United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Colfax Corporation
(Exact name of registrant as specified in its charter)
Delaware | 001-34045 | 54-1887631 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||
420 National Business Parkway, 5th Floor Annapolis Junction, Maryland | 20701 | |
(Address of principal executive offices) | (Zip Code) | |
A. Lynne Puckett, Senior Vice President, General Counsel & Secretary
(301) 323-9000
(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 31, 2014. |
Section 1—Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
As required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following Internet website: http://ir.colfaxcorp.com/governance.cfm. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2—Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – | Conflict Minerals Report for the calendar year ended December 31, 2014 | |
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.
COLFAX CORPORATION | |||||||||||
By: | /s/ Stephen Wittig | Date: June 1, 2015 | |||||||||
Name: | Stephen Wittig | ||||||||||
Title: | Senior Vice President, CBS and Supply Chain | ||||||||||
EXHIBIT INDEX
Exhibit | Description | |
1.01 | Conflict Minerals Report for the calendar year ended December 31, 2014 | |
Exhibit 1.01
Conflict Minerals Report
Colfax Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for 2014 as required by Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is June 1, 2015.
Unless the context indicates otherwise, the terms “we,” “its,” “us,” and “our” refer to Colfax Corporation and its consolidated subsidiaries. As used herein, “Conflict Minerals” are columbite-tantalite (coltan), cassiterite, gold, wolframite and the derivatives tantalum, tin and tungsten, without regard to the location of origin.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary Conflict Minerals benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source Conflict Minerals, and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
Applicability of the Conflict Minerals Rule to Our Company
Our products include: a broad range of gas- and fluid-handling products, including pumps, fluid-handling systems and controls, specialty valves, heavy-duty centrifugal and axial fans, rotary heat exchangers and gas compressors; and welding equipment, cutting equipment and automated welding and cutting systems. We are subject to the Conflict Minerals Rule because products that we manufacture contain Conflict Minerals that are necessary to their functionality or production.
We generally do not source Conflict Minerals from smelters or refiners and have no direct relationships with mines, and we believe that we are in most cases many levels removed from all of these market participants. We therefore have limited influence over these upstream actors. Furthermore, because of the depth, breadth and constant evolution of our supply chain and competitive factors affecting our supplier base, we have difficulty identifying actors upstream from our direct suppliers. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below, and encourage conflict free sourcing in our supply chain.
For 2014, each of our in-scope products contained Conflict Minerals content for which we were unable to determine the origin. Product, smelter and refiner information in respect of 2014 is described under "Product Information" below and on Annex A. None of the necessary Conflict Minerals contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were "DRC conflict free." The terms “adjoining country,” “armed group” and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.
Our Conflict Minerals Policy
We are committed to being a responsible corporate citizen and are opposed to human rights abuses such as are occurring in the DRC. To this end, we have adopted and communicated to our suppliers and the public a company policy (the “Conflict Minerals Policy”) for the supply chain of Conflict Minerals. The Conflict Minerals Policy includes, but is not limited to, our expectations that:
1. | The components, parts and products supplied to us are DRC conflict free within the meaning of the Conflict Minerals Rule; | |
2. | Our suppliers define, implement and communicate to sub-suppliers their own Conflict Minerals policy consistent with our Conflict Minerals Policy and the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”); and | |
3. | Our suppliers implement policies, procedures and frameworks that are consistent with the OECD Guidance and require their direct and indirect sub-suppliers to do the same, and that our suppliers otherwise work with sub-suppliers to ensure traceability of Conflict Minerals. | |
Reasonable Country of Origin Inquiry Information
As required by the Conflict Minerals Rule, for 2014, we conducted a "reasonable country of origin inquiry." Our inquiry included approximately 6,908 suppliers (the "Suppliers") that we identified as having provided us with components, parts or products that contain Conflict Minerals or that we believe may have provided us with components, parts or products that contain Conflict Minerals.
