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)
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Delaware |
0-19672 |
04-2959321 |
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(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
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114 East Main Street, Ayer, Massachusetts |
01432 |
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(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:
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☑ |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018. |
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.
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American Superconductor Corporation |
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(Registrant) |
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/s/ John W. Kosiba, Jr. |
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May 30, 2019 |
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By (Signature and Title)* John W. Kosiba, Jr., Senior Vice President and Chief Financial Officer |
(Date) |
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* |
Print name and title of the registrant’s signing executive officer under his or her signature. |
| Exhibit 1.01 to Form SD |  |
AMSC CONFLICT MINERALS REPORT
For the year ended December 31, 2018
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, 2018 to December 31, 2018.
This Report relates to the process undertaken for AMSC products that were manufactured during calendar year 2018 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 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 | |
PRODUCT DESCRIPTIONS
We segment our operations into two market-facing business units: Wind and Grid.
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• |
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 through our Grid business segment. |
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• |
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 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’s 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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 throughout 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.
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. 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 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, 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:
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Questions 1 and 2 are minimum requirements for the CMRT |
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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. |
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Question 3 – Do any of your 3TGs originate from the covered countries? |
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Any supplier that has any 3TGs from the covered countries, even 1 positive response from their supply chain must answer yes. |
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Question 4– is 100% of the 3TG in question from a recycled source? |
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Question 5 – Have you received info from all relevant 3TG Suppliers? |
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If you are not at 100%, then you can’t make definitive statements for Questions 3, 4 and 6 |
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Question 6 – Have you identified all your Smelters and refiners? |
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o |
If the answer here is yes, then question 5 must be yes. This also impacts question 3. |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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. Suppliers are also provided with guidance on how to correct these validation errors. As of 22nd April 2019, there are 13 invalid supplier submissions that could not be corrected.
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:
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1. |
Establishing strong company management systems regarding conflict minerals; |
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2. |
Identifying and assessing risks in our supply chain; |
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3. |
Designing and implementing a strategy to respond to identified risks in our supply chain; |
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4. |
Utilizing independent third-party audits of supply chain diligence; and |
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5. |
Publicly reporting on our supply chain due diligence. |
We are a downstream supplier, many steps removed from the mining of 3TGs. 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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 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. 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 provided 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
AMSC through Assent 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 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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 Assent Compliance Manager system based on criteria established for supplier responses in the System. These risks are addressed by Assent Compliance Supply Chain 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 2018 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.
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 3TGs processing facility that was operational during the 2018 calendar year.
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 3TGs 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 22nd April 2019, we have validated 321 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
Each facility that meets the RMI definition of a smelter or refiner of a 3TGs 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:
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Geographic proximity to the DRC and covered countries; |
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Known mineral source country of origin; |
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Responsible Minerals Assurance Process (RMAP) audit status; |
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Credible evidence of unethical or conflict sourcing; and |
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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?
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 10th, 2019, 35 suppliers were identified as having a weak program while 71 suppliers were considered as having a strong program.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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 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. 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, 2018 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 6th May 2019, our overall response rate was approximately 75% for this reporting year. Thirteen suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. Of the 246 originally surveyed suppliers for our combined product mix, 35 have reported that the 3TG used in the products that we purchase from them were not sourced from a Covered Country. Forty-one 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 six 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 6 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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 321 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 255 smelters and refiners that are deemed RMAP Compliant – this indicates these smelters or refiners are compliant with the RMAP assessment protocols. A further 7 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:
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Continuous internal oversight and review process of responses; |
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Continuous risk based evaluation of bills of material to confirm suspect materials; |
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Risk based selection of suppliers providing suspect materials for current products; |
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Process for requesting declarations and after a reasonable period with no response, second requests; |
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Detailed inspection of responses and following up on inconsistencies, missing information, or possible inaccuracies of information; and |
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For suppliers not responding to second requests, phone call follow-up and escalation to the VP, Operations, is mandatory; |
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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 actually process 3TGs contained in our products. |
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Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs. |
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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. |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
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.
