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

FORM SD

Specialized Disclosure Report

ABAXIS, INC.
(Exact name of registrant as specified in its charter)

California
000-19720
77-0213001
(State or other Jurisdiction of Incorporation)
(Commission File Number)
(I.R.S. Employer Identification No.)

3240 Whipple Road
Union City, CA 94587
(Address of principal executive offices, including zip code)

Donald P. Wood, (510) 675-6500
(Name and telephone number, including area code, of the person to contact in connection with this report.)

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

☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

Section 1 - Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of Abaxis, Inc. is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2014 to December 31, 2014. A copy of Abaxis’ Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available in the Investor Relations section of the Company’s website at http://www.abaxis.com.

Item 1.02 Exhibit

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

Section 2 – Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form
 
2

SIGNATURES


Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
ABAXIS, INC.
 
     
By:
/s/ Donald P. Wood
Date: June 1, 2015
 
Donald P. Wood
 
 
Chief Operating Officer
 


3

EXHIBIT INDEX

Exhibit No.
Description
   
Conflict Minerals Report of Abaxis, Inc.

 
4

 



Exhibit 1.01

Abaxis, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2014

This report for the period from January 1, 2014 through December 31, 2014 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“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. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that are necessary to their functionality or production. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG” or “Conflict Minerals”). The intent of these requirements is to further the goal of ending violent conflict in the Democratic Republic of Congo and in adjoining countries (the “Covered Countries”), which conflict has been financed, in part, by the exploitation and trade of conflict minerals. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.

If a registrant can establish that the Conflict Minerals originated from sources other than the Covered Countries, or from recycled or scrap sources, it must submit a Form SD that describes the Reasonable Country of Origin Inquiry (“RCOI”) completed.

If a registrant has reason to believe that any of the Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the registrant must conduct due diligence on the conflict minerals’ source and chain of custody. The registrant must annually submit a Conflict Minerals Report (“CMR”), to the SEC that includes a description of those due diligence measures. Abaxis is filing this CMR because, based on its RCOI, the Company was unable to determine the country of origin of all Conflict Minerals in its supply chain.

Covered Products

Abaxis, Inc. (“Abaxis” or the “Company”), incorporated in California in 1989, develops, manufactures and markets portable blood analysis systems that are used in a broad range of medical specialties in human or veterinary patient care to provide clinicians with rapid blood constituent measurements.

Our medical devices are manufactured using parts and components that are several levels removed from the actual mining of conflict minerals. The blood chemistry analyzers that we manufacture employ a variety of components designed or specified by us that contain Conflict Minerals that are necessary to their functionality or production (the “Covered Products”). The components are manufactured by several third-party suppliers that have been qualified and approved by us and then assembled by our contract manufacturers.

The Company’s Reasonable Country-of-Origin Inquiry and Due Diligence Process

The Company’s supply chain with respect to the Covered Products is complex, and its manufacturing process is significantly removed from the mining, smelting and refining of Conflict Minerals. In this regard, the Company does not purchase Conflict Minerals directly from mines, smelters or refiners, 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. 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. However, tracing these minerals to their sources is a challenge that requires the Company to rely on its suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. Moreover, because of the Company’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited. Accordingly, the Company can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals in the Covered Products.
 

As described below, for Covered Products the manufacture of which was completed during the Reporting Period, Abaxis has undertaken a RCOI and due diligence on the source and chain of custody of the Conflict Minerals that were included in those products. To perform its RCOI and supply chain due diligence, the Company surveyed its suppliers using the Conflict Minerals Reporting Template (the “Template”) developed by the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (“EICC-GeSI”) available through the Conflict-Free Sourcing Initiative (“CFSI”). The Template facilitates the transfer of information through the supply chain regarding country of origin and smelters and refiners, including suppliers’ conflict-free policies and information regarding their engagement with lower-tier suppliers.

Reasonable Country-of-Origin Inquiry

The Company has conducted a good faith RCOI that was reasonably designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Using the Template, Abaxis conducted a survey of all suppliers that provided components or parts the Company reasonably believed were likely to contain 3TG. Because, as a result of its RCOI, the Company was unable to determine the country of origin of all Conflict Minerals in its supply chain, the Company also performed due diligence on the source and chain of custody to determine whether the Conflict Minerals directly or indirectly financed or benefitted armed groups in the Covered Countries.

Design of Due Diligence

The Company’s due diligence process has been designed to conform to the framework developed by The Organisation of Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”), consistent with the Company’s position as a downstream company.

