Control4 Corporation
CONTROL4 CORP (Form: SD, Received: 05/26/2017 16:08:31)

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 


 

FORM SD

 

Specialized Disclosure Report

 


 

Control4 Corporation

(Exact name of registrant as specified in its charter)

 

Delaware

 

001-36017

 

42-1583209

(State or other jurisdiction
of incorporation)

 

(Commission File Number)

 

(I.R.S. Employer
Identification No.)

 

11734 S. Election Road

Salt Lake City, Utah, 84020

(Address of principal executive offices) (Zip Code)

 

Greg Bishop

General Counsel, Chief Compliance Officer and Corporate Secretary

(801) 523-3100

(Name and telephone number, including area code, of 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, 2016.

 

 

 



 

Section 1 — Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

This Form SD of Control4 Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2016 to December 31, 2016.  A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available on the Company’s website along with our Conflict Minerals Policy at: https://www.control4.com/legal/conflict-minerals-policy .

 

Item 1.02 Exhibit

 

As specified in Section 2, Item 2.01 of this Form SD, the Company 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 for the reporting period January 1, 2016 to December 31, 2016.

 

2



 

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.

 

CONTROL4 CORPORATION.

 

 

 

By:

/s/ Greg Bishop

 

 

Greg Bishop

General Counsel, Chief Compliance Officer and Corporate Secretary

 

 

Date: May 26, 2017

 

 

3



 

EXHIBIT INDEX

 

Exhibit
No.

 

Description

 

 

 

1.01

 

Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016.

 

4


Exhibit 1.01

 

CONFLICT MINERALS REPORT OF CONTROL4 CORPORATION

FOR THE REPORTING PERIOD FROM JANUARY 1, 2016 TO DECEMBER 31, 2016

 

Background

 

This Conflict Minerals Report of Control4 Corporation (“Control4”) has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (17 CFR 240.13p-1) (the “Rule”) promulgated by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to how companies source certain minerals as directed by the Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”).

 

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. These specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, namely tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo and adjoining countries, namely the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

 

If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company knows or has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, and may not be from recycled or scrap sources, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.

 

Company Overview

 

Control4 is a leading provider of personalized, smart home solutions that are designed to enhance the daily lives of our customers. Our entertainment, smart lighting, comfort and convenience and safety and security solutions unlock the potential of connected devices throughout the house, making entertainment systems easier to use and more accessible, homes more comfortable and energy efficient, and families more secure. Our premium smart home solutions provide consumers with the ability to integrate audio, video, lighting, temperature, security, communications and other functionalities into a unified home-automation solution,

 



 

customized to match their lifestyle. Our advanced software, delivered through our controller products, cloud services and user-interface product, powers this customized experience, enabling cohesive interoperability with thousands of connected Control4 and third-party devices in the home .

 

Description of the Products Covered by this Report

 

This Report relates to Control4’s products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were contracted to be manufactured by Control4; and (iii) for which the manufacture was completed during calendar year 2016. These products, which are referred to in this Report collectively as the “Covered Products,” are the following:

 

·                   Controllers: These devices contain Control4’s proprietary software that serves as a central hub to connect and control connected Control4 and third-party devices throughout the home. Our controllers use a ZigBee transceiver and a WiFi transceiver to interface to the home network.

 

·                   Interfaces:  Interface products include remote controls, touch screens and door station units.

 

·                   Audio/Visual Products: Audio/Visual products are designed to deliver audio and video to multiple rooms within a home automation system, and include amplifiers and audio matrix switches.

 

·                   Lighting:  Lighting products include dimmers, relays, switches and configurable keypads and allow lighting control and automation throughout the home. Our keypad and controls switches may also be used for other functions such as garage doors, etc.

 

·                   Climate Control: Climate control products include thermostats, automatic blinds and fireplace switches and integrate existing heating and cooling systems with the home automation system.

 

·                   Networking:  Networking products include wireless routers, switches and access points.

 

Supply Chain Overview

 

Control4 does not directly manufacture any of its Covered Products, but instead relies on contract manufacturers to fabricate its products.  Thus, Control4 is completely removed from the sourcing and mining of Conflict Minerals.  We do not purchase the Conflict Minerals directly from mines, smelters, or refiners. Control4’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals that are used to make the Covered Products’ component parts. Therefore, we must rely on our contract

 



 

manufacturers and suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products as explained in greater detail below.

 

Reasonable Country-of-Origin Inquiry and Due Diligence Performed

 

Control4 has conducted a good faith RCOI regarding the Conflict Minerals that was designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Covered Countries and/or whether any of the Conflict Minerals may be from recycled or scrap sources. In order to conduct this RCOI, Control4 identified the suppliers providing products and components that may contain Conflict Minerals (the “Identified Suppliers”), and requested that each Identified Supplier complete and return the Conflict Minerals Reporting Template (“Template”) created by the Conflict-Free Sourcing Initiative (“CFSI”), an initiative founded by the Electronic Industry Citizenship Coalition and Global e-Sustainability Initiative, which provides a standardized method for companies to collect representations, statements and data from their suppliers related to the presence, use, source and chain of custody of the Conflict Minerals.   As a result of the RCOI, Control4 has reason to believe that a portion of the Conflict Minerals in its Covered Products may have originated in the “Covered Countries” and that these necessary Conflict Minerals may not be from recycled or scrap sources, so Control4 also performed due diligence on the source and chain of custody of the necessary Conflict Minerals. Control4 designed its due diligence process based on the due diligence framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition , (the “OECD Framework”), taking into account Control4’s distance in the supply chain from the direct procurement of Conflict Minerals.  We describe our due diligence process in greater detail below.

 

Description of Due Diligence Measures

 

Control4 integrated OECD’s Five-Step Framework into its due diligence measures as described below.

 

1.  Establish Strong Company Management Systems

 

Control4 has a policy regarding Conflict Minerals that outlines its commitment to promote responsible sourcing practices and to promote the use of conflict-free minerals in our supply chain (the “Conflict Minerals Policy”). This policy is available on our website at http://www.control4.com/legal/conflict-minerals-policy. Control4 formed a cross-organizational committee (the “Committee”) to help us comply with our obligations under the Rule.  The Committee includes representatives from our finance, legal, product and supply chain teams. The

 



 

Committee met periodically over the course of 2016 and the first part of 2017 to review Control4’s supply chain with respect to our use of components containing Conflict Minerals in 2016. Members of Control4’s executive team have oversight authority for the work done by the Committee.

 

Committee members reviewed the Rule, the OECD Framework, and various other supplementary materials provided by third parties, including the Conflict-Free Smelter & Refiners information provided by CFSI.  The Committee was responsible for communicating with our suppliers in order to encourage reporting, including completing and returning the Conflict Minerals Reporting Template created by CFSI.  In addition, Control4 established an internal electronic database for maintenance of business records relating to Conflict Minerals due diligence, including supplier responses to our inquiries, as well as spreadsheets containing aggregate data and analysis.

 

If any investor has any concern about Control4’s Conflict Minerals Policy, they may contact Control4’s board of directors in the manner described at http://investor.control4.com/directors.cfm.

 

2.  Identify and Assess Risk in the Supply Chain

 

As mentioned above, as the first step in the good faith RCOI and due diligence processes, Control4 identified the suppliers providing products and components that may contain Conflict Minerals (the “Identified Suppliers”), which excluded packaging suppliers and suppliers of other products which do not contain any components that could contain Conflict Minerals. We then sent a letter to each of our Identified Suppliers communicating Control4’s commitment to sourcing responsibly and outlining our expectation that they do the same.  To help suppliers understand Control4’s expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness to Control4’s inquiry, Control4 provided suppliers with Control4’s Conflict Minerals Policy and our latest Conflict Minerals Report, as well as background information about the Rule and references to training materials and other informational resources.

 

Control4 requested that each Identified Supplier complete and return the Conflict Minerals Reporting Template, which provides a standardized method for companies to collect representations, statements and data from their suppliers related to the presence, use, source and chain of custody of the Conflict Mineral. We requested our Identified Suppliers to use the Template to identify the smelters and refiners in the supply chain, as well as the country and mine of origin, of the Conflict Minerals used in our Covered Products.

 



 

A total of 83 out of 108 suppliers were classified as Identified Suppliers and were contacted as part of the due diligence process. Out of 83 Identified Suppliers, Control4 has received responses from 56 of Identified Suppliers. In instances where an Identified Supplier failed to return a completed Template, committee members had follow-up discussions and/or sent repeat requests to insist on completion of the Template. While we have seen some improvement in the quality of some of our Identified Suppliers’ responses as compared with the previous year, even after providing our suppliers with explanatory materials, instructions and/or follow-up, in a number of instances Control4 received incomplete information regarding the facilities utilized to process necessary Conflict Minerals in supplier parts, as well as insufficient information regarding the mines or sources of origin of those Conflict Minerals. Some Identified Suppliers responded generally on a company-wide basis when a more tailored response would have been more appropriate.

 

Control4 has not conducted its own supply chain audits, but rather, has relied on the information provided by the Conflict-Free Smelter Program (“CFSP”) developed by the CFSI to help assess the due diligence conducted by the identified smelters and refiners and to assess or verify their conflict-free status.  The CFSP identifies smelters and refiners that an independent third-party audit has confirmed comply with the CFSP’s assessment protocols to assure sourcing of only conflict-free minerals. In particular, we compared the smelters and refiners used by our Identified Suppliers against the list of smelter and refinery facilities that received a “conflict free” designation through the CFSP.

