SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
SPECIALIZED DISCLOSURE REPORT
(Exact name of registrant as specified in its charter)
|(State or other jurisdiction of||Commission file number||(IRS Employer Identification|
|incorporation or organization)||No.)|
|c/o Stratasys, Inc.||1 Holtzman Street, Science Park|
|7665 Commerce Way||P.O. Box 2496|
|Eden Prairie, Minnesota 55344||Rehovot, Israel 76124|
|(Address of principal executive offices)|
Vered Ben Jacob, Esq.,
Vice President Corporate Legal Affairs, +972-74-745-4029
(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, 2017.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In accordance with the requirements of Item 1.01(c) of Form SD, Stratasys Ltd. (“Stratasys”) has posted the Conflict Minerals Report filed as Exhibit 1.01 hereto to its publically available Internet website at http://www.stratasys.com/corporate/investor-relations/financial-information/sec-filings.
Item 1.02 Exhibit
Stratasys has filed its Conflict Minerals Report as Exhibit 1.01 hereto as required by Item 1.01 of Form SD.
Section 2 — Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report.
Exhibit 1.01 — Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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.
|May 30, 2018||/s/ Lilach Payorski|
|By: Lilach Payorski|
|Chief Financial Officer|
Conflict Minerals Report of Stratasys Ltd.
This is the Conflict Minerals Report of Stratasys Ltd. for calendar year 2017 in accordance with Rule13p-1 of the Securities Exchange Act of 1934 (“Rule 13p-1”) and Form SD. The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to "Conflict Minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals that are necessary to the functionality or production of their products. If the SEC registrant has reason to believe that any of those Conflict Minerals may have originated in the Democratic Republic of the Congo (the “DRC”) or a country that shares an internationally recognized border with the Democratic Republic of the Congo (collectively, “Covered Countries”) or is unable to determine the country of origin of those Conflict Minerals, the SEC registrant is required to submit a Conflict Minerals Report to the SEC that includes a description of the measures it took to exercise due diligence on the Conflict Minerals’ source and chain of custody.
Stratasys Ltd. (“Stratasys” or “we”) is the product of the 2012 merger of two leading additive manufacturing companies, Stratasys, Inc. and Objet Ltd. Our ordinary shares are listed on the NASDAQ Global Select Market under the trading symbol “SSYS”. We have dual headquarters. One of our two principal places of business is located at 7665 Commerce Way, Eden Prairie, Minnesota. Our registered office and other principal place of business is located at 1 Holtzman Street, Science Park, P.O. Box 2496, Rehovot 76124, Israel.
We are a leading global provider of applied additive technology solutions for industries including aerospace, automotive, healthcare, consumer products and education. For nearly 30 years, we have focused on customers’ business requirements and have sought to create new value for our customers across their product lifecycle processes, from design prototypes to manufacturing tools and final production parts. This customer-centric focus is reflected in our innovation, which is exemplified by our 1,200 granted and pending additive technology patents to date. We operate a 3D printing ecosystem of solutions and expertise, comprised of advanced materials; software with voxel level control; precise, repeatable and reliable fused deposition modeling (FDM) and PolyJet 3D printers; application-based services; on-demand parts and key partnerships. We strive to ensure that our solutions are integrated seamlessly into each customer’s evolving workflow. Our applications are industry-specific and geared towards accelerating business processes, optimizing value chains and driving business performance improvements. Our customers range from individuals and smaller businesses to large, global enterprises, and we include a number of Fortune 100 companies among our customers.
We believe that the range of 3D printing consumable materials that we offer, consisting of 58 FDM cartridge-based materials, 37 PolyJet cartridge-based materials, 158 non-color digital materials, and over 500,000 color variations is the widest in the industry. Our service offerings include Stratasys Direct Manufacturing printed parts services which offers AM capabilities encompassing a wide range of technologies allowing for plastic and metal parts for rapid prototyping and production processes, as well as related professional services.
We offer a broad range of systems, consumables and services for 3D printing and additive manufacturing. Our wide range of solutions, based on our proprietary 3D printing technologies and materials, enhance the ability of designers, engineers and manufacturers to:
visualize and communicate product ideas and designs;
verify the form, fit and function of prototypes;
manufacture tools, jigs, fixtures, casts and injection molds used in the process of manufacturing end-products;
manufacture customized and short-run end-products more efficiently and with greater agility; and
produce objects that could not otherwise be manufactured through subtractive manufacturing methodologies.
We offer a dedicated range of products for applications such as rapid prototyping (RP), tooling, as well as manufacturing parts. Our products include 3D printing systems, consumable materials, software and services.
Collectively, this portfolio of products offers a broad range of performance options for users, depending on their desired application, as well as on the nature and size of the designs, prototypes or final parts they seek to produce. Our products are available at a variety of different price points and include entry-level desktop 3D printers, a range of systems for RP, and large production systems for additive manufacturing. We also offer a range of 3D printing materials (as described under “Consumable materials” below).
Our systems also integrate our software and are supported by services that we provide to our customers, both directly and through our reseller channel.
Our 3D printing systems, which are based on our proprietary FDM and PolyJet technologies, are described below:
We offer a series of printing systems suitable for RP, from design validation, visualization and communication to form, fit and functional performance testing. These systems are targeted at work groups and offers a variety of products that provide customers with a broad range of choices of features such as printing capacity, production speed and price. The Objet systems offer high accuracy and print quality using a variety of PolyJet materials. The new F123 product line allows users to create parts in PLA, ABS plus, ASA and PC-ABS materials. These materials enable production of parts with the strength required for true form, fit and functional testing. The F123 is designed to enable ease of use and ease of maintenance and offers easy-to-use but functionality-rich user experience by using the GrabCAD Print software.
We also offer printing systems typically used for Additive Manufacturing – production tooling and end parts applications - and high performance Prototyping applications.
Our FDM technology based systems produce durable, production-grade thermoplastic heated parts suitable for RP manufacturing, tooling and end-used parts use cases.
Our PolyJet technology based high-end printing systems offer the ability to print multiple materials including color printing in a single part build.
Our MakerBot Replicator series represents our desktop 3D printers, compact, and professional-grade 3D printers. Our desktop and compact 3D printers are affordable, and designed for easy, desktop use and are typically used by individuals operating alone or within an enterprise. Our larger, professional 3D printer has a large build volume ideal for industrial prototypes, models and products.
The materials we sell are described below:
The modeling and support filament used in the FDM-based 3D printers and production systems features a wide variety of production grade thermoplastic materials. We continue to develop filament modeling materials that meet our customers’ needs for increased speed, strength, accuracy, surface resolution, chemical and heat resistance, color, and mechanical properties. These materials are processed into our proprietary filament form, which is then utilized by our FDM systems. Our spool-based system has proven to be a significant advantage for our products, because it allows the user to quickly change material by simply mounting the lightweight spool and feeding the desired filament into the FDM devices that are office friendly. Currently, we have a variety of build materials in multiple colors commercially available for use with our FDM technology.