Description of Due Diligence Measures

The Company’s due diligence on the source and chain of custody of the Conflict Minerals contained in the Covered Products included the following measures:

Establish Strong Management Systems

· Conflict Minerals Policy. The Company has adopted a conflict minerals policy (the “Company Policy”), which provides in part as follows:

We support the objectives underlying Section 1502 and the efforts being made to reduce the risk that trade in conflict minerals contributes to this humanitarian crisis. We have initiated a process to comply with the SEC rules. In particular, we are taking steps to (1) conduct due diligence regarding the origin of any conflict minerals in our supply chain and enhance our supply chain internal controls; (2) strive to eliminate conflict minerals that may be supporting the conflict in the DRC; and (3) notify our suppliers of our policy on conflict minerals and encourage them to make similar commitments and take similar measures. We are in the process of determining the exposure of our supply chain to conflict minerals mined in conditions of armed conflict and human rights abuses and following an internationally recognized due diligence framework to understand and minimize our risk. However, the global supply chain for these minerals is complex, and tracing these minerals to their sources is a challenge. To meet that challenge, we must rely on the cooperation of our suppliers. To help us adhere to our policy, implement the tracking process and meet our SEC reporting obligations, we expect our suppliers to respond to our queries about purchased components on a timely basis, including assistance in reaching out to their suppliers when necessary to trace the source of minerals and regular communications with us about supplier’s conflict minerals tracking and tracing efforts. In addition, we are taking steps to encourage our suppliers to commit to responsible “conflict-free” sourcing to prevent directly or indirectly contributing to armed conflicts and human rights abuses. If conflict minerals are identified in our supply chain, we plan to work with our suppliers to determine if practical conflict-free sources certified under the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative (EICC/GeSI) Conflict-Free Smelter Program, are available and work to qualify those sources.
 
2

This policy will be regularly reviewed and updated as needed. The Company has posted the Company Policy on its website (http://www.abaxis.com/investor_relations/supply-chain-policy-and-supplier-guidelines.html). The Company has also advised its suppliers about the Company Policy and has encouraged them to adopt similar policies.

· Conflict Minerals Team. Abaxis has identified an internal Conflict Minerals Rule compliance team consisting of a cross-functional group that includes representatives from manufacturing/engineering, purchasing/procurement and finance. The compliance team is responsible for developing and implementing the Company’s compliance program.

· Strengthen Engagement with Suppliers. The Company enhanced its engagement with its suppliers principally by communicating to suppliers, information and guidance regarding the Company’s requirements under the SEC’s Conflict Minerals rules, as well as the standards and expectations set forth in the Company Policy.

· Grievance Mechanism. The Company’s Corporate Governance policies include a whistleblower hotline for reporting any grievances, including issues concerning the Company’s Conflict Minerals compliance.

Identify and Assess Risks in the Supply Chain

· Identification of Supply Chain Risk. To identify the risk in the supply chain, consistent with the approach taken for the RCOI, the Company reviewed the Templates and other information provided by the suppliers that responded to the survey. All suppliers surveyed responded to the Company’s inquiry.  However, the responses contained varying degrees of information regarding the names and locations of 3TG smelters or refiners in the suppliers’ respective supply chains. The Company assessed the reasonableness of the representations made, reviewing the responses against criteria it developed to determine which responses required further engagement with suppliers. These criteria included untimely or incomplete responses as well as inconsistencies or other apparent inaccuracies within the data reported. Where necessary, the Company contacted suppliers for follow-up, clarification or additional information.
 
3

· Risk Assessment. To the extent that suppliers identified smelters and refiners in the supply chain, the Company took steps to assess the risk that the Conflict Minerals directly or indirectly financed or benefitted armed groups in the Covered Countries. To that end, the Company evaluated suppliers’ stated responses regarding the locations of origin of the Conflict Minerals as well as the mine locations. In particular, the Company compared the smelters and refiners identified by its surveyed suppliers against currently available independently verified lists of compliant smelters or refiners such as the CFSI’s Conflict-Free Smelter Program (“CFSP”) – Compliant Refiners/Smelters, the Responsible Jewellery Council (RJC) – Chain of Custody Certified Entities and the London Bullion Market Association (LBMA) – Good Delivery List. Generally, these programs identify smelters and refiners that an independent third-party audit has confirmed have systems in place designed to assure sourcing of only conflict-free minerals.

Carry Out Independent Third-Party Audit of Supply Chain

The Company does not have any direct relationships with smelters or refiners that process Conflict Minerals, and it does not perform or direct audits of these entities within its supply chain.  As an alternative, the Company has relied on audit results and information collected and provided by independent third-party audit programs, such as the CFSP.

