UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
LivaNova PLC
England and Wales (State or Other Jurisdiction of Incorporation) | 001-37599 (Commission File Number) | 98-1268150 (IRS Employer Identification No.) | ||
20 Eastbourne Terrace
London, United Kingdom
W2 6LG
(Address of Principal Executive Offices) (Zip Code)
Pascal Govi
Senior Vice President, Global Operations
+44 (0)203 325 0660
(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, 2016. |
INFORMATION TO BE INCLUDED IN THE REPORT
Section 1—Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
LivaNova PLC, a public limited company incorporated under the laws of England and Wales (“LivaNova”) was formed for the purpose of facilitating the business combination of Cyberonics, Inc., a Delaware corporation (“Cyberonics”), and Sorin S.p.A., a joint stock company organized under the laws of Italy (“Sorin”). Cyberonics was considered the accounting acquirer and LivaNova PLC (“LivaNova”, “registrant”, “we”, “us”, or “our”) became the successor organization to Cyberonics. Per the instructions to Item 1.01 of the SEC’s Form SD, a “registrant that acquires or otherwise obtains control over a company that manufactures or contracts to manufacture products with conflict minerals necessary to the functionality or production of those products that previously had not been obligated to provide a specialized disclosure report with respect to its conflict minerals will be permitted to delay reporting on the products manufactured by the acquired company until the end of the first reporting calendar year that begins no sooner than eight months after the effective date of the acquisition.” As a result, LivaNova is filing this Specialized Disclosure Report on Form SD (this “Form SD”) for legacy Cyberonics’ supply chain operations for the year ended December 31, 2016. 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, 2016 to December 31, 2016.
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 http://www.livanova.com/investor-relations/sec-filings.
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.
Exhibit | Description | |
10.1 | Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. | |
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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.
LivaNova PLC | |
Date: May 30, 2017 | By:/s/ Catherine Moroz |
Name: Catherine Moroz | |
Title: Company Secretary | |
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Exhibit 1.01
LivaNova PLC
Conflict Minerals Report
For the Year Ended December 31, 2016
This Conflict Minerals Report of LivaNova PLC (this “Report”) has been prepared for the reporting period from January 1, 2016 to December 31, 2016 for Cyberonics, Inc. 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-tanlite (tantalum), gold, wolframite (tungsten), (together, “3TG”) or their derivatives (“Conflict Minerals”). The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, 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.
If a registrant has reason to believe that any of the 3TGs necessary to the functionality or production of their products may have originated in the Covered Countries, or if they are unable to determine the country of origin of those minerals, then the registrant must exercise due diligence on the minerals’ source and chain of custody and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
1. | Company Overview |
This Report has been prepared by the management of LivaNova PLC (“LivaNova,” “we,” “us,” “registrant,” or “our”). It does not include the activities of variable interest entities that are not required to be consolidated.
As described in Item 1.01 of the Form SD, LivaNova PLC, a public limited company incorporated under the laws of England and Wales (“LivaNova”) was formed for the purpose of facilitating the business combination of Cyberonics, Inc., a Delaware corporation (“Cyberonics”), and Sorin S.p.A., a joint stock company organized under the laws of Italy (“Sorin”). Cyberonics was considered the accounting acquirer and LivaNova PLC (“LivaNova”, “registrant”, “we”, “us”, or “our”) became the successor organization to Cyberonics. Per the instructions to Item 1.01 of the SEC’s Form SD, a “registrant that acquires or otherwise obtains control over a company that manufactures or contracts to manufacture products with conflict minerals necessary to the functionality or production of those products that previously had not been obligated to provide a specialized disclosure report with respect to its conflict minerals will be permitted to delay reporting on the products manufactured by the acquired company until the end of the first reporting calendar year that begins no sooner than eight months after the effective date of the acquisition.” As a result, in this Form SD and related Conflict Minerals Report, LivaNova is reporting the results for LivaNova Neuromodulation (Cyberonics’) supply chain operations for the year ended December 31, 2016.
LivaNova 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 medical professionals in the fields of Cardiac Surgery, Neuromodulation and Cardiac Rhythm Management, we design, develop, manufacture and sell innovative therapeutic solutions that are consistent with our mission to improve our patients’ quality of life, increase the skills and capabilities of healthcare professionals and minimize healthcare costs.
