Washington, D.C. 20549






Harvard Bioscience, Inc.

(Exact name of the registrant as specified in its charter)



DELAWARE 001-33957 04-3306140

(State or Other Jurisdiction of


(Commission File Number) (IRS Employer Identification Number)


  84 October Hill Road, Holliston, MA   01746  
  (Address of Principal Executive Offices)   (Zip Code)  


  Michael A. Rossi (508) 893-8999  
(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, 2019.






Section 1 - Conflict Minerals Disclosure


Item 1.01   Conflict Minerals Disclosure and Report


Harvard Bioscience, Inc. (“Harvard Bioscience” or “the Company”) has evaluated its current product lines and has determined in good faith that during 2019 it manufactured or contracted to manufacture products as to which columbite-tantalite (coltan), cassiterite, gold, wolframite and their derivatives, which are limited to tantalum, tin, and tungsten (herein referred to as “Conflict Minerals”) are necessary to the functionality or production of such products (herein referred to as “Covered Products”). Based on such determination, Harvard Bioscience conducted a reasonable country of origin inquiry, or RCOI, that was reasonably designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Democratic Republic of the Congo or an adjoining country (the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola); or were from recycled or scrap sources.


Following the RCOI, Harvard Bioscience exercised due diligence on the source and chain of custody of its applicable products. Information on the RCOI, steps we have taken to exercise due diligence on the source and chain of custody of any Conflict Minerals in the Covered Products and the results of this due diligence, are disclosed in the Conflict Minerals Report filed as Exhibit 1.01 to this Form SD.


Conflict Minerals Disclosure


A copy of Harvard Bioscience’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available at: http://investor.harvardbioscience.com/corporate-governance.cfm.  The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.


Item 1.02   Exhibit


Harvard Bioscience, Inc. has filed its Conflict Minerals Report as Exhibit 1.01 to this Form SD.


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 SD










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.


Harvard Bioscience, Inc.      
/s/ Michael A. Rossi      
By: Michael A. Rossi, Chief Financial Officer May 29, 2020  




















Exhibit 1.01

Harvard Bioscience, Inc.


Conflict Minerals Report


For the Year Ended December 31, 2019


Forward Looking Statements


Forward-looking statements contained in this Report are made based on known events and circumstances at the time of release, and as such, are subject in the future to unforeseen uncertainties and risks. Statements in this Report which express a belief, expectation, or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company’s compliance efforts and expected actions identified in this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other matters, the Company’s customers’ requirements to use certain suppliers, the Company’s suppliers’ responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to implement improvements in its conflict minerals program and the Company’s ability to identify and mitigate related risks in its supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see the Company’s other filings with the Securities and Exchange Commission (“SEC”), including its Annual Report on Form 10-K for the year ended December 31, 2019 and subsequent Quarterly Reports on Form 10-Q. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.




Conflict Minerals Disclosure


This report for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“Conflict Minerals”) for the purposes of this report. These requirements apply to registrants whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.


As described in this report, Harvard Bioscience, Inc., a Delaware corporation (herein referred to as “Harvard Bioscience,” the “Company,” “we,” “us,” or “our”) has reason to believe that some of the Conflict Minerals present in its supply chain may have originated in the Covered Countries.  For purposes of this report, Covered Countries refers to the Democratic Republic of the Congo (the “DRC”) and adjoining countries, defined as any country that shares an internationally recognized border with the Democratic Republic of the Congo.  We are unable with absolute assurance to determine the origin of the Conflict Minerals in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries.


1. Company Overview


This report has been prepared by management of Harvard Bioscience. The information includes the activities of all majority-owned subsidiaries as of December 31, 2019.


Harvard Bioscience is a leading developer, manufacturer and seller of technologies, products and services that enable fundamental research, discovery, and pre-clinical testing for drug development. The Company’s customers range from renowned academic institutions and government laboratories, to the world’s leading pharmaceutical, biotechnology and contract research organizations. With operations in North America and Europe, the Company sells through a combination of direct and distribution channels to customers around the world.