 

3.  Design and Implement a Strategy to Respond to Risk

 

Through its Conflict Minerals Policy, contractual provisions, and interaction with its Identified Suppliers, Control4 encourages its Identified Suppliers to promote responsible sourcing practices for any Conflict Minerals used in our Covered Products. Control4 determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts. Potential outcomes typically include continuing to work with the supplier while risks are addressed, but could also include reassessing the relationship with, including looking for alternative sources and restricting or terminating our relationship with, the supplier. As we assess these relationships, we also take additional factors into consideration including supplier size and capabilities, whether alternatives are reasonable and economically available, switching costs and Control4’s dependence on the Identified Supplier.

 



 

4.   Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

 

Control4 does not have any direct relationships with any smelters or refiners in its supply chain, and it did not perform or direct audits of any entity within its supply chain. As an alternative, the Company has relied on publicly available information, including principally information provided by the CFSP, an independent third-party audit program.

 

5.   Report on Supply Chain Due Diligence

 

As required under the Rule, Control4 has timely filed our Form SD with the SEC for the 2016 Reporting Period, which contains this Report as an exhibit, and we have posted this Report on our website, see a link to this document on our Conflict Minerals Policy page at https://www.control4.com/legal/conflict-minerals-policy.

 

Due Diligence Outcome

 

Based on the information gathered in connection with our due diligence efforts, given that not all smelters identified by our Identified Suppliers were certified as “conflict free” by the CFSP and that a number of Identified Supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain, or unknown, overbroad, or incomplete, Control4 cannot conclude that Conflict Minerals in Covered Products did not finance or benefit, directly or indirectly, armed groups in the Covered Countries.

 

The statements above are based on the RCOI process and due diligence performed in good faith by Control4 as described above, but as noted, Control4 is a downstream entity, and does not purchase Conflict Minerals directly from mines, smelters or refiners. Tracing these minerals to their sources is a challenge that requires Control4 to rely on its Identified Suppliers in its efforts to achieve supply chain transparency. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, incomplete product or product content information, gaps in Identified Suppliers’ data, gaps in smelter data, errors or omissions by Identified Suppliers in their reporting, failure to accurately identify all Identified Suppliers and the appropriate persons to contact at each Identified Supplier, errors or omissions by smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries sourced materials being declared secondary materials, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.

 



 

Identified Smelters and Refiners

 

While some of Control4’s Identified Suppliers provided information for the particular products they supply to Control4, the majority provided this information on a company-wide basis. When the Identified Suppliers provided product-level information, Control4 has listed in Schedule 1 of this Report the smelters or refiners identified. However, with the exception of our largest supplier, Sanmina Corporation, which Control4 determined should also be included because of the large number of products they supply to Control4, when the Identified Suppliers provided only company-level information, Control4 determined that it did not have sufficient information to reasonably identify the particular smelter or refiner that processed the Conflict Minerals contained in the particular type of component in the Covered Products, and thus did not include the smelters or refiners in Schedule 1. In addition, the smelters and refiners listed on Schedule 1 include only those reported entities that were listed on the CFSI Standard Smelter List tab of the Template with a current smelter identification number, because those are the only reported entities that Control4 was able to determine were bona fide smelters or refiners. Based solely on information provided by our Identified Suppliers and the CFSP, of the 306 smelters and refiners identified on Schedule 1,171 have been certified as “conflict free” by the CFSP, and an additional 75 of the remaining smelters and refiners were previously certified as “conflict free” but the certifications have subsequently expired, with 48 of these 75 that are currently actively involved in the re-audit process.  Furthermore, 13 additional smelters and refiners are actively under-going audits in the process of becoming certified as “conflict free” by the CFSP for the first time.

 

Identified Countries of Origin of Necessary Conflict Minerals

 

Where such information was provided, Control4 has listed in Schedule 2 of this Report the countries of origin of the Necessary Conflict Minerals provided to us in the Templates of Identified Suppliers which reported product-level information as well as Sanmina Corporation.

 

Future Due Diligence and Risk Mitigation

 

Control4 expects to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the necessary Conflict Minerals in Control4’s products benefit armed groups in the Covered Countries, including:

 

1. Control4 intends to continue to work with Identified Suppliers that provided incomplete or insufficient information, or were unresponsive to the information request, in an effort to obtain complete and accurate information.

 



 

2. Control4 intends to request that all Identified Suppliers complete the Template by providing product- or component-specific information and provide responses that identify materials down to the smelter and countries of origin of the Conflict Minerals.

 

3. Control4 intends to engage in continuing education to employees who are involved with material, component and supplier selection.

 

4. Control4 intends to consider and evaluate opportunities to join industry groups to better obtain and evaluate more complete information from our Identified Suppliers.

