amsc20210527_sd.htm

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

 

FORM SD

SPECIALIZED DISCLOSURE REPORT

 

 

 

American Superconductor Corporation

(Exact name of the registrant as specified in its charter)

 

 

 

 

         

Delaware

 

0-19672

 

04-2959321

         

(State or other jurisdiction of

incorporation or organization)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

 

 

     

114 East Main Street,

Ayer, Massachusetts

 

01432

     

(Address of principal executive offices)

 

(Zip code)

 

(978) 842-3000

(Name and telephone number, including area code, of the person to contact in connection with this report.)

 

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed and provide the period to which the information in this form applies:

 

 

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

 

Under the final rule, a company that uses any of the designated minerals is required to conduct a reasonable ‘country of origin’ inquiry that must be performed in good faith and be reasonably designed to determine whether any of its minerals originated in the covered countries or are from scrap or recycled sources.

 

 

 

 

Section 1 – Conflict Minerals Disclosure

 

ITEM 1.01 – Conflicts Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

A copy of The Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at http://ir.amsc.com/governance.cfm

 

ITEM 1.02 – Exhibit

 

Exhibit 1.01 – Conflict Minerals Report is attached per Section 1.

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

Exhibit 1.01 – Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form.

 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

 

             

American Superconductor Corporation

           

(Registrant)

           
       

/s/ John W. Kosiba, Jr.

 

 

     

May 27, 2021

By (Signature and Title)* John W. Kosiba, Jr., Senior Vice President and Chief Financial Officer

     

(Date)

 

 

 

*

Print name and title of the registrant’s signing executive officer under his or her signature.

 

 
ex_253676.htm

 

Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

 

AMSC CONFLICT MINERALS REPORT

 

For the year ended December 31, 2020

 

 

 

INTRODUCTION AND SUMMARY

 

This AMSC Conflict Minerals Report (this “Report”) has been prepared in accordance with Section 13(p) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and Rule 13p-1 (the “Rule”) promulgated thereunder, for the reporting period from January 1, 2020 to December 31, 2020.

 

This Report relates to the process undertaken for AMSC products that were manufactured during calendar year 2020 and that contain or are believed to contain conflict minerals that are necessary to the functionality or production of our products. The term “conflict minerals” is defined in Section 13(p) of the Exchange Act as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (the “3TG minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC“) or any adjoining country that shares an internationally recognized border with the DRC. This Report includes a discussion of our conflict minerals program, reasonable country of origin inquiry (“RCOI”), due diligence procedures performed, and the disclosures required by the Securities and Exchange Commission (the “SEC”). AMSC is required to file this Report with the SEC because based on our RCOI and further due diligence, we have reason to believe that the 3TG minerals used in our products may originate in the DRC or certain countries that share an internationally-recognized border with the DRC and that they may not be from recycled or scrap sources. The adjoining countries are the Republic of the Congo, Angola, Burundi, Central African Republic, Rwanda, Tanzania, Uganda, and Zambia (together with the DRC, the “Covered Countries”).

 

AMSC is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, ASMC has put into place a robust due diligence program to ensure its contributions to upholding human rights and responsible practices across the supply chain.

 

COMPANY OVERVIEW

 

American Superconductor Corporation (together with its subsidiaries, “AMSC®” or the “Company”) was founded on April 9, 1987. We are a leading system provider of megawatt-scale power solutions that enhance the performance of the power grid, protect our Navy’s fleet, and lower the cost of wind power. Our products leverage the company’s proprietary “smart materials” and “smart software and controls” to provide enhanced resiliency and improved performance of megawatt-scale power flow.

 

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

PRODUCT DESCRIPTIONS

 

We segment our operations into two market-facing business units: Grid and Wind.

 

 

• 

Grid. Through our Gridtec Solutions™, our Grid business segment enables electric utilities and renewable energy project developers to connect, transmit and distribute power with exceptional efficiency, reliability, security and affordability. We provide planning services that allow us to identify power grid congestion, poor power quality, and other risks, which help us, determine how our solutions can improve network performance. These services often lead to sales of our grid interconnection solutions for wind farms and solar power plants, power quality systems and transmission and distribution cable systems.  We also sell marine protection systems to the U.S. Navy through our Grid business segment.

 

 

• 

Wind. Through our Windtec Solutions™, our Wind business segment enables manufacturers to field wind turbines with exceptional power output, reliability, and affordability. We supply advanced power electronics and control systems, license our highly engineered wind turbine designs, and provide extensive customer support services to wind turbine manufacturers. Our design portfolio includes a broad range of drive trains and power ratings of 2 megawatts (“MW”) and higher. We provide a broad range of power electronics and software-based control systems that are highly integrated and designed for optimized performance, efficiency, and grid compatibility.

 

 

We have determined that virtually all our products may contain one or more of the 3TG minerals.

 

The Company has disclosed the information above, along with a copy of this Report, publicly on its website, http://ir.amsc.com/governance.cfm.

 

RCOI

 

The Conflict Mineral Rule requires and AMSC is committed to and engaged in, conducting in good faith an RCOI reasonably designed to determine whether any of our 3TG minerals originated in the Covered Countries, are from recycled or scrap sources. This data collection and analysis process consisted of two phases.

 

Phase One

 

Our conflict minerals compliance program included a comprehensive screening of our product families. This screening, which mainly consisted of a detailed engineering review of our bill of materials, determined that virtually all our products may contain 3TG minerals as detailed in the Description of Products above.

 

Phase Two

 

Our conflict minerals compliance program included AMSC’s engineers and others conducting a detailed bill of material review to ascertain if any of our components contain, or are believed to contain, 3TG minerals. All parts identified through the screening and detailed bill of material review, including purchased components, are screened and reviewed as described below.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

To determine whether any 3TG minerals in our products originated in the Covered Countries, we continued to retain a third-party service provider, Assent Compliance (“Assent”), to assist us in collecting and reviewing data from our supply chain including upstream risk analysis.   Suppliers of purchased parts or components that are believed to contain 3TG via the engineering reviews described above and survey are required throughout by the supply chain to disclose the source of origin using the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 5.12 or higher detailing the unique smelter ID number of every source of material procured.

 

CMRTs are first requested of suppliers based on delivery quantities from the supplier, in addition to the period deliveries were received. Current products manufactured in the last year and related deliveries are prioritized based on quantities used in production and the likelihood that suppliers are available to respond. Due to the unpredictability of response rates and the completeness of the responses, the Company continues to update its due diligence process to assure the highest response rate and most valid answers reasonably possible. Our efforts to achieve complete transparency in our supply chain are made more difficult due to the fact that a significant portion of our supply chain is not required to file reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act and is therefore not concerned by reporting obligations pursuant to Rule 13p-1 thereunder.

 

We contacted our suppliers via the Assent Compliance Manager (“ACM”), a SaaS platform provided by Assent that enables its users to complete and track supplier communications and allows suppliers to upload completed CMRTs forms directly to the platform for assessment, reporting and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement.

 

Assent requested that suppliers complete a CMRT and included training and education on the completion of the CMRT in its electronic communication to suppliers.  Assent monitored and tracked all of this communication in Assent’s system for future reporting and transparency.

 

Assent periodically informed the Company of the response rate of suppliers during the inquiry process.  AMSC directly contacted suppliers that were unresponsive to Assent’s communications during the RCOI and requested such suppliers to complete the CMRT and submit such form to Assent.  Suppliers requesting additional information regarding the CMRT were encouraged to review informational materials prepared by Assent and to contact Assent with further questions.

 

Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. This data validation is based on:

 

 

Questions 1 and 2 are minimum requirements for the CMRT

 

o

If suppliers state (via Q1 and Q2) that their products do not contain 3TG minerals necessary to the function or production of said products, then no further information is required, and no further data validation is completed.

