Form SD Alphatec Holdings, Inc.

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

 

 

FORM SD

 

 

Specialized Disclosure Report

 

 

ALPHATEC HOLDINGS, INC.

(Exact Name of Registrant as Specified in Charter)

 

 

 

Delaware		000-52024		20-2463898
(State or Other Jurisdiction of Incorporation)		(Commission File Number)		(I.R.S. Employer Identification No.)

5818 El Camino Real

Carlsbad, California 92008

(Address of Principal Executive Offices)

 

 

Jeffrey G. Black

Executive Vice President and Chief Financial Officer

(760) 431-9286

(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 applies:

 

☒	Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.

 

 

 

---

Section 1 – Conflict Minerals Disclosure

 

Item 1.01

Conflict Minerals Disclosure and Report

This Form SD of Alphatec Holdings, Inc. (“Alphatec” or the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2017 to December 31, 2017.

 

Item 1.02

Exhibit

As specified in Section 2, Item 2.01 of this Form SD, Alphatec is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report. The Conflict Minerals Report is also available on the “Investor Relations” page of the Company’s website, located at: http://www.atecspine.com.

Section 2 – Exhibits

 

Item 2.01

The following exhibit is filed as part of this Form SD.

 

Exhibit     No.		Description
1.01		Conflict Minerals Report of Alphatec Holdings, Inc. for the Year Ended December 31, 2017

---

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.

 

Date: May 22, 2018				ALPHATEC HOLDINGS, INC.
				By:		/s/ Jeffrey Black
				Name:		Jeffrey Black
				Title:		Executive Vice President and Chief Financial Officer

Exhibit 1.01

ALPHATEC HOLDINGS, INC.

Conflict Minerals Report

For the Year Ended December 31, 2017

 

1.	Introduction

This Conflict Minerals Report (“Report”) of Alphatec Holdings, Inc. (“Alphatec,” the “Company,” “we,” “us” or “our”) has been prepared pursuant to Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2017 to December 31, 2017 (the “Reporting Period”). Numerous terms in this Report are defined in the Rule and Form SD and the reader is referred to those sources and to SEC Release No. 34-67716, issued by the Securities and Exchange Commission (“SEC”) on August 22, 2012, for such definitions.

The Rule requires us to disclose annually whether any products that we manufactured or contracted to manufacture during the Reporting Period contain certain, specified minerals which are necessary to the functionality or production of the products and whether those specified minerals, if found necessary, originated in the Democratic Republic of the Congo or any adjoining country (each a “Covered Country” and collectively, the “Covered Countries”). The specific minerals at issue are cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, “Conflict Minerals”). If any of these Conflict Minerals originated in the Covered Countries, we are also required under the Rule to submit this Report, which describes the due diligence we performed in an effort to determine the source and chain of custody of those Conflict Minerals, among other things.

After conducting our reasonable country of origin inquiry (“RCOI”), briefly described below, we know or have reason to believe that some of our products manufactured or contracted for manufacture during the Reporting Period contain necessary Conflict Minerals that originated, or may have originated, in the Covered Countries and that they are not or may not be from recycled or scrap sources. Accordingly, we conducted due diligence on the source and chain of custody of those necessary Conflict Minerals that originated in the Covered Countries for the Reporting Period.

Certain statements in this Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. These forward-looking statements include expectations concerning the Company’s future actions to engage suppliers, to identify to the extent possible the source of Conflict Minerals in its products and to take other actions regarding its product sourcing. The Company’s actual actions or results may differ materially from those expected or anticipated in the forward-looking statements due to both known and unknown risks and uncertainties including, but not limited to, decisions to make changes in the Company’s continual improvement efforts and delays or difficulties in engaging suppliers and identifying the source of Conflict Minerals contained in the Company’s products.

This Report has not been audited, nor is an independent private sector audit required for this Report under the Rule, the SEC partial stay of the Rule or existing SEC guidance and instruction.

 

2.	Company Overview

We are a medical technology company focused on the design, development and promotion of products for the surgical treatment of spine disorders. Our mission is to improve patient lives through our relentless pursuit of superior outcomes. We have a broad product portfolio and pipeline that are designed to address the cervical, thoracolumbar and intervertebral regions of the spine and cover a variety of spinal disorders and surgical procedures. Our principal product offerings are focused on the U.S. market for fusion-based spinal disorder solutions. We believe that our products and systems are attractive to surgeons and patients due to innovative features and benefits that are designed to simplify surgical procedures for the surgeon and improve patient outcomes.

---

We are a Delaware corporation. We were incorporated in March 2005. Our principal executive office is located at 5818 El Camino Real, Carlsbad, California 92008 and our telephone number is (760) 431-9286. Our Internet address is www.atecspine.com.

 

3.	Reasonable Country of Origin Inquiry

We determined after review that necessary Conflict Minerals were contained in certain of our products during the Reporting Period. This determination was made due to the anticipated presence of such minerals in parts obtained from suppliers, either contract manufacturers or original equipment manufacturers, or from utilization of conflict minerals in manufacturing processes employed by our suppliers. Because of this determination, we conducted a RCOI, which was designed to determine whether any of the necessary Conflict Minerals in our products originated or may have originated in a Covered Country or came from recycled or scrap sources.

For the Reporting Period, we used our sourcing and procurement data and internal inquiries to identify sixty-one (61) suppliers who supplied us necessary Conflict Minerals during the Reporting Period. We contacted each of these suppliers and asked them to provide information on (1) the Conflict Minerals contained in each of the products manufactured for us by that supplier and (2) the source of the Conflict Minerals, including smelter/refinery information and location of mines. Each supplier was asked to complete the Conflict Minerals Reporting Template (“CMRT”) developed by the Conflict-Free Sourcing Initiative (the “CFSI”).

We received CMRT responses from 61 of the suppliers who supplied us necessary Conflict Minerals during the Reporting Period. Based on those responses, we determined that Conflict Minerals present in certain of our products, as well as Conflict Minerals utilized in the production of certain of our product parts, may have originated in the Covered Countries and were not from scrap or recycled sources. Accordingly, in accordance with the Rule, we performed due diligence in an effort to determine the source and chain of custody of these necessary Conflict Minerals.

 

4.	Due Diligence

We are several levels removed from the actual mining of Conflict Minerals. We do not make purchases of raw ore or unrefined Conflict Minerals, and we make no direct purchases of materials from third parties located in the Covered Countries. Because of our position in the supply chain, we designed our due diligence framework in conformity with, in all material respects, the criteria and five-step framework set forth 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, Third Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser. In this regard, we must rely on our suppliers to provide information regarding the country of origin and chain of custody of the Conflict Minerals included in products covered by the Rule.

In conformity with the OECD Guidance, below is a description of the measures we performed for the Reporting Period to exercise due diligence on the source and chain of custody of the necessary Conflict Minerals contained in our products that we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources.

OECD Step 1: Establish Strong Company Management Systems

 

•

We are committed to compliance with Conflict Minerals legislation and have implemented appropriate due-diligence processes to meet our obligations. We continued to review and assess our Conflict Minerals processes to ensure that we conduct all of our operations and activities in compliance with applicable Conflict Minerals legislation.

 

Page 2 of 13

---

•

We maintained a risk management plan that includes due diligence reviews of suppliers, smelters and refiners which we identified may be sourcing or processing Conflict Minerals from the Covered Countries and which may not be from recycled or scrap sources.

 

•

We maintained an internal Conflict Minerals taskforce with cross functional team members and executives, to facilitate communication and supplier engagement, conduct due diligence compliance process and measurement, keep records and implement our risk management plan.

OECD Step 2: Identify and Assess Risk in the Supply Chain

 

•

We compiled a list of all suppliers who provide components that are used in the manufacturing of all Alphatec products.

 

•

We stratified the supplier list by the commodity type provided by each given supplier.

 

•

We excluded from the supplier list commodity types for which there is no risk of the use of Conflict Minerals.

 

•

We actively surveyed the remaining suppliers by submitting the CFSI CMRT and utilizing reasonable means to obtain self-declarations identifying the minerals used in the manufacture of products, the origin of any Conflict Minerals used, where applicable, included in the product(s) provided to Alphatec.

 

•

Where necessary, we followed up with those direct suppliers contacted to obtain additional information and/or responses to supply chain survey template that we identified contained incomplete or potentially inaccurate information to seek additional clarifying information.

 

•

We used the CMRT to review our direct suppliers’ due diligence activities, such as whether they had a Conflict Minerals policy, required their own suppliers to source from processing facilities validated by an independent audit firm, and implemented a review process that includes corrective action management.

 

•

We used the CMRT to identify Conflict Minerals processing facilities if reported in our supply chain by direct suppliers.

 

•

We determined if the processing facilities adhere to responsible sourcing practices by cross-checking with the list of Conflict Free Smelter Program (“CFSP”) compliant processing facilities.

 

•

We obtained countries of origin (when available) for CFSP-compliant processing facilities by relying on information provided by our direct suppliers and other public data sources.

OECD Step 3: Design and Implement a Strategy to Respond to Risk

 

•

We reported information on the source and chain of custody of Conflict Minerals in our supply chain to our Conflict Minerals working team and Conflicts Mineral taskforce on a regular basis.

 

•

We maintained a Conflict Minerals risk management plan that sets forth direct supplier-risk management strategies ranging from continued procurement to disengagement.

 

•

We provided formal and informal continuing education and training to members of our Conflict Minerals taskforce and our other employees who are involved with Conflict Minerals and suppliers.

OECD Step 4: Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

 

•

Because we do not source directly from processing facilities, we rely on the publicly-available results of the CFSP, London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”) third-party audits to validate the responsible sourcing practices of processing facilities in our supply chain.

 

Page 3 of 13

---

•

The CFSI recognizes processing facilities as CFSP-compliant through validations conducted by the LBMA and RJC.

OECD Step 5: Report Annually on Supply Chain Due Diligence

 

•

We file a Form SD and Conflict Minerals Report with the SEC on an annual basis. Our Form SD and Conflict Minerals Report are also available on our website.

 

5.	Results of Good Faith RCOI and Due Diligence Process

Based on the information obtained pursuant to the good faith RCOI and due diligence processes described above, for the Reporting Period, we do not have sufficient information with respect to the Conflict Minerals to determine the country of origin of all of the Conflict Minerals we use to manufacture the our subject products and thus are unable to determine whether any of the Conflict Minerals originated in the Covered Countries and, if so, whether the Conflict Minerals were from recycled or scrap sources or financed conflict in the Covered Countries.

Our inability to reach specific and verifiable conclusions as to the products containing or utilizing Conflict Minerals, despite our efforts, primarily resulted from the following challenges or complicating factors.

 

•

We are dependent on information received from our direct suppliers to conduct our good faith RCOI process.

 

•

We have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to the Rule.

 

•

The information our suppliers provided was often incomplete and required significant follow-up. Nevertheless, each supplier response was evaluated and, where possible, validated to determine sufficiency, accuracy or completeness of its response. For each supplier response, we subsequently assessed whether the Conflict Minerals identified, or those Conflict Minerals that may not have been identified, were consistent with the nature and characteristics of the manufactured product or supplied part. For each supplier response that was insufficient, potentially inaccurate or incomplete, we contacted that supplier for follow up, sometimes contacting certain suppliers on multiple occasions. When a supplier EICC-GeSI response stated that Conflict Minerals were sourced from the Covered Countries and identified the smelter involved, we endeavored to verify whether the smelter referenced by the supplier was identified on the EICC-GeSI Conflict Free Smelter List. If a supplier stated that Conflict Minerals in its product were not sourced from the Covered Countries but did not substantiate that information, we proceeded to verify that supplier response. Typically, verification involved a more detailed review of the supplier’s smelter response and, where possible, discussion with the supplier. If a supplier’s response could not be validated through details provided with regard to the smelter and/or smelters involved, then the supplier response in question was determined to be uncertain or unknown relative to the question of sourcing of raw material and was reflected as such in the Company’s EICC-GeSI template summary.

 

•

Suppliers provided responses at a company or divisional level, and not at a product level specific to the materials and components we use in the identified products.

 

•

As a downstream purchaser of Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary Conflict Minerals. Our ability to influence cooperation from certain suppliers was limited when our use of these suppliers was mandated by our customers or when we were multiple tiers away from the smelter in the supply chain.

 

Page 4 of 13

---

•

We rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.

 

•

The unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. Under the Dodd-Frank Act and the Rule, a product is “DRC conflict free” if it meets the required standard every day of the reporting year; conversely, a product would “not be found to be DRC conflict free” if it does not meet the required standard even one day of the reporting year. The supply chain of commodities such as Conflict Minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.

As a result, we have not been able to identify or verify all of the smelters from which our suppliers sourced the Conflict Minerals. For the Conflict Minerals which we were able to identify information about the smelter, we have noted that some of the smelters are currently on the conflict free smelters list published by the CFSI.

Set forth below is the list of known smelters we identified through our good faith RCOI and related due diligence:

 

Subject Mineral		Smelter or Refiner Name		Location of Smelter/ Refiner
Tungsten		A.L.M.T. TUNGSTEN Corp.		JAPAN
Gold		Abington Reldan Metals, LLC		USA
Tungsten		ACL Metais Eireli		BRAZIL
Gold		Advanced Chemical Company		USA
Gold		Aida Chemical Industries Co., Ltd.		JAPAN
Gold		Al Etihad Gold Refinery DMCC		UAE
Gold		Allgemeine Gold-und Silberscheideanstalt A.G.		GERMANY
Gold		Almalyk Mining and Metallurgical Complex (AMMC)		UZBEKISTAN
Tin		Alpha		USA
Tin		An Thai Minerals Co., Ltd.		VIETNAM
Tin		An Vinh Joint Stock Mineral Processing Company		VIETNAM
Gold		AngloGold Ashanti Córrego do Sítio Mineração		BRAZIL
Gold		Argor-Heraeus S.A.		SWITZERLAND
Gold		Asahi Pretec Corp.		JAPAN
Gold		Asahi Refining Canada Ltd.		CANADA
Gold		Asahi Refining USA Inc.		USA
Gold		Asaka Riken Co., Ltd.		JAPAN

 

Page 5 of 13

---

Tungsten		Asia Tungsten Products Vietnam Ltd.		VIETNAM
Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY
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		Caridad		MEXICO
Gold		CCR Refinery - Glencore Canada Corporation		CANADA
Gold		Cendres + Métaux S.A.		SWITZERLAND
Tantalum		Changsha South Tantalum Niobium Co., Ltd.		CHINA
Tungsten		Chenzhou Diamond Tungsten Products Co., Ltd.		CHINA
Tin		Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.		CHINA
Gold		Chimet S.p.A.		ITALY
Tin		China Tin Group Co., Ltd.		CHINA
Tungsten		Chongyi Zhangyuan Tungsten Co., Ltd.		CHINA
Gold		Chugai Mining		JAPAN
Tin		CNMC (Guangxi) PGMA Co., Ltd.		CHINA
Tantalum		Conghua Tantalum and Niobium Smeltry		CHINA
Tin		Cooperativa Metalurgica de Rondônia Ltda.		BRAZIL
Tin		CV Ayi Jaya		INDONESIA
Tin		CV Dua Sekawan		INDONESIA
Tin		CV Gita Pesona		INDONESIA
Tin		CV Serumpun Sebalai		INDONESIA
Tin		CV Tiga Sekawan		INDONESIA
Tin		CV United Smelting		INDONESIA
Tin		CV Venus Inti Perkasa		INDONESIA
Tantalum		D Block Metals, LLC		USA
Gold		Daejin Indus Co., Ltd.		SOUTH KOREA
Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA
Tungsten		Dayu Weiliang Tungsten Co., Ltd.		CHINA
Gold		Degussa Sonne / Mond Goldhandel GmbH		GERMANY
Gold		DODUCO GmbH		GERMANY
Gold		Dowa		JAPAN
Tin		Dowa		JAPAN
Gold		DSC (Do Sung Corporation)		SOUTH KOREA
Tantalum		Duoluoshan		CHINA
Gold		Eco-System Recycling Co., Ltd.		JAPAN
Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIETNAM
Gold		Elemetal Refining, LLC		USA

 