 

Cautionary Note on Forward-looking Statements

 

This Report includes forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements other than statements of historical fact contained in this Report are forward-looking statements, including without limitation, Control4’s ability to improve its Conflict Minerals due diligence processes and engage more productively with its current suppliers as well as any future suppliers. These forward-looking statements are made as of the date they were first issued, and were based on the then-current expectations, estimates, forecasts, and projections, as well as the beliefs and assumptions of management. Forward-looking statements are subject to a number of risks and uncertainties, many of which involve factors or circumstances that are beyond Control4’s control. Control4’s actual actions or results could differ materially from those stated or implied in forward-looking statements due to a number of factors, including but not limited to, risks detailed in Control4’s most recent Annual Report on Form 10-K and subsequent reports filed with the Securities and Exchange Commission, as well as other documents that may be filed by the company from time to time with the Securities and Exchange Commission. Past performance is not necessarily indicative of future results. The forward-looking statements included in this Report represent Control4’s views as of the date this Report was filed with the SEC. Control4 anticipates that subsequent events and developments may cause its views to change. Control4 has no intention and undertakes no obligation to update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise. These forward-looking statements should not be relied upon as representing Control4’s views as of any date subsequent to the date of filing of this Report.

 



 

Schedule 1

 

Smelter and Refiner Information

 

Metal

 

Standard Smelter Name

 

Smelter Facility Location

Gold

 

Chugai Mining

 

JAPAN

Gold

 

Caridad

 

MEXICO

Gold

 

Navoi Mining and Metallurgical Combinat

 

UZBEKISTAN

Gold

 

Advanced Chemical Company

 

UNITED STATES OF AMERICA

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 Corrego do Sitio Mineracao

 

BRAZIL

Gold

 

Argor-Heraeus S.A.

 

SWITZERLAND

Gold

 

Asahi Pretec Corp.

 

JAPAN

Gold

 

Asaka Riken Co., Ltd.

 

JAPAN

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

 

Boliden AB

 

SWEDEN

Gold

 

C. Hafner GmbH + Co. KG

 

GERMANY

Gold

 

CCR Refinery - Glencore Canada Corporation

 

CANADA

Gold

 

Cendres + Metaux S.A.

 

SWITZERLAND

Gold

 

Yunnan Copper Industry Co., Ltd.

 

CHINA

Gold

 

Chimet S.p.A.

 

ITALY

Gold

 

Daejin Indus Co., Ltd.

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

Daye Non-Ferrous Metals Mining Ltd.

 

CHINA

Gold

 

DSC (Do Sung Corporation)

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

DODUCO GmbH

 

GERMANY

Gold

 

Dowa

 

JAPAN

Gold

 

Eco-System Recycling Co., Ltd.

 

JAPAN

Gold

 

OJSC Novosibirsk Refinery

 

RUSSIAN FEDERATION

Gold

 

Gansu Seemine Material Hi-Tech Co., Ltd.

 

CHINA

Gold

 

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

 

CHINA

Gold

 

Hangzhou Fuchunjiang Smelting Co., Ltd.

 

CHINA

Gold

 

Heimerle + Meule GmbH

 

GERMANY

Gold

 

Heraeus Metals Hong Kong Ltd.

 

CHINA

Gold

 

Heraeus Metals Hong Kong Ltd.

 

CHINA

Gold

 

Heraeus Precious Metals GmbH & Co. KG

 

GERMANY

Gold

 

Heraeus Precious Metals GmbH & Co. KG

 

GERMANY

Gold

 

Heraeus Precious Metals GmbH & Co. KG

 

GERMANY

Gold

 

Heraeus Precious Metals GmbH & Co. KG

 

GERMANY

Gold

 

Hunan Chenzhou Mining Co., Ltd.

 

CHINA

Gold

 

HwaSeong CJ CO., LTD.

 

KOREA, PEOPLE’S REPUBLIC OF

 



 

Gold

 

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

 

CHINA

Gold

 

Ishifuku Metal Industry Co., Ltd.

 

JAPAN

Gold

 

Istanbul Gold Refinery

 

TURKEY

Gold

 

Japan Mint

 

JAPAN

Gold

 

Jiangxi Copper Co., Ltd.

 

CHINA

Gold

 

Asahi Refining USA Inc.

 

UNITED STATES OF AMERICA

Gold

 

Asahi Refining Canada Ltd.

 

CANADA

Gold

 

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

 

RUSSIAN FEDERATION

Gold

 

JSC Uralelectromed

 

RUSSIAN FEDERATION

Gold

 

JX Nippon Mining & Metals Co., Ltd.

 

JAPAN

Gold

 

Kazakhmys Smelting LLC

 

KAZAKHSTAN

Gold

 

Kazzinc

 

KAZAKHSTAN

Gold

 

Kennecott Utah Copper LLC

 

UNITED STATES OF AMERICA

Gold

 

Kojima Chemicals Co., Ltd.

 

JAPAN

Gold

 

Kyrgyzaltyn JSC

 

KYRGYZSTAN

Gold

 

L’azurde Company For Jewelry

 

SAUDI ARABIA

Gold

 

Lingbao Gold Co., Ltd.

