UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
Specialized Disclosure Report
___________________________________________________________________________________________________________________
ACUITY BRANDS, INC.
(Exact name of registrant as specified in its charter)
___________________________________________________________________________________________________________________
Delaware | 001-16583 | 58-2632672 |
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (I.R.S. Employer Identification Number) |
1170 Peachtree Street, N.E., Suite 2300, Atlanta, Georgia (Address of principal executive offices) | 30309-7676 (Zip Code) | |
Richard K. Reece, (404) 853-1400
(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:
þ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
___________________________________________________________________________________________________________________
Introduction
This Specialized Disclosure Report on Form SD ("Form SD") of Acuity Brands, Inc. ("Acuity Brands" or the "Company") for the year ended December 31, 2017 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (the metal ore from which tantalum is extracted), cassiterite (the metal ore from which tin is extracted), gold, wolframite (the metal ore from which tungsten is extracted), or their derivatives (collectively, the "Subject Minerals"). The Rule requires certain registrants to conduct a reasonable country of origin inquiry ("RCOI") designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo ("DRC"), or an adjoining country (collectively, the "Covered Countries").
Company Overview
Acuity Brands is one of the world's leading providers of lighting and building management solutions and services for commercial, institutional, industrial, infrastructure, and residential applications throughout North America and select international markets. The Company’s lighting and building management solutions include devices such as luminaires, lighting controls, controllers for various building systems, power supplies, prismatic skylights, and drivers, as well as integrated systems designed to optimize energy efficiency and comfort for various indoor and outdoor applications. Additionally, the Company continues to expand its solutions portfolio, including software and services, to provide a host of other economic benefits resulting from data analytics that enables the Internet of Things and supports the advancement of smart buildings, smart cities, and the smart grid, and allows businesses to develop custom applications to scale their operations. The Company manufactures or procures lighting and building management devices primarily in North America, Europe, and Asia. The production or functionality of certain of the Company's devices requires components such as circuit boards, capacitors, metal wires, electrodes, and other electronic components that contain the Subject Minerals. Consequently, the Company is subject to the disclosure and reporting requirements of the Rule.
Supply Chain Description
The Company utilizes a blend of internal and outsourced manufacturing processes and capabilities to fulfill a variety of customer needs in the most cost-effective manner. The Company operates 19 manufacturing facilities in North America and Europe. The Company also purchases certain components and finished goods from a broad network of suppliers located primarily in the U.S., Asia, and Europe. While some of the Company's products contain the Subject Minerals, the Company does not procure ore or unrefined minerals directly from mines and is many steps removed from the mining of the Subject Minerals. The origin of the Subject Minerals cannot be determined with any certainty once the ores are smelted, refined, and converted to ingots, bullion, or other mineral derivatives. The smelters and refiners are consolidating points for ore and, therefore, are in the best position to identify the origin of the ore. The Company relies on its suppliers to provide accurate information, including the identification of smelters and refiners, during its RCOI and due diligence procedures.
SECTION 1 - CONFLICT MINERALS DISCLOSURE
Item 1.01. Conflict Minerals Disclosure and Report.
Description of Reasonable Country of Origin Inquiry Efforts
For the 2017 reporting year, the Company conducted a supply chain survey with direct suppliers to determine the origin of the Subject Minerals using the Conflict Minerals Reporting Template. Specifically, the survey requests direct suppliers to identify the smelters and refiners as well as the countries of origin for Subject Minerals contained in the products they sell to the Company. Management reviewed the responses and compared the smelters and refiners identified in the surveys against the lists of facilities with a "conflict free" designation by the Responsible Minerals Assurance Process ("RMAP") or other independent third-party audit program. The Company's procedures for the RCOI and due diligence process are overlapping in nature; therefore, this report should be read in conjunction with the Company's Conflict Minerals Report filed as Exhibit 1.01 of this filing.
Conclusion Based on Reasonable Country of Origin Inquiry
Based on its RCOI, the Company believes it is possible that certain of the Subject Minerals used in its products may have originated in the Covered Countries and may not be from recycled or scrap sources. As discussed in the attached Conflict Minerals Report, the Company has insufficient information from suppliers or other sources regarding all of the smelters and refiners that processed the Subject Minerals to conclude whether the Subject Minerals originated in the Covered Countries.
Conflict Minerals Disclosure
The Conflict Minerals Report for the calendar year ended December 31, 2017, filed herewith as Exhibit 1.01, is publicly available at www.acuitybrands.com, but the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.
