Exhibit 1.01
Dynasil Corporation of America
Conflict Minerals Report
For the reporting period from January 1, 2016 to December 31, 2016
This Conflict Minerals Report (the "Report") of Dynasil
Corporation of America ("Dynasil" or the "Company") has
been prepared pursuant to Rule 13p-1 and Form SD (the
"Rule") promulgated under the Securities Exchange Act of
1934 for the reporting period January 1, 2016 to December
31, 2016.
The Rule requires disclosure of certain information when a
company manufactures or contracts to manufacture products
for which the minerals specified in the Rule are necessary
to the functionality or production of those products. The
specified minerals, which we collectively refer to in this
Report as the "Conflict Minerals," are gold, columbite-
tantalite (coltan), cassiterite and wolframite, including
their derivatives, which are limited to tantalum, tin and
tungsten. The "Covered Countries" for the purposes of the
Rule and this Report are the Democratic Republic of the
Congo, the Republic of the Congo, the Central African
Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania,
Zambia and Angola.
As described in this Report, certain of the Company's
operations manufacture, or contract to manufacture,
products for which the Conflict Minerals are necessary to
the functionality or production of those products.
Description of the Company's Products Covered by this
Report
This Report relates to products: (i) for which Conflict
Minerals are necessary to the functionality or production
of that product; (ii) that were manufactured, or
contracted to be manufactured, by the Company; and (iii)
for which the manufacture was completed during calendar
year 2016.
These products, which are referred to in this Report
collectively as the "Covered Products," are the following:
1. Optical thin films
2. Crystals for X-ray detection
3. Optical gratings
4. Optical filters
5. Radiation detection instruments
RCOI and Due Diligence
The Company's supply chain with respect to the Covered
Products is complex, and there are many third parties in
the supply chain between the ultimate manufacture of the
Covered Products and the original sources of Conflict
Minerals. In this regard, the Company does not purchase
Conflict Minerals directly from mines, smelters or
refiners. The Company must therefore rely on its suppliers
to provide information regarding the origin of 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 therefore
has taken steps to identify the applicable smelters and
refiners of Conflict Minerals in the Company's supply
chain.
Conflict Mineral Policy
Dynasil adopted a policy relating to the Conflict Minerals
(the "Company Policy"), incorporating the standards set
forth in OECD Guidance. The Company Policy outlines the
Company's commitment to the responsible sourcing of its
products and its expectations that its suppliers will be
similarly committed to responsible sourcing in the supply
chain. The Company Policy states, among other things, that
suppliers: (i) should not supply us with any products or
other materials that directly or indirectly finance or
benefit armed groups in the Covered Countries; (ii) are
expected to source Conflict Minerals only from sources that
are DRC conflict free; (iii) should develop policies, due
diligence processes and management systems that are
reasonably designed to prevent products or materials that
are not DRC conflict free from entering the Company's
supply chain; and (iv) are expected to take steps to
identify the smelter, refiner or mine from which Conflict
Minerals originate, and to provide information to the
Company necessary to facilitate its compliance efforts with
respect to the Rule.
Our policy is publicly available on our website at
www.dynasil.com under "Corporate Governance".
RCOI
The Company conducted a good faith reasonable country of
origin inquiry ("RCOI") regarding the Conflict Minerals as
described in the Company's Form SD to which this Report is
an exhibit. This good faith RCOI was designed to determine
whether any of the Conflict Minerals originated in the
Covered Countries and whether any of the Conflict Minerals
may be from recycled or scrap sources. As a result of the
RCOI, the Company was unable to determine that none of the
Conflict Minerals contained in the Covered Products
originated in the Covered Countries or were from recycled
or scrap sources.
Due Diligence Process
Based on the results of the RCOI, the Company exercised due
diligence on the source and chain of custody of the
Conflict Minerals. The Company's due diligence measures
have been designed to conform to the framework in the
Organization for Economic Co-operation and Development Due
Diligence Guidance for Responsible Supply Chain of Minerals
from Conflict-Affected and High Risk Areas: Second Edition,
including the related supplements on gold, tin, tantalum
and tungsten (the "OECD Guidance").