For 2014, the Suppliers identified to us 314 smelters and refiners that processed or may have processed the necessary Conflict Minerals contained in our in-scope products, as shown and described under Annex A below. These smelters and refiners include 160 smelters and refiners identified as “Compliant” as defined in Annex A, This information is based primarily on company-level declarations from Suppliers. Accordingly, many of these smelters and refiners may not be part of our supply chain.
Pursuant to the Conflict Minerals Rule, based on the results of our reasonable country of origin inquiry, we were required to conduct due diligence for 2014. These due diligence efforts are discussed below.
For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures as for our due diligence.
Due Diligence Program Design
Design Framework
We designed our due diligence measures relating to Conflict Minerals to conform with, in all material respects, the criteria set forth in the OECD Guidance, Second Edition 2013 (hereinafter referred to as the "OECD Guidance").
Selected Elements of Design Framework
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the elements of the program that we have put in place to help ensure that the Conflict Minerals contained in our in-scope products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2014 are discussed under "Due Diligence Program Execution."
1. | OECD Guidance Step One: “Establish strong company management systems” | |
a. | We have a Conflict Minerals Policy. We communicate the policy internally to our sourcing teams and to selected suppliers. The Conflict Minerals Policy also is posted on our website. | |
b. | We have a team of senior staff under the Senior Vice President, Colfax Business System (“CBS”) and Supply Chain and General Counsel charged with managing our Conflict Minerals compliance strategy. The working group also includes representatives from each business platform. We supplement our compliance efforts with specialist outside counsel. | |
c. | Selected internal personnel are educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. | |
d. | We utilize the Conflict Minerals Reporting Template (the "CMRT") developed by the Conflict-Free Sourcing Initiative (the "CFSI") to identify smelters and refiners in our supply chain. The CMRT requests suppliers to provide information concerning the usage and source of Conflict Minerals in their products, as well as information concerning their related compliance efforts. We utilize a third-party service provider (the "Service Provider") to conduct our supplier outreach and follow-up, as well as for the review and validation of supplier responses. | |
e. | We maintain business records relating to Conflict Minerals due diligence, including records of due diligence processes, findings and resulting decisions, for at least five years. | |
f. | The Service Provider provides training and educational materials to suppliers to enhance the quality of responses. | |
g. | We have contractual terms relating to Conflict Minerals, which are incorporated into selected supplier contracts. | |
h. | We have a mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. | |
2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” | |
a. | We request in writing, through the Service Provider, that suppliers provide us with a completed CMRT. The Service Provider follows up by email or phone on our behalf with suppliers that do not respond to the request within the specified time frame. | |
b. | The Service Provider on our behalf reviews supplier responses against its written review criteria to identify incomplete responses, potential errors, inaccuracies and "red flags" in the CMRTs that are received from suppliers. The Service Provider follows up by email or phone with suppliers that submit an incomplete response or a response that it concludes contains errors or inaccuracies. | |
c. | Smelter and refiner information provided by suppliers is reviewed by the Service Provider against the smelters and refiners listed on the Standard Smelter Names tab of the CMRT and the list of known processing facilities published by the U.S. Department of Commerce (the "Commerce Department List"). To the extent that a smelter or refiner identified by a supplier is not on either of these lists, the Service Provider may take additional steps to attempt to determine whether the listed entity is a smelter or refiner. | |
d. | Smelter and refiner information also is reviewed against the lists of "compliant" and "active" smelters and refiners and country of origin information published by the CFSI. To the extent that a smelter or refiner identified by a supplier is not listed as compliant by the CFSI, the Service Provider consults publicly available information to attempt to determine whether that smelter or refiner obtained Conflict Minerals from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. | |
e. | The Service Provider evaluates suppliers on program strength based on the suppliers' responses to certain of the questions in the CMRT. | |
3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” | |
a. | Our Conflict Minerals compliance team reviews the reports and evaluations prepared by the Service Provider and liaises with appropriate members of senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence. | |
b. | We undertake additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries, and respond via supplier follow-up, commercial escalation or other commensurate means to the risks identified via these reviews. | |
4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” | |
In connection with our due diligence, we utilize information made available by the CFSI concerning independent third-party audits of smelters and refiners.
