UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
|
JOHNSON OUTDOORS INC.
|
|
(Exact name of registrant as specified in its charter)
|
|
Wisconsin
|
0-16255
|
39-1536083
|
|
(State or other jurisdiction of incorporation or organization)
|
(Commission File Number)
|
(IRS Employer Identification No.)
|
|
555 Main Street, Racine, Wisconsin 53403
|
|
(Address of principal executive offices)
|
|
Lori Strangberg, Corporate Controller, (262) 631-6600
|
|
(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, 2018.
Section 1 - Conflict Minerals Disclosure
| Item 1.01 |
Conflict Minerals Disclosure and Report
|
Johnson Outdoors Inc. (“JOI” or “the Company”) is a leading global manufacturer and marketer of branded seasonal outdoor recreation products used
primarily for fishing, diving, watercraft recreation and camping.
JOI has a publically available Conflict Minerals Policy that may be found at the following URL: https://www.johnsonoutdoors.com/legal/conflict-minerals-policy. The content of any website referred to in this Form SD (or in the attached Conflict Minerals Report) is included for general information
only and is not incorporated by reference in this Form SD.
The Company has concluded in good faith that during the year ended December 31, 2018, conflict minerals were necessary to the functionality and/or
production of products manufactured by JOI (such minerals are referred to as "necessary conflict minerals"). Necessary conflict minerals were sourced from the Company’s multi-tiered supply chain and were ultimately incorporated into its products
via both internal manufacturing processes and by component manufacturers. The Company, through its independent third-party consultant, conducted a reasonable country of origin inquiry (“RCOI”) with due diligence, based on the “Organisation for
Economic Co-operation and Development Due Diligence guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,” for its products which was designed to determine whether any of these conflict minerals originated
in the Democratic Republic of the Congo (“DRC”) or an adjoining country (together, “Covered Countries”) or were from recycled or scrap sources. For a description of our due diligence, please see our Conflict Minerals Report (Exhibit 1.01).
2
| Item 1.02 |
Exhibit
|
The Company has filed a Conflict Minerals Report for the reporting period January 1, 2018 to December 31, 2018 as Exhibit 1.01 to this Form SD which
further describes its products that contain necessary conflict minerals, RCOI methodology, due diligence procedures, results and steps that will be taken to mitigate the risk that necessary conflict minerals benefit armed groups, including steps to
improve due diligence.
3
Section 2 – Exhibits
| Item 2.01 |
Exhibits
|
Exhibit 1.01 –
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form. A copy of the Conflict Minerals Report is on the Company's website.
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.
|
JOHNSON OUTDOORS INC.
|
||
|
/s/ David W. Johnson
|
May 31st, 2019
|
|
|
David W. Johnson
|
(Date)
|
|
|
Vice President and Chief Financial Officer
|
4
Exhibit 1.01
Johnson Outdoors Inc.
Conflict Minerals Report for Calendar Year 2018
May 31, 2019
Exhibit 1.01
to Specialized Disclosure Report Accompanying Form SD
Filed with the SEC on: May 31, 2019
| Signed by: |
/s/ David W. Johnson |
|
|
|
Name, Title: David W. Johnson, Chief Financial Officer
|
|
||
|
Date: May 31, 2019
|
|
||
Introduction:
Johnson Outdoors Inc. (“JOI,” “we,” “us,” “our”) is a publicly traded U.S. company that recognizes itself as an issuer as defined under section
1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, referred to in this report as “Dodd-Frank.” JOI manufactures, and contracts to manufacture, products for which conflict minerals, as defined by Dodd-Frank, are
necessary to functionality. Through its due diligence regarding the source and chain of custody of the conflict minerals (tin, tantalum, tungsten and gold) in its supply chain in calendar year 2018, JOI has reason to believe that some of these
necessary conflict minerals may have originated from the Democratic Republic of Congo or adjoining countries, and that some of those minerals may not be solely from recycled or scrap sources.
As an issuer under Dodd-Frank, JOI has fully complied with issuer requirements under the law by designing, implementing, executing, and managing
its Conflict Minerals Program as mandated by the legislation. This Conflict Minerals Report is filed with our Form SD to comply with the requirements of Rule 13p-1 of the Securities and Exchange Act 1934. This report includes elements, efforts,
results, and conclusions of compliance and due diligence activities required by the legislation.
All terms and definitions in this conflict minerals report are as defined by the Final Rules promulgated under Dodd-Frank and by 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.
JOI supports the Responsible Minerals Initiative’s (RMI) Responsible Minerals Assurance Process (RMAP) by performing supply chain compliance and due diligence requirements for smelters sourcing from, or believed to source from, or have operations or activities in or through, the Democratic Republic of Congo (DRC) and adjoining countries. The DRC and its nine adjoining countries (Angola, Burundi, Central African Republic,
Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia) are referred to collectively as Covered Countries, or CCs. JOI’s compliance efforts under Dodd-Frank include supporting a clean minerals trade in Covered Countries and
maintaining economic relationships with conflict-free smelters in Covered Countries.
1
JOI’s Conflict Minerals Program is performed annually and engages JOI’s first-tier and in-scope suppliers under the applicable provisions of
Dodd-Frank to perform risk assessments of smelters and refiners (hereafter referred to collectively as smelters or SORs) of tin, tantalum, tungsten, and gold (collectively, “3TG”) that may source from and/or may have operations in Covered
Countries. Although JOI’s Conflict Minerals Program directly engages first-tier and in-scope suppliers, the program annually assesses all active suppliers, both in and out of scope of our Conflict Minerals Program, to ensure that we evaluate 100%
of the suppliers in our supply chain.
JOI’s Conflict Minerals Program is holistically managed and includes comprehensive supplier evaluations and smelter due diligence in order to
identify all the smelters in our global supply chain, as well as the smelter mines and country of origin of 3TG in Covered Countries to the best of our abilities.