LivaNova Neuromodulation (Cyberonics) currently operates as one of LivaNova’s three business units, with core expertise in neuromodulation. Cyberonics develops and markets the VNS Therapy System®, which is FDA-approved for the treatment of refractory epilepsy and treatment-resistant depression. The VNS Therapy System uses an implanted medical device that delivers pulsed electrical signals to the vagus nerve. The VNS Therapy System is offered in selected markets worldwide.
Our VNS Therapy System includes the following:
• | an implantable pulse generator to provide appropriate stimulation to the vagus nerve; |
• | a lead that connects the pulse generator to the vagus nerve; |
• | a surgical instrument to assist with the implant procedure; |
• | equipment to enable the treating physician to set the pulse generator stimulation parameters for the patient; |
• | instruction manuals; and |
• | magnets to suspend or induce stimulation manually. |
Our broad and complex product range may contain conflict minerals within the following components:
• | Tantalum, used in capacitors; |
• | Tin, used in soldered components; |
• | Tungsten, used in coatings, alloys, heating elements and electrodes; and |
• | Gold, used in circuit boards, electrodes and electronic components. |
Additional information on LivaNova and the VNS Therapy System is available at www.livanova.com.
2. | General Policy and Team |
We strive to conduct our activities in a manner that reflects our mission and Code of Business Conduct and Ethics - 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, Cyberonics supports the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products and that 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 in the DRC in our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and to comply with our Code of 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 beginning our analysis in conjunction with our partners at Assent Compliance, 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 (“RCOI”) with respect to 3TGs contained in our products by assessing our supply chain in accordance with the OECD Guidance (as defined below).
The RCOI was designed to determine whether any 3TGs contained in our products originated in the Covered Countries. The “Covered Countries” for the purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. 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 manufactured products contain one or more of the 3TGs; |
• | Identifying our suppliers that manufactured or contracted to manufacture products containing 3TGs in 2016; and |
• | Identified suppliers that provide product or service that are deemed out of scope (provide material that does not ship with or does not impact functionality of the final product). |
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The supply chain survey, and the conflict minerals program as a whole, has been developed and implemented in cooperation with Assent Compliance.
Our primary means of determining country of origin information for the necessary 3TGs was by conducting a supply chain survey with direct suppliers using the Conflict Minerals Reporting Template, or CMRT, developed by the EICC GeSI. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, engagement with its direct suppliers, and a listing of the smelters and refiners that the direct supplier and its suppliers source from. In addition, the CMRT contains questions about the origin of conflict minerals included in the direct supplier’s products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool are available on EICC’s website as well as provided by Assent Compliance. The CMRT version 4.10 or higher was the industry standard template used for conflict minerals data collection for 2016.
We surveyed 84 suppliers based on the scoping process noted above. Responses were tracked and supplier statuses reported regularly by Assent to LivaNova. As of May 19, 2017, we received responses from 82% of the suppliers surveyed.
During the survey, Assent Compliance assessed the supplier list and received information from suppliers in the following groups that could be deemed as out of scope:
• | Service providers/suppliers |
• | Indirect materials suppliers |
• | Inactive suppliers (minimum 5 years since last purchase) |
Once Assent received confirmation from LivaNova on these designations, the suppliers were classified as Out of Scope in the Assent Compliance Manager (“ACM”), which is the software tool used to manage the conflict minerals program. Through this process three suppliers were deemed out of scope.
Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions, identify submissions not including smelter lists and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted in regards to invalid forms and were encouraged to resubmit a valid form. As of May 19, 2017, we still had three invalid supplier submissions that were not yet corrected.
There were some suppliers who were unable to provide smelter or refiner lists and suppliers who could not provide full smelter lists. Accordingly, before conducting an in-depth examination of the smelter information itself, it is important to note that since the Company was unable to obtain full smelter information from all in-scope suppliers, Cyberonics 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
Cyberonics designed its due diligence process to be in conformity, in all material respects, with the due diligence framework of the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively the “OECD Guidance”). Cyberonics’ due diligence process is based on multi-industry initiatives with the smelters and refiners who provide conflict minerals within global supply chains.
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4.1.1 Establish Strong Company Management and Control Systems
Conflict Minerals Policy
Cyberonics has adopted a Conflict Minerals Policy, which is provided in section 2 of this report.
Internal Team and Training
The Company has established a management team relating to conflict minerals. Our management team is overseen by the Senior Vice President 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 is led by the Sr. Manager of Purchasing, who acts as the Conflict Minerals Program Manager.
The Company has provided external and internal training to key personnel involved in supply chain activities. This year, we have also provided all in-scope suppliers with access to online training courses utilizing Assent Compliance’s Learning Management System, Assent University.
