As filed with the Securities and Exchange Commission on June 1, 2021
Washington, D.C. 20549
Specialized Disclosure Report
LivaNova PLC

England and Wales
(State or other jurisdiction of
incorporation or organization)
(Commission File Number)
(I.R.S. Employer Identification No.)

20 Eastbourne Terrace
London, United Kingdom
W2 6LG
(Address of Principal Executive Offices) (Zip Code)

Keyna Skeffington
Company Secretary
+ 44 (0) 203 325 0665
(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, 2020.


Section 1 Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report
LivaNova PLC, headquartered in London, (collectively with its subsidiaries, the “Company”, “LivaNova”, “we” or “our”), is a global medical device company focused on the development and delivery of important therapeutic solutions for the benefit of patients, healthcare professionals and healthcare systems throughout the world. Working closely with our global team of medical professionals in the fields of cardiovascular disease and neuromodulation, we design, develop, manufacture and sell innovative therapeutic solutions. At LivaNova, we unite to provide hope for patients and their families through innovative medical technologies, delivering life-changing improvements for both the Head and Heart.
LivaNova is filing this Specialized Disclosure report on Form SD (this “Form SD”) for LivaNova’s Neuromodulation and Cardiac Surgery supply chain operations for the year ended December 31, 2020. This Form SD is presented in compliance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2020 to December 31, 2020.
A copy of our Conflict Minerals Report is filed as a part of this Form SD. In accordance with Rule 12b-12 (17 CFR 240.12b-12), a copy of this Form SD may be found on our website at

Item 1.02 Exhibits
LivaNova has filed as an exhibit to this Form SD, the Conflict Minerals Report required by Item 1.01.

Section 2 Exhibits

Item 2.01 Exhibits
The following exhibit is filed as part of this report.

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.

LivaNova PLC
Date: June 1, 2021
By:/s/ Keyna Skeffington
Name: Keyna Skeffington
Title: Company Secretary


Exhibit 1.01
LivaNova PLC
Conflict Minerals Report
For the Year Ended December 31, 2020

This Conflict Minerals Report of LivaNova PLC (this “Report”) has been prepared for the reporting period from January 1, 2020 to December 31, 2020 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 disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). The Act defines conflict minerals as cassiterite (tin), columbite-tantalite (tantalum), gold, wolframite (tungsten), (together, “3TGs”) or their derivatives (“Conflict Minerals”). The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo (DRC), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. The Rule imposes certain reporting requirements on SEC registrants who manufacture or contract to manufacture products that include Conflict Minerals if such Conflict Minerals are necessary to the functionality or production of the products.
1.Company Overview
This Report has been prepared by the management of LivaNova PLC (“LivaNova,” “we,” “us,” “registrant,” “Company” or “our”). It does not include the activities of variable interest entities that are not required to be consolidated.
This Conflict Minerals Report reports the reasonable country of origin inquiry (“RCOI”) conducted in good faith to determine whether any of the 3TGs in LivaNova’s Neuromodulation and Cardiovascular product offerings originated from the Covered Countries for the year ended December 31, 2020.
At LivaNova, we understand the importance of bringing both clinical and economic value to our customers. We are a strong, market-leading medical technology and services company, offering a diverse product portfolio and global reach. In fiscal year 2020, LivaNova operated as two reportable segments:
Cardiovascular: Engages in the development, production and sale of cardiopulmonary products, heart valves and advanced circulatory support products. Cardiopulmonary products include oxygenators, heart-lung machines, autotransfusion systems, perfusion tubing systems, cannulae and other related accessories. Advanced circulatory support includes temporary life support controllers and product kits that can include a combination of pumps, oxygenators and cannulae. Heart valves include mechanical heart valves, tissue heart valves, related repair products and minimally invasive surgical instruments.
Neuromodulation: Designs, develops, and markets Neuromodulation therapy for the treatment of drug-resistant epilepsy, difficult-to-treat depression and obstructive sleep apnea. We are also developing and conducting clinical testing of the VITARIA® System for treating heart failure. Products consist of an implantable pulse generator and connective lead, surgical equipment to assist with the implant procedure, equipment and software to configure and set parameters and magnets to manually suspend or induce nerve stimulation.

