Exhibit 1.01
Conflict Minerals Report
This is the Conflict Minerals Report for Magal Security Systems Ltd. (“Magal”, “we” or “our”), filed with the SEC pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2018 to December 31, 2018. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on Securities and Exchange Commission (the “SEC”) registrants whose manufactured products contain Conflict Minerals that are necessary to the functionality or production of their products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("3TG") for the purposes of this assessment.
If a registrant cannot establish with complete certainty that the Conflict Minerals that are necessary to the manufacture or functionality of its products originated from sources other than the Democratic Republic of the Congo ("DRC") or an adjoining countries (together referred to as the "Covered Countries), or originate from wholly recycled or scrap sources, the registrant must submit a specialized disclosure report under the Form SD that describes the steps that the registrant took to determine the origin of the Conflict Minerals in its products.
If a registrant has reason to believe that any Conflict Minerals in its supply chain may have originated in the Covered Countries, or if the registrant is unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence on the Conflict Minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report (a “CMR”) as an exhibit to its Form SD to the SEC that includes a description of those due diligence measures.
As permitted by the Rule and the SEC, this report has not been subject to an independent private sector audit.
1. | Company Overview |
Magal, incorporated under the laws of the State of Israel on March 27, 1984, develops, manufactures, markets and sells comprehensive computerized physical and cyber security products and systems to high profile customers. Our systems are used in more than 80 countries to protect sensitive facilities, including national borders, military bases, power plants, airports, seaports, prisons, industrial sites, oil and gas facilities, Olympic villages and stadiums and municipalities from intrusion, crime, sabotage or vandalism to infrastructure, assets and personnel.
Our goal in designing and implementing our Conflict Minerals risk management strategy is not to eliminate sourcing from the DRC and Covered Countries, but to encourage participation with the Responsible Minerals Initiative ("RMI") and other relevant independent third party auditing bodies, where possible.
2. | Supply Chain and Products Overview |
Our products are categorized into different technologies, consisting of physical and cyber security solutions:
- | Perimeter Intrusion Detection Systems (PIDS); |
- | Video Management Systems (VMS); |
- | CCTV systems, including a perimeter security Robot; |
- | Cyber security systems; |
- | Command and control systems; and |
- | Miscellaneous systems tailored for specific vertical market needs. |
Our products often require the use of tin, tantalum and gold, which fall under the definition of Conflict Minerals:
· | Gold – after being melted and applied to a component part in a thin coating, forms part of Magal’s sensors. |
· | Tin – used in electronic circuit cards while soldering components into the cards. |
· | Gold plating – contact pins as part of connectors that Magal purchases as strictly off-the-shelf product and are soldered or attached to wire harnesses or electronic circuit cards. |
· | Tantalum - forms part of capacitors that Magal purchases as strictly off-the-shelf product and is soldered or attached to the electronic cards. |
Our supply chain is complex. There are multiple tiers between our company and the sources of the Conflict Minerals. Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components that are included in our products.
3. | Reasonable Country of Origin Inquiry |
In order to conduct a Reasonable Country of Origin Inquiry on the source or origin of conflict minerals that are necessary to the functionality or production of our products, we developed a risk-based approach that focuses on all suppliers involved in the manufacture of the relevant abovementioned products that contain or use the necessary conflict minerals. We identified 55 relevant suppliers that we concluded provide us with products and components that do or may contain 3TG that are necessary to functionality or production of our products and which accounted for 90% of all applicable materials purchased by Magal in 2018.
Utilizing the Responsible Minerals Initiative's ("RMI"), formerly the Conflict Free Sourcing Initiative ("CFSI"), standard Conflict Minerals Reporting Template (“CMRT”) of at a minimum version 5.01 or higher, and the services of a third-party data management provider (“Service Provider”), we surveyed the relevant suppliers. Additionally, we sent letters to our relevant suppliers, informing them of the Rule and the Company's Conflict Minerals Policy. We reviewed the responses and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. We received responses from 87% of the suppliers we approached.
The majority of suppliers from which we requested information indicated in their response that the information provided was at a company level (69%). Thus, the majority of the manufacturers were unable to accurately report which specific smelters or refiners (“SORs”) were part of the supply chain applicable to the components that were sold to us in 2018.
Based on information obtained in the RCOI, and taking into account the complexities of our supply chain, we do not have sufficient information from our suppliers to determine the country of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries, and are not from recycled or scrap sources.
In accordance with the Rule, Magal undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its products during 2018. There is significant overlap between our RCOI efforts and the due diligence measures performed.
4. | Design of Our Due Diligence |
Based on the findings of our RCOI, we designed our due-diligence process in reference to the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ("OECD Guidance") and its related Supplements for 3TG.