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Metal
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Standard Smelter Name |
Smelter Facility Location |
Smelter ID |
RMI Audit Status |
Conflict Free? |
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Gold |
8853 S.p.A. |
ITALY |
CID002763 |
Conformant |
Yes |
|
Gold |
Abington Reldan Metals, LLC |
UNITED STATES |
CID002708 |
Non Conformant |
Unknown |
|
Gold |
Advanced Chemical Company |
UNITED STATES |
CID000015 |
Conformant |
Yes |
|
Gold |
African Gold Refinery |
UGANDA |
CID003185 |
Not Enrolled |
Unknown |
|
Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
CID000019 |
Conformant |
Yes |
|
Gold |
Al Etihad Gold LLC |
UNITED ARAB EMIRATES |
CID002560 |
Conformant |
Yes |
|
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY |
CID000035 |
Conformant |
Yes |
|
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
CID000041 |
Conformant |
Yes |
|
Gold |
AngloGold Ashanti Córrego do Sítio Mineração |
BRAZIL |
CID000058 |
Conformant |
Yes |
|
Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
CID000077 |
Conformant |
Yes |
|
Gold |
Asahi Pretec Corp. |
JAPAN |
CID000082 |
Conformant |
Yes |
|
Gold |
Asahi Refining Canada Ltd. |
CANADA |
CID000924 |
Conformant |
Yes |
|
Gold |
Asahi Refining USA Inc. |
UNITED STATES |
CID000920 |
Conformant |
Yes |
|
Gold |
Asaka Riken Co., Ltd. |
JAPAN |
CID000090 |
Conformant |
Yes |
|
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
CID000103 |
Not Enrolled |
Unknown |
|
Gold |
AU Traders and Refiners |
SOUTH AFRICA |
CID002850 |
Conformant |
Yes |
|
Gold |
Aurubis AG |
GERMANY |
CID000113 |
Conformant |
Yes |
|
Gold |
Bangalore Refinery |
INDIA |
CID002863 |
Active |
Unknown |
|
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
CID000128 |
Conformant |
Yes |
|
Gold |
Boliden AB |
SWEDEN |
CID000157 |
Conformant |
Yes |
|
Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
CID000176 |
Conformant |
Yes |
|
Gold |
Caridad |
MEXICO |
CID000180 |
Not Enrolled |
Unknown |
|
Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
CID000185 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Gold |
Cendres + Métaux S.A. |
SWITZERLAND |
CID000189 |
Conformant |
Yes |
|
Gold |
Chimet S.p.A. |
ITALY |
CID000233 |
Conformant |
Yes |
|
Gold |
Chugai Mining |
JAPAN |
CID000264 |
Active |
Unknown |
|
Gold |
Daejin Indus Co., Ltd. |
KOREA, REPUBLIC OF |
CID000328 |
Conformant |
Yes |
|
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
CID000343 |
Not Enrolled |
Unknown |
|
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
GERMANY |
CID002867 |
Not Enrolled |
Unknown |
|
Gold |
Dijllah Gold Refinery FZC |
UNITED ARAB EMIRATES |
CID003348 |
Not Enrolled |
Unknown |
|
Gold |
DODUCO Contacts and Refining GmbH |
GERMANY |
CID000362 |
Conformant |
Yes |
|
Gold |
Dowa |
JAPAN |
CID000401 |
Conformant |
Yes |
|
Gold |
DS PRETECH Co., Ltd. |
KOREA, REPUBLIC OF |
CID003195 |
Conformant |
Yes |
|
Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
CID000359 |
Conformant |
Yes |
|
Gold |
Eco-System Recycling Co., Ltd. |
JAPAN |
CID000425 |
Conformant |
Yes |
|
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
CID002561 |
Conformant |
Yes |
|
Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
CID002515 |
Not Enrolled |
Unknown |
|
Gold |
Fujairah Gold FZE |
UNITED ARAB EMIRATES |
CID002584 |
Not Enrolled |
Unknown |
|
Gold |
GCC Gujrat Gold Centre Pvt. Ltd. |
INDIA |
CID002852 |
Not Enrolled |
Unknown |
|
Gold |
Geib Refining Corporation |
UNITED STATES |
CID002459 |
Conformant |
Yes |
|
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CHINA |
CID002243 |
Conformant |
Yes |
|
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
CID001909 |
Not Enrolled |
Unknown |
|
Gold |
Guangdong Jinding Gold Limited |
CHINA |
CID002312 |
Not Enrolled |
Unknown |
|
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA |
CID000651 |
Not Enrolled |