5. | OECD Guidance Step 5 : “Report on supply chain due diligence” | |
We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission and make these filings available on our website.
Due Diligence Program Execution
We performed the following due diligence measures in respect of 2014. These are not all of the measures that we took in furtherance of our Conflict Minerals Policy and Conflict Minerals compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, see "Due Diligence Program Design."
1. | The Service Provider requested that the Suppliers provide us with a completed Conflict Minerals Reporting Template. Requests were sent to approximately 6,908 suppliers. The Service Provider generally followed up by email or phone with Suppliers that did not respond to the request within a specified time frame. |
2. | The Service Provider reviewed the responses received from the Suppliers based on its written review criteria for completeness, errors, inaccuracies and "red flags." The Service Provider generally followed up by email or phone with the Suppliers that submitted a response that triggered specified quality issues relating to completeness and accuracy. |
3. | To the extent that a completed response identified a smelter or refiner, the Service Provider reviewed that information against the lists of compliant and active smelters published by the CFSI. 160 of the identified smelters and refiners were listed as compliant by the CFSI and 49 were listed as active, as of May 1, 2015. Please see Annex A below for further information regarding the smelters and refiners identified to us through our reasonable county of origin inquiry and due diligence. |
4. | To the extent that a smelter or refiner identified by a Supplier was not listed as compliant by the CFSI, the Service Provider attempted to contact the smelter or refiner and/or consulted publicly available information to attempt to determine whether that smelter or refiner obtained Conflict Minerals from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. |
5. | Our Conflict Minerals compliance team reviewed the reports and evaluations prepared by the Service Provider and liaised with members of our senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence |
6. | We undertook additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries. |
Product Information
Our in-scope product categories for 2014 were: (1) gas- and fluid-handling products, consisting of pumps, fluid-handling systems and controls, specialty valves, heavy-duty centrifugal and axial fans, rotary heat exchangers and gas compressors; and (2) welding equipment, cutting equipment and automated welding and cutting systems. For a further discussion of our products, see our Annual Report on Form 10-K for the year ended December 31, 2014. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or the Form SD.
Due to the challenges of gathering information from a large, diverse and dynamic supply chain, for 2014, notwithstanding our due diligence efforts, we were unable to determine the country of origin of the necessary Conflict Minerals contained in our in-scope products and at least some of the smelters and refiners of the Conflict Minerals in each of our in-scope products. Identified smelters and refiners are discussed below and on Annex A. For 2014, none of the necessary Conflict Minerals contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were "DRC conflict free." An “armed group” under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to the Democratic Republic of the Congo or an adjoining country.
Identified Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the facilities listed on Annex A below either as part of our supply chain or as potentially having processed the necessary Conflict Minerals contained in our in-scope products in 2014. Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary Conflict Minerals contained in our in-scope products.
Please see Annex A below for further information regarding the smelters and refiners identified to us by the Suppliers.
We endeavored to determine the mine or location of origin of the Conflict Minerals contained in our in-scope products by requesting that the Suppliers provide us or our Service Provider with a completed CMRT, and through the other activities described herein that were taken by us or the Service Provider.
Future Risk Mitigation Efforts
We intend to take the following additional steps to mitigate the risk that the necessary Conflict Minerals in our in-scope products benefit armed groups. These steps are in addition to the steps that we took in respect of 2014, which we intend to continue to take in respect of 2015 to the extent applicable.
