Conflict Minerals Report of Stratasys Ltd.
This is the Conflict Minerals Report of Stratasys Ltd. (“Stratasys” or “we” or “Company”) for calendar year 2020 in accordance with Rule 13p-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. As part of the Company’s desire to take responsibility for and concern themselves with human rights issues, we decided to review the Company’s supply chain according to the EU regulation’s guidance, and within that have included conflict-affected or high-risk areas (“CAHRAs”) when approaching suppliers for information.
Company and business Overview
Stratasys Ltd. is the product of the 2012 merger of two leading additive manufacturing companies, Stratasys, Inc. and Objet Ltd. Stratasys, Inc. was incorporated in Delaware in 1989, and Objet Ltd. was incorporated in Israel in 1998. Our ordinary shares are listed on the NASDAQ Global Select Market under the trading symbol “SSYS”.
We are a global leader in connected, polymer-based 3D printing solutions, across the entire manufacturing value chain. Specifically, we are focused on polymers and technologies that address fast-growing manufacturing solutions, which we view as the biggest potential growth opportunity in the 3D printing industry. Leveraging distinct competitive advantages that include a broad set of best-in-class 3D printing platforms, software, materials and technology partner ecosystems, innovative leadership, and a global GTM infrastructure, we are positioned to expand further in a significant and growing global marketplace.
Our approximately 1,600 granted and pending additive technology patents to date have been used to create models, prototypes, manufacturing tools, and production parts for a multitude of industries including aerospace, automotive, transportation, healthcare, consumer products, dental, medical, and education. Our products and comprehensive solutions improve product quality, development time, cost, and time-to-market. Our additive manufacturing ecosystem of solutions and expertise includes materials, software, expert services, and on-demand parts production.
With the recent acquisition of Origin Inc., or Origin, a provider of photopolymer solutions for production-oriented applications, which closed on December 31, 2020, we expanded our leadership through innovation in the fast-growing mass production parts segment with a next-generation photopolymer platform. Origin’s pioneering approach to additive manufacturing of end-use parts will enable us to serve a large market with manufacturing-grade 3D printers, utilizing Programmable PhotoPolymerization (P3). This technology precisely controls light, heat, and force, among other variables, to produce parts with exceptional accuracy and consistency and enables a broad range of chemistry which turns into unique production grade properties. On February 16, 2021 We acquired RP Support Limited (“RPS”), a provider of industrial stereolithography 3D printers and solutions. RPS’ Neo line of 3D printers feature dynamic laser beam technology that enables build accuracy, feature detail, and low variability across the full extent of a large build platform. As an open resin system, the Neo products provide customers materials with a wide range of properties such as chemical resistance, heat tolerance, flexibility, durability, and optical clarity. RPS’ complementary technology further expands Stratasys’ polymer suite of solutions across the product life cycle, from concept modeling to manufacturing. Both the Origin and RPS products are not included in the scope of this Conflict Minerals report to the closing dates for these acquisitions, which occurred following the reporting period which this Report refers to.
We offer a broader range of systems, consumables and services for 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-to-medium-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, and manufacturing parts. Our products include 3D printing systems, consumable materials, software and services. Further below we will cover only the products covered by this Conflict Minerals Disclosure and Report.
Collectively, this portfolio of products offers a broad range of performance options for users, depending on their application, as well as on the nature and size of the designs, prototypes and/or final parts desired. 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). The performance of our different systems varies in terms of capabilities, which are related to the following features:
|●||resin cartridge capacity / filament spool size;|
|●||maximum model (or tray) size; and|
|●||duty cycle, or the number of parts that a printer can produce over a given period of time without requiring maintenance.|
Our systems also integrate our software and are supported by services that we provide to our customers, both directly and through our reseller channel.
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 provide customers with a broad range of features such as printing capacity, production speed and price.
Our 3D printing systems, which are based on our proprietary FDM, PolyJet and stereolithography technologies, are described below:
Our PolyJet technology-based, high-end printing systems offer the ability to print eight multiple materials including color printing in a single part build. The Stratasys J8 Series printers break restrictive technology barriers, enabling customers to print more than 500,000 different color shades and textures, including Pantone® Validated colors, and multiple material properties— ranging from rigid to flexible, and opaque to transparent. It also 3D prints concept models twice as fast as our previous generation printers, supported by a new, low-cost DraftGrey material.
Our J55 3D Printer makes that same fast, full-color design realism accessible to designers and teams everywhere in an office-friendly format and smaller footprint. At about a third the price of J8 Series printers, the J55 including high fidelity and five simultaneously printer materials enabling nearly 500,000 colors.
Both J8 Series 3D printers and the J55 printer support KeyShot 3D rendering software, enabling designers to save KeyShot designs directly in the new 3MF format and produce 3D printed models in a single day, when traditional modeling can take one-to-three weeks.
The Stratasys J750 Digital Anatomy printer helps medical device companies optimize design throughout the product lifecycle. It 3D prints with GelMatrix resin, TissueMatrix resin and BoneMatrix resin — three new materials which, when combined, form over 100 new, unique digital materials to suit anatomical applications. These materials, when used for 3D printing, produce medical models and anatomies that achieve a true-to-life feel and response. This includes both soft tissues, including organs and blood vessels as small as 1mm in diameter, as well as porous bone structures, fibrotic tissues, and ligaments.
The F123 Series printers enable end-to-end rapid prototyping for every stage of the prototyping process, as well as preparation of jigs and fixtures. The prototypes that can be created include: rapid, economically effective concept verification models in PLA material and fast-draft mode and advanced design validation prototypes using a 0.005-inch slice resolution and soluble support for unmatched precision, repeatability and aesthetics. The F123 Series product line allows users to create parts in PLA, ABS plus, ASA, TPU, ABS-ESD, Diran and PC-ABS materials. These materials can produce parts with the strength required for true form, fit and functional testing. The F123 Series printers are designed to enable ease of use and maintenance while offering an easy-to-use yet rich user experience with GrabCAD Print software.
