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, 2023. |
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. |
May 23, 2024 |
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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. |
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Exhibit 1.01 to Form SD |
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AMSC CONFLICT MINERALS REPORT
For the year ended December 31, 2023
INTRODUCTION AND SUMMARY
This Conflict Minerals Report (this “Report”) of American Superconductor Corporation (together with its subsidiaries, “AMSC” or the “Company”) 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, 2023 to December 31, 2023.
This Report relates to the process undertaken for AMSC products that were manufactured during calendar year 2023 and that contain or are believed to contain conflict minerals that are necessary to the functionality or production of our products. The term “conflict minerals” is defined in Section 13(p) of the Exchange Act as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (the “3TG minerals”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. This Report includes a discussion of our conflict minerals program, reasonable country of origin inquiry (“RCOI”), due diligence procedures performed, and the disclosures required by the Securities and Exchange Commission (the “SEC”). AMSC is required to file this Report with the SEC because based on our RCOI and further due diligence, we have reason to believe that the 3TG minerals used in our products may originate in the DRC or certain countries that share an internationally recognized border with the DRC and that they may not be from recycled or scrap sources. The adjoining countries are the Republic of the Congo, Angola, Burundi, Central African Republic, Rwanda, Tanzania, Uganda, and Zambia (together with the DRC, the “Covered Countries”).
AMSC is committed to complying with the requirements of the Rule and upholding responsible sourcing practices. As such, AMSC has put into place a robust due diligence program to ensure its contributions to upholding human rights and responsible practices across the supply chain.
COMPANY OVERVIEW
AMSC was founded on April 9, 1987. The Company is a leading system provider of megawatt-scale power resiliency solutions that orchestrate the rhythm and harmony of power on the grid™, and that protect and expand the capability of the Navy’s fleet. The Company’s system level products leverage its propriety “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
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Exhibit 1.01 to Form SD |
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PRODUCT DESCRIPTIONS
We segment our operations into two market-facing business units: Grid and Wind.
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Grid. Through our Gridtec™ Solutions, our Grid business segment enables electric utilities, industrial facilities, and renewable energy project developers to connect, transmit and distribute power with exceptional efficiency, reliability, security and affordability. We provide transmission 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 drivetrains and power ratings of 2 megawatts (“MW’s”) and higher. We provide a broad range of power electronics and software-based control systems that are highly integrated and designed for optimized performance, efficiency, and grid compatibility. |
We have determined that virtually all our products may contain one or more of the 3TG minerals.
The Company has disclosed the information above, along with a copy of this Report, publicly on its website, http://ir.amsc.com/corporate-governance.
RCOI
The Conflict Mineral Rule requires and AMSC is committed to and engaged in, conducting in good faith an RCOI reasonably designed to determine whether any of our 3TG minerals originated in the Covered Countries, are from recycled or scrap sources. This data collection and analysis process consisted of two phases.
Phase One
Our conflict minerals compliance program included a comprehensive screening of our product families. This screening, which mainly consisted of a detailed engineering review of our bill of materials and purchasing activity, determined that virtually all our products may contain 3TG minerals as detailed in the Description of Products above.
Phase Two
Our conflict minerals compliance program included AMSC’s engineers and others conducting a detailed bill of material review to ascertain if any of our components contain, or are believed to contain, 3TG minerals. All parts identified through the screening and detailed bill of material review, including purchased components, are screened and reviewed as described below.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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To determine whether any 3TG minerals in our products originated in the Covered Countries, we continued to retain a third-party service provider, Assent Compliance (“Assent”), to assist us in collecting and reviewing data from our supply chain including upstream risk analysis. Suppliers of purchased parts or components that are believed to contain 3TG via the engineering reviews described above and survey are required throughout by the supply chain to disclose the source of origin using the RBA-GeSI Conflict Minerals Reporting Template (“CMRT”) version 6.1 or higher detailing the unique smelter ID number of every source of material procured.
CMRTs are first requested of suppliers based on delivery quantities from the supplier, in addition to the period deliveries were received. Current products manufactured in the last year and related deliveries are prioritized based on quantities used in production and the likelihood that suppliers are available to respond. Due to the unpredictability of response rates and the completeness of the responses, the Company continues to update its due diligence process to assure the highest response rate and most valid answers reasonably possible. Our efforts to achieve complete transparency in our supply chain are made more difficult due to the fact that a significant portion of our supply chain is not required to file reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act and is therefore not concerned by reporting obligations pursuant to Rule 13p-1 thereunder.
We contacted our suppliers via the Assent Sustainability Manager (“ASM”), a SaaS platform provided by Assent that enables its users to complete and track supplier communications and allows suppliers to upload completed CMRTs forms directly to the platform for assessment, reporting and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement.
Assent requested that suppliers complete a CMRT and included training and education on the completion of the CMRT in its electronic communication to suppliers. Assent monitored and tracked all of this communication in Assent’s system for future reporting and transparency.
Assent periodically informed the Company of the response rate of suppliers during the inquiry process. AMSC directly contacted suppliers that were unresponsive to Assent’s communications during the RCOI and requested such suppliers to complete the CMRT and submit such form to Assent. Suppliers requesting additional information regarding the CMRT were encouraged to review informational materials prepared by Assent and to contact Assent with further questions.
Our program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. This data validation is based on:
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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 3TG minerals necessary to the function or production of said products, then no further information is required, and no further data validation is completed. |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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● |
Question 3 – Do any of your 3TG minerals originate from the Covered Countries? |
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Any supplier that has any 3TG minerals 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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If the answer here is yes, then question 5 must be yes. This also impacts question 3. |
Based on its assessment of survey responses received from our suppliers, AMSC determined that the majority of the materials used in the production of its products do not contain 3TG minerals sourced from the Covered Countries. However, from our RCOI we could not determine that the remainder of the 3TG minerals used in the production of our products did not originate from the Covered Countries.