1. | Engage with applicable Suppliers that provided incomplete responses or that did not provide responses for 2014 to help ensure that they provide requested information for 2015. | |
2. | Encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2014 that the source of Conflict Minerals was unknown or undeterminable. | |
3. | Continue communicating to suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them and required adherence to contractual sourcing requirements. | |
4. | Use Revision 4.0 of the CMRT for our 2015 supplier outreach. | |
Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below as either being part of our supply chain or as potentially having processed the necessary Conflict Minerals contained in our in-scope products in 2014. Please see the notes that accompany the tables for additional information concerning the information in the tables.
Summary Smelter and Refiner Information
Metal | Compliant | Active | Known | Total | ||
Tantalum | 44 | 1 | 1 | 46 | ||
Tin | 35 | 16 | 45 | 96 | ||
Tungsten | 13 | 25 | 16 | 54 | ||
Gold | 68 | 7 | 43 | 118 | ||
Totals | 160 | 49 | 105 | 314 | ||
Smelter and Refiner Names and Status
Metal | Standard Smelter Name | CFSI Audit Status |
Gold | Aida Chemical Industries Co. Ltd. | Compliant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Compliant |
Gold | AngloGold Ashanti Córrego do Sítio Minerção | Compliant |
Gold | Argor-Heraeus SA | Compliant |
Gold | Asahi Pretec Corporation | Compliant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Compliant |
Gold | Aurubis AG | Compliant |
Gold | Boliden AB | Compliant |
Gold | C. Hafner GmbH + Co. KG | Compliant |
Gold | CCR Refinery – Glencore Canada Corporation | Compliant |
Gold | Chimet S.p.A. | Compliant |
Gold | Dowa | Compliant |
Gold | Eco-System Recycling Co., Ltd. | Compliant |
Gold | Heimerle + Meule GmbH | Compliant |
Gold | Heraeus Ltd. Hong Kong | Compliant |
Gold | Heraeus Precious Metals GmbH & Co. KG | Compliant |
Gold | Ishifuku Metal Industry Co., Ltd. | Compliant |
Gold | Istanbul Gold Refinery | Compliant |
Gold | Japan Mint | Compliant |
Gold | Johnson Matthey Inc | Compliant |
Gold | Johnson Matthey Ltd | Compliant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Compliant |
Gold | JSC Uralelectromed | Compliant |
Gold | JX Nippon Mining & Metals Co., Ltd. | Compliant |
Gold | Kazzinc Ltd | Compliant |
Gold | Kennecott Utah Copper LLC | Compliant |
Gold | Kojima Chemicals Co., Ltd | Compliant |
Gold | L' azurde Company For Jewelry | Compliant |
Gold | LS-NIKKO Copper Inc. | Compliant |
Gold | Materion | Compliant |
Gold | Matsuda Sangyo Co., Ltd. | Compliant |
Gold | Metalor Technologies (Hong Kong) Ltd | Compliant |
Gold | Metalor Technologies (Singapore) Pte. Ltd. | Compliant |
Gold | Metalor Technologies SA | Compliant |
Gold | Metalor USA Refining Corporation | Compliant |
Gold | Met-Mex Peñoles, S.A. | Compliant |
Gold | Mitsubishi Materials Corporation | Compliant |
Gold | Mitsui Mining and Smelting Co., Ltd. | Compliant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Compliant |
Gold | Nihon Material Co. LTD | Compliant |
Gold | Ohio Precious Metals, LLC | Compliant |
Gold | Ohura Precious Metal Industry Co., Ltd | Compliant |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Compliant |
Gold | PAMP SA | Compliant |
Gold | PT Aneka Tambang (Persero) Tbk | Compliant |
Gold | PX Précinox SA | Compliant |
Gold | Rand Refinery (Pty) Ltd | Compliant |
Gold | Royal Canadian Mint | Compliant |
Gold | Schone Edelmetaal | Compliant |
Gold | SEMPSA Joyería Platería SA | Compliant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | Compliant |
Gold | Sichuan Tianze Precious Metals Co., Ltd | Compliant |
Gold | Solar Applied Materials Technology Corp. | Compliant |
Gold | Sumitomo Metal Mining Co., Ltd. | Compliant |
