UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
Tesco Corporation
(Exact name of registrant as specified in its charter)
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Commission File No.: 001-34090 |
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Alberta | 76-0419312 |
(State or Other Jurisdiction of Incorporation or Organization) | (I.R.S. Employer Identification No.) |
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3993 West Sam Houston Parkway North, Suite 100 Houston, Texas | 77043-1221 |
(Address of Principal Executive Offices) | (Zip Code) |
Dean Ferris 713-359-7000
(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:
[X] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 1, 2014.
Company Profile:
Tesco Corporation (“we,” “our,” “us,” “Tesco,” or the “Company”) is a global leader in the design, assemble, and service delivery of technology-based solutions for the upstream energy industry with operations in 23 countries across five continents. With a strong commitment to in-house research and engineering, we seek to change the way wells are drilled by delivering safer and more efficient solutions that add real value by reducing the costs of drilling for, and producing, oil and natural gas. Our product and service offerings consist mainly of equipment sales and services to drilling contractors and exploration and production companies throughout the world.
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with the disclosure requirements promulgated by the U.S. Securities and Exchange Commission, we have undertaken efforts to determine our conflict minerals1 reporting requirements for the period from January 1 to December 31, 2014.
We have determined that during 2014 our company manufactured (or contracted to manufacture) products as to which conflict minerals are necessary to the functionality or production of such products. As is required, we have conducted a good faith reasonable country of origin inquiry (“RCOI”) reasonably designed to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
Tesco’s RCOI process included conducting an inquiry of our direct suppliers using the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template. We relied upon our suppliers’ representations regarding the origin of their minerals and their smelter data to determine the source of the conflict minerals within our supply chain. Based on the results of our RCOI, we exercised due diligence on the source and chain of custody of the conflict minerals.
The Company has filed this Specialized Disclosure Form and the associated Conflict Minerals Report, which appears as Exhibit 1.01 hereto and is publicly available on the Company’s website at www.tescocorp.com under Investor Relations>Corporate Governance.
Item 1.02 Exhibit
The Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.
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1The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; 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 an adjoining country.
Section 2 Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report.
Exhibit 1.01 - Tesco Corporation’s Conflict Minerals Report for the period January 1 to December 31, 2014.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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| TESCO CORPORATION |
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Date: May 28, 2015 | By: | /s/ Dean Ferris |
| | Dean Ferris, Sr. Vice President, General Counsel and Corporate Secretary |
Exhibit 1.01
CONFLICT MINERALS REPORT OF
Tesco Corporation
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2014
I. Introduction
This is the Conflict Minerals Report1 of Tesco Corporation (“we,” “our,” “us,” “Tesco,” or the “Company”) prepared for calendar year 2014 (except for conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Form SD and the reader is referred to those sources, and also to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
In accordance with Rule 13p-1, we undertook efforts to determine whether the necessary conflict minerals in our products were or were not “DRC conflict-free.” The Company designed its efforts in conformity with the internationally recognized due diligence framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below are based on the activities performed to date and in good faith by Tesco and are based on the infrastructure and information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.
II. Design of Conflict Minerals Program
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
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1The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; 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 an adjoining country.
2OECD (2013), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing. http://dx.doi.org/10.1787/9789264185050-en
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5: Report annually on supply chain due diligence.
We relied upon multi-stakeholder initiatives that provide verification processes for conflict-free minerals from smelters or refiners who may provide those minerals to companies in our supply chain. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals; the Company does not purchase raw ore or unrefined conflict minerals, and conducts no purchasing activities directly in the Covered Countries.
Tesco also engaged Crowe Horwath, an international accounting and consulting firm, to assist in the design and implementation of our program. We utilized the Crowe Horwath’s technology platform to communicate with our supply chain, collect Conflict Minerals Reporting Templates, and validate key information from our suppliers.