Report Annually on Supply Chain Due Diligence

The Company expects to report annually, as required by the Rule, and has posted this Report on its website.

Risk Mitigation and Future Due Diligence Measures

As noted above, Abaxis adopted the Company Policy and strives to take steps to ensure that Conflict Minerals contained in its products are sourced with due respect for human rights, avoid contributing to conflict, and support development through responsible supply chain practices.

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

· Enhancing supply chain transparency by continuing to engage with suppliers to obtain current, accurate and complete information about the supply chain; and

· Encouraging suppliers to implement responsible sourcing and to request that they encourage smelters and refiners to obtain a “conflict-free” designation from a recognized third-party auditor through a program such as the CFSP and other industry-sponsored programs.

Results of Due Diligence

Although some suppliers were unable to identify the smelters or refiners or the mine locations, the suppliers who were able to identify the smelters and refiners in their supply chains provided lists of smelters or refiners at product-level. For the calendar year 2014, the Company’s suppliers identified 605 3TG smelters or refiners at product-level. Of these, 304 facilities were not confirmed to be actual smelters or refiners, based on the list of “all known conflict mineral processing facilities worldwide” developed by the U.S. Department of Commerce. Of the 301 facilities the Company believes were actual smelters or refiners, 161 or 53% were identified by one of the programs above as certified conflict-free based on currently available independently verified lists of compliant smelters or refiners.
 
4

Identified Smelters and Refiners

As noted above, not all of the Company’s suppliers were able to identify smelters and refiners either at company-level or product-level. Moreover, there were facilities identified by suppliers that were not identified as actual smelters or refiners on the list developed by the U.S. Department of Commerce. As a result, at this point, the Company does not believe that it can reliably identify all smelters and/or refiners in its supply chain and, therefore, has presented in Table I of this CMR, only the 301 facilities believed to be actual smelters or refiners and that were identified by suppliers that provided product-level information.

Identified Countries of Origin

Based on the above-described due diligence process, the Company does not have sufficient information to conclusively determine the countries of origin of the 3TG in each of the Covered Products or whether the 3TG were from scrap or recycled sources. However, based on the information provided by the suppliers, as well as from other sources such as CFSI, RJC and LBMA, the Company believes that the countries of origin of the 3TG contained in the Covered Products include the countries listed in Table II of this this CMR. In compiling this list, the Company included all of the countries of origin identified by suppliers that provided product-level information, consistent with the Company’s approach with respect to smelters and refiners.

Efforts to Determine Mine or Location of Origin

To determine the mines or location of origin of the Conflict Minerals with the greatest possible specificity, the Company performed the due diligence measures described above.

Cautionary Note on Forward-Looking Statements

Forward-looking statements in this CMR are made pursuant to the safe harbor provisions of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this CMR that are not strictly historical statements, including without limitation, the Company’s intentions and expectations regarding further supplier engagement, due diligence, and risk mitigation efforts and strategy, constitute forward-looking statements that involve risks and uncertainties. Words such as “expects,” “anticipates,” “goals,” “strives,” “intends,” “plans,” “believes,” “seeks,” variations of these words, and similar expressions are intended to identify such forward-looking statements. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on the Company’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others.
 
5

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Gold
 
Aida Chemical Industries Co. Ltd.
 
JAPAN
Gold
 
Allgemeine Gold-und Silberscheideanstalt A.G.
 
GERMANY
Gold
 
Almalyk Mining and Metallurgical Complex (AMMC)
 
UZBEKISTAN
Gold
 
AngloGold Ashanti Córrego do Sítio Minerção
 
BRAZIL
Gold
 
Argor-Heraeus SA
 
SWITZERLAND
Gold
 
Asahi Pretec Corporation
 
JAPAN
Gold
 
Asaka Riken Co Ltd
 
JAPAN
Gold
 
Asarco
 
UNITED STATES
Gold
 
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
 
TURKEY
Gold
 
Aurubis AG
 
GERMANY
Gold
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
 
PHILIPPINES
Gold
 
Bauer Walser AG
 
GERMANY
Gold
 
Boliden AB
 
SWEDEN
Gold
 
C. Hafner GmbH + Co. KG
 
GERMANY
Gold
 
Caridad
 
MEXICO
Gold
 
CCR Refinery – Glencore Canada Corporation / Xstrata Canada Corportion
 
CANADA
Gold
 
Cendres + Métaux SA
 
SWITZERLAND
Gold
 
Chimet S.p.A.
 
