UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
PMFG, INC.
(Exact name of registrant as specified in its charter)
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| Delaware |
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001-34156 |
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51-0661574 |
| (State or other jurisdiction
of incorporation) |
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(Commission
File Number) |
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(IRS Employer
Identification No.) |
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| 14651 North Dallas Parkway, Suite 500
Dallas, Texas |
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75254 |
| (Address of principal executive offices) |
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(Zip Code) |
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| Ronald L. McCrummen |
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(214) 357-6181 |
| (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:
| x |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In
accordance with the disclosure requirements promulgated by the U.S. Securities and Exchange Commission, the Company has undertaken efforts to determine our conflict minerals1 reporting
requirements for the period from January 1 to December 31, 2014.
We have determined that during 2014 our company manufactured (or contracted to
manufacture) products as to which conflict minerals are necessary to the functionality or production of such products. As is required, we have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the
necessary conflict minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country or came from recycled or scrap sources.
The Company’s RCOI process included conducting an inquiry of our direct suppliers using the Conflict-Free Sourcing Initiative’s Conflict Minerals
Reporting Template. We relied upon our suppliers’ representations regarding the origin of their minerals and their smelter data to determine the source of the conflict minerals within our supply chain.
The Company has filed this Specialized Disclosure Form (“Form SD”) and the associated Conflict Minerals Report, which appears as Exhibit 1.01 hereto
and is publicly available on our website under the Investors tab at www.pmfginc.com. The content on any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.
Item 1.02 Exhibit
The Company’s Conflict
Minerals Report is provided as Exhibit 1.01 hereto.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as
part of this report.
Exhibit 1.01 – PMFG, Inc.’s Conflict Minerals Report for the period January 1 to December 31, 2014 as required
by Items 1.01 and 1.02 of this Form.
*****
| 1 |
The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (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; or (B) any other mineral or its derivatives determined by the
Secretary of State to be financing conflict in the DRC or an adjoining country. |
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.
PMFG, Inc.
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| By: |
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/s/ Ronald L. McCrummen |
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Date: May 29, 2015 |
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Ronald L. McCrummen |
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Executive Vice President and Chief Financial Officer |
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Exhibit 1.01
CONFLICT MINERALS REPORT OF
PMFG, Inc.
FOR THE
REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2014
This is the Conflict Minerals2 Report
of PMFG, Inc. (“we,” “our,” “us,” or the “Company”) prepared for calendar year 2014 (except for conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accordance
with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Release
No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
We are a leading provider of custom-engineered
systems and products designed to help ensure that the delivery of energy is safe, efficient and clean. We conduct our business globally and primarily serve the markets for natural gas infrastructure, power generation and refining and petrochemical
processing. Our primary customers include original equipment manufacturers, engineering contractors, commercial and industrial companies and operators of power facilities.
In accordance with Rule 13p-1, we undertook efforts to determine the source of the necessary conflict minerals used in our products. The Company designed its
efforts in conformity, with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas3 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below
are based on the due diligence activities performed to date and in good faith by the Company and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these
statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or
other third-party sources, continuing guidance regarding the U.S. Securities and Exchange Commission (“SEC”) final rules, and other issues.
| II. |
Design of Conflict Minerals Program |
The Company designed its overall conflict minerals program based on
the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as it relates to our position in the minerals supply chain as a “downstream” company.
| 2 |
The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (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; or (B) any other mineral or its derivatives determined by the
Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country. |
| 3 |
OECD (2013), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing. http://dx.doi.org/10.1787/9789264185050-en
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1
The Company’s implementation of the five-step framework consists of the following overarching steps which
are discussed in further detail in Section III.