DESIGN OF DUE DILIGENCE
AMSC’s due diligence efforts on the source and chain of custody of 3TG have been designed to conform to the Organization of Economic Cooperation and Development “OECD” Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (Second Edition) (including the supplements on Gold and on Tin, Tungsten and Tantalum) (“OECD Guidance”) being adopted and described below.
We developed our due diligence process to address each of the five steps as outlined by the OECD Guidance, namely:
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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 annually on our supply chain due diligence. |
We are a downstream supplier, many steps removed from the mining of 3TG minerals. Many suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, AMSC does not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined, and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us. Through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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DUE DILIGENCE PERFORMED
Step 1: Establish Strong Company Management Systems
Internal Compliance Team
Senior management is involved with the overall execution of our program. The Compliance team consists of members of the Procurement and Sourcing teams in addition to other support. These teams are responsible for providing all screened supplier data to Assent and coordination of issues and other tasks that may arise. The teams are also responsible for following up with non-responsive suppliers. The teams also review along with senior management and the Director of Internal Audit, periodic progress and status reports provided by Assent.
Control Systems
AMSC expects all its suppliers to have policies and procedures in place to ensure that any 3TG minerals used in the production of the products sold to AMSC are DRC conflict-free. This means that the products must not contain 3TG minerals that directly or indirectly finance, or benefit armed groups in the Covered Countries. These expectations are communicated directly to suppliers.
Other controls include, but are not limited to, our Code of Business Conduct and Ethics that outlines certain expected behaviors for all employees. This Code of Conduct is based on industry and internationally accepted principles such as the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance. The Code of Conduct is available to all direct suppliers and if a supplier does not meet the Company’s requirements, the relationship with this supplier will be evaluated. Our Code of Conduct is reviewed annually to ensure it continues to align with industry best practices.
In addition, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.
Supplier Engagement
Through Assent, AMSC engages with suppliers to request that they complete a valid CMRT for the products that they supply to the Company. Suppliers requiring outreach for reasons such as unresponsiveness or other matters are called, emailed and written to. Every effort is made to contact and manage issues with suppliers. Suppliers not responding are dealt with as a risk to the Company and are subject to our termination of relationship with the supplier.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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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.
Grievance Mechanism
AMSC maintains a Global Hotline and an intranet-based Hotline reporting portal for all employees. The Hotline is available for use with respect to conflict minerals. An independent company (the, “Contractor”) receives calls and electronically submitted tips and issues. The Contractor will notify the President, CFO, General Counsel, and Chair of the Audit Committee of the Board of Directors of any calls or other submissions. Upon notification, we evaluate the best method of investigation, evaluation, and if required resolution of any matters. A quarterly report of any activity received by the Contractor is also provided to us and further disclosed and if required reviewed by the Audit Committee during their quarterly meetings.
Maintain Records
AMSC has adopted a policy to retain relevant documentation for a period of 5 years. We implemented a document retention policy through Assent to retain conflict minerals related documents, including supplier responses to CMRTs. We store all of the information and findings from this process in a database hosted by Assent Compliance that can be audited by internal or external parties.
Step 2: Identifying and Assessing Risks in Our Supply Chain
Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent Compliance staff and members of our Conflict Minerals team internally who contact the supplier, gather pertinent data and perform an assessment of the supplier’s conflict minerals status.
The primary risk we identified with respect to the data we collected from our supply chain for reporting year 2023 related to the nature of the responses we received. A large number of the responses we received were company-level CMRTs or did not specify the smelters or refiners used for the 3TG minerals in the components supplied to us. For those who did provide smelter or refiner information, this data was assessed for risk level and suppliers were made aware of any risk that their CMRT submission may include.
In accordance with OECD Guidelines, it is important to identify and assess risks associated with conflict minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TG minerals processing facility that was operational during the 2023 calendar year.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the RMAP. We do not typically have a direct relationship with 3TG minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
As of April 19, 2024, we have validated 346 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primarily supplier-level CMRTs, we cannot definitely determine their connection to the Covered Products.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG minerals mineral is assessed according to red flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:
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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; |
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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?
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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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 April 19, 2024, 26 suppliers were identified as having a weak program while 30 suppliers were considered as having a strong program.
Step 3: Designing and Implementing a Strategy to Respond to Identified Risks
The Company deals with each supplier on an individual basis as our response to suppliers is dependent on the risk(s) identified and exposure. Factors considered include the overall willingness of the supplier to mitigate risk as well as our ability to procure alternative suppliers. Our response is measured and does include termination of our relationship, if necessary.
Step 4: Independent Third-Party Audits of 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, 2023 and this Report on our website, http://ir.amsc.com/corporate-governance. 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 April 19, 2024, our overall response rate was approximately 59% for this reporting year. Of the 163 originally surveyed suppliers for our combined product mix, 18 have reported that the 3TG used in the products that we purchase from them were not sourced from a Covered Country. Thirty-one suppliers indicate that the products they provide to us contain 3TG minerals, of which based on due diligence we have not been able to determine whether such 3TG minerals may have been sourced from the Covered Countries. Forty of the surveyed suppliers reported to not use any 3TG minerals.