ITALY
Gold
 
China National Gold Group Corporation
 
CHINA
Gold
 
Chugai Mining
 
JAPAN
Gold
 
Codelco
 
CHILE
Gold
 
Colt Refining
 
UNITED STATES
Gold
 
Daejin Indus Co. Ltd
 
REPUBLIC OF KOREA
Gold
 
Daye Non-Ferrous Metals Mining Ltd.
 
CHINA
Gold
 
Do Sung Corporation
 
REPUBLIC OF KOREA
Gold
 
Doduco
 
GERMANY
Gold
 
Dowa
 
JAPAN
Gold
 
Eco-System Recycling Co., Ltd.
 
JAPAN
Gold
 
FSE Novosibirsk Refinery
 
RUSSIAN FEDERATION
Gold
 
Gansu Seemine Material Hi-Tech Co Ltd
 
CHINA
Gold
 
Guangdong Jinding Gold Limited
 
CHINA
Gold
 
Hangzhou Fuchunjiang Smelting Co., Ltd.
 
CHINA
Gold
 
Heimerle + Meule GmbH
 
GERMANY
Gold
 
Heraeus Ltd. Hong Kong
 
HONG KONG
Gold
 
Heraeus Precious Metals GmbH & Co. KG
 
GERMANY
Gold
 
Hunan Chenzhou Mining Group Co., Ltd.
 
CHINA
Gold
 
Hwasung CJ Co. Ltd
 
REPUBLIC OF KOREA
Gold
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
 
CHINA
Gold
 
Ishifuku Metal Industry Co., Ltd.
 
JAPAN
Gold
 
Istanbul Gold Refinery
 
TURKEY
Gold
 
Japan Mint
 
JAPAN
Gold
 
Jiangxi Copper Company Limited
 
CHINA
Gold
 
Johnson Matthey Inc
 
UNITED STATES
Gold
 
Johnson Matthey Ltd
 
CANADA
Gold
 
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
 
RUSSIAN FEDERATION
 
6

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Gold
 
JSC Uralelectromed
 
RUSSIAN FEDERATION
Gold
 
JX Nippon Mining & Metals Co., Ltd.
 
JAPAN
Gold
 
Kazzinc Ltd
 
KAZAKHSTAN
Gold
 
Kennecott Utah Copper LLC
 
UNITED STATES
Gold
 
Kojima Chemicals Co., Ltd
 
JAPAN
Gold
 
Korea Metal Co. Ltd
 
REPUBLIC OF KOREA
Gold
 
Kyrgyzaltyn JSC
 
KYRGYZSTAN
Gold
 
L' azurde Company For Jewelry
 
SAUDI ARABIA
Gold
 
Lingbao Gold Company Limited
 
CHINA
Gold
 
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
 
CHINA
Gold
 
LS-NIKKO Copper Inc.
 
REPUBLIC OF KOREA
Gold
 
Luoyang Zijin Yinhui Metal Smelt Co Ltd
 
CHINA
Gold
 
Materion
 
UNITED STATES
Gold
 
Matsuda Sangyo Co., Ltd.
 
JAPAN
Gold
 
Metalor Technologies (Hong Kong) Ltd
 
HONG KONG
Gold
 
Metalor Technologies (Singapore) Pte. Ltd.
 
SINGAPORE
Gold
 
Metalor Technologies (Suzhou) Ltd.
 
CHINA
Gold
 
Metalor Technologies SA
 
SWITZERLAND
Gold
 
Metalor USA Refining Corporation
 
UNITED STATES
Gold
 
Met-Mex Peñoles, S.A.
 
MEXICO
Gold
 
Mitsubishi Materials Corporation
 
JAPAN
Gold
 
Mitsui Mining and Smelting Co., Ltd.
 
JAPAN
Gold
 
Moscow Special Alloys Processing Plant
 
RUSSIAN FEDERATION
Gold
 
Nadir Metal Rafineri San. Ve Tic. A.Ş.
 