Each material has specific characteristics that make it appropriate for various applications. The ability to use different materials allows the user to match the material to the end use application, whether it is a pattern for tooling, a concept model, a functional prototype, a manufacturing tool, or a DDM end use part.
Our resin consumables, which consist of our PolyJet family of proprietary acrylic-based photopolymer materials as well as our other inkjet-based systems, and enable users of those products to create highly accurate, finely detailed 3D models and parts for a wide range of prototype development and customized manufacturing applications. The wide variety of resins within the PolyJet family is characterized by transparent, colored, or opaque visual properties and flexible, rigid or other physical properties. Support materials that are used together with the model materials enable the 3D printing of models with a wide array of complex geometries. Our resin materials are produced in-house and are specially designed for our printing systems.
We have invested significant research and development efforts in optimizing our PolyJet materials for use with inkjet technology. These efforts are reflected in the properties of these materials, which enable them to be packaged, stored, combined and readily cured upon printing. Our PolyJet materials are packaged in cartridges for safe handling and are suitable for use in office environments. The polymerized materials can also be machined, drilled, chrome-plated or painted in most cases.
Stratasys Direct Manufacturing paid-parts service
Stratasys Direct Manufacturing was formed on January 1, 2015 from our three AM service companies – RedEye (formerly a business unit of Stratasys, Inc.) and the acquired businesses known as Harvest Technologies and Solid Concepts – and is a provider of 3D printing and custom AM services. Stratasys Direct Manufacturing offers AM capabilities encompassing a wide range of technologies allowing for plastic and metal parts for rapid prototyping and production processes. Our Stratasys Direct Manufacturing paid-parts service produces prototypes and end-use parts for customers from a customer-provided CAD file. This allows the customer to benefit from our process-related knowhow, capitalize on the variety of materials and machine types available through our service center, and take advantage of additional capacity using the latest in proven RP and DDM technologies and processes. Our Stratasys Direct Manufacturing business operates a website service, www.stratasysdirect.com, which enables our customers to obtain quotes and order parts around the clock, seven days a week. Stratasys Direct Manufacturing also provides companies with access to an Expert Services team, which helps companies to identify and evaluate new applications for 3D printing.
Recent Key Portfolio Additions & Innovations
To further strengthen our leadership position and following our strategy to deepen the focus on additive manufacturing, tooling and rapid prototyping for specific vertical market, we announced a variety of innovations in 2016 and 2017 across multiple applications for various key vertical markets, such as automotive, aerospace, consumer products and healthcare.
The Stratasys F123 Series – Smarter Prototyping for Workgroups
In February 2017, we introduced the F123 Series, a new comprehensive rapid prototyping solution that answers the specific needs of professional designers and engineers in the workgroup and office setting. For the first time, the F123 Series enables end-to-end rapid prototyping for every stage of the prototyping process: Rapid, economically-effective concept verification models in PLA material and fast-draft mode; advanced design validation prototypes using a 0.005 in. slice resolution and soluble support for unmatched precision, repeatability and aesthetics. Functional performance testing is enabled with a wide range of functional FDM materials including ABS, ASA, and PC-ABS.
Utilizing over 30 patented inventions selected from the entire Stratasys FDM range together with several new patents pending, the F123 Series offers wide-ranging engineering and interface usability enhancements to answer the needs of design workgroups: Engineering grade quality prototyping results - but easy enough for anyone to learn and operate. Professional levels of productivity -but quiet and unobtrusive enough to work in the office environment. The system incorporates GrabCAD Print software that enables printing straight from native CAD files, as well as the ability to manage jobs in real-time and remotely. The F123 Series comes in a range of 3 versatile platform sizes.
Stratasys J 750 fist true color 3D printer
In April 2016, we introduced what we believe to be an industry-first with our market-disruptive 3D printer, the J750. The new solution breaks restrictive technology barriers, enabling customers for the first time to mix-and-match full color gradients alongside a wide range of materials to achieve one-stop realism without post-processing. This, together with the systems superior versatility, makes the J750 a choice 3D printing solution for product designers, engineers and manufacturers, as well as service bureaus.
As the premier addition to the Objet Connex multi-color, multi-material series of 3D Printers, the Stratasys J 750 allows customers to choose from more than 500,000 different color shades plus multiple material properties - ranging from rigid to flexible and opaque to transparent. Prototypes can include a vast array of colors, materials and material properties in the same part, speeding production of realistic models, prototypes and parts for virtually any application need - as well as delivering incomparable 3D printing versatility to produce tooling, molds, jigs and fixtures and more.
Next Generation Production line enhancement for Fortus 900 mc
The Stratasys Fortus 900mc next Generation offers a streamlined workflow and easier job-monitoring with an internal camera and GrabCAD Print Software. Standard certifications are included, eliminating the effort and cost to qualify the 3D printer for the users production floor.
New FDM Material Nylon 6
Stratasys Nylon 6 combines the strength of ULTEM 9085™ with the toughness of Nylon 12. It affords a higher strength and stiffness as well as a better 3D printed appearance than Nylon 12. Nylon 6 is one of the most widely used thermoplastics applied in traditional manufacturing. For FDM 3D printing, Stratasys Nylon 6 is specially formulated to control the right balance between mature Nylon 6 properties and controlled shrinkage effects during the FDM 3D printing process.
Tough PC-ABS Material Now Available on More Stratasys 3D Printers
With its high durability and smooth matte finish, PC-ABS is a natural choice for challenging applications, such as power-tool prototyping and industrial equipment manufacturing. Owners of the F370, Fortus 380mc and 450mc 3D Printers will now have the ability to leverage PC-ABS, reducing time-to-market and high tooling costs for low-volume and custom production builds. 3D printing in real engineering thermoplastics results in stronger parts, more confident testing and prototypes that mimic the material properties of the final product.
Easier to Manufacture Complex Hollow Composite Parts with New Sacrificial Tooling Solution
Sacrificial tooling, a process in which 3D printed molds are wrapped in composite material and then removed after part curing, enables manufacturers to rapidly and cost-effectively create complex, hollow composite parts. We are improving this process with a new sacrificial tooling solution, consisting of our new ST-130 material and new fill patterns. Together, the new material and fill patterns provide faster dissolution, rapid build speed, better autoclave performance and greatly improved tool quality.
Stratasys Manufacturing Aids Package
Our Manufacturing Aids Package offers assistance to manufacturers seeking to create custom manufacturing tools. The materials-and-services package includes 40 hours of design work from Stratasys Professional Services to make producing a first tool easy.