Our broad and complex product offerings may contain conflict minerals within the following components:
Tantalum, used in capacitors;
Tin, used in electrical components, printed circuit board assembly (PCBA), hardware and equipment;
Tungsten, used in coatings, alloys, heating elements and electrodes; and
Gold, used in circuit boards, electrodes and electronic components.
Additional information on LivaNova is available at
2.General Policy and Team

LivaNova embraces the key principles of the International Labour Organizations fundamental conventions. We believe that our business can only succeed where the rights of all workers involved in the value chain of our business are protected and respected, and we aim to conduct business with third parties including consultants, suppliers and other business partners (Third Parties) who share our commitment to operating in a responsible and ethical manner.

We strive to conduct our activities in a manner that reflects our mission and Code of Ethics and Business Conduct – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act and upholds responsible sourcing practices. We expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and to comply with our Code of Ethics and Business Conduct, our Third-Party Code of Ethics and Business Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources.
We have established a cross-functional team to implement our conflict mineral compliance strategy and policy. This team has executive level involvement and access to various subject matter experts from such areas as sourcing, procurement, legal and finance.
3.Reasonable Country of Origin Inquiry

In collaboration with our partners at Assent Compliance (who are experts in supply chain data management), we first determined which of our products contained 3TGs necessary to the functionality or production of such products. We then conducted a good faith reasonable country of origin inquiry with respect to 3TGs contained in our products by assessing our supply chain in accordance with the framework in The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).

The RCOI was designed to determine whether any 3TGs contained in our products originated in the Covered Countries. We do not purchase minerals directly from mines, smelters or refiners and therefore must rely on our direct suppliers to provide information on the origin of the minerals contained in components and materials supplied to us or products manufactured for us.


We began our supplier scoping process by:

Determining which of our products commercially distributed in 2020 potentially contained one or more of the 3TGs;

Identifying our suppliers that manufactured or contracted to manufacture components or products containing these 3TGs contained in our distributed products; and

Providing this list composed of suppliers and parts associated with the in-scope products to Assent Compliance for upload to the Assent Compliance Manager (“ACM”).

The supply chain survey, and the conflict minerals program as a whole, has been developed and implemented in cooperation with Assent Compliance.

To collect data on the materials’ sources of origin procured by the supply chain, LivaNova utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.0+ to conduct a survey of all in-scope suppliers.

During the supplier survey, LivaNova contacted 356 suppliers via ACM, a software-as-a-service (SaaS) platform provided by Assent Compliance that enables users to complete and track supplier communications, and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

Via the ACM and Assent Compliance team, LivaNova requested that all suppliers, identified as possibly providing components containing 3TGs, complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent Compliance monitored and tracked all communications in the ACM for future reporting and transparency. LivaNova directly contacted suppliers that were unresponsive to Assent Compliances’ repeated communication attempts during the diligence process and requested these suppliers complete the CMRT and submit it to Assent Compliance.

LivaNova’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.

All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent Compliances’ multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback, LivaNova tracks program gaps to account for future improvement opportunities. As of May 19, 2021, there were nine invalid or incomplete supplier submissions that could not be corrected.

As of May 19, 2021, there were 356 suppliers in scope of the conflict minerals program. Of those 356 suppliers, 163 suppliers provided a completed CMRT and 70 suppliers were deemed out of scope based on information provided. LivaNova’s total response rate for this reporting year was 65.45%.

LivaNova determined the countries of origin for a large portion of the 3TGs in its products as a result of the RCOI process. However, further due diligence on the source and chain of custody of the minerals in question

determined that some suppliers were unable to provide smelter or refiner lists and some suppliers could not provide full smelter lists. Because the Company is unable to obtain full smelter information from all in-scope suppliers, LivaNova is unable to confidently state the countries of origin for all 3TGs contained in our products.

4.Due Diligence

4.1 Design of Due Diligence

LivaNova designed its due diligence process to be in conformity, in all material respects, with the due diligence framework of the OECD Due Diligence Guidance and related supplements. The program aligns with the five steps for due diligence that are described by OECD Guidance, and LivaNova continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.

Due diligence requires LivaNova to rely on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by LivaNova. However, through continued outreach and process validation, in collaboration with Assent Compliance, our process aligns with industry standards and market expectations for downstream companies’ due diligence.