Magal has processes in place for the purpose of exercising due diligence on its supply chain. The design of the due diligences processes conforms with the OECD Guidance as it relates to “downstream” purchasers of products and components. The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
5. | Due Diligence Performance |
Step 1 - Establish strong company management systems:
- | Our Conflict Minerals Policy is publicly available on our website at https://magalsecurity.com/about-magal/corporate-governance, and describes our commitment towards responsible sourcing. |
- | We structured a team of individuals from various functions (Operations, Legal and Finance) within the organization to support the process of supply chain due diligence. The team meets to assess identified risks and determine follow up actions. |
- | Magal maintains a system of controls and transparency over the mineral supply chain through use of the RMI's CMRT reporting template of, at a minimum, version 5.01 or higher. Due to the large size of our supply chain, we have also contracted a Service Provider to enhance the supplier data collection process and to help minimize sourcing risks. |
- | We maintain records relating to our Conflict Minerals program for 5 years. |
- | We provide training to assist our suppliers to meet our requirements. |
- | We enable employees, suppliers and other stakeholders to report any concerns relating to our Conflict Minerals program through our grievance mechanism. Contact details for concerns or questions are provided in our Conflict Mineral Policy that is publically available at our website under the heading “Corporate Governance” and at the following link: https://magalsecurity.com/about-magal/corporate-governance. |
Step 2 - Identify and assess risk in the supply chain:
- | We mapped and evaluated our family of products. Magal mapped the relevant agents and suppliers, as well as the manufacturers that sell to these agents and suppliers in order to identify relevant suppliers for the supply chain inquiry. |
- | We surveyed our suppliers using, at a minimum, version 5.01 of the CMRT (as detailed above in "Reasonable Country of Origin" section). We compared the SORs identified by our suppliers against the lists of facilities that have received a conformant or active designation by the RMI's Responsible Minerals Assurance Process (RMAP) smelter and refiner validation program or other independent third party audit programs. We contacted suppliers that did not respond or provided inadequate responses. |
- | Due to our size, the breadth and complexity of our products and the constant evolution of our supply chain, it is difficult to identify SORs in our supply chain. We do not purchase Conflict Minerals directly from mines or the SORs, and there are many tiers in the supply chain between us and the original source of the Conflict Minerals. As a result, we rely on our direct suppliers and manufacturers to provide information regarding the origin of any Conflict Minerals. This challenge brings us to engage a Service Provider to assist in certain aspects of the process. |
Step 3 - Design and implementation of a strategy to respond to identified risks:
- | We reviewed the survey responses, assessed the risks identified and implemented a strategy to respond to those risks. |
o | We followed up on inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. |
o | Relevant senior management was briefed about our due diligence efforts, risk analysis results and mitigation efforts. |
o | Our team, led by our CFO, assessed identified risks and determined follow up actions, as needed. |
o | Suppliers that source from uncertified SORs from the Covered Countries were contacted and were asked to submit more information about their sourcing practices, including a corrective action plan. |
- | Supply chain due diligence is a dynamic process and requires on-going risk monitoring. To ensure the effectiveness of risk management, after implementation of our strategy, we review the identified risks on a regular basis. |
Step 4 - Carry Out Independent Third Party Audit of SORs’ Due Diligence Practices:
Magal does not have a direct relationship with 3TG SORs. As such, we do not perform direct audits of SORs in our supply chain, but rather rely on due diligence performed by organizations such as the RMI and compare SOR data received with the RMI's Standard Smelter List of SORs compliant with the RMAP program.
Step 5 - Report Annually on Supply Chain Due Diligence:
We currently, subject to SEC guidelines, report annually on our supply chain due diligence through Form SD. Our reports on Form SD are publicly available at https://magalsecurity.com/about-magal/corporate-governance.
6. | Results for the 2018 Calendar Year |
The following factors materially affect the results of our assessment:
• | We are dependent on information received from our direct suppliers to conduct our good faith RCOI process; |
• • | We do not have a direct relationship with 3TG SORs, nor do we perform direct audits of the other entities in our supply chain; We have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to the Rule; |
• | The information our suppliers provide us with is sometimes incomplete and requires significant follow-up; |
• | Most suppliers provided responses at a company or divisional level, and not at a product level specific to the materials and components we use in the subject products; |
• | Certain suppliers were unable or unwilling to specify the SORs used for materials and components supplied to us; |
• • | Our ability to influence cooperation from certain suppliers was limited as we were multiple tiers away from the SORs in the supply chain; and The information gathered from our suppliers is not obtained on a continuous, real-time basis. |
We conducted a supply-chain survey of 55 of our direct suppliers that we identified may contribute necessary Conflict Minerals to our products. The overall response rate to this survey was 87%.
Response analysis:
Out of the total responses received, 48 responses were defined as complete responses and 7 responses were incomplete or inconsistent.
Declaration scope:
Based on the responses that we received, most of our suppliers delivered declaration in company level as shown below:
Company level | 69% |
User-defined | 15% |
Products list | 16% |
As such, Magal was unable to identify with complete certainty the country of origin of the Conflict Minerals used in the Company’s products in 2018.
