Exhibit 1.01
Vista Outdoor Inc.
Conflict Minerals Report
For the reporting period from January 1, 2015 to December 31, 2015
This report (the “Report”) of Vista Outdoor Inc. (together with our consolidated subsidiaries, “Vista Outdoor,” “we,” “our,” and “us”), for the year ended December 31, 2015 is presented to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), which require public companies, including Vista Outdoor, to provide certain disclosures about conflict minerals that are necessary to the functionality or production of a product manufactured or contracted to be manufactured by the company. These rules require that, if we have reason to believe that any of the conflict minerals in our supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, the “Covered Countries”) and are not solely from scrap or recycled sources, we must conduct due diligence on the source and chain of custody of such conflict minerals. “Conflict minerals,” or “3TG,” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten.
This Conflict Minerals Report describes the measures we have taken to exercise due diligence on the source and chain of custody of the conflict minerals contained in our products manufactured during the 2015 calendar year (the “Reporting Period”).
I. | Company and Product Overview |
Vista Outdoor Inc. is a leading global designer, manufacturer and marketer of consumer products in the growing outdoor sports and recreation markets. Vista Outdoor is a world leader with key brands in outdoor recreation and shooting sports products including: centerfire and rimfire rifles, shotguns, range systems, primers, binoculars, golf rangefinders, rifle scopes, trial cameras, gun care products, reloading equipment, tactical accessories, archery accessories, hunting decoys, and game calls. Vista Outdoor is headquartered in Utah and has manufacturing operations and facilities in 10 U.S. States, Canada, Mexico and Puerto Rico along with international sales and sourcing operations in Asia, Australia, Canada, Europe, and New Zealand.
On February 9, 2015, Vista Outdoor was formed when Alliant Techsystems Inc. (now known as Orbital ATK, Inc.) completed the spin-off of its Sporting Group reporting segment into Vista Outdoor. Therefore, information regarding the Reporting Period prior to February 9, 2015, refers to the Sporting Group reporting segment of Alliant Techsystems Inc.
Certain Vista Outdoor products (“Covered Products”) contain materials and components that use 3TG. Due to the depth of the supply chain, we are far removed from the mining of 3TG ores and the smelters/refiners that process those ores; the efforts we undertook to identify the countries of origin of those ores reflect our circumstances and downstream position in the supply chain. Further, the amount of information available globally on the traceability and sourcing of these ores is limited at this time, and this situation is not unique to us. We have taken steps to identify the applicable smelters and refiners of 3TG in our supply chain; however, we believe that the smelters and
refiners of the 3TG contained in the Covered Products are best situated to identify the sources and countries of origin of the 3TG metals they use. We rely on our suppliers to provide us with information on the origin of any conflict minerals contained in components and materials supplied to us.
II. | Reasonable Country of Origin Inquiry |
Our conflict minerals due diligence process began with a reasonable country of origin inquiry (“RCOI”) for all conflict minerals known to be contained in products that we manufactured or contracted to be manufactured during the Reporting Period. To implement the RCOI, the companies that provide relevant parts, materials and finished goods directly to Vista Outdoor (our “first tier suppliers”) were engaged to collect information regarding the presence and sourcing of conflict minerals used in those products. Information was collected, stored and evaluated largely using an online platform provided by a third party vendor.
Our supplier engagement included the following steps:
• | An introductory email was sent to all of our first tier suppliers and those of our licensees (hereinafter, collectively referred to as “suppliers”) describing our Conflict Minerals Compliance Program and requesting information concerning the presence of conflict minerals in the supplier’s products. |
• | Following that introductory email, a subsequent email was sent to suppliers containing registration information and a survey request link for the online data collection platform, which utilized the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict Free Sourcing Initiative (the “CFSI”). |
• | Our suppliers also were provided access to a Conflict Minerals Supplier Resource Center (https://conflictmineralsresources.com) sponsored by the third party vendor as an educational tool to facilitate a deeper understanding of our Conflict Minerals Compliance Program, supporting regulation and frequently asked questions concerning conflict minerals tracing. |
• | Up to five additional reminder emails were sent to any non-responsive supplier from whom we requested survey completion. |
• | Suppliers who remained non-responsive to email reminders were contacted by telephone and offered assistance. This assistance included, but was not limited to, providing further information about our Conflict Minerals Compliance Program, explaining why the information was being collected, explaining how the information would be used and clarifying how the needed information could be provided. |
The third party vendor assisted in evaluating supplier responses for plausibility, consistency and gaps, both in terms of information on the products that were stated to contain or not contain necessary conflict minerals and information on the origin of those conflict minerals. The third party vendor also followed up with suppliers to address issues including implausible statements regarding the presence of conflict minerals, incomplete data on CMRTs, responses that did not identify smelters or refiners (“SORs”) and responses that indicated sourcing location without complete supporting information from the supply chain.