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| Step 1: |
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Establish strong company management systems |
| Step 2: |
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Identify and assess risks in the supply chain |
| Step 3: |
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Design and implement a strategy to respond to identified risks |
| Step 4: |
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Carry out independent third-party audit of smelter/refiner’s due diligence practices |
| Step 5: |
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Report annually on supply chain due diligence. |
As described below, we relied upon multi-stakeholder initiatives that provide verification processes for conflict-free
minerals from smelters or refiners who may provide those minerals to companies in our supply chain. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals; the Company does not purchase raw ore or
unrefined conflict minerals, and conducts no purchasing activities directly in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”).
| III. |
Due Diligence Measures Performed by PMFG, Inc. |
The following describes the measures taken to reasonably
exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management
systems
| a. |
Conflict minerals team – We established a conflict minerals team that includes individuals from the appropriate business units and departments to ensure critical information reached relevant employees and
suppliers. This team is charged with overseeing and driving conflict minerals compliance. The conflict minerals team engagement a third party service provider to assist with process design and data collection. |
| b. |
Position statement – We adopted and published a position statement articulating the Company’s position with regard to the matters that gave rise to the SEC’s regulations, as well as the expectations of
our suppliers with regard to responsible sourcing. The position statement can be found on our website under the Investor tab at www.pmfginc.com. |
| c. |
Internal engagement – We developed a training program for internal use to educate relevant employees on our conflict minerals program and reporting obligations. |
| d. |
Supplier engagement – We provided educational materials to our queried suppliers. Suppliers were provided information on the conflict minerals disclosure requirements as well as recommendations for developing,
implementing, and documenting a conflict minerals compliance program. |
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
| a. |
Identify products in scope – Our conflict minerals team reviewed a summary of products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope
as described by the Adopting Release. Using the summary of products identified, the conflict minerals team determined the suppliers for inclusion in the reasonable country of origin inquiry (“RCOI”). |
| b. |
Conduct RCOI – We utilized the industry-developed Conflict Minerals Reporting Template (“CMRT”) to query our suppliers for conflict minerals information. We requested this information from the Tier 1
suppliers who provide material and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI.
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| c. |
Validated and evaluated supplier responses – We contacted direct suppliers that did not respond to our request for conflict minerals information by the requested date. For those suppliers that completed a CMRT, we
applied an established risk rating criteria to validate and evaluate suppliers’ responses. We plan to use the ratings to design and implement a risk management plan to respond to the identified risks. |
| d. |
Identify smelters/processors – We collected a list of smelters/processors that are in our supply chain by utilizing the CMRT. |
2
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
| a. |
Designed and implemented a plan – We used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT as well as any additional documentation furnished to support those
responses. The resulting risk ratings will be used to develop specific supplier outreach and education to address the identified risks. |
| b. |
Verify smelters – As part of the risk mitigation process, the Company reconciled the list of smelters collected from suppliers to the list of smelter facilities designated as “conflict-free” by the
Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict-Free Smelter Program. |
Step 4: Carry out independent third-party audit
of smelter/refiner’s due diligence practices
We are relying on the CFSI’s published lists to verify the conflict-free status of
smelters/processors that source from the covered countries.
Step 5: Report annually on supply chain due diligence
We have determined that a portion of the conflict minerals used to manufacture our products originated from the Covered Countries. Based on our due diligence
of the mineral supply chain, we have determined that our products are DRC conflict undeterminable at this time. Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website under the Investors tab at
www.pmfginc.com.
| IV. |
Product Determination |
On the basis of the measures described above, the Company was unable to determine
the source for all of the conflict minerals used in its products manufactured during the period January 1, 2014 through December 31, 2014.
Products – The Company offers a broad range of separation and
filtration products, Selective Catalytic Reduction systems, Selective Non-Catalytic Reduction systems, low emission burner and related combustion systems and other complementary products including head transfer equipment, pulsation dampeners and
silencers. Our products are highly customized and are designed and configured based on the specific requirements of our customers.
Processing
Facilities – Based on the input received from our suppliers, we determined that the following facilities, among others, were used to process the conflict minerals used in our products.