III. Due Diligence Measures Performed by Tesco
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong company management systems
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a. | Conflict minerals team - Tesco established a conflict minerals team that includes individuals from the appropriate business units and departments. The team was structured to ensure critical information was collected by the Company, Tesco adopted and published a policy establishing the expectations of our suppliers. The policy can be found at www.tescocorp.com under Investor Relations>Corporate Governance. It is periodically reviewed and will be updated, if necessary. |
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b. | Internal engagement - We developed a training program for internal use to educate relevant employees on our conflict minerals program and reporting obligations. |
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c. | Supplier engagement - Tesco provided educational materials to our queried suppliers. Suppliers were provided information on the conflict minerals disclosure requirements as well as recommendations for developing, implementing, and documenting a conflict minerals compliance program. |
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d. | Company level grievance mechanism - As recommended by the OECD Due Diligence Guidance, Tesco has established a grievance mechanism as a risk-awareness system for conflict minerals issues. Stakeholders can communicate directly and confidentially with our general counsel’s office and chair of the audit committee. |
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e. | Records management - Tesco will maintain records relating to our conflict minerals program in accordance with the recommended record retention guidelines. |
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
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a. | Identify products in scope - Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release. |
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b. | Conduct Reasonable Country of Origin Inquiry (“RCOI”) - Tesco utilized the industry-developed Conflict Minerals Reporting Template (“CMRT”) to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide material and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. |
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c. | Completed additional follow-up - Tesco contacted direct suppliers that did not respond to our request for conflict minerals information by the requested date. We also worked to clarify and validate the information provided by our suppliers. |
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d. | Identify smelters/processors - Tesco collected a list of smelters/processors that are in our supply chain by utilizing the CMRT. The Company reconciled this list to the list of smelter facilities designated by the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict-Free Smelter Program. We have provided that list in this report. |
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
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a. | Designed and implemented a plan - Tesco used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT as well as any additional documentation furnished to support those responses. The resulting risk ratings will be used to develop specific supplier outreach and education to address the identified risks. |
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b. | Verify smelters - As part of the risk mitigation process, the Company reconciled the list of smelters collected from suppliers to the list of smelter facilities designated as “conflict-free” by the CFSI’s Conflict-Free Smelter Program. |
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Tesco is relying on the CFSI’s published lists to verify the conflict-free status of smelters/processors that source from Covered Countries.
Step 5: Report annually on supply chain due diligence
Tesco has determined that a portion of the conflict minerals used to manufacture our products originated from the Covered Countries. Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website at www.tescocorp.com under Investor Relations>Corporate Governance.
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IV. | Product Determination |
On the basis of the measures described above, the Company has determined that all of our products manufactured as of December 31, 2014 are considered to be DRC conflict undeterminable.
V. Product Description; Processing Facilities
With a strong commitment to in-house research and engineering, we seek to change the way wells are drilled by delivering safer and more efficient solutions that add real value by reducing the costs of drilling for, and producing, oil and natural gas. Our product and service offerings consist mainly of equipment sales and services to drilling contractors and exploration and production companies throughout the world.
Processing Facilities - Based on our due diligence process and the information received from our suppliers, the following facilities may have been used to process conflict minerals used in our products.
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Mineral | Smelter Name | Country | Conflict-Free Status |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conflict-Free |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conflict-Free |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Conflict-Free |
Gold | Argor-Heraeus SA | SWITZERLAND | Conflict-Free |
Gold | Asahi Pretec Corporation | JAPAN | Conflict-Free |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Conflict-Free |
Gold | Aurubis AG | GERMANY | Conflict-Free |
Gold | Boliden AB | SWEDEN | Conflict-Free |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conflict-Free |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conflict-Free |
Gold | Chimet S.p.A. | ITALY | Conflict-Free |
Gold | Dowa | JAPAN | Conflict-Free |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conflict-Free |
Gold | Heimerle + Meule GmbH | GERMANY | Conflict-Free |
Gold | Heraeus Ltd. Hong Kong | CHINA | Conflict-Free |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conflict-Free |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conflict-Free |
Gold | Istanbul Gold Refinery | TURKEY | Conflict-Free |
Gold | Japan Mint | JAPAN | Conflict-Free |
Gold | Johnson Matthey Inc. | UNITED STATES | Conflict-Free |
Gold | Johnson Matthey Limited | CANADA | Conflict-Free |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conflict-Free |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conflict-Free |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conflict-Free |
