UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

 

FORM SD 

Specialized Disclosure Report

 

IntriCon Corporation 

(Exact name of registrant as specified in its charter) 

     
Pennsylvania 1-5005 23-1069060
(State or other jurisdiction of incorporation or organization) (Commission File Number) (IRS Employer Identification No.)
   
1260 Red Fox Road, Arden Hills, Minnesota 55112
(Address of principal executive offices) (Zip Code)
   
Scott Longval (651) 636-9770
(Name and telephone number, including area code, of the person to contact in connection with this report)

 

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

 

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period of January 1 to December 31, 2018.

 

 Page 1 of 17

 

 

 

Section 1 – Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Conflict Minerals Disclosure

 

This Form SD of IntriCon Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for calendar year 2018.

 

Through the reasonable country of origin inquiry described in its Conflict Minerals Report, some suppliers disclosed to the Company that recycled or scrap sources of Conflict Minerals were identified in their supply chains and did not require due diligence. This determination is discussed further in the Company’s Conflict Minerals Report.

 

A copy of the Company’s Conflict Minerals Report for calendar year 2018 is filed as Exhibit 1.01 to this Form SD. It is publicly available at https://investorrelations.intricon.com/sec-filings; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.

 

Item 1.02 Exhibits

 

As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

The following exhibit is filed as part of this report:

 

Exhibit 1.01— Conflict Minerals Report of IntriCon Corporation for calendar year 2018

 

 Page 2 of 17

 

 

 

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.

 

IntriCon Corporation
 
By: /s/ Scott Longval Date: May 30, 2019
Name: Scott Longval
Title: Executive Vice President, Chief Operating Officer and Chief Financial Officer

 

 Page 3 of 17

 

 

Exhibit 1.01

 

Conflict Minerals Report of IntriCon Corporation
in Accordance with Rule 13p-1 under the Securities Exchange Act of 1934

 

Explanatory Note

 

This is the Conflict Minerals Report (the “Report”) of IntriCon Corporation (the “Company”) for calendar year 2018 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “1934 Act”). Please refer to Rule 13p-1, Form SD, and the 1934 Act Release No. 34-67716 for definitions of the terms used in this Report, unless otherwise defined herein.

 

Rule 13p-1 requires disclosure of certain information when a company manufactures or contracts to manufacture products and any of the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The minerals specified in Rule 13p-1 are collectively referred to as Conflict Minerals. For purposes of Rule 13p-1 and the related disclosures, the term “Conflict Minerals” is defined to include: (A) columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to metallic forms of tin, tantalum and tungsten, or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The “Covered Countries” for the purposes of Rule 13p-1 and this Report are the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola. As described in this Report, Conflict Minerals are necessary to the functionality or production of certain of the Company’s products that the Company manufactures or contracts to manufacture.

 

Description of the Company and the Products Covered by this Report

 

The Company is an international company engaged in designing, developing, engineering, manufacturing and distributing body-worn devices. The Company serves the body-worn device market by designing, developing, engineering, manufacturing and distributing micro-miniature products, microelectronics, micro-mechanical assemblies, complete assemblies and software solutions, primarily for the emerging value-based hearing health market, the medical biotelemetry market and the professional audio communication market. Conflict Minerals are necessary to the functionality or production of certain of the Company’s products that the Company manufactured or contracted to manufacture and for which the manufacture was completed during calendar year 2018 (the “Covered Products”). The Covered Products include:

 

hearing aids and hearing aid components;

 

cardiac monitoring devices;

 

medical telecoils; and

 

professional audio devices and accessories.

 

 Page 4 of 17

 

 

 

The Company does not purchase ore or unrefined Conflict Minerals from mines and is many steps removed in the supply chain from the mining of Conflict Minerals. The Company purchases materials used in its products from a large network of suppliers. The Company must therefore rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in the Covered Products. Moreover, the Company believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals, and the Company has therefore requested suppliers take steps to identify the applicable smelters and refiners of Conflict Minerals in the Company’s Covered Products supply chain.

