Document


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, 2017.
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 25, 2018
By John W. Kosiba, Jr., Senior Vice President and Chief Financial Officer
 
 
 
(Date)
 



Exhibit
Exhibit 1.01

http://api.tenkwizard.com/cgi/image?quest=1&rid=23&ipage=12278900&doc=3


AMSC CONFLICT MINERALS REPORT
For the year ended December 31, 2017


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, 2017 to December 31, 2017.
This Report relates to the process undertaken for AMSC products that were manufactured during calendar year 2017 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 “3TGs”); 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 3TGs 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”).
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 3TGs sourced from the Covered Countries. However, from our RCOI we could not determine that the remainder of the 3TGs used in the production of our products did not originate from the Covered Countries.
COMPANY OVERVIEW
American Superconductor Corporation (together with its subsidiaries, “AMSC ®” or the “Company”) was founded on April 9, 1987. We are a leading provider of megawatt-scale solutions that lower the cost of wind power and enhance the performance of the power grid. In the wind power market, we enable manufacturers to field highly competitive wind turbines through our advanced power electronics products, engineering, and support services. In the power grid market, we enable electric utilities, industrial facilities, and renewable energy project developers to connect, transmit and distribute power through our transmission planning services and power electronics, and superconductor-based products. Our wind and power grid products and services provide exceptional reliability, security, efficiency, and affordability to our customers.
PRODUCT DESCRIPTIONS
We segment our operations into two market-facing business units: Wind and Grid.


AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com


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.

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 ship protection products to the U.S. Navy.


We have determined that virtually all of our products may contain 3TGs.
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 us to conduct in good faith an RCOI reasonably designed to determine whether any of our 3TGs originated in the Covered Countries, are from recycled or scrap sources. Phase one of 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 of our products may contain 3TGs.
Phase two of our conflict minerals compliance program included AMSC engineers’ conducting a detailed bill of material review to ascertain if any of our components contain, or are believed to contain, 3TGs. All parts identified through the screening and detailed bill of material review, including purchased components, are screened and reviewed as described below.
To determine whether any 3TGs in our products originated in the Covered Countries, we retained a third-party service provider, Assent Compliance (“Assent”), to assist us in collecting and reviewing data from our supply chain.   Suppliers of purchased parts or components that are believed to contain 3TG via the engineering reviews described above and survey are required by the supply chain to disclose the source of origin using the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) detailing the unique smelter ID number of every source of material procured.
Disclosure requests 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 suppliers are available to respond. Responses received from suppliers in North America continue to be generally more complete and often indicate that they are more conflict free than those from other parts of the world. 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 14(b) 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, 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. Assent requested that suppliers complete the Conflict Minerals Reporting Template “CMRT” forms and included training and education on the completion of the CMRT form in its electronic communications to suppliers.  Assent monitored and tracked all of these communications 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. 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 3TGs 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 3TGs originate from the covered countries?
o
Any supplier that has any 3TGs from the covered countries, even 1 positive response from their supply chain must answer yes.
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.
All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted in regard to invalid forms and are encouraged to submit a valid form.
DESIGN OF DUE DILIGENCE
AMSC undertook due diligence on the source and chain of custody of the 3TG has 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 on our supply chain due diligence.
DUE DILIGENCE PERFORMED
Step 1: Company Management System
Internal Team
Senior management is involved with the overall execution of our program. The team consists mainly of members of the Procurement and Sourcing team. This team is responsible for providing all suppler 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
The Company expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to AMSC are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. 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. 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
Suppliers requiring outreach for reasons such as unresponsiveness response or other matters are called, emailed and written to. Every effort possible 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 courses. All training is tracked and evaluated based on completion.
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
Our Service Provider retains conflict minerals related documents, including supplier responses to CMRTs. This information is stored in a database hosted by our Service Provider.
Step 2: Identifying and Assessing Risks in Our Supply Chain
To identify and assess risks in our supply chain related to conflict minerals, we reviewed and assessed all CMRTs submitted to us. We used Assent’s software to collect and manage the information from our supply chain. The primary risk we identified with respect to the data we collected from our supply chain for reporting year 2017 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 3TGs 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.
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?

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 May 4th, 2018, 30 suppliers were identified as having a weak program.
Step 3: Designing and Implementing a Response 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 Smelter’s and Refiner’s 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.
Step 5: Publicly Report Our Supply Chain Due Diligence
We have published our Form SD for the year ended December 31, 2017 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 May 4, 2018, our overall response rate was 76% for this reporting year. Five suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. Of the 113 originally surveyed suppliers for our combined product mix, 17 have reported that the 3TG used in the products that we purchase from them were not sourced from a Covered Country. 29 suppliers indicate that the products they provide to us contain 3TGs, of which based on due diligence we have not been able to determine whether such 3TGs may have been sourced from the Covered Countries.

From the responses that we received, we identified 5 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 315 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 256 smelters and refiners that are deemed RMAP Compliant – this indicates these smelters or refiners are compliant with the RMAP assessment protocols. A further 8X 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.

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 actually processed the 3TGs 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.

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.
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 3TGs 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
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103



Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangalore Refinery
INDIA
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
Caridad
MEXICO
CID000180
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
Chugai Mining
JAPAN
CID000264
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
HeeSung
KOREA, REPUBLIC OF
CID000689
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Italpreziosi
ITALY
CID002765



Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Gold
Marsam Metals
BRAZIL
CID002606
Gold
Materion
UNITED STATES
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Gold
Morris and Watson
NEW ZEALAND
CID002282
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259



Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Pease & Curren
UNITED STATES
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
SAAMP
FRANCE
CID002761
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Gold
Safimet S.p.A
Italy
CID002973
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Gold
Sai Refinery
INDIA
CID002853
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Gold
Sudan Gold Refinery
SUDAN
CID002567
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
SungEel HiTech
KOREA, REPUBLIC OF
CID002918
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875



Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Gold
Tony Goetz NV
BELGIUM
CID002587
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Tantalum
Duoluoshan
CHINA
CID000410
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492



Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Tantalum
QuantumClean
UNITED STATES
CID001508
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemicals
JAPAN
CID001869
Tantalum
Telex Metals
UNITED STATES
CID001891
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Tin
Alpha
UNITED STATES
CID000292
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Tin
CV Ayi Jaya
INDONESIA
CID002570
Tin
CV Dua Sekawan
INDONESIA
CID002592
Tin
CV Gita Pesona
INDONESIA
CID000306
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Tin
CV United Smelting
INDONESIA
CID000315
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Tin
Dowa
JAPAN
CID000402



Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Tin
EM Vinto
BOLIVIA
CID000438
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Tin
PT Bangka Tin Industry
INDONESIA
CID001419



Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Tin
PT Bukit Timah
INDONESIA
CID001428
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Tin
PT Karimun Mining
INDONESIA
CID001448
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Tin
PT Tommy Utama
INDONESIA
CID001493
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Super Ligas
Brazil
CID002756
Tin
Thaisarco
THAILAND
CID001898
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645



Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011



Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
 
 
 
 
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.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe