Form SD Wesco Aircraft Holdings,
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Wesco Aircraft Holdings, Inc.
(Exact name of registrant as specified in its charter)
Delaware | 001-35253 | 20-5441563 | ||
(State or other jurisdiction of incorporation or organization) | (Commission File Number) | (IRS Employer Identification No.) | ||
24911 Avenue Stanford, Valencia, California | 91355 | |
(Address of principal executive offices) | (Zip Code) | |
John G. Holland
Executive Vice President, Chief Legal and Human Resources Officer
(661) 775-7200
(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:
ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.
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Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
A copy of Wesco Aircraft Holdings, Inc.’s Conflict Minerals Report filed for the calendar year ended December 31, 2018 is publicly available at http://ir.wescoair.com/financial-information/sec-filings.
Item 1.02 Exhibit
Wesco Aircraft Holdings, Inc.’s Conflict Minerals Report for the calendar year ended December 31, 2018 is filed as Exhibit 1.01 hereto.
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.
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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.
WESCO AIRCRAFT HOLDINGS, INC. | ||
BY: | /s/ John G. Holland | |
John G. Holland Executive Vice President, Chief Legal and Human Resources Officer | ||
Date: May 29, 2019
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Exhibit 1.01
Wesco Aircraft Holdings, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2018
This Conflict Minerals Report (the “Report”) for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”).
Wesco Aircraft Holdings, Inc. (“Wesco” or the “Company”) is the world’s leading independent distributor and provider of comprehensive supply chain management services to the global aerospace industry, based on annual sales. Wesco’s services range from traditional distribution to the management of supplier relationships, quality assurance, kitting, just-in-time (“JIT”) delivery, chemical management services, third-party logistics or fourth-party logistics programs and point-of-use inventory management. The Company supplies over 560,000 active stock-keeping units, including C-class hardware, chemicals, electronic components, bearings, tools and machined parts. Wesco serves its customers under both (1) long-term contractual arrangements, which include JIT contracts that govern the provision of comprehensive outsourced supply chain management services and long-term agreements that typically set prices for specific products, and (2) ad hoc sales. Unless the context otherwise indicates or requires, as used in this Report, references to “we,” “us,” “our,” “Wesco” or our “Company” refer to Wesco Aircraft Holdings, Inc. and its subsidiaries.
Products Covered by This Report
For the period covered by this Report, we did not manufacture or contract to manufacture most of the products that we supplied to customers; however, we did manufacture certain of our electronic products and contracted to manufacture certain of our machined and customer-designed parts (collectively, the “Covered Products”) containing conflict minerals (defined in Item 1.01 of Form SD as columbite-tantalite (coltan), cassiterite, gold, wolframite and their derivatives, which are limited to tantalum, tin and tungsten) that are necessary to the functionality or production of the Covered Products.
For the 2018 reporting year, we treated all electronic products assembled by Wesco as “manufactured” and all products for which we enter into subcontracts with manufacturers and for which we provide customer designs as “contracted to manufacture” under the Rule.
Reasonable Country of Origin Inquiry
We conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary conflict minerals in our Covered Products originated in the Democratic Republic of the Congo (“DRC”) or a country that shares an internationally recognized border with DRC (each a “Covered Country”) or were from recycled or scrap sources. To make this determination, we focused on engaging our direct suppliers to identify the smelters and refiners (“facilities”) of necessary conflict minerals that may have been contained in our products and that are recognized by the Conflict Free Sourcing Initiative (“CFSI”) to be processors of conflict minerals (“Potential 3TG Facilities”), and reviewing available information on the sourcing of conflict minerals by Potential 3TG Facilities.