Unknown |
|
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
CID000671 |
Not Enrolled |
Unknown |
|
Gold |
HeeSung |
KOREA, REPUBLIC OF |
CID000689 |
Conformant |
Yes |
|
Gold |
Heimerle + Meule GmbH |
GERMANY |
CID000694 |
Conformant |
Yes |
|
Gold |
Heraeus Metals Hong Kong Ltd. |
CHINA |
CID000707 |
Conformant |
Yes |
|
Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY |
CID000711 |
Conformant |
Yes |
|
Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
CID000767 |
Not Enrolled |
Unknown |
|
Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
CHINA |
CID000773 |
Not Enrolled |
Unknown |
|
Gold |
Hwasung CJ Co., Ltd. |
KOREA, REPUBLIC OF |
CID000778 |
Not Enrolled |
Unknown |
|
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
CID000801 |
Conformant |
Yes |
|
Gold |
International Precious Metal Refiners |
UNITED ARAB EMIRATES |
CID002562 |
Not Enrolled |
Unknown |
|
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
CID000807 |
Conformant |
Yes |
|
Gold |
Istanbul Gold Refinery |
TURKEY |
CID000814 |
Conformant |
Yes |
|
Gold |
Italpreziosi |
ITALY |
CID002765 |
Conformant |
Yes |
|
Gold |
Japan Mint |
JAPAN |
CID000823 |
Conformant |
Yes |
|
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
CID000855 |
Conformant |
Yes |
|
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
CID000927 |
Not Enrolled |
Unknown |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
CID000929 |
Conformant |
Yes |
|
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
CID000937 |
Conformant |
Yes |
|
Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
CID002563 |
Not Enrolled |
Unknown |
|
Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
CID000956 |
Not Enrolled |
Unknown |
|
Gold |
Kazzinc |
KAZAKHSTAN |
CID000957 |
Conformant |
Yes |
|
Gold |
Kennecott Utah Copper LLC |
UNITED STATES |
CID000969 |
Conformant |
Yes |
|
Gold |
KGHM Polska Miedz Spolka Akcyjna |
POLAND |
CID002511 |
Active |
Unknown |
|
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
CID000981 |
Conformant |
Yes |
|
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
CID002605 |
Conformant |
Yes |
|
Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
CID001029 |
Conformant |
Yes |
|
Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
RUSSIAN FEDERATION |
CID002865 |
Not Enrolled |
Unknown |
|
Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
CID001032 |
Not Enrolled |
Unknown |
|
Gold |
Lingbao Gold Co., Ltd. |
CHINA |
CID001056 |
Not Enrolled |
Unknown |
|
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
CID001058 |
Not Enrolled |
Unknown |
|
Gold |
L'Orfebre S.A. |
ANDORRA |
CID002762 |
Conformant |
Yes |
|
Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
CID001078 |
Conformant |
Yes |
|
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
CID001093 |
Not Enrolled |
Unknown |
|
Gold |
Marsam Metals |
BRAZIL |
CID002606 |
Conformant |
Yes |
|
Gold |
Materion |
UNITED STATES |
CID001113 |
Conformant |
Yes |
|
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
CID001119 |
Conformant |
Yes |
|
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
CID001149 |
Conformant |
Yes |
|
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
CID001152 |
Conformant |
Yes |
|
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
CID001147 |
Conformant |
Yes |
|
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
CID001153 |
Conformant |
Yes |
|
Gold |
Metalor USA Refining Corporation |
UNITED STATES |
CID001157 |
Conformant |
Yes |
|
Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
MEXICO |
CID001161 |
Conformant |
Yes |
|
Gold |
Mitsubishi Materials Corporation |
JAPAN |
CID001188 |
Conformant |
Yes |
|
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
CID001193 |
Conformant |
Yes |
|
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
CID002509 |
Conformant |
Yes |
|
Gold |
Modeltech Sdn Bhd |
MALAYSIA |
CID002857 |
Non Conformant |
Unknown |
|
Gold |
Morris and Watson |
NEW ZEALAND |
CID002282 |
Not Enrolled |
Unknown |
|
Gold |
Morris and Watson Gold Coast |
AUSTRALIA |
CID002866 |
Not Enrolled |
Unknown |
|
Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
CID001204 |
Conformant |
Yes |
|
Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
TURKEY |
CID001220 |
Conformant |
Yes |
|
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
CID001236 |
Not Enrolled |
Unknown |
|
Gold |
NH Recytech Company |
KOREA, REPUBLIC OF |
CID003189 |
Active |
Unknown |
|
Gold |
Nihon Material Co., Ltd. |
JAPAN |
CID001259 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
CID002779 |
Conformant |
Yes |
|
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
CID001325 |
Conformant |
Yes |
|
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
CID001326 |
Conformant |
Yes |
|
Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
CID000493 |
Conformant |
Yes |
|
Gold |
PAMP S.A. |
SWITZERLAND |
CID001352 |
Conformant |
Yes |
|
Gold |
Pease & Curren |
UNITED STATES |
CID002872 |
Not Enrolled |
Unknown |
|
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
CID001362 |
Not Enrolled |
Unknown |
|
Gold |
Planta Recuperadora de Metales SpA |
CHILE |
CID002919 |
Conformant |
Yes |
|
Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
CID001386 |
Conformant |
Yes |
|
Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
CID001397 |
Conformant |
Yes |
|
Gold |
PX Précinox S.A. |
SWITZERLAND |
CID001498 |
Conformant |
Yes |
|
Gold |
QG Refining, LLC |
UNITED STATES OF AMERICA |
CID003324 |
Not Enrolled |
Unknown |
|
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
CID001512 |
Conformant |
Yes |
|
Gold |
Refinery of Seemine Gold Co., Ltd. |
CHINA |
CID000522 |
Not Enrolled |
Unknown |
|
Gold |
Remondis Argentia B.V. |
NETHERLANDS |
CID002582 |
Conformant |
Yes |
|
Gold |
Republic Metals Corporation |
UNITED STATES |
CID002510 |
Conformant |
Yes |
|
Gold |
Royal Canadian Mint |
CANADA |
CID001534 |
Conformant |
Yes |
|
Gold |
SAAMP |
FRANCE |
CID002761 |
Conformant |
Yes |
|
Gold |
Sabin Metal Corp. |
UNITED STATES |
CID001546 |
Not Enrolled |
Unknown |
|
Gold |
Safimet S.p.A |
Italy |
CID002973 |
Conformant |
Yes |
|
Gold |
SAFINA A.S. |
CZECH REPUBLIC |
CID002290 |
Not Enrolled |
Unknown |
|
Gold |
Sai Refinery |
INDIA |
CID002853 |
Not Enrolled |
Unknown |
|
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
CID001555 |
Non Conformant |
Unknown |
|
Gold |
SAMWON Metals Corp. |
KOREA, REPUBLIC OF |
CID001562 |
Not Enrolled |
Unknown |
|
Gold |
SAXONIA Edelmetalle GmbH |
GERMANY |
CID002777 |
Conformant |
Yes |
|
Gold |
SEMPSA Joyería Platería S.A. |
SPAIN |
CID001585 |
Conformant |
Yes |
|
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA |
CID001619 |
Not Enrolled |
Unknown |
|
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
CID001622 |
Conformant |
Yes |
|
Gold |
Shangdong Humon Smelting Co., Ltd. |
CHINA |
CID002525 |
Not Enrolled |
Unknown |
|
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
CID001736 |
Conformant |
Yes |
|
Gold |
Singway Technology Co., Ltd. |
TAIWAN |
CID002516 |
Conformant |
Yes |
|
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
CID001756 |
Conformant |
Yes |
|
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN |
CID001761 |
Conformant |
Yes |
|
Gold |
State Research Institute Center for Physical Sciences and Technology |
LITHUANIA |
CID003153 |
Not Enrolled |
Unknown |
|
Gold |
Sudan Gold Refinery |
SUDAN |
CID002567 |
Not Enrolled |
Unknown |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
CID001798 |
Conformant |
Yes |
|
Gold |
SungEel HiTech |
KOREA, REPUBLIC OF |
CID002918 |
Conformant |
Yes |
|
Gold |
T.C.A S.p.A |
ITALY |
CID002580 |
Conformant |
Yes |
|
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
CID001875 |
Conformant |
Yes |
|
Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
CHINA |
CID001916 |
Conformant |
Yes |
|
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
CID001938 |
Conformant |
Yes |
|
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA |
CID001947 |
Not Enrolled |
Unknown |
|
Gold |
Tony Goetz NV |
BELGIUM |
CID002587 |
Non Conformant |
Unknown |
|
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
CID002615 |
Not Enrolled |
Unknown |
|
Gold |
Torecom |
KOREA, REPUBLIC OF |
CID001955 |
Conformant |
Yes |
|
Gold |
Umicore Brasil Ltda. |
BRAZIL |
CID001977 |
Conformant |
Yes |
|
Gold |
Umicore Precious Metals Thailand |
THAILAND |
CID002314 |
Conformant |
Yes |
|
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
CID001980 |
Conformant |
Yes |
|
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES |
CID001993 |
Conformant |
Yes |
|
Gold |
Universal Precious Metals Refining Zambia |
ZAMBIA |
CID002854 |
Not Enrolled |
Unknown |
|
Gold |
Valcambi S.A. |
SWITZERLAND |
CID002003 |
Conformant |
Yes |
|
Gold |
Western Australian Mint trading as The Perth Mint |
AUSTRALIA |
CID002030 |
Conformant |
Yes |
|
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
CID002778 |
Conformant |
Yes |
|
Gold |
Yamamoto Precious Metal Co., Ltd. |
JAPAN |
CID002100 |
Conformant |
Yes |
|
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
CID002129 |
Conformant |
Yes |
|
Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA |
CID000197 |
Not Enrolled |
Unknown |
|
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
CID002224 |
Conformant |
Yes |
|
Tantalum |
Asaka Riken Co., Ltd. |
JAPAN |
CID000092 |
Conformant |
Yes |
|
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
CID000211 |
Conformant |
Yes |
|
Tantalum |
D Block Metals, LLC |
UNITED STATES |
CID002504 |
Conformant |
Yes |
|
Tantalum |
Exotech Inc. |
UNITED STATES |
CID000456 |
Conformant |
Yes |
|
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
CID000460 |
Conformant |
Yes |
|
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
CID002505 |
Conformant |
Yes |
|
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
CID002558 |
Conformant |
Yes |
|
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES |
CID002557 |
Conformant |
Yes |
|
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
CHINA |
CID000291 |
Conformant |
Yes |
|
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA |
CID000616 |
Conformant |
Yes |
|
Tantalum |
H.C. Starck Co., Ltd. |
THAILAND |
CID002544 |
Conformant |
Yes |
|
Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY |
CID002547 |
Conformant |
Yes |
|
Tantalum |
H.C. Starck Inc. |
UNITED STATES |
CID002548 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Tantalum |
H.C. Starck Ltd. |
JAPAN |
CID002549 |
Conformant |
Yes |
|
Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY |
CID002550 |
Conformant |
Yes |
|
Tantalum |
H.C. Starck Tantalum and Niobium GmbH |
GERMANY |
CID002545 |
Conformant |
Yes |
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
CID002492 |
Conformant |
Yes |
|
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
CID002512 |
Conformant |
Yes |
|
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
CID002842 |
Conformant |
Yes |
|
Tantalum |
Jiujiang Janny New Material Co., Ltd. |
CHINA |
CID003191 |
Conformant |
Yes |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
CID000914 |
Conformant |
Yes |
|
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
CID000917 |
Conformant |
Yes |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
CID002506 |
Conformant |
Yes |
|
Tantalum |
KEMET Blue Metals |
MEXICO |
CID002539 |
Conformant |
Yes |
|
Tantalum |
KEMET Blue Powder |
UNITED STATES |
CID002568 |
Conformant |
Yes |
|
Tantalum |
LSM Brasil S.A. |
BRAZIL |
CID001076 |
Conformant |
Yes |
|
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
CID001163 |
Conformant |
Yes |
|
Tantalum |
Mineracao Taboca S.A. |
BRAZIL |
CID001175 |
Conformant |
Yes |
|
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