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Number of In-Scope Suppliers |
Change in Number of In-Scope Supplier from 2022 |
Response Rate |
Valid Response Rate |
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163 |
+3 |
59% |
59% |
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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From the responses that we received, we identified 28 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 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 346 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 224 smelters and refiners that are deemed RMAP Compliant – this indicates these smelters or refiners are compliant with the RMAP assessment protocols. No smelters or refiners have agreed to undergo or are currently undergoing a third-party audit. Sixty of the smelters are or will undergo an educational outreach program to be conformant with our RMAP program. 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.
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Status |
Number of Identified Smelters and Refiners |
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RMAP Conformant |
224 |
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RMAP Active |
4 |
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Not Enrolled |
89 |
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Non-Conformant |
29 |
Attached, as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI as legitimate. Since most of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product-level basis, we are not able to identify which smelters or refiners listed on Appendix A processed the 3TG minerals contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the 3TG contained in our products.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
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Exhibit 1.01 to Form SD |
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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 process 3TG minerals 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 3TG minerals. |
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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. |
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 actually processed the 3TG minerals contained in our products. Therefore, our list of processing smelters and refiners disclosed 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.
AMSC
114 East Main Street | Ayer MA 01432 | +1 (978) 842-3000
www.amsc.com
Exhibit 1.02 to Form SD
AMSC FY23 Conflict Minerals Smelter Report
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Metal |
Smelter Name |
Smelter Facility Location |
Smelter ID |
RMAP Audit Status |
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Tin |
Thaisarco |
Thailand |
CID001898 |
Conformant |
|
Tin |
Luna Smelter, Ltd. |
Rwanda |
CID003387 |
Conformant |
|
Tungsten |
A.L.M.T. Corp. |
Japan |
CID000004 |
Conformant |
|
Gold |
Advanced Chemical Company |
United States Of America |
CID000015 |
Active |
|
Gold |
Aida Chemical Industries Co., Ltd. |
Japan |
CID000019 |
Conformant |
|
Gold |
Agosi AG |
Germany |
CID000035 |
Conformant |
|
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
Uzbekistan |
CID000041 |
Conformant |
|
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
Brazil |
CID000058 |
Conformant |
|
Gold |
Argor-Heraeus S.A. |
Switzerland |
CID000077 |
Conformant |
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Gold |
Asahi Pretec Corp. |
Japan |
CID000082 |
Conformant |
|
Gold |
Asaka Riken Co., Ltd. |
Japan |
CID000090 |
Conformant |
|
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Turkey |
CID000103 |
Outreach Required |
|
Tungsten |
Kennametal Huntsville |
United States Of America |
CID000105 |
Conformant |
|
Gold |
Aurubis AG |
Germany |
CID000113 |
Conformant |
|
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
CID000128 |
Conformant |
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Gold |
Boliden AB |
Sweden |
CID000157 |
Conformant |
|
Gold |
C. Hafner GmbH + Co. KG |
Germany |
CID000176 |
Conformant |
|
Gold |
Caridad |
Mexico |
CID000180 |
Outreach Required |
|
Gold |
CCR Refinery - Glencore Canada Corporation |
Canada |
CID000185 |
Conformant |
|
Gold |
Cendres + Metaux S.A. |
Switzerland |
CID000189 |
Non Conformant |
|
Gold |
Yunnan Copper Industry Co., Ltd. |
China |
CID000197 |
Outreach Required |
|
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
China |
CID000218 |
Conformant |
|
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
China |
CID000228 |
Conformant |
|
Gold |
Chimet S.p.A. |
Italy |
CID000233 |
Conformant |
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
China |
CID000258 |
Conformant |
|
Gold |
Chugai Mining |
Japan |
CID000264 |
Conformant |
|
Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. |
China |
CID000281 |
Outreach Required |
|
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
China |
CID000291 |
Conformant |
|
Tin |
Alpha |
United States Of America |
CID000292 |
Conformant |
|
Tin |
PT Aries Kencana Sejahtera |
Indonesia |
CID000309 |
Conformant |
|
Tin |
PT Premium Tin Indonesia |
Indonesia |
CID000313 |
Conformant |
|