 

Question 3 – Do any of your 3TG minerals originate from the Covered Countries?

 

o

Any supplier that has any 3TG minerals from the Covered Countries, even 1 positive response from their supply chain must answer yes.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

 

Question 4– is 100% of the 3TG in question from a recycled source?

 

Question 5 – Have you received info from all relevant 3TG Suppliers?

 

o

If you are not at 100%, then you can’t make definitive statements for Questions 3, 4 and 6.

 

Question 6 – Have you identified all your Smelters and refiners?

 

o

If the answer here is yes, then question 5 must be yes. This also impacts question 3.

 

Based on its assessment of survey responses received from our suppliers, AMSC determined that the majority of the materials used in the production of its products do not contain 3TG minerals sourced from the Covered Countries. However, from our RCOI we could not determine that the remainder of the 3TG minerals used in the production of our products did not originate from the Covered Countries.

 

 

 

DESIGN OF DUE DILIGENCE

 

AMSC’s due diligence efforts on the source and chain of custody of 3TG have been designed to conform to the Organization of Economic Cooperation and Development “OECD” Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (Second Edition) (including the supplements on Gold and on Tin, Tungsten and Tantalum) (“OECD Guidance”) being adopted and described below.

 

We developed our due diligence process to address each of the five steps as outlined by the OECD Guidance, namely:

 

 

1.

Establishing strong company management systems regarding conflict minerals;

 

2.

Identifying and assessing risks in our supply chain;

 

3.

Designing and implementing a strategy to respond to identified risks in our supply chain;

 

4.

Utilizing independent third-party audits of supply chain diligence; and

 

5.

Publicly reporting annually on our supply chain due diligence.

 

We are a downstream supplier, many steps removed from the mining of 3TG minerals. Many suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, AMSC does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined, and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

 

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us. Through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

DUE DILIGENCE PERFORMED

 

Step 1: Establish Strong Company Management Systems

 

Internal Compliance Team

 

Senior management is involved with the overall execution of our program. The Compliance team consists of members of the Procurement and Sourcing team in addition to other support. This team is responsible for providing all screened supplier data to Assent and coordination of issues and other tasks that may arise. The team is also responsible for following up with non-responsive suppliers. The team also reviews along with senior management and the Director of Internal Audit, periodic progress and status reports provided by Assent.

 

Control Systems

 

AMSC expects all its suppliers to have policies and procedures in place to ensure that any 3TG minerals used in the production of the products sold to AMSC are DRC conflict-free. This means that the products must not contain 3TG minerals that directly or indirectly finance or benefit armed groups in the Covered Countries. These expectations are communicated directly to suppliers.

 

Other controls include, but are not limited to, our Code of Business Conduct and Ethics that outlines certain expected behaviors for all employees. This Code of Conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Code of Conduct is available to all direct suppliers and if a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. Our Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.

 

In addition, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.

 

Supplier Engagement

 

Through Assent, AMSC engages with suppliers to request that they complete a valid CMRT for the products that they supply to the Company. Suppliers requiring outreach for reasons such as unresponsiveness or other matters are called, emailed and written to. Every effort is made to contact and manage issues with suppliers. Suppliers not responding are dealt with as a risk to the Company and are subject to our termination of relationship with the supplier.

 

We continue to put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s learning management system, Assent University, to enroll all our in-scope suppliers in Conflict Minerals training and support resources. All training is tracked and evaluated based on completion.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

AMSC believes that the combination of the Code of Business Conduct and Ethics, our Conflict Minerals Policy, and engagement with suppliers for Conflict Minerals training and requests constitute a strong program when it comes to supplier engagement.

 

Grievance Mechanism

 

AMSC maintains a Global Hotline and an intranet based Hotline reporting portal for all employees. The Hotline is available for use with respect to conflict minerals. An independent company (the, “Contractor”) receives calls and electronically submitted tips and issues. The Contractor will notify the President, CFO, General Counsel, and Chair of the Audit Committee of the Board of Directors of any calls or other submissions. Upon notification, we evaluate the best method of investigation, evaluation, and if required resolution of any matters. A quarterly report of any activity received by the Contractor is also provided to us and further disclosed and if required reviewed by the Audit Committee during their quarterly meetings.