 

CHINA

Gold

 

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

 

CHINA

Gold

 

LS-NIKKO Copper Inc.

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

 

CHINA

Gold

 

Materion

 

UNITED STATES OF AMERICA

Gold

 

Matsuda Sangyo Co., Ltd.

 

JAPAN

Gold

 

Metalor Technologies (Suzhou) Ltd.

 

CHINA

Gold

 

Metalor Technologies (Hong Kong) Ltd.

 

CHINA

Gold

 

Metalor Technologies (Singapore) Pte., Ltd.

 

SINGAPORE

Gold

 

Metalor Technologies S.A.

 

SWITZERLAND

Gold

 

Metalor USA Refining Corporation

 

UNITED STATES OF AMERICA

Gold

 

Metalurgica Met-Mex Penoles S.A. De C.V.

 

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.S.

 

TURKEY

Gold

 

Nihon Material Co., Ltd.

 

JAPAN

Gold

 

Elemetal Refining, LLC

 

UNITED STATES OF AMERICA

Gold

 

Ohura Precious Metal Industry Co., Ltd.

 

JAPAN

Gold

 

OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)

 

RUSSIAN FEDERATION

Gold

 

PAMP S.A.

 

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 Precinox S.A.

 

SWITZERLAND

Gold

 

Rand Refinery (Pty) Ltd.

 

SOUTH AFRICA

Gold

 

Royal Canadian Mint

 

CANADA

Gold

 

Sabin Metal Corp.

 

UNITED STATES OF AMERICA

 



 

Gold

 

Samduck Precious Metals

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

Samwon Metals Corp.

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

Schone Edelmetaal B.V.

 

NETHERLANDS

Gold

 

SEMPSA Joyeria Plateria S.A.

 

SPAIN

Gold

 

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

 

CHINA

Gold

 

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

 

CHINA

Gold

 

Sichuan Tianze Precious Metals Co., Ltd.

 

CHINA

Gold

 

So Accurate Group, Inc.

 

UNITED STATES OF AMERICA

Gold

 

SOE Shyolkovsky Factory of Secondary Precious Metals

 

RUSSIAN FEDERATION

Gold

 

Solar Applied Materials Technology Corp.

 

TAIWAN, PROVINCE OF CHINA

Gold

 

Sumitomo Metal Mining Co., Ltd.

 

JAPAN

Gold

 

Tanaka Kikinzoku Kogyo K.K.

 

JAPAN

Gold

 

Great Wall Precious Metals Co., Ltd. of CBPM

 

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

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

Umicore Brasil Ltda.

 

BRAZIL

Gold

 

Umicore S.A. Business Unit Precious Metals Refining

 

BELGIUM

Gold

 

United Precious Metal Refining, Inc.

 

UNITED STATES OF AMERICA

Gold

 

Valcambi S.A.

 

SWITZERLAND

Gold

 

Western Australian Mint (T/a The Perth Mint)

 

AUSTRALIA

Gold

 

Yamamoto Precious Metal Co., Ltd.

 

JAPAN

Gold

 

Yokohama Metal Co., Ltd.

 

JAPAN

Gold

 

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

 

CHINA

Gold

 

Gold Refinery of Zijin Mining Group Co., Ltd.

 

CHINA

Gold

 

Morris and Watson

 

NEW ZEALAND

Gold

 

SAFINA A.S.

 

CZECH REPUBLIC

Gold

 

Guangdong Jinding Gold Limited

 

CHINA

Gold

 

Umicore Precious Metals Thailand

 

THAILAND

Gold

 

Geib Refining Corporation

 

UNITED STATES OF AMERICA

Gold

 

MMTC-PAMP India Pvt., Ltd.

 

INDIA

Gold

 

Republic Metals Corporation

 

UNITED STATES OF AMERICA

Gold

 

KGHM Polska Miedz Spolka Akcyjna

 

POLAND

Gold

 

Fidelity Printers and Refiners Ltd.

 

ZIMBABWE

Gold

 

Singway Technology Co., Ltd.

 

TAIWAN, PROVINCE OF CHINA

Gold

 

Al Etihad Gold LLC

 

UNITED ARAB EMIRATES

Gold

 

Emirates Gold DMCC

 

UNITED ARAB EMIRATES

Gold

 

Kaloti Precious Metals

 

UNITED ARAB EMIRATES

Gold

 

Sudan Gold Refinery

 

SUDAN

Gold

 

T.C.A S.p.A

 

ITALY

Gold

 

Remondis Argentia B.V.

 

NETHERLANDS

Gold

 

Tony Goetz NV

 

BELGIUM

Gold

 

Korea Zinc Co., Ltd.

 

KOREA, PEOPLE’S REPUBLIC OF

Gold

 

TOO Tau-Ken-Altyn

 

KAZAKHSTAN

 



 

Gold

 

SAAMP

 

FRANCE

Gold

 

SAXONIA Edelmetalle GmbH

 

GERMANY

Gold

 

WIELAND Edelmetalle GmbH

 

GERMANY

Gold

 

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

 

AUSTRIA

Gold

 

AU Traders and Refiners

 

SOUTH AFRICA

Gold

 

GCC Gujrat Gold Centre Pvt. Ltd.