This Form SD and the Conflict Minerals Report filed as Exhibit 1.01 contain statements that are forward looking, as that term is defined by the Private Securities Litigation Reform Act of 1995 or by the SEC in its rules, regulations and releases. Forward-looking statements also include any statement that is not based on historical fact, including statements containing the words "believes," "may," "plans," "will," "could," "should," "estimates," "continues," "anticipates," "intends," "expects," and similar expressions. The Company intends that such forward-looking statements be subject to the safe harbors created thereby. All forward-looking statements are based on current expectations regarding important risk factors and should not be regarded as a representation by the Company or any other person that the results expressed therein will be achieved. The Company assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in the Company’s reports, including its Form 10-K for the fiscal year ended August 31, 2017 and other forms filed by the Company with the SEC.
Item 1.02 Exhibit
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.
Exhibit 1.01 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. |
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 undersigned thereunto duly authorized.
Date: May 31, 2018
ACUITY BRANDS, INC. | ||
By: | /s/ Richard K. Reece | |
Richard K. Reece | ||
Executive Vice President and Chief Financial Officer | ||
Exhibit 1.01
Acuity Brands, Inc.
Conflict Minerals Report
For Calendar Year Ended December 31, 2017
This Conflict Minerals Report of Acuity Brands, Inc. ("Acuity Brands" or the "Company") for the year ended December 31, 2017 is filed to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (the metal ore from which tantalum is extracted), cassiterite (the metal ore from which tin is extracted), gold, wolframite (the metal ore from which tungsten is extracted), or their derivatives (collectively, the "Subject Minerals"). The Rule requires certain registrants to conduct a reasonable country of origin inquiry ("RCOI") designed to determine whether any of the Subject Minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively, the "Covered Countries").
Pursuant to the Rule, the Company performed due diligence procedures on the source and chain of custody of the Subject Minerals that are included in its products and for which, based on its RCOI, the Company believes it is possible that some may have originated from the Covered Countries and may not be from recycled or scrap sources.
Design of Due Diligence
The Company implemented a due diligence framework consistent with the Organization of Economic Co-Operation and Development's ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum, and Tungsten and Gold (collectively, "OECD Guidance"). Summarized below are the design components of the Company's procedures as they relate to the five-step framework set forth in the OECD Guidance:
1) Establish strong company management systems:
• | Publish and maintain a conflict minerals policy, which is available at http://www.acuitybrands.com/resources/regulations-codes-and-standards/conflict-minerals. |
• | Adopt and maintain a conflict minerals governance charter, which defines the internal committee supporting compliance and due diligence efforts and the responsibilities of the internal committee. |
• | Periodically review conflict minerals procedures with the Company's Chief Financial Officer and Audit Committee of the Board of Directors. |
• | Utilize a conflict minerals compliance process, including the RCOI procedures described in the Form SD. |
• | Incorporate requirements related to conflict minerals in the Company's standard supplier agreements and purchase order terms and conditions to obligate current and future suppliers to comply with the Company's conflict minerals policy, including participation in the supply chain survey and related due diligence activities. |
• | Maintain records related to the RCOI and due diligence procedures in accordance with the Company's retention policy. |
• | Facilitate employee, supplier, or other stakeholder grievance reporting through the Company's website. |
2) Identify and assess risks in our supply chain:
• | Identify raw material components that may contain one or more of the Subject Minerals. |
• | Identify finished goods that may contain one or more of the Subject Minerals for which the Company contracted to manufacture the finished goods. |
• | Identify the direct suppliers that provided the raw material components and finished goods that may contain one or more of the Subject Minerals. |
• | Conduct a supply chain survey using the Conflict Minerals Reporting Template ("CMRT"), requesting direct suppliers to identify smelters and refiners as well as the country of origin of the Subject Minerals in the products they sell to the Company. |
• | Follow up with non-responsive suppliers by requesting compliance with the Company's request for information. |
• | Review all responses received from suppliers based on the Company's conflict minerals compliance process and request supplemental information from suppliers providing responses that are deemed implausible, incomplete, inaccurate, or otherwise require clarification. |
• | Compare smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict-free" designation from the Responsible Minerals Assurance Process ("RMAP") or other |
independent third party audit program; these designations also provide country of origin and due diligence information on the Subject Minerals sourced by such facilities.