Gold | Tanaka Kikinzoku Kogyo K.K. | Compliant |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | Compliant |
Gold | Tokuriki Honten Co., Ltd | Compliant |
Gold | Umicore Brasil Ltda | Compliant |
Gold | Umicore SA Business Unit Precious Metals Refining | Compliant |
Gold | United Precious Metal Refining, Inc. | Compliant |
Gold | Valcambi SA | Compliant |
Gold | Western Australian Mint trading as The Perth Mint | Compliant |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Compliant |
Gold | Zijin Mining Group Co. Ltd | Compliant |
Gold | Umicore Precious Metals Thailand | Compliant |
Gold | MMTC-PAMP India Pvt. Ltd | Compliant |
Gold | Republic Metals Corporation | Compliant |
Gold | Singway Technology Co., Ltd. | Compliant |
Gold | Asaka Riken Co Ltd | Active |
Gold | Cendres + Métaux SA | Active |
Gold | Sabin Metal Corp. | Active |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Active |
Gold | Torecom | Active |
Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | Active |
Gold | Yokohama Metal Co Ltd | Active |
Gold | Advanced Chemical Company | Known |
Gold | Aktyubinsk Copper Company TOO | Known |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Known |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Known |
Gold | Bauer Walser AG | Known |
Gold | Caridad | Known |
Gold | Yunnan Copper Industry Co Ltd | Known |
Gold | China National Gold Group Corporation | Known |
Gold | Chugai Mining | Known |
Gold | Colt Refining | Known |
Gold | Daejin Indus Co. Ltd | Known |
Gold | Daye Non-Ferrous Metals Mining Ltd. | Known |
Gold | Do Sung Corporation | Known |
Gold | Doduco | Known |
Gold | FSE Novosibirsk Refinery | Known |
Gold | Gansu Seemine Material Hi-Tech Co Ltd | Known |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | Known |
Gold | Hunan Chenzhou Mining Group Co., Ltd. | Known |
Gold | Hwasung CJ Co. Ltd | Known |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Known |
Gold | Jiangxi Copper Company Limited | Known |
Gold | Korea Metal Co. Ltd | Known |
Gold | Kyrgyzaltyn JSC | Known |
Gold | Lingbao Gold Company Limited | Known |
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | Known |
Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | Known |
Gold | Moscow Special Alloys Processing Plant | Known |
Gold | Navoi Mining and Metallurgical Combinat | Known |
Gold | OJSC Kolyma Refinery | Known |
Gold | Penglai Penggang Gold Industry Co Ltd | Known |
Gold | Prioksky Plant of Non-Ferrous Metals | Known |
Gold | Samduck Precious Metals | Known |
Gold | SAMWON METALS Corp. | Known |
Gold | So Accurate Group, Inc. | Known |
Gold | The Great Wall Gold and Silver Refinery of China | Known |
Gold | Tongling nonferrous Metals Group Co.,Ltd | Known |
Gold | Guangdong Jinding Gold Limited | Known |
Gold | KGHM Polska Miedź Spółka Akcyjna | Known |
Gold | Fidelity Printers and Refiners Ltd. | Known |
Gold | House of Currency of Brazil (Casa da Moeda do Brazil) | Known |
Gold | Kazakhmys plc | Known |
Gold | Kovohute Pribram Nastupickna a.s. | Known |
Gold | Shandong Tarzan Bio-Gold Co Ltd | Known |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | Compliant |
Tantalum | Exotech Inc. | Compliant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | Compliant |
Tantalum | Hi-Temp | Compliant |
Tantalum | King-Tan Tantalum Industry Ltd | Compliant |
Tantalum | LSM Brasil S.A. | Compliant |
Tantalum | Metallurgical Products India (Pvt.) Ltd. | Compliant |
Tantalum | Mineração Taboca S.A. | Compliant |
Tantalum | Mitsui Mining & Smelting | Compliant |
Tantalum | Molycorp Silmet A.S. | Compliant |
Tantalum | QuantumClean | Compliant |
Tantalum | RFH Tantalum Smeltry Co., Ltd | Compliant |
Tantalum | Solikamsk Magnesium Works OAO | Compliant |
Tantalum | Taki Chemicals | Compliant |