Control Systems
The Company expects its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to LivaNova are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. Other controls include, but are not limited to, our Code of Business Conduct and Ethics 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.
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 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 accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with Assent Compliance, provided education to suppliers on the Conflict Minerals regulations as well as the expectations of the law. This year, we have also utilized Assent Compliance’s Learning Management System, Assent University. Through this tool we have provided all in-scope suppliers with online training courses that are tracked and evaluated based on completion. In addition, we have leveraged the 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 the training, focus it and adapt it to each user’s needs. It has also allowed for our supplier communications to be more focused and ensure expectations are clear.
As part of our risk management plan, we intend to include a clause in our supplier contracts that requires suppliers to provide information about the sourcing of conflict minerals and smelters and to ensure that suppliers are conducting due diligence on the source and chain of the conflict minerals. We anticipate this effort may take several years to ensure that all our supplier contracts contain appropriate flow-down clauses as some of the contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. Therefore, we expect to add these new provisions as our contracts are renewed or when entering into new contracts.
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Grievance Mechanism
We have longstanding grievance mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Code of Business Conduct and Ethics policy.
Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence process.
4.1.2 Identify and Assess Risk in Our Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult for us to identify actors upstream from our direct suppliers.
We have identified over 148 direct suppliers to the company. Out of those 148 suppliers, we initially deemed 64 as out of scope based upon the criteria listed above. We then based our RCOI on the remaining 84 suppliers. We rely on suppliers whose materials or components contain 3TGs to provide us with information about the source of 3TGs contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or are suppliers to other SEC registrants that are subject to the Rule.
In accordance with OECD Guidelines, it is important to understand risk levels associated with 3TGs in the supply chain. Smelter(s) or refiner(s) (“SORs”) that are not certified as DRC-Conflict Free by third party sources such as the Conflict-Free Sourcing Initiative (“CFSI”) pose a potential risk. Where a smelter is not identified as Conflict Free, it is assigned a risk rating of High, Medium or Low. This rating is based on various factors, including the SOR’s geographic location, including proximity to the Covered Countries, the SOR’s Conflict-Free Smelter Program (CFSP) audit status, and any known or plausible evidence of unethical or conflicting sourcing.
We calculate supplier risk based on the chances that a supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT. Based on the above criteria the following facilities have been identified as being of highest concern to the supply chain:
• | Tony Goetz NV - CID002587 |
• | Kaloti Precious Metals - CID002563 |
• | Phoenix Metals - CID002507 |
• | Universal Precious Metals Refining Zambia - CID002854 |
• | Fidelity Printers and Refiners - CID002515 |
• | Sudan Gold Refinery - CID002567 |
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to the Company, and escalating up to removal of these high-risk smelters from their supply chain.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of these risks from the supply chain.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
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• | Do you have a policy in place that includes DRC conflict-free sourcing? |
• | Have you implemented due diligence measures for conflict-free sourcing? |
• | Do you verify due diligence information received from your suppliers? |
• | Does your verification process include corrective action management? |
When suppliers answer yes, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
The SORs listed by suppliers in their CMRTs were matched against a database of verified SORs. Verified SORs were matched against available lists of processors that have been certified by internationally-recognized industry validation schemes, such as the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program. In cases where suppliers and products were associated with certified SORs they were categorized by the Company as “DRC Conflict Free.”
If the SOR was not certified by an internationally-recognized organization, research was conducted to gain more information about the SOR’s sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR had taken to track the chain-of-custody on the source of its mineral ores.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG 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. This was done by adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.
4.1.3 Design and Implement a Strategy to Respond to Risks
In designing and implementing our strategy to respond to the supply chain risks that we identified, Cyberonics analyzed various industry approaches and consulted with other companies in our industry. The Company has established a risk management plan through which the conflict minerals program is implemented, managed and monitored.
As part of our risk management plan, to ensure suppliers understand our expectations, we have provided both video, online training courses and documented instructions through Assent Compliance. We answered all questions or requests for clarification from suppliers, assistance completing the CMRT and one-on-one email or phone discussions with supplier personnel. We then provided each supplier a copy of the CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with specific suppliers where we needed clarification. We intend to engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. In cases where suppliers may contain 3TG, Cyberonics will assess the risks and determine the response strategy to address those scenarios.
4.1.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Cyberonics does not have a direct relationship with SORs of 3TGs and as a result, Cyberonics does not perform direct audits of these entities in its supply chain. Cyberonics 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.