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
China |
CID000343 |
Outreach Required |
|
Gold |
DSC (Do Sung Corporation) |
Korea, Republic Of |
CID000359 |
Conformant |
|
Gold |
Dowa |
Japan |
CID000401 |
Conformant |
|
Tin |
Dowa |
Japan |
CID000402 |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. East Plant |
Japan |
CID000425 |
Conformant |
|
Tin |
EM Vinto |
Bolivia (Plurinational State Of) |
CID000438 |
Conformant |
|
Tin |
Estanho de Rondonia S.A. |
Brazil |
CID000448 |
Conformant |
|
Tantalum |
F&X Electro-Materials Ltd. |
China |
CID000460 |
Conformant |
|
Tin |
Fenix Metals |
Poland |
CID000468 |
Conformant |
|
Gold |
JSC Novosibirsk Refinery |
Russian Federation |
CID000493 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Refinery of Seemine Gold Co., Ltd. |
China |
CID000522 |
Outreach Required |
|
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
China |
CID000538 |
Conformant |
|
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
China |
CID000555 |
Non Conformant |
|
Tungsten |
Global Tungsten & Powders LLC |
United States Of America |
CID000568 |
Conformant |
|
Tantalum |
XIMEI RESOURCES (GUANGDONG) LIMITED |
China |
CID000616 |
Conformant |
|
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
China |
CID000651 |
Outreach Required |
|
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
China |
CID000671 |
Outreach Required |
|
Gold |
LT Metal Ltd. |
Korea, Republic Of |
CID000689 |
Conformant |
|
Gold |
Heimerle + Meule GmbH |
Germany |
CID000694 |
Conformant |
|
Gold |
Heraeus Metals Hong Kong Ltd. |
China |
CID000707 |
Conformant |
|
Gold |
Heraeus Germany GmbH Co. KG |
Germany |
CID000711 |
Conformant |
|
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
China |
CID000766 |
Conformant |
|
Gold |
Hunan Chenzhou Mining Co., Ltd. |
China |
CID000767 |
Outreach Required |
|
Tungsten |
Hunan Jintai New Material Co., Ltd. |
China |
CID000769 |
Non Conformant |
|
Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
China |
CID000773 |
Outreach Required |
|
Gold |
HwaSeong CJ CO., LTD. |
Korea, Republic Of |
CID000778 |
Communication Suspended - Not Interested |
|
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
China |
CID000801 |
Conformant |
|
Gold |
Ishifuku Metal Industry Co., Ltd. |
Japan |
CID000807 |
Conformant |
|
Gold |
Istanbul Gold Refinery |
Turkey |
CID000814 |
Conformant |
|
Gold |
Japan Mint |
Japan |
CID000823 |
Conformant |
|
Tungsten |
Japan New Metals Co., Ltd. |
Japan |
CID000825 |
Conformant |
|
Gold |
Jiangxi Copper Co., Ltd. |
China |
CID000855 |
Conformant |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
China |
CID000914 |
Conformant |
|
Tantalum |
Jiujiang Tanbre Co., Ltd. |
China |
CID000917 |
Conformant |
|
Gold |
Asahi Refining USA Inc. |
United States Of America |
CID000920 |
Conformant |
|
Gold |
Asahi Refining Canada Ltd. |
Canada |
CID000924 |
Conformant |
|
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Russian Federation |
CID000927 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
JSC Uralelectromed |
Russian Federation |
CID000929 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
JX Nippon Mining & Metals Co., Ltd. |
Japan |
CID000937 |
Conformant |
|
Tin |
Gejiu Kai Meng Industry and Trade LLC |
China |
CID000942 |
Non Conformant |
|
Gold |
Kazakhmys Smelting LLC |
Kazakhstan |
CID000956 |
Outreach Required |
|
Gold |
Kazzinc |
Kazakhstan |
CID000957 |
Conformant |
|
Tungsten |
Kennametal Fallon |
United States Of America |
CID000966 |
Conformant |
|
Gold |
Kennecott Utah Copper LLC |
United States Of America |
CID000969 |
Conformant |
|
Gold |
Kojima Chemicals Co., Ltd. |
Japan |
CID000981 |
Conformant |
|
Gold |
Kyrgyzaltyn JSC |
Kyrgyzstan |
CID001029 |
Non Conformant |
|
Gold |
L'azurde Company For Jewelry |
Saudi Arabia |
CID001032 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Lingbao Gold Co., Ltd. |
China |
CID001056 |
Outreach Required |
|
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
China |
CID001058 |
Outreach Required |
|
Tin |
China Tin Group Co., Ltd. |
China |
CID001070 |
Conformant |
|
Tantalum |
AMG Brasil |
Brazil |
CID001076 |
Conformant |
|
Gold |
LS-NIKKO Copper Inc. |
Korea, Republic Of |
CID001078 |
Conformant |
|
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
China |
CID001093 |
Outreach Required |
|
Tin |
Malaysia Smelting Corporation (MSC) |
Malaysia |
CID001105 |
Conformant |
|
Gold |
Materion |
United States Of America |
CID001113 |
Conformant |
|
Gold |
Matsuda Sangyo Co., Ltd. |
Japan |
CID001119 |
Conformant |
|
Tin |
Metallic Resources, Inc. |
United States Of America |
CID001142 |
Conformant |
|
Gold |
Metalor Technologies (Suzhou) Ltd. |
China |
CID001147 |
Conformant |
|
Gold |
Metalor Technologies (Hong Kong) Ltd. |
China |
CID001149 |
Conformant |
|
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
Singapore |
CID001152 |
Conformant |
|
Gold |
Metalor Technologies S.A. |
Switzerland |
CID001153 |
Conformant |
|
Gold |
Metalor USA Refining Corporation |
United States Of America |
CID001157 |
Conformant |
|
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
Mexico |
CID001161 |
Conformant |
|
Tantalum |
Metallurgical Products India Pvt., Ltd. |