TURKEY
Gold
 
Navoi Mining and Metallurgical Combinat
 
UZBEKISTAN
Gold
 
Nihon Material Co. LTD
 
JAPAN
Gold
 
Ohio Precious Metals, LLC
 
UNITED STATES
Gold
 
Ohura Precious Metal Industry Co., Ltd
 
JAPAN
Gold
 
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
 
RUSSIAN FEDERATION
Gold
 
OJSC Kolyma Refinery
 
RUSSIAN FEDERATION
Gold
 
PAMP SA
 
SWITZERLAND
Gold
 
Penglai Penggang Gold Industry Co Ltd
 
CHINA
Gold
 
Prioksky Plant of Non-Ferrous Metals
 
RUSSIAN FEDERATION
Gold
 
PT Aneka Tambang (Persero) Tbk
 
INDONESIA
Gold
 
PX Précinox SA
 
SWITZERLAND
Gold
 
Rand Refinery (Pty) Ltd
 
SOUTH AFRICA
Gold
 
Royal Canadian Mint
 
CANADA
Gold
 
Sabin Metal Corp.
 
UNITED STATES
Gold
 
Samduck Precious Metals
 
REPUBLIC OF KOREA
Gold
 
SAMWON METALS Corp.
 
REPUBLIC OF KOREA
Gold
 
Schone Edelmetaal
 
NETHERLANDS
Gold
 
SEMPSA Joyería Platería SA / Cookson
 
SPAIN
Gold
 
Shandong Zhaojin Gold & Silver Refinery Co. Ltd
 
CHINA
Gold
 
So Accurate Group, Inc.
 
UNITED STATES
Gold
 
SOE Shyolkovsky Factory of Secondary Precious Metals
 
RUSSIAN FEDERATION
 
7

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Gold
 
Solar Applied Materials Technology Corp.
 
TAIWAN
Gold
 
Sumitomo Metal Mining Co., Ltd. / Niihama Nickel Refinery
 
JAPAN
Gold
 
Tanaka Kikinzoku Kogyo K.K.
 
JAPAN
Gold
 
The Great Wall Gold and Silver Refinery of China
 
CHINA
Gold
 
The Refinery of Shandong Gold Mining Co. Ltd
 
CHINA
Gold
 
Tokuriki Honten Co., Ltd
 
JAPAN
Gold
 
Tongling nonferrous Metals Group Co.,Ltd
 
CHINA
Gold
 
Torecom
 
REPUBLIC OF KOREA
Gold
 
Umicore Brasil Ltda
 
BRAZIL
Gold
 
Umicore Precious Metals Thailand
 
THAILAND
Gold
 
Umicore SA Business Unit Precious Metals Refining
 
BELGIUM
Gold
 
United Precious Metal Refining, Inc.
 
UNITED STATES
Gold
 
Valcambi SA
 
SWITZERLAND
Gold
 
Western Australian Mint trading as The Perth Mint
 
AUSTRALIA
Gold
 
YAMAMOTO PRECIOUS METAL CO., LTD.
 
JAPAN
Gold
 
Yokohama Metal Co Ltd
 
JAPAN
Gold
 
Yunnan Copper Industry Co Ltd
 
CHINA
Gold
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
 
CHINA
Gold
 
Zijin Mining Group Co. Ltd
 
CHINA
Tantalum
 
Changsha South Tantalum Niobium Co., Ltd.
 
CHINA
Tantalum
 
Conghua Tantalum and Niobium Smeltry
 
CHINA
Tantalum
 
Duoluoshan
 
CHINA
Tantalum
 
Exotech Inc.
 
UNITED STATES
Tantalum
 
F&X Electro-Materials Ltd.
 
CHINA
Tantalum
 
Gannon & Scott
 
UNITED STATES
Tantalum
 
Global Advanced Metals Aizu
 
JAPAN
Tantalum
 
Global Advanced Metals Boyertown
 
UNITED STATES
Tantalum
 
Guangdong Zhiyuan New Material Co., Ltd.
 
CHINA
Tantalum
 
H.C. Starck Co., Ltd.
 
THAILAND
Tantalum
 
H.C. Starck GmbH Goslar
 
GERMANY
Tantalum
 
H.C. Starck GmbH Laufenburg
 
GERMANY
Tantalum
 
H.C. Starck Hermsdorf GmbH
 
GERMANY
Tantalum
 
H.C. Starck Inc.
 
UNITED STATES
Tantalum
 
H.C. Starck Ltd.
 
JAPAN
Tantalum
 
H.C. Starck Smelting GmbH & Co.KG
 
GERMANY
Tantalum
 
Hengyang King Xing Lifeng New Materials Co., Ltd.
 
CHINA
Tantalum
 
Hi-Temp
 
UNITED STATES
Tantalum
 
Jiangxi Dinghai Tantalum & Niobium Co., LTD
 
CHINA
Tantalum
 
JiuJiang JinXin Nonferrous Metals Co., Ltd.
 
CHINA
Tantalum
 
Jiujiang Tanbre Co., Ltd.
 