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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 http://www.livanova.com/investor-relations/sec-filings.
5. | Due Diligence Results |
During our due diligence efforts, members of Assent Compliance and/or members of the Cyberonics 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 was contained in components or parts supplied to us are actually in our supply chain.
As noted above, we received 82% responses from our in-scope suppliers as of May 19, 2017. 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 CFSI. If a supplier indicated that the facility was certified as “Conflict-Free,” Assent Compliance confirmed that the name was listed by CFSI as a certified SOR. No violations were identified. As of May 19, 2017, we have validated 311 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 upon information provided by suppliers and CFSI.
Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, we have identified 246 SORs that are certified conflict free smelters by the CFSI.
Efforts to Determine Mine or Location of Origin
By requesting our suppliers to 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.
Planned Process Improvements
We intend to take the following steps to improve our conflict minerals program:
• | Track and add new suppliers as they enter our supply chain to the Company’s Conflict Minerals program. |
• | Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
• | Engage any of our suppliers found to be supplying us with 3TG from sources in the DRC or any adjoining country that they cannot demonstrate are “DRC conflict free” to establish an alternative source of 3TG that they can demonstrate are “DRC conflict free”. |
• | Expand the program to include all other divisions of LivaNova that were previously excluded prior to the merger. |
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Appendix A 2016 Smelter or Refiner (SOR) List
The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme (CFSI) for 3TGs smelters and refiners are identified below.
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | CFSI Audit Status |
Gold | Advanced Chemical Company | UNITED STATES | CID000015 | Compliant |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Compliant |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | Compliant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Compliant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Compliant |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 | Compliant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Compliant |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Compliant |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Compliant |
Gold | Asahi Refining USA Inc. | UNITED STATES | CID000920 | Compliant |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Compliant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | Not Enrolled |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | Compliant |
Gold | AURA-II | UNITED STATES | CID002851 | Not Enrolled |
Gold | Aurubis AG | GERMANY | CID000113 | Compliant |
Gold | Bangalore Refinery | INDIA | CID002863 | Active |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Compliant |
Gold | Boliden AB | SWEDEN | CID000157 | Compliant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Compliant |
Gold | Caridad | MEXICO | CID000180 | Not Enrolled |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Compliant |
Gold | Cendres + Métaux S.A. | SWITZERLAND | CID000189 | Active |
Gold | Chimet S.p.A. | ITALY | CID000233 | Compliant |
Gold | Chugai Mining | JAPAN | CID000264 | Not Enrolled |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | Compliant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | Not Enrolled |
Gold | DODUCO GmbH | GERMANY | CID000362 | Compliant |
Gold | Dowa | JAPAN | CID000401 | Compliant |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Compliant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 | Compliant |
Gold | Elemetal Refining, LLC | UNITED STATES | CID001322 | Compliant |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Compliant |
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Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | Not Enrolled |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | CID000522 | Not Enrolled |
Gold | Geib Refining Corporation | UNITED STATES | CID002459 | Active |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Not Enrolled |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Not Enrolled |
Gold | Gujarat Gold Centre | INDIA | CID002852 | Not Enrolled |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | Not Enrolled |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | Not Enrolled |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Compliant |
Gold | Heraeus Ltd. Hong Kong | CHINA | CID000707 | Compliant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Compliant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Not Enrolled |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 | Not Enrolled |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Compliant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Compliant |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Compliant |
Gold | Japan Mint | JAPAN | CID000823 | Compliant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Compliant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | Compliant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Compliant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Compliant |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | Not Enrolled |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | Not Enrolled |
Gold | Kazzinc | KAZAKHSTAN | CID000957 | Compliant |
Gold | Kennecott Utah Copper LLC | UNITED STATES | CID000969 | Compliant |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | CID002511 | Active |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Compliant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Compliant |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Compliant |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 | Not Enrolled |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Not Enrolled |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Not Enrolled |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Compliant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Not Enrolled |
Gold | Materion | UNITED STATES | CID001113 | Compliant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Compliant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Compliant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Compliant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | Compliant |
9
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Compliant |
Gold | Metalor USA Refining Corporation | UNITED STATES | CID001157 | Compliant |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | CID001161 | Compliant |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Compliant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Compliant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Compliant |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Not Enrolled |
Gold | Morris and Watson | NEW ZEALAND | CID002282 | Not Enrolled |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Compliant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | CID001220 | Compliant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Active |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Compliant |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Compliant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Compliant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Compliant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Compliant |