To create strong, lightweight tools, the kit includes canisters of thermoplastic build material and support material. Build material includes Nylon 6 - our newest engineering-grade material - as well as PC and ASA plastic. ASA is available in a choice of ten colors. The Manufacturing Aids Package includes our new SR-35 advanced soluble support material which offers faster dissolve time and extended bath life compared to our previous SR-30 soluble support material.
In November 2017, we introduced the Stratasys H2000, which utilizes horizontal FDM 3D printing to create strong, custom parts and tooling at unlimited lengths. From an automobile armrest to an entire aircraft interior panel, the Stratasys H2000 delivers large, lightweight thermoplastic parts with repeatable mechanical properties. It is characterized by the following innovations:
3D print custom tooling faster and bigger than ever before.
Rapidly production of strong parts for custom OEM and on-demand aftermarket applications.
Builds very large, custom production parts with accuracy, repeatability and speed.
The Stratasys H2000 is designed to meet the advancing demands in the aerospace and automotive industries and other industries for large lightweight, thermoplastic parts with repeatable mechanical properties. It eliminates the barriers to the production of large custom parts or panels, manufacturing aids such as large trim and drill guides and holding fixtures, and development-level or small-run layup tooling. These applications are in high demand with FDM systems because of the combination of strong thermoplastic materials and the freedom of design that additive manufacturing offers.
The Stratasys H2000 supports new production part applications for custom vehicle interior components such as personalized custom panels, decorative elements and large environmental control system ducts with all of the advantages of FDM, but with increased size and reduced speed limitations. That same scale and speed enables production of significantly larger prototypes without the need for bonding or assembly of multiple smaller parts.
Next generation manufacturing technologies: Robotic Composite 3D Demonstrator
At IMTS 2016, we previewed demonstrations of next-generation manufacturing technologies as part of our vision for additive manufacturing specifically dedicated to verticals like automotive and aerospace. The new technology demonstrations build on our industrial FDM® 3D printing expertise to respond to the needs of customers most challenging applications, addressing manufacturers needs to rapidly produce strong parts ranging in size from an automobile armrest to an entire aircraft interior panel.
The Stratasys Robotic Composite 3D Demonstrator delivers true 3D printing by using an 8-axis motion system that enables precise, directional material placement for strength while also dramatically reducing the need for speed-hindering support strategies. This redefines how future lightweight parts will be built, and provides a glimpse into how this technology could be used to accelerate the production of parts made from a wide variety of materials.
We developed the Robotic Composite 3D Demonstrator integrating our core additive manufacturing technologies with industrial motion control hardware and design-to-3D printing software capabilities provided by Siemens.
As an issuer that offers products that include Conflict Minerals necessary in our manufactured products, we are subject to Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 Section 1502 reporting requirements associated with Conflict Minerals and the Rule 13p-1.
1. Reasonable Country of Origin Inquiry
In accordance with our Conflict Minerals Policy, Stratasys has concluded in good faith that during calendar year 2017, we have manufactured and contracted to manufacture products containing all four Conflict Minerals and have determined that the use of these minerals is necessary to the functionality or production of these products.
We performed a reasonable country of origin inquiry (RCOI) simultaneously with the due diligence phase in which we engaged to determine whether the Conflict Minerals necessary to the functionality or production of our products were or were not DRC conflict free. This was done simultaneously due to the large number of applicable suppliers from which we source materials that we surveyed and the timeframe in which we needed to complete both the RCOI and due diligence. We operate significantly downstream from the sources of the minerals used in our products components. As such, we rely upon the due diligence conducted by our own supply base to which we have limited amount of control. Our RCOI that we conduct therefore has certain limitations that limit the total degree of certainty that can be determined. Our RCOI employed several methods to assess whether the necessary Conflict Minerals in our products originated from the DRC or Covered Countries. These measures consisted primarily of the following actions:
Internal assessments of our products to determine which products contain or may contain necessary Conflict Minerals.
We identified a list of suppliers we purchased from directly during calendar year 2017 (“Tier 1 Suppliers”), and segmented the list according to the type of material the supplier provides. Some of the suppliers categories were excluded for the following reasons: they were not necessary to the functionality or production of the products, they did not contain Conflict Minerals or the supplier provided a commercial off the shelf product.
To reduce the risk of not receiving full information from our Tier 1 Suppliers, we also directly approach plastic, metal and electronic manufacturers, even though we have not purchased from them directly. We rely on our in-scope suppliers and manufacturers to provide us with information concerning the source and chain of custody of Conflict Minerals contained in the products and components they supply. The cumulative number of suppliers and manufacturers (“in scope suppliers”) we have approached is 971.
Solicited survey responses using the standard template designed by the Responsible Minerals Initiative (RMI), formerly Conflict-Free Sourcing Initiative (CFSI) (the “Conflict Minerals Reporting Template version 5.0 and above” (“CMRT”)). We engaged our supply chain to respond to the CMRT by referring suppliers to training materials that included an overview of the law and instructions on how to complete the CMRT.
Assessment of responses received for information that would identify as inconsistent, incomplete, or inaccurate. In addition, we validate CMRTs received from suppliers to identify deviation from the RMIs requirements as per its RMAP audit program. Responses that failed any of the “red flag” review tests were identified for additional follow up.
To non-responsive in scope suppliers, we sent periodic reminders to provide surveys or updated responses.
Based on the RCOI conducted, Stratasys has reason to believe that a portion of the Conflict Minerals necessary to the functionality of its products originated in the DRC or a Covered Country and knows, or has reason to believe, that those necessary Conflict Minerals may not be from recycled or scrap sources. Based on this result, Stratasys conducted due diligence activities and details these efforts in this Conflict Minerals Report.
2. Due Diligence
Due diligence design
In accordance with Rule 13p-1 and Form SD, we undertook due diligence to determine whether the Conflict Minerals necessary to the functionality or production of our products were or were not “DRC conflict free.” We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD, 2013) (“OECD Framework”) and related supplements for Conflict Minerals.
The five steps defined in the OECD Due Diligence Guidance are: (1) establishment of strong internal company management systems; (2) identification and assessment of risks in the supply chain; (3) design and implementation of a strategy to respond to risks as they are identified; (4) carry out independent third-party audits of smelters’ and refiners’ due diligence practices; and (5) report annually on supply chain due diligence.
The due diligence measures we undertook consisted primarily of:
a. Established strong company management systems
We reviewed and maintained the company management systems previously established through the following actions:
Renewed our commitment to ethical business practices through the global rollout of an updated Code of Business Conduct and Ethics (“Code), which also includes a specific reference to Stratasys efforts as it relates to conflict minerals. Our Code is available at
Continued focus on integrating socially beneficial programs and practices as part of our business model and culture through the Stratasys Corporate Social Responsibility (CSR) Program. We are extending 3D printing by applying the unique capabilities and advantages of our 3D printing technologies for social change. Our current CSR initiatives span around healthcare, and education.