A total of 425 suppliers were contacted as part of our RCOI process. The response rate among these suppliers was 49%. Of these responding suppliers, 30% indicated that certain components they produce contain one or more conflict minerals.
We believe our RCOI process was reasonably designed and performed in good faith, but there are inherent limitations in the information provided to us by third parties, including the possibility of information being inaccurate, incomplete or falsified despite our efforts to validate and confirm the information. The Company does not purchase Conflict Minerals directly from SORs and, therefore, must rely on its suppliers to provide information regarding the origin of the Conflict Minerals that are included in the Covered Products. Based on the results of our RCOI, which indicated that one or more of our product components contained conflict minerals that may have originated in the Covered Countries and may not be from recycled or scrap sources, we exercised due diligence on the source and chain of custody of those conflict minerals as described below.
III. | Due Diligence Measures Performed by Vista Outdoor |
We designed our conflict minerals due diligence process to conform, in all material respects, with the Organization for Economic Cooperation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum and Tungsten and on Gold (the “OECD Guidance”). The design of our due diligence process took into account the recommendations of the OECD Guidance for “downstream” companies (those entities in the minerals supply chain from the SORs to retailers).
In accordance with the OECD Guidance, our due diligence measures included the following:
Establishing Strong Company Management Systems
• | We maintain a multi-disciplinary internal team to implement our due diligence measures. Our Conflict Minerals project team is headed by our Supply Chain Council, consisting of supply chain leadership, and includes other members of our supply chain, engineering, finance and legal departments. The team met regularly to discuss the due diligence process and progress. We also engaged a third party vendor to support our conflict minerals program. |
• | We have adopted a Conflict Minerals Policy, which details the standards by which our supply chain due diligence will be conducted. We communicated the Conflict Minerals Policy to our direct suppliers. |
• | We employ a system of controls and transparency over our mineral supply chain through the use of the due diligence tools developed by the CFSI, including the CMRT, which is designed to identify the smelters and refiners that process the conflict minerals in a company’s supply chain. |
• | We maintain a company-level grievance mechanism, as described in our Code of Business Ethics, which enables employees and others to report concerns. |
Identifying and Assessing Risk in Our Supply Chain
• | For the Reporting Period, we identified and assessed risks in our supply chain through engagement with suppliers as discussed in Section II of this Report, including through the CMRT survey process and by evaluating suppliers’ responses to the CMRT. |
Designing and Implementing a Strategy to Respond to Supply Chain Risks
• | In order to assess the due diligence practices of the SORs reported to us by suppliers that were known or reasonably believed to have sourced from a Covered Country or that had unknown sourcing, the third party vendor attempted to match each SOR on the list to available lists of SORs that have been certified, or are in the process of being certified, by internationally recognized third party audit programs, such as the CFSI’s |
Conflict-Free Smelter Program, the London Bullion Market Association Good Delivery Program and the Responsible Jewellery Council Chain of Custody Certification program.
• | If the SOR is not certified by any of these internationally recognized programs, the third party vendor attempted to contact the SOR to gain more information about the SOR’s sourcing practices, including countries of origin, as well as whether the SOR uses any internal due diligence procedures or other processes to track the chain of custody of its mineral ores. In addition, Internet research was also performed to determine whether there are any additional sources of information regarding the SOR’s sourcing practices. |
• | We are in the process of developing a risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries. |
• | The Conflict Minerals project team reports to senior management on the status of our survey and due diligence processes. |
Carrying out Independent Third-Party Audits of Supply Chain Due Diligence
• | We do not have direct relationships with SORs and we do not perform direct audits of SORs’ supply chains for conflict minerals. However, we support the development and implementation of, and SORs’ participation in, independent third-party audits of SORs’ sourcing practices, such as the CFSI’s Conflict-Free Smelter Program. |
Reporting on Supply Chain Due Diligence
• | As indicated in the Form SD, this Report is publicly available on our website at http://vistaoutdoor.com/social-responsibility/. |
IV. | Smelters or Refiners and Country of Origin of Conflict Minerals |
Based on our due diligence efforts, we do not have conclusive information regarding the country of origin of, or SORs used to process, the necessary conflict minerals in the Covered Products for the Reporting Period. Annex A below includes a list of the SORs that our suppliers reported as being in their supply chains, as well as an aggregated list of the countries of origin from which we believe the reported SORs collectively source conflict minerals, based on our review data from several sources, including information provided by suppliers and information third party vendor has obtained through engagement with SORs. In many cases, the SOR information provided to us by our suppliers was produced at a company or divisional level based on all of their products as a whole, rather than being limited to the specific products supplied to Vista Outdoor. In addition, many of the supplier responses were incomplete as all minerals supply chain participants continue to map their upstream supply chains. As a result, we are unable to determine whether all of the SORs listed below actually processed conflict minerals used in the Covered Products for the Reporting Period.