We also offer printing systems typically used for Additive Manufacturing— production tooling and end parts applications— and high-performance Prototyping applications. The Stratasys Fortus 380mc and 450mc build high-performance parts in customary materials, but with advanced complexity and other requirements needed for current-day manufacturers. These systems are run via easy-to-use interfaces and software controls, making them user-friendly in producing complex parts more efficiently. When a job demands exclusive production of high-strength parts for tough applications, the Fortus 380mc Carbon Fiber Edition may be used. It produces functional prototypes, production parts and parts used for rugged tooling, based on the strength and stiffness of carbon-filled composite material used with that printing system.
The Stratasys Fortus F900 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 user’s production floor. Additionally, we announced the Aircraft Interiors Solution in 2018, which allows a faster, simpler path for certifying additively manufactured parts for aircraft installation, and the Rail Industry Solution in 2019 to provide the same benefits for end-use parts on trains.
Our MakerBot Replicator series represents our desktop 3D printers, compact 3D printers, and connected 3D printers. Our desktop and compact 3D printers are affordable, and designed for easy, desktop use. They are typically used by educational institutions and designed for individuals operating alone or within an enterprise. Our new Method™ series of performance printers is aimed at bridging the gap between industrial and desktop systems, providing industrial level of reliability and precision combined with accessibility and ease of use found in desktop systems. The Method™ printers are built for the professional individual user. The METHOD Carbon Fiber Edition and METHOD X Carbon Fiber Edition are manufacturing workstations with a heated chamber, capable of printing composite materials such as Nylon Carbon Fiber. MakerBot Nylon Carbon Fiber is compatible with Stratasys SR-30 soluble support material, has a heat deflection temperature of 100C greater, tensile strength 155% stronger than MakerBot real ABS. The MakerBot LABS Experimental Extruder allows customers to print 3rd party materials on the METHOD platform, including abrasive composite materials with carbon fiber and glass fillings. We also introduced PC-ABS, PC-ABS FR, Nylon 12 Carbon fiber along with Labs materials from Polymaker, Kimya, MCPP and Jabil Additive, bringing the total number of released materials for the METHOD platform to 24.
Our first stereolithography printing system—the V650 Flex 3D Printer (which was optimized for DSM’s Somos™ resins in partnership with DSM, a global company)— combines the power of a large-scale system with a configurable environment for fine-tuning across a broad range of resins, thereby giving customers greater accuracy, choice, and lower costs in 3D printed prototype and part development. The printer enables our customers to capitalize on the quality and high-performance of DSM’s Somos stereolithography resins that enable the production of high-quality, durable parts that meet requirements of a wide range of applications, as well as additive manufacturing prototypes and tools. Following our acquisition of RPS, which was completed in February 2021, we will also be offering industrial stereolithography 3D printers for prototyping and tooling applications, namely RPS’ Neo® line of systems which offers open choice in resins, low service requirements, and reliable and accurate builds with simple day-to-day operation.
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 office-friendly FDM devices. 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 FDM printing materials are also environmentally friendly, as the packaging in which they are sold is returned to us for reuse after the contents are consumed.
For MakerBot METHOD users, we also provide the MakerBot LABS Experimental Extruder. This extruder turns METHOD into an open materials platform, enabling users to print with a wide variety of third-party materials on an industrial 3D printing platform. We have been qualifying third-party materials for the extruder, such as Kimya ABS composite materials by ARMOR and Polymaker polycarbonate materials.
Our resin consumables, which consist of our PolyJet family of proprietary acrylic-based photopolymer materials as well as our other inkjet-based systems, enable users 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-based 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.
Our stereolithography materials— DSM’s Somos stereolithography resins—are used in our first stereolithography system to be brought to market, the V650 Flex 3D Printer. There are four such materials: (i) Somos Element— DSM’s next-generation investment casting resin; (ii) Somos NeXt— this material provides Stereolithography accuracy with the look, feel and performance of thermoplastic; (iii) Somos PerFORM— for applications needing strong, stiff, high-heat-resistant composites with very detailed resolution; and (iv) Somos Watershed XC 11122— a clear solution delivering ABS and PBT-like properties for stereolithography.
These materials, like the V650 Flex 3D Printer, are backed by years of significant utilization at our service bureau, Stratasys Direct Manufacturing.
Stratasys Direct Manufacturing paid-parts service
Stratasys Direct Manufacturing is a contract manufacturing service provider of parts on-demand via 3D printing and conventional production processes. With over 30 years of experience, Stratasys Direct Manufacturing provides rapid prototyping and production parts using the broadest set of additive and conventional technologies of any service bureau in North America and backed by experts ready for the most complex projects. With Stratasys Direct Manufacturing, customers can quickly design, innovate and meet demands of any complexity or scale by accessing the right expertise, industrial-grade 3D printing technologies, and materials without the capital expense. Stratasys Direct Manufacturing pioneered additive manufacturing production applications and specializes in guiding customers from concept development and prototyping through short run production and long-term manufacturing. It also operates an ecommerce service for quick-turn parts, www.stratasysdirect.com, which enables our customers to obtain quotes and order parts around the clock, seven days a week.
As we offer our clients products that might include Conflict Minerals that are necessary to the production or functionality of our manufactured products, we are subject to Section 1502 of the Dodd-Frank Act -reporting requirements associated with Conflict Minerals and the Rule 13p-1. We are committed to responsible sourcing, as outlined in the company’s Conflict Minerals Policy. Further we are committed to conducting supply chain due diligence practices in alignment with the smelter or refiner verification program set up by third party audit bodies, such as the Responsible Minerals Initiative (“RMI”, formerly the CFSI), and the London Bullion Market Association (“LBMA”). We are also committed to ensuring human rights are upheld and respects, including the elimination of child or forced labor conditions in our supply chain, generally, and more specifically in the CAHRAs. However, as the Company is “downstream”, in that the Company or its suppliers purchase cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which presently are limited to tin, tantalum, tungsten, and gold (collectively “3TG”) -related materials after processing by smelters or refiners, we can only report with reasonable certainty the origins or likely origins of the necessary 3TG in our minerals supply chain.