The Company's due diligence process was designed to both
gather information on the country of origin and to educate
our internal staff and suppliers regarding this initiative.
Our due diligence process is based on the following five-
step framework provided by the OECD Guidance:
* Establishing strong company management systems
* Identifying and assessing risks in the supply chain
* Designing and implementing a strategy to respond to
identified risks
* Carrying out an independent third-party audit of
supply chain due diligence at identified points in the
supply chain
* Reporting annually on supply chain due diligence
Under the Rule, the independent third-party audit
contemplated by the OECD Guidance is not required until the
Company's report for the period ending December 31, 2017.
Findings and Conclusions
Based on the information obtained pursuant to our RCOI and
the due diligence process, Dynasil does not have sufficient
information with respect to the Covered Products to
determine the country of origin of all the Conflict
Minerals in the Covered Products; however, based on the
information that was provided by the responding suppliers
and otherwise obtained by Dynasil through the due diligence
process, the Company believes that, to the extent
reasonably determinable by the Company, the facilities that
were used to process the Conflict Minerals contained in
some of the Covered Products included the smelters and
refiners listed below:
Metal Smelter: Smelter Name Smelter ID
Gold Advanced Chemical Company CID000015
Gold Western Australian Mint trading as
The Perth Mint CID002030
Gold Argor-Heraeus S.A. CID000077
Gold Asahi Pretec Corp. CID000082
Gold CCR Refinery - Glencore Canada Corporation CID000185
Gold The Refinery of Shandong Gold Mining Co., Ltd. CID001916
Gold Heimerle + Meule GmbH CID000694
Gold Heraeus Precious Metals GmbH & Co. KG CID000711
Gold Asahi Refining USA Inc. CID000920
Gold Kennecott Utah Copper LLC CID000969
Gold Materion CID001113
Gold Metalor Technologies S.A. CID001153
Gold Elemetal Refining, LLC CID001322
Gold Royal Canadian Mint CID001534
Gold Shandong Zhaojin Gold & Silver Refinery
Co., Ltd. CID001622
Gold United Precious Metal Refining, Inc. CID001993
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CID001277
Tin Alpha CID000292
Tin Cooperativa Metalurgica de Rondonia Ltda. CID000295
Tin CV Gita Pesona CID000306
Tin PT Justindo CID000307
Tin PT Aries Kencana Sejahtera CID000309
Tin CV Serumpun Sebalai CID000313
Tin CV United Smelting CID000315
Tin EM Vinto CID000438
Tin EM Vinto CID000438
Tin EM Vinto CID000438
Tin Alpha CID000292
Tin Fenix Metals CID000468
Tin Minsur CID001182
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CID000538
Tin China Tin Group Co., Ltd. CID001070
Tin China Tin Group Co., Ltd. CID001070
Tin Malaysia Smelting Corporation (MSC) CID001105
Tin PT Timah (Persero) Tbk Mentok CID001482
Tin Metallo-Chimique N.V. CID002773
Tin Mineracao Taboca S.A. CID001173
Tin Minsur CID001182
Tin Mitsubishi Materials Corporation CID001191
Tin Malaysia Smelting Corporation (MSC) CID001105
Tin Operaciones Metalurgical S.A. CID001337
Tin PT Artha Cipta Langgeng CID001399
Tin PT Babel Inti Perkasa CID001402
Tin PT Bangka Tin Industry CID001419
Tin PT Belitung Industri Sejahtera CID001421
Tin PT Bukit Timah CID001428
Tin PT DS Jaya Abadi CID001434
Tin PT Eunindo Usaha Mandiri CID001438
Tin PT Mitra Stania Prima CID001453
Tin PT Panca Mega Persada CID001457
Tin PT Refined Bangka Tin CID001460
Tin PT Sariwiguna Binasentosa CID001463
Tin PT Stanindo Inti Perkasa CID001468
Tin PT Sumber Jaya Indah CID001471
Tin PT Timah (Persero) Tbk Kundur CID001477
Tin PT Timah (Persero) Tbk Mentok CID001482
Tin PT Tinindo Inter Nusa CID001490
Tin Yunnan Tin Company Limited CID002180