 

Reasonable Country of Origin Inquiry

 

The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) with respect to the Conflict Minerals included in the Covered Products. Such RCOI was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products originated in the Covered Countries or were from recycled or scrap sources.

 

The Company began the RCOI by (i) creating a list of part numbers of component parts that the Company utilizes in the Covered Products, and (ii) identifying the names of the suppliers from whom the Company obtained such parts. The list of suppliers was then provided to the Company’s third-party service provider for upload to their cloud-based compliance management system (“Compliance Management tool”) that allows the Company to store and manage supplier requests and documentation.

 

The service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Alliance, formerly the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative, the suppliers were surveyed on the sourcing of the Conflict Minerals identified in the Company’s products.

 

As part of the survey, suppliers were asked to complete the survey and were provided educational materials on how to complete the form. In completing the CMRT, each supplier was asked, among other questions; whether the products or components they supplied to the Company contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; to determine the smelter or mine origin or whether the Conflict Minerals were sourced from recycled or scrap sources. The service provider also followed up with suppliers that did not respond to the request to complete the CMRT. All communications were tracked and monitored by the service provider’s Compliance Management tool. Suppliers were asked to return a copy of the CMRT once completed via email, or to upload the CMRT directly to the service provider’s Compliance Management tool. All submitted CMRTs were automatically analyzed by the Compliance Management tool for completeness and internal consistency and against lists of known smelters and refiners. If information on the CMRT returned from a supplier appeared to be incomplete, incorrect, or not trustworthy, the supplier was contacted with a request to complete or correct the questionable information.

 

Through the RCOI, some of the Company’s suppliers disclosed that recycled or scrap sources of Conflict Minerals were identified in their supply chains and did not require due diligence. Based on the balance of the results of the RCOI, the Company could not definitively determine whether or not suppliers sourced Conflict Minerals from the Covered Countries. Therefore, the Company determined that there was reason to believe that some of the Conflict Minerals necessary for the functionality of the Covered Products may have originated in a Covered Country. Accordingly, it was necessary for the Company to exercise due diligence on the source and chain of custody of such Conflict Minerals.

 

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Design of Due Diligence Framework

 

The Company’s due diligence measures have been designed to conform, in all material respects, to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas: Third Edition.

 

Due Diligence Measures Performed by the Company

 

The due diligence measures the Company performed related to the Covered Products included, but were not limited to, the following:

 

The Company maintained an internal Conflict Minerals project team comprised of representatives from the Company’s corporate finance, quality and regulatory, and supply chain management departments to implement the Company’s Conflict Minerals due diligence.

 

The team reported to senior management on suppliers’ responses to the Company’s Conflict Minerals information requests.

 

The Company communicated its Conflict Minerals Policy to suppliers. A copy of the Company’s Conflict Minerals Policy is available at https://www.intricon.com/about-intricon/; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD. Contractual provisions which require that all products and materials sold to the Company do not include Conflict Minerals from the Covered Countries that benefit armed groups in the Covered Countries were included in applicable purchase orders and new or renewed supplier contracts.

 

The Company reviewed supplier risk ratings based on the responses provided within their completed CMRTs. In the situation where the Company becomes aware of a potential risk in the supply chain, where an item being purchased is believed to have been sourced from a smelter or refiner which is supporting armed conflict in the Covered Countries, the Company will explore sourcing alternatives for the item in question and take appropriate action.

 

Compared the smelters and refiners identified in the RCOI against the list of Compliant Smelters on the Responsible Minerals Initiative (RMI) website. The Company does not typically have a direct relationship with smelters and refiners, and therefore does not perform direct audits of such entities. Instead, reliance is on third party assurances and certifications such as from RMI’s Responsible Minerals Assurance Process.

 

This Report, which constitutes the Company’s annual report of due diligence efforts, has been filed with the SEC and is available on the Company’s website, at: https://investorrelations.intricon.com/sec-filings. The contents of that website are not incorporated by reference into, and are not otherwise a part of, this Form SD.