Our efforts to determine the mine or location of origin of the conflict minerals in the Covered Products with the greatest possible specificity consisted of the due diligence measures described in this Report, including our efforts to seek information from suppliers using the CMRT.
V. | Future Measures to Mitigate Risk |
We continue to evaluate our supplier relationships to promote compliance with our Conflict Minerals Policy and mitigate the risk that the conflict minerals contained in our products could benefit armed groups in the Covered Countries. We are committed to continuously improving our supply chain due diligence efforts using the following measures:
• | Continuing to assess the presence of conflict minerals in our supply chain; |
• | Continuing to communicate expectations to our suppliers with regard to sourcing of conflict minerals, supplier performance, and transparency; |
• | Continuing engagement with suppliers and working to increase the response rate to the CMRT; |
• | Continuing to develop our risk management plan to assist us in evaluating supplier relationships and avoiding the use of conflict minerals which could directly or indirectly finance or benefit armed groups in the Covered Countries; |
• | Working to establish a system of controls and transparency over our mineral supply chain through our work with our third party vendor; |
• | Implementing internal measures to strengthen our engagement with suppliers on these issues; and |
• | Continuing to compare RCOI results to information collected through independent conflict free smelter validation programs such as the CFSI Conflict Free Smelter Program. |
Annex A
Gold | Advanced Chemical Company |
Gold | Aida Chemical Industries Co., Ltd.* |
Gold | Aktyubinsk Copper Company TOO |
Gold | Al Etihad Gold |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* |
Gold | Almalyk Mining and Metallurgical Complex (AMMC)* |
Gold | AngloGold Ashanti Córrego do Sítio Mineração* |
Gold | Argor-Heraeus SA |
Gold | Asahi Pretec Corporation |
Gold | Asahi Refining Canada Limited* |
Gold | Asahi Refining USA Inc.* |
Gold | Asaka Riken Co., Ltd.* |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Gold | Aurubis AG* |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* |
Gold | Bauer Walser AG |
Gold | BHP Billiton |
Gold | Boliden AB* |
Gold | C. Hafner GmbH + Co. KG* |
Gold | Caridad |
Gold | CCR Refinery - Glencore Canada Corporation* |
Gold | Cendres + Métaux SA |
Gold | Chimet S.p.A.* |
Gold | China Nonferrous Metal Mining (Group) Co., Ltd. |
Gold | Chugai Mining |
Gold | Codelco |
Gold | Daejin Indus Co., Ltd. |
Gold | Daye Non-Ferrous Metals Mining Ltd. |
Gold | DODUCO GmbH* |
Gold, Tin | Dowa |
Gold | DSC (Do Sung Corporation) |
Gold | Eco-System Recycling Co., Ltd.* |
Gold | Eldorado Gold Corporation |
Gold | Elemetal Refining, LLC* |
Gold | Emirates Gold DMCC |
Gold | ESG Edelmetall-Service GmbH & Co. KG |
Gold | Faggi Enrico S.p.A. |
Gold | Fidelity Printers and Refiners Ltd. |
Gold | Gannon & Scott |
Gold | Gansu Seemine Material Hi-Tech Co Ltd |
Gold | Geib Refining Corporation |
Gold | Guangdong Jinding Gold Limited |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
Gold | Heimerle + Meule GmbH* |
Gold | Heraeus Ltd. Hong Kong* |
Gold | Heraeus Precious Metals GmbH & Co. KG* |
Gold | House of Currency of Brazil (Casa da Moeda do Brazil) |
Gold, Tin | Huichang Jinshunda Tin Co. Ltd |
Gold, Tungsten | Hunan Chenzhou Mining Co., Ltd. |
Gold | Hwasung CJ Co. Ltd |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited* |
Gold, Tantalum | Ishifuku Metal Industry Co., Ltd. |