4.1.1 Establish Strong Company Management and Control Systems

Internal Team and Training

LivaNova has established a management team responsible for the conflict minerals program. In 2020, our management team was overseen by the Senior Vice President of Global Operations and a team of subject matter experts from relevant functions such as, supply chain, operations, finance and legal. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and was led by the Vice President of Neuromodulation Operations, who acts as the Conflict Minerals Program Manager.

LivaNova leverages Assent Compliances’ Managed Services to work with dedicated program specialists who support LivaNova’s conflict minerals program. LivaNova communicates regularly with the Assent Compliance team to receive updates on program status. Each member of Assent Compliance’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.

Control Systems

LivaNova controls include, but are not limited to, our Code of Ethics and Business Conduct which outlines certain expected behaviors for all employees. In addition, we rely on our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us, including sources of 3TGs that are supplied to them from lower tier suppliers.

In 2020, we introduced the Third-Party Code of Ethics and Business Conduct (Third Party Code of Conduct), which we have published externally (in multiple languages) as well as within our distributor agreements and purchase order terms and conditions this Third Party Code of Ethics and Business Conduct defines the standards we demand of all LivaNova Third Parties.

Compliance with our Third-Party Code of Conduct informs an important part of LivaNova’s Third Party selection and evaluation. We require Third Parties to meet our requirements and to pass on these requirements to their respective supply chains. If an audit conducted by or on behalf of LivaNova reveals non-alignment with our

Third Party Code of Ethics and Business Conduct, we have the right to take corrective measures that, in the event of significant non-compliance, may also include immediate termination of the business relationship.

We also strengthened the language in our General Terms and Conditions for the Purchase of Products and Services included with our purchase orders to clarify that, in order to conduct business with LivaNova, a supplier may be required to complete a questionnaire designed to identify the potential presence of “conflict minerals” in any products it sells to LivaNova and if necessary, perform appropriate due diligence.

Supplier Engagement

As we do not have a direct relationship with 3TGs smelters and refiners, we are engaged and actively cooperate with other manufacturers in our industry and other sectors. We rely primarily on our Tier 1 direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us, including sources of 3TGs that are supplied to them from lower tier suppliers.

We have leveraged existing communications within the Company, specifically through our procurement personnel, to encourage supplier interactions with Assent Compliance as well for them to understand the need for completion of the surveys. Feedback from this process has allowed us to enhance, focus, and adapt the training to each user’s needs. It has also focused our supplier communications, thus ensuring clear expectations on both sides.

LivaNova continues to place a strong emphasis on supplier education and training. To accomplish this, Assent Compliance’s online resources are leveraged, and all in-scope suppliers have been provided with access to the library of conflict minerals training and support resources.

We engage with suppliers directly to request a valid CMRT for the products that they supply to LivaNova. With respect to the OECD requirement to strengthen engagement with suppliers, LivaNova has developed an internal process that includes steps of supplier engagement escalation such as in-person meetings and corrective actions. Feedback from this engagement has allowed LivaNova to oversee improvements in supplier responses and supplier compliance for this initiative.

LivaNova believes that the combination of the LivaNova Code of Ethics and Business Conduct, Third-Party Code of Ethics and Business Conduct, and direct engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.

Grievance Mechanism

LivaNova proactively promotes ethical behavior and encourages employees to report violations of laws, regulations, and/or our policies and procedures, including our Code of Ethics and Business Conduct. While we encourage employees to raise issues with their managers, we also maintain an Ethics and Integrity Helpline where concerns can be reported confidentially and anonymously. All reports received are triaged to ensure timely and effective follow up.

Records Maintenance

We have retained relevant documentation from our RCOI and due diligence process. Through Assent Compliance, a document retention policy to retain conflict minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented.


4.1.2 Identify and Assess Risk in Our Supply Chain

Risks associated with supplier CMRT content are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent Compliance staff and members of the internal Conflict Minerals Team, who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at the company level. LivaNova is unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied in the case of a company-level CMRT (such as when a company declares there are no 3TGs in any of its products). Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent Compliance compared facilities listed in the responses to the list of smelters and refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TG processing facility that was operational during the 2020 calendar year.

Assent Compliance determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). LivaNova does not have a direct relationship with smelters and refiners and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed an RMAP audit are considered to be DRC-conflict free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

Geographic proximity to the DRC and covered countries
Known mineral source country of origin
RMAP audit status
Credible evidence of unethical or conflict sourcing; and/or
Peer assessments conducted by credible third-party sources

Risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through Assent Compliance, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.