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| Mineral |
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Smelter Name |
| Gold |
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Aida Chemical Industries Co., Ltd. |
| Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
| Gold |
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AngloGold Ashanti Córrego do Sítio Mineração |
| Gold |
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Argor-Heraeus SA |
| Gold |
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Asahi Pretec Corporation |
| Gold |
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold |
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Aurubis AG |
| Gold |
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Boliden AB |
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| Gold |
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C. Hafner GmbH + Co. KG |
| Gold |
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CCR Refinery – Glencore Canada Corporation |
| Gold |
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Chimet S.p.A. |
| Gold |
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Dowa |
| Gold |
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Eco-System Recycling Co., Ltd. |
| Gold |
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Heimerle + Meule GmbH |
| Gold |
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Heraeus Ltd. Hong Kong |
| Gold |
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Heraeus Precious Metals GmbH & Co. KG |
| Gold |
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Ishifuku Metal Industry Co., Ltd. |
| Gold |
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Istanbul Gold Refinery |
| Gold |
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Japan Mint |
| Gold |
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Johnson Matthey Inc. |
| Gold |
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Johnson Matthey Limited |
| Gold |
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold |
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JSC Uralelectromed |
| Gold |
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JX Nippon Mining & Metals Co., Ltd. |
| Gold |
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Kazzinc |
| Gold |
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Kennecott Utah Copper LLC |
| Gold |
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Kojima Chemicals Co., Ltd. |
| Gold |
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L’ azurde Company For Jewelry |
| Gold |
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LS-NIKKO Copper Inc. |
| Gold |
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Materion |
| Gold |
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Matsuda Sangyo Co., Ltd. |
| Gold |
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Metalor Technologies (Hong Kong) Ltd. |
| Gold |
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Metalor Technologies (Singapore) Pte., Ltd. |
| Gold |
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Metalor Technologies SA |
| Gold |
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Metalor USA Refining Corporation |
| Gold |
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METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V |
| Gold |
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Mitsubishi Materials Corporation |
| Gold |
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Mitsui Mining and Smelting Co., Ltd. |
| Gold |
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Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| Gold |
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Nihon Material Co., Ltd. |
| Gold |
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Ohio Precious Metals, LLC |
| Gold |
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Ohura Precious Metal Industry Co., Ltd. |
| Gold |
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) |
| Gold |
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PAMP SA |
| Gold |
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PT Aneka Tambang (Persero) Tbk |
| Gold |
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PX Précinox SA |
| Gold |
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Rand Refinery (Pty) Ltd. |
| Gold |
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Republic Metals Corporation |
| Gold |
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Royal Canadian Mint |
| Gold |
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Schone Edelmetaal |
| Gold |
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SEMPSA Joyería Platería SA |
| Gold |
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Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold |
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Sichuan Tianze Precious Metals Co., Ltd. |
| Gold |
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Solar Applied Materials Technology Corp. |
| Gold |
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Sumitomo Metal Mining Co., Ltd. |
| Gold |
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Tanaka Kikinzoku Kogyo K.K. |
| Gold |
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The Refinery of Shandong Gold Mining Co., Ltd. |
| Gold |
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Tokuriki Honten Co., Ltd. |
| Gold |
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Umicore Brasil Ltda. |
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| Gold |
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Umicore Precious Metals Thailand |
| Gold |
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Umicore SA Business Unit Precious Metals Refining |
| Gold |
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United Precious Metal Refining, Inc. |
| Gold |
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Valcambi SA |
| Gold |
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Western Australian Mint trading as The Perth Mint |
| Gold |
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Yamamoto Precious Metal Co., Ltd. |
| Gold |
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Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Gold |
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Zijin Mining Group Co., Ltd. Gold Refinery |
| Gold |
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Advanced Chemical Company |
| Gold |
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Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold |
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Asaka Riken Co., Ltd. |
| Gold |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold |
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Bauer Walser AG |
| Gold |
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Caridad |
| Gold |
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Cendres + Métaux SA |
| Gold |
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Chugai Mining |
| Gold |
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Daejin Indus Co., Ltd. |
| Gold |
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Daye Non-Ferrous Metals Mining Ltd. |
| Gold |
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Do Sung Corporation |
| Gold |
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Doduco |
| Gold |
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Gansu Seemine Material Hi-Tech Co., Ltd. |
| Gold |