 

Appendix A contains a list of known smelters and refiners reported by the Company’s suppliers which may have been used to process the Conflict Minerals utilized in the Covered Products. Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to those Covered Products purchased from its suppliers to determine the country of origin of the Conflict Minerals in all Covered Products. At the same time, the Company received no information from its suppliers indicating that the Conflict Minerals in the Company’s Covered Products directly or indirectly financed or benefitted armed groups in the Covered Countries. Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the RMI. Many supplier responses were provided at the company level, therefore, Appendix B may contain more countries than the Covered Products are being sourced from.

 

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Inherent Limitations on Due Diligence Measures

 

As a downstream purchaser of Conflict Minerals, the Company’s efforts undertaken to identify the source and chain of custody of Conflict Minerals in its products can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. The Company’s process relies on data obtained directly from suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.

 

Steps to be Taken to Mitigate Risk

 

The Company expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries:

 

The Company will continue to work closely with its third party conflict minerals service provider to obtain CMRTs on a product-specific basis to enable it to determine which smelters and refiners actually process Conflict Minerals contained in the Company’s products.

The Company will continue to provide its suppliers with information and training resources regarding responsible sourcing of Conflict Minerals.

The Company will continue to encourage its suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.

The Company will continue to include contractual provisions in supplier contracts, as well as in each purchase order issued, regarding products and materials sold to the Company not including Conflict Minerals from the Covered Countries that benefit armed groups in the Covered Countries.

 

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APPENDIX A 

SMELTERS AND REFINERS

 

Set forth below are known smelters and refiners reported by the Company’s suppliers which may have been used to process Conflict Minerals in the Covered Products. It is difficult to confirm the accuracy of information that was collected and transmitted through many levels of the supply chain for the Covered Products. In some cases information was provided to the Company for the entire supply chain of a supplier, and was not necessarily limited to facilities that have been confirmed to contribute necessary Conflict Minerals to a Covered Product. Accordingly, the Company has been unable to definitively link the identified smelters and refiners to only those products/materials in its supply chain; therefore, the following smelter and refiner list likely contains more processing facilities than are actually in the Company’s supply chain or Covered Products. As the Company’s engagement with its supply chain evolves, the list of facilities may change to reflect improvements in the quality of information provided.

 

Metal Standard Smelter Name
Gold Abington Reldan Metals, LLC
Gold Advanced Chemical Company
Gold African Gold Refinery
Gold Aida Chemical Industries Co., Ltd.
Gold Al Etihad Gold LLC
Gold Allgemeine Gold-und Silberscheideanstalt A.G.
Gold Almalyk Mining and Metallurgical Complex (AMMC)
Gold AngloGold Ashanti Córrego do Sítio Mineração
Gold Argor-Heraeus S.A.
Gold Asahi Pretec Corp.
Gold Asahi Refining Canada Ltd.
Gold Asahi Refining USA Inc.
Gold Asaka Riken Co., Ltd.
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold AU Traders and Refiners
Gold Aurubis AG
Gold Bangalore Refinery
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold Boliden AB
Gold C. Hafner GmbH + Co. KG
Gold Caridad
Gold CCR Refinery - Glencore Canada Corporation
Gold Cendres + Métaux S.A.
Gold Chimet S.p.A.
Gold Chugai Mining

 

 Page 8 of 17

 

 

 