 

Maintain Records

 

AMSC has adopted a policy to retain relevant documentation for a period of 5 years. We implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. We store all of the information and findings from this process in a database hosted by Assent Compliance that can be audited by internal or external parties.

 

Step 2: Identifying and Assessing Risks in Our Supply Chain

 

Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent Compliance staff and members of our Conflict Minerals team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.

 

The primary risk we identified with respect to the data we collected from our supply chain for reporting year 2020 related to the nature of the responses we received. A large number of the responses we received were company-level CMRTs or did not specify the smelters or refiners used for the 3TG minerals in the components supplied to us. For those who did provide smelter or refiner information, this data was assessed for risk level and suppliers were made aware of any risk that their CMRT submission may include.

 

In accordance with OECD Guidelines, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG minerals processing facility that was operational during the 2020 calendar year.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. We do not typically have a direct relationship with 3TG minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

 

As of 16th April 2021, we have validated 332 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.

 

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

 

Geographic proximity to the DRC and Covered Countries;

 

Known mineral source country of origin;

 

Responsible Minerals Assurance Process (RMAP) audit status;

 

Credible evidence of unethical or conflict sourcing;

 

Peer Assessments conducted by credible third-party sources.

 

As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent Compliance, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to AMSC, and escalating up to removal of these red flag smelters from their supply chain.

 

As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these red flags from the supply chain. In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

 

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:

 

A. Have you established a conflict minerals sourcing policy?

 

E. Have you implemented due diligence measures for conflict-free sourcing?

 

G. Do you review due diligence information received from your suppliers against your company’s expectations?

 

H. Does your review process include corrective action management?

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

When suppliers meet or exceed those criteria (Yes to at least A, E, G and H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. As of 16th April 2021, 27 suppliers were identified as having a weak program while 29 suppliers were considered as having a strong program.

 

Step 3: Designing and Implementing a Strategy to Respond to Identified Risks

 

The Company deals with each supplier on an individual basis as our response to suppliers is dependent on the risk(s) identified and exposure. Factors considered include the overall willingness of the supplier to mitigate risk as well as our ability to procure alternative suppliers. Our response is measured and does include termination of our relationship, if necessary.

 

Step 4: Independent Third-Party Audits of Smelters and Refiners Due Diligence Practices.

 

We do not have a direct relationship with any 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the program.

 

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

 

Step 5: Publicly Report Our Supply Chain Due Diligence

 

We have published our Form SD for the year ended December 31, 2020 and this Report on our website, http://ir.amsc.com/governance.cfm. Information found on or accessed through our website is not considered part of this Report and is not incorporated by reference herein.

 

Due Diligence Results

 

Survey Results

 

As of 16th April 2021, our overall response rate was approximately 60% for this reporting year. One supplier was unable to correct their CMRT and as such, is still listed as an invalid submission. Of the 144 originally surveyed suppliers for our combined product mix, 37 have reported that the 3TG used in the products that we purchase from them were not sourced from a Covered Country. Thirty-seven suppliers indicate that the products they provide to us contain 3TG minerals, of which based on due diligence we have not been able to determine whether such 3TG minerals may have been sourced from the Covered Countries.

 

Number of In-Scope

Suppliers

Change in Number of

In-Scope Supplier

from 2019

Response Rate

Valid Response Rate

144

-49

60%

59%

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

From the responses that we received, we identified 8 smelters that potentially posed a risk. These concerns stem from (i) proximity to the DRC and Covered Countries, (ii) Responsible Minerals Assurance Process RMAP audit status, (iii) known or plausible evidence of unethical or conflict sourcing. For suppliers that identified these specific smelters of concern on their CMRT, we created a due diligence plan. These suppliers were contacted by Assent on behalf of AMSC to mitigate these risks in the supply chain. The suppliers were asked to provide a revised company level, product specific or, user-defined CMRT that does not contain the 5 red flagged smelters identified in their CMRTs submitted to AMSC initially. The suppliers were also asked to conduct additional due diligence to confirm the presence of gold or the presence of any of these flagged facilities in the chain of custody for the part or parts supplied to AMSC.