3) Design and implement a strategy to respond to identified risks:
• | Publish and maintain a conflict minerals policy. |
• | Utilize a risk management plan that outlines the Company's response to identified risks. |
• | Perform risk mitigation efforts to bring suppliers into conformity with the Company's conflict minerals policy. |
• | Provide, on a periodic basis, progress reports to the Company's Chief Financial Officer and the Audit Committee of the Board of Directors summarizing risk mitigation efforts. |
• | When required by the Rule, obtain an independent private sector audit of this Report. |
4) Support the development and implementation of independent third party audits of smelters' and refiners' sourcing:
• | Utilize multi-industry due diligence initiatives, including RMAP, to evaluate the procurement practices of the smelters and refiners that process and provide the Subject Minerals used in the Company's products. |
5) Report on supply chain due diligence:
• | Communicate the Company's conflict minerals policy publicly on the Company's website at http://www.acuitybrands.com/resources/regulations-codes-and-standards/conflict-minerals. |
• | Annually file a Conflict Minerals Report with the SEC and publish on the Company's website at http://www.acuitybrands.com. |
The content of any website referred to in this report is included for general information only and is not incorporated by reference in this filing.
Due Diligence Measures Performed
Below is a description of the measures performed for the 2017 reporting period to exercise due diligence on the source and chain of custody of the Subject Minerals contained in the Company's products that the Company believes may have originated from the Covered Countries and may not be from recycled or scrap sources:
• | Utilized a risk management plan that outlines the Company's response to identified risks. |
• | Followed up with non-responsive suppliers by requesting compliance with the Company's request for information. |
• | Reviewed all responses received from suppliers based on the Company's conflict minerals compliance process and requested supplemental information from suppliers providing responses that were deemed implausible, incomplete, inaccurate, or otherwise required clarification. |
• | Compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict-free" designation from the RMAP or other independent third party audit program; these designations provide country of origin and due diligence information on the Subject Minerals sourced by such facilities. |
• | Performed risk mitigation efforts to bring suppliers into conformity with the Company's conflict minerals policy. |
• | Provided periodic progress reports to the Company's Chief Financial Officer and the Audit Committee of the Board of Directors summarizing risk mitigation efforts. |
• | Identified improvement opportunities within the Company's conflict minerals compliance process and developed corrective action plans. |
Results of Due Diligence Measures
Inherent Limitations on Due Diligence Measures
As an indirect purchaser of the Subject Minerals, the Company's due diligence efforts can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Subject Minerals. The Company is dependent on the data obtained from direct suppliers and in turn, the data those suppliers obtain from within their supply chains to identify sources of the Subject Minerals. In addition, the Company relies on the information collected by independent third party audit programs. These sources of information may yield incomplete or inaccurate data and may be subject to fraud.
Product Determination
Based on due diligence procedures performed in this report, the Company does not have sufficient information to conclusively confirm the country of origin or chain of custody of the Subject Minerals used in its products. The Company received company-level responses from certain of its suppliers with extensive lists of smelters without product-based information. As a result, the Company was unable to verify that Subject Minerals from these smelters were used in its products. Based on the information provided by the Company's suppliers, the Company believes some subset of the smelters and refiners listed in Table I potentially produced certain of the Subject Minerals contained in the Company's products. Based on the information from suppliers and the information available from the Conflict Free Sourcing Initiative, the Company believes the origin of the Subject Minerals processed by these smelters and refiners includes the countries listed in Table II.
Independent Private Sector Audit
This report is not subject to an independent private sector audit as allowed under Rule 13p-1.