JOI mandates participation in our Conflict Minerals Program as a compulsory element of JOI’s Supplier Statement of Basic Standards for all
suppliers in our supply chain. Active involvement is required from JOI’s first-tier and in-scope suppliers, and passive evaluation is requested from out of scope
suppliers. The supplier evaluation portion of JOI’s Conflict Minerals Program is just part of the entire scope of its comprehensive supply chain transparency program. Other critical elements of this program include cooperation from JOI business
group leaders, management, and other supply chain actors. The cornerstone of this project is a strong company management system and dedication from business group leaders, senior management, and senior executives to ensure the completeness,
integrity, and evolution of the program.
Communication and training for suppliers and JOI employees is performed throughout the calendar year to promote continued support and
understanding of the program as it relates to fulfillment of internal and external obligations under the Dodd-Frank rule. Because JOI’s successful Conflict Minerals Program includes both suppliers and JOI employees, all participants in the
program are advised routinely during each calendar year regarding their respective responsibilities associated with their role in JOI’s supply chain, their compliance expectations, and applicable risks associated with the performance of their
obligations.
This report may be found on our website at: https://www.johnsonoutdoors.com/sec. This report is inclusive for all JOI products at a company
level, and all covered products in all JOI business groups.
JOI’s Conflict Minerals Program:
JOI has successfully implemented and completed its annual Conflict Minerals Program for the past six years, from the time law first required
reporting on due diligence efforts performed in 2013. As in all previous years, JOI has performed required due diligence procedures for evaluating chain of custody of the extraction, through end use, of mineral ores containing tin, tantalum,
tungsten and gold (3TG), also referred to as conflict minerals. While JOI’s Conflict Minerals Program is a routine part of its standard Corporate Social Responsibility business practice, JOI continues to improve its processes and annually
reporting of additional information that it discloses regarding its sourcing of conflict minerals.
JOI’s Conflict Minerals Program is based on well-established
and strong management systems to support all portions and efforts of the program. This foundation creates a comprehensive and robust supply chain transparency and due diligence program that identifies and evaluates smelters of 3TG in JOI’s supply
chain relating to the conflict minerals necessary to the functionality or production of products manufactured by JOI, or contracted to be manufactured for JOI.
2
Throughout the calendar year, routine and continued communication is made with all first-tier and in-scope suppliers in order to reasonably
identify all global 3TG smelters in Covered Countries. Routine communication is also made to all first-tier active, and out of scope suppliers, to ensure they are consistently queried from year to year regarding any changes in their conflict
minerals status. All communication from JOI to its first-tier active suppliers encourages ongoing sourcing from conflict-free smelters within the global supply chain in order to support legitimate trade in conflict minerals in Covered Countries.
JOI’s annual Conflict Minerals Program includes, but is not limited, to the following:
| • |
Maintenance of a publicly available corporate conflict minerals policy.
|
| • |
Design and implementation of an organization-wide process that ensures awareness, outreach, and training offered to 100% of JOI suppliers, both in and out of
scope of the Dodd-Frank conflict minerals rule.
|
| • |
Ensure that 100% of JOI suppliers, both in and out of scope of the Dodd-Frank conflict minerals rule, are made aware of JOI’s policy and standards regarding
conflict minerals, as well as internal and supplier obligations to comply with our conflict minerals policy.
|
| • |
Maintenance of internal protocols that ensure conflict minerals supply chain due diligence and obligations are clearly presented and understood by JOI
employees, including senior executives, senior management, business group leaders, and support staff, who have responsibility for the SEC disclosure requirements under the Dodd-Frank conflict minerals rule.
|
| • |
Survey and analysis of all suppliers and identifiable sources of 3TG, including distributors and original equipment manufacturers (OEMs).
|
| • |
Annual implementation of a supply chain communication plan that includes requests, and repeated requests where necessary, for the completed and current RMI
Conflict Minerals Reporting Template (CMRT) from suppliers in order to facilitate supply chain transparency by gathering, surveying, and evaluating suppliers and sources of 3TG, and identifying 3TG smelters in JOI’s supply chain.
|
| • |
Annual internal audit of all first-tier suppliers regarding their understanding of the conflict minerals rule, their obligations regarding the rule, and JOI’s
expectations of them regarding their compliance with the rule.
|
| • |
Identification of priority first-tier suppliers that supply electrical and electronic equipment (EEE) and electrical and electronic parts (EEP).
|
| • |
Escalation of Reasonable Country of Origin Inquiry (RCOI) efforts to JOI business group leaders, including identifying smelters from priority suppliers of EEE
and EEP.
|
| • |
Collection of conflict minerals information to identify 3TG in our supply chain, and identification and mitigation of risk that our products may contain
conflict minerals that could finance or benefit armed groups in Covered Countries.
|
| • |
Identification of global 3TG smelters in order to determine the locations, country of origin, and mines of these ores, as well as the processing facilities,
operations, or trade routes of 3TG from extraction to end use.
|
| • |
Reliance on the RMAP and other industry approved mechanisms to validate smelter supply chain due diligence and perform independent third-party audits of smelter
due diligence practices.
|
| • |
Internal research and due diligence to evaluate and validate smelters not participating in the RMAP or other industry approved mechanisms.
|
3
| • |
Review and due diligence of RMAP smelters to ensure the validity and current state of RMI information.
|
| • |
Perform due diligence on RMAP smelters to determine and/or confirm presence in Covered Countries.
|
| • |
Make annual requests that first-tier and subsequent tier suppliers only source from RMAP participating smelters and/or validated conflict-free smelters of 3TG.
|
| • |
Direct contact with smelters that are not participating in the RMAP to encourage them to participate in the RMAP, wherever possible.
|
| • |
Public disclosure and reporting of the results of our due diligence.
|
| • |
Secure maintenance of all records relating to our due diligence efforts for a minimum of five years.
|
| • |
Multi-tiered assessment and performance of risk mitigation efforts throughout our supply chain including review, evaluation and escalation to, and by, business
group leaders and senior management.
|
| • |
Maintenance of an annual improvement plan based on previous reporting years and annual lessons learned.
|
| • |
Maintenance of an online grievance mechanism that allows JOI, its suppliers, and any concerned parties to communicate concerns regarding our Conflict Minerals
Program.
|
Due Diligence:
Design of Due Diligence:
Per the SEC requirements that
due diligence measures must conform to a nationally or internationally recognized due diligence framework, JOI’s Conflict Minerals Program is designed and implemented based on the “Five Step Framework for Risk-Based Due Diligence in the
Mineral Supply Chain” (Annex I) and the “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and
High-Risk Areas” (Annex II) included 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 (Third Edition).