Tantalum | Telex | Compliant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | Compliant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | Compliant |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | Compliant |
Tantalum | D Block Metals, LLC | Compliant |
Tantalum | FIR Metals & Resource., Ltd. | Compliant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co, Ltd | Compliant |
Tantalum | XinXing HaoRong Electronic Material CO.,LTD | Compliant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., LTD | Compliant |
Tantalum | Plansee SE Liezen | Compliant |
Tantalum | H.C. Starck Hermsdorf GmbH | Compliant |
Tantalum | H.C. Starck Inc. | Compliant |
Tantalum | H.C. Starck Ltd. | Compliant |
Tantalum | Plansee SE Reutte | Compliant |
Tantalum | Conghua Tantalum and Niobium Smeltry | Compliant |
Tantalum | Duoluoshan | Compliant |
Tantalum | F&X Electro-Materials Ltd. | Compliant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Compliant |
Tantalum | Jiujiang Tanbre Co., Ltd. | Compliant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | Compliant |
Tantalum | Ulba | Compliant |
Tantalum | Zhuzhou Cement Carbide | Compliant |
Tantalum | KEMET Blue Metals | Compliant |
Tantalum | H.C. Starck Co., Ltd. | Compliant |
Tantalum | H.C. Starck GmbH Goslar | Compliant |
Tantalum | H.C. Starck GmbH Laufenburg | Compliant |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | Compliant |
Tantalum | Global Advanced Metals Boyertown | Compliant |
Tantalum | Global Advanced Metals Aizu | Compliant |
Tantalum | KEMET Blue Powder | Compliant |
Tantalum | Phoenix Metal Ltd | Active |
Tantalum | Shanghai Jiangxi Metals Co. Ltd | Known |
Tin | China Rare Metal Materials Company | Compliant |
Tin | Alpha | Compliant |
Tin | CV United Smelting | Compliant |
Tin | Dowa | Compliant |
Tin | EM Vinto | Compliant |
Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | Compliant |
Tin | Metallo Chimique | Compliant |
Tin | Mineração Taboca S.A. | Compliant |
Tin | Minsur | Compliant |
Tin | Mitsubishi Materials Corporation | Compliant |
Tin | OMSA | Compliant |
Tin | PT Babel Inti Perkasa | Compliant |
Tin | PT Bangka Putra Karya | Compliant |
Tin | PT Bangka Tin Industry | Compliant |
Tin | PT Belitung Industri Sejahtera | Compliant |
Tin | PT Bukit Timah | Compliant |
Tin | PT DS Jaya Abadi | Compliant |
Tin | PT Eunindo Usaha Mandiri | Compliant |
Tin | PT Mitra Stania Prima | Compliant |
Tin | PT Panca Mega Persada | Compliant |
Tin | PT Prima Timah Utama | Compliant |
Tin | PT REFINED BANGKA TIN | Compliant |
Tin | PT Sariwiguna Binasentosa | Compliant |
Tin | PT Stanindo Inti Perkasa | Compliant |
Tin | PT Tambang Timah | Compliant |
Tin | PT Timah (Persero), Tbk | Compliant |
Tin | PT Tinindo Inter Nusa | Compliant |
Tin | White Solder Metalurgia e Mineração Ltda. | Compliant |
Tin | Yunnan Tin Company, Ltd. | Compliant |
Tin | Magnu's Minerais Metais e Ligas LTDA | Compliant |
Tin | PT WAHANA PERKIT JAYA | Compliant |
Tin | Melt Metais e Ligas S/A | Compliant |
Tin | PT ATD Makmur Mandiri Jaya | Compliant |
Tin | Malaysia Smelting Corporation (MSC) | Compliant |
Tin | Thaisarco | Compliant |
Tin | Cooper Santa | Active |
Tin | CV Gita Pesona | Active |
Tin | CV JusTindo | Active |
Tin | CV Nurjanah | Active |
Tin | Fenix Metals | Active |
Tin | China Tin Group Co., Ltd. | Active |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Active |
Tin | PT Artha Cipta Langgeng | Active |
Tin | PT BilliTin Makmur Lestari | Active |
Tin | PT Karimun Mining | Active |
Tin | PT Sumber Jaya Indah | Active |
Tin | Rui Da Hung | Active |
Tin | Soft Metais, Ltda. | Active |
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | Active |
Tin | O.M. Manufacturing Philippines, Inc. | Active |
Tin | PT Inti Stania Prima | Active |
Tin | CNMC (Guangxi) PGMA Co. Ltd. | Known |
Tin | CV Makmur Jaya | Known |
Tin | CV Serumpun Sebalai | Known |