India |
CID001163 |
Conformant |
|
Tin |
Mineracao Taboca S.A. |
Brazil |
CID001173 |
Conformant |
|
Tantalum |
Mineracao Taboca S.A. |
Brazil |
CID001175 |
Conformant |
|
Tin |
Minsur |
Peru |
CID001182 |
Conformant |
|
Gold |
Mitsubishi Materials Corporation |
Japan |
CID001188 |
Conformant |
|
Tin |
Mitsubishi Materials Corporation |
Japan |
CID001191 |
Conformant |
|
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
CID001192 |
Conformant |
|
Gold |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
CID001193 |
Conformant |
|
Tantalum |
NPM Silmet AS |
Estonia |
CID001200 |
Conformant |
|
Gold |
Moscow Special Alloys Processing Plant |
Russian Federation |
CID001204 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
Turkey |
CID001220 |
Conformant |
|
Tin |
Jiangxi New Nanshan Technology Ltd. |
China |
CID001231 |
Conformant |
|
Gold |
Navoi Mining and Metallurgical Combinat |
Uzbekistan |
CID001236 |
Conformant |
|
Gold |
Nihon Material Co., Ltd. |
Japan |
CID001259 |
Conformant |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
China |
CID001277 |
Conformant |
|
Tin |
Novosibirsk Tin Combine |
Russian Federation |
CID001305 |
RMI Due Diligence Review - Unable to Proceed |
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
Thailand |
CID001314 |
Conformant |
|
Gold |
Ohura Precious Metal Industry Co., Ltd. |
Japan |
CID001325 |
Conformant |
|
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Russian Federation |
CID001326 |
RMI Due Diligence Review - Unable to Proceed |
|
Tin |
Operaciones Metalurgicas S.A. |
Bolivia (Plurinational State Of) |
CID001337 |
Conformant |
|
Gold |
MKS PAMP SA |
Switzerland |
CID001352 |
Conformant |
|
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
China |
CID001362 |
Outreach Required |
|
Gold |
Prioksky Plant of Non-Ferrous Metals |
Russian Federation |
CID001386 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
PT Aneka Tambang (Persero) Tbk |
Indonesia |
CID001397 |
Conformant |
|
Tin |
PT Artha Cipta Langgeng |
Indonesia |
CID001399 |
Conformant |
|
Tin |
PT Babel Inti Perkasa |
Indonesia |
CID001402 |
Conformant |
|
Tin |
PT Babel Surya Alam Lestari |
Indonesia |
CID001406 |
Conformant |
|
Tin |
PT Bangka Tin Industry |
Indonesia |
CID001419 |
Active |
|
Tin |
PT Belitung Industri Sejahtera |
Indonesia |
CID001421 |
Conformant |
|
Tin |
PT Bukit Timah |
Indonesia |
CID001428 |
Conformant |
|
Tin |
PT Mitra Stania Prima |
Indonesia |
CID001453 |
Conformant |
|
Tin |
PT Panca Mega Persada |
Indonesia |
CID001457 |
Outreach Required |
|
Tin |
PT Prima Timah Utama |
Indonesia |
CID001458 |
Conformant |
|
Tin |
PT Refined Bangka Tin |
Indonesia |
CID001460 |
Conformant |
|
Tin |
PT Sariwiguna Binasentosa |
Indonesia |
CID001463 |
Conformant |
|
Tin |
PT Stanindo Inti Perkasa |
Indonesia |
CID001468 |
Conformant |
|
Tin |
PT Timah Tbk Kundur |
Indonesia |
CID001477 |
Conformant |
|
Tin |
PT Timah Tbk Mentok |
Indonesia |
CID001482 |
Conformant |
|
Tin |
PT Timah Nusantara |
Indonesia |
CID001486 |
Conformant |
|
Tin |
PT Tinindo Inter Nusa |
Indonesia |
CID001490 |
Conformant |
|
Tin |
PT Tommy Utama |
Indonesia |
CID001493 |
Conformant |
|
Gold |
PX Precinox S.A. |
Switzerland |
CID001498 |
Conformant |
|
Tantalum |
QuantumClean |
United States Of America |
CID001508 |
Conformant |
|
Gold |
Rand Refinery (Pty) Ltd. |
South Africa |
CID001512 |
Conformant |
|
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
China |
CID001522 |
Conformant |
|
Gold |
Royal Canadian Mint |
Canada |
CID001534 |
Conformant |
|
Tin |
Rui Da Hung |
Taiwan, Province Of China |
CID001539 |
Conformant |
|
Gold |
Sabin Metal Corp. |
United States Of America |
CID001546 |
Communication Suspended - Not Interested |
|
Gold |
Samduck Precious Metals |
Korea, Republic Of |
CID001555 |
Non Conformant |
|
Gold |
Samwon Metals Corp. |
Korea, Republic Of |
CID001562 |
Communication Suspended - Not Interested |
|
Gold |
SEMPSA Joyeria Plateria S.A. |
Spain |
CID001585 |
Conformant |
|
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
China |
CID001619 |
Outreach Required |
|
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
CID001622 |
Conformant |
|
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
China |
CID001736 |
Conformant |
|
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
Russian Federation |
CID001756 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Solar Applied Materials Technology Corp. |
Taiwan, Province Of China |
CID001761 |
Conformant |
|
Tantalum |
Solikamsk Magnesium Works OAO |
Russian Federation |
CID001769 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Sumitomo Metal Mining Co., Ltd. |
Japan |
CID001798 |
Conformant |
|
Gold |
Super Dragon Technology Co., Ltd. |
Taiwan, Province Of China |
CID001810 |
Outreach Required |
|
Tantalum |
Taki Chemical Co., Ltd. |
Japan |
CID001869 |
Conformant |
|
Gold |
Tanaka Kikinzoku Kogyo K.K. |
Japan |
CID001875 |
Conformant |
|
Tantalum |
Telex Metals |
United States Of America |
CID001891 |
Conformant |
|
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
China |
CID001908 |
Non Conformant |
|
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
China |
CID001909 |