 

 

 

Smelters and Refiners

 

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TG.  Our suppliers identified a total of 331 legitimate smelters and refiners that appear on the lists maintained by RMI.  Based on the smelter list provided by suppliers via the CMRT and publicly available information, we have identified 238 smelters and refiners that are deemed RMAP Compliant – this indicates these smelters or refiners are compliant with the RMAP assessment protocols. A further 5 smelters or refiners have agreed to undergo or are currently undergoing a third-party audit.  Most of the CMRTs we received were made on a company or division level basis, which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TG contained in our products.  All smelters and refiners identified by our suppliers that we believe may source 3TG from the Covered Countries appear on RMI’s list of validated conflict free smelters and refiners.

 

Status

Number of Identified Smelters and Refiners

RMAP Conformant

238

RMAP Active

22

Not Enrolled

63

Non-Conformant

8

 

 

Attached, as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI as legitimate.  Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A processed the 3TG minerals contained in our products.  Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the 3TG contained in our products.

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Risk Mitigation

 

AMSC has taken significant steps to improve the due diligence process and is committed to continuous process improvement and taking additional steps to mitigate the risk that its necessary conflict minerals benefit armed groups. These steps include implementing a:

 

 

Continuous internal oversight and review process of responses;

 

Continuous risk based evaluation of bills of material to confirm suspect materials;

 

Risk based selection of suppliers providing suspect materials for current products;

 

Process for requesting declarations and after a reasonable period with no response, second requests;

 

Detailed inspection of responses and following up on inconsistencies, missing information, or possible inaccuracies of information; and

 

For suppliers not responding to second requests, phone call follow-up and escalation to the VP, Operations, is mandatory;

 

Work more closely with our third-party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable us to determine which smelters and refiners process 3TG minerals contained in our products.

 

Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TG minerals.

 

Non-responding suppliers face discontinuation of their supply service to AMSC. The Company will keep improving its due diligence measures by working more closely with suppliers to help them understand and satisfy AMSC’s requirements fully.

 

Appendix A: List of Smelters and Refiners

 

This list includes all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed below actually processed the 3TG minerals contained in our products. Therefore, our list of processing smelters and refiners disclosed here may contain more facilities than those that actually processed the conflict minerals contained in our products. The efforts described above under “Due Diligence Performed” represent our efforts to determine the location of origin of our conflict minerals.

 

Metal

Standard Smelter Name

Smelter Facility Location

 Smelter ID

 RMI Audit Status

Gold

8853 S.p.A.

ITALY

CID002763

Conformant

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

CID002708

Non Conformant

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

CID000015

Conformant

Gold

African Gold Refinery

UGANDA

CID003185

Outreach Required

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Conformant

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

CID002560

Conformant

Gold

Alexy Metals

UNITED STATES OF AMERICA

CID003500

Active

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

CID000058

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Conformant

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Conformant

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Conformant

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

CID000920

Conformant

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

Due Diligence Vetting Process

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Conformant

Gold

Augmont Enterprises Private Limited

INDIA

CID003461

Active

Gold

Aurubis AG

GERMANY

CID000113

Conformant

Gold

Bangalore Refinery

INDIA

CID002863

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Conformant

Gold

Boliden AB

SWEDEN

CID000157

Conformant

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Conformant

Gold

C.I Metales Procesados Industriales SAS

COLOMBIA

CID003421

Active

Gold

Caridad

MEXICO

CID000180

Communication Suspended - Not Interested

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Conformant

Gold

Cendres + Metaux S.A.