CHINA
Tantalum
 
Jiujiang Zhongao Tantalum & Niobium Co, Ltd
 
CHINA
Tantalum
 
KEMET Blue Metals
 
MEXICO
Tantalum
 
KEMET Blue Powder
 
UNITED STATES
Tantalum
 
King-Tan Tantalum Industry Ltd
 
CHINA
Tantalum
 
LSM Brasil S.A.
 
BRAZIL
 
8

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Tantalum
 
Metallurgical Products India (Pvt.) Ltd.
 
INDIA
Tantalum
 
Mineração Taboca S.A.
 
BRAZIL
Tantalum
 
Mitsui Mining & Smelting
 
JAPAN
Tantalum
 
Molycorp Silmet A.S.
 
ESTONIA
Tantalum
 
Ningxia Orient Tantalum Industry Co., Ltd.
 
CHINA
Tantalum
 
Plansee SE Liezen
 
AUSTRIA
Tantalum
 
Plansee SE Reutte
 
AUSTRIA
Tantalum
 
QuantumClean
 
UNITED STATES
Tantalum
 
RFH Tantalum Smeltry Co., Ltd
 
CHINA
Tantalum
 
Shanghai Jiangxi Metals Co. Ltd
 
CHINA
Tantalum
 
Solikamsk Magnesium Works OAO
 
RUSSIAN FEDERATION
Tantalum
 
Taki Chemicals
 
JAPAN
Tantalum
 
Tantalite Resources
 
SOUTH AFRICA
Tantalum
 
Telex
 
UNITED STATES
Tantalum
 
Ulba
 
KAZAKHSTAN
Tantalum
 
Yichun Jin Yang Rare Metal Co., Ltd
 
CHINA
Tantalum
 
Zhuzhou Cement Carbide
 
CHINA
Tin
 
Alpha / Cookson
 
UNITED STATES
Tin
 
Amalgamated Metal Corporation PLC
 
INDONESIA
Tin
 
Amalgamet Inc
 
PERU
Tin
 
China Rare Metal Materials Company
 
CHINA
Tin
 
China Tin Group Co., Ltd. / Liuzhou China Tin
 
CHINA
Tin
 
CNMC (Guangxi) PGMA Co. Ltd.
 
CHINA
Tin
 
Cooper Santa
 
BRAZIL
Tin
 
CV Duta Putra Bangka
 
INDONESIA
Tin
 
CV JusTindo
 
INDONESIA
Tin
 
CV Makmur Jaya
 
INDONESIA
Tin
 
CV Nurjanah
 
INDONESIA
Tin
 
CV Serumpun Sebalai
 
INDONESIA
Tin
 
CV United Smelting
 
INDONESIA
Tin
 
Dowa
 
JAPAN
Tin
 
Electroloy Metal Pte.
 
SINGAPORE
Tin
 
EM Vinto
 
BOLIVIA
Tin
 
Estanho de Rondônia S.A.
 
BRAZIL
Tin
 
Fenix Metals
 
POLAND
Tin
 
FSE Novosibirsk Refinery
 
RUSSIAN FEDERATION
Tin
 
Gejiu Kai Meng Industry and Trade LLC
 
CHINA
Tin
 
Gejiu Non-Ferrous Metal Processing Co. Ltd.
 
CHINA
Tin
 
Gejiu Zi-Li
 
CHINA
Tin
 
Guangxi China Tin Group Co., Ltd
 
CHINA
Tin
 
Guangxi Pinggui PGMA Co. Ltd.
 
CHINA
Tin
 
Heraeus Materials Singapore Pte. Ltd.
 
SINGAPORE
Tin
 
Huichang Jinshunda Tin Co. Ltd
 
CHINA
Tin
 
Hyundai-Steel
 
REPUBLIC OF KOREA
Tin
 
Jean Goldschmidt International
 
BELGIUM
 
9

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Tin
 
Jiangxi Nanshan
 
CHINA
Tin
 
Kovohute Pribram Nastupnicka, A.S.
 
CZECH REPUBLIC
Tin
 
Lai'bin China Tin Smelting Ltd.
 
CHINA
Tin
 
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
 
CHINA
Tin
 
Linwu Xianggui Smelter Co
 
CHINA
Tin
 
Magnu's Minerais Metais e Ligas LTDA
 
BRAZIL
Tin
 
Malaysia Smelting Corporation (MSC)
 
MALAYSIA
Tin
 
Melt Metais e Ligas S/A
 
BRAZIL
Tin
 
Metallo Chimique
 
BELGIUM
Tin
 
Mineração Taboca S.A.
 