Tin | Estanho de Rondônia S.A. | Known |
Tin | Gejiu Zi-Li | Known |
Tin | Huichang Jinshunda Tin Co. Ltd | Known |
Tin | Jiangxi Nanshan | Known |
Tin | Gejiu Kai Meng Industry and Trade LLC | Known |
Tin | Linwu Xianggui Smelter Co | Known |
Tin | Novosibirsk Integrated Tin Works | Known |
Tin | PT Alam Lestari Kencana | Known |
Tin | PT Babel Surya Alam Lestari | Known |
Tin | PT Bangka Kudai Tin | Known |
Tin | PT Bangka Timah Utama Sejahtera | Known |
Tin | PT Fang Di MulTindo | Known |
Tin | PT HP Metals Indonesia | Known |
Tin | PT Koba Tin | Known |
Tin | PT Seirama Tin investment | Known |
Tin | PT Supra Sukses Trinusa | Known |
Tin | PT Pelat Timah Nusantara Tbk | Known |
Tin | PT Tommy Utama | Known |
Tin | PT Yinchendo Mining Industry | Known |
Tin | PT HANJAYA PERKASA METALS | Known |
Tin | CV Venus Inti Perkasa | Known |
Tin | PT Donna Kembara Jaya | Known |
Tin | PT Rajwa International | Known |
Tin | PT Singkep Times Utama | Known |
Tin | PT Tirus Putra Mandiri | Known |
Tin | CSC Pure Technologies | Known |
Tin | CV Duta Putra Bangka | Known |
Tin | Dongguan Qiandao Tin Co., Ltd | Known |
Tin | EFD INC. | Known |
Tin | Electroloy Metal Pte | Known |
Tin | Hongqiao Metals (Kunshan) Co., Ltd. | Known |
Tin | Hyundai-Steel | Known |
Tin | Jean Goldschmidt International SA | Known |
Tin | Koki Products Co. Ltd. | Known |
Tin | KOVOHUTE PRIBRAM NASTUPNICKA, A.S. | Known |
Tin | PBT | Known |
Tin | Poongsan Corporation | Known |
Tin | POSCO | Known |
Tin | Rahman Hydraulic Tin Sdn Bhd | Known |
Tin | Sumitomo Metal Mining Co. Ltd. | Known |
Tin | TaeguTec Ltd. | Known |
Tin | Technic Inc. | Known |
Tungsten | Global Tungsten & Powders Corp. | Compliant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | Compliant |
Tungsten | Japan New Metals Co., Ltd. | Compliant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | Compliant |
Tungsten | Wolfram Bergbau und Hütten AG | Compliant |
Tungsten | Xiamen Tungsten Co., Ltd. | Compliant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Compliant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | Compliant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | Compliant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | Compliant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | Compliant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | Compliant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | Compliant |
Tungsten | A.L.M.T. Corp. | Active |
Tungsten | Kennametal Huntsville | Active |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | Active |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | Active |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | Active |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | Active |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | Active |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | Active |
Tungsten | Kennametal Fallon | Active |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Active |
Tungsten | Wolfram Company CJSC | Active |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Active |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | Active |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Active |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Active |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | Active |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | Active |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Active |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | Active |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Active |
Tungsten | H.C. Starck GmbH | Active |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | Active |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Active |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Active |