SWITZERLAND

CID000189

Conformant

Gold

CGR Metalloys Pvt Ltd.

INDIA

CID003382

Outreach Required

Gold

Chimet S.p.A.

ITALY

CID000233

Conformant

Gold

Chugai Mining

JAPAN

CID000264

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

In Communication

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

Outreach Required

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

CID003348

In Communication

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000362

Conformant

Gold

Dowa

JAPAN

CID000401

Conformant

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

CID003195

Conformant

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Conformant

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

CID000425

Conformant

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

CID003424

Conformant

Gold

Eco-System Recycling Co., Ltd. West Plant

JAPAN

CID003425

Conformant

Gold

Emerald Jewel Industry India Limited (Unit 1)

INDIA

CID003487

In Communication

Gold

Emerald Jewel Industry India Limited (Unit 2)

INDIA

CID003488

In Communication

Gold

Emerald Jewel Industry India Limited (Unit 3)

INDIA

CID003489

In Communication

Gold

Emerald Jewel Industry India Limited (Unit 4)

INDIA

CID003490

In Communication

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Conformant

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

RMI Due Diligence Review - Unable to Proceed

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

CID002584

Outreach Required

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

In Communication

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

CID002459

Conformant

Gold

Gold Coast Refinery

GHANA

CID003186

Outreach Required

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Outreach Required

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Outreach Required

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000651

Outreach Required

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

Outreach Required

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Active

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

Outreach Required

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

CID000773

Outreach Required

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

CID000778

Communication Suspended - Not Interested

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Conformant

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

CID002562

Active

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Conformant

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Conformant

Gold

Italpreziosi

ITALY

CID002765

Conformant

Gold

JALAN & Company

INDIA

CID002893

Outreach Required

Gold

Japan Mint

JAPAN

CID000823

Conformant

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

RMI Due Diligence Review - Unable to Proceed

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Conformant

Gold

K.A. Rasmussen

NORWAY

CID003497

Outreach Required

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

RMI Due Diligence Review - Unable to Proceed

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

In Communication

Gold

Kazzinc

KAZAKHSTAN

CID000957

Conformant

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID000969

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Conformant

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Conformant

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Conformant

Gold

Kundan Care Products Ltd.

INDIA

CID003463

In Communication

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

Outreach Required

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

RMI Due Diligence Review - Unable to Proceed

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001056

Outreach Required

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

Outreach Required

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Conformant

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Conformant

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

CID000689

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Outreach Required

Gold

Marsam Metals

BRAZIL

CID002606

Conformant

Gold

Materion

UNITED STATES OF AMERICA

CID001113

Conformant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Conformant

Gold

MD Overseas

INDIA

CID003548

In Communication

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

CID003575

Conformant

Gold

Metallix Refining Inc.

UNITED STATES OF AMERICA

CID003557

Active

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Conformant

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

CID001157

Conformant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

CID001161

Conformant

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Conformant

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Non Conformant

Gold

Morris and Watson

NEW ZEALAND

CID002282

Communication Suspended - Not Interested

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

CID001220

Conformant

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Conformant

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Non Conformant

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001326

Conformant

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Conformant

Gold

PAMP S.A.

SWITZERLAND

CID001352

Conformant

Gold

Pease & Curren

UNITED STATES OF AMERICA

CID002872

Outreach Required

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Outreach Required

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

Conformant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Conformant

Gold

PX Precinox S.A.

SWITZERLAND

CID001498

Conformant

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

CID003324

Outreach Required

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID000522

Outreach Required

Gold

REMONDIS PMR B.V.

NETHERLANDS

CID002582

Conformant

Gold

Royal Canadian Mint

CANADA

CID001534

Conformant

Gold

SAAMP

FRANCE

CID002761

Conformant

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

CID001546

Outreach Required

Gold

Safimet S.p.A

ITALY

CID002973

Conformant

Gold

SAFINA A.S.