Gold | Istanbul Gold Refinery* |
Gold | Japan Mint* |
Gold, Tin | Jiangxi Copper Company Limited |
Gold | Jinlong Copper Co., Ltd. |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant* |
Gold | JSC Uralelectromed* |
Gold, Tantalum, Tin | JX Nippon Mining & Metals Co., Ltd. |
Gold | Kaloti Precious Metals |
Gold | Kazakhmys plc |
Gold | Kazzinc* |
Gold | Kennecott Utah Copper LLC* |
Gold | KGHM Polska Miedź Spółka Akcyjna |
Gold | Kojima Chemicals Co., Ltd.* |
Gold | Korea Metal Co. Ltd |
Gold | Korea Zinc Co. Ltd. |
Gold | Kyrgyzaltyn JSC* |
Gold | L' azurde Company For Jewelry |
Gold | Laizhou Gold Co. |
Gold | Lingbao Gold Company Ltd. |
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. |
Gold | LS-NIKKO Copper Inc.* |
Gold | Luo yang Zijin Yinhui Metal Smelt Co Ltd |
Gold | Materion* |
Gold | Matsuda Sangyo Co., Ltd.* |
Gold, Tin | Metallic Resources, Inc. |
Gold | Metalor Technologies (Hong Kong) Ltd.* |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* |
Gold | Metalor Technologies (Suzhou) Co Ltd |
Gold, Tin | Metalor Technologies SA |
Gold | Metalor USA Refining Corporation* |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V* |
Gold, Tin | Mitsubishi Materials Corporation* |
Gold, Tantalum, Tin | Mitsui Mining & Smelting |
Gold | MMTC-PAMP India Pvt., Ltd.* |
Gold | Morris and Watson |
Gold | Moscow Special Alloys Processing Plant* |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş.* |
Gold | Navoi Mining and Metallurgical Combinat* |
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 Kolyma Refinery |
Gold | OJSC Novosibirsk Refinery* |
Gold | PAMP SA* |
Gold | Penglai Penggang Gold Industry Co Ltd |
Gold | Prioksky Plant of Non-Ferrous Metals* |
Gold | PT Aneka Tambang (Persero) Tbk* |
Gold | PX PrŽcinox SA* |
Gold | Rand Refinery (Pty) Ltd.* |
Gold | Republic Metals Corporation* |
Gold | Royal Canadian Mint* |
Gold | Sabin Metal Corp. |
Gold | Samduck Precious Metals |
Gold | SAMWON METALS Corp. |
Gold | SAXONIA Edelmetalle GmbH |
Gold | Schone Edelmetaal B.V.* |
Gold | SEMPSA Joyería Platería SA* |
Gold | Shandong Gold Mining Co., Ltd. |
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 | So Accurate Group, Inc. |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* |
Gold | Solar Applied Materials Technology Corp.* |
Gold | Sudan Gold Refinery |
Gold, Tin | Sumitomo Metal Mining Co., Ltd. |
Gold | Super Dragon Technology Co., Ltd. |
Gold | T.C.A S.p.A* |
Gold | Tanaka Kikinzoku Kogyo K.K.* |
Gold | The Great Wall Gold and Silver Refinery of China* |
Gold | The Refinery of Shandong Gold Mining Co., Ltd.* |
Gold | Tokuriki Honten Co., Ltd.* |
Gold | TongLing Nonferrous Metals Group Holdings Co., Ltd. |
Gold | Torecom |
Gold | Umicore Brasil Ltda.* |
Gold | Umicore Precious Metals Thailand* |
Gold, Tin | Umicore SA Business Unit Precious Metals Refining |
Gold | United Precious Metal Refining, Inc.* |
Gold | Valcambi SA* |
Gold | Western Australian Mint trading as The Perth Mint* |
Gold | WIELAND Edelmetalle GmbH |
Gold | Yamamoto Precious Metal Co., Ltd.* |
Gold | Yantai Guodasafina High-tech Environmental Refinery CO., Ltd. |
Gold | Yokohama Metal Co., Ltd.* |
Gold | Yunnan Copper Industry Co Ltd |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery* |
Tantalum | AMG Advanced Metallurgical Group |
Tantalum | Avon Specialty Metals Ltd |
Tantalum | Changsha South Tantalum Niobium Co., Ltd.* |
Tantalum | Conghua Tantalum and Niobium Smeltry* |
Tantalum | D Block Metals, LLC* |
Tantalum | Duoluoshan* |
Tantalum | Exotech Inc.* |
Tantalum | F&X Electro-Materials Ltd.* |
Tantalum | FIR Metals & Resource Ltd.* |