Due Diligence Performed:
The table below details JOI’s due diligence measures performed according to each of the Five Steps in the OECD Framework Guidance. These steps
are specific to the due diligence regarding the source and chain of custody of conflict minerals identified in our supply chain, and regarding the smelters identified with 3TG in our supply chain. These activities include, but are not limited to,
the following:
|
OECD Steps:
|
JOI Due Diligence Measures Performed:
|
|
|
Step 1:
Establish strong company management systems.
|
• Assign
and implement multi-disciplinary responsibilities to internal JOI senior executives, senior management, business group leaders, support staff, and our third-party consultant to carry out all elements of JOI’s Conflict Minerals Program.
• Maintain
a detailed project plan and hold semi-monthly meetings for JOI employees, business group leaders, and senior management who have responsibility for the SEC disclosure requirements for Dodd-Frank regarding conflict minerals, and
regularly publish this project plan on JOI’s intranet.
|
4
|
• Annual
review of JOI’s Conflict Minerals Program and results by senior management, senior executives, and legal counsel.
• Annual
discussion and conclusions made by business group leaders, senior management and senior executives regarding decisions that are determined in the Conflict Minerals Report and Form SD.
• Maintain
records in a secure computerized database repository for a minimum of five years.
|
||
|
Step 2:
Identify and assess risk in the supply chain.
|
• Evaluate
100% of JOI first-tier suppliers across all business groups as being in or out of scope of the Conflict Minerals Program.
• Review
and verify supplier commodity class and status.
• Review
and update of affected and priority suppliers.
• Review
new suppliers and changes in supplier status and commodity class.
• Assess
risk in our supply chain according to commodity class, supplier status and supplier responses.
• Engage
suppliers by performing multi-tiered survey of 100% of JOI in-scope and first-tier conflict minerals suppliers by requesting current, complete, and accurate CMRTs in order to identify 3TG smelters in the supply chain and set expectations
for compliance.
• Annually
redistribute copies of our conflict minerals policy and basic standards to all active first-tier suppliers, regardless of commodity class or in-scope status of conflict minerals.
• Analyze
smelter information from suppliers with the information available from the RMI, the London Market Bullion Association (LBMA), the Responsible Jewellery Council (RJC), and other accredited industry mechanisms.
• Analyze
smelter information from suppliers via other sources, including but not limited to information from: the United States Department of Commerce; United Nations publications; iTSCi (ITRI Tin Supply Chain Initiative); extensive internet
research including smelter websites and company profiles; non-governmental organization (NGO) websites; in-region sourcing programs; industry leader CMRTs and reports; specialized SEC research reports; public news articles and
publications.
• Identify
smelters of 3TG that appear to have facilities, or likelihood of facilities, operations or trade routes, in Covered Countries.
• Report
identified and/or potential supply chain risks to business group leaders and senior management.
• Report
potential supply chain risks to applicable suppliers and request further supplier due diligence where needed.
|
|
|
Step 3:
Design and implement a strategy to respond to identified risks.
|
• Perform
internal audit of the distribution of our conflict minerals policy to evaluate and ensure supplier understanding, acknowledgment, and adherence to this policy and our basic standards.
• Perform
internal multi-tiered analysis of our suppliers’ CMRTs including: completeness; reasonable response based on commodity class and scope; consistency with previous reporting year(s) information; and identification of smelters.
|
5
|
• Communicate
supplier expectations for return of the most current CMRT including identifying all valid and current smelters.
• Communicate
supplier expectation that they notify us of any risks and red flags identified by their own due diligence activities for smelters.
• Communicate
supplier expectation that they notify us immediately of any smelters that may be suspected of supporting armed groups in Covered Countries.
• Request
supplier confirmation for the validity of questionable and high-risk smelter presence in the supply chain.
• Inform
suppliers not to source from smelters associated with U.S. sanctioned entities.
• Perform
ongoing internal and external training of the conflict minerals rule and risks to JOI employees and all suppliers in the supply chain.
• Engage
JOI business group leaders, support staff, and our third-party consultant in multi-tiered follow ups and escalations with suppliers in an effort to obtain higher quantity and quality of smelter information, particularly from suppliers of
EEE and EEP.
• Use
JOI level of influence to encourage suppliers to source from RMI audited and compliant smelter lists and communicate the expectation that they source only from smelters participating in the RMAP or other industry approved mechanism.
• Encourage
identified smelters to participate in the RMAP and obtain RMAP Conformant certification if they have not already done so.
• Continue
to improve on efficiencies and effectiveness of our Conflict Minerals Program to close gaps and mitigate risks for each subsequent reporting year.
• Perform
risk mitigation efforts to ensure suppliers are in conformance with our conflict minerals policy and expectations.
• Execute
a risk mitigation plan that improves supply chain due diligence and mitigates the risk that any conflict minerals identified in our supply chain may benefit any armed groups in Covered Countries.
• Communicate
risks to business group leaders, our internal conflict minerals senior management team, and senior executives.
• Request
that business group leaders evaluate and identify any additional risks throughout the due diligence process.
• Perform
gap analysis and communicate these gaps and issues to our conflict minerals senior management team, and senior executives.
• Review
and discuss supplier and smelter gaps with business group leaders, conflict minerals senior management team and senior executives.
|
||
|
Step 4:
Carry out independent third-party audit of smelter due diligence practices.
|
• Identify
smelters in Covered Countries that are conflict-free, or participating in a conflict-free program as defined by the RMI.
• Rely on
the due diligence performed by the RMI, LBMA and RJC regarding smelter conflict-free status.
|
6
|
• Review
RMI smelter information for timeliness, accuracy, and changes.
• Review
RMAP corrective action plans and schedules for relevant smelters.