We strive to ensure that purchased metals originate only from smelters validated as being DRC conflict free. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. Our Conflict Minerals Policy is available at http://files.shareholder.com/downloads/AMDA-FNA1K/4441022834x0x748757/72402B7D-BD98-4480-A580-59F519FDBC16/Stratasys-CM_Policy_FINAL_DISTRIBUTED_04-29-14.pdf.
Maintained the Conflict Minerals Governance Charter that sets the Conflict Minerals annual work plan including: steps for compliance, objectives, timeline, internal management and cross functional team with identified roles and responsibilities to support supply chain due diligence.
Held periodic meetings of the cross functional team, for the purpose of sharing best practices and monitoring our progress regarding the various steps required for compliance.
Engaged with in scope suppliers and referred them to training materials online, including an overview of relevant Conflict Minerals regulation and provided instructions on how to respond to the due diligence survey (which was based on the CMRT).
Continue to include a Conflict Minerals provision to our standard Terms and Conditions of Purchase to require suppliers to comply with our Conflict Minerals Policy and requirements.
Communicated the due diligence efforts to customers, suppliers and other relevant functions in our organization, as requested and applicable.
Maintained a grievance mechanism whereby concerns and violations of the Conflict Minerals Policy should be reported to Stratasys’ Chief Financial Officer and/or Vice President Legal affairs.
b. Identified and assessed risks in the supply chain
As part of our risk-based approach, Stratasys identified the suppliers from which it made purchases over a specified amount during 2017. We assessed two primary risks in our supply chain while trying to move towards the goal of being DRC conflict free: (1) the risk of not receiving timely and accurate information from the supplier; and (2) the risk of not being able to replace a supplier due to reasons such as volume, ease of replacement, complexity of relationship and criticality to business operations.
In order to segment our suppliers into three risk levels (high, medium and low) we have identified and assessed Conflict Minerals-related risks based on suppliers’ and manufacturers’ characteristics, such as our spending with a supplier during calendar year 2017 and the extent to which we are dependent upon any particular manufacturer or supplier or the availability of alternative suppliers. This segmentation allowed us to invest our risk mitigation efforts according to the supplier level of risk.
We have identified, to the best of our efforts, the smelters and refiners in the supply chain by conducting a supply chain survey using the CMRT, requesting suppliers and manufactures to identify smelters and refiners and country of origin of the Conflict Minerals in products they supply to Stratasys. In addition, Stratasys compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a conflict free designation from the RMAP (the RMIs Responsible Minerals Assurance Process) or other independent third party audit programs.
As part of the risk assessment phase, we identified that 51.3% of our in scope suppliers have policy in place that addresses the Conflict Minerals sourcing and 18.44% do not provide us with products containing Conflict Minerals.
c. Designed and implemented a strategy to respond to identified risks
The findings of the supply chain risk assessment were and continue to be reported to designated members of our senior management. As part of our risk management strategy, we continue to work with the in scope suppliers while we advance our efforts to investigate our supply chain as follows:
Continued periodic reporting to the team sponsor to track
progress, assess risks and provide management support as needed.
Contacted in scope suppliers whose responses were identified as incomplete, inconsistent or inaccurate.
Reviewed in scope suppliers’ responses to track smelters and refiners in our supply chain that supply us with Conflict Minerals and have not received a conflict-free designation based on the RMAP or other independent third party validation program.
Referred in scope suppliers to online training materials that included an overview of the law and instructions on how to complete the CMRT.
As part of our continued risk management efforts, we send follow up letters to high risk non-responsive in scope suppliers, and to in scope suppliers who declared the existence of Conflict Minerals in their supply chain from the DRC or Covered Countries from non-certified smelters. While the Company is committed to responsible sourcing of Conflict Minerals, it does not seek to eliminate sourcing from the DRC or Covered Countries.
Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process occasionally and update the risk mitigation strategy accordingly.
d. Reviewed independent third-party audits of smelter and refiner due diligence practices
Stratasys is a downstream consumer of necessary Conflict Minerals and is many steps removed from smelters and refiners who provide minerals and ores. Therefore, Stratasys does not perform audits of smelters and refiners within the supply chain. As a result, Stratasys’ due diligence efforts relied on reviewing cross-industry initiatives such as those led by the RMI to conduct smelter and refiner due diligence.
e. Prepared this annual report on supply chain due diligence
Stratasys’ Conflict Mineral Policy states that we will comply with Section 1502 of the Dodd Frank Act which includes filing a Form SD and this Conflict Minerals report with the SEC and posting publicly on the Internet.
3. Results of Assessment
We conducted a supply chain survey of the 971 in scope suppliers that we identified may contribute necessary Conflict Minerals to our products compared to 703 in scope suppliers in calendar year 2016. In calendar year 2017 we included metal, electronics and plastic suppliers and manufacturers and took a risk based approach which focus on the majority of our manufacturing spend.
We received responses from in scope suppliers representing approximately a 55.3% response rate, containing the names and locations of smelters and refiners (see Annex 1) and the potential countries of origin (see Annex 2) if the mines or facilities that process Conflict Minerals, compared to approximately a 54.5% response rate attained for reporting year 2016.
Of the 55.3% of suppliers and manufacturers that responded:
13.22% of in scope suppliers were classified as “DRC conflict free”|
4.47% of in scope suppliers were classified as “Not from DRC”|
18.44% of in scope suppliers were classified as “Free no 3TG”
16.39% of in scope suppliers were classified as “Undetermined not from DRC”
42.46% of in scope suppliers were classified as “Undetermined from DRC”
5.03% of in scope suppliers were classified as “Undefined from DRC”
The terms above have the following meaning as part of our due diligence efforts:
|●||DRC conflict free indicates the in scope suppliers that reported that Conflict Minerals used in the products provided to Stratasys originate from Covered Countries, but that the smelters are approved by the RMAP, the RMIs Responsible Minerals Assurance Process.|
|●||Not from DRC indicates the in scope suppliers that reported that they source Conflict Minerals, but from countries other than the Covered Countries.|
|●||Free no 3TG indicates the in scope suppliers that reported that Conflict Minerals are not contained in the product, or are not necessary for the functionality or are not included in the production of the products provided to Stratasys.|
|●||Undetermined not from DRC indicates the in scope suppliers that reported that Conflict Minerals being used in the products do not originate from Covered Countries, but they have not yet concluded their due diligence process so this determination could potentially change. Due diligence for these in scope suppliers will continue until the status changes or is confirmed.|
|●||Undetermined from DRC indicates the in scope suppliers that reported that Conflict Minerals used originate from the Covered Countries and that the smelters are approved by the RMAP program, but they have not yet concluded their due diligence process so this determination could potentially change. Due diligence for these in scope suppliers will continue until the status changes or is confirmed.|
|●||Undefined from DRC indicates the in scope suppliers that reported that Conflict Minerals used originate from the Covered Countries and that the suppliers are not yet approved by the RMAP program. Due diligence for these in scope suppliers will continue until the status changes or is confirmed.|
Despite in scope suppliers indicating that they source Conflict Minerals from the DRC and Covered Countries, these in scope suppliers were unable to accurately report which specific smelters or refiners were part of the supply chain in regards to the components sold to Stratasys in 2017.