Metal Standard Smelter Name
Gold Daejin Indus Co., Ltd.
Gold Daye Non-Ferrous Metals Mining Ltd.
Gold Degussa Sonne / Mond Goldhandel GmbH
Gold DODUCO Contacts and Refining GmbH
Gold Dowa
Gold DS PRETECH Co., Ltd.
Gold DSC (Do Sung Corporation)
Gold Eco-System Recycling Co., Ltd.
Gold Emirates Gold DMCC
Gold Fidelity Printers and Refiners Ltd.
Gold GCC Gujrat Gold Centre Pvt. Ltd.
Gold Geib Refining Corporation
Gold Gold Refinery of Zijin Mining Group Co., Ltd.
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Guangdong Jinding Gold Limited
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd.
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold HeeSung
Gold Heimerle + Meule GmbH
Gold Heraeus Metals Hong Kong Ltd.
Gold Heraeus Precious Metals GmbH & Co. KG
Gold Hunan Chenzhou Mining Co., Ltd.
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold Hwasung CJ Co., Ltd.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold Ishifuku Metal Industry Co., Ltd.
Gold Istanbul Gold Refinery
Gold Italpreziosi
Gold Japan Mint
Gold Jiangxi Copper Co., Ltd.
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant
Gold JSC Uralelectromed
Gold JX Nippon Mining & Metals Co., Ltd.
Gold Kaloti Precious Metals
Gold Kazakhmys Smelting LLC
Gold Kazzinc
Gold Kennecott Utah Copper LLC

 

 Page 9 of 17

 

 

 

Metal Standard Smelter Name
Gold KGHM Polska Miedz Spolka Akcyjna
Gold Kojima Chemicals Co., Ltd.
Gold Korea Zinc Co., Ltd.
Gold Kyrgyzaltyn JSC
Gold Kyshtym Copper-Electrolytic Plant ZAO
Gold L’azurde Company For Jewelry
Gold Lingbao Gold Co., Ltd.
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd.
Gold L’Orfebre S.A.
Gold LS-NIKKO Copper Inc.
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
Gold Marsam Metals
Gold Materion
Gold Matsuda Sangyo Co., Ltd.
Gold Metalor Technologies (Hong Kong) Ltd.
Gold Metalor Technologies (Singapore) Pte., Ltd.
Gold Metalor Technologies (Suzhou) Ltd.
Gold Metalor Technologies S.A.
Gold Metalor USA Refining Corporation
Gold Metalúrgica Met-Mex Peñoles S.A. De C.V.
Gold Mitsubishi Materials Corporation
Gold Mitsui Mining and Smelting Co., Ltd.
Gold MMTC-PAMP India Pvt., Ltd.
Gold Modeltech Sdn Bhd
Gold Morris and Watson
Gold Morris and Watson Gold Coast
Gold Moscow Special Alloys Processing Plant
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş.
Gold Navoi Mining and Metallurgical Combinat
Gold NH Recytech Company
Gold Nihon Material Co., Ltd.
Gold Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
Gold Ohura Precious Metal Industry Co., Ltd.
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
Gold OJSC Novosibirsk Refinery
Gold PAMP S.A.

 

 Page 10 of 17

 

 

 

Metal Standard Smelter Name
Gold Pease & Curren
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold Planta Recuperadora de Metales SpA
Gold Prioksky Plant of Non-Ferrous Metals
Gold PT Aneka Tambang (Persero) Tbk
Gold PX Précinox S.A.
Gold QG Refining, LLC
Gold Rand Refinery (Pty) Ltd.
Gold Refinery of Seemine Gold Co., Ltd.
Gold Remondis Argentia B.V.
Gold Republic Metals Corporation
Gold Royal Canadian Mint
Gold SAAMP
Gold Sabin Metal Corp.
Gold Safimet S.p.A
Gold SAFINA A.S.
Gold Sai Refinery
Gold Samduck Precious Metals
Gold SAMWON Metals Corp.
Gold SAXONIA Edelmetalle GmbH
Gold SEMPSA Joyería Platería S.A.
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold Sichuan Tianze Precious Metals Co., Ltd.
Gold Singway Technology Co., Ltd.
Gold SOE Shyolkovsky Factory of Secondary Precious Metals
Gold Solar Applied Materials Technology Corp.
Gold State Research Institute Center for Physical Sciences and Technology
Gold Sudan Gold Refinery
Gold Sumitomo Metal Mining Co., Ltd.
Gold SungEel HiTech
Gold T.C.A S.p.A
Gold Tanaka Kikinzoku Kogyo K.K.
Gold The Refinery of Shandong Gold Mining Co., Ltd.
Gold Tokuriki Honten Co., Ltd.
Gold Tongling Nonferrous Metals Group Co., Ltd.
Gold Tony Goetz NV