BRAZIL
Tin
 
Minsur
 
PERU
Tin
 
Mitsubishi Materials Corporation
 
JAPAN
Tin
 
Novosibirsk Integrated Tin Works
 
RUSSIAN FEDERATION
Tin
 
O.M. Manufacturing (Thailand) Co., Ltd.
 
THAILAND
Tin
 
O.M. Manufacturing Philippines, Inc.
 
PHILIPPINES
Tin
 
Ohio Precious Metals, LLC
 
UNITED STATES
Tin
 
OMSA
 
BOLIVIA
Tin
 
Poongsan Corporation
 
REPUBLIC OF KOREA
Tin
 
Posco
 
REPUBLIC OF KOREA
Tin
 
PT Alam Lestari Kencana
 
INDONESIA
Tin
 
PT Artha Cipta Langgeng
 
INDONESIA
Tin
 
PT Babel Inti Perkasa
 
INDONESIA
Tin
 
PT Babel Surya Alam Lestari
 
INDONESIA
Tin
 
PT Bangka Kudai Tin
 
INDONESIA
Tin
 
PT Bangka Putra Karya
 
INDONESIA
Tin
 
PT Bangka Timah Utama Sejahtera
 
INDONESIA
Tin
 
PT Bangka Tin Industry
 
INDONESIA
Tin
 
PT Belitung Industri Sejahtera
 
INDONESIA
Tin
 
PT BilliTin Makmur Lestari
 
INDONESIA
Tin
 
PT Bukit Timah
 
INDONESIA
Tin
 
PT DS Jaya Abadi
 
INDONESIA
Tin
 
PT Eunindo Usaha Mandiri
 
INDONESIA
Tin
 
PT Fang Di MulTindo
 
INDONESIA
Tin
 
PT HP Metals Indonesia
 
INDONESIA
Tin
 
PT Karimun Mining
 
INDONESIA
Tin
 
PT Koba Tin
 
INDONESIA
Tin
 
PT Mitra Stania Prima
 
INDONESIA
Tin
 
PT Panca Mega Persada
 
INDONESIA
Tin
 
PT Pelat Timah Nusantara Tbk
 
INDONESIA
Tin
 
PT Prima Timah Utama
 
INDONESIA
Tin
 
PT REFINED BANGKA TIN
 
INDONESIA
Tin
 
PT Sariwiguna Binasentosa
 
INDONESIA
Tin
 
PT Seirama Tin investment
 
INDONESIA
Tin
 
PT Stanindo Inti Perkasa
 
INDONESIA
Tin
 
PT Sumber Jaya Indah
 
INDONESIA
 
10

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Tin
 
PT Supra Sukses Trinusa
 
INDONESIA
Tin
 
PT Tambang Timah
 
INDONESIA
Tin
 
PT Timah (Persero), Tbk
 
INDONESIA
Tin
 
PT Tinindo Inter Nusa
 
INDONESIA
Tin
 
PT Yinchendo Mining Industry
 
INDONESIA
Tin
 
Pure Technology
 
RUSSIAN FEDERATION
Tin
 
Rahman Hydrulic Tin Sdn Bhd
 
MALAYSIA
Tin
 
Rui Da Hung
 
TAIWAN
Tin
 
Senju Metal Industry Co. (SMIC)
 
JAPAN
Tin
 
Shao Xing Tian Long Tin Materials Co. Ltd
 
CHINA
Tin
 
SMIC Senju  Malysia
 
MALAYSIA
Tin
 
Soft Metais, Ltda.
 
BRAZIL
Tin
 
Technic  Inc.
 
UNITED STATES
Tin
 
Thaisarco
 
THAILAND
Tin
 
Umicore Haboken
 
BELGIUM
Tin
 
White Solder Metalurgia e Mineração Ltda.
 
BRAZIL
Tin
 
Yokohama Metal Co Ltd
 
JAPAN
Tin
 
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
 
CHINA
Tin
 
Yunnan Tin Company, Ltd.
 
CHINA
Tin
 
ZhongShi Metal Co., Ltd
 
CHINA
Tin
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
 
CHINA
Tin
 
Zijin Copper Co. Ltd.
 
CHINA
Tungsten
 
A.L.M.T. Corp.
 
JAPAN
Tungsten
 
Air Products
 
UNITED STATES
Tungsten
 
Chaozhou Xianglu Tungsten Industry Co., Ltd.
 
CHINA
Tungsten
 
Chenzhou Diamond Tungsten Products Co., Ltd.
 