As a result of this lack of information, Stratasys is unable to determine the full list of facilities used to process those necessary Conflict Minerals or their country of origin and to conclude whether or not the Conflict Minerals used in its products may have directly or indirectly financed armed groups in Covered Countries. Stratasys’ efforts to determine the mine(s) or location of origin included the use of the due diligence measures described above.
Smelters and refiners verified as conflict free or in the audit process:
|Tin||71 of 80 (88.75%)|
|Tantalum||39 of 42 (92.85%)|
|Tungsten||42 of 46 (91.30%)|
|Gold||106 of 147 (72.11%)|
|Total||258 of 315 (81.90%)|
Status of identified smelters and refiners:
|Verified Conflict Free (RMI Compliant)||251 of 315 (79.68%)|
|Participating in an audit process (RMI Active)||7 of 315 (2.22%)|
|Not Participating||57 of 315 (18.09%)|
|Total (Conflict Free and under Audit process)||258 of 315 (81.90%)|
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Stratasys. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our conclusions.
These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, errors or omissions by or of suppliers, confusion over requirements of SEC final rules, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier unfamiliarity with the protocol, conflict area sourced materials being declared secondary materials, companies going out of business in 2017 and smuggling of conflict area Conflict Minerals to countries beyond the Covered Countries.
We do not gather information from our suppliers on a continuous or real-time basis, but rather information is gathered from suppliers at the time that it is provided in a CMRT.
We cannot be certain about our conclusions regarding the source and chain of custody of the necessary Conflict Minerals, as the information comes from direct and secondary suppliers and independent third party audit programs.
Continuous improvement efforts to mitigate risk
Stratasys continues to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals, as required by Rule 13p-1. Stratasys continues to take, as applicable, the following steps to improve the due diligence process and mitigate the possibility that we are utilizing Conflict Minerals that benefit armed groups contributing to human rights violations:
|●||Work with in scope suppliers that did not respond to Stratasys’ 2013, 2014, 2015, 2016 and 2017 surveys to help them understand the importance of this initiative to Stratasys and to encourage their participation in 2018.|
|●||Attempt to validate in scope supplier responses using information collected via independent, conflict-free smelter validation programs such as the RMAP.|
|●||Send follow up letters to high risk non-responsive in scope suppliers and to in scope suppliers with Conflict Minerals from the Covered Countries from non-certified smelters.|
This Report contains forward-looking statements within the meaning of U.S. federal securities laws. These forward-looking statements can generally be identified as such because the context of the statement will include words such as may, will, intends, plans, believes, anticipates, expects, estimates, predicts, potential, continue, or opportunity, the negative of these words or words of similar import. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may or may not prove to be accurate. Forward-looking statements are subject to risks, uncertainties and other factors that could cause actual results to differ materially from those stated in such statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by U.S. federal securities laws.
Names And Locations of Smelters and Refiners
|Metal||Smelter or Refiner Name||Smelter or Refiner|
|Gold||Advanced Chemical Company||UNITED STATES OF AMERICA|
|Gold||Aida Chemical Industries Co., Ltd.||JAPAN|
|Gold||Allgemeine Gold-und Silberscheideanstalt A.G.||GERMANY|
|Gold||Almalyk Mining and Metallurgical Complex (AMMC)||UZBEKISTAN|
|Gold||AngloGold Ashanti Corrego do Sitio Mineracao||BRAZIL|
|Gold||Asahi Pretec Corp.||JAPAN|
|Gold||Asaka Riken Co., Ltd.||JAPAN|
|Gold||Atasay Kuyumculuk Sanayi Ve Ticaret A.S.||TURKEY|
|Gold||Bangko Sentral ng Pilipinas (Central Bank of the Philippines)||PHILIPPINES|
|Gold||C. Hafner GmbH + Co. KG||GERMANY|
|Gold||CCR Refinery - Glencore Canada Corporation||CANADA|
|Gold||Cendres + Metaux S.A.||SWITZERLAND|
|Gold||Yunnan Copper Industry Co., Ltd.||CHINA|
|Gold||Daejin Indus Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Daye Non-Ferrous Metals Mining Ltd.||CHINA|
|Gold||DSC (Do Sung Corporation)||KOREA, REPUBLIC OF|
|Gold||DODUCO Contacts and Refining GmbH||GERMANY|
|Gold||Eco-System Recycling Co., Ltd.||JAPAN|
|Gold||OJSC Novosibirsk Refinery||RUSSIAN FEDERATION|
|Gold||Refinery of Seemine Gold Co., Ltd.||CHINA|
|Gold||Guoda Safina High-Tech Environmental Refinery Co., Ltd.||CHINA|
|Gold||Hangzhou Fuchunjiang Smelting Co., Ltd.||CHINA|