CID001192 |
Conformant |
Yes |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
CID001277 |
Conformant |
Yes |
|
Tantalum |
NPM Silmet AS |
ESTONIA |
CID001200 |
Conformant |
Yes |
|
Tantalum |
Power Resources Ltd. |
MACEDONIA |
CID002847 |
Conformant |
Yes |
|
Tantalum |
QuantumClean |
UNITED STATES |
CID001508 |
Conformant |
Yes |
|
Tantalum |
Resind Industria e Comercio Ltda. |
BRAZIL |
CID002707 |
Conformant |
Yes |
|
Tantalum |
RFH Tantalum Smeltry Co., Ltd. |
CHINA |
CID001522 |
Conformant |
Yes |
|
Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
CID001769 |
Conformant |
Yes |
|
Tantalum |
Taki Chemicals |
JAPAN |
CID001869 |
Conformant |
Yes |
|
Tantalum |
Telex Metals |
UNITED STATES |
CID001891 |
Conformant |
Yes |
|
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
CID001969 |
Conformant |
Yes |
|
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
CID002508 |
Conformant |
Yes |
|
Tin |
Alpha |
UNITED STATES |
CID000292 |
Conformant |
Yes |
|
Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
CID002703 |
Not Enrolled |
Unknown |
|
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
CID000228 |
Conformant |
Yes |
|
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CHINA |
CID003190 |
Conformant |
Yes |
|
Tin |
China Tin Group Co., Ltd. |
CHINA |
CID001070 |
Conformant |
Yes |
|
Tin |
CV Ayi Jaya |
INDONESIA |
CID002570 |
Conformant |
Yes |
|
Tin |
CV Dua Sekawan |
INDONESIA |
CID002592 |
Conformant |
Yes |
|
Tin |
CV Gita Pesona |
INDONESIA |
CID000306 |
Conformant |
Yes |
|
Tin |
CV Tiga Sekawan |
INDONESIA |
CID002593 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD |
|
|
Tin |
CV United Smelting |
INDONESIA |
CID000315 |
Conformant |
Yes |
|
Tin |
CV Venus Inti Perkasa |
INDONESIA |
CID002455 |
Conformant |
Yes |
|
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
CHINA |
CID003356 |
Active |
Unknown |
|
Tin |
Dowa |
JAPAN |
CID000402 |
Conformant |
Yes |
|
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
CID002572 |
Non Conformant |
Unknown |
|
Tin |
EM Vinto |
BOLIVIA |
CID000438 |
Conformant |
Yes |
|
Tin |
Estanho de Rondônia S.A. |
BRAZIL |
CID000448 |
Not Enrolled |
Unknown |
|
Tin |
Fenix Metals |
POLAND |
CID000468 |
Conformant |
Yes |
|
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA |
CID002848 |
Conformant |
Yes |
|
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
CID000942 |
Conformant |
Yes |
|
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
CID000538 |
Conformant |
Yes |
|
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
CID001908 |
Conformant |
Yes |
|
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
CID000555 |
Conformant |
Yes |
|
Tin |
Guangdong Hanhe Non-ferrous Metal Limited Company |
CHINA |
CID003116 |
Conformant |
Yes |
|
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CHINA |
CID002849 |
Conformant |
Yes |
|
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
CID002844 |
Non Conformant |
Unknown |
|
Tin |
Huichang Jinshunda Tin Co., Ltd. |
CHINA |
CID000760 |
Conformant |
Yes |
|
Tin |
Jiangxi New Nanshan Technology Ltd. |
CHINA |
CID001231 |
Conformant |
Yes |
|
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
CID002468 |
Conformant |
Yes |
|
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
CID001105 |
Conformant |
Yes |
|
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
CID002500 |
Conformant |
Yes |
|
Tin |
Metallic Resources, Inc. |
UNITED STATES |
CID001142 |
Conformant |
Yes |
|
Tin |
Metallo Belgium N.V. |
BELGIUM |
CID002773 |
Conformant |
Yes |
|
Tin |
Metallo Spain S.L.U. |
SPAIN |
CID002774 |
Conformant |
Yes |
|
Tin |
Mineracao Taboca S.A. |
BRAZIL |
CID001173 |
Conformant |
Yes |
|
Tin |
Minsur |
PERU |
CID001182 |
Conformant |
Yes |
|
Tin |
Mitsubishi Materials Corporation |
JAPAN |
CID001191 |
Conformant |
Yes |
|
Tin |
Modeltech Sdn Bhd |
MALAYSIA |
CID002858 |
Conformant |
Yes |
|