• Directly
contact smelters in the form of an RCOI regarding chain of custody of conflict minerals and evidence of due diligence for whom we were unable to confirm conflict-free status via the sources above.
• Conduct
screening of smelters against the current Office of Foreign Assets Control (OFAC) list.
|
||
|
Step 5:
Report on supply chain due diligence.
|
• In
compliance with Dodd-Frank and the SEC Final Rule, on or before May 31, 2019, JOI will file Form SD and Conflict Minerals Report (this report) with the SEC, as well as publish this information on its website.
|
Results of Due Diligence:
JOI identified 314 unique and validated 3TG smelters in its supply chain in calendar year/reporting year 2018 (RY2018). These are associated
with the following 3TG as follows:
| • |
Gold: 143
|
| • |
Tantalum: 41
|
| • |
Tin: 88
|
| • |
Tungsten: 42
|
Out of these 314 smelters, JOI identified 96 unique smelters that we have reason to believe either source 3TG from the DRC and/or surrounding
countries (Covered Countries) or have some type of facility, operation, or trade route in Covered Countries anywhere from extraction to end use. JOI exercised due
diligence on the conflict mineral (CM) source and chain of custody for these 96 smelters who we believe may have a presence in Covered Countries.
Conflict-free (CF) status and believed Covered Country facility location for these 96 smelters are summarized in the table below. The
conflict-free status is based on due diligence research performed starting from January 23rd, 2019 and concluded on March 26th, 2019. Details regarding specific smelter names, countries, and believed facility locations of
3TG, in and out of Covered Countries, may be shared upon request.
7
Smelter Table:
|
3TG; # of Smelters:
|
96 Smelters with 346 Possible Locations in Covered Countries (CCs):
|
|
Gold:
24 Smelters
|
56 possible presences located in 9 CCs:
• 21 RMI RMAP
SORs include 47 possible presences in the following CCs: DRC (12); Angola (1); Burundi (3); Central African Republic (1); Republic of the Congo (2); Rwanda (12); S. Sudan (1); Tanzania (7); Uganda (4); Zambia (4)
• 1 CF
self-declared and believed to be CF SOR include 4 possible presences in the following CCs: DRC (1); Angola (0); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda (1); S. Sudan (1); Tanzania (0); Uganda (1);
Zambia (0)
• 2 unknown CM
Compliant SORs include 5 possible presences in the following CCs: DRC (1); Angola (2); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda; (1) S. Sudan (0); Tanzania (0); Uganda (0); Zambia (1)
|
|
Tantalum:
24 Smelters
|
167 possible presences located in 10 CCs:
• 24 RMI RMAP
SORs include 167 possible presences in the following CCs: DRC (23); Angola (14); Burundi (19); Central African Republic (14); Republic of the Congo (16); Rwanda (21); S. Sudan (14); Tanzania (16); Uganda (16); Zambia (14)
|
|
Tin:
26 Smelters
|
69 possible presences located in 10 CCs:
• 26 RMI RMAP
SORs include 69 possible presences in the following CCs: DRC (22); Angola (5); Burundi (4); Central African Republic (3); Republic of the Congo (6); Rwanda (16); S. Sudan (3); Tanzania (3); Uganda (3); Zambia (4)
|
|
Tungsten:
22 Smelters
|
54 possible presences located in 10 CCs:
• 21 RMI RMAP
SORs include 52 possible presences in the following CCs: DRC (14); Angola (1); Burundi (10); Central African Republic (1); Republic of the Congo (1); Rwanda (14); S. Sudan (2); Tanzania (3); Uganda (5); Zambia (1)
• 1 unknown CM
Compliant SORs include 2 possible presences in the following CCs: DRC (1); Angola (0); Burundi (0); Central African Republic (0); Republic of the Congo (0); Rwanda; (0) S. Sudan (0); Tanzania (0); Uganda (0); Zambia (1)
|
3TG Conflict-Free Due Diligence Summary:
The conflict-free (CF) status for all 3TG smelters that may have facilities located in Covered Countries is as follows:
| • |
Gold appears to be 92% CF
|
| • |
Tantalum appears to be 100% CF
|
| • |
Tin appears to be 100% CF
|
| • |
Tungsten appears to be 95% CF
|
8
RMAP Participation Summary:
The conflict-free status of the 96 smelters listed as a having a possible presence in Covered Countries is as follows:
| • |
92 (96%) are RMI RMAP Conformant
|
| • |
1 (1%) are believed to be CF due to self-declaration or other accreditation(s)
|
| • |
3 (3%) are unknown CF status, as no information was available from public sources and the smelters were not able to be confirmed as CF via direct RCOI
|
Due Diligence Conclusion:
| ➢ |
97% of all 3TG smelters that may be in Covered Countries appear to be conflict-free (93 out of 96 smelters)
|
| ➢ |
3% of all 3TG smelters that may be in Covered Countries are unknown CF status (3 out of 96)
|
| ➢ |
96% of all 3TG smelters that may be in Covered Countries were participating in an RMAP program
|
| ➢ |
99% of the 3TG smelters in JOI’s entire supply chain, either believed to source in or out of Covered Countries, are conflict-free
|
Improvements:
The total number of smelters identified in RY2018 is 33.33% more than were identified in RY2017. Despite the notable increase in the number of
smelters identified, only three smelters were identified as conflict-free unknown status, which is consistent with RY2017. This is likely due to a 40% increase in the number of RMI RMAP smelters from RY2017 to RY2018.
Smelters that had possible presences in Covered Countries increased significantly, by over 33%, from 72 to 96, demonstrating an improvement in
the information being provided by JOI’s suppliers regarding their smelters and increased supply chain transparency.
The supplier RCOI response rate also increased in RY2018, by 6%, and there was a 4% increase in number suppliers who furnished smelter names.
JOI experienced a decrease in the number of invalid smelters provided by supplier CMRTs in RY2018 while the percentage of duplicate smelters
remained the same. This demonstrates that JOI’s suppliers have gained a higher level of consistency in the smelters they report, meaning they may have performed a higher level of smelter due diligence in their own supply chains.