CZECH REPUBLIC

CID002290

Conformant

Gold

Sai Refinery

INDIA

CID002853

Outreach Required

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Conformant

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

CID001562

Communication Suspended - Not Interested

Gold

Sancus ZFS (L’Orfebre, SA)

COLOMBIA

CID003529

In Communication

Gold

SAXONIA Edelmetalle GmbH

GERMANY

CID002777

Conformant

Gold

Sellem Industries Ltd.

MAURITANIA

CID003540

Outreach Required

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

CID001585

Conformant

Gold

Shandong Humon Smelting Co., Ltd.

CHINA

CID002525

Outreach Required

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001619

Outreach Required

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Conformant

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

CHINA

CID002527

Outreach Required

Gold

Shirpur Gold Refinery Ltd.

INDIA

CID002588

Outreach Required

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002516

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001756

Conformant

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

CID001761

Conformant

Gold

Sovereign Metals

INDIA

CID003383

Outreach Required

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID003153

Outreach Required

Gold

Sudan Gold Refinery

SUDAN

CID002567

Outreach Required

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Conformant

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

CID002918

Conformant

Gold

T.C.A S.p.A

ITALY

CID002580

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

CID001916

Conformant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID001947

Outreach Required

Gold

Tony Goetz NV

BELGIUM

CID002587

Non Conformant

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Conformant

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Conformant

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Conformant

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

CID001993

Conformant

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

CID002030

Conformant

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Conformant

Gold

Yamakin Co., Ltd.

JAPAN

CID002100

Conformant

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID000197

Outreach Required

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Conformant

Tantalum

Asaka Riken Co., Ltd.

JAPAN

CID000092

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Conformant

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

CID002504

Conformant

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

CID000456

Conformant

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Conformant

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Conformant

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Conformant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

CID002557

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

Conformant

Tantalum

H.C. Starck Co., Ltd.

THAILAND

CID002544

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

Conformant

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

CID002548

Conformant

Tantalum

H.C. Starck Ltd.

JAPAN

CID002549

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Conformant

Tantalum

KEMET Blue Metals

MEXICO

CID002539

Conformant

Tantalum

LSM Brasil S.A.

BRAZIL

CID001076

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Conformant

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Conformant

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Conformant

Tantalum

PRG Dooel

NORTH MACEDONIA, REPUBLIC OF

CID002847

Conformant

Tantalum

QuantumClean

UNITED STATES OF AMERICA

CID001508

Conformant

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Conformant

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Conformant

Tantalum

Taki Chemical Co., Ltd.

JAPAN

CID001869

Conformant

Tantalum

Telex Metals

UNITED STATES OF AMERICA

CID001891

Conformant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Conformant

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID001522

Conformant

Tin

Alpha

UNITED STATES OF AMERICA

CID000292

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID002703

Outreach Required

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Conformant

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Conformant

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

CID003486

Active

Tin

CRM Synergies

SPAIN

CID003524

Active

Tin

CV Ayi Jaya

INDONESIA

CID002570

Active

Tin

CV Venus Inti Perkasa

INDONESIA

CID002455

Active

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

CID003356

Non Conformant

Tin

Dowa

JAPAN

CID000402

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

CID002572

Non Conformant

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000438

Conformant

Tin

Estanho de Rondonia S.A.

BRAZIL

CID000448

Active

Tin

Fenix Metals

POLAND

CID000468

Conformant

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

CHINA

CID003410

Outreach Required

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

CID002848

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

CID003116

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Conformant

Tin

Luna Smelter, Ltd.

RWANDA

CID003387

Conformant

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

CID003379

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Conformant

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Conformant

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

CID001142

Conformant

Tin

Metallo Belgium N.V.

BELGIUM

CID002773

Conformant

Tin

Metallo Spain S.L.U.

SPAIN

CID002774

Conformant

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Conformant

Tin

Minsur

PERU

CID001182

Conformant

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Conformant

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Non Conformant

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002573

Outreach Required

Tin

Novosibirsk Processing Plant Ltd.