Conflict Minerals Policy


We adopted a conflict minerals policy in 2013 which is publicly available at http://investor.harvardbioscience.com/corporate-governance.cfm.


2. Product Description


As of December 31, 2019, our broad core product range was organized into two commercial product families: Pre-clinical devices and instruments and Cellular and Molecular technologies. As of December 31, 2019, we primarily sold our products under brand names, including Harvard Apparatus, KD Scientific, Hoefer, Biochrom, BTX, Warner Instruments, MCS, HEKA, Hugo Sachs Elektronik, Panlab, Coulbourn Instruments, DSI, and CMA Microdialysis. Our products consist of instruments, consumables, and systems made up of several individual products. We manufacture our products at our locations in the United States, Germany, Sweden and Spain. Our broad and complex product range may contain conflict minerals within the following components:




·         Tantalum, used in capacitors,
·         Tin, used in soldered components,
·         Tungsten, used in coatings, alloys, heating elements and electrodes,
·         Gold, used in circuit boards, electrodes and electronic components.


3. Description of Reasonable Country of Origin Inquiry, or RCOI


We began our RCOI by completing a supplier list extraction from our Vendor List. This list was then filtered to remove:


•             Service Providers/Suppliers

•             Indirect Materials Suppliers

•             Inactive Suppliers (minimum 2 years since last purchase)


This ensures that all suppliers surveyed provided items to Harvard Bioscience that were used in final products in the year 2019. Once the filtering was completed, we populated the list with contact information and this list was then provided to Assent Compliance (“Assent”), our third-party service provider, for upload to their Assent Compliance Manager SaaS system (“ACM”). It was deemed appropriate to not further filter this list based on the necessity of the presence of Conflict Minerals in the products as we could not definitively determine the presence or absence of Conflict Minerals in all parts supplied. The survey employed the Responsible Minerals Initiative’s (RMI’s Conflict Minerals Reporting Template (the “CMRT”), version 5.12, originally developed by the Responsible Business Alliance (RBA) and The Global e-Sustainability Initiative. The CMRT allows for further scoping as they ask suppliers whether any of the Conflict Minerals are intentionally added and if they are necessary to the functionality or production of their products. Assent conducted additional analysis of the supply chain and such analysis combined with supplier feedback, allowed Assent and Harvard Bioscience to remove additional suppliers from scope of the conflict minerals regulation. The factors considered in Assent’s secondary analysis and the information provided that removed these suppliers from scope included:


•             The product they supply is packaging. (Labels do not count as packaging)

•             Parts that do not end up in the final product.

•             Test Labs (i.e. Providers that test the resistance or durability of a product)

•             Service Providers (i.e. any supplier that provides a service but not an actual physical part).

•             Any supplier who has not supplied anything to Harvard Bioscience, Inc., in the last 2 years.


Assent then conducted the supplier survey portion of the RCOI. During the supplier survey, suppliers were contacted via the ACM, a SaaS platform that enables its users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for assessment and management. Non-responsive suppliers were contacted a minimum of three times by ACM and then were also managed by the Assent Compliance team in one on one communications. This includes two to three direct follow ups from that team. Assent’s communications with suppliers included training and education on the completion of the CMRT to alleviate any remaining confusion with suppliers. All of these communications were monitored and tracked in Assent's system for future reporting and transparency.


The program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of suppliers. The results of this data validation contribute to the program’s health assessment and are shared with suppliers to ensure they understand areas that require clarification or improvement. As of May 11, 2020, there were 4 (0.3%) invalid supplier submissions that could not be corrected.


As of May 18, 2020, there were 1,217 suppliers in scope of the conflict minerals program and 533 provided a completed CMRT. The Company’s total response rate for this reporting year was 44%.