Tin Mineracao Taboca S.A. CID001173
Tin Yunnan Tin Company Limited CID002180
Tin Yunnan Tin Company Limited CID002180
Tin Jiangxi Ketai Advanced Material Co., Ltd. CID000244
Tin CNMC (Guangxi) PGMA Co., Ltd. CID000278
Tin PT Justindo CID000307
Tin PT Aries Kencana Sejahtera CID000309
Tin Dowa CID000402
Tin Estanho de Rondonia S.A. CID000448
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CID000555
Tin Huichang Jinshunda Tin Co., Ltd. CID000760
Tin Gejiu Kai Meng Industry and Trade LLC CID000942
Tin China Tin Group Co., Ltd. CID001070
Tin O.M. Manufacturing (Thailand) Co., Ltd. CID001314
Tin Operaciones Metalurgical S.A. CID001337
Tin PT Karimun Mining CID001448
Tin PT Prima Timah Utama CID001458
Tin PT Tommy Utama CID001493
Tin Rui Da Hung CID001539
Tin Soft Metais Ltda. CID001758
Tin Thaisarco CID001898
Tin White Solder Metalurgia e Mineracao Ltda. CID002036
Tin CV Venus Inti Perkasa CID002455
Tin Magnu's Minerais Metais e Ligas Ltda. CID002468
Tin PT Tirus Putra Mandiri CID002478
Tin PT Wahana Perkit Jaya CID002479
Tin Melt Metais e Ligas S.A. CID002500
Tin PT ATD Makmur Mandiri Jaya CID002503
Tin O.M. Manufacturing Philippines, Inc. CID002517
Tin PT Inti Stania Prima CID002530
Tin Resind Industria e Comercio Ltda. CID002706
Tungsten Global Tungsten & Powders Corp. CID000568
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CID002320
Tungsten Kennametal Huntsville CID000105
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CID000258
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CID000875
Tungsten Global Tungsten & Powders Corp. CID000568
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CID002316
Tungsten H.C. Starck GmbH CID002541
Tungsten H.C. Starck Smelting GmbH & Co.KG CID002542
Tungsten Hunan Chenzhou Mining Co., Ltd. CID000766
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CID000769
Tungsten Japan New Metals Co., Ltd. CID000825
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CID002321
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CID002317
Tungsten Kennametal Huntsville CID000105
Tungsten Tejing (Vietnam) Tungsten Co., Ltd. CID001889
Tungsten Wolfram Bergbau und Hutten AG CID002044
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CID002320
Tungsten Xiamen Tungsten Co., Ltd. CID002082
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CID002095
Our efforts to determine the mine or location of origin
of the Conflict Minerals in the Covered Products
consisted of the due diligence measures described in this
Report. In particular, because independent third party
audit programs validate whether sufficient evidence
exists regarding country, mine and/or location of origin
of the Conflict Minerals that the audited smelter or
refiner facilities have processed, we relied on the
information made available by such programs for the
smelters and refiners in our supply chain. Dynasil was
unable to ascertain the country of origin and/or chain of
custody of all necessary Conflict Minerals processed by
these facilities because, for this reporting period,
certain smelter and refiner facilities had not yet
received a "conflict free" designation from an
independent third party audit program.
Risk Mitigation Steps
Dynasil has taken and expects to continue 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 our products
benefit armed groups in the Covered Countries:
- continue to engage suppliers to obtain current,
accurate and complete information about the supply
chain;
- encourage suppliers to implement responsible
sourcing and to have them encourage smelters and
refiners to obtain a "conflict-free" designation
from an independent, third-party auditor; and
- engaging in industry initiatives encouraging
"conflict-free" supply chains.