The number of potential presences in Covered Countries rose significantly by 45%, from 238 in RY2017 to 346 in RY2018. This demonstrates the
evolution of supply chain transparency, not only for JOI, but for industry, as much of this information is available from public sources.
For the second year in a row, JOI is able to reasonably determine that the tin and tantalum in our supply chain that are believed to be sourced
from Covered Countries appear to be 100% conflict-free. The conflict-free status for gold rose significantly from 80% in RY2017 to 92% in RY2018. The conflict-free status for the tungsten in our supply chain was evaluated at 95% conflict–free.
9
Despite the 33% increase in the number of smelters believed to have some kind of presence in Covered Countries, the number of conflict-free
unknown smelters remained at only three, the same number for RY2017. This reflects a conflict-free status of 97% of 3TG smelters in Covered Counties, compared to 96% in RY2017. The overall evaluation of JOI’s entire 3TG supply chain, both in and
out of Covered Countries, remained consistent with RY2017, at 99% conflict-free.
Year after year JOI has consistently improved its due diligence results by identifying more smelters involved in the sourcing and chain of
custody of conflict minerals in our supply chain. This improvement is reflective not only of our due diligence performed, but reflective of the maturing of supply chains across industry as a whole, and the commitment to supporting clean minerals
trade in Covered Countries and conflict-affected and high-risk areas (CAHRA) worldwide.
Additional information regarding statistical improvements may be shared upon request.
Determination:
JOI has made a reasonable good faith effort to collect and evaluate all information regarding 3TG smelters in our supply chain as provided by
our first-tier and in-scope suppliers, and original equipment manufacturers (OEMs).
JOI performed due diligence on smelters, and their source and chain of custody of conflict minerals, that were identified by JOI first-tier
suppliers in scope of Dodd-Frank and applicable OEMs. Additionally, JOI conducted a direct smelter RCOI program to further demonstrate due diligence regarding
applicable smelters. Based on these due diligence efforts, JOI has concluded in good faith that certain smelters in our supply chain either do have, or may have, facilities that source 3TG from Covered Countries or may have some type of
operations or trade routes, from extraction to end use, in Covered Countries.
Based on these due diligence efforts, JOI has concluded that it does not have sufficient information to conclusively confirm that 100% of the
3TG smelters in our supply chain that may have presences in Covered Countries are conflict-free, or that all 3TGs in our supply chain are sourced exclusively from recycled or scrap sources.
Although we have not been able to confirm the identification and conflict-free status (as defined by the RMI) for 100% of the smelters
identified by our first-tier suppliers and OEMs, we can confirm that none of the smelters identified by our first-tier suppliers or OEMs have confirmed to us as sourcing 3TG that directly or indirectly finance or benefit armed groups in Covered
Countries.
JOI can reasonably conclude after its due diligence efforts that 100% of the tin and tantalum in its supply chain is sourced from smelters that
are either conflict-free or that the tin and tantalum tungsten are from recycled or scrap sources. 100% of all smelter information is based on research from smelter identification by JOI first-tier suppliers and/or original equipment
manufacturers.
Planned Risk Mitigation and Future Due Diligence Measures:
JOI’s annual Conflict Minerals program includes routine tasks for planned risk mitigation to identify and remove possible sources of smelters
that may support or benefit armed groups in Covered Countries. JOI’s due diligence process is designed to identify legitimate sources of 3TG in our supply chain and eliminate smelters that are not validated as being in our supply chain. Continued
awareness, education, and outreach to our first-tier suppliers, both in and out of scope of the Conflict Minerals law, has proven an effective method to identify and reduce risks, as well as improve the overall supplier RCOI response rate.
10
These activities include but are not limited to the following:
| • |
Engage internal business group leaders and support staff at a deep level for review, analysis, evaluation, and recommendation for both supplier and smelter
risks in each business group.
|
| • |
Impose direct responsibility and action items on business group leaders for supplier escalations and risk assessment for their respective business groups.
|
| • |
Leverage multi-tiered influence from JOI internal and external resources in order to compel its first-tier and in-scope suppliers to deliver more current,
accurate, timely, and complete information to correctly identify smelters of conflict minerals, and increase both response level and quality of responses.
|
| • |
Leverage multi-tiered influence from JOI internal and external resources to increase response level from in-scope and first-tier distributors regarding JOI
supply chain procedures and increase their participation in supply chain transparency of conflict minerals, including furnishing CMRTs for their OEMs.
|
| • |
Emphasize the high probability of 3TG in EEE and EEP, and maintain pressure, specifically on suppliers of EEE/EEP, to provide current, correct, and more comprehensive smelter information, including CMRTs from their OEMs as applicable.
|
| • |
Continue to review commodity classes with business group leaders for veracity and inclusion of EEE/EEP criteria.
|
| • |
Repeat, and continue to enhance, our annual pro-active supplier communication plan to further assist 100% of JOI active suppliers, regardless of scope,
regarding the need for correct and complete conflict minerals information to satisfy the SEC requirements, including annual updates, reminders, and ongoing training.
|
| • |
Use our level of influence to encourage all suppliers to source only from smelters validated as compliant to an RMAP assessment protocol using the most recent
version of the RMI RMAP Conformant Smelter List or other accredited independent validation scheme or institutional mechanism.
|
| • |
Use our level of influence to encourage all suppliers to source away from un-validated conflict-free smelters, unknown status smelters, and to identify the
sources of conflict minerals in their supply chains.
|
| • |
Use our level of influence to have suppliers re-evaluate and confirm or refute the actual presence of questionable smelters as identified in their supply chains, including providing updated CMRTs.
|
| • |
Instruct suppliers to advise JOI if they have reason to believe that any person or entity in their supply chain is directly or indirectly financing or
benefiting armed groups in the Covered Countries and provide a discrete mechanism to do so.
|
| • |
Pressure smelters with undeterminable conflict-free status to become verified as having conflict-free sourcing practices and encourage participation in the RMAP
audit process; this is done through direct and repeat smelter RCOIs and other electronic communication where available.
|
| • |
Review smelter red flags for locations of gold origin and transit and remind suppliers to notify JOI of any smelters where risks and red flags may be identified
in their diligence activities for all 3TG.