CHINA
Tungsten
 
China Minmetals Nonferrous Metals Co., Ltd.
 
CHINA
Tungsten
 
Chongyi Zhangyuan Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Dayu Weiliang Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Fujian Jinxin Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Grand Sea W & Mo Group Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Huaxing Tungsten Products Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Seadragon W & Mo Co., Ltd.
 
CHINA
Tungsten
 
Ganzhou Sinda W&Mo Co., Ltd.
 
CHINA
Tungsten
 
Global Tungsten & Powders Corp.
 
UNITED STATES
Tungsten
 
Guangdong Xianglu Tungsten Co., Ltd.
 
CHINA
Tungsten
 
H.C. Starck
 
UNITED STATES
Tungsten
 
H.C. Starck
 
RUSSIAN FEDERATION
Tungsten
 
H.C. Starck GmbH
 
GERMANY
Tungsten
 
H.C. Starck Smelting GmbH & Co.KG
 
GERMANY
Tungsten
 
Hunan Chenzhou Mining Group Co., Ltd.
 
CHINA
Tungsten
 
Hunan Chunchang Nonferrous Metals Co., Ltd.
 
CHINA
Tungsten
 
Japan New Metals Co., Ltd.
 
JAPAN
 
11

Table I. Names of Smelters or Refiners are believed to include:
   
         
Mineral
 
Smelter or Refiner Name
 
Smelter or Refiner Country Location
Tungsten
 
Jiangxi Gan Bei Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Rare Earth & Rare Metals Tungsten Group Corp.
 
CHINA
Tungsten
 
Jiangxi Richsea New Materials Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Tungsten Co Ltd
 
CHINA
Tungsten
 
Jiangxi Tungsten Industry Group Co Ltd
 
CHINA
Tungsten
 
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
 
CHINA
Tungsten
 
Jiangxi Yaosheng Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Kennametal Fallon
 
UNITED STATES
Tungsten
 
Kennametal Huntsville
 
UNITED STATES
Tungsten
 
Malipo Haiyu Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Metallo Chimique
 
BELGIUM
Tungsten
 
Mitsubishi Materials Corporation
 
JAPAN
Tungsten
 
Mitsui Mining & Smelting
 
JAPAN
Tungsten
 
Nanchang Cemented Carbide Limited Liability Company
 
CHINA
Tungsten
 
Ningxia Orient Tantalum Industry Co., Ltd.
 
CHINA
Tungsten
 
Plansee SE Liezen
 
AUSTRIA
Tungsten
 
Plansee SE Reutte
 
AUSTRIA
Tungsten
 
Solar Applied Materials Technology Corp.
 
TAIWAN
Tungsten
 
Sumitomo Metal Mining Co., Ltd.
 
JAPAN
Tungsten
 
TaeguTec Ltd.
 
REPUBLIC OF KOREA
Tungsten
 
Tejing (Vietnam) Tungsten Co., Ltd.
 
VIETNAM
Tungsten
 
Vietnam Youngsun Tungsten Industry Co., Ltd
 
VIETNAM
Tungsten
 
Wolfram Bergbau und Hütten AG
 
AUSTRIA
Tungsten
 
Wolfram Company CJSC
 
RUSSIAN FEDERATION
Tungsten
 
Xiamen Honglu Tungsten Molybdenum Industry Co., Ltd.
 
CHINA
Tungsten
 
Xiamen Tungsten (H.C.) Co., Ltd.
 
CHINA
Tungsten
 
Xiamen Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
 
CHINA
Tungsten
 
Zhuzhou Cement Carbide
 
CHINA
 
12

Table II. Countries of Origin of Conflict Minerals are believed to include:
     
Countries of Origin
 
 
AUSTRALIA
 
MEXICO
AUSTRIA
 
NETHERLANDS
BELGIUM
 
PERU
BOLIVIA
 
PHILIPPINES
BRAZIL
 
POLAND
CANADA
 
REPUBLIC OF KOREA
CHILE
 
RUSSIAN FEDERATION
CHINA
 
SAUDI ARABIA
CZECH REPUBLIC
 
SINGAPORE
ESTONIA
 
SOUTH AFRICA
GERMANY
 
SPAIN
HONG KONG
 
SWEDEN
INDIA
 
SWITZERLAND
INDONESIA
 
TAIWAN
ITALY
 
THAILAND
JAPAN
 
TURKEY
KAZAKHSTAN
 
UNITED STATES
KYRGYZSTAN
 
UZBEKISTAN
MALAYSIA
 
VIETNAM
 
 
13

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