It should also be indicated that we do not directly purchase or procure raw materials from the mineral sites.
1. Reasonable Country of Origin Inquiry
In accordance with our Conflict Minerals Policy, Stratasys has concluded in good faith that during calendar year 2020, we have manufactured and contracted to manufacture products containing 3TG 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 did or did not originate from the CAHRAs, as defined per the Rule. We integrated aspects of the reasonable country of origin inquiry (“RCOI”) into the design of our policies and management systems on Conflict Minerals, and carry out the RCOI in the due diligence phase in which we engaged our relevant upstream suppliers to determine whether the Conflict Minerals necessary to the functionality or production of our products originated from the CAHRAs, as defined per the Rule. The RCOI and the due diligence process were done simultaneously due to the large number of applicable suppliers from which we source materials. We operate significantly downstream from the sources of the minerals necessary to the production and/or functionality of our products’ components. As such, we rely upon the due diligence conducted by our own applicable suppliers. The RCOI that we conducted therefore has certain limitations that limit the total degree of certainty and we cannot determine with absolute certainty the exact source location of all of the necessary Conflict Minerals used in our products in 2020. However, the RCOI we conducted employed several methods to assess whether the necessary Conflict Minerals in our products may have originated from the CAHRAs. These measures consisted primarily of the following actions:
|a)||We performed internal assessments of our products and components to determine which of them contain, or for which the necessary Conflict Minerals were employed, in the production and manufacturing phases.|
|b)||We identified a list of suppliers we purchased from directly during calendar year 2020 (“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 the necessary Conflict Minerals, or the supplier provided a commercial off the shelf product.|
|c)||To reduce the risk of not receiving full information from our Tier 1 Suppliers, we also directly approach plastic, metal and electronic manufacturers, though we did not purchase 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 approached is 542.|
|d)||We solicited survey responses using the standardized template designed by the Responsible Minerals Initiative (“RMI”), , (the “Conflict Minerals Reporting Template version 6.01 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. These are part of our on-going efforts to ensure compliance with our responsible sourcing program among our suppliers, as well as contributing to our goal of increasing the number of relevant smelters or refiners that cooperate with Third Party Audit bodies, such as the RMI.|
|e)||We assessed the responses received from our relevant suppliers of the necessary 3TG for information that would be identified as inconsistent, incomplete, or inaccurate. In addition, we validate CMRTs received from suppliers to identify deviation from the RMI’s requirements as per its RMAP audit program. Responses that failed any of the “red flag” review tests were identified for additional follow up.|
|f)||To non-responsive in scope suppliers, we sent periodic reminders to provide surveys or updated responses according to our expectations regarding the CMRT, such as provision of a current version (i.e.6.01or above).|
Based on the RCOI conducted, Stratasys has reason to believe that a portion of the Conflict Minerals necessary to the functionality of its products or its components is likely to have originated in the CAHRAs and has reason to believe, that those necessary Conflict Minerals may not be entirely from recycled or scrap sources. Based on this result, Stratasys conducted due diligence activities and details these efforts in the forthcoming Conflict Minerals Report and in accordance with the company’s Conflict Minerals Policy and general sourcing expectations from its suppliers.
2. Due Diligence
Due diligence design
In accordance with Rule 13p-1 and Form SD, we undertook to perform a robust due diligence on the source and chain of custody of the 3TG to determine whether the Conflict Minerals necessary to the functionality or production of our products or products’ components originated from the DRC or the Covered Countries, or financially benefitted the armed groups in those countries in any way, as defined per the Rule. We designed our due diligence measures according to the recommendations of the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related supplements for (the “OECD Due Diligence Guidance”) for downstream companies that have no direct relationships to smelters or refiners as we believe that we are a “downstream company”.
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. OECD Step 1: Establishment of strong company management systems
We review and maintain our management system to support supply chain due diligence related to the 3TG. The Company’s management system includes a steering committee sponsored by the senior responsible executive and a team of subject matter experts from various functions such as supplier management, engineering, , and legal. The team subject matter experts are responsible for implementing the Company’s Conflict Minerals compliance strategy. As part of responsible sourcing and supply chain due diligence, the Company has established 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 )https://investors.stratasys.com/corporate-governance/governance-documents(.|
|●||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, to the greatest degree possible, only from smelters or refiners have been validated as conformant or active according to the RMI’s RMAP audit program or other Third Party Audit programs, such as the LBMA.|
|●||In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and any other applicable policy and encourage them to define, implement and communicate to their sub-suppliers their own policy, outlining their commitment to responsible sourcing of 3TG and other minerals from conflict-afflicted areas, legal compliance and measures for implementation of the supply chain due diligence. Our Conflict Minerals Policy is available at )https://investors.stratasys.com/corporate-governance/governance-documents(.|
|●||Maintained the Company’s Conflict Minerals Governance Charter that sets out the Conflict Minerals annual due diligence plan including: establishing steps for compliance, objectives, timelines, internal management and the cross functional team with identified roles and responsibilities to support supply chain due diligence.|
|●||Conducted ongoing communication of the cross functional Conflict Minerals team, for the purpose of sharing best practices and monitoring our progress regarding the various steps required for achieving compliance among our suppliers.|
|●||Engaged with in-scope suppliers of the necessary 3TG and referred them to training materials online, including an overview of relevant Conflict Minerals regulations and compliance measures, and instructions on how to respond to the due diligence survey (based on receiving at a minimum version 6.01 of the CMRT or higher).|
|●||Continued to include a Conflict Minerals provision in our standard Purchasing Terms and Conditions for Goods and Services to require suppliers to comply with our Conflict Minerals Policy and requirements.|
|●||Communicated the due diligence efforts both internally and externally to relevant direct suppliers, surveyed suppliers, customers, employees, senior management, the Board of Directors, and all Company stakeholders , 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 General Counsel.|
b. OECD Step 2: Identify and assess risk in the supply chain
As part of our risk-based approach for the management of a responsible supply chain, Stratasys identified the suppliers from which it made purchases over a specified amount during 2020. We assessed two primary risks in our supply chain while trying to move towards the goal of sourcing the necessary Conflict Minerals from smelters or refiners that have received a conformant or active designation from the RMI or other Third Party Audit bodies, such as the LBMA: (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 spend with a supplier during calendar year 2020 and the extent to which we are dependent upon any particular manufacturer or supplier as well as the availability of alternative suppliers. This segmentation allowed us to invest our risk mitigation efforts according to the level of supplier risk.