 

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Metal Standard Smelter Name
Gold TOO Tau-Ken-Altyn
Gold Torecom
Gold Umicore Brasil Ltda.
Gold Umicore Precious Metals Thailand
Gold Umicore S.A. Business Unit Precious Metals Refining
Gold United Precious Metal Refining, Inc.
Gold Universal Precious Metals Refining Zambia
Gold Valcambi S.A.
Gold Western Australian Mint trading as The Perth Mint
Gold WIELAND Edelmetalle GmbH
Gold Yamamoto Precious Metal Co., Ltd.
Gold Yokohama Metal Co., Ltd.
Gold Yunnan Copper Industry Co., Ltd.
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Tantalum Asaka Riken Co., Ltd.
Tantalum Changsha South Tantalum Niobium Co., Ltd.
Tantalum D Block Metals, LLC
Tantalum Exotech Inc.
Tantalum F&X Electro-Materials Ltd.
Tantalum FIR Metals & Resource Ltd.
Tantalum Global Advanced Metals Aizu
Tantalum Global Advanced Metals Boyertown
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum Guangdong Zhiyuan New Material Co., Ltd.
Tantalum H.C. Starck Co., Ltd.
Tantalum H.C. Starck Hermsdorf GmbH
Tantalum H.C. Starck Inc.
Tantalum H.C. Starck Ltd.
Tantalum H.C. Starck Smelting GmbH & Co. KG
Tantalum H.C. Starck Tantalum and Niobium GmbH
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum Jiangxi Tuohong New Raw Material
Tantalum Jiujiang Janny New Material Co., Ltd.
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum Jiujiang Tanbre Co., Ltd.
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

 

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Metal Standard Smelter Name
Tantalum KEMET Blue Metals
Tantalum KEMET Blue Powder
Tantalum LSM Brasil S.A.
Tantalum Metallurgical Products India Pvt., Ltd.
Tantalum Mineracao Taboca S.A.
Tantalum Mitsui Mining and Smelting Co., Ltd.
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum NPM Silmet AS
Tantalum Power Resources Ltd.
Tantalum QuantumClean
Tantalum Resind Industria e Comercio Ltda.
Tantalum RFH Tantalum Smeltry Co., Ltd.
Tantalum Solikamsk Magnesium Works OAO
Tantalum Taki Chemicals
Tantalum Telex Metals
Tantalum Ulba Metallurgical Plant JSC
Tantalum XinXing HaoRong Electronic Material Co., Ltd.
Tin Alpha
Tin An Vinh Joint Stock Mineral Processing Company
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin Chifeng Dajingzi Tin Industry Co., Ltd.
Tin China Tin Group Co., Ltd.
Tin CV Ayi Jaya
Tin CV Dua Sekawan
Tin CV Gita Pesona
Tin CV Tiga Sekawan
Tin CV United Smelting
Tin CV Venus Inti Perkasa
Tin Dowa
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin EM Vinto
Tin Estanho de Rondônia S.A.
Tin Fenix Metals
Tin Gejiu Fengming Metallurgy Chemical Plant
Tin Gejiu Kai Meng Industry and Trade LLC
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd.

 