|
| • |
Review RMAP corrective actions plans and schedules for relevant smelters.
|
| • |
Review all smelters against the current Office of Foreign Asset Control (OFAC) list.
|
11
| • |
Remind all JOI suppliers that they must not directly or indirectly have dealings with an entity that appears on the U.S. Office of Foreign Assets Control’s
lists of Specially Designated Nationals (SDN) and Blocked Persons as these are U.S. sanctioned entities.
|
| • |
Remind all JOI suppliers to perform their own risk mitigation actions regarding high-risk
smelters.
|
Description of Products:
Conflict minerals may be found in products that JOI manufactures, or contracts to manufacture. Accessories are included in all groups. The
descriptions of product families by business group are as follows:
Fishing Group:
| • |
Trolling motors
|
| • |
Shallow water anchors
|
| • |
Battery chargers
|
| • |
Fishfinders
|
| • |
Downriggers
|
Dive Group:
| • |
Dive computers, instruments and gauges
|
| • |
Dive watches
|
| • |
Scuba dive equipment
|
| • |
Buoyancy compensators
|
Camping Group:
| • |
Camping tents, sleeping bags and furniture
|
| • |
Camping stoves
|
| • |
Military, party, and event tents
|
Watercraft Recreation Group:
| • |
Canoes
|
| • |
Kayaks
|
| • |
Personal flotation devices
|
| • |
Paddles
|
In Conclusion:
JOI has performed smelter due diligence in good faith and has followed the “OECD Five Step Framework for Risk-Based Due Diligence in the
Mineral Supply Chain” (Annex I) and the “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and
High-Risk Areas” (Annex II) to ensure a strong and effective Conflict Minerals Program designed to identify the source and chain of custody
regarding conflict minerals necessary to the production of JOI products where applicable. The information in this Conflict Minerals report is represented with the most accuracy to our knowledge. The results are based on and the information
represented by our first-tier and in-scope suppliers and OEMs, as well as information from the RMI’s website, during the window of research and due diligence performed.
12
Errors or omissions may be inherent in these results due to errors or omissions in supplier and smelter RCOIs, supplier and OEM CMRTs, the RMI
definition of a smelter at the time of the research, and subsequent updates to RMI smelter status and information.
In order for JOI to receive any additional relevant information that may not have been uncovered through our due diligence process in supply
chain transparency as it relates to conflict minerals, JOI maintains an early warning risk-awareness conflict minerals grievance mechanism. Any information found to be contradictory to this CMR may be communicated to JOI through this grievance
mechanism which may be found at the following URL: https://www.johnsonoutdoors.com/legal.
13
Appendix A:
Below is a list of the 3TG smelters with one or more worldwide
facilities that JOI suppliers identified to potentially be in our supply chain and that were participating at some level with the Responsible Minerals Initiative (RMI) Responsible Minerals Assurance Process (RMAP) in RY2018. The presence of a smelter on the list below does not indicate
that JOI products necessarily contained conflict minerals sourced or processed by that smelter. The identity and location information for each entity was reported by the RMI as of January 23rd, 2019.
| 3TG: | Smelter Name: | Location: | |||
|
Gold
|
Advanced Chemical Company
|
UNITED STATES OF AMERICA
|
|||
|
Gold
|
Aida Chemical Industries Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Al Etihad Gold Refinery DMCC
|
UNITED ARAB EMIRATES
|
|||
|
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
|
Asahi Refining Canada Ltd.
|
CANADA
|
|||
|
Gold
|
Asahi Refining USA Inc.
|
UNITED STATES OF AMERICA
|
|||
|
Gold
|
Asaka Riken Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
AU Traders and Refiners
|
SOUTH AFRICA
|
|||
|
Gold
|
Aurubis AG
|
GERMANY
|
|||
|
Gold
|
Bangalore Refinery
|
INDIA
|
|||
|
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
|
Chimet S.p.A.
|
ITALY
|
|||
|
Gold
|
Chugai Mining
|
JAPAN
|
|||
|
Gold
|
Daejin Indus Co., Ltd.
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
DODUCO Contacts and Refining GmbH
|
GERMANY
|
|||
|
Gold
|
Dowa
|
JAPAN
|
|||
|
Gold
|
DS PRETECH Co., Ltd.
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
DSC (Do Sung Corporation)
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Eco-System Recycling Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Emirates Gold DMCC
|
UNITED ARAB EMIRATES
|
|||
|
Gold
|
Geib Refining Corporation
|
UNITED STATES OF AMERICA
|
|||
|
Gold
|
Gold Refinery of Zijin Mining Group Co., Ltd.
|
CHINA
|
|||
|
Gold
|
HeeSung Metal Ltd.
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Heimerle + Meule GmbH
|
GERMANY
|
|||
|
Gold
|
Heraeus Metals Hong Kong Ltd.
|
Hong Kong
|
|||
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG
|
GERMANY
|
|||
|
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
|
Italpreziosi
|
ITALY
|
|||
|
Gold
|
Japan Mint
|
JAPAN
|
14
|
Gold
|
Jiangxi Copper Co., Ltd.
|
CHINA
|
|||
|
Gold
|
JSC Uralelectromed
|
RUSSIAN FEDERATION
|
|||
|
Gold
|
JX Nippon Mining & Metals Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Kazzinc
|
KAZAKHSTAN
|
|||
|
Gold
|
Kennecott Utah Copper LLC
|
UNITED STATES OF AMERICA
|
|||
|
Gold
|
KGHM Polska Miedz Spolka Akcyjna
|
POLAND
|
|||
|
Gold
|
Kojima Chemicals Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Korea Zinc Co., Ltd.
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Kyrgyzaltyn JSC
|
KYRGYZSTAN
|
|||
|
Gold
|
L'Orfebre S.A.
|
ANDORRA
|
|||
|
Gold
|
LS-NIKKO Copper Inc.