We have identified, to the best of our efforts, the smelters or refiners in our minerals supply chain by conducting a supply chain inquiry using, at a minimum, version 6.01 or higher of the CMRT, requesting suppliers and manufactures to identify smelters or refiners and the likely country of origin of the Conflict Minerals in products or product components that they supply to Stratasys. In addition, Stratasys compared smelters or refiners identified by the supply chain survey against the list of facilities that have received a have received a conformant or active designation the RMAP (the RMI’s “Responsible Minerals Assurance Process”) and other independent Third Party Audit programs.
As part of the risk assessment phase, we identified that 69% of our in scope suppliers have policy in place that addresses the Conflict Minerals sourcing and 57.6 do not provide us with products containing Conflict Minerals.
c. OECD Step 3: Design and implement 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 Conflict Minerals 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 or refiners in our supply chain that supply us with Conflict Minerals and have not received a conformant or active designation from the RMI’s RMAP program or other independent Third Party Audit programs.|
|●||Referred in scope suppliers to online training materials that included an overview of the Rule 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 CAHRAs from smelters or refiners that do not participate in the RMI’s RMAP program. While the Company is committed to responsible sourcing of Conflict Minerals, it does not seek to eliminate sourcing from the CAHRAs.|
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 while consulting and communicating with relevant stakeholders.
d. OECD Step 4: Review independent third-party audits of smelter or refiner due diligence practices
Stratasys is a downstream consumer of necessary Conflict Minerals and is many steps removed from the smelters or refiners who process, provide and mine the minerals and ores. Therefore, Stratasys does not perform direct audits of smelters or refiners within its supply chain - the due diligence efforts relying instead on reviewing cross-industry initiatives, such as those led by the RMI i.e. the RMAP smelter or refiner validation program, to conduct smelter or refiner due diligence to verify and audit the status of the smelters or refiners.
e. OECD Step 5: Prepare 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 )https://investors.stratasys.com/corporate-governance/governance-documents(.
3. Results of the Assessment
We conducted a supply chain survey of the 542 in scope suppliers that we identified may contribute necessary Conflict Minerals to our products compared to 573 in scope suppliers in calendar year 2019. In calendar year 2020 we included metal, electronics and plastic suppliers and manufacturers and took a risk-based approach which focused on the majority of our manufacturing spend.
We received responses from in scope suppliers representing approximately a 71% response rate, containing the names and locations of reported smelters or refiners (see Annex 1) and the potential countries of origin (see Annex 2) of the mines or facilities that process Conflict Minerals, compared to approximately a 70.3% response rate attained for reporting year 2019.
Of the 71% (66 from 93) of suppliers and manufacturers that responded:
|●||0% of in scope suppliers were classified as “DRC conflict free”|
|●||1.5% of in scope suppliers were classified as “Not from DRC”|
|●||57.6% of in scope suppliers were classified as “Free no 3TG”|
|●||6.1% of in scope suppliers were classified as “Undetermined not from DRC”|
|●||19.7% of in scope suppliers were classified as “Undetermined from DRC”|
|●||15.2% 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 the DRC or one of the Covered Countries, but that the smelters are approved by the RMAP, the RMI’s Responsible Minerals Assurance Process.|
|●||“Not from DRC” indicates the in-scope suppliers reported that they source Conflict Minerals, but from countries other than the DRC or Covered Countries.|
|●||“Free no 3TG” indicates the in-scope suppliers reported that Conflict Minerals are not contained in the product, or which 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 the DRC or one of the 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 their status is confirmed.|
|●||“Undetermined from DRC” indicates the in-scope suppliers that reported that Conflict Minerals used originate from the DRC or one of the Covered Countries and that the smelters or refiners 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 is confirmed.|
|●||“Undefined from DRC” indicates the in-scope suppliers that reported that Conflict Minerals used originate from the DRC or one of the Covered Countries and that the smelters or refiners are not yet approved by the RMAP program. Due diligence for these in-scope suppliers will continue until the status 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 terms of the components sold to Stratasys in 2020.
As a result of this lack of information, Stratasys is unable to determine with complete accuracy the full list of facilities used to process those necessary Conflict Minerals or their likely country of origin, and therefore, we are unable to conclude whether or not the Conflict Minerals used in our products may have directly or indirectly financed armed groups in the CAHRAs. Stratasys’ efforts to determine the likely mine(s) or location of origin for the necessary Conflict Minerals are realized through the due diligence measures described above.
Smelters or refiners verified as conflict free or in the audit process:
|Tin||49 of 59 (83.0%)|
|Tantalum||37 of 38 (97.4%)|
|Tungsten||47 of 54 (87.0%)|
|Gold||111 of 160 (69.4%)|
|Total||244 of 311 (78.5%)|
Status of identified smelters or refiners:
|Verified Conflict Free (RMI Compliant)||233 of 311 (74.9%)|
|Participating in an audit process (RMI Active)||11 of 311 (3.5%)|
|Not Participating||67 of 311 (21.5%)|
|Total (Conflict Free and under Audit process)||244 of 311 (78.5%)|
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 Rule and or with the company’s Conflict Minerals Policy, conflict-area sourced materials being declared as secondary materials, companies going out of business in 2020 and the potential smuggling of conflict-area Conflict Minerals to countries beyond the CAHRAs.