|Gold||HeeSung Metal Ltd.||KOREA, REPUBLIC OF|
|Gold||Heimerle + Meule GmbH||GERMANY|
|Gold||Heraeus Metals Hong Kong Ltd.||CHINA|
|Gold||Heraeus Precious Metals GmbH & Co. KG||GERMANY|
|Gold||Hunan Chenzhou Mining Co., Ltd.||CHINA|
|Gold||HwaSeong CJ CO., LTD.||KOREA, REPUBLIC OF|
|Gold||Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.||CHINA|
|Gold||Ishifuku Metal Industry Co., Ltd.||JAPAN|
|Gold||Istanbul Gold Refinery||TURKEY|
|Gold||Jiangxi Copper Co., Ltd.||CHINA|
|Gold||Asahi Refining USA Inc.||UNITED STATES OF AMERICA|
|Gold||Asahi Refining Canada Ltd.||CANADA|
|Gold||JSC Ekaterinburg Non-Ferrous Metal Processing Plant||RUSSIAN FEDERATION|
|Gold||JSC Uralelectromed||RUSSIAN FEDERATION|
|Gold||JX Nippon Mining & Metals Co., Ltd.||JAPAN|
|Gold||Kazakhmys Smelting LLC||KAZAKHSTAN|
|Gold||Kennecott Utah Copper LLC||UNITED STATES OF AMERICA|
|Gold||Kojima Chemicals Co., Ltd.||JAPAN|
|Gold||Lazurde Company For Jewelry||SAUDI ARABIA|
|Gold||Lingbao Gold Co., Ltd.||CHINA|
|Gold||Lingbao Jinyuan Tonghui Refinery Co., Ltd.||CHINA|
|Gold||LS-NIKKO Copper Inc.||KOREA, REPUBLIC OF|
|Gold||Luoyang Zijin Yinhui Gold Refinery Co., Ltd.||CHINA|
|Gold||Materion||UNITED STATES OF AMERICA|
|Gold||Matsuda Sangyo Co., Ltd.||JAPAN|
|Gold||Metalor Technologies (Suzhou) Ltd.||CHINA|
|Gold||Metalor Technologies (Hong Kong) Ltd.||CHINA|
|Gold||Metalor Technologies (Singapore) Pte., Ltd.||SINGAPORE|
|Gold||Metalor Technologies S.A.||SWITZERLAND|
|Gold||Metalor USA Refining Corporation||UNITED STATES OF AMERICA|
|Gold||Metalurgica Met-Mex Penoles S.A. De C.V.||MEXICO|
|Gold||Mitsubishi Materials Corporation||JAPAN|
|Gold||Mitsui Mining and Smelting Co., Ltd.||JAPAN|
|Gold||Moscow Special Alloys Processing Plant||RUSSIAN FEDERATION|
|Gold||Nadir Metal Rafineri San. Ve Tic. A.S.||TURKEY|
|Gold||Navoi Mining and Metallurgical Combinat||UZBEKISTAN|
|Gold||Nihon Material Co., Ltd.||JAPAN|
|Gold||Elemetal Refining, LLC||UNITED STATES OF AMERICA|
|Gold||Ohura Precious Metal Industry Co., Ltd.||JAPAN|
|Gold||OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet)||RUSSIAN FEDERATION|
|Gold||Penglai Penggang Gold Industry Co., Ltd.||CHINA|
|Gold||Prioksky Plant of Non-Ferrous Metals||RUSSIAN FEDERATION|
|Gold||PT Aneka Tambang (Persero) Tbk||INDONESIA|
|Gold||PX Precinox S.A.||SWITZERLAND|
|Gold||Rand Refinery (Pty) Ltd.||SOUTH AFRICA|
|Gold||Royal Canadian Mint||CANADA|
|Gold||Sabin Metal Corp.||UNITED STATES OF AMERICA|
|Gold||Samduck Precious Metals||KOREA, REPUBLIC OF|
|Gold||Samwon Metals Corp.||KOREA, REPUBLIC OF|
|Gold||Schone Edelmetaal B.V.||NETHERLANDS|
|Gold||SEMPSA Joyeria Plateria S.A.||SPAIN|
|Gold||Shandong Tiancheng Biological Gold Industrial Co., Ltd.||CHINA|
|Gold||Shandong Zhaojin Gold & Silver Refinery Co., Ltd.||CHINA|
|Gold||Sichuan Tianze Precious Metals Co., Ltd.||CHINA|
|Gold||So Accurate Group, Inc.||UNITED STATES OF AMERICA|
|Gold||SOE Shyolkovsky Factory of Secondary Precious Metals||RUSSIAN FEDERATION|
|Gold||Solar Applied Materials Technology Corp.||TAIWAN, PROVINCE OF CHINA|
|Gold||Sumitomo Metal Mining Co., Ltd.||JAPAN|
|Gold||Tanaka Kikinzoku Kogyo K.K.||JAPAN|
|Gold||Great Wall Precious Metals Co., Ltd. of CBPM||CHINA|
|Gold||The Refinery of Shandong Gold Mining Co., Ltd.||CHINA|
|Gold||Tokuriki Honten Co., Ltd.||JAPAN|
|Gold||Tongling Nonferrous Metals Group Co., Ltd.||CHINA|
|Gold||Torecom||KOREA, REPUBLIC OF|
|Gold||Umicore Brasil Ltda.||BRAZIL|
|Gold||Umicore S.A. Business Unit Precious Metals Refining||BELGIUM|
|Gold||United Precious Metal Refining, Inc.||UNITED STATES OF AMERICA|
|Gold||Western Australian Mint (T/a The Perth Mint)||AUSTRALIA|
|Gold||Yamakin Co., Ltd.||JAPAN|
|Gold||Yokohama Metal Co., Ltd.||JAPAN|
|Gold||Zhongyuan Gold Smelter of Zhongjin Gold Corporation||CHINA|
|Gold||Gold Refinery of Zijin Mining Group Co., Ltd.||CHINA|
|Gold||Morris and Watson||NEW ZEALAND|
|Gold||SAFINA A.S.||CZECH REPUBLIC|
|Gold||Guangdong Jinding Gold Limited||CHINA|
|Gold||Umicore Precious Metals Thailand||THAILAND|
|Gold||Geib Refining Corporation||UNITED STATES OF AMERICA|
|Gold||MMTC-PAMP India Pvt., Ltd.||INDIA|
|Gold||Republic Metals Corporation||UNITED STATES OF AMERICA|
|Gold||KGHM Polska Miedz Spolka Akcyjna||POLAND|
|Gold||Fidelity Printers and Refiners Ltd.||ZIMBABWE|
|Gold||Singway Technology Co., Ltd.||TAIWAN, PROVINCE OF CHINA|
|Gold||Al Etihad Gold LLC||UNITED ARAB EMIRATES|
|Gold||Emirates Gold DMCC||UNITED ARAB EMIRATES|
|Gold||Kaloti Precious Metals||UNITED ARAB EMIRATES|
|Gold||Sudan Gold Refinery||SUDAN|
|Gold||Remondis Argentia B.V.||NETHERLANDS|
|Gold||Tony Goetz NV||BELGIUM|
|Gold||Korea Zinc Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Abington Reldan Metals, LLC||UNITED STATES OF AMERICA|
|Gold||SAXONIA Edelmetalle GmbH||GERMANY|
|Gold||WIELAND Edelmetalle GmbH||GERMANY|
|Gold||Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH||AUSTRIA|
|Gold||AU Traders and Refiners||SOUTH AFRICA|