Future Due Diligence Measures
The Company intends to implement steps to mitigate the risk that the Subject Minerals benefit armed groups and to improve the RCOI and due diligence processes. These include, but are not limited to, the following:
• | Modifying the conflict minerals compliance process with the intent to increase the supplier response rate and to improve the quality of supplier responses; |
• | Leveraging industry efforts to identify additional resources to facilitate compliance; and |
• | Conducting an annual review of the Company's conflict minerals policy, conflict minerals compliance process and the related procedure documentation, and risks for any updates. |
Table I
Listing of Smelters Potentially Producing Subject Minerals in Company Products
Metal | Smelter | Country of Smelter |
Gold | Abington Reldan Metals, LLC | United States |
Gold | Advanced Chemical Company | United States |
Gold | Aida Chemical Industries Co., Ltd. | Japan |
Gold | Al Etihad Gold LLC | United Arab Emirates |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
Gold | Argor-Heraeus S.A. | Switzerland |
Gold | Asahi Pretec Corp. | Japan |
Gold | Asahi Refining Canada Ltd. | Canada |
Gold | Asahi Refining USA Inc. | United States |
Gold | Asaka Riken Co., Ltd. | Japan |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
Gold | AU Traders and Refiners | South Africa |
Gold | Aurubis AG | Germany |
Gold | Bangalore Refinery | India |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
Gold | Boliden AB | Sweden |
Gold | C. Hafner GmbH + Co. KG | Germany |
Gold | Caridad | Mexico |
Gold | CCR Refinery - Glencore Canada Corporation | Canada |
Gold | Cendres + Metaux S.A. | Switzerland |
Gold | Chimet S.p.A. | Italy |
Gold | Chugai Mining | Japan |
Gold | Daejin Indus Co., Ltd. | Republic of Korea |
Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
Gold | DODUCO Contacts and Refining GmbH | Germany |
Gold | Dowa | Japan |
Gold | DSC (Do Sung Corporation) | Republic of Korea |
Gold | Eco-System Recycling Co., Ltd. | Japan |
Gold | Elemetal Refining, LLC (1) | United States |
Gold | Emirates Gold DMCC | United Arab Emirates |
Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
Gold | Geib Refining Corporation | United States |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
Gold | Guangdong Jinding Gold Limited | China |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
Gold | HeeSung Metal Ltd. | Republic of Korea |
Gold | Heimerle + Meule GmbH | Germany |
Gold | Heraeus Metals Hong Kong Ltd. | China |
Metal | Smelter | Country of Smelter |
Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
Gold | Hunan Chenzhou Mining Co., Ltd. | China |
Gold | HwaSeong CJ CO., LTD. | Republic of Korea |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
Gold | Istanbul Gold Refinery | Turkey |
Gold | Italpreziosi | Italy |
Gold | Japan Mint | Japan |
Gold | Jiangxi Copper Co., Ltd. | China |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
Gold | JSC Uralelectromed | Russian Federation |
Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
Gold | Kaloti Precious Metals | United Arab Emirates |
Gold | Kazakhmys Smelting LLC | Kazakhstan |
Gold | Kazzinc | Kazakhstan |
Gold | Kennecott Utah Copper LLC | United States |
Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
Gold | Kojima Chemicals Co., Ltd. | Japan |
Gold | Korea Zinc Co., Ltd. | Republic of Korea |
Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
Gold | L'azurde Company For Jewelry | Saudi Arabia |
Gold | Lingbao Gold Co., Ltd. | China |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
Gold | L'Orfebre S.A. | Andorra |
Gold | LS-NIKKO Copper Inc. | Republic of Korea |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
Gold | Marsam Metals | Brazil |
Gold | Materion | United States |
Gold | Matsuda Sangyo Co., Ltd. | Japan |
Gold | Metalor Technologies (Hong Kong) Ltd. | China |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
Gold | Metalor Technologies (Suzhou) Ltd. | China |
Gold | Metalor Technologies S.A. | Switzerland |
Gold | Metalor USA Refining Corporation | United States |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
Gold | Mitsubishi Materials Corporation | Japan |
Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
Gold | MMTC-PAMP India Pvt., Ltd. | India |
Gold | Modeltech Sdn Bhd | Malaysia |
Gold | Morris and Watson | New Zealand |
Gold | Morris and Watson Gold Coast | Australia |
Gold | Moscow Special Alloys Processing Plant | Russian Federation |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
Gold | Nihon Material Co., Ltd. | Japan |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
Metal | Smelter | Country of Smelter |
Gold | OJSC Novosibirsk Refinery | Russian Federation |
Gold | PAMP S.A. | Switzerland |
Gold | Pease & Curren | United States |
Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
Gold | Planta Recuperadora de Metales SpA | Chile |
Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
Gold | PX Precinox S.A. | Switzerland |
Gold | Rand Refinery (Pty) Ltd. | South Africa |
Gold | Refinery of Seemine Gold Co., Ltd. | China |
Gold | Remondis Argentia B.V. | Netherlands |
Gold | Republic Metals Corporation | United States |
Gold | Royal Canadian Mint | Canada |
Gold | SAAMP | France |
Gold | Sabin Metal Corp. | United States |
Gold | Safimet S.p.A | Italy |
Gold | SAFINA A.S. | Czech Republic |
Gold | Sai Refinery | India |
Gold | Samduck Precious Metals | Republic of Korea |
Gold | SAMWON METALS Corp. | Republic of Korea |
Gold | SAXONIA Edelmetalle GmbH | Germany |
Gold | SEMPSA Joyeria Plateria S.A. | Spain |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
Gold | Singway Technology Co., Ltd. | Taiwan |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
Gold | Solar Applied Materials Technology Corp. | Taiwan |
Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
Gold | Sudan Gold Refinery | Sudan |
Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
Gold | SungEel HiMetal Co., Ltd. | Republic of Korea |
Gold | T.C.A S.p.A | Italy |
Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
Gold | Tokuriki Honten Co., Ltd. | Japan |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
Gold | Tony Goetz NV | Belgium |
Gold | TOO Tau-Ken-Altyn | Kazakhstan |
Gold | Torecom | Republic of Korea |
Gold | Umicore Brasil Ltda. | Brazil |
Gold | Umicore Precious Metals Thailand | Thailand |
Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
Gold | United Precious Metal Refining, Inc. | United States |
Gold | Universal Precious Metals Refining Zambia | Zambia |
Gold | Valcambi S.A. | Switzerland |
Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
Gold | WIELAND Edelmetalle GmbH | Germany |
Gold | Yamakin Co., Ltd. | Japan |
Metal | Smelter | Country of Smelter |
Gold | Yokohama Metal Co., Ltd. | Japan |
Gold | Yunnan Copper Industry Co., Ltd. | China |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
Tantalum | Asaka Riken Co., Ltd. | Japan |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
Tantalum | D Block Metals, LLC | United States |
Tantalum | Exotech Inc. | United States |
Tantalum | F&X Electro-Materials Ltd. | China |
Tantalum | FIR Metals & Resource Ltd. | China |
Tantalum | Global Advanced Metals Aizu | Japan |
Tantalum | Global Advanced Metals Boyertown | United States |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
Tantalum | H.C. Starck Co., Ltd. | Thailand |
Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
Tantalum | H.C. Starck Inc. | United States |
Tantalum | H.C. Starck Ltd. | Japan |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
Tantalum | Jiangxi Tuohong New Raw Material | China |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | China |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
Tantalum | KEMET Blue Metals | Mexico |
Tantalum | Kemet Blue Powder | United States |
Tantalum | LSM Brasil S.A. | Brazil |
Tantalum | Metallurgical Products India Pvt., Ltd. | India |
Tantalum | Mineracao Taboca S.A. | Brazil |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
Tantalum | NPM Silmet AS | Estonia |
Tantalum | Power Resources Ltd. | Republic of Macedonia |
Tantalum | QuantumClean | United States |
Tantalum | Resind Industria e Comercio Ltda. | Brazil |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
Tantalum | Taki Chemical Co., Ltd. | Japan |
Tantalum | Telex Metals | United States |
Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
Tantalum | XinXing Haorong Electronic Material Co., Ltd. | China |
Tin | Alpha | United States |
Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
Tin | China Tin Group Co., Ltd. | China |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
Tin | CV Ayi Jaya | Indonesia |
Metal | Smelter | Country of Smelter |
Tin | CV Dua Sekawan | Indonesia |
Tin | CV Gita Pesona | Indonesia |
Tin | CV United Smelting | Indonesia |
Tin | CV Venus Inti Perkasa | Indonesia |
Tin | Dowa | Japan |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
Tin | EM Vinto | Bolivia |
Tin | Estanho de Rondonia S.A. | Brazil |
Tin | Fenix Metals | Poland |
Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
Tin | Gejiu Jinye Mineral Company | China |
Tin | Gejiu Kai Meng Industry and Trade LLC | China |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
Tin | Huichang Jinshunda Tin Co., Ltd. | China |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
Tin | Jiangxi New Nanshan Technology Ltd. | China |
Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
Tin | Melt Metais e Ligas S.A. | Brazil |
Tin | Metallic Resources, Inc. | United States |
Tin | Metallo Belgium N.V. | Belgium |
Tin | Metallo Spain S.L.U. | Spain |
Tin | Mineracao Taboca S.A. | Brazil |