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, of at least version 6.01 or higher.
We cannot be completely certain of our conclusions regarding the source and chain of custody of the necessary Conflict Minerals used or necessary to the production or for the functionality of our products or product components in 2020, 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, directly or indirectly, benefit armed groups propagating human rights violations in the CAHRAs:
|●||Work with in scope suppliers that did not respond to Stratasys’ surveys to help them understand the importance of this initiative to Stratasys and to encourage their participation in 2021.|
|●||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 CAHRAs, as well as from smelters or refiners that do not participate in the RMI’s RMAP.|
In addition to the above steps, Stratasys continues to implement the Company’s Conflict Minerals Policy and Code of Conduct to the best of the Company’s abilities, namely through the methods of communication on the Company’s Conflict Minerals Policy to the stakeholders and suppliers.
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 or Refiners
|Metal||Smelter Name||Smelter Country|
|Gold||Gussa Sterreichische Gold- und Silber-Scheideanstalt GmbH||AUSTRIA|
|Gold||Abington Reldan Metals, LLC||UNITED STATES OF AMERICA|
|Gold||Advanced Chemical Company||UNITED STATES|
|Gold||African Gold Refinery||UGANDA|
|Gold||Aida Chemical Industries Co., Ltd.||JAPAN|
|Gold||Al Etihad Gold Refinery DMCC||UNITED ARAB EMIRATES|
|Gold||Allgemeine Gold-und Silberscheideanstalt A.G.||GERMANY|
|Gold||Almalyk Mining and Metallurgical Complex (AMMC)||UZBEKISTAN|
|Gold||AngloGold Ashanti C?rrego do S?tio Minera??o||BRAZIL|
|Gold||Asahi Pretec Corp.||JAPAN|
|Gold||Asahi Refining Canada Ltd.||CANADA|
|Gold||Asaka Riken Co., Ltd.||JAPAN|
|Gold||Atasay Kuyumculuk Sanayi Ve Ticaret A.S.||TURKEY|
|Gold||AU Traders and Refiners||SOUTH AFRICA|
|Gold||Augmont Enterprises Private Limited||India|
|Gold||Bangko Sentral ng Pilipinas (Central Bank of the Philippines)||PHILIPPINES|
|Gold||C. Hafner GmbH + Co. KG||GERMANY|
|Gold||C.I Metales Procesados Industriales SAS||COLOMBIA|
|Gold||Cendres + Metaux S.A.||SWITZERLAND|
|Gold||CGR Metalloys Pvt Ltd.||INDIA|
|Gold||China Henan Zhongyuan Gold Smelter||CHINA|
|Gold||Daye Non-Ferrous Metals Mining Ltd.||CHINA|
|Gold||Degussa Sonne / Mond Goldhandel GmbH||GERMANY|
|Gold||Dijllah Gold Refinery FZC||UNITED ARAB EMIRATES|
|Gold||Do Sung Corporation||KOREA, REPUBLIC OF|
|Gold||Dowa Metals & Mining Co. Ltd||JAPAN|
|Gold||DS PRETECH Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Eco-System Recycling Co., Ltd.||JAPAN|
|Gold||Eco-System Recycling Co., Ltd. North Plant||JAPAN|
|Gold||Eco-System Recycling Co., Ltd. West Plant||JAPAN|
|Gold||Emirates Gold DMCC||UNITED ARAB EMIRATES|
|Gold||Fidelity Printers and Refiners Ltd.||ZIMBABWE|
|Gold||Fujairah Gold FZC||UNITED ARAB EMIRATES|
|Gold||GCC Gujrat Gold Centre Pvt. Ltd.||INDIA|
|Gold||Geib Refining Corporation||UNITED STATES|
|Gold||Gold Coast Refinery||GHANA|
|Gold||Great Wall Precious Metals Co., Ltd. of CBPM||CHINA|
|Gold||Guangdong Jinding Gold Limited||CHINA|
|Gold||Guoda Safina High-Tech Environmental Refinery Co., Ltd.||CHINA|
|Gold||Hangzhou Fuchunjiang Smelting Co., Ltd.||CHINA|
|Gold||Heimerle + Meule GmbH||GERMANY|
|Gold||Heraeus Ltd. Hong Kong||CHINA|
|Gold||Heraeus Precious Metals GmbH & Co. KG||GERMANY|
|Gold||Hunan Chenzhou Mining Co., Ltd.||CHINA|
|Gold||Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.||CHINA|
|Gold||HwaSeong CJ CO., LTD.||KOREA, REPUBLIC OF|
|Gold||Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.||CHINA|
|Gold||International Precious Metal Refiners||UNITED ARAB EMIRATES|
|Gold||Ishifuku Metal Industry Co., Ltd.||JAPAN|
|Gold||Istanbul Gold Refinery||TURKEY|
|Gold||JALAN & Company||INDIA|
|Gold||Johnson Matthey Inc.||UNITED STATES|
|Gold||JSC Ekaterinburg Non-Ferrous Metal Processing Plant||RUSSIAN FEDERATION|