Tantalum, Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
Tantalum | Global Advanced Metals Aizu* |
Tantalum | Global Advanced Metals Boyertown* |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch |
Tantalum | H.C. Starck Co., Ltd.* |
Tantalum | H.C. Starck GmbH Goslar* |
Tantalum | H.C. Starck GmbH Laufenburg* |
Tantalum | H.C. Starck Hermsdorf GmbH* |
Tantalum | H.C. Starck Inc.* |
Tantalum | H.C. Starck Ltd.* |
Tantalum, Tungsten | H.C. Starck Smelting GmbH & Co. KG* |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* |
Tantalum | Hi-Temp Specialty Metals, Inc.* |
Tantalum, Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd* |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* |
Tantalum | Jiujiang Tanbre Co., Ltd.* |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* |
Tantalum | KEMET Blue Metals* |
Tantalum | Kemet Blue Powder* |
Tantalum | King-Tan Tantalum Industry Ltd.* |
Tantalum | LSM Brasil S.A.* |
Tantalum | Metallurgical Products India Pvt., Ltd.* |
Tantalum, Tin | Mineração Taboca S.A. |
Tantalum | Molycorp Silmet A.S.* |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* |
Tantalum | Plansee SE Liezen* |
Tantalum | Plansee SE Reutte* |
Tantalum | QuantumClean* |
Tantalum, Tin | Resind Indústria e Comércio Ltda. |
Tantalum | RFH Tantalum Smeltry Co., Ltd.* |
Tantalum | Solikamsk Magnesium Works OAO* |
Tantalum | Taki Chemicals* |
Tantalum | Telex Metals* |
Tantalum | Tranzact, Inc.* |
Tantalum | Ulba Metallurgical Plant JSC* |
Tantalum | XinXing Haorong Electronic Material Co., Ltd.* |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.* |
Tantalum | Zhuzhou Cemented Carbide* |
Tin | Alpha* |
Tin | An Thai Minerals Company Limited* |
Tin | An Vinh Joint Stock Mineral Processing Company |
Tin | Best Metais e Soldas SA |
Tin | China Tin Group Co., Ltd.* |
Tin | CNMC (Guangxi) PGMA Co. Ltd. |
Tin | Colonial Metals, Inc |
Tin | Cooperativa Metalurgica de Rondônia Ltda.* |
Tin | CSC Pure Technologies |
Tin | CV Ayi Jaya* |
Tin | CV Duta Putra Bangka |
Tin | CV Gita Pesona* |
Tin | CV Prima Timah Utama |
Tin | CV Serumpun Sebalai* |
Tin | CV United Smelting* |
Tin | CV Venus Inti Perkasa* |
Tin | Dongguan Qiandao Tin Co., Ltd |
Tin | EFD INC. |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Tin | Electroloy Metal Pte |
Tin | Elmet S.A. de C.V. |
Tin | Elmet S.L.U. (Metallo Group)* |
Tin | EM Vinto* |
Tin | Estanho de Rondônia S.A. |
Tin | Feinhutte Halsbrucke GmbH |
Tin | Fenix Metals* |
Tin | Gejiu Kai Meng Industry and Trade LLC* |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
Tin | Gejiu Zi-Li |
Tin | Guangxi Non-ferrous Metals Group Company Limited |
Tin | Heraeus Materials Technology GmbH & Co. KG |
Tin | Hyundai-Steel |
Tin, Tungsten | Japan New Metals Co., Ltd. |
Tin | Jean Goldschmidt International SA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd.* |
Tin | Linwu Xianggui Smelter Co |
Tin | Magnu's Minerais Metais e Ligas Ltda.* |
Tin | Malaysia Smelting Corporation (MSC)* |
Tin | Materials Eco-Refining CO., LTD |
Tin | Melt Metais e Ligas S/A* |
Tin | Metahub Industries Sdn. Bhd. |
Tin | Metallo-Chimique N.V.* |
Tin | Minsur* |
Tin | Nankang Nanshan Tin Co., Ltd. |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Tin | Novosibirsk Integrated Tin Works |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* |
Tin | O.M. Manufacturing Philippines, Inc.* |
Tin | Operaciones Metalurgical S.A.* |
Tin | PBT |
Tin | Phoenix Metal Ltd |
Tin | POSCO |
Tin | PT Alam Lestari Kencana |
Tin | PT Aries Kencana Sejahtera* |
Tin | PT Artha Cipta Langgeng* |
Tin | PT ATD Makmur Mandiri Jaya* |