|Gold||GCC Gujrat Gold Centre Pvt. Ltd.||INDIA|
|Gold||Universal Precious Metals Refining Zambia||ZAMBIA|
|Gold||Modeltech Sdn Bhd||MALAYSIA|
|Gold||Kyshtym Copper-Electrolytic Plant ZAO||RUSSIAN FEDERATION|
|Gold||Morris and Watson Gold Coast||AUSTRALIA|
|Gold||Degussa Sonne / Mond Goldhandel GmbH||GERMANY|
|Gold||Pease & Curren||UNITED STATES OF AMERICA|
|Gold||SungEel HiMetal Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Planta Recuperadora de Metales SpA||CHILE|
|Gold||State Research Institute Center for Physical Sciences and Technology||LITHUANIA|
|Tantalum||Asaka Riken Co., Ltd.||JAPAN|
|Tantalum||Changsha South Tantalum Niobium Co., Ltd.||CHINA|
|Tantalum||Guangdong Rising Rare Metals-EO Materials Ltd.||CHINA|
|Tantalum||Exotech Inc.||UNITED STATES OF AMERICA|
|Tantalum||F&X Electro-Materials Ltd.||CHINA|
|Tantalum||Guangdong Zhiyuan New Material Co., Ltd.||CHINA|
|Tantalum||JiuJiang JinXin Nonferrous Metals Co., Ltd.||CHINA|
|Tantalum||Jiujiang Nonferrous Metals Smelting Company Limited||CHINA|
|Tantalum||King-Tan Tantalum Industry Ltd.||CHINA|
|Tantalum||LSM Brasil S.A.||BRAZIL|
|Tantalum||Metallurgical Products India Pvt., Ltd.||INDIA|
|Tantalum||Mineracao Taboca S.A.||BRAZIL|
|Tantalum||Mitsui Mining and Smelting Co., Ltd.||JAPAN|
|Tantalum||NPM Silmet AS||ESTONIA|
|Tantalum||Ningxia Orient Tantalum Industry Co., Ltd.||CHINA|
|Tantalum||QuantumClean||UNITED STATES OF AMERICA|
|Tantalum||RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.||CHINA|
|Tantalum||Solikamsk Magnesium Works OAO||RUSSIAN FEDERATION|
|Tantalum||Taki Chemical Co., Ltd.||JAPAN|
|Tantalum||Telex Metals||UNITED STATES OF AMERICA|
|Tantalum||Ulba Metallurgical Plant JSC||KAZAKHSTAN|
|Tantalum||Yichun Jin Yang Rare Metal Co., Ltd.||CHINA|
|Tantalum||Hengyang King Xing Lifeng New Materials Co., Ltd.||CHINA|
|Tantalum||D Block Metals, LLC||UNITED STATES OF AMERICA|
|Tantalum||FIR Metals & Resource Ltd.||CHINA|
|Tantalum||Jiujiang Zhongao Tantalum & Niobium Co., Ltd.||CHINA|
|Tantalum||XinXing HaoRong Electronic Material Co., Ltd.||CHINA|
|Tantalum||Jiangxi Dinghai Tantalum & Niobium Co., Ltd.||CHINA|
|Tantalum||KEMET Blue Metals||MEXICO|
|Tantalum||H.C. Starck Co., Ltd.||THAILAND|
|Tantalum||H.C. Starck Tantalum and Niobium GmbH||GERMANY|
|Tantalum||H.C. Starck Hermsdorf GmbH||GERMANY|
|Tantalum||H.C. Starck Inc.||UNITED STATES OF AMERICA|
|Tantalum||H.C. Starck Ltd.||JAPAN|
|Tantalum||H.C. Starck Smelting GmbH & Co. KG||GERMANY|
|Tantalum||Global Advanced Metals Boyertown||UNITED STATES OF AMERICA|
|Tantalum||Global Advanced Metals Aizu||JAPAN|
|Tantalum||KEMET Blue Powder||UNITED STATES OF AMERICA|
|Tantalum||Resind Industria e Comercio Ltda.||BRAZIL|
|Tantalum||Jiangxi Tuohong New Raw Material||CHINA|
|Tantalum||Power Resources Ltd.||MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF|
|Tin||Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.||CHINA|
|Tin||Jiangxi Ketai Advanced Material Co., Ltd.||CHINA|
|Tin||CNMC (Guangxi) PGMA Co., Ltd.||CHINA|
|Tin||Alpha||UNITED STATES OF AMERICA|
|Tin||CV Gita Pesona||INDONESIA|
|Tin||PT Aries Kencana Sejahtera||INDONESIA|
|Tin||CV Serumpun Sebalai||INDONESIA|
|Tin||CV United Smelting||INDONESIA|
|Tin||EM Vinto||BOLIVIA (PLURINATIONAL STATE OF)|
|Tin||Estanho de Rondonia S.A.||BRAZIL|
|Tin||Gejiu Non-Ferrous Metal Processing Co., Ltd.||CHINA|
|Tin||Gejiu Zili Mining And Metallurgy Co., Ltd.||CHINA|
|Tin||Huichang Jinshunda Tin Co., Ltd.||CHINA|
|Tin||Gejiu Kai Meng Industry and Trade LLC||CHINA|
|Tin||China Tin Group Co., Ltd.||CHINA|
|Tin||Malaysia Smelting Corporation (MSC)||MALAYSIA|
|Tin||Metallic Resources, Inc.||UNITED STATES OF AMERICA|
|Tin||Mineracao Taboca S.A.||BRAZIL|
|Tin||Mitsubishi Materials Corporation||JAPAN|
|Tin||Nankang Nanshan Tin Manufactory Co., Ltd.||CHINA|
|Tin||O.M. Manufacturing (Thailand) Co., Ltd.||THAILAND|
|Tin||Operaciones Metalurgical S.A.||BOLIVIA (PLURINATIONAL STATE OF)|
|Tin||PT Artha Cipta Langgeng||INDONESIA|
|Tin||PT Babel Inti Perkasa||INDONESIA|
|Tin||PT Bangka Tin Industry||INDONESIA|
|Tin||PT Belitung Industri Sejahtera||INDONESIA|
|Tin||PT Bukit Timah||INDONESIA|
|Tin||PT DS Jaya Abadi||INDONESIA|
|Tin||PT Eunindo Usaha Mandiri||INDONESIA|
|Tin||PT Karimun Mining||INDONESIA|
|Tin||PT Mitra Stania Prima||INDONESIA|
|Tin||PT Panca Mega Persada||INDONESIA|
|Tin||PT Prima Timah Utama||INDONESIA|
|Tin||PT Refined Bangka Tin||INDONESIA|
|Tin||PT Sariwiguna Binasentosa||INDONESIA|
|Tin||PT Stanindo Inti Perkasa||INDONESIA|
|Tin||PT Sumber Jaya Indah||INDONESIA|
|Tin||PT Timah (Persero) Tbk Kundur||INDONESIA|
|Tin||PT Timah (Persero) Tbk Mentok||INDONESIA|
|Tin||PT Tinindo Inter Nusa||INDONESIA|
|Tin||PT Tommy Utama||INDONESIA|
|Tin||Rui Da Hung||TAIWAN, PROVINCE OF CHINA|
|Tin||Soft Metais Ltda.||BRAZIL|
|Tin||Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.||CHINA|
|Tin||White Solder Metalurgia e Mineracao Ltda.||BRAZIL|