|Gold||JSC Uralelectromed||RUSSIAN FEDERATION|
|Gold||JX Nippon Mining & Metals Co., Ltd.||JAPAN|
|Gold||Kaloti Precious Metals||UNITED ARAB EMIRATES|
|Gold||Kazakhmys Smelting LLC||KAZAKHSTAN|
|Gold||Kennecott Utah Copper LLC||UNITED STATES|
|Gold||KGHM Polska Miedz Spolka Akcyjna||POLAND|
|Gold||Kojima Chemicals Co., Ltd.||JAPAN|
|Gold||Korea Zinc Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Kundan Care Products Ltd.||India|
|Gold||Kyshtym Copper-Electrolytic Plant ZAO||RUSSIAN FEDERATION|
|Gold||L’azurde Company For Jewelry||SAUDI ARABIA|
|Gold||Lingbao Gold Co., Ltd.||CHINA|
|Gold||Lingbao Jinyuan Tonghui Refinery Co., Ltd.||CHINA|
|Gold||LS-NIKKO Copper Inc.||KOREA, REPUBLIC OF|
|Gold||LT Metal Ltd.||KOREA, REPUBLIC OF|
|Gold||Luoyang Zijin Yinhui Gold Refinery Co., Ltd.||CHINA|
|Gold||Matsuda Sangyo Co., Ltd.||JAPAN|
|Gold||Metalor Technologies (Hong Kong) Ltd.||HONG KONG|
|Gold||Metalor Technologies (Singapore) Pte., Ltd.||SINGAPORE|
|Gold||Metalor Technologies (Suzhou) Ltd.||CHINA|
|Gold||Metalor Technologies S.A.||SWITZERLAND|
|Gold||Metalor USA Refining Corporation||UNITED STATES|
|Gold||Metalurgica Met-Mex Penoles S.A. De C.V.||MEXICO|
|Gold||Mitsubishi Materials Corporation||JAPAN|
|Gold||Mitsui Mining and Smelting Co., Ltd.||JAPAN|
|Gold||MMTC-PAMP India Pvt., Ltd.||INDIA|
|Gold||Modeltech Sdn Bhd||MALAYSIA|
|Gold||Morris and Watson||NEW ZEALAND|
|Gold||Moscow Special Alloys Processing Plant||RUSSIAN FEDERATION|
|Gold||Nadir Metal Rafineri San. Ve Tic. A.?.||TURKEY|
|Gold||Navoi Mining and Metallurgical Combinat||UZBEKISTAN|
|Gold||NH Recytech Company||KOREA, REPUBLIC OF|
|Gold||Nihon Material Co., Ltd.||JAPAN|
|Gold||Ohura Precious Metal Industry Co., Ltd.||JAPAN|
|Gold||OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)||RUSSIAN FEDERATION|
|Gold||OJSC Novosibirsk Refinery||RUSSIAN FEDERATION|
|Gold||Pease & Curren||UNITED STATES OF AMERICA|
|Gold||Penglai Penggang Gold Industry Co., Ltd.||CHINA|
|Gold||Planta Recuperadora de Metales SpA||CHILE|
|Gold||Prioksky Plant of Non-Ferrous Metals||RUSSIAN FEDERATION|
|Gold||PT Aneka Tambang (Persero) Tbk||INDONESIA|
|Gold||PX Precinox S.A.||SWITZERLAND|
|Gold||QG Refining, LLC||UNITED STATES OF AMERICA|
|Gold||Rand Refinery (Pty) Ltd.||SOUTH AFRICA|
|Gold||Refinery of Seemine Gold Co., Ltd.||CHINA|
|Gold||REMONDIS PMR B.V.||NETHERLANDS|
|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||SAXONIA Edelmetalle GmbH||GERMANY|
|Gold||SEMPSA Joyeria Plateria S.A.||SPAIN|
|Gold||Shandong Gold Mine(Laizhou) Smelter Co., Ltd.||CHINA|
|Gold||Shandong Humon Smelting Co., Ltd.||CHINA|
|Gold||Shandong Tiancheng Biological Gold Industrial Co., Ltd.||CHINA|
|Gold||Shandong Zhaojin Gold & Silver Refinery Co., Ltd.||CHINA|
|Gold||Shirpur Gold Refinery Ltd.||India|
|Gold||Sichuan Tianze Precious Metals Co., Ltd.||CHINA|
|Gold||Singway Technology Co., Ltd.||TAIWAN|
|Gold||SOE Shyolkovsky Factory of Secondary Precious Metals||RUSSIAN FEDERATION|
|Gold||Solar Applied Materials Technology Corp.||TAIWAN|
|Gold||State Research Institute Center for Physical Sciences and Technology||LITHUANIA|
|Gold||Sudan Gold Refinery||SUDAN|
|Gold||Sumitomo Metal Mining Co., Ltd.||JAPAN|
|Gold||SungEel HiMetal Co., Ltd.||KOREA, REPUBLIC OF|
|Gold||Tanaka Kikinzoku Kogyo K.K.||JAPAN|
|Gold||Tokuriki Honten Co., Ltd.||JAPAN|
|Gold||Tongling Nonferrous Metals Group Co., Ltd.||CHINA|
|Gold||Tony Goetz NV||BELGIUM|
|Gold||Torecom||KOREA, REPUBLIC OF|
|Gold||Umicore Brasil Ltda.||BRAZIL|
|Gold||Umicore Precious Metals Thailand||THAILAND|
|Gold||Umicore S.A. Business Unit Precious Metals Refining||BELGIUM|
|Gold||United Precious Metal Refining, Inc.||UNITED STATES|
|Gold||Western Australian Mint (T/a The Perth Mint)||AUSTRALIA|
|Gold||WIELAND Edelmetalle GmbH||GERMANY|
|Gold||Yamamoto Precious Metal Co., Ltd.||JAPAN|
|Gold||Yokohama Metal Co., Ltd.||JAPAN|
|Gold||Yunnan Copper Industry Co., Ltd.||CHINA|
|Gold||Zijin Mining Group Co., Ltd. Gold Refinery||CHINA|
|Tantalum||Asaka Riken Co., Ltd.||JAPAN|