Assent compared the list of smelters and refiners provided in our suppliers’ responses to the lists of smelters maintained by the RMI and, if a supplier indicated that a facility was certified as conflict-free, confirmed that the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total of 305 smelters and refiners that appear on the lists maintained by RMI. Of these 305 smelters and refiners, 235 are validated as conflict free by RMI or a cross-recognized initiative, and, based on information provided by RMI, a further 8 have agreed to undergo or are currently undergoing a third-party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products. Based on the RCOI, we had reason to believe that some of the 3TGs may have originated from the Covered Countries, therefore, in accordance with the Rule, performed due diligence on the source and chain of custody of the conflict minerals in question





4. Due Diligence Process


4.1 Design of Due Diligence


Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”) and the related Supplements for Conflict Minerals.


The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, namely:


  1. Establishing strong company management systems regarding conflict minerals;
  2. Identifying and assessing risks in our supply chain;
  3. Designing and implementing a strategy to respond to identified risks in our supply chain;
  4. Utilizing independent third-party audits of supply chain diligence; and
  5. Publicly reporting on our supply chain due diligence


We are a downstream supplier, many steps removed from the mining of 3TG. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, we do not purchase raw ore or unrefined conflict minerals or make purchases from the Covered Countries. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.


The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain.  In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors.  Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.


4.2 Management Systems


Internal Team


Harvard Bioscience has established a management system for conflict minerals. Our management system includes a committee selected by the Chief Financial Officer of the Company as well as executive-level representatives and a team of subject matter experts from relevant functions such as:


· Quality
· Purchasing
· Finance
· Engineering


The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis.


The Company also uses a third-party service provider, Assent, to assist with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that the Company will undertake with suppliers in regard to conflict minerals.


The Company leverages Assent’s Managed Services in order to work with dedicated program specialists who support Harvard Bioscience’s conflict minerals program. The Company communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.





Control systems


As we do not typically have a direct relationship with Conflict Minerals smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our sector and other sectors. Controls include, but are not limited to, the use of the CMRT as the data collection format for our suppliers, our Code of Business Conduct and Ethics which outlines certain expected behaviors for all Harvard Bioscience employees. In addition, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us – including sources of Conflict Minerals that are supplied to them from lower tier suppliers.


Supplier Engagement


With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education on the Conflict Minerals regulation as well as the expectations of the law and for a continued business relationship. This year, we put a stronger emphasis on supplier education and training. To accomplish this, we utilized Assent’s learning management system, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.


Grievance Mechanism


Various communication channels exist to serve as grievance mechanisms for early-warning risk awareness. We have multiple longstanding grievance mechanisms whereby employees (internal) and suppliers (external) can report violations of our policies. This includes , but is not limited to our whistleblower policies that are part of our Code of Business Conduct and Ethics policy located on our website at http://investor.harvardbioscience.com/corporate-governance.cfm.


Maintain Records


Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation will be retained for a period of at least five years. We store all of the information and findings from this process in a database that can be audited by internal or external parties.


4.3 Identify and assess risk in the supply chain


Because of the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in‎ ACM based on criteria established for supplier responses in the Conflict Policy document and Management System.


All of the information and findings from this process are stored in a database that can be audited by internal or external ‎parties.


Certain of the responses to the surveys included the names of facilities listed by the suppliers as smelters or refiners. We compared, via Assent, each facility listed in the responses to the lists of smelters and refiners maintained by the RMI to verify the existence of the facility and to determine whether the facility has met the requirements of the RMI’s Responsible Minerals Assurance Process (RMAP) and is considered Compliant to that protocol.


Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on the following scoring criteria:


  1. Geographic proximity to the DRC and covered countries;
  2. Responsible Minerals Assurance Process (RMAP) audit status;
  3. Known or plausible evidence of unethical or conflict sourcing;
  4. Peer Assessments conducted by credible third-party sources;
  5. Known mineral source country of origin.


Based on this criteria, certain facilities have been identified as being of highest concern to the supply chain. When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through Assent, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Harvard Bioscience, and escalating up to removal of these high risk smelters from their supply chain.

As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.  


In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.




If any smelter or refiner is not recognized by the RMI, Assent conducts outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, Assent conducts outreach providing education on the RMAP and encouraging them to join this program.


Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:


A. Have you established a conflict minerals sourcing policy?


E. Have you implemented due diligence measures for conflict-free sourcing?


G. Do you review due diligence information received from your suppliers against your company’s expectations?


H. Does your review process include corrective action management?


When suppliers meet or exceed those criteria (“Yes” to at least A, E, G, H), they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.


We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our Covered Products, including (1) seeking information about Conflict Minerals smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.


4.4 Design and Implement a Strategy to Respond to Risks


In response to this risk assessment, Harvard Bioscience has an approved risk management plan, through which the conflict minerals program is implemented, managed, and monitored.


As part of our risk management plan, to ensure suppliers understand our expectations we have provided both video recorded training, and documented instructions through Assent. As the program progresses, contacts via email and phone by Harvard Bioscience procurement team members will be completed as an escalation to ensure the importance of a response via CMRTs to Assent and the required cooperation for compliance to the Conflict Minerals rules will be emphasized.


As described in our conflict minerals policy, we engage any of our suppliers whom we have reason to believe are supplying us with Conflict Minerals from sources that may support conflict in the Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict, as provided in the OECD guidance. We have found no instances where it was necessary to terminate a contract or find a replacement supplier.


4.5 Carry out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain


We do not typically have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities. However, we will rely on publicly available third-party assurances and certifications, for example, through the RMI’s Responsible Minerals Assurance Process “RMAP”.


4.6 Report annually on supply chain due diligence


We report annually on our supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the SEC. Our Form SD and Conflict Minerals Report can be found on the Corporate Governance page of our website: http://investor.harvardbioscience.com/corporate-governance.cfm.


5. Due Diligence Results


Survey Responses


We are actively surveying our supplier chain. This year we surveyed 1,217 suppliers. Of those suppliers we received CMRTs from 537 suppliers. We review the responses against criteria developed to determine whether further engagement with our suppliers is required. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the template. We, through the assistance of Assent, have worked with these suppliers to provide revised responses. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. At the end of our campaigning, 4 suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions.





Smelters or Refiners


The information that we received from a majority of our Applicable Suppliers was at their company-wide level. Thus, the smelters or refiners identified by our Applicable Suppliers contained in the tables below may contain smelters or refiners that processed conflict minerals that our Applicable Suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during 2019. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during 2019, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we receive from our Applicable Suppliers may yield inaccurate or incomplete information because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. As we are not a member of the RMI, we also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the RMI’s RMAP or the LBMA Responsible Gold Program and, as a result, are not responsible for the quality of these audits or the audit findings.


Our third-party service provider compared the facilities listed in the responses in the CMRT to the list of smelters maintained by the RMI, and confirmed that the name was listed by RMI as a legitimate smelter. As of May 11, 2020, we have validated in this manner that 305 smelters or refiners provided in our supplier CMRTs are included on these lists. The facilities determined to be legitimate smelters or refiners based on this comparison to the RMI-maintained list have also been compared to the RMI’s RMAP list. Based on this comparison, we are aware of 235 compliant smelters or refiners, 7 smelters or refiners that have begun the process and are deemed as active in the RMAP but have not yet been validated as Conflict-Free and 56 smelters or refiners that are not enrolled in the process to become compliant to the RMAP. Confirmed smelter or refiner sourcing is not generally available through public information sources related to the smelter or refiner however Attachment A does include an aggregate country list of known smelter or refiner sourcing countries. Despite the additional smelter information obtained from these suppliers, in most cases information has been provided on a company or division level, rather than on a component level. Therefore, we cannot yet ascertain whether the smelters identified by our suppliers are related to any parts or components actually provided to us by the suppliers. Attachment A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not included in Attachment A any smelters or refiners that we have not been able to validate. Attachment A also includes the facility RMI audit status.


Efforts to determine mine or location of origin


As noted above, the current efforts focus on gathering smelter information via the CMRT reporting template and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the Conflict Minerals to their location of origin. Seeking information about Conflict Minerals smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the Conflict Minerals in our supply chain.