 

INDIA

Gold

 

Sai Refinery

 

INDIA

Gold

 

Universal Precious Metals Refining Zambia

 

ZAMBIA(1)

Gold

 

Modeltech Sdn Bhd

 

MALAYSIA

Gold

 

Bangalore Refinery

 

INDIA

Gold

 

Kyshtym Copper-Electrolytic Plant ZAO

 

RUSSIAN FEDERATION

Tantalum

 

Changsha South Tantalum Niobium Co., Ltd.

 

CHINA

Tantalum

 

Conghua Tantalum and Niobium Smeltry

 

CHINA

Tantalum

 

Duoluoshan

 

CHINA

Tantalum

 

Exotech Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

F&X Electro-Materials Ltd.

 

CHINA

Tantalum

 

Guangdong Zhiyuan New Material Co., Ltd.

 

CHINA

Tantalum

 

Hi-Temp Specialty Metals, Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

JiuJiang JinXin Nonferrous Metals Co., Ltd.

 

CHINA

Tantalum

 

Jiujiang Nonferrous Metals Smelting Company Limited

 

CHINA

Tantalum

 

King-Tan Tantalum Industry Ltd.

 

CHINA

Tantalum

 

LSM Brasil S.A.

 

BRAZIL

Tantalum

 

Metallurgical Products India Pvt., Ltd.

 

INDIA

Tantalum

 

Mineracao Taboca S.A.

 

BRAZIL

Tantalum

 

Mitsui Mining and Smelting Co., Ltd.

 

JAPAN

Tantalum

 

NPM Silmet AS

 

ESTONIA

Tantalum

 

Ningxia Orient Tantalum Industry Co., Ltd.

 

CHINA

Tantalum

 

QuantumClean

 

UNITED STATES OF AMERICA

Tantalum

 

RFH Tantalum Smeltry Co., Ltd.

 

CHINA

Tantalum

 

Solikamsk Magnesium Works OAO

 

RUSSIAN FEDERATION

Tantalum

 

Taki Chemical Co., Ltd.

 

JAPAN

Tantalum

 

Telex Metals

 

UNITED STATES OF AMERICA

Tantalum

 

Ulba Metallurgical Plant JSC

 

KAZAKHSTAN

Tantalum

 

Zhuzhou Cemented Carbide Group Co., Ltd.

 

CHINA

Tantalum

 

Yichun Jin Yang Rare Metal Co., Ltd.

 

CHINA

Tantalum

 

Hengyang King Xing Lifeng New Materials Co., Ltd.

 

CHINA

Tantalum

 

D Block Metals, LLC

 

UNITED STATES OF AMERICA

Tantalum

 

FIR Metals & Resource Ltd.

 

CHINA

Tantalum

 

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

 

CHINA

Tantalum

 

XinXing HaoRong Electronic Material Co., Ltd.

 

CHINA

Tantalum

 

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

 

CHINA

Tantalum

 

KEMET Blue Metals

 

MEXICO

Tantalum

 

H.C. Starck Co., Ltd.

 

THAILAND

Tantalum

 

H.C. Starck Tantalum and Niobium GmbH

 

GERMANY

Tantalum

 

H.C. Starck Hermsdorf GmbH

 

GERMANY

 



 

Tantalum

 

H.C. Starck Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

H.C. Starck Ltd.

 

JAPAN

Tantalum

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

Tantalum

 

Global Advanced Metals Boyertown

 

UNITED STATES OF AMERICA

Tantalum

 

Global Advanced Metals Aizu

 

JAPAN

Tantalum

 

KEMET Blue Powder

 

UNITED STATES OF AMERICA

Tantalum

 

Tranzact, Inc.

 

UNITED STATES OF AMERICA

Tantalum

 

Resind Industria e Comercio Ltda.

 

BRAZIL

Tantalum

 

Jiangxi Tuohong New Raw Material

 

CHINA

Tin

 

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

 

CHINA

Tin

 

Jiangxi Ketai Advanced Material Co., Ltd.

 

CHINA

Tin

 

CNMC (Guangxi) PGMA Co., Ltd.

 

CHINA

Tin

 

Alpha

 

UNITED STATES OF AMERICA

Tin

 

Cooperativa Metalurgica de Rondonia Ltda.

 

BRAZIL

Tin

 

CV Gita Pesona

 

INDONESIA

Tin

 

PT Aries Kencana Sejahtera

 

INDONESIA

Tin

 

CV Serumpun Sebalai

 

INDONESIA

Tin

 

CV United Smelting

 

INDONESIA

Tin

 

Dowa

 

JAPAN

Tin

 

EM Vinto

 

BOLIVIA (PLURINATIONAL STATE OF)

Tin

 

Estanho de Rondonia S.A.