Outreach Required |
|
Gold |
Shandong Gold Smelting Co., Ltd. |
China |
CID001916 |
Conformant |
|
Gold |
Tokuriki Honten Co., Ltd. |
Japan |
CID001938 |
Conformant |
|
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
China |
CID001947 |
Outreach Required |
|
Gold |
Torecom |
Korea, Republic Of |
CID001955 |
Conformant |
|
Tantalum |
Ulba Metallurgical Plant JSC |
Kazakhstan |
CID001969 |
Conformant |
|
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
Belgium |
CID001980 |
Conformant |
|
Gold |
United Precious Metal Refining, Inc. |
United States Of America |
CID001993 |
Conformant |
|
Gold |
Valcambi S.A. |
Switzerland |
CID002003 |
Conformant |
|
Tin |
VQB Mineral and Trading Group JSC |
Viet Nam |
CID002015 |
Outreach Required |
|
Gold |
Western Australian Mint (T/a The Perth Mint) |
Australia |
CID002030 |
Conformant |
|
Tin |
White Solder Metalurgia e Mineracao Ltda. |
Brazil |
CID002036 |
Conformant |
|
Tungsten |
Wolfram Bergbau und Hutten AG |
Austria |
CID002044 |
Conformant |
|
Tungsten |
Xiamen Tungsten Co., Ltd. |
China |
CID002082 |
Conformant |
|
Gold |
Yamakin Co., Ltd. |
Japan |
CID002100 |
Conformant |
|
Gold |
Yokohama Metal Co., Ltd. |
Japan |
CID002129 |
Conformant |
|
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
China |
CID002158 |
Conformant |
|
Tin |
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
China |
CID002180 |
Conformant |
|
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
China |
CID002224 |
Conformant |
|
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
China |
CID002243 |
Conformant |
|
Gold |
Morris and Watson |
New Zealand |
CID002282 |
Outreach Required |
|
Gold |
SAFINA A.S. |
Czechia |
CID002290 |
Conformant |
|
Gold |
Guangdong Jinding Gold Limited |
China |
CID002312 |
Outreach Required |
|
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
China |
CID002313 |
Communication Suspended - Not Interested |
|
Gold |
Umicore Precious Metals Thailand |
Thailand |
CID002314 |
Non Conformant |
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
China |
CID002315 |
Conformant |
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
China |
CID002316 |
Conformant |
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
China |
CID002317 |
Conformant |
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
China |
CID002318 |
Conformant |
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
China |
CID002319 |
Conformant |
|
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
China |
CID002320 |
Conformant |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
China |
CID002321 |
Conformant |
|
Tin |
CV Venus Inti Perkasa |
Indonesia |
CID002455 |
Conformant |
|
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
Brazil |
CID002468 |
Conformant |
|
Tin |
PT Tirus Putra Mandiri |
Indonesia |
CID002478 |
Communication Suspended - Not Interested |
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
China |
CID002492 |
Conformant |
|
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
China |
CID002494 |
Conformant |
|
Tin |
Melt Metais e Ligas S.A. |
Brazil |
CID002500 |
Non Conformant |
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
Viet Nam |
CID002502 |
Conformant |
|
Tin |
PT ATD Makmur Mandiri Jaya |
Indonesia |
CID002503 |
Conformant |
|
Tantalum |
D Block Metals, LLC |
United States Of America |
CID002504 |
Conformant |
|
Tantalum |
FIR Metals & Resource Ltd. |
China |
CID002505 |
Conformant |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
China |
CID002506 |
Conformant |
|
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
China |
CID002508 |
Conformant |
|
Gold |
MMTC-PAMP India Pvt., Ltd. |
India |
CID002509 |
Conformant |
|
Gold |
KGHM Polska Miedz Spolka Akcyjna |
Poland |
CID002511 |
Conformant |
|
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
China |
CID002512 |
Conformant |
|
Tungsten |
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
China |
CID002513 |
Conformant |
|
Gold |
Fidelity Printers and Refiners Ltd. |
Zimbabwe |
CID002515 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Singway Technology Co., Ltd. |
Taiwan, Province Of China |
CID002516 |
Non Conformant |
|
Tin |
O.M. Manufacturing Philippines, Inc. |
Philippines |
CID002517 |
Conformant |
|
Gold |
Shandong Humon Smelting Co., Ltd. |
China |
CID002525 |
Outreach Required |
|
Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
China |
CID002527 |
Outreach Required |
|
Tantalum |
KEMET de Mexico |
Mexico |
CID002539 |
Conformant |
|
Tungsten |
H.C. Starck Tungsten GmbH |
Germany |
CID002541 |
Conformant |
|
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
CID002542 |
Conformant |
|
Tungsten |
Masan High-Tech Materials |
Viet Nam |
CID002543 |
Conformant |
|
Tantalum |
TANIOBIS Co., Ltd. |
Thailand |
CID002544 |
Conformant |
|
Tantalum |
TANIOBIS GmbH |
Germany |
CID002545 |
Conformant |
|
Tantalum |
Materion Newton Inc. |
United States Of America |
CID002548 |
Conformant |
|
Tantalum |
TANIOBIS Japan Co., Ltd. |
Japan |
CID002549 |
Conformant |
|
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
Germany |
CID002550 |
Conformant |
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
China |
CID002551 |
Conformant |
|