Tin | PT Babel Inti Perkasa* |
Tin | PT Bangka Kudai Tin |
Tin | PT Bangka Prima Tin* |
Tin | PT Bangka Timah Utama Sejahtera |
Tin | PT Bangka Tin Industry* |
Tin | PT Belitung Industri Sejahtera* |
Tin | PT BilliTin Makmur Lestari* |
Tin | PT Bukit Timah* |
Tin | PT Cipta Persada Mulia* |
Tin | PT DS Jaya Abadi* |
Tin | PT Eunindo Usaha Mandiri* |
Tin | PT Fang Di MulTindo |
Tin | PT Inti Stania Prima* |
Tin | PT Justindo* |
Tin | PT Karimun Mining |
Tin | PT Mitra Stania Prima* |
Tin | PT Panca Mega Persada* |
Tin | PT Pelat Timah Nusantara Tbk |
Tin | PT Prima Timah Utama* |
Tin | PT Refined Bangka Tin* |
Tin | PT Sariwiguna Binasentosa* |
Tin | PT Seirama Tin investment |
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 | PT WAHANA PERKIT JAYA* |
Tin | Pure Technology |
Tin | Ritchey Metals |
Tin | Rui Da Hung* |
Tin | Senju Metal Industry Co., Ltd. |
Tin | SGS |
Tin | Shangrao Xuri Smelting Factory |
Tin | Shaoxing Tianlong Tin Materials Co., Ltd |
Tin | Soft Metais Ltda.* |
Tin | Technic Inc. |
Tin | Thai Nguyen Nonferrous Metal Co. |
Tin | Thaisarco* |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
Tin | VQB Mineral and Trading Group JSC* |
Tin | White Solder Metalurgia e Mineração Ltda.* |
Tin | Xianghualing Tin Co., Ltd. |
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.* |
Tin | Yunnan Tin Group (Holding) Company Limited* |
Tungsten | A.L.M.T. TUNGSTEN Corp.* |
Tungsten | Asia Tungsten Products Vietnam Ltd.* |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd.* |
Tungsten | Dayu Weiliang Tungsten Co., Ltd.* |
Tungsten | Fujian Jinxin Tungsten Co., Ltd.* |
Tungsten | Ganxian Shirui New Material Co., Ltd. |
Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* |
Tungsten | Ganzhou Non-ferrous Metals Smelting 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.* |
Tungsten | H.C. Starck GmbH* |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin* |
Tungsten | Hydrometallurg, JSC* |
Tungsten | Jiangwu H.C. Starck Tungsten Products 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 Xiushui Xianggan Nonferrous Metals Co., Ltd.* |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* |
Tungsten | Kennametal Fallon* |
Tungsten | Kennametal Huntsville* |
Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* |
Tungsten | Niagara Refining LLC* |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* |
Tungsten | Pobedit, JSC* |
Tungsten | Sanher Tungsten Vietnam Co., Ltd.* |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* |
Tungsten | Wolfram Bergbau und Hütten AG* |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* |
Tungsten | Xiamen Tungsten Co., Ltd.* |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* |
*Denotes SORs that have received a “conflict free” designation from an independent third party audit program as of May 13, 2016.
We believe that the countries of origin for the conflict minerals processed by these SORs include Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bolivia, Brazil, Burundi, Canada, Chile, China, DRC-Congo (Kinshasa), Estonia, Ethiopia, France, Germany, Ghana, Greece, Guinea, Guyana, Hong Kong, India, Indonesia, Italy, Japan, Jersey, Kazakhstan, Kyrgyzstan, Laos, Malaysia, Mali, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, Niger, Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Romania, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, South Africa, South Korea, Spain, Suriname, Sweden, Switzerland, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, United Arab Emirates, United Kingdom, United States, Uzbekistan, Vietnam, Zambia and Zimbabwe.