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
CID002573 |
Not Enrolled |
Unknown |
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
CID001314 |
Conformant |
Yes |
|
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
CID002517 |
Conformant |
Yes |
|
Tin |
Operaciones Metalurgical S.A. |
BOLIVIA |
CID001337 |
Conformant |
Yes |
|
Tin |
Pongpipat Company Limited |
MYANMAR |
CID003208 |
Not Enrolled |
Unknown |
|
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
CID000309 |
Conformant |
Yes |
|
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
CID001399 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD |
|
|
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
CID002503 |
Conformant |
Yes |
|
Tin |
PT Babel Inti Perkasa |
INDONESIA |
CID001402 |
Conformant |
Yes |
|
Tin |
PT Babel Surya Alam Lestari |
INDONESIA |
CID001406 |
Conformant |
Yes |
|
Tin |
PT Bangka Prima Tin |
INDONESIA |
CID002776 |
Conformant |
Yes |
|
Tin |
PT Bangka Serumpun |
INDONESIA |
CID003205 |
Conformant |
Yes |
|
Tin |
PT Bangka Tin Industry |
INDONESIA |
CID001419 |
Conformant |
Yes |
|
Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
CID001421 |
Conformant |
Yes |
|
Tin |
PT Bukit Timah |
INDONESIA |
CID001428 |
Conformant |
Yes |
|
Tin |
PT DS Jaya Abadi |
INDONESIA |
CID001434 |
Conformant |
Yes |
|
Tin |
PT Inti Stania Prima |
INDONESIA |
CID002530 |
Conformant |
Yes |
|
Tin |
PT Karimun Mining |
INDONESIA |
CID001448 |
Conformant |
Yes |
|
Tin |
PT Kijang Jaya Mandiri |
INDONESIA |
CID002829 |
Conformant |
Yes |
|
Tin |
PT Menara Cipta Mulia |
INDONESIA |
CID002835 |
Conformant |
Yes |
|
Tin |
PT Mitra Stania Prima |
INDONESIA |
CID001453 |
Conformant |
Yes |
|
Tin |
PT Panca Mega Persada |
INDONESIA |
CID001457 |
Conformant |
Yes |
|
Tin |
PT Premium Tin Indonesia |
INDONESIA |
CID000313 |
Conformant |
Yes |
|
Tin |
PT Prima Timah Utama |
INDONESIA |
CID001458 |
Conformant |
Yes |
|
Tin |
PT Rajawali Rimba Perkasa |
INDONESIA |
CID003381 |
Active |
Unknown |
|
Tin |
PT Refined Bangka Tin |
INDONESIA |
CID001460 |
Conformant |
Yes |
|
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
CID001463 |
Conformant |
Yes |
|
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
CID001468 |
Conformant |
Yes |
|
Tin |
PT Sukses Inti Makmur |
INDONESIA |
CID002816 |
Conformant |
Yes |
|
Tin |
PT Sumber Jaya Indah |
INDONESIA |
CID001471 |
Conformant |
Yes |
|
Tin |
PT Timah (Persero) Tbk Kundur |
INDONESIA |
CID001477 |
Conformant |
Yes |
|
Tin |
PT Timah (Persero) Tbk Mentok |
INDONESIA |
CID001482 |
Conformant |
Yes |
|
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
CID001490 |
Conformant |
Yes |
|
Tin |
PT Tirus Putra Mandiri |
INDONESIA |
CID002478 |
Conformant |
Yes |
|
Tin |
PT Tommy Utama |
INDONESIA |
CID001493 |
Conformant |
Yes |
|
Tin |
Resind Industria e Comercio Ltda. |
BRAZIL |
CID002706 |
Conformant |
Yes |
|
Tin |
Rui Da Hung |
TAIWAN |
CID001539 |
Conformant |
Yes |
|
Tin |
Soft Metais Ltda. |
BRAZIL |
CID001758 |
Conformant |
Yes |
|
Tin |
Super Ligas |
Brazil |
CID002756 |
Not Enrolled |
Unknown |
|
Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd. |
VIET NAM |
CID002834 |
Conformant |
Yes |
|
Tin |
Thaisarco |
THAILAND |
CID001898 |
Conformant |
Yes |
|
Tin |
Tin Technology & Refining |
UNITED STATES OF AMERICA |
CID003325 |
Conformant |
Yes |
|
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIET NAM |
CID002574 |
Not Enrolled |
Unknown |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD | |
|
Tin |
White Solder Metalurgia e Mineração Ltda. |
BRAZIL |
CID002036 |
Conformant |
Yes |
|
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
CID002158 |
Conformant |
Yes |
|
Tin |
Yunnan Tin Company Limited |
CHINA |
CID002180 |
Conformant |
Yes |
|
Tungsten |
A.L.M.T. TUNGSTEN Corp. |
JAPAN |
CID000004 |
Conformant |
Yes |
|
Tungsten |
ACL Metais Eireli |
BRAZIL |
CID002833 |
Conformant |
Yes |
