CHINA |
CID001070 |
YES |
|
Tantalum |
LSM Brasil S.A. |
BRAZIL |
CID001076 |
YES |
|
Gold |
LS-NIKKO Copper Inc. |
KOREA (REPUBLIC OF) |
CID001078 |
YES |
|
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
CID001093 |
NO |
|
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
CID001105 |
YES |
|
Gold |
Materion |
UNITED STATES OF AMERICA |
CID001113 |
YES |
|
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
CID001119 |
YES |
|
Tin |
Metallic Resources, Inc. |
UNITED STATES OF AMERICA |
CID001142 |
YES |
|
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
CID001147 |
YES |
|
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
CID001149 |
YES |
|
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
CID001152 |
YES |
|
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
CID001153 |
YES |
|
Gold |
Metalor USA Refining Corporation |
UNITED STATES OF AMERICA |
CID001157 |
YES |
|
Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
MEXICO |
CID001161 |
YES |
|
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
CID001163 |
YES |
|
Tin |
Mineração Taboca S.A. |
BRAZIL |
CID001173 |
YES |
|
Tantalum |
Mineração Taboca S.A. |
BRAZIL |
CID001175 |
YES |
|
Tin |
Minsur |
PERU |
CID001182 |
YES |
|
Gold |
Mitsubishi Materials Corporation |
JAPAN |
CID001188 |
YES |
|
Tin |
Mitsubishi Materials Corporation |
JAPAN |
CID001191 |
YES |
|
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
CID001192 |
YES |
|
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
CID001193 |
YES |
|
Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
CID001204 |
YES |
|
Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
TURKEY |
CID001220 |
YES |
|
Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. |
CHINA |
CID001231 |
NO |
|
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
CID001236 |
NO |
|
Gold |
Nihon Material Co., Ltd. |
JAPAN |
CID001259 |
YES |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
CID001277 |
YES |
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
CID001314 |
YES |
|
Gold |
Elemetal Refining, LLC |
UNITED STATES OF AMERICA |
CID001322 |
NO |
|
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
CID001325 |
YES |
|
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
CID001326 |
YES |
|
Tin |
Operaciones Metalurgical S.A. |
BOLIVIA (PLURINATIONAL STATE OF) |
CID001337 |
YES |
|
Gold |
PAMP S.A. |
SWITZERLAND |
CID001352 |
YES |
|
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
CID001362 |
NO |
|
Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
CID001386 |
YES |
|
Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
CID001397 |
YES |
|
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
CID001399 |
YES |
|
Tin |
PT Babel Inti Perkasa |
INDONESIA |
CID001402 |
YES |
|
Tin |
PT Bangka Tin Industry |
INDONESIA |
CID001419 |
YES |
|
Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
CID001421 |
YES |
|
Tin |
PT Bukit Timah |
INDONESIA |
CID001428 |
YES |
|
Tin |
PT DS Jaya Abadi |
INDONESIA |
CID001434 |
YES |
|
Tin |
PT Eunindo Usaha Mandiri |
INDONESIA |
CID001438 |
YES |
|
Tin |
PT Karimun Mining |
INDONESIA |
CID001448 |
YES |
|
Tin |
PT Mitra Stania Prima |
INDONESIA |
CID001453 |
YES |
|
Tin |
PT Panca Mega Persada |
INDONESIA |
CID001457 |
YES |
|
Tin |
PT Prima Timah Utama |
INDONESIA |
CID001458 |
YES |
|
Tin |
PT Refined Bangka Tin |
INDONESIA |
CID001460 |
YES |
|
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
CID001463 |
YES |
|
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
CID001468 |
YES |
|
Tin |
PT Sumber Jaya Indah |
INDONESIA |
CID001471 |
YES |
|
Tin |
PT Timah (Persero) Tbk Mentok |
INDONESIA |
CID001482 |
YES |
|
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
CID001490 |
YES |
|
Tin |
PT Tommy Utama |
INDONESIA |
CID001493 |
YES |
|
Tantalum |
QuantumClean |
UNITED STATES OF AMERICA |
CID001508 |
YES |
|
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
CID001512 |
YES |
|
Tantalum |
RFH Tantalum Smeltry Co., Ltd. |
CHINA |
CID001522 |
YES |
|
Gold |
Royal Canadian Mint |
CANADA |
CID001534 |
YES |
|
Tin |
Rui Da Hung |
TAIWAN, PROVINCE OF CHINA |
CID001539 |
YES |
|
Gold |
Sabin Metal Corp. |
UNITED STATES OF AMERICA |
CID001546 |
NO |
|
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
CID001908 |
NO |
|
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
CID001909 |
NO |
|
Gold |
Morris and Watson |
NEW ZEALAND |
CID002282 |
NO |
|
Gold |
Guangdong Jinding Gold Limited |
CHINA |
CID002312 |
NO |
|
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
CID002313 |
NO |
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
CID002315 |
YES |
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
CID002316 |
YES |
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
CID002317 |
YES |
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
CID002318 |
YES |
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
CID002319 |
YES |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
CID002321 |
YES |
|
Tin |
CV Venus Inti Perkasa |
INDONESIA |
CID002455 |
YES |
|
Gold |
Geib Refining Corporation |
UNITED STATES OF AMERICA |
CID002459 |
YES |
|
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
CID002468 |
YES |
|
Tin |
PT Tirus Putra Mandiri |
INDONESIA |
CID002478 |
NO |
|
Tin |
PT Wahana Perkit Jaya |
INDONESIA |
CID002479 |
NO |
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
CID002492 |
YES |
|
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
CID002494 |
YES |
|
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
CID002500 |
YES |
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
CID002502 |
YES |
|
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
CID002503 |
YES |
|
Tantalum |
D Block Metals, LLC |
UNITED STATES OF AMERICA |
CID002504 |
YES |
|
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
CID002505 |
YES |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
CID002506 |
YES |
|
Tin |
Phoenix Metal Ltd. |
RWANDA |
CID002507 |
NO |
|
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
CID002509 |
YES |
|
Gold |
Republic Metals Corporation |
UNITED STATES OF AMERICA |
CID002510 |
YES |
|
Gold |
KGHM Polska Miedź Spółka Akcyjna |
POLAND |
CID002511 |
NO |
|
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
CID002512 |
YES |
|
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA |
CID002513 |
YES |
|
Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
CID002515 |
NO |
|
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
CID002517 |
YES |
|
Tungsten |
Dayu Jincheng Tungsten Industry Co., Ltd. |
CHINA |
CID002518 |
NO |
|
Tin |
PT Inti Stania Prima |
INDONESIA |
CID002530 |
YES |
|
Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. |
CHINA |
CID002536 |
NO |
|
Tantalum |
KEMET Blue Metals |
MEXICO |
CID002539 |
YES |
|
Tantalum |
Plansee SE Liezen |
AUSTRIA |
CID002540 |
NO |
|
Tungsten |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY |
CID002542 |
YES |
|
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIET NAM |
CID002543 |
YES |
|
Tantalum |
H.C. Starck Co., Ltd. |
THAILAND |
CID002544 |
YES |
|
Tantalum |
H.C. Starck GmbH Laufenburg |
GERMANY |
CID002546 |
NO |
|
Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY |
CID002547 |
YES |
|
Tantalum |
H.C. Starck Inc. |
UNITED STATES OF AMERICA |
CID002548 |
YES |
|
Tantalum |
H.C. Starck Ltd. |
JAPAN |
CID002549 |
YES |
|
Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY |
CID002550 |
YES |
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
CID002551 |
YES |
|
Tantalum |
Plansee SE Reutte |
AUSTRIA |
CID002556 |
NO |
|
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES OF AMERICA |
CID002557 |
YES |
|
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
CID002558 |
YES |
|
Gold |
Al Etihad Gold LLC |
UNITED ARAB EMIRATES |
CID002560 |
YES |
|
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
CID002561 |
YES |
|
Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
CID002563 |
NO |
|
Tantalum |
KEMET Blue Powder |
UNITED STATES OF AMERICA |
CID002568 |
YES |
|
Tin |
CV Ayi Jaya |
INDONESIA |
CID002570 |
YES |
|
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
CID002572 |
NO |
|
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
CID002573 |
NO |
|
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA |
CID002579 |
YES |
|
Gold |
Remondis Argentia B.V. |
NETHERLANDS |
CID002582 |
NO |
|
Tungsten |
Niagara Refining LLC |
UNITED STATES OF AMERICA |
CID002589 |
YES |
|
Tantalum |
E.S.R. Electronics |
UNITED STATES OF AMERICA |
CID002590 |
NO |
|
Tin |
CV Dua Sekawan |
INDONESIA |
CID002592 |
YES |
|
Tin |
CV Tiga Sekawan |
INDONESIA |
CID002593 |
YES |
|
Gold |
Korea Zinc Co., Ltd. |
KOREA (REPUBLIC OF) |
CID002605 |
YES |
|
Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CHINA |
CID002647 |
NO |
|
Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
CID002649 |
YES |
|
Tin |
PT Cipta Persada Mulia |
INDONESIA |
CID002696 |
NO |
|
Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
CID002703 |
NO |
|
Tin |
Resind Indústria e Comércio Ltda. |
BRAZIL |
CID002706 |
YES |
|
Tantalum |
Resind Indústria e Comércio Ltda. |
BRAZIL |
CID002707 |
YES |
|
Gold |
Abington Reldan Metals, LLC |
UNITED STATES OF AMERICA |
CID002708 |
NO |
|
Gold |
SAAMP |
FRANCE |
CID002761 |
NO |
|
Tin |
Metallo-Chimique N.V. |
BELGIUM |
CID002773 |
YES |
|
Tin |
PT Bangka Prima Tin |
INDONESIA |
CID002776 |
YES |
|
Tin |
PT Sukses Inti Makmur |
INDONESIA |
CID002816 |
YES |
|
Tin |
An Thai Minerals Co., Ltd. |
VIET NAM |
CID002825 |
NO |
|
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
CID002827 |
YES |
|
Tin |
PT Kijang Jaya Mandiri |
INDONESIA |
CID002829 |
YES |
|
Tungsten |
ACL Metais Eireli |
BRAZIL |
CID002833 |
NO |
|
Tin |
PT Menara Cipta Mulia |
INDONESIA |
CID002835 |
YES |
|
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
CID002842 |
YES |
|
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
CID002844 |
YES |
|
Tungsten |
Moliren Ltd |
RUSSIAN FEDERATION |
CID002845 |
YES |
|
Tantalum |
Power Resources Ltd. |
MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
CID002847 |
YES |
|
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA |
CID002848 |
YES |
|
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CHINA |
CID002849 |
YES |
|
Gold |
AU Traders and Refiners |
SOUTH AFRICA |
CID002850 |
YES |
|
Gold |
AURA-II |
UNITED STATES OF AMERICA |
CID002851 |
NO |
|
Gold |
Gujarat Gold Centre |
INDIA |
CID002852 |
NO |
|
Gold |
Modeltech Sdn Bhd |
MALAYSIA |
CID002857 |
NO |
|
Tin |
Modeltech Sdn Bhd |
MALAYSIA |
CID002858 |
NO |
|
Tin |
Gejiu Jinye Mineral Company |
CHINA |
CID002859 |
YES |
|
Gold |
Bangalore Refinery |
INDIA |
CID002863 |
NO |
|
Tin |
PT Lautan Harmonis Sejahtera |
INDONESIA |
CID002870 |
YES |
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 had not yet received a “conflict free” designation from an independent third party.
2016 Improvement Review
Supplier education is a priority for Spartan Motors. We are committed to continuing to educate and support our suppliers and internal staff. Through our supplier feedback process we have learned that mandating software only reporting is not feasible. With these lessons learned we are now able to move forward, understanding that a new software platform may be required as well as allowing the use of Excel versions of the template.
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 suppliers to reference the CFSI list of smelters when completing their CMRT report. |
|
2. |
Provide educational materials to suppliers annually that include instructions and any updates when completing their CMRT reports. |
|
3. |
Review alternative software that will be easier for suppliers to navigate and more consistent |
|
4. |
Review more efficient ways to accept and review Excel versions of CMRT |
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