|Tantalum||Changsha South Tantalum Niobium Co., Ltd.||CHINA|
|Tantalum||CP Metals Inc.||UNITED STATES OF AMERICA|
|Tantalum||D Block Metals, LLC||UNITED STATES OF AMERICA|
|Tantalum||Exotech Inc.||UNITED STATES OF AMERICA|
|Tantalum||F&X Electro-Materials Ltd.||CHINA|
|Tantalum||FIR Metals & Resource Ltd.||CHINA|
|Tantalum||Global Advanced Metals Aizu||JAPAN|
|Tantalum||Global Advanced Metals Boyertown||UNITED STATES OF AMERICA|
|Tantalum||Guangdong Zhiyuan New Material Co., Ltd.||CHINA|
|Tantalum||H.C. Starck Co., Ltd.||THAILAND|
|Tantalum||H.C. Starck Hermsdorf GmbH||GERMANY|
|Tantalum||H.C. Starck Inc.||UNITED STATES OF AMERICA|
|Tantalum||H.C. Starck Ltd.||JAPAN|
|Tantalum||H.C. Starck Smelting GmbH & Co. KG||GERMANY|
|Tantalum||H.C. Starck Tantalum and Niobium GmbH||GERMANY|
|Tantalum||Hengyang King Xing Lifeng New Materials Co., Ltd.||CHINA|
|Tantalum||Jiangxi Dinghai Tantalum & Niobium Co., Ltd.||CHINA|
|Tantalum||Jiangxi Tuohong New Raw Material||CHINA|
|Tantalum||JiuJiang JinXin Nonferrous Metals Co., Ltd.||CHINA|
|Tantalum||Jiujiang Tanbre Co., Ltd.||CHINA|
|Tantalum||Jiujiang Zhongao Tantalum & Niobium Co., Ltd.||CHINA|
|Tantalum||KEMET Blue Metals||MEXICO|
|Tantalum||LSM Brasil S.A.||BRAZIL|
|Tantalum||Metallurgical Products India Pvt., Ltd.||INDIA|
|Tantalum||Mineracao Taboca S.A.||BRAZIL|
|Tantalum||Mitsui Mining and Smelting Co., Ltd.||JAPAN|
|Tantalum||Ningxia Orient Tantalum Industry Co., Ltd.||CHINA|
|Tantalum||NPM Silmet AS||ESTONIA|
|Tantalum||PRG Dooel||NORTH MACEDONIA|
|Tantalum||QuantumClean||UNITED STATES OF AMERICA|
|Tantalum||Resind Industria e Comercio Ltda.||BRAZIL|
|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||XinXing HaoRong Electronic Material Co., Ltd.||CHINA|
|Tantalum||Yanling Jincheng Tantalum & Niobium Co., Ltd.||CHINA|
|Tin||Alent plc||UNITED STATES|
|Tin||An Vinh Joint Stock Mineral Processing Company||VIET NAM|
|Tin||Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.||CHINA|
|Tin||Chifeng Dajingzi Tin Industry Co., Ltd.||CHINA|
|Tin||China Tin Co.,Ltd.||CHINA|
|Tin||Dongguan CiEXPO Environmental Engineering Co., Ltd.||CHINA|
|Tin||Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company||VIET NAM|
|Tin||Estanho de Rondonia S.A.||BRAZIL|
|Tin||Gejiu City Fuxiang Industry and Trade Co., Ltd.||CHINA|
|Tin||Gejiu Kai Meng Industry and Trade LLC||CHINA|
|Tin||Gejiu Non-Ferrous Metal Processing Co., Ltd.||CHINA|
|Tin||Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.||CHINA|
|Tin||Gejiu Zili Mining And Metallurgy Co., Ltd.||CHINA|
|Tin||Guangdong Hanhe Non-Ferrous Metal Co., Ltd.||CHINA|
|Tin||Guanyang Guida Nonferrous Metal Smelting Plant||CHINA|
|Tin||HuiChang Hill Tin Industry Co., Ltd.||CHINA|
|Tin||Huichang Jinshunda Tin Co., Ltd.||CHINA|
|Tin||Luna Smelter, Ltd.||RWANDA|
|Tin||Ma’anshan Weitai Tin Co., Ltd.||CHINA|
|Tin||Magnu’s Minerais Metais e Ligas Ltda.||BRAZIL|
|Tin||Malaysia Smelting Corporation (MSC)||MALAYSIA|
|Tin||Melt Metais e Ligas S.A.||BRAZIL|
|Tin||Metallic Resources, Inc.||UNITED STATES|
|Tin||Metallo Spain S.L.U.||SPAIN|
|Tin||Minerao Taboca S.A.||BRAZIL|
|Tin||Mitsubishi Materials Corporation||JAPAN|
|Tin||Modeltech Sdn Bhd||MALAYSIA|
|Tin||Nankang Nanshan Tin Manufactory Co., Ltd.||CHINA|
|Tin||Nghe Tinh Non-Ferrous Metals Joint Stock Company||VIET NAM|
|Tin||O.M. Manufacturing (Thailand) Co., Ltd.||THAILAND|
|Tin||O.M. Manufacturing Philippines, Inc.||PHILIPPINES|
|Tin||Operaciones Metalurgical S.A.||BOLIVIA|
|Tin||Pongpipat Company Limited||MYANMAR|
|Tin||Precious Minerals and Smelting Limited||INDIA|
|Tin||PT Artha Cipta Langgeng||INDONESIA|
|Tin||PT ATD Makmur Mandiri Jaya||INDONESIA|
|Tin||PT Bangka Serumpun||INDONESIA|
|Tin||PT Mitra Stania Prima||INDONESIA|
|Tin||PT Mitra Sukses Globalindo||Indonesia|
|Tin||PT Refined Bangka Tin||INDONESIA|
|Tin||PT Timah (Persero) Tbk Kundur||INDONESIA|
|Tin||PT Timah (Persero) Tbk Mentok||INDONESIA|
|Tin||Resind Industria e Comrcio Ltda.||BRAZIL|
|Tin||Rui Da Hung||TAIWAN|
|Tin||Soft Metais Ltda.||BRAZIL|