Tungsten | Niagara Refining LLC | Active |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Known |
Tungsten | Jiangxi Richsea New Materials Co., Ltd. | Known |
Tungsten | Ganxian Shirui New Material Co., Ltd. | Known |
Tungsten | Air Products | Known |
Tungsten | Ganzhou Haichuang Tungsten Industry Co., Ltd. [Ganzhou Tejing Tungsten & Molybdenum Co., Ltd. (GZTJ)] | Known |
Tungsten | Izawa Metal Co., Ltd | Known |
Tungsten | Jiangsu Hetian Technological Material Co., Ltd | Known |
Tungsten | Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd. | Known |
Tungsten | Mitsubishi Material | Known |
Tungsten | North American Tungsten | Known |
Tungsten | Sumitomo Metal Mining Co. Ltd. | Known |
Tungsten | TaeguTec Ltd. | Known |
Tungsten | Tamano Smelter, Hibi Kyodo Smelting Co., Ltd | Known |
Tungsten | Voss Metals Company, Inc | Known |
Tungsten | Xiamen Honglu Tungsten Molybdenum Industry Co. Ltd | Known |
Tungsten | Zigong Cemented Carbide Co., Ltd. [Hunan Nonferrous Metals Holding Group (HNG)] | Known |
We note the following in connection with the information contained in the foregoing tables: | |
(a) | The smelters and refiners reflected in the tables were identified by the Suppliers to us as potentially being part of our 2014 supply chain. However, not all of the included smelters and refiners are believed by us to have processed the necessary Conflict Minerals contained in our in-scope products, since most Suppliers reported to us at a "company level" the Conflict Minerals contained in all of their products, not just those in the products that they sold to us. Some Suppliers also may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners reflected above may not be all of the smelters and refiners in our supply chain, since many Suppliers were unable to identify all of the smelters and refiners used to process the necessary Conflict Minerals content contained in our in-scope products and not all of the Suppliers responded to our inquiries. |
(b) | All compliance status information in the tables is as of May 1, 2015. |
(c) | "Compliant" means that a smelter or refiner was listed as compliant with the Conflict-Free Smelter Program's ("CSFP") assessment protocols, including through mutual recognition, or was indicated as "Re-audit in process," as publicly reported by the CFSI. Included smelters and refiners were not necessarily Compliant for all or part of 2014 and may not continue to be Compliant for any future period. We do not have information on the origin of the Conflict Minerals processed by any of the Compliant smelters and refiners prior to their respective compliance dates. |
(d) | "Active" means that the smelter or refiner was listed as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or the smelter has agreed to complete a CFSP validation audit within two years of membership issuance by the Tungsten Industry – Council Minerals Council, in each case according to information published by the CFSI. |
(e) | A smelter or refiner is listed as "Known" if it was not Compliant or Active. |
(f) | The compliance status in both tables are based information published by the CFSI, without independent verification by us. |
(g) The tables include only entities that are listed as verified smelters on the Standard Smelter Names tab of the CMRT, Version
3.02, or that are listed as verified smelting facilities on the Commerce Department List.
(h) Country of Origin and Recycled or Scrap Sourcing Information: Despite Colfax’s best due diligence efforts, there is not
sufficient information available to conclusively determine the countries of origin of the Conflict Minerals in its supply chain.
In addition, sufficiently consistent and reliable information is not available to determine recycled or scrap sources, and what
proportion of each smelter’s or refiner's source minerals are from recycled or scrap.