Tin | Minsur | Peru |
Tin | Mitsubishi Materials Corporation | Japan |
Tin | Modeltech Sdn Bhd | Malaysia |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
Tin | Operaciones Metalurgical S.A. | Bolivia |
Tin | Pongpipat Company Limited | Myanmar |
Tin | PT Aries Kencana Sejahtera | Indonesia |
Tin | PT Artha Cipta Langgeng | Indonesia |
Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
Tin | PT Babel Inti Perkasa | Indonesia |
Tin | PT Babel Surya Alam Lestari | Indonesia |
Tin | PT Bangka Prima Tin | Indonesia |
Tin | PT Bangka Serumpun | Indonesia |
Tin | PT Bangka Tin Industry | Indonesia |
Tin | PT Belitung Industri Sejahtera | Indonesia |
Tin | PT Bukit Timah | Indonesia |
Tin | PT DS Jaya Abadi | Indonesia |
Tin | PT Eunindo Usaha Mandiri | Indonesia |
Tin | PT Inti Stania Prima | Indonesia |
Metal | Smelter | Country of Smelter |
Tin | PT Karimun Mining | Indonesia |
Tin | PT Kijang Jaya Mandiri | Indonesia |
Tin | PT Lautan Harmonis Sejahtera | Indonesia |
Tin | PT Menara Cipta Mulia | Indonesia |
Tin | PT Mitra Stania Prima | Indonesia |
Tin | PT Panca Mega Persada | Indonesia |
Tin | PT Premium Tin Indonesia | Indonesia |
Tin | PT Prima Timah Utama | Indonesia |
Tin | PT Rajehan Ariq | Indonesia |
Tin | PT Refined Bangka Tin | Indonesia |
Tin | PT Sariwiguna Binasentosa | Indonesia |
Tin | PT Stanindo Inti Perkasa | Indonesia |
Tin | PT Sukses Inti Makmur | Indonesia |
Tin | PT Sumber Jaya Indah | Indonesia |
Tin | PT Timah (Persero) Tbk Kundur | Indonesia |
Tin | PT Timah (Persero) Tbk Mentok | Indonesia |
Tin | PT Tinindo Inter Nusa | Indonesia |
Tin | PT Tommy Utama | Indonesia |
Tin | Resind Industria e Comercio Ltda. | Brazil |
Tin | Rui Da Hung | Taiwan |
Tin | Soft Metais Ltda. | Brazil |
Tin | Super Ligas | Brazil |
Tin | Thaisarco | Thailand |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
Tin | Yunnan Tin Company Limited | China |
Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan |
Tungsten | ACL Metais Eireli | Brazil |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. | China |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China |
Tungsten | Global Tungsten & Powders Corp. | United States |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
Tungsten | H.C. Starck Tungsten GmbH | Germany |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | China |
Tungsten | Hydrometallurg, JSC | Russian Federation |
Tungsten | Japan New Metals Co., Ltd. | Japan |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
Metal | Smelter | Country of Smelter |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
Tungsten | Kennametal Fallon | United States |
Tungsten | Kennametal Huntsville | United States |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
Tungsten | Moliren Ltd. | Russian Federation |
Tungsten | Niagara Refining LLC | United States |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
Tungsten | Unecha Refractory Metals Plant | Russian Federation |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam |
Tungsten | Wolfram Bergbau und Hutten AG | Austria |
Tungsten | Woltech Korea Co., Ltd. | Republic of Korea |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
Tungsten | Xiamen Tungsten Co., Ltd. | China |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
__________________________
(1) This smelter is believed to source the Subject Minerals from the Covered Countries and is not included on the Conflict-Free Sourcing Initiative's list of certified or active smelters. The Company received company-level responses from suppliers sourcing from this smelter; therefore, the Company is unable to conclusively determine whether components or finished goods sourced from those suppliers contain Subject Minerals from this smelter.
Table II
Listing of Subject Minerals' Countries of Origin
Angola | Hungary | Poland |
Argentina | India | Portugal |
Armenia | Indonesia | Republic of the Congo |
Australia | Ireland | Russian Federation |
Austria | Israel | Rwanda |
Belarus | Italy | Saudi Arabia |
Belgium | Ivory Coast | Sierra Leone |
Bermuda | Japan | Singapore |
Bolivia | Jersey | Slovakia |
Brazil | Kazakhstan | South Africa |
Burundi | Kenya | South Sudan |
Cambodia | Republic of Korea | Spain |
Canada | Kyrgyzstan | Suriname |
Central African Republic | Laos | Sweden |
Chile | Luxembourg | Switzerland |
China | Madagascar | Taiwan |
Colombia | Malaysia | Tajikistan |
Czech Republic | Mali | Tanzania |
Djibouti | Mexico | Thailand |
Democratic Republic of the Congo | Mongolia | Turkey |
Ecuador | Morocco | Uganda |
Egypt | Mozambique | United Arab Emirates |
Estonia | Myanmar | United Kingdom |
Ethiopia | Namibia | United States |
Finland | Netherlands | Uzbekistan |
France | New Zealand | Vietnam |
Germany | Niger | Zambia |
Ghana | Nigeria | Zimbabwe |
Guinea | Papua New Guinea | |
Guyana | Peru | |
Hong Kong | Philippines | |