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Marsam Metals
|
BRAZIL
|
|||
|
Gold
|
Materion
|
UNITED STATES OF AMERICA
|
|||
|
Gold
|
Matsuda Sangyo Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Metalor Technologies (Hong Kong) Ltd.
|
CHINA
|
|||
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd.
|
SINGAPORE
|
|||
|
Gold
|
Metalor Technologies (Suzhou) Ltd.
|
CHINA
|
|||
|
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
|
MMTC-PAMP India Pvt., Ltd.
|
INDIA
|
|||
|
Gold
|
Moscow Special Alloys Processing Plant
|
RUSSIAN FEDERATION
|
|||
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.S.
|
TURKEY
|
|||
|
Gold
|
NH Recytech Company
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Nihon Material Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
|
AUSTRIA
|
|||
|
Gold
|
Ohura Precious Metal Industry Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
|
RUSSIAN FEDERATION
|
|||
|
Gold
|
OJSC Novosibirsk Refinery
|
RUSSIAN FEDERATION
|
|||
|
Gold
|
PAMP S.A.
|
SWITZERLAND
|
|||
|
Gold
|
Planta Recuperadora de Metales SpA
|
CHILE
|
|||
|
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
|
REMONDIS PMR B.V.
|
NETHERLANDS
|
|||
|
Gold
|
Royal Canadian Mint
|
CANADA
|
|||
|
Gold
|
SAAMP
|
FRANCE
|
|||
|
Gold
|
Safimet S.p.A
|
ITALY
|
|||
|
Gold
|
Samduck Precious Metals
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
SAXONIA Edelmetalle GmbH
|
GERMANY
|
|||
|
Gold
|
SEMPSA Joyeria Plateria S.A.
|
SPAIN
|
|||
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
|
CHINA
|
|||
|
Gold
|
Sichuan Tianze Precious Metals Co., Ltd.
|
CHINA
|
|||
|
Gold
|
Singway Technology Co., Ltd.
|
TAIWAN, PROVINCE OF CHINA
|
|||
|
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
|
SungEel HiMetal Co., Ltd.
|
KOREA, REPUBLIC OF
|
15
|
Gold
|
T.C.A S.p.A
|
ITALY
|
|||
|
Gold
|
Tanaka Kikinzoku Kogyo K.K.
|
JAPAN
|
|||
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd.
|
CHINA
|
|||
|
Gold
|
Tokuriki Honten Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Torecom
|
KOREA, REPUBLIC OF
|
|||
|
Gold
|
Umicore Brasil Ltda.
|
BRAZIL
|
|||
|
Gold
|
Umicore Precious Metals Thailand
|
THAILAND
|
|||
|
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
|
WIELAND Edelmetalle GmbH
|
GERMANY
|
|||
|
Gold
|
Yamakin Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Yokohama Metal Co., Ltd.
|
JAPAN
|
|||
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CHINA
|
|||
|
Tantalum
|
Asaka Riken Co., Ltd.
|
JAPAN
|
|||
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
D Block Metals, LLC
|
UNITED STATES OF AMERICA
|
|||
|
Tantalum
|
Exotech Inc.
|
UNITED STATES OF AMERICA
|
|||
|
Tantalum
|
F&X Electro-Materials Ltd.
|
CHINA
|
|||
|
Tantalum
|
FIR Metals & Resource Ltd.
|
CHINA
|
|||
|
Tantalum
|
Global Advanced Metals Aizu
|
JAPAN
|
|||
|
Tantalum
|
Global Advanced Metals Boyertown
|
UNITED STATES OF AMERICA
|
|||
|
Tantalum
|
Guangdong Rising Rare Metals-EO Materials Ltd.
|
CHINA
|
|||
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
H.C. Starck Co., Ltd.
|
THAILAND
|
|||
|
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
|
H.C. Starck Tantalum and Niobium GmbH
|
GERMANY
|
|||
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
Jiangxi Tuohong New Raw Material
|
CHINA
|
|||
|
Tantalum
|
Jiujiang Janny New Material 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 OF AMERICA
|
|||
|
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
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
NPM Silmet AS
|
ESTONIA
|
|||
|
Tantalum
|
Power Resources Ltd.
|
MACEDONIA
|
|||
|
Tantalum
|
QuantumClean
|
UNITED STATES OF AMERICA
|
|||
|
Tantalum
|
Resind Industria e Comercio Ltda.
|
BRAZIL
|
|||
|
Tantalum
|
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
CHINA
|
|||
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
RUSSIAN FEDERATION
|
16
|
Tantalum
|
Taki Chemical Co., Ltd.
|
JAPAN
|
|||
|
Tantalum
|
Telex Metals
|
UNITED STATES OF AMERICA
|
|||
|
Tantalum
|
Ulba Metallurgical Plant JSC
|
KAZAKHSTAN
|
|||
|
Tantalum
|
XinXing HaoRong Electronic Material Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Alpha
|
UNITED STATES OF AMERICA
|
|||
|
Tin
|
Gejiu Zili Mining And Metallurgy Co., Ltd.
|
CHINA
|
|||
|
Tin
|
PT Tirus Putra Mandiri
|
INDONESIA
|
|||
|
Tin
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Chifeng Dajingzi Tin Industry Co., Ltd.
|
CHINA
|
|||
|
Tin
|
China Tin Group Co., Ltd.
|
CHINA
|
|||
|
Tin
|
CV Ayi Jaya
|
INDONESIA
|
|||
|
Tin
|
CV Dua Sekawan
|
INDONESIA
|
|||
|
Tin
|
CV Gita Pesona
|
INDONESIA
|
|||
|
Tin
|
CV United Smelting
|
INDONESIA
|
|||
|
Tin
|
CV Venus Inti Perkasa
|
INDONESIA
|
|||
|
Tin
|
Dowa
|
JAPAN
|
|||
|
Tin
|
EM Vinto
|
BOLIVIA
|
|||
|
Tin
|
Fenix Metals
|
POLAND
|
|||
|
Tin
|
Gejiu Fengming Metallurgy Chemical Plant
|
CHINA
|
|||
|
Tin
|
Gejiu Jinye Mineral Company
|
CHINA
|
|||
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
CHINA
|
|||
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Guanyang Guida Nonferrous Metal Smelting Plant
|
CHINA
|
|||
|
Tin
|
HuiChang Hill Tin Industry Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Huichang Jinshunda Tin Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Jiangxi New Nanshan Technology Ltd.