 

BRAZIL

Tin

 

Fenix Metals

 

POLAND

Tin

 

Gejiu Non-Ferrous Metal Processing Co., Ltd.

 

CHINA

Tin

 

Gejiu Zili Mining And Metallurgy Co., Ltd.

 

CHINA

Tin

 

Huichang Jinshunda Tin Co., Ltd.

 

CHINA

Tin

 

Gejiu Kai Meng Industry and Trade LLC

 

CHINA

Tin

 

China Tin Group Co., Ltd.

 

CHINA

Tin

 

Malaysia Smelting Corporation (MSC)

 

MALAYSIA

Tin

 

Metallic Resources, Inc.

 

UNITED STATES OF AMERICA

Tin

 

Mineracao Taboca S.A.

 

BRAZIL

Tin

 

Minsur

 

PERU

Tin

 

Mitsubishi Materials Corporation

 

JAPAN

Tin

 

Nankang Nanshan Tin Manufactory Co., Ltd.

 

CHINA

Tin

 

O.M. Manufacturing (Thailand) Co., Ltd.

 

THAILAND

Tin

 

Operaciones Metalurgical S.A.

 

BOLIVIA (PLURINATIONAL STATE OF)

Tin

 

PT Artha Cipta Langgeng

 

INDONESIA

Tin

 

PT Babel Inti Perkasa

 

INDONESIA

Tin

 

PT Bangka Tin Industry

 

INDONESIA

Tin

 

PT Belitung Industri Sejahtera

 

INDONESIA

Tin

 

PT Bukit Timah

 

INDONESIA

Tin

 

PT DS Jaya Abadi

 

INDONESIA

Tin

 

PT Eunindo Usaha Mandiri

 

INDONESIA

Tin

 

PT Karimun Mining

 

INDONESIA

Tin

 

PT Mitra Stania Prima

 

INDONESIA

Tin

 

PT Panca Mega Persada

 

INDONESIA

 



 

Tin

 

PT Prima Timah Utama

 

INDONESIA

Tin

 

PT Refined Bangka Tin

 

INDONESIA

Tin

 

PT Sariwiguna Binasentosa

 

INDONESIA

Tin

 

PT Stanindo Inti Perkasa

 

INDONESIA

Tin

 

PT Sumber Jaya Indah

 

INDONESIA

Tin

 

PT Timah (Persero) Tbk Kundur

 

INDONESIA

Tin

 

PT Timah (Persero) Tbk Mentok

 

INDONESIA

Tin

 

PT Tinindo Inter Nusa

 

INDONESIA

Tin

 

PT Tommy Utama

 

INDONESIA

Tin

 

Rui Da Hung

 

TAIWAN, PROVINCE OF CHINA

Tin

 

Soft Metais Ltda.

 

BRAZIL

Tin

 

Thaisarco

 

THAILAND

Tin

 

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

 

CHINA

Tin

 

VQB Mineral and Trading Group JSC

 

VIET NAM

Tin

 

White Solder Metalurgia e Mineracao Ltda.

 

BRAZIL

Tin

 

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

 

CHINA

Tin

 

Yunnan Tin Company Limited

 

CHINA

Tin

 

CV Venus Inti Perkasa

 

INDONESIA

Tin

 

Magnu’s Minerais Metais e Ligas Ltda.

 

BRAZIL

Tin

 

Melt Metais e Ligas S.A.

 

BRAZIL

Tin

 

PT ATD Makmur Mandiri Jaya

 

INDONESIA

Tin

 

O.M. Manufacturing Philippines, Inc.

 

PHILIPPINES

Tin

 

PT Inti Stania Prima

 

INDONESIA

Tin

 

CV Ayi Jaya

 

INDONESIA

Tin

 

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

 

VIET NAM

Tin

 

Nghe Tinh Non-Ferrous Metals Joint Stock Company

 

VIET NAM

Tin

 

Tuyen Quang Non-Ferrous Metals Joint Stock Company

 

VIET NAM

Tin

 

CV Dua Sekawan

 

INDONESIA

Tin

 

CV Tiga Sekawan

 

INDONESIA

Tin

 

An Vinh Joint Stock Mineral Processing Company

 

VIET NAM

Tin

 

Resind Industria e Comercio Ltda.

 

BRAZIL

Tin

 

PT O.M. Indonesia

 

INDONESIA

Tin

 

Metallo Belgium N.V.

 

BELGIUM

Tin

 

Metallo Spain S.L.U.

 

SPAIN

Tin

 

PT Bangka Prima Tin

 

INDONESIA

Tin

 

PT Sukses Inti Makmur

 

INDONESIA

Tin

 

An Thai Minerals Co., Ltd.

 

VIET NAM

Tin

 

PT Kijang Jaya Mandiri

 

INDONESIA

Tin

 

HuiChang Hill Tin Industry Co., Ltd.