|Tin||Yunnan Chengfeng Non-ferrous Metals Co., Ltd.||CHINA|
|Tin||Yunnan Tin Company Limited||CHINA|
|Tin||CV Venus Inti Perkasa||INDONESIA|
|Tin||Magnus Minerais Metais e Ligas Ltda.||BRAZIL|
|Tin||Melt Metais e Ligas S.A.||BRAZIL|
|Tin||PT ATD Makmur Mandiri Jaya||INDONESIA|
|Tin||O.M. Manufacturing Philippines, Inc.||PHILIPPINES|
|Tin||PT Inti Stania Prima||INDONESIA|
|Tin||CV Ayi Jaya||INDONESIA|
|Tin||Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company||VIETNAM|
|Tin||Nghe Tinh Non-Ferrous Metals Joint Stock Company||VIETNAM|
|Tin||Tuyen Quang Non-Ferrous Metals Joint Stock Company||VIETNAM|
|Tin||CV Dua Sekawan||INDONESIA|
|Tin||CV Tiga Sekawan||INDONESIA|
|Tin||An Vinh Joint Stock Mineral Processing Company||VIETNAM|
|Tin||Resind Industria e Comercio Ltda.||BRAZIL|
|Tin||PT O.M. Indonesia||INDONESIA|
|Tin||Metallo Belgium N.V.||BELGIUM|
|Tin||Metallo Spain S.L.U.||SPAIN|
|Tin||PT Bangka Prima Tin||INDONESIA|
|Tin||PT Sukses Inti Makmur||INDONESIA|
|Tin||PT Kijang Jaya Mandiri||INDONESIA|
|Tin||PT Menara Cipta Mulia||INDONESIA|
|Tin||HuiChang Hill Tin Industry Co., Ltd.||CHINA|
|Tin||Gejiu Fengming Metallurgy Chemical Plant||CHINA|
|Tin||Guanyang Guida Nonferrous Metal Smelting Plant||CHINA|
|Tin||Modeltech Sdn Bhd||MALAYSIA|
|Tin||Gejiu Jinye Mineral Company||CHINA|
|Tin||PT Lautan Harmonis Sejahtera||INDONESIA|
|Tin||Guangdong Hanhe Non-Ferrous Metal Co., Ltd.||CHINA|
|Tungsten||A.L.M.T. TUNGSTEN Corp.||JAPAN|
|Tungsten||Kennametal Huntsville||UNITED STATES OF AMERICA|
|Tungsten||Guangdong Xianglu Tungsten Co., Ltd.||CHINA|
|Tungsten||Chongyi Zhangyuan Tungsten Co., Ltd.||CHINA|
|Tungsten||Fujian Jinxin Tungsten Co., Ltd.||CHINA|
|Tungsten||Global Tungsten & Powders Corp.||UNITED STATES OF AMERICA|
|Tungsten||Hunan Chenzhou Mining Co., Ltd.||CHINA|
|Tungsten||Hunan Chunchang Nonferrous Metals Co., Ltd.||CHINA|
|Tungsten||Japan New Metals Co., Ltd.||JAPAN|
|Tungsten||Ganzhou Huaxing Tungsten Products Co., Ltd.||CHINA|
|Tungsten||Kennametal Fallon||UNITED STATES OF AMERICA|
|Tungsten||Tejing (Vietnam) Tungsten Co., Ltd.||VIETNAM|
|Tungsten||Vietnam Youngsun Tungsten Industry Co., Ltd.||VIETNAM|
|Tungsten||Wolfram Bergbau und Hutten AG||AUSTRIA|
|Tungsten||Xiamen Tungsten Co., Ltd.||CHINA|
|Tungsten||Xinhai Rendan Shaoguan Tungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd.||CHINA|
|Tungsten||Ganzhou Jiangwu Ferrotungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Yaosheng Tungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Xinsheng Tungsten Industry Co., Ltd.||CHINA|
|Tungsten||Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.||CHINA|
|Tungsten||Malipo Haiyu Tungsten Co., Ltd.||CHINA|
|Tungsten||Xiamen Tungsten (H.C.) Co., Ltd.||CHINA|
|Tungsten||Jiangxi Gan Bei Tungsten Co., Ltd.||CHINA|
|Tungsten||Ganzhou Seadragon W & Mo Co., Ltd.||CHINA|
|Tungsten||Asia Tungsten Products Vietnam Ltd.||VIETNAM|
|Tungsten||Chenzhou Diamond Tungsten Products Co., Ltd.||CHINA|
|Tungsten||Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.||CHINA|
|Tungsten||Ganzhou Yatai Tungsten Co., Ltd.||CHINA|
|Tungsten||H.C. Starck Tungsten GmbH||GERMANY|
|Tungsten||H.C. Starck Smelting GmbH & Co. KG||GERMANY|
|Tungsten||Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC||VIETNAM|
|Tungsten||Jiangwu H.C. Starck Tungsten Products Co., Ltd.||CHINA|
|Tungsten||Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji||CHINA|
|Tungsten||Niagara Refining LLC||UNITED STATES OF AMERICA|
|Tungsten||Ganzhou Haichuang Tungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Dayu Longxintai Tungsten Co., Ltd.||CHINA|
|Tungsten||Hydrometallurg, JSC||RUSSIAN FEDERATION|
|Tungsten||Unecha Refractory metals plant||RUSSIAN FEDERATION|
|Tungsten||South-East Nonferrous Metal Company Limited of Hengyang City||CHINA|
|Tungsten||Philippine Chuangxin Industrial Co., Inc.||PHILIPPINES|
|Tungsten||Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.||CHINA|
|Tungsten||ACL Metais Eireli||BRAZIL|
|Tungsten||Woltech Korea Co., Ltd.||KOREA, REPUBLIC OF|
|Tungsten||Moliren Ltd.||RUSSIAN FEDERATION|
|Tungsten||Hunan Litian Tungsten Industry Co., Ltd.||CHINA|
Country of Origin*
|Australia||China||Bolivia (Plurinational State of)||Brazil|
|Canada||Japan||Japan||Korea, Republic of|
|China||Macedonia, The Former
Yugoslav Republic of
|Czech Republic||Mexico||Philippines||United States of America|
|India||United States of America||Taiwan, Province of China|
|Italy||United States of America|
|Korea, Republic of|
|Taiwan, Province of China|
|United Arab Emirates|
|United States of America|
*As Smelters or Refiners (SORs) did not in all cases provide information on Location of Mine in their CMRTs, and the company was not able to establish from the SORs sourcing information on their Conflict Minerals, it has indicated in the COO the closest indication provided as to the source of Conflict Minerals, i.e the Smelter Country as reported in the suppliers CMRT.