Page 6 of 13

---

Tin		EM Vinto		BOLIVIA
Gold		Emirates Gold DMCC		UAE
Tin		Estanho de Rondônia S.A.		BRAZIL
Tantalum		Exotech Inc.		USA
Tantalum		F&X Electro-Materials Ltd.		CHINA
Tin		Fenix Metals		POLAND
Gold		Fidelity Printers and Refiners Ltd.		ZIMBABWE
Tantalum		FIR Metals & Resource Ltd.		CHINA
Tungsten		Fujian Jinxin 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		Ganzhou Yatai Tungsten Co., Ltd.		CHINA
Gold		Geib Refining Corporation		USA
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		Gejiu Zili Mining And Metallurgy Co., Ltd.		CHINA
Tantalum		Global Advanced Metals Aizu		JAPAN
Tantalum		Global Advanced Metals Boyertown		USA
Tungsten		Global Tungsten & Powders Corp.		USA
Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA
Gold		Guangdong Jinding Gold Limited		CHINA
Tantalum		Guangdong Rising Rare Metals-EO Materials Ltd.		CHINA
Tungsten		Guangdong Xianglu Tungsten Co., Ltd.		CHINA
Tantalum		Guangdong Zhiyuan New Material Co., Ltd.		CHINA
Tin		Guanyang Guida Nonferrous Metal Smelting Plant		CHINA
Gold		Gujarat Gold Centre		INDIA
Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA
Tantalum		H.C. Starck Co., Ltd.		THAILAND
Tungsten		H.C. Starck GmbH		GERMANY
Tantalum		H.C. Starck Hermsdorf GmbH		GERMANY
Tantalum		H.C. Starck Inc.		USA
Tantalum		H.C. Starck Ltd.		JAPAN
Tantalum		H.C. Starck Smelting GmbH & Co. KG		GERMANY
Tungsten		H.C. Starck Smelting GmbH & Co. KG		GERMANY
Tantalum		H.C. Starck Tantalum and Niobium GmbH		GERMANY
Tungsten		H.C. Starck Tungsten GmbH		GERMANY
Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA
Gold		Heimerle + Meule GmbH		GERMANY

 

Page 7 of 13

---

Tantalum		Hengyang King Xing Lifeng New Materials Co., Ltd.		CHINA
Gold		Heraeus Metals Hong Kong Ltd.		CHINA
Gold		Heraeus Precious Metals GmbH & Co. KG		GERMANY
Tantalum		Hi-Temp Specialty Metals, Inc.		USA
Tin		HuiChang Hill Tin Industry Co., Ltd.		CHINA
Tin		Huichang Jinshunda Tin Co., Ltd.		CHINA
Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA
Tungsten		Hunan Chenzhou Mining Co., Ltd.		CHINA
Tungsten		Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji		CHINA
Tungsten		Hunan Chunchang Nonferrous Metals Co., Ltd.		CHINA
Gold		Hwaseong CJ Co., Ltd.		SOUTH KOREA
Tungsten		Hydrometallurg, JSC		RUSSIAN FEDERATION
Gold		Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.		CHINA
Gold		Ishifuku Metal Industry Co., Ltd.		JAPAN
Gold		Istanbul Gold Refinery		TURKEY
Gold		Japan Mint		JAPAN
Tungsten		Japan New Metals Co., Ltd.		JAPAN
Tungsten		Jiangwu H.C. Starck Tungsten Products Co., Ltd.		CHINA
Gold		Jiangxi Copper Co., Ltd.		CHINA
Tungsten		Jiangxi Dayu Longxintai Tungsten Co., Ltd.		CHINA
Tantalum		Jiangxi Dinghai Tantalum & Niobium Co., Ltd.		CHINA
Tungsten		Jiangxi Gan Bei Tungsten Co., Ltd.		CHINA
Tin		Jiangxi Ketai Advanced Material Co., Ltd.		CHINA
Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA
Tungsten		Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.		CHINA
Tantalum		Jiangxi Tuohong New Raw Material		CHINA
Tungsten		Jiangxi Xinsheng Tungsten Industry Co., Ltd.		CHINA
Tungsten		Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.		CHINA
Tungsten		Jiangxi Yaosheng Tungsten Co., Ltd.		CHINA
Tantalum		JiuJiang JinXin Nonferrous Metals Co., Ltd.		CHINA
Tantalum		Jiujiang Nonferrous Metals Smelting Company Limited		CHINA
Tantalum		Jiujiang Tanbre Co., Ltd.		CHINA
Tantalum		Jiujiang Zhongao Tantalum & Niobium Co., Ltd.		CHINA
Gold		JSC Ekaterinburg Non-Ferrous Metal Processing Plant		RUSSIAN FEDERATION
Gold		JSC Uralelectromed		RUSSIAN FEDERATION
Gold		JX Nippon Mining & Metals Co., Ltd.		JAPAN
Gold		Kaloti Precious Metals		UAE
Gold		Kazakhmys Smelting LLC		KAZAKHSTAN
Gold		Kazzinc		KAZAKHSTAN
Tantalum		KEMET Blue Metals		MEXICO
Tantalum		KEMET Blue Powder		USA