6. Steps to improve future due diligence and to mitigate risk


We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary Conflict Minerals in our products could benefit armed groups in the DRC or adjoining countries:


• Continue to engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses.

• Suppliers will continue to be requested to inform Harvard Bioscience of the correlation between these smelters and the products and parts they supply to Harvard Bioscience

• Continue to engage any of our suppliers found to be supplying us with Conflict Minerals from sources that support conflict in the DRC or any adjoining country to establish an alternative source of Conflict Minerals that does not support such conflict.

• Continue to evaluate upstream sources through a broader set of tools to evaluate risk that includes using a comprehensive smelter and refiner library with detailed status and notes for each listing, scanning for credible media on each smelter and refiner to flag risk issues, and comparing the list of smelters and refiners against government watch and denied parties lists.







Smelter Table


Metal Standard Smelter Name Smelter Facility Location  Smelter ID
Gold 8853 S.p.A. ITALY CID002763
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA CID002708
Gold Advanced Chemical Company UNITED STATES OF AMERICA CID000015
Gold African Gold Refinery UGANDA CID003185
Gold Aida Chemical Industries Co., Ltd. JAPAN CID000019
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES CID002560
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY CID000035
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN CID000041
Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL CID000058
Gold Argor-Heraeus S.A. SWITZERLAND CID000077
Gold Asahi Pretec Corp. JAPAN CID000082
Gold Asahi Refining Canada Ltd. CANADA CID000924
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA CID000920
Gold Asaka Riken Co., Ltd. JAPAN CID000090
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY CID000103
Gold AU Traders and Refiners SOUTH AFRICA CID002850
Gold Aurubis AG GERMANY CID000113
Gold Bangalore Refinery INDIA CID002863
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES CID000128
Gold Boliden AB SWEDEN CID000157
Gold C. Hafner GmbH + Co. KG GERMANY CID000176
Gold C.I Metales Procesados Industriales SAS COLOMBIA CID003421
Gold Caridad MEXICO CID000180
Gold CCR Refinery - Glencore Canada Corporation CANADA CID000185
Gold Cendres + Metaux S.A. SWITZERLAND CID000189
Gold CGR Metalloys Pvt Ltd. INDIA CID003382
Gold Chimet S.p.A. ITALY CID000233
Gold Chugai Mining JAPAN CID000264
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA CID000343
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY CID002867
Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES CID003348
Gold DODUCO Contacts and Refining GmbH GERMANY CID000362
Gold Dowa JAPAN CID000401
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF CID000359
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN CID000425
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN CID003424
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN CID003425
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE CID002515



Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA CID002852
Gold Geib Refining Corporation UNITED STATES OF AMERICA CID002459
Gold Gold Coast Refinery GHANA CID003186
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA CID002243
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA CID001909
Gold Guangdong Jinding Gold Limited CHINA CID002312
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA CID000651
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA CID000671
Gold Heimerle + Meule GmbH GERMANY CID000694
Gold Heraeus Metals Hong Kong Ltd. CHINA CID000707
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY CID000711
Gold Hunan Chenzhou Mining Co., Ltd. CHINA CID000767
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. CHINA CID000773
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA CID000801
Gold International Precious Metal Refiners UNITED ARAB EMIRATES CID002562
Gold Ishifuku Metal Industry Co., Ltd. JAPAN CID000807
Gold Istanbul Gold Refinery TURKEY CID000814
Gold Italpreziosi ITALY CID002765
Gold JALAN & Company INDIA CID002893
Gold Japan Mint JAPAN CID000823
Gold Jiangxi Copper Co., Ltd. CHINA CID000855
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION CID000927
Gold JSC Uralelectromed RUSSIAN FEDERATION CID000929
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN CID000937
Gold Kaloti Precious Metals UNITED ARAB EMIRATES CID002563
Gold Kazakhmys Smelting LLC KAZAKHSTAN CID000956
Gold Kazzinc KAZAKHSTAN CID000957
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA CID000969
Gold KGHM Polska Miedz Spolka Akcyjna POLAND CID002511
Gold Kojima Chemicals Co., Ltd. JAPAN CID000981
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF CID002605
Gold Kyrgyzaltyn JSC KYRGYZSTAN CID001029
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION CID002865
Gold L'azurde Company For Jewelry SAUDI ARABIA CID001032
Gold Lingbao Gold Co., Ltd. CHINA CID001056
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA CID001058
Gold L'Orfebre S.A. ANDORRA CID002762
Gold LT Metal Ltd. KOREA, REPUBLIC OF CID000689
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA CID001093
Gold Marsam Metals BRAZIL CID002606