Gold | Kazzinc | KAZAKHSTAN | Conflict-Free |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Conflict-Free |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conflict-Free |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Conflict-Free |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conflict-Free |
Gold | Materion | UNITED STATES | Conflict-Free |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conflict-Free |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conflict-Free |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conflict-Free |
Gold | Metalor Technologies SA | SWITZERLAND | Conflict-Free |
Gold | Metalor USA Refining Corporation | UNITED STATES | Conflict-Free |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Conflict-Free |
Gold | Mitsubishi Materials Corporation | JAPAN | Conflict-Free |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conflict-Free |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Conflict-Free |
Gold | Nihon Material Co., Ltd. | JAPAN | Conflict-Free |
Gold | Ohio Precious Metals, LLC | UNITED STATES | Conflict-Free |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conflict-Free |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | Conflict-Free |
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Gold | PAMP SA | SWITZERLAND | Conflict-Free |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conflict-Free |
Gold | PX Précinox SA | SWITZERLAND | Conflict-Free |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conflict-Free |
Gold | Royal Canadian Mint | CANADA | Conflict-Free |
Gold | Schone Edelmetaal | NETHERLANDS | Conflict-Free |
Gold | SEMPSA Joyería Platería SA | SPAIN | Conflict-Free |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conflict-Free |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | Conflict-Free |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conflict-Free |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conflict-Free |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conflict-Free |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conflict-Free |
Gold | Umicore Brasil Ltda. | BRAZIL | Conflict-Free |
Gold | Umicore Precious Metals Thailand | THAILAND | Conflict-Free |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Conflict-Free |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Conflict-Free |
Gold | Valcambi SA | SWITZERLAND | Conflict-Free |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Conflict-Free |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conflict-Free |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conflict-Free |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Conflict-Free |
Gold | Advanced Chemical Company | UNITED STATES | Not Determined |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Not Determined |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Not Determined |
Gold | Asaka Riken Co., Ltd. | JAPAN | Not Determined |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Not Determined |
Gold | Bauer Walser AG | GERMANY | Not Determined |
Gold | Caridad | MEXICO | Not Determined |
Gold | Cendres + Métaux SA | SWITZERLAND | Not Determined |
Gold | Chugai Mining | JAPAN | Not Determined |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Not Determined |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Determined |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Not Determined |
Gold | Doduco | GERMANY | Not Determined |
Gold | Faggi Enrico S.p.A. | ITALY | Not Determined |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Not Determined |
Gold | Geib Refining Corporation | UNITED STATES | Not Determined |
Gold | Guangdong Jinding Gold Limited | CHINA | Not Determined |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Determined |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Determined |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Not Determined |
Gold | Jiangxi Copper Company Limited | CHINA | Not Determined |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Determined |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Not Determined |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Not Determined |
Gold | Lingbao Gold Company Limited | CHINA | Not Determined |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Determined |
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Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Not Determined |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Not Determined |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Not Determined |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Not Determined |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Determined |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Not Determined |
Gold | Sabin Metal Corp. | UNITED STATES | Not Determined |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Not Determined |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Determined |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Determined |
Gold | So Accurate Group, Inc. | UNITED STATES | Not Determined |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Not Determined |
Gold | The Great Wall Gold and Silver Refinery of China | CHINA | Not Determined |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Determined |
Gold | Torecom | KOREA, REPUBLIC OF | Not Determined |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Not Determined |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Conflict-Free |
Tantalum | Duoluoshan | CHINA | Conflict-Free |
Tantalum | Exotech Inc. | UNITED STATES | Conflict-Free |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conflict-Free |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Conflict-Free |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conflict-Free |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conflict-Free |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Conflict-Free |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conflict-Free |
Tantalum | H.C. Starck Inc. | UNITED STATES | Conflict-Free |
Tantalum | H.C. Starck Ltd. | JAPAN | Conflict-Free |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Conflict-Free |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Conflict-Free |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conflict-Free |
Tantalum | KEMET Blue Metals | MEXICO | Conflict-Free |
Tantalum | KEMET Blue Powder | UNITED STATES | Conflict-Free |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conflict-Free |