 

Page 8 of 13

---

Tungsten		Kennametal Fallon		USA
Tungsten		Kennametal Huntsville		USA
Gold		Kennecott Utah Copper LLC		USA
Gold		KGHM Polska Miedź Spółka Akcyjna		POLAND
Tantalum		King-Tan Tantalum Industry Ltd.		CHINA
Gold		Kojima Chemicals Co., Ltd.		JAPAN
Gold		Korea Zinc Co., Ltd.		SOUTH KOREA
Gold		Kyrgyzaltyn JSC		KYRGYZSTAN
Gold		L’azurde Company For Jewelry		SAUDI ARABIA
Gold		Lingbao Gold Co., Ltd.		CHINA
Gold		Lingbao Jinyuan Tonghui Refinery Co., Ltd.		CHINA
Tantalum		LSM Brasil S.A.		BRAZIL
Gold		LS-NIKKO Copper Inc.		SOUTH KOREA
Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA
Tin		Magnu’s Minerais Metais e Ligas Ltda.		BRAZIL
Tin		Malaysia Smelting Corporation (MSC)		MALAYSIA
Tungsten		Malipo Haiyu Tungsten Co., Ltd.		CHINA
Gold		Materion		USA
Gold		Matsuda Sangyo Co., Ltd.		JAPAN
Tin		Melt Metais e Ligas S.A.		BRAZIL
Tin		Metallic Resources, Inc.		USA
Tin		Metallo Belgium N.V.		BELGIUM
Tin		Metallo-Chimique N.V.		BELGIUM
Tantalum		Metallurgical Products India Pvt., Ltd.		INDIA
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		USA
Gold		Metalúrgica Met-Mex Peñoles S.A. De C.V.		MEXICO
Tantalum		Mineração Taboca S.A.		BRAZIL
Tin		Mineração Taboca S.A.		BRAZIL
Tin		Minsur		PERU
Gold		Mitsubishi Materials Corporation		JAPAN
Tin		Mitsubishi Materials Corporation		JAPAN
Tantalum		Mitsui Mining & Smelting		JAPAN
Gold		Mitsui Mining and Smelting Co., Ltd.		JAPAN
Tantalum		Mitsui Mining and Smelting Co., Ltd.		JAPAN
Gold		MMTC-PAMP India Pvt., Ltd.		INDIA
Gold		Modeltech Sdn Bhd		MALAYSIA
Tin		Modeltech Sdn Bhd		MALAYSIA
Tungsten		Moliren Ltd		RUSSIAN FEDERATION
Tantalum		Molycorp Silmet A.S.		ESTONIA

 

Page 9 of 13

---

Gold		Morris and Watson		NEW ZEALAND
Gold		Moscow Special Alloys Processing Plant		RUSSIAN FEDERATION
Gold		Nadir Metal Rafineri San. Ve Tic. A.Ş.		TURKEY
Tin		Nankang Nanshan Tin Manufactory Co., Ltd.		CHINA
Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN
Tin		Nghe Tinh Non-Ferrous Metals Joint Stock Company		VIETNAM
Tungsten		Niagara Refining LLC		USA
Gold		Nihon Material Co., Ltd.		JAPAN
Tantalum		Ningxia Orient Tantalum Industry Co., Ltd.		CHINA
Tungsten		Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC		VIETNAM
Tin		O.M. Manufacturing (Thailand) Co., Ltd.		THAILAND
Tin		O.M. Manufacturing Philippines, Inc.		PHILIPPINES
Gold		Ögussa Österreichische 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
Tin		Operaciones Metalurgical S.A.		BOLIVIA
Gold		PAMP S.A.		SWITZERLAND
Gold		Penglai Penggang Gold Industry Co., Ltd.		CHINA
Tungsten		Philippine Chuangxin Industrial Co., Inc.		PHILIPPINES
Tantalum		Power Resources Ltd.		MACEDONIA
Gold		Prioksky Plant of Non-Ferrous Metals		RUSSIAN FEDERATION
Gold		PT Aneka Tambang (Persero) Tbk		INDONESIA
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 Tin Industry		INDONESIA
Tin		PT Belitung Industri Sejahtera		INDONESIA
Tin		PT Bukit Timah		INDONESIA
Tin		PT Cipta Persada Mulia		INDONESIA
Tin		PT DS Jaya Abadi		INDONESIA
Tin		PT Eunindo Usaha Mandiri		INDONESIA
Tin		PT Inti Stania Prima		INDONESIA
Tin		PT Justindo		INDONESIA
Tin		PT Karimun Mining		INDONESIA
Tin		PT Kijang Jaya Mandiri		INDONESIA
Tin		PT Lautan Harmonis Sejahtera		INDONESIA
Tin		PT Mitra Stania Prima		INDONESIA
Tin		PT O.M. Indonesia		INDONESIA