Gold Matsuda Sangyo Co., Ltd. JAPAN CID001119
Gold Metalor Technologies (Hong Kong) Ltd. CHINA CID001149
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE CID001152
Gold Metalor Technologies (Suzhou) Ltd. CHINA CID001147
Gold Metalor Technologies S.A. SWITZERLAND CID001153
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA CID001157
Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO CID001161
Gold Mitsubishi Materials Corporation JAPAN CID001188
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN CID001193
Gold MMTC-PAMP India Pvt., Ltd. INDIA CID002509
Gold Modeltech Sdn Bhd MALAYSIA CID002857
Gold Morris and Watson NEW ZEALAND CID002282
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION CID001204
Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY CID001220
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN CID001236
Gold NH Recytech Company KOREA, REPUBLIC OF CID003189
Gold Nihon Material Co., Ltd. JAPAN CID001259
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA CID002779
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN CID001325
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION CID001326
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION CID000493
Gold Pease & Curren UNITED STATES OF AMERICA CID002872
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA CID001362
Gold Planta Recuperadora de Metales SpA CHILE CID002919
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION CID001386
Gold PT Aneka Tambang (Persero) Tbk INDONESIA CID001397
Gold PX Precinox S.A. SWITZERLAND CID001498
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA CID001512
Gold Refinery of Seemine Gold Co., Ltd. CHINA CID000522
Gold Royal Canadian Mint CANADA CID001534
Gold Sabin Metal Corp. UNITED STATES OF AMERICA CID001546
Gold Safimet S.p.A ITALY CID002973
Gold Sai Refinery INDIA CID002853
Gold Samduck Precious Metals KOREA, REPUBLIC OF CID001555
Gold Samwon Metals Corp. KOREA, REPUBLIC OF CID001562
Gold SAXONIA Edelmetalle GmbH GERMANY CID002777
Gold SEMPSA Joyeria Plateria S.A. SPAIN CID001585
Gold Shandong Humon Smelting Co., Ltd. CHINA CID002525
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA CID001619
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA CID001622
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA CID001736



Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA CID002516
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION CID001756
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA CID001761
Gold Sovereign Metals INDIA CID003383
Gold State Research Institute Center for Physical Sciences and Technology LITHUANIA CID003153
Gold Sudan Gold Refinery SUDAN CID002567
Gold Sumitomo Metal Mining Co., Ltd. JAPAN CID001798
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF CID002918
Gold T.C.A S.p.A ITALY CID002580
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN CID001875
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA CID001916
Gold Tokuriki Honten Co., Ltd. JAPAN CID001938
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA CID001947
Gold Tony Goetz NV BELGIUM CID002587
Gold TOO Tau-Ken-Altyn KAZAKHSTAN CID002615
Gold Torecom KOREA, REPUBLIC OF CID001955
Gold Umicore Brasil Ltda. BRAZIL CID001977
Gold Umicore Precious Metals Thailand THAILAND CID002314
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM CID001980
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA CID001993
Gold Valcambi S.A. SWITZERLAND CID002003
Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA CID002030
Gold WIELAND Edelmetalle GmbH GERMANY CID002778
Gold Yamakin Co., Ltd. JAPAN CID002100
Gold Yokohama Metal Co., Ltd. JAPAN CID002129
Gold Yunnan Copper Industry Co., Ltd. CHINA CID000197
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA CID002224
Tantalum Asaka Riken Co., Ltd. JAPAN CID000092
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA CID000211
Tantalum CP Metals Inc. UNITED STATES OF AMERICA CID003402
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA CID002504
Tantalum Exotech Inc. UNITED STATES OF AMERICA CID000456
Tantalum F&X Electro-Materials Ltd. CHINA CID000460
Tantalum FIR Metals & Resource Ltd. CHINA CID002505
Tantalum Global Advanced Metals Aizu JAPAN CID002558
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA CID002557
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA CID000616
Tantalum H.C. Starck Co., Ltd. THAILAND CID002544
Tantalum H.C. Starck Hermsdorf GmbH GERMANY CID002547
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA CID002548
Tantalum H.C. Starck Ltd. JAPAN CID002549
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY CID002550
Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY CID002545



Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA CID002492
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA CID002512
Tantalum Jiangxi Tuohong New Raw Material CHINA CID002842
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA CID000914
Tantalum Jiujiang Tanbre Co., Ltd. CHINA CID000917
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA CID002506
Tantalum KEMET Blue Metals MEXICO CID002539
Tantalum LSM Brasil S.A. BRAZIL CID001076
Tantalum Metallurgical Products India Pvt., Ltd. INDIA CID001163
Tantalum Mineracao Taboca S.A. BRAZIL CID001175
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN CID001192
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA CID001277
Tantalum NPM Silmet AS ESTONIA CID001200
Tantalum QuantumClean UNITED STATES OF AMERICA CID001508
Tantalum Resind Industria e Comercio Ltda. BRAZIL CID002707
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION CID001769
Tantalum Taki Chemical Co., Ltd. JAPAN CID001869
Tantalum Telex Metals UNITED STATES OF AMERICA CID001891
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN CID001969
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA CID002508
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA CID001522
Tin An Vinh Joint Stock Mineral Processing Company VIET NAM CID002703
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA CID000228
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA CID003190
Tin China Tin Group Co., Ltd. CHINA CID001070
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA CID003356
Tin Dowa JAPAN CID000402
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIET NAM CID002572
Tin Estanho de Rondonia S.A. BRAZIL CID000448
Tin Fenix Metals POLAND CID000468
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA CID003410
Tin Gejiu Kai Meng Industry and Trade LLC CHINA CID000942
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA CID000538
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA CID001908
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA CID000555



Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA CID003116
Tin Guanyang Guida Nonferrous Metal Smelting Plant CHINA CID002849
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA CID002844
Tin Huichang Jinshunda Tin Co., Ltd. CHINA CID000760
Tin Jiangxi New Nanshan Technology Ltd. CHINA CID001231
Tin Luna Smelter, Ltd. RWANDA CID003387
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA CID003379
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL CID002468
Tin Malaysia Smelting Corporation (MSC) MALAYSIA CID001105
Tin Melt Metais e Ligas S.A. BRAZIL CID002500
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA CID001142
Tin Metallo Belgium N.V. BELGIUM CID002773
Tin Metallo Spain S.L.U. SPAIN CID002774
Tin Mineracao Taboca S.A. BRAZIL CID001173
Tin Minsur PERU CID001182
Tin Mitsubishi Materials Corporation JAPAN CID001191
Tin Modeltech Sdn Bhd MALAYSIA CID002858
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIET NAM CID002573
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND CID001314
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES CID002517
Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF) CID001337
Tin Pongpipat Company Limited MYANMAR CID003208
Tin Precious Minerals and Smelting Limited INDIA CID003409
Tin PT Artha Cipta Langgeng INDONESIA CID001399
Tin PT ATD Makmur Mandiri Jaya INDONESIA CID002503
Tin PT Menara Cipta Mulia INDONESIA CID002835
Tin PT Mitra Stania Prima INDONESIA CID001453
Tin PT Refined Bangka Tin INDONESIA CID001460
Tin PT Timah Tbk Kundur INDONESIA CID001477
Tin PT Timah Tbk Mentok INDONESIA CID001482
Tin Resind Industria e Comercio Ltda. BRAZIL CID002706
Tin Soft Metais Ltda. BRAZIL CID001758
Tin Super Ligas BRAZIL CID002756
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIET NAM CID002834
Tin Thaisarco THAILAND CID001898
Tin Tin Technology & Refining UNITED STATES OF AMERICA CID003325
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIET NAM CID002574
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL CID002036
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA CID002158
Tin Yunnan Tin Company Limited CHINA CID002180
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA CID003397
Tungsten A.L.M.T. Corp. JAPAN CID000004