Tantalum |
Global Advanced Metals Boyertown |
United States Of America |
CID002557 |
Conformant |
|
Tantalum |
Global Advanced Metals Aizu |
Japan |
CID002558 |
Conformant |
|
Gold |
Al Etihad Gold Refinery DMCC |
United Arab Emirates |
CID002560 |
Non Conformant |
|
Gold |
Emirates Gold DMCC |
United Arab Emirates |
CID002561 |
Non Conformant |
|
Gold |
International Precious Metal Refiners |
United Arab Emirates |
CID002562 |
Outreach Required |
|
Gold |
Kaloti Precious Metals |
United Arab Emirates |
CID002563 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Sudan Gold Refinery |
Sudan |
CID002567 |
Outreach Required |
|
Tin |
CV Ayi Jaya |
Indonesia |
CID002570 |
Conformant |
|
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Viet Nam |
CID002572 |
Non Conformant |
|
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Viet Nam |
CID002573 |
Outreach Required |
|
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
Viet Nam |
CID002574 |
Outreach Required |
|
Gold |
T.C.A S.p.A |
Italy |
CID002580 |
Conformant |
|
Gold |
REMONDIS PMR B.V. |
Netherlands |
CID002582 |
Conformant |
|
Gold |
Fujairah Gold FZC |
United Arab Emirates |
CID002584 |
Outreach Required |
|
Gold |
Industrial Refining Company |
Belgium |
CID002587 |
Non Conformant |
|
Gold |
Shirpur Gold Refinery Ltd. |
India |
CID002588 |
Outreach Required |
|
Tungsten |
Niagara Refining LLC |
United States Of America |
CID002589 |
Conformant |
|
Tin |
PT Rajehan Ariq |
Indonesia |
CID002593 |
Conformant |
|
Gold |
Korea Zinc Co., Ltd. |
Korea, Republic Of |
CID002605 |
Conformant |
|
Gold |
Marsam Metals |
Brazil |
CID002606 |
Non Conformant |
|
Gold |
TOO Tau-Ken-Altyn |
Kazakhstan |
CID002615 |
Conformant |
|
Tungsten |
China Molybdenum Tungsten Co., Ltd. |
China |
CID002641 |
Conformant |
|
Tungsten |
Hydrometallurg, JSC |
Russian Federation |
CID002649 |
RMI Due Diligence Review - Unable to Proceed |
|
Tin |
PT Cipta Persada Mulia |
Indonesia |
CID002696 |
Conformant |
|
Tin |
An Vinh Joint Stock Mineral Processing Company |
Viet Nam |
CID002703 |
Outreach Required |
|
Tin |
Resind Industria e Comercio Ltda. |
Brazil |
CID002706 |
Conformant |
|
Tantalum |
Resind Industria e Comercio Ltda. |
Brazil |
CID002707 |
Conformant |
|
Gold |
Abington Reldan Metals, LLC |
United States Of America |
CID002708 |
Conformant |
|
Tungsten |
Unecha Refractory metals plant |
Russian Federation |
CID002724 |
Non Conformant |
|
Gold |
Shenzhen CuiLu Gold Co., Ltd. |
China |
CID002750 |
Outreach Required |
|
Tin |
Super Ligas |
Brazil |
CID002756 |
Conformant |
|
Gold |
Albino Mountinho Lda. |
Portugal |
CID002760 |
Outreach Required |
|
Gold |
SAAMP |
France |
CID002761 |
Non Conformant |
|
Gold |
L'Orfebre S.A. |
Andorra |
CID002762 |
Conformant |
|
Gold |
8853 S.p.A. |
Italy |
CID002763 |
Non Conformant |
|
Gold |
Italpreziosi |
Italy |
CID002765 |
Conformant |
|
Tin |
Aurubis Beerse |
Belgium |
CID002773 |
Conformant |
|
Tin |
Aurubis Berango |
Spain |
CID002774 |
Conformant |
|
Tin |
PT Bangka Prima Tin |
Indonesia |
CID002776 |
Conformant |
|
Gold |
WIELAND Edelmetalle GmbH |
Germany |
CID002778 |
Conformant |
|
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
Austria |
CID002779 |
Conformant |
|
Tin |
PT Sukses Inti Makmur |
Indonesia |
CID002816 |
Conformant |
|
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
Philippines |
CID002827 |
Conformant |
|
Tungsten |
ACL Metais Eireli |
Brazil |
CID002833 |
Non Conformant |
|
Tin |
PT Menara Cipta Mulia |
Indonesia |
CID002835 |
Conformant |
|
Tantalum |
Jiangxi Tuohong New Raw Material |
China |
CID002842 |
Conformant |
|
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
China |
CID002844 |
Conformant |
|
Tungsten |
Moliren Ltd. |
Russian Federation |
CID002845 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
AU Traders and Refiners |
South Africa |
CID002850 |
Non Conformant |
|
Gold |
GGC Gujrat Gold Centre Pvt. Ltd. |
India |
CID002852 |
Non Conformant |
|
Gold |
Sai Refinery |
India |
CID002853 |
Outreach Required |
|
Gold |
Modeltech Sdn Bhd |
Malaysia |
CID002857 |
Non Conformant |
|
Tin |
Modeltech Sdn Bhd |
Malaysia |
CID002858 |
Non Conformant |
|
Gold |
Bangalore Refinery |
India |
CID002863 |
Active |
|
Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
Russian Federation |
CID002865 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
Germany |
CID002867 |
Outreach Required |
|
Gold |
Pease & Curren |
United States Of America |
CID002872 |
Communication Suspended - Not Interested |
|
Gold |
JALAN & Company |
India |
CID002893 |
Outreach Required |
|
Gold |
SungEel HiMetal Co., Ltd. |
Korea, Republic Of |
CID002918 |
Conformant |
|
Gold |
Planta Recuperadora de Metales SpA |
Chile |
CID002919 |
Conformant |
|
Gold |
ABC Refinery Pty Ltd. |
Australia |
CID002920 |
Outreach Required |
|
Gold |
Safimet S.p.A |
Italy |
CID002973 |
Non Conformant |
|
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
China |
CID003116 |
Conformant |
|
Gold |
State Research Institute Center for Physical Sciences and Technology |
Lithuania |
CID003153 |
Outreach Required |
|
Gold |
African Gold Refinery |
Uganda |
CID003185 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Gold Coast Refinery |