 

Page 10 of 13

---

Tin		PT Panca Mega Persada		INDONESIA
Tin		PT Prima Timah Utama		INDONESIA
Tin		PT Refined Bangka Tin		INDONESIA
Tin		PT Sariwiguna Binasentosa		INDONESIA
Tin		PT Stanindo Inti Perkasa		INDONESIA
Tin		PT Sukses Inti Makmur		INDONESIA
Tin		PT Sumber Jaya Indah		INDONESIA
Tin		PT Timah (Persero) Tbk Kundur		INDONESIA
Tin		PT Timah (Persero) Tbk Mentok		INDONESIA
Tin		PT Tinindo Inter Nusa		INDONESIA
Tin		PT Tommy Utama		INDONESIA
Gold		PX Précinox S.A.		SWITZERLAND
Tantalum		QuantumClean		USA
Gold		Rand Refinery (Pty) Ltd.		SOUTH AFRICA
Gold		Remondis Argentia B.V.		NETHERLANDS
Gold		Republic Metals Corporation		USA
Tantalum		Resind Indústria e Comércio Ltda.		BRAZIL
Tin		Resind Indústria e Comércio Ltda.		BRAZIL
Tantalum		RFH Tantalum Smeltry Co., Ltd.		CHINA
Gold		Royal Canadian Mint		CANADA
Tin		Rui Da Hung		TAIWAN
Gold		SAAMP		FRANCE
Gold		Sabin Metal Corp.		USA
Gold		SAFINA A.S.		CZECH REPUBLIC
Gold		Sai Refinery		INDIA
Gold		Samduck Precious Metals		SOUTH KOREA
Gold		SAMWON Metals Corp.		SOUTH KOREA
Gold		SAXONIA Edelmetalle GmbH		GERMANY
Gold		Schone Edelmetaal B.V.		NETHERLANDS
Gold		SEMPSA Joyería Platería S.A.		SPAIN
Gold		Shandong Tiancheng Biological Gold Industrial Co., Ltd.		CHINA
Gold		Shandong Zhaojin Gold & Silver Refinery Co., Ltd.		CHINA
Gold		Sichuan Tianze Precious Metals Co., Ltd.		CHINA
Gold		Singway Technology Co., Ltd.		TAIWAN
Gold		So Accurate Group, Inc.		USA
Gold		SOE Shyolkovsky Factory of Secondary Precious Metals		RUSSIAN FEDERATION
Tin		Soft Metais Ltda.		BRAZIL
Gold		Solar Applied Materials Technology Corp.		TAIWAN
Tantalum		Solikamsk Magnesium Works OAO		RUSSIAN FEDERATION
Tungsten		South-East Nonferrous Metal Company Limited of Hengyang City		CHINA
Gold		Sudan Gold Refinery		SUDAN

 