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the Conflict Minerals in our products include the SORs listed in Exhibit A below. Based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals in our products or whether the Conflict Minerals in our products are from entirely recycled or scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.
7. | Conclusion |
Due to the breadth and scope of our product categories, the resulting complexity of our supply chain, and the human and financial resources available to us, we acknowledge that the process of successfully tracing all of the Conflict Minerals used in our manufactured or contracted to manufacture products to their country of origin will take additional time and resources. Moving forward, subject to the legal requirements and any changes to the Rule, we will continue to implement commercially reasonable processes to improve the quantity and quality of supplier responses.
The failure to obtain reliable information from any level of our supply chain could have a material impact on our future ability to report on the presence of Conflict Minerals with any degree of certainty. There can be no assurance that our suppliers will continue to cooperate with diligence inquiries and requests for certifications or provide documentation or other evidence that we consider reliable or provided to us within a time frame sufficient to allow us to make our own assessment following appropriate further diligence measures, if any. The information provided in this Conflict Mineral Report speaks only as of its date. Subsequent events, including future guidelines by the SEC, and the inability or unwillingness of participants in our supply chain to provide complete and accurate information requested, may affect our future determinations under the Rule.
Cautionary Statement about Forward-Looking Statements
Statements in this Conflict Minerals Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our Conflict Minerals program and our ability to identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the SEC, including our Annual Report on Form 20-F for the year ended December 31, 2018. We caution that undue reliance should not be placed on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
Exhibit A
List of identified certified SORs
Metal | Smelter or Refiner (SOR) Name | Smelter or Refiner (SOR) Country |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Boliden AB | SWEDEN |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | T.C.A S.p.A | ITALY |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
Gold | PX Precinox S.A. | SWITZERLAND |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | Planta Recuperadora de Metales SpA | CHILE |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | Japan Mint | JAPAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | Aurubis AG | GERMANY |
Gold | Chimet S.p.A. | ITALY |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Chugai Mining | JAPAN |
Gold | Bauer Walser AG | GERMANY |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | Dowa | JAPAN |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | Remondis Argentia B.V. | NETHERLANDS |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | NH Recytech Company | KOREA, REPUBLIC OF |
Gold | 8853 S.p.A. | ITALY |
Gold | Royal Canadian Mint | CANADA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | Cendres + Metaux S.A. | SWITZERLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Bangalore Refinery | INDIA |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
Gold | SAAMP | FRANCE |
Gold | Italpreziosi | ITALY |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
Gold | Marsam Metals | BRAZIL |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Safimet S.p.A | ITALY |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Yamakin Co., Ltd. | JAPAN |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | Mineracao Taboca S.A. | BRAZIL |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Thaisarco | THAILAND |
Tin | Mineracao Taboca S.A. | BRAZIL |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
Tin | PT Tirus Putra Mandiri | INDONESIA |
Tin | PT Babel Surya Alam Lestari | INDONESIA |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
Tin | Yunnan Tin Company Limited | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | Minsur | PERU |
Tin | Fenix Metals | POLAND |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | CV Gita Pesona | INDONESIA |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Premium Tin Indonesia | INDONESIA |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | PT REFINED BANGKA TIN | INDONESIA |
Tin | Dowa | JAPAN |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | CV Dua Sekawan | INDONESIA |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | CV Tiga Sekawan | INDONESIA |
Tin | PT Menara Cipta Mulia | INDONESIA |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
Tin | PT Sukses Inti Makmur | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | PT Bangka Serumpun | INDONESIA |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
Exhibit B
Countries of origin of the Conflict Minerals
Based on Magal's due diligence, the above SOR may process conflict minerals from one or more of the following countries of origin:
All 3TG metals |
ANDORRA |
AUSTRALIA |
AUSTRIA |
BELGIUM |
BOLIVIA (PLURINATIONAL STATE OF) |
BRAZIL |
CANADA |
CHILE |
CHINA |
CZECH REPUBLIC |
ESTONIA |
FRANCE |
GERMANY |
INDIA |
INDONESIA |
ITALY |
JAPAN |
KAZAKHSTAN |
KOREA, REPUBLIC OF |
KYRGYZSTAN |
LITHUANIA |
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
MALAYSIA |
MEXICO |
MYANMAR |
NETHERLANDS |
NEW ZEALAND |
NORWAY |
PERU |
PHILIPPINES |
POLAND |
RUSSIAN FEDERATION |
SAUDI ARABIA |
SINGAPORE |
SOUTH AFRICA |
SPAIN |
SUDAN |
SWEDEN |
SWITZERLAND |
TAIWAN, PROVINCE OF CHINA |
THAILAND |
TURKEY |
UGANDA |
UNITED ARAB EMIRATES |
UNITED STATES OF AMERICA |
UZBEKISTAN |
VIET NAM |
ZAMBIA |
ZIMBABWE |