Ghana |
CID003186 |
Outreach Required |
|
Gold |
NH Recytech Company |
Korea, Republic Of |
CID003189 |
Conformant |
|
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
China |
CID003190 |
Conformant |
|
Tin |
PT Bangka Serumpun |
Indonesia |
CID003205 |
Conformant |
|
Tin |
Pongpipat Company Limited |
Myanmar |
CID003208 |
Outreach Required |
|
Gold |
QG Refining, LLC |
United States Of America |
CID003324 |
Outreach Required |
|
Tin |
Tin Technology & Refining |
United States Of America |
CID003325 |
Conformant |
|
Gold |
Dijllah Gold Refinery FZC |
United Arab Emirates |
CID003348 |
Outreach Required |
|
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
China |
CID003356 |
Non Conformant |
|
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
China |
CID003379 |
Non Conformant |
|
Tin |
PT Rajawali Rimba Perkasa |
Indonesia |
CID003381 |
Conformant |
|
Gold |
CGR Metalloys Pvt Ltd. |
India |
CID003382 |
Outreach Required |
|
Gold |
Sovereign Metals |
India |
CID003383 |
Outreach Required |
|
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
China |
CID003397 |
Conformant |
|
Tungsten |
Lianyou Metals Co., Ltd. |
Taiwan, Province Of China |
CID003407 |
Conformant |
|
Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
Russian Federation |
CID003408 |
RMI Due Diligence Review - Unable to Proceed |
|
Tin |
Precious Minerals and Smelting Limited |
India |
CID003409 |
Active |
|
Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. |
China |
CID003410 |
Outreach Required |
|
Tungsten |
NPP Tyazhmetprom LLC |
Russian Federation |
CID003416 |
RMI Due Diligence Review - Unable to Proceed |
|
Tungsten |
Hubei Green Tungsten Co., Ltd. |
China |
CID003417 |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. North Plant |
Japan |
CID003424 |
Conformant |
|
Gold |
Eco-System Recycling Co., Ltd. West Plant |
Japan |
CID003425 |
Conformant |
|
Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
Brazil |
CID003427 |
Non Conformant |
|
Tin |
PT Mitra Sukses Globalindo |
Indonesia |
CID003449 |
Conformant |
|
Gold |
Augmont Enterprises Private Limited |
India |
CID003461 |
Non Conformant |
|
Gold |
Kundan Care Products Ltd. |
India |
CID003463 |
Outreach Required |
|
Tungsten |
Cronimet Brasil Ltda |
Brazil |
CID003468 |
Conformant |
|
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Brazil |
CID003486 |
Conformant |
|
Gold |
Emerald Jewel Industry India Limited (Unit 1) |
India |
CID003487 |
Outreach Required |
|
Gold |
Emerald Jewel Industry India Limited (Unit 2) |
India |
CID003488 |
Outreach Required |
|
Gold |
Emerald Jewel Industry India Limited (Unit 3) |
India |
CID003489 |
Outreach Required |
|
Gold |
Emerald Jewel Industry India Limited (Unit 4) |
India |
CID003490 |
Outreach Required |
|
Gold |
K.A. Rasmussen |
Norway |
CID003497 |
Outreach Required |
|
Gold |
Alexy Metals |
United States Of America |
CID003500 |
Non Conformant |
|
Tin |
CRM Synergies |
Spain |
CID003524 |
Conformant |
|
Gold |
MD Overseas |
India |
CID003548 |
Outreach Required |
|
Tungsten |
Artek LLC |
Russian Federation |
CID003553 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
Metallix Refining Inc. |
United States Of America |
CID003557 |
Outreach Required |
|
Gold |
Metal Concentrators SA (Pty) Ltd. |
South Africa |
CID003575 |
Conformant |
|
Tin |
Fabrica Auricchio Industria e Comercio Ltda. |
Brazil |
CID003582 |
Conformant |
|
Tantalum |
RFH Yancheng Jinye New Material Technology Co., Ltd. |
China |
CID003583 |
Conformant |
|
Tungsten |
Fujian Xinlu Tungsten Co., Ltd. |
China |
CID003609 |
Conformant |
|
Tungsten |
OOO “Technolom” 2 |
Russian Federation |
CID003612 |
RMI Due Diligence Review - Unable to Proceed |
|
Tungsten |
OOO “Technolom” 1 |
Russian Federation |
CID003614 |
RMI Due Diligence Review - Unable to Proceed |
|
Gold |
WEEEREFINING |
France |
CID003615 |
Conformant |
|
Gold |
Gold by Gold Colombia |
Colombia |
CID003641 |
Conformant |
|
Tungsten |
LLC Vostok |
Russian Federation |
CID003643 |
RMI Due Diligence Review - Unable to Proceed |
|
Tungsten |
YUDU ANSHENG TUNGSTEN CO., LTD. |
China |
CID003662 |
Outreach Required |
|
Gold |
Dongwu Gold Group |
China |
CID003663 |
Outreach Required |
|
Tin |
DS Myanmar |
Myanmar |
CID003831 |
Conformant |
|
Tin |
PT Putera Sarana Shakti (PT PSS) |
Indonesia |
CID003868 |
Conformant |
|
Tantalum |
5D Production OU |
Estonia |
CID003926 |
Outreach Required |
|
Tungsten |
HANNAE FOR T Co., Ltd. |
Korea, Republic Of |
CID003978 |
Outreach Required |
|
Tungsten |
DONGKUK INDUSTRIES CO., LTD. |
Korea, Republic Of |
CID004060 |
Outreach Required |
|
Gold |
Sam Precious Metals |
United Arab Emirates |
CID003666 |
Outreach Required |
|
Gold |
Coimpa Industrial LTDA |
Brazil |
CID004010 |
Conformant |
|
Tin |
Mining Minerals Resources SARL |
Congo, Democratic Republic Of The |
CID004065 |
Conformant |
|
Tungsten |
Tungsten Vietnam Joint Stock Company |
Viet Nam |
CID003993 |
Conformant |
|
Tungsten |
Nam Viet Cromit Joint Stock Company |
Viet Nam |
CID004034 |
Outreach Required |
|
Tantalum |
PowerX Ltd. |
Rwanda |
CID004054 |
Conformant |
|
Tungsten |
Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
China |
CID004430 |
Conformant |