4.1.3 Design and Implement a Strategy to Respond to Risks

Together with Assent Compliance, LivaNova developed processes to assess and respond to the risks identified in the supply chain. LivaNova has a plan, through which the conflict minerals program is implemented, managed, and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the conflict minerals rules and LivaNova’s expectations.

Feedback on supplier submissions is given directly to suppliers, and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. Assent Compliance also communicates directly with smelters that have not yet been determined to be conformant with the RMAP to request sourcing information and encourage their involvement with the RMI program.

In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, LivaNova assesses if replacement of such supplier is feasible.

4.1.4 Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

LivaNova does not have a direct relationship with SORs of 3TGs and as a result, LivaNova does not perform direct audits of these entities in its supply chain. LivaNova relies on the efforts of the industry associations that administer independent third-party SOR audit programs and encourages suppliers with more direct relationships with SORs to participate in comparable due diligence validation activities.

Assent Compliance also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.

4.1.5. Report on Supply Chain Due Diligence

This Conflict Minerals Report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at

This year, LivaNova has also considered impacts from the European Union Conflict Minerals Rule when disclosing details with regards to due diligence efforts. We continue to expand efforts to increase transparency through our data collection process and risk evaluation, as well as for disclosure by way of public reporting tools.

5.Due Diligence Results

During our due diligence efforts, members of Assent Compliance and/or members of the LivaNova supply chain team made at least three follow-up inquiries to each “non-responsive” supplier who did not respond to our initial survey, by phone or email. Assent Compliance reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent Compliance worked directly with those suppliers to provide revised responses.


The large majority of the responses received provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a part number that the supplier supplies to us, or were otherwise unable to specify the SORs used for components supplied to us. We were therefore unable to determine whether any of the 3TGs that these suppliers reported were contained in components or parts supplied to us.

As noted above, we received 233 responses from our in-scope suppliers as of May 19, 2021. Based on these responses, for all responses that indicated a SOR, our third-party consultant compared the facilities listed to the list of SORs maintained by the RMI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent Compliance confirmed that the name was listed by RMI as a certified SOR. No violations were identified. As of May 19, 2021, we have validated 331 SORs, and we are working to validate the additional SOR entries from the submitted CMRTs. Appendix A lists all legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix B includes an aggregated list of the potential countries of origin from which the reported facilities collectively source conflict minerals, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. It is understood that many responses may provide more data than can be directly linked to LivaNova products, therefore, Appendix B may contain more countries than those that our products are being sourced from.

Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, we have identified 237 SORs that are RMAP Conformant and an additional 24 that are RMAP Active as defined by the RMI smelter data. The remaining 70 have been identified as Non-Conformant or Not Enrolled.

Efforts to Determine Mine or Location of Origin

By requesting that our suppliers complete the CMRT, and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the SORs as well as the tracing of the 3TGs to their location of origin, we have determined that seeking information about 3TGs SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain.

6.Planned Process Improvements to Mitigate Risks

We intend to take the following steps to improve our conflict minerals program:

Track and add new suppliers who provide components containing 3TGs to the conflict minerals program.

Engage with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses.

Engage any suppliers found to be supplying 3TG from sources in the DRC or any adjoining country that is not definitively “DRC conflict free”, to establish an alternative source of 3TG that they can definitively identify as “DRC conflict free”.

Continue to consider the European Union Conflict Minerals Rule within our conflict mineral program and when applicable to LivaNova, comply with the relevant requirements.


Continue to evaluate our conflict mineral program and, if necessary, implement relevant updates, e.g., if cobalt becomes a mandatory regulation compliance requirement.