Tantalum | LSM Brasil S.A. | BRAZIL | Conflict-Free |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conflict-Free |
Tantalum | Mineração Taboca S.A. | BRAZIL | Conflict-Free |
Tantalum | Mitsui Mining & Smelting | JAPAN | Conflict-Free |
Tantalum | Molycorp Silmet A.S. | ESTONIA | Conflict-Free |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Plansee SE Liezen | AUSTRIA | Conflict-Free |
Tantalum | Plansee SE Reutte | AUSTRIA | Conflict-Free |
Tantalum | QuantumClean | UNITED STATES | Conflict-Free |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conflict-Free |
Tantalum | Taki Chemicals | JAPAN | Conflict-Free |
Tantalum | Telex Metals | UNITED STATES | Conflict-Free |
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Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conflict-Free |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conflict-Free |
Tantalum | Zhuzhou Cemented Carbide | CHINA | Conflict-Free |
Tin | Alpha | UNITED STATES | Conflict-Free |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Conflict-Free |
Tin | CV United Smelting | INDONESIA | Conflict-Free |
Tin | EM Vinto | BOLIVIA | Conflict-Free |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conflict-Free |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conflict-Free |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conflict-Free |
Tin | Melt Metais e Ligas S/A | BRAZIL | Conflict-Free |
Tin | Mineração Taboca S.A. | BRAZIL | Conflict-Free |
Tin | Minsur | PERU | Conflict-Free |
Tin | Mitsubishi Materials Corporation | JAPAN | Conflict-Free |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Conflict-Free |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conflict-Free |
Tin | PT Babel Inti Perkasa | INDONESIA | Conflict-Free |
Tin | PT Bangka Putra Karya | INDONESIA | Conflict-Free |
Tin | PT Bangka Tin Industry | INDONESIA | Conflict-Free |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Conflict-Free |
Tin | PT Bukit Timah | INDONESIA | Conflict-Free |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conflict-Free |
Tin | PT Mitra Stania Prima | INDONESIA | Conflict-Free |
Tin | PT Panca Mega Persada | INDONESIA | Conflict-Free |
Tin | PT Prima Timah Utama | INDONESIA | Conflict-Free |
Tin | PT Refined Bangka Tin | INDONESIA | Conflict-Free |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conflict-Free |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conflict-Free |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conflict-Free |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conflict-Free |
Tin | PT Tinindo Inter Nusa | INDONESIA | Conflict-Free |
Tin | Thaisarco | THAILAND | Conflict-Free |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Conflict-Free |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Conflict-Free |
Tin | China Tin Group Co., Ltd. | CHINA | Not Determined |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Determined |
Tin | CV Gita Pesona | INDONESIA | Not Determined |
Tin | CV Serumpun Sebalai | INDONESIA | Not Determined |
Tin | Estanho de Rondônia S.A. | BRAZIL | Not Determined |
Tin | Feinhütte Halsbrücke GmbH | GERMANY | Not Determined |
Tin | Fenix Metals | POLAND | Not Determined |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Not Determined |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Determined |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Not Determined |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Not Determined |
Tin | Metallic Resources, Inc. | UNITED STATES | Not Determined |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Not Determined |
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | Not Determined |
Tin | PT Alam Lestari Kencana | INDONESIA | Not Determined |
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Tin | PT Aries Kencana Sejahtera | INDONESIA | Not Determined |
Tin | PT Bangka Kudai Tin | INDONESIA | Not Determined |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Not Determined |
Tin | PT BilliTin Makmur Lestari | INDONESIA | Not Determined |
Tin | PT Fang Di MulTindo | INDONESIA | Not Determined |
Tin | PT Inti Stania Prima | INDONESIA | Not Determined |
Tin | PT Justindo | INDONESIA | Not Determined |
Tin | PT Karimun Mining | INDONESIA | Not Determined |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Not Determined |
Tin | PT Seirama Tin Investment | INDONESIA | Not Determined |
Tin | PT Sumber Jaya Indah | INDONESIA | Not Determined |
Tin | PT Supra Sukses Trinusa | INDONESIA | Not Determined |
Tin | Rui Da Hung | TAIWAN | Not Determined |
Tin | Soft Metais Ltda. | BRAZIL | Not Determined |
Tin | VQB Mineral and Trading Group JSC | VIETNAM | Not Determined |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Not Determined |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conflict-Free |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Conflict-Free |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conflict-Free |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Conflict-Free |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Conflict-Free |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conflict-Free |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conflict-Free |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Not Determined |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Not Determined |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | H.C. Starck GmbH | GERMANY | Not Determined |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Not Determined |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Not Determined |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Not Determined |
Tungsten | Kennametal Fallon | UNITED STATES | Not Determined |
Tungsten | Kennametal Huntsville | UNITED STATES | Not Determined |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Not Determined |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Not Determined |
VI. Future Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
In addition to those above, the Company will undertake the following steps during the next compliance period:
| |
• | Continue to collect responses from suppliers using the CMRT. |
| |
• | Monitor and track performance of risk mitigation efforts. |
| |
• | Compare and validate RCOI results to information collected via independent conflict-free smelter validation programs such as the CFSI. |
| |
• | Continue to allow verified conflict-free material from the region to enter our supply chain. |
VII. Independent Private Sector Audit
Not required for calendar year 2014.
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