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Guangdong Jinding Gold Limited |
| Gold |
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Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold |
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Hunan Chenzhou Mining Group Co., Ltd. |
| Gold |
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Hwasung CJ Co., Ltd. |
| Gold |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited |
| Gold |
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Jiangxi Copper Company Limited |
| Gold |
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Korea Metal Co., Ltd. |
| Gold |
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Kyrgyzaltyn JSC |
| Gold |
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Lingbao Gold Company Limited |
| Gold |
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Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold |
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Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold |
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Metalor Technologies (Suzhou) Ltd. |
| Gold |
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Moscow Special Alloys Processing Plant |
| Gold |
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Navoi Mining and Metallurgical Combinat |
| Gold |
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OJSC Kolyma Refinery |
| Gold |
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OJSC Novosibirsk Refinery |
| Gold |
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Penglai Penggang Gold Industry Co., Ltd. |
| Gold |
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Prioksky Plant of Non-Ferrous Metals |
| Gold |
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Sabin Metal Corp. |
| Gold |
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Samduck Precious Metals |
| Gold |
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SAMWON Metals Corp. |
| Gold |
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So Accurate Group, Inc. |
| Gold |
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SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold |
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The Great Wall Gold and Silver Refinery of China |
| Gold |
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Tongling Nonferrous Metals Group Co., Ltd. |
| Gold |
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Torecom |
| Gold |
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Yokohama Metal Co., Ltd. |
| Gold |
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Yunnan Copper Industry Co., Ltd. |
| Tantalum |
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Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum |
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Conghua Tantalum and Niobium Smeltry |
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| Tantalum |
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Duoluoshan |
| Tantalum |
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Exotech Inc. |
| Tantalum |
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F&X Electro-Materials Ltd. |
| Tantalum |
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Global Advanced Metals Aizu |
| Tantalum |
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Global Advanced Metals Boyertown |
| Tantalum |
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Guangdong Zhiyuan New Material Co., Ltd. |
| Tantalum |
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H.C. Starck Co., Ltd. |
| Tantalum |
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H.C. Starck GmbH Goslar |
| Tantalum |
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H.C. Starck GmbH Laufenburg |
| Tantalum |
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H.C. Starck Hermsdorf GmbH |
| Tantalum |
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H.C. Starck Inc. |
| Tantalum |
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H.C. Starck Ltd. |
| Tantalum |
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H.C. Starck Smelting GmbH & Co.KG |
| Tantalum |
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Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum |
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Hi-Temp Specialty Metals, Inc. |
| Tantalum |
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Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum |
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JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum |
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Jiujiang Tanbre Co., Ltd. |
| Tantalum |
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KEMET Blue Metals |
| Tantalum |
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KEMET Blue Powder |
| Tantalum |
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King-Tan Tantalum Industry Ltd. |
| Tantalum |
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LSM Brasil S.A. |
| Tantalum |
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Metallurgical Products India Pvt., Ltd. |
| Tantalum |
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Mineração Taboca S.A. |
| Tantalum |
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Mitsui Mining & Smelting |
| Tantalum |
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Molycorp Silmet A.S. |
| Tantalum |
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Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum |
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Plansee SE Liezen |
| Tantalum |
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Plansee SE Reutte |
| Tantalum |
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QuantumClean |
| Tantalum |
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RFH Tantalum Smeltry Co., Ltd. |
| Tantalum |
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Solikamsk Magnesium Works OAO |
| Tantalum |
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Taki Chemicals |
| Tantalum |
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Telex Metals |
| Tantalum |
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Ulba Metallurgical Plant JSC |
| Tantalum |
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Yichun Jin Yang Rare Metal Co., Ltd. |
| Tantalum |
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Zhuzhou Cemented Carbide |
| Tin |
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Alpha |
| Tin |
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Cooperativa Metalurgica de Rondônia Ltda. |
| Tin |
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CV United Smelting |
| Tin |
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Dowa |
| Tin |
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EM Vinto |
| Tin |
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Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin |
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Jiangxi Ketai Advanced Material Co., Ltd. |
| Tin |
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Magnu’s Minerais Metais e Ligas Ltda. |
| Tin |
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Malaysia Smelting Corporation (MSC) |
| Tin |
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Melt Metais e Ligas S/A |
| Tin |
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Metallo-Chimique N.V. |
| Tin |
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Mineração Taboca S.A. |