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
CID002502 |
Conformant |
Yes |
|
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA |
CID002513 |
Conformant |
Yes |
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
CID000258 |
Conformant |
Yes |
|
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
CID000499 |
Conformant |
Yes |
|
Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. |
CHINA |
CID002645 |
Conformant |
Yes |
|
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
CID000875 |
Conformant |
Yes |
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
CID002315 |
Conformant |
Yes |
|
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
CID002494 |
Conformant |
Yes |
|
Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. |
CHINA |
CID002536 |
Non Conformant |
Unknown |
|
Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES |
CID000568 |
Conformant |
Yes |
|
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
CID000218 |
Conformant |
Yes |
|
Tungsten |
H.C. Starck Smelting GmbH & Co.KG |
GERMANY |
CID002542 |
Conformant |
Yes |
|
Tungsten |
H.C. Starck Tungsten GmbH |
GERMANY |
CID002541 |
Conformant |
Yes |
|
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
CID000766 |
Conformant |
Yes |
|
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA |
CID002579 |
Conformant |
Yes |
|
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA |
CID000769 |
Conformant |
Yes |
|
Tungsten |
Hunan Litian Tungsten Industry Co., Ltd. |
CHINA |
CID003182 |
Active |
Unknown |
|
Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
CID002649 |
Conformant |
Yes |
|
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
CID000825 |
Conformant |
Yes |
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
CID002551 |
Conformant |
Yes |
|
Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CHINA |
CID002647 |
Not Enrolled |
Unknown |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
CID002321 |
Conformant |
Yes |
|
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
CID002313 |
Not Enrolled |
Unknown |
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
CID002318 |
Conformant |
Yes |
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
CID002317 |
Conformant |
Yes |
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
CID002316 |
Conformant |
Yes |
|
Tungsten |
Kennametal Fallon |
UNITED STATES |
CID000966 |
Conformant |
Yes |
|
Tungsten |
Kennametal Huntsville |
UNITED STATES |
CID000105 |
Conformant |
Yes |
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
CID002319 |
Conformant |
Yes |
|
Tungsten |
Moliren Ltd |
RUSSIAN FEDERATION |
CID002845 |
Conformant |
Yes |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
| Exhibit 1.01 to Form SD |
|
|
Tungsten |
Niagara Refining LLC |
UNITED STATES |
CID002589 |
Conformant |
Yes |
|
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIET NAM |
CID002543 |
Conformant |
Yes |
|
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
CID002827 |
Conformant |
Yes |
|
Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City |
CHINA |
CID002815 |
Conformant |
Yes |
|
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIET NAM |
CID001889 |
Conformant |
Yes |
|
Tungsten |
Unecha Refractory metals plant |
RUSSIAN FEDERATION |
CID002724 |
Conformant |
Yes |
|
Tungsten |
Wolfram Bergbau und Hütten AG |
AUSTRIA |
CID002044 |
Conformant |
Yes |
|
Tungsten |
Woltech Korea Co., Ltd. |
KOREA, REPUBLIC OF |
CID002843 |
Conformant |
Yes |
|
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
CID002320 |
Conformant |
Yes |
|
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
CID002082 |
Conformant |
Yes |
|
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CHINA |
CID002830 |
Conformant |
Yes |
|
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA |
CID002095 |
Conformant |
Yes |
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
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com