RUSSIAN FEDERATION

CID001305

Active

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID001314

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Conformant

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID001337

Conformant

Tin

Pongpipat Company Limited

MYANMAR

CID003208

Outreach Required

Tin

Precious Minerals and Smelting Limited

INDIA

CID003409

Non Conformant

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID000309

Active

Tin

PT Artha Cipta Langgeng

INDONESIA

CID001399

Conformant

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Conformant

Tin

PT Babel Inti Perkasa

INDONESIA

CID001402

Conformant

Tin

PT Babel Surya Alam Lestari

INDONESIA

CID001406

Conformant

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Conformant

Tin

PT Bukit Timah

INDONESIA

CID001428

Active

Tin

PT Lautan Harmonis Sejahtera

INDONESIA

CID002870

Active

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Conformant

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Conformant

Tin

PT Mitra Sukses Globalindo

INDONESIA

CID003449

Outreach Required

Tin

PT Prima Timah Utama

INDONESIA

CID001458

Conformant

Tin

PT Rajawali Rimba Perkasa

INDONESIA

CID003381

Conformant

Tin

PT Rajehan Ariq

INDONESIA

CID002593

Conformant

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Conformant

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID001468

Conformant

Tin

PT Timah Nusantara

INDONESIA

CID001486

Active

Tin

PT Timah Tbk Kundur

INDONESIA

CID001477

Conformant

Tin

PT Timah Tbk Mentok

INDONESIA

CID001482

Conformant

Tin

PT Tinindo Inter Nusa

INDONESIA

CID001490

Conformant

Tin

Resind Industria e Comercio Ltda.

BRAZIL

CID002706

Conformant

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001539

Conformant

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Conformant

Tin

Super Ligas

BRAZIL

CID002756

Active

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

CID002834

Conformant

Tin

Thaisarco

THAILAND

CID001898

Conformant

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002574

Outreach Required

Tin

VQB Mineral and Trading Group JSC

VIET NAM

CID002015

Outreach Required

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

CID002036

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Conformant

Tin

Yunnan Tin Company Limited

CHINA

CID002180

Conformant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

CID003397

Conformant

Tungsten

A.L.M.T. Corp.

JAPAN

CID000004

Conformant

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Conformant

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

CID003427

Active

Tungsten

Artek LLC

RUSSIAN FEDERATION

CID003553

Active

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Conformant

Tungsten

China Molybdenum Co., Ltd.

CHINA

CID002641

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Conformant

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID000281

Outreach Required

Tungsten

Cronimet Brasil Ltda

BRAZIL

CID003468

Active

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

CID003401

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Conformant

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Conformant

Tungsten

GEM Co., Ltd.

CHINA

CID003417

In Communication

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

CID000568

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002542

Conformant

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Conformant

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Conformant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Conformant

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Conformant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002313

Communication Suspended - Not Interested

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002318

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Conformant

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

CID003408

Active

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000966

Conformant

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID000105

Conformant

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

CID003388

Conformant

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID003407

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Conformant

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIET NAM

CID002543

Conformant

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

CID002845

Conformant

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

CID002589

Conformant

Tungsten

NPP Tyazhmetprom LLC

RUSSIAN FEDERATION

CID003416

Active

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Conformant

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com


Exhibit 1.01 to Form SD
https://cdn.kscope.io/0ead9034f178988a27ab69ea1dfa874c-a1.jpg

 

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Conformant

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

CID002044

Conformant

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

CID002843

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002320

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

CID002830

Conformant

 

Appendix B – Countries of Origin

 

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

 

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country(Covered Countries), Ecuador Egypt England Estonia Ethiopia Finland France Germany Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic Of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suri, Suri name, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab Emirates, United Kingdom, USA, Uzbekistan, Vietnam, Zambia, Zimbabwe

 

AMSC

114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000

www.amsc.com