| Tin |
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Minsur |
| Tin |
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Mitsubishi Materials Corporation |
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| Tin |
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O.M. Manufacturing Philippines, Inc. |
| Tin |
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Operaciones Metalurgical S.A. |
| Tin |
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PT Artha Cipta Langgeng |
| Tin |
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PT ATD Makmur Mandiri Jaya |
| Tin |
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PT Babel Inti Perkasa |
| Tin |
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PT Bangka Putra Karya |
| Tin |
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PT Bangka Tin Industry |
| Tin |
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PT Belitung Industri Sejahtera |
| Tin |
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PT Bukit Timah |
| Tin |
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PT DS Jaya Abadi |
| Tin |
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PT Eunindo Usaha Mandiri |
| Tin |
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PT Mitra Stania Prima |
| Tin |
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PT Panca Mega Persada |
| Tin |
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PT Prima Timah Utama |
| Tin |
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PT Refined Bangka Tin |
| Tin |
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PT Sariwiguna Binasentosa |
| Tin |
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PT Stanindo Inti Perkasa |
| Tin |
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PT Timah (Persero) Tbk Kundur |
| Tin |
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PT Timah (Persero) Tbk Mentok |
| Tin |
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PT Tinindo Inter Nusa |
| Tin |
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Soft Metais Ltda. |
| Tin |
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Thaisarco |
| Tin |
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White Solder Metalurgia e Mineração Ltda. |
| Tin |
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Yunnan Tin Group (Holding) Company Limited |
| Tin |
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China Tin Group Co., Ltd. |
| Tin |
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CNMC (Guangxi) PGMA Co., Ltd. |
| Tin |
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CV Gita Pesona |
| Tin |
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CV Serumpun Sebalai |
| Tin |
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Estanho de Rondônia S.A. |
| Tin |
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Fenix Metals |
| Tin |
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Gejiu Kai Meng Industry and Trade LLC |
| Tin |
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Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin |
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Huichang Jinshunda Tin Co., Ltd. |
| Tin |
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Linwu Xianggui Ore Smelting Co., Ltd. |
| Tin |
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Metallic Resources, Inc. |
| Tin |
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Novosibirsk Processing Plant Ltd. |
| Tin |
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O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin |
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PT Alam Lestari Kencana |
| Tin |
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PT Aries Kencana Sejahtera |
| Tin |
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PT Bangka Kudai Tin |
| Tin |
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PT Bangka Timah Utama Sejahtera |
| Tin |
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PT BilliTin Makmur Lestari |
| Tin |
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PT Fang Di MulTindo |
| Tin |
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PT Inti Stania Prima |
| Tin |
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PT Justindo |
| Tin |
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PT Karimun Mining |
| Tin |
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PT Pelat Timah Nusantara Tbk |
| Tin |
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PT Seirama Tin Investment |
| Tin |
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PT Sumber Jaya Indah |
| Tin |
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PT Supra Sukses Trinusa |
| Tin |
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Rui Da Hung |
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| Tin |
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VQB Mineral and Trading Group JSC |
| Tin |
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Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tungsten |
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Asia Tungsten Products Vietnam Ltd. |
| Tungsten |
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Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten |
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Fujian Jinxin Tungsten Co., Ltd. |
| Tungsten |
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Ganzhou Huaxing Tungsten Products Co., Ltd. |
| Tungsten |
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Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten |
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Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten |
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Global Tungsten & Powders Corp. |
| Tungsten |
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Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten |
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Japan New Metals Co., Ltd. |
| Tungsten |
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Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten |
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Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten |
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Vietnam Youngsun Tungsten Industry Co., Ltd. |
| Tungsten |
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Wolfram Bergbau und Hütten AG |
| Tungsten |
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Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten |
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Xiamen Tungsten Co., Ltd. |
| Tungsten |
|
A.L.M.T. TUNGSTEN Corp. |
| Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten |
|
Dayu Jincheng Tungsten Industry Co., Ltd. |
| Tungsten |
|
Dayu Weiliang Tungsten Co., Ltd. |
| Tungsten |
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten |
|
H.C. Starck GmbH |
| Tungsten |
|
H.C. Starck Smelting GmbH & Co.KG |
| Tungsten |
|
Hunan Chenzhou Mining Group Co., Ltd. |
| Tungsten |
|
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten |
|
Kennametal Fallon |
| Tungsten |
|
Kennametal Huntsville |
| Tungsten |
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
| Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
Country of Origin – Based on the input received from our suppliers, we determined that the conflict minerals used
in our products were sourced from the following countries, among others.
|
|
|
| Mineral |
|
Country of Origin |
| Gold |
|
Australia |
| Gold |
|
Belgium |
| Gold |
|
Brazil |
| Gold |
|
Canada |
| Gold |
|
China |
| Gold |
|
Germany |
| Gold |
|
Indonesia |
| Gold |
|
Italy |
| Gold |
|
Japan |
| Gold |
|
Kazakhstan |
| Gold |
|
Kyrgyzstan |
8
|
|
|
| Gold |
|
Mexico |
| Gold |
|
Netherlands |
| Gold |
|
Philippines |
| Gold |
|
Republic Of Korea |
| Gold |
|
Russia |
| Gold |
|
Saudi Arabia |
| Gold |
|
Singapore |
| Gold |
|
South Africa |
| Gold |
|
Spain |
| Gold |
|
Sweden |
| Gold |
|
Switzerland |
| Gold |
|
Taiwan |
| Gold |
|
Thailand |
| Gold |
|
Turkey |
| Gold |
|
United States |
| Gold |
|
Uzbekistan |
| Tantalum |
|
Austria |
| Tantalum |
|
Brazil |
| Tantalum |
|
China |
| Tantalum |
|
Estonia |
| Tantalum |
|
Germany |
| Tantalum |
|
India |
| Tantalum |
|
Japan |
| Tantalum |
|
Kazakhstan |
| Tantalum |
|
Mexico |
| Tantalum |
|
Russia |
| Tantalum |
|
Thailand |
| Tantalum |
|
United States |
| Tin |
|
Belgium |
| Tin |
|
Bolivia |
| Tin |
|
Brazil |
| Tin |
|
China |
| Tin |
|
Indonesia |
| Tin |
|
Japan |
| Tin |
|
Malaysia |
| Tin |
|
Peru |
| Tin |
|
Philippines |
| Tin |
|
Poland |
| Tin |
|
Russia |
| Tin |
|
Taiwan |
| Tin |
|
Thailand |
| Tin |
|
United States |
| Tin |
|
Vietnam |
| Tungsten |
|
Austria |
| Tungsten |
|
China |
| Tungsten |
|
Germany |
| Tungsten |
|
Japan |
| Tungsten |
|
United States |
| Tungsten |
|
Vietnam |
9
| VI. |
Additional Due Diligence and Risk Mitigation |
We will continue to communicate our expectations and
information requirements to our direct suppliers. Over time, we anticipate that the amount of information globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our
direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified.
In addition to
those above, the Company will undertake the following steps during the next compliance period:
| • |
|
Continue to collect responses from suppliers using tools such as the CMRT. |
| • |
|
Monitor and track performance of risk mitigation efforts. |
| • |
|
Compare and validate RCOI results to information collected via independent conflict-free smelter validation programs such as the CFSI. |
| • |
|
Continue to allow verified conflict-free material from the region to enter our supply chain. |
| VII. |
Independent Private Sector Audit |
Not required for calendar year 2014.
10
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