Gold | PAMP S.A. | SWITZERLAND | CID001352 | Compliant |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Not Enrolled |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Compliant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Compliant |
Gold | PX Précinox S.A. | SWITZERLAND | CID001498 | Compliant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Compliant |
Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 | Not Enrolled |
Gold | Republic Metals Corporation | UNITED STATES | CID002510 | Compliant |
Gold | Royal Canadian Mint | CANADA | CID001534 | Compliant |
Gold | SAAMP | FRANCE | CID002761 | Not Enrolled |
Gold | Sabin Metal Corp. | UNITED STATES | CID001546 | Not Enrolled |
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | Not Enrolled |
Gold | Sai Refinery | INDIA | CID002853 | Not Enrolled |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Compliant |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Not Enrolled |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | Compliant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 | Compliant |
Gold | SEMPSA Joyería Platería S.A. | SPAIN | CID001585 | Compliant |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Not Enrolled |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Compliant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Compliant |
Gold | Singway Technology Co., Ltd. | TAIWAN | CID002516 | Compliant |
Gold | So Accurate Group, Inc. | UNITED STATES | CID001754 | Not Enrolled |
10
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Compliant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | CID001761 | Compliant |
Gold | Sudan Gold Refinery | SUDAN | CID002567 | Not Enrolled |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Compliant |
Gold | T.C.A S.p.A | ITALY | CID002580 | Compliant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Compliant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Compliant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Compliant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Not Enrolled |
Gold | Tony Goetz NV | BELGIUM | CID002587 | Active |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Not Enrolled |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Compliant |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Compliant |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Compliant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Compliant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | CID001993 | Compliant |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 | Not Enrolled |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Compliant |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | Compliant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | Compliant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | CID002100 | Compliant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | Compliant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Not Enrolled |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Compliant |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | CID002243 | Compliant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Compliant |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 | Compliant |
Tantalum | D Block Metals, LLC | UNITED STATES | CID002504 | Compliant |
Tantalum | Duoluoshan | CHINA | CID000410 | Compliant |
Tantalum | Exotech Inc. | UNITED STATES | CID000456 | Compliant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Compliant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Compliant |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Compliant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | CID002557 | Compliant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Compliant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Compliant |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | CID002545 | Compliant |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | CID002546 | Not Enrolled |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | Compliant |
Tantalum | H.C. Starck Inc. | UNITED STATES | CID002548 | Compliant |
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | Compliant |
11
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Compliant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Compliant |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | CID000731 | Compliant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Compliant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Compliant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Compliant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Compliant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Compliant |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Compliant |
Tantalum | KEMET Blue Powder | UNITED STATES | CID002568 | Compliant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | CID000973 | Compliant |
Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | Compliant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Compliant |
Tantalum | Mineração Taboca S.A. | BRAZIL | CID001175 | Compliant |
Tantalum | Mitsui Mining & Smelting | JAPAN | CID001192 | Compliant |
Tantalum | Molycorp Silmet A.S. | ESTONIA | CID001200 | Compliant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Compliant |
Tantalum | Plansee SE Liezen | AUSTRIA | CID002540 | Not Enrolled |
Tantalum | Plansee SE Reutte | AUSTRIA | CID002556 | Compliant |
Tantalum | Power Resources Ltd. | MACEDONIA | CID002847 | Compliant |
Tantalum | QuantumClean | UNITED STATES | CID001508 | Compliant |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | CID002707 | Compliant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | CID001522 | Compliant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | Compliant |
Tantalum | Taki Chemicals | JAPAN | CID001869 | Compliant |
Tantalum | Telex Metals | UNITED STATES | CID001891 | Compliant |
Tantalum | Tranzact, Inc. | UNITED STATES | CID002571 | Compliant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Compliant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Compliant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 | Compliant |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | CID002232 | Compliant |
Tin | Alpha | UNITED STATES | CID000292 | Compliant |
Tin | An Thai Minerals Co., Ltd. | VIET NAM | CID002825 | Not Enrolled |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | Not Enrolled |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Compliant |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Compliant |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 | Not Enrolled |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | CID000295 | Compliant |
Tin | CV Ayi Jaya | INDONESIA | CID002570 | Compliant |
Tin | CV Dua Sekawan | INDONESIA | CID002592 | Compliant |
Tin | CV Gita Pesona | INDONESIA | CID000306 | Compliant |
12
Tin | CV Serumpun Sebalai | INDONESIA | CID000313 | Compliant |
Tin | CV Tiga Sekawan | INDONESIA | CID002593 | Compliant |
Tin | CV United Smelting | INDONESIA | CID000315 | Compliant |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | Compliant |
Tin | Dowa | JAPAN | CID000402 | Compliant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | Active |
Tin | Elmet S.L.U. | SPAIN | CID002774 | Compliant |
Tin | EM Vinto | BOLIVIA | CID000438 | Compliant |
Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 | Not Enrolled |
Tin | Fenix Metals | POLAND | CID000468 | Compliant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | Compliant |
Tin | Gejiu Jinye Mineral Company | CHINA | CID002859 | Compliant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | Active |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Compliant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | Active |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Not Enrolled |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 | Compliant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | Compliant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | Not Enrolled |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 | Compliant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Compliant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Compliant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | Compliant |
Tin | Metallic Resources, Inc. | UNITED STATES | CID001142 | Compliant |
Tin | Metallo-Chimique N.V. | BELGIUM | CID002773 | Compliant |
Tin | Mineração Taboca S.A. | BRAZIL | CID001173 | Compliant |
Tin | Minsur | PERU | CID001182 | Compliant |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Compliant |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Not Enrolled |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | Not Enrolled |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Compliant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Compliant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | CID001337 | Compliant |
Tin | Phoenix Metal Ltd. | RWANDA | CID002507 | Not Enrolled |
Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | Compliant |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Compliant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Compliant |
Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | Compliant |
Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | Compliant |
Tin | PT Bangka Tin Industry | INDONESIA | CID001419 | Compliant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 | Compliant |
13
Tin | PT Bukit Timah | INDONESIA | CID001428 | Compliant |
Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | Compliant |
Tin | PT DS Jaya Abadi | INDONESIA | CID001434 | Compliant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | CID001438 | Compliant |
Tin | PT Inti Stania Prima | INDONESIA | CID002530 | Compliant |
Tin | PT Justindo | INDONESIA | CID000307 | Not Enrolled |
Tin | PT Karimun Mining | INDONESIA | CID001448 | Compliant |
Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 | Compliant |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 | Compliant |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Compliant |
Tin | PT O.M. Indonesia | INDONESIA | CID002757 | Compliant |
Tin | PT Panca Mega Persada | INDONESIA | CID001457 | Compliant |
Tin | PT Prima Timah Utama | INDONESIA | CID001458 | Compliant |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Compliant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 | Compliant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | Compliant |
Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | Compliant |
Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 | Compliant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 | Compliant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 | Compliant |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | Compliant |
Tin | PT Tommy Utama | INDONESIA | CID001493 | Compliant |
Tin | PT Wahana Perkit Jaya | INDONESIA | CID002479 | Compliant |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | CID002706 | Compliant |
Tin | Rui Da Hung | TAIWAN | CID001539 | Compliant |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 | Compliant |
Tin | Thaisarco | THAILAND | CID001898 | Compliant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | Not Enrolled |
Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 | Compliant |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 | Compliant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | Active |
Tin | Yunnan Tin Company Limited | CHINA | CID002180 | Compliant |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 | Compliant |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | Not Enrolled |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Compliant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | Compliant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Compliant |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | CID000345 | Not Enrolled |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | Compliant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | Compliant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Compliant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Compliant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 | Not Enrolled |
14
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | CID000568 | Compliant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Compliant |
Tungsten | H.C. Starck GmbH | GERMANY | CID002541 | Compliant |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002542 | Compliant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Compliant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 | Compliant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | Compliant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | Compliant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Compliant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Compliant |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 | Not Enrolled |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Compliant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Not Enrolled |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Compliant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Compliant |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 | Compliant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Compliant |
Tungsten | Kennametal Fallon | UNITED STATES | CID000966 | Compliant |
Tungsten | Kennametal Huntsville | UNITED STATES | CID000105 | Compliant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Compliant |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | CID002845 | Compliant |
Tungsten | Niagara Refining LLC | UNITED STATES | CID002589 | Compliant |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 | Compliant |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Compliant |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 | Compliant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | Compliant |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | Compliant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 | Compliant |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 | Compliant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | Compliant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Compliant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Compliant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | Compliant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | Compliant |
15
Appendix B 2016 Countries of Origin List
Countries of origin of the conflict minerals that the facilities listed in Appendix A process are believed to include the following countries, based on information provided by suppliers, and the CFSI, and are aggregated for confidentiality purposes:
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D'Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia
16