|
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
|
Metallic Resources, Inc.
|
UNITED STATES OF AMERICA
|
|||
|
Tin
|
Metallo Belgium N.V.
|
BELGIUM
|
|||
|
Tin
|
Metallo Spain S.L.U.
|
SPAIN
|
|||
|
Tin
|
Mineracao Taboca S.A.
|
BRAZIL
|
|||
|
Tin
|
Minsur
|
PERU
|
|||
|
Tin
|
Mitsubishi Materials Corporation
|
JAPAN
|
|||
|
Tin
|
Modeltech Sdn Bhd
|
MALAYSIA
|
|||
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
THAILAND
|
|||
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
PHILIPPINES
|
|||
|
Tin
|
Operaciones Metalurgical S.A.
|
BOLIVIA
|
|||
|
Tin
|
PT Aries Kencana Sejahtera
|
INDONESIA
|
|||
|
Tin
|
PT Artha Cipta Langgeng
|
INDONESIA
|
|||
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
INDONESIA
|
|||
|
Tin
|
PT Babel Inti Perkasa
|
INDONESIA
|
|||
|
Tin
|
PT Bangka Prima Tin
|
INDONESIA
|
|||
|
Tin
|
PT Bangka Serumpun
|
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 Inti Stania Prima
|
INDONESIA
|
17
|
Tin
|
PT Karimun Mining
|
INDONESIA
|
|||
|
Tin
|
PT Kijang Jaya Mandiri
|
INDONESIA
|
|||
|
Tin
|
PT Lautan Harmonis Sejahtera
|
INDONESIA
|
|||
|
Tin
|
PT Menara Cipta Mulia
|
INDONESIA
|
|||
|
Tin
|
PT Mitra Stania Prima
|
INDONESIA
|
|||
|
Tin
|
PT Panca Mega Persada
|
INDONESIA
|
|||
|
Tin
|
PT Premium Tin Indonesia
|
INDONESIA
|
|||
|
Tin
|
PT Prima Timah Utama
|
INDONESIA
|
|||
|
Tin
|
PT Rajehan Ariq
|
INDONESIA
|
|||
|
Tin
|
PT Refined Bangka Tin
|
INDONESIA
|
|||
|
Tin
|
PT Sariwiguna Binasentosa
|
INDONESIA
|
|||
|
Tin
|
PT Stanindo Inti Perkasa
|
INDONESIA
|
|||
|
Tin
|
PT Sukses Inti Makmur
|
INDONESIA
|
|||
|
Tin
|
PT Sumber Jaya Indah
|
INDONESIA
|
|||
|
Tin
|
PT Timah Tbk Kundur
|
INDONESIA
|
|||
|
Tin
|
PT Timah Tbk Mentok
|
INDONESIA
|
|||
|
Tin
|
PT Tinindo Inter Nusa
|
INDONESIA
|
|||
|
Tin
|
PT Tommy Utama
|
INDONESIA
|
|||
|
Tin
|
Resind Industria e Comercio Ltda.
|
BRAZIL
|
|||
|
Tin
|
Rui Da Hung
|
TAIWAN, PROVINCE OF CHINA
|
|||
|
Tin
|
Soft Metais Ltda.
|
BRAZIL
|
|||
|
Tin
|
Thaisarco
|
THAILAND
|
|||
|
Tin
|
Tin Technology & Refining
|
UNITED STATES OF AMERICA
|
|||
|
Tin
|
White Solder Metlagurgia
|
BRAZIL
|
|||
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
CHINA
|
|||
|
Tin
|
Yunnan Tin Company Limited
|
CHINA
|
|||
|
Tungsten
|
A.L.M.T. Corp.
|
JAPAN
|
|||
|
Tungsten
|
ACL Metais Eireli
|
BRAZIL
|
|||
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Ganzhou Haichuang Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Global Tungsten & Powders Corp.
|
UNITED STATES OF AMERICA
|
|||
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
H.C. Starck Smelting GmbH & Co. KG
|
GERMANY
|
|||
|
Tungsten
|
H.C. Starck Tungsten GmbH
|
GERMANY
|
|||
|
Tungsten
|
Hunan Chenzhou Mining Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
|
CHINA
|
|||
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Hunan Litian High-tech Materials Co.,Ltd.
|
CHINA
|
|||
|
Tungsten
|
Hydrometallurg, JSC
|
RUSSIAN FEDERATION
|
|||
|
Tungsten
|
Japan New Metals Co., Ltd.
|
JAPAN
|
|||
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Kennametal Fallon
|
UNITED STATES OF AMERICA
|
|||
|
Tungsten
|
Kennametal Huntsville
|
UNITED STATES OF AMERICA
|
18
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Masan Tungsten Chemical LLC (MTC)
|
VIET NAM
|
|||
|
Tungsten
|
Moliren Ltd.
|
RUSSIAN FEDERATION
|
|||
|
Tungsten
|
Niagara Refining LLC
|
UNITED STATES OF AMERICA
|
|||
|
Tungsten
|
Philippine Chuangxin Industrial Co., Inc.
|
PHILIPPINES
|
|||
|
Tungsten
|
South-East Nonferrous Metal Company Limited of Hengyang City
|
CHINA
|
|||
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
VIET NAM
|
|||
|
Tungsten
|
Unecha Refractory metals plant
|
RUSSIAN FEDERATION
|
|||
|
Tungsten
|
Wolfram Bergbau und Hutten AG
|
AUSTRIA
|
|||
|
Tungsten
|
Woltech Korea Co., Ltd.
|
KOREA, REPUBLIC OF
|
|||
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CHINA
|
|||
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CHINA
|
JOI suppliers and OEMs identified at least 56 additional entities which are not listed here because they were either not identified by the RMI
or Department of Commerce as valid smelters and/or were not participating in any RMAP program at the time of the report. Consequently, these additional entities are not included in the list above. The names of these smelters may be provided upon
request.
19