|Tin||Thai Nguyen Mining and Metallurgy Co., Ltd.||VIET NAM|
|Tin||Tin Technology & Refining||UNITED STATES OF AMERICA|
|Tin||Tuyen Quang Non-Ferrous Metals Joint Stock Company||VIET NAM|
|Tin||White Solder Metalurgia e Minera??o Ltda.||BRAZIL|
|Tin||Yunnan Tin Company Limited||CHINA|
|Tin||Yunnan Yunfan Non-ferrous Metals Co., Ltd.||CHINA|
|Tungsten||ACL Metais Eireli||BRAZIL|
|Tungsten||Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.||BRAZIL|
|Tungsten||Asia Tungsten Products Vietnam Ltd.||VIET NAM|
|Tungsten||Chenzhou Diamond Tungsten Products Co., Ltd.||CHINA|
|Tungsten||China Molybdenum Co., Ltd.||CHINA|
|Tungsten||Chongyi Zhangyuan Tungsten Co., Ltd.||CHINA|
|Tungsten||CNMC (Guangxi) PGMA Co., Ltd.||CHINA|
|Tungsten||CP Metals Inc.||UNITED STATES OF AMERICA|
|Tungsten||Cronimet Brasil Ltda||Brazil|
|Tungsten||Fujian Ganmin RareMetal Co., Ltd.||CHINA|
|Tungsten||Fujian Jinxin Tungsten Co., Ltd.||CHINA|
|Tungsten||Ganzhou Haichuang Tungsten Co., Ltd.||CHINA|
|Tungsten||Ganzhou Huaxing Tungsten Products Co., Ltd.||CHINA|
|Tungsten||Ganzhou Jiangwu Ferrotungsten Co., Ltd.||CHINA|
|Tungsten||Ganzhou Seadragon W & Mo Co., Ltd.||CHINA|
|Tungsten||GEM Co., Ltd.||CHINA|
|Tungsten||Global Tungsten & Powders Corp.||UNITED STATES OF AMERICA|
|Tungsten||Guangdong Xianglu Tungsten Co., Ltd.||CHINA|
|Tungsten||H.C. Starck Smelting GmbH & Co. KG||GERMANY|
|Tungsten||H.C. Starck Tungsten GmbH||GERMANY|
|Tungsten||Hunan Chenzhou Mining Co., Ltd.||CHINA|
|Tungsten||Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji||CHINA|
|Tungsten||Hunan Chunchang Nonferrous Metals Co., Ltd.||CHINA|
|Tungsten||Hunan Litian Tungsten Industry Co., Ltd.||CHINA|
|Tungsten||Hydrometallurg, JSC||RUSSIAN FEDERATION|
|Tungsten||Japan New Metals Co., Ltd.||JAPAN|
|Tungsten||Jiangwu H.C. Starck Tungsten Products Co., Ltd.||CHINA|
|Tungsten||Jiangxi Gan Bei Tungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.||CHINA|
|Tungsten||Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.||CHINA|
|Tungsten||Jiangxi Xianglu Tungsten Co., Ltd.||CHINA|
|Tungsten||Jiangxi Xinsheng Tungsten Industry Co., Ltd.||CHINA|
|Tungsten||Jiangxi Yaosheng Tungsten Co., Ltd.||CHINA|
|Tungsten||JSC “Kirovgrad Hard Alloys Plant”||RUSSIAN FEDERATION|
|Tungsten||Kennametal Fallon||UNITED STATES OF AMERICA|
|Tungsten||Kennametal Huntsville||UNITED STATES OF AMERICA|
|Tungsten||KGETS Co., Ltd.||KOREA, REPUBLIC OF|
|Tungsten||Lianyou Metals Co., Ltd.||TAIWAN, PROVINCE OF CHINA|
|Tungsten||Malipo Haiyu Tungsten Co., Ltd.||CHINA|
|Tungsten||Masan Tungsten Chemical LLC (MTC)||VIET NAM|
|Tungsten||Moliren Ltd.||RUSSIAN FEDERATION|
|Tungsten||Niagara Refining LLC||UNITED STATES OF AMERICA|
|Tungsten||NPP Tyazhmetprom LLC||RUSSIAN FEDERATION|
|Tungsten||Philippine Chuangxin Industrial Co., Inc.||PHILIPPINES|
|Tungsten||South-East Nonferrous Metal Company Limited of Hengyang City||CHINA|
|Tungsten||Tejing (Vietnam) Tungsten Co., Ltd.||VIET NAM|
|Tungsten||Unecha Refractory metals plant||RUSSIAN FEDERATION|
|Tungsten||Wolfram Bergbau und Hutten AG||AUSTRIA|
|Tungsten||Woltech Korea Co., Ltd.||KOREA, REPUBLIC OF|
|Tungsten||Xiamen Tungsten (H.C.) Co., Ltd.||CHINA|
|Tungsten||Xiamen Tungsten Co., Ltd.||CHINA|
|Tungsten||Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.||CHINA|
|Tungsten||Xinhai Rendan Shaoguan Tungsten Co., Ltd.||CHINA|
Country of Origin (COO)*
|CANADA||JAPAN||INDONESIA||KOREA, REPUBLIC OF|
|COLOMBIA||NORTH MACEDONIA||MYANMAR||TAIWAN, PROVINCE OF CHINA|
|CZECHIA||RUSSIAN FEDERATION||PERU||UNITED STATES OF AMERICA|
|GERMANY||UNITED STATES OF AMERICA||POLAND|
|JAPAN||UNITED STATES OF AMERICA|
|KOREA, REPUBLIC OF|
|UNITED ARAB EMIRATES|
|UNITED STATES OF AMERICA|
*As not all of the smelters or refiners (SORs) reported by our suppliers or manufacturers in the supply chain inquiry did not provide information on the Location of Mine in their CMRTs, and the Company was not able to establish from the SORs complete 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.