 

CHINA

Tin

 

Gejiu Fengming Metallurgy Chemical Plant

 

CHINA

Tin

 

Guanyang Guida Nonferrous Metal Smelting Plant

 

CHINA

Tin

 

Modeltech Sdn Bhd

 

MALAYSIA

Tin

 

Gejiu Jinye Mineral Company

 

CHINA

Tungsten

 

A.L.M.T. TUNGSTEN Corp.

 

JAPAN

 



 

Tungsten

 

Kennametal Huntsville

 

UNITED STATES OF AMERICA

Tungsten

 

Guangdong Xianglu Tungsten 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

 

Global Tungsten & Powders Corp.

 

UNITED STATES OF AMERICA

Tungsten

 

Hunan Chenzhou Mining Co., Ltd.

 

CHINA

Tungsten

 

Hunan Chunchang Nonferrous Metals Co., Ltd.

 

CHINA

Tungsten

 

Japan New Metals Co., Ltd.

 

JAPAN

Tungsten

 

Ganzhou Huaxing Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

Kennametal Fallon

 

UNITED STATES OF AMERICA

Tungsten

 

Tejing (Vietnam) Tungsten Co., Ltd.

 

VIET NAM

Tungsten

 

Vietnam Youngsun Tungsten Industry Co., Ltd.

 

VIET NAM

Tungsten

 

Wolfram Bergbau und Hutten AG

 

AUSTRIA

Tungsten

 

Xiamen Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.

 

CHINA

Tungsten

 

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Yaosheng Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

 

CHINA

Tungsten

 

Malipo Haiyu Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Xiamen Tungsten (H.C.) Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Gan Bei Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Ganzhou Seadragon W & Mo Co., Ltd.

 

CHINA

Tungsten

 

Asia Tungsten Products Vietnam Ltd.

 

VIET NAM

Tungsten

 

Chenzhou Diamond Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

 

CHINA

Tungsten

 

Ganzhou Yatai Tungsten Co., Ltd.

 

CHINA

Tungsten

 

H.C. Starck Tungsten GmbH

 

GERMANY

Tungsten

 

H.C. Starck Smelting GmbH & Co. KG

 

GERMANY

Tungsten

 

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

 

VIET NAM

Tungsten

 

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

 

CHINA

Tungsten

 

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

 

CHINA

Tungsten

 

Niagara Refining LLC

 

UNITED STATES OF AMERICA

Tungsten

 

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

 

CHINA

Tungsten

 

Hydrometallurg, JSC

 

RUSSIAN FEDERATION

Tungsten

 

Unecha Refractory metals plant

 

RUSSIAN FEDERATION

Tungsten

 

South-East Nonferrous Metal Company Limited of Hengyang City

 

CHINA

Tungsten

 

Philippine Chuangxin Industrial Co., Inc.

 

PHILIPPINES

Tungsten

 

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

 

CHINA

Tungsten

 

ACL Metais Eireli

 

BRAZIL

Tungsten

 

Woltech Korea Co., Ltd.

 

KOREA, PEOPLE’S REPUBLIC OF

Tungsten

 

Moliren Ltd.

 

RUSSIAN FEDERATION

 



 


(1)This smelter is located in Zambia and is not certified as conflict-free by the CFSP.  Our Identified Supplier that reported that some of its suppliers source gold from this smelter did not include information about the country of origin of materials obtained.  From a review of the smelter’s publically available website, it appears that it may obtain gold from both recycled materials and gold mines located in Zambia, but since we have no relationship with this smelter, we are continuing to follow-up with our Identified Supplier that reported sourcing from this smelter and encouraging it to further investigate its supply chain to obtain more certain information about the origin of the materials obtained from this smelter that are used in our products.

 



 

Schedule 2

 

Countries of Origin

 

Australia

Belgium

Bolivia

Brazil

Burundi(1)

Canada

China

Democratic Republic of the Congo(1)

Ethiopia

India

Indonesia

Japan

Mozambique

Namibia

Nigeria

Peru

Russia

Rwanda(1)

Sierra Leone

Switzerland

United States

Zambia(2)

Zimbabwe

 


(1)  Control4 confirmed that the identified smelter or refiner was certified as “conflict-free” by the CFSP.

 

(2)  One of our Identified Suppliers reported that some of its suppliers reported obtaining gold from a smelter located in Zambia, but our Identified Supplier that reported sourcing from this smelter did not include information about the country of origin of materials obtained.  This smelter is not certified as conflict-free by the CFSP and, from a review of the smelter’s publically available website, it appears that it may obtain gold from both recycled materials and gold mines located in Zambia, so to be conservative we listed this as a country of origin.  However, since we have no relationship with this smelter, we are continuing to follow-up with our Identified Supplier that reported sourcing from this smelter and encouraging it to further investigate its supply chain to obtain more certain information about the origin of the materials obtained from this smelter that are used in our products.