Our RCOI included:
• | a survey of our direct suppliers using the CFSI Conflict Minerals Reporting Template (the “CFSI Template”), from which we identified the 637 suppliers of materials, parts, components or products containing necessary conflict minerals (“3TG Direct Suppliers”); |
• | requiring, as part of the survey and our accompanying communications, that 3TG Direct Suppliers use the CFSI Template to obtain and provide us information from their supply chains regarding Potential 3TG Facilities and the origin of necessary conflict minerals processed at these facilities; |
• | following up with 3TG Direct Suppliers to clarify, update or complete information reported to us through the survey; and |
• | reviewing any information on countries of origin available through our membership in CFSI for Potential 3TG Facilities. |
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As a result of our RCOI efforts, we received responses from 562 of our 637 3TG Direct Suppliers, representing approximately 88%. Based on our RCOI efforts, our 3TG Direct Suppliers identified 319 operational smelters and refiner facilities which may process the necessary conflict minerals contained in our products. We know, or have reason to believe, that a portion of these conflict minerals processed by 189 of these 319 smelters and refiners may have originated in a Covered Country and may not be solely from recycled or scrap sources.
Design of Our Due Diligence Measures
The design of our due diligence measures is intended to conform, in all material respects, to the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related Supplements on Tin, Tantalum and Tungsten and on Gold (the “OECD Guidance”).
Consistent with the OECD Guidance, the design of our due diligence has the following features:
(1) Establishment of strong internal company management systems.
During calendar year 2018, we communicated with 3TG Direct Suppliers regarding their responsibilities under our conflict minerals program through direct communications, including letters explaining the Rule, our expectations of 3TG Direct Suppliers and how to access the CFSI Template on our website, which also includes our written conflict minerals policy, which we adopted in 2014 and is publicly available on our website at https://www.wescoair.com/docs/default-source/compliance/conflict-minerals-policy-v2.pdf?sfvrsn=ee4001a1_6. Our policy sets forth our commitment to responsible sourcing of conflict minerals and our expectation for 3TG Direct Suppliers to provide materials to Wesco that do not directly or indirectly finance or benefit armed groups in the Covered Countries, adopt policies and procedures to support our compliance with the Rule, and participate in our due diligence efforts.
Since its creation in 2013, our internal conflict minerals team has been responsible for the development, leadership and execution of our conflict minerals program. The team provides direct oversight of our conflict minerals program and is comprised of senior representatives of the following departments: legal, quality engineering and supply chain. Additionally, members of the internal conflict minerals team have provided regular updates on the progress of Wesco’s conflict minerals program directly to senior management and have kept Wesco’s board of directors apprised of material developments in the conflict minerals program.
We do not purchase conflict minerals directly from mines, smelters or refiners. As a result, we must rely on our 3TG Direct Suppliers to provide us with information regarding the conflict minerals contained in the products and materials those 3TG Direct Suppliers provide to us, and our 3TG Direct Suppliers are similarly reliant upon information provided by their suppliers. In order to collect information from 3TG Direct Suppliers, we implemented and maintain a supply chain transparency effort based on the due diligence tools developed by CFSI, including a 3TG Direct Supplier survey based on the CFSI Template, which is designed to identify the smelters and refiners that process the conflict minerals in a company’s supply chain.
After identifying the Covered Products, we compiled a list of 3TG Direct Suppliers to survey and sent a letter explaining the SEC’s conflict minerals reporting requirements to these 3TG Direct Suppliers. This letter also included instructions for completing the survey and links to training resources on due diligence provided by CFSI.
We are committed to operating under the highest ethical standards of business conduct, and we have an established grievance mechanism, as described in our Code of Business Ethics and Conduct, that enables individuals to report concerns, including any concerns regarding our conflict minerals supply chain.
(2) Identification and assessment of risks in the supply chain.
We documented the information received from the 3TG Direct Suppliers, and, with respect to the 3TG Direct Suppliers that provided smelter and refiner information, compared the smelters and refiners identified by the supply chain survey against CFSI’s conflict-free smelter list. We also reviewed responses for completeness and have sent follow-up notifications to nonresponsive 3TG Direct Suppliers and 3TG Direct Suppliers that failed to complete the CFSI Template. Through this process, we identified the 3TG Direct Suppliers that, notwithstanding our efforts to follow up about the 3TG Direct Supplier survey, provided incomplete responses, were unresponsive to our requests or refused to respond to our inquiry.
(3) Design and implementation of a strategy to respond to identified risks.
We have taken steps to respond to identified risks and monitor 3TG Direct Suppliers’ progress in meeting the expectations set
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forth in our conflict minerals policy. We have worked with 3TG Direct Suppliers to develop strategies that avoid sourcing conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries, communicated our expectations to 3TG Direct Suppliers, communicated with 3TG Direct Suppliers to understand their progress and plans and supported industry efforts to encourage smelters and refiners to participate in the Conflict-Free Smelter Program. We also communicated to non-compliant 3TG Direct Suppliers that we may not be able to continue to do business with them in the future if they fail to take steps to become certified as conflict-free. In addition, our purchase orders include provisions requiring our 3TG Direct Suppliers to comply with the Rule and to provide us with the information necessary for both Wesco’s and its customers’ continued compliance with the Rule.
We summarized key findings from our risk mitigation efforts and have provided regular updates on the progress of Wesco’s conflict minerals program directly to senior management, and we have kept Wesco’s board of directors apprised of material developments in the conflict minerals program.
(4) Support of industry organizations to carry out independent third-party audits of facilities’ due diligence practices.
As discussed above, we do not have direct relationships with smelters or refiners, and we do not perform direct audits of these entities’ supply chains of conflict minerals. However, we continue to support the development and implementation of the independent third party audits of smelters’ and refiners’ sourcing by programs like the CFSI’s Conflict-Free Smelter Program, by our membership in, and financial support of, the CSFI. In furtherance of these goals, we are also actively involved with the Aerospace Industries Association, the National Aerospace Standards Committee and the Industrial Fasteners Institute.
(5) Report on Supply Chain Due Diligence.
As indicated in the Form SD, this Report is publicly available on our website at http://ir.wescoair.com/financial-information/sec-filings, and, as indicated above, our conflict minerals policy is publicly available on our website at https://www.wescoair.com/docs/default-source/compliance/conflict-minerals-policy-v2.pdf?sfvrsn=ee4001a1_6.
Results of Our Due Diligence Measures
Wesco received responses to the 3TG Direct Supplier survey from approximately 88% of the 637 3TG Direct Suppliers surveyed. Of the 637 3TG Direct Suppliers Wesco surveyed, approximately 12% did not respond. Overall, 61% indicated that their supplied parts did not contain conflict minerals sourced from the Covered Countries and some of the 61% were able to provide information about the smelters and refiners in their supply chains, 23% indicated that their supplied parts did contain conflict minerals sourced from the Covered Countries and were able to provide information about the smelters and refiners in their supply chains and 4% indicated that they were unable to determine at present whether or not their supplied parts contain conflict minerals sourced from the Covered Countries and were unable to provide information about the smelters and refiners in their supply chains. Certain 3TG Direct Suppliers indicated that they needed additional time and would complete the survey upon finishing their due diligence processes.
As noted above, we were able to identify 189 operational smelters and refiner facilities in the supply chain of our 3TG Direct Suppliers that are known or thought to potentially be sourcing from one or more Covered Country or for which sourcing information was not available. The 3TG Direct Suppliers that were able to provide information about these smelters and refiners were not able to provide information sufficient to allow us conclusively to determine whether identified facilities were used to process the conflict minerals in the Covered Products. Although Wesco requested information regarding the specific parts and products 3TG Direct Suppliers provided to us for our own products, the 3TG Direct Suppliers that were able to provide information about the smelters and refiners in their supply chains in many cases provided this information to us for their entire supply chain, rather than for the facilities that contributed conflict minerals used in the Covered Products. As a result, we are unable to validate which Covered Products in fact contain conflict minerals from any particular smelter or refiner.
For each of the 3TG Direct Supplier supply chains utilizing the 189 smelters or refiners known or thought to potentially be sourcing from a Covered Country, we conducted due diligence intended to determine the source and chain-of custody of the conflict minerals sourced by such smelters and refiners. We relied on the internationally accepted audit standards of the CFSI Conflict-Free Smelter Program to determine which smelters and refiners can be considered to be sourcing conflict minerals that do not directly or indirectly finance or benefit armed groups in the Covered Countries