Tungsten ACL Metais Eireli BRAZIL CID002833
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. BRAZIL CID003427
Tungsten Asia Tungsten Products Vietnam Ltd. VIET NAM CID002502
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA CID002513
Tungsten China Molybdenum Co., Ltd. CHINA CID002641
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA CID000258
Tungsten CNMC (Guangxi) PGMA Co., Ltd. CHINA CID000281
Tungsten CP Metals Inc. UNITED STATES OF AMERICA CID003448
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA CID003401
Tungsten Fujian Jinxin Tungsten Co., Ltd. CHINA CID000499
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA CID002645
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA CID000875
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA CID002315
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA CID002494
Tungsten GEM Co., Ltd. CHINA CID003417
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA CID000568
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA CID000218
Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY CID002542
Tungsten H.C. Starck Tungsten GmbH GERMANY CID002541
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA CID000766
Tungsten Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji CHINA CID002579
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA CID000769
Tungsten Hunan Litian Tungsten Industry Co., Ltd. CHINA CID003182
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION CID002649
Tungsten Japan New Metals Co., Ltd. JAPAN CID000825
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA CID002551
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA CID002321
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA CID002313
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA CID002318
Tungsten Jiangxi Xianglu Tungsten Co., Ltd. CHINA CID002647
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA CID002317
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA CID002316
Tungsten JSC "Kirovgrad Hard Alloys Plant" RUSSIAN FEDERATION CID003408
Tungsten Kennametal Fallon UNITED STATES OF AMERICA CID000966
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA CID000105
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF CID003388
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA CID003407
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA CID002319
Tungsten Masan Tungsten Chemical LLC (MTC) VIET NAM CID002543
Tungsten Moliren Ltd. RUSSIAN FEDERATION CID002845
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA CID002589
Tungsten NPP Tyazhmetprom LLC RUSSIAN FEDERATION CID003416
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES CID002827



Tungsten Tejing (Vietnam) Tungsten Co., Ltd. VIET NAM CID001889
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION CID002724
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA CID002044
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF CID002843
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA CID002320
Tungsten Xiamen Tungsten Co., Ltd. CHINA CID002082
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA CID002830
Tungsten Xinhai Rendan Shaoguan Tungsten Co., Ltd. CHINA CID002095


Country of Origin List:


This list below sets out possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in the Report, however, these possible countries of origin cannot necessarily be linked to our products:


Afghanistan Albania Angola Argentina Armenia Australia Austria Belarus Belgium Bermuda Bolivia Brazil Bulgaria Burundi Cambodia Canada Central African Republic Chile China Colombia Czech Republic Djibouti Dominican Republic DRC or an adjoining country (Covered Countries) Ecuador Egypt England Estonia Ethiopia Finland France Germany Ghana Guinea Guyana Hungary India Indonesia Ireland Israel Italy Ivory Coast Japan Kazakhstan Kenya Kyrgyzstan Laos Liberia Lithuania Luxembourg Madagascar Malaysia Mali Mauritania Mexico Mongolia Morocco Mozambique Myanmar Namibia Netherlands New Zealand Niger Nigeria Papua New Guinea Peru Philippines Poland Portugal Republic Of Korea Russia Rwanda Saudi Arabia Sierra Leone Singapore Slovakia Slovenia South Africa Spain Sudan Suri Suriname Sweden Switzerland Tanzania Thailand Turkey Uganda United Arab Emirates United Kingdom USA Uzbekistan Viet Nam Zambia Zimbabwe