Appendix A 2020 Smelter or Refiner (SOR) List
The following smelters and refiners were reported by our suppliers as being in their supply chains. Only those which were validated as being legitimate are provided. The validation process involves cross-referencing incoming data from our suppliers with the Assent Compliance database, as well as the latest publicly available Responsible Minerals Initiative (RMI) smelter data.
MetalStandard Smelter NameSmelter Facility LocationSmelter ID
Gold8853 S.p.A.ITALYCID002763
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAfrican Gold RefineryUGANDACID003185
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAugmont Enterprises Private LimitedINDIACID003461
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldEmerald Jewel Industry India Limited (Unit 1)INDIACID003487
GoldEmerald Jewel Industry India Limited (Unit 2)INDIACID003488
GoldEmerald Jewel Industry India Limited (Unit 3)INDIACID003489
GoldEmerald Jewel Industry India Limited (Unit 4)INDIACID003490
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Coast RefineryGHANACID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
GoldIstanbul Gold RefineryTURKEYCID000814
GoldJALAN & CompanyINDIACID002893
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldK.A. RasmussenNORWAYCID003497
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKundan Care Products Ltd.INDIACID003463
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldL'Orfebre S.A.ANDORRACID002762
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldMarsam MetalsBRAZILCID002606
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMD OverseasINDIACID003548
GoldMetal Concentrators SA (Pty) Ltd.SOUTH AFRICACID003575
GoldMetallix Refining Inc.UNITED STATES OF AMERICACID003557
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldRoyal Canadian MintCANADACID001534
GoldSafimet S.p.AITALYCID002973
GoldSai RefineryINDIACID002853
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldSancus ZFS (L’Orfebre, SA)COLOMBIACID003529
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSellem Industries Ltd.MAURITANIACID003540
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CHINACID002527
GoldShirpur Gold Refinery Ltd.INDIACID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaBRAZILCID003486
TinCRM SynergiesSPAINCID003524
TinCV Venus Inti PerkasaINDONESIACID002455
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572
TinEstanho de Rondonia S.A.BRAZILCID000448
TinFenix MetalsPOLANDCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinGejiu Fengming Metallurgy Chemical PlantCHINACID002848
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinLuna Smelter, Ltd.RWANDACID003387
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMitsubishi Materials CorporationJAPANCID001191
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573
TinNovosibirsk Processing Plant Ltd.RUSSIAN FEDERATIONCID001305
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinPT Aries Kencana SejahteraINDONESIACID000309
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Babel Inti PerkasaINDONESIACID001402
TinPT Babel Surya Alam LestariINDONESIACID001406
TinPT Bangka SerumpunINDONESIACID003205
TinPT Bukit TimahINDONESIACID001428
TinPT Lautan Harmonis SejahteraINDONESIACID002870
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
TinPT Mitra Sukses GlobalindoINDONESIACID003449
TinPT Prima Timah UtamaINDONESIACID001458
TinPT Rajawali Rimba PerkasaINDONESIACID003381
TinPT Rajehan AriqINDONESIACID002593
TinPT Refined Bangka TinINDONESIACID001460
TinPT Stanindo Inti PerkasaINDONESIACID001468
TinPT Sukses Inti MakmurINDONESIACID002816
TinPT Timah NusantaraINDONESIACID001486
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinPT Tinindo Inter NusaINDONESIACID001490
TinResind Industria e Comercio Ltda.BRAZILCID002706


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
TinSoft Metais Ltda.BRAZILCID001758
TinSuper LigasBRAZILCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574
TinVQB Mineral and Trading Group JSCVIET NAMCID002015
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChina Molybdenum Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281
TungstenCronimet Brasil LtdaBRAZILCID003468
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGEM Co., Ltd.CHINACID003417
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825


MetalStandard Smelter NameSmelter Facility LocationSmelter ID
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830


Appendix B 2020 Countries of Origin List

This list of potential countries of origin is populated based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. It is important to note that the below list includes every potential country reported by our suppliers, regardless of whether the materials at issue used by LivaNova originated from that particular country. As a result, Appendix B may contain more countries than those from which our products are being sourced.

Country of Origin ListCountry of Origin ListCountry of Origin ListCountry of Origin List
AfghanistanEcuadorLithuaniaSaudi Arabia
AlbaniaEgyptLuxembourgSierra Leone
AustraliaFinlandMauritaniaSouth Africa
BurundiIndonesiaNew ZealandTurkey
CanadaIsraelNigeriaUnited Arab Emirates
Central African RepublicItalyPapua New GuineaUnited Kingdom
ChileIvory CoastPeruUSA
Czech RepublicKenyaPortugalZambia
DjiboutiKyrgyzstanRepublic Of KoreaZimbabwe
Dominican RepublicLaosRussia 
DRC or an adjoining country (Covered Countries)LiberiaRwanda