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Metal Standard Smelter Name
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin Guangdong Hanhe Non-ferrous Metal Limited Company
Tin Guanyang Guida Nonferrous Metal Smelting Plant
Tin HuiChang Hill Tin Industry Co., Ltd.
Tin Huichang Jinshunda Tin Co., Ltd.
Tin Jiangxi New Nanshan Technology Ltd.
Tin Magnu’s Minerais Metais e Ligas Ltda.
Tin Malaysia Smelting Corporation (MSC)
Tin Melt Metais e Ligas S.A.
Tin Metallic Resources, Inc.
Tin Metallo Belgium N.V.
Tin Metallo Spain S.L.U.
Tin Mineracao Taboca S.A.
Tin Minsur
Tin Mitsubishi Materials Corporation
Tin Modeltech Sdn Bhd
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin O.M. Manufacturing (Thailand) Co., Ltd.
Tin O.M. Manufacturing Philippines, Inc.
Tin Operaciones Metalurgical S.A.
Tin Pongpipat Company Limited
Tin PT Aries Kencana Sejahtera
Tin PT Artha Cipta Langgeng
Tin PT ATD Makmur Mandiri Jaya
Tin PT Babel Inti Perkasa
Tin PT Babel Surya Alam Lestari
Tin PT Bangka Prima Tin
Tin PT Bangka Serumpun
Tin PT Bangka Tin Industry
Tin PT Belitung Industri Sejahtera
Tin PT Bukit Timah
Tin PT DS Jaya Abadi
Tin PT Inti Stania Prima
Tin PT Karimun Mining
Tin PT Kijang Jaya Mandiri
Tin PT Menara Cipta Mulia

 

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Metal Standard Smelter Name
Tin PT Mitra Stania Prima
Tin PT Panca Mega Persada
Tin PT Premium Tin Indonesia
Tin PT Prima Timah Utama
Tin PT Refined Bangka Tin
Tin PT Sariwiguna Binasentosa
Tin PT Stanindo Inti Perkasa
Tin PT Sukses Inti Makmur
Tin PT Sumber Jaya Indah
Tin PT Timah (Persero) Tbk Kundur
Tin PT Timah (Persero) Tbk Mentok
Tin PT Tinindo Inter Nusa
Tin PT Tirus Putra Mandiri
Tin PT Tommy Utama
Tin Resind Industria e Comercio Ltda.
Tin Rui Da Hung
Tin Soft Metais Ltda.
Tin Super Ligas
Tin Thaisarco
Tin Tin Technology & Refining
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company
Tin White Solder Metalurgia e Mineração Ltda.
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin Yunnan Tin Company Limited
Tungsten A.L.M.T. TUNGSTEN Corp.
Tungsten ACL Metais Eireli
Tungsten Asia Tungsten Products Vietnam Ltd.
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd.
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten Fujian Jinxin Tungsten Co., Ltd.
Tungsten Ganzhou Haichuang Tungsten Co., Ltd.
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd.
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten Ganzhou Yatai Tungsten Co., Ltd.
Tungsten Global Tungsten & Powders Corp.
Tungsten Guangdong Xianglu Tungsten Co., Ltd.

 

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Metal Standard Smelter Name
Tungsten H.C. Starck Smelting GmbH & Co.KG
Tungsten H.C. Starck Tungsten GmbH
Tungsten Hunan Chenzhou Mining Co., Ltd.
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd.
Tungsten Hunan Litian Tungsten Industry Co., Ltd.
Tungsten Hydrometallurg, JSC
Tungsten Japan New Metals Co., Ltd.
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten Jiangxi Dayu Longxintai Tungsten Co., Ltd.
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten Kennametal Fallon
Tungsten Kennametal Huntsville
Tungsten Malipo Haiyu Tungsten Co., Ltd.
Tungsten Moliren Ltd
Tungsten Niagara Refining LLC
Tungsten Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
Tungsten Philippine Chuangxin Industrial Co., Inc.
Tungsten South-East Nonferrous Metal Company Limited of Hengyang City
Tungsten Tejing (Vietnam) Tungsten Co., Ltd.
Tungsten Unecha Refractory metals plant
Tungsten Wolfram Bergbau und Hütten AG
Tungsten Woltech Korea Co., Ltd.
Tungsten Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten Xiamen Tungsten Co., Ltd.
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd.

 

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APPENDIX B

 

Countries of Origin

 

Below is an aggregated list of countries of origin, to the extent known, from which the smelters and refiners listed in Annex A are believed to have sourced conflict minerals, based on data available from RMI as of May 07, 2019. 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 list is derived from company level responses from some our suppliers and therefore, it is not certain which of these countries of origin can be linked to the Covered 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.

 

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