Page 11 of 13

---

Gold		Sumitomo Metal Mining Co., Ltd.		JAPAN
Gold		T.C.A S.p.A		ITALY
Tantalum		Taki Chemical Co., Ltd.		JAPAN
Gold		Tanaka Kikinzoku Kogyo K.K.		JAPAN
Tungsten		Tejing (Vietnam) Tungsten Co., Ltd.		VIETNAM
Tantalum		Telex Metals		USA
Tin		Thaisarco		THAILAND
Gold		The Refinery of Shandong Gold Mining Co., Ltd.		CHINA
Gold		Tokuriki Honten Co., Ltd.		JAPAN
Gold		Tongling Nonferrous Metals Group Co., Ltd.		CHINA
Gold		Tony Goetz NV		BELGIUM
Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN
Gold		Torecom		SOUTH KOREA
Tantalum		Tranzact, Inc.		USA
Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIETNAM
Tantalum		Ulba Metallurgical Plant JSC		KAZAKHSTAN
Gold		Umicore Brasil Ltda.		BRAZIL
Gold		Umicore Precious Metals Thailand		THAILAND
Gold		Umicore S.A. Business Unit Precious Metals Refining		BELGIUM
Tungsten		Unecha Refractory metals plant		RUSSIAN FEDERATION
Gold		United Precious Metal Refining, Inc.		USA
Gold		Universal Precious Metals Refining Zambia		ZAMBIA
Gold		Valcambi S.A.		SWITZERLAND
Tungsten		Vietnam Youngsun Tungsten Industry Co., Ltd.		VIETNAM
Tin		VQB Mineral and Trading Group JSC		VIETNAM
Gold		Western Australian Mint trading as The Perth Mint		AUSTRALIA
Tin		White Solder Metalurgia e Mineracao Ltda.		BRAZIL
Gold		WIELAND Edelmetalle GmbH		GERMANY
Tungsten		Wolfram Bergbau und Hütten AG		AUSTRIA
Tungsten		Woltech Korea Co., Ltd.		SOUTH KOREA
Tungsten		Xiamen Tungsten Co., Ltd.		CHINA
Tungsten		Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.		CHINA
Tungsten		Xinhai Rendan Shaoguan Tungsten Co., Ltd.		CHINA
Tantalum		XinXing HaoRong Electronic Material Co., Ltd.		CHINA
Gold		Yamamoto Precious Metal Co., Ltd.		JAPAN
Tantalum		Yichun Jin Yang Rare Metal Co., Ltd.		CHINA
Gold		Yokohama Metal Co., Ltd.		JAPAN
Tin		Yunnan Chengfeng Non-ferrous Metals Co., Ltd.		CHINA
Gold		Yunnan Copper Industry Co., Ltd.		CHINA
Tin		Yunnan Tin Company Limited		CHINA
Gold		Zhongyuan Gold Smelter of Zhongjin Gold Corporation		CHINA

 

Page 12 of 13

---

Tantalum		Zhuzhou Cemented Carbide Group Co., Ltd.		CHINA
Gold		Zijin Mining Group Co., Ltd. Gold Refinery		CHINA

Despite our good faith, reasonable country of origin inquiries, due to the number of suppliers for which we have not received confirmed responses from for all of our questions regarding the source and chain of custody of the necessary Conflict Minerals in our Products, we currently have not obtained sufficient information from all of our suppliers to determine the origin, name and location of the facilities used to process all of the necessary Conflict Minerals.

Despite the foregoing conclusion, we undertook and continue to undertake the due diligence measures and procedures to attempt to determine the applicable facilities and countries of origin for the necessary Conflict Minerals for the Products, including making numerous follow up inquiries of the applicable suppliers who were nonresponsive and/or who indicated to us that they were still attempting to independently determine the smelter or source of the Conflict Minerals obtained by such suppliers.

 

6.	Risk Mitigation

We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. Our supply chain management next steps may include, but are not limited to the following:

 

•

continue to work with suppliers that provided incomplete responses or that did not provide responses for 2017 to help ensure that they provide requested information for 2018;

 

•

continue to request information and supporting data from each supplier manufacturing products for Alphatec that are subject to reporting requirements by utilizing any revised CMRT; and will pursue a completed template response that identifies material down to the smelter and mine;

 

•

continue to refine our Conflict Minerals risk management strategy based on the results of our due diligence on products manufactured and procured in 2017;

 

•

continue our due diligence process to review and validate supplier responses that are obtained in support of our Conflict Minerals reporting; and

 

•

provide continuing education and training to members of our Conflict Minerals taskforce and our other employees who are involved with Conflict Minerals and suppliers.

 

Page 13 of 13

---

Serious News for Serious Traders! Try StreetInsider.com Premium Free!

---

You May Also Be Interested In

• Man Group PLC : Form 8.3 - Barratt Developments plc
• Entergy Texas’ First Solar Resource Helps Customers Meet Sustainability Goals
• RROCKET Burns 50% of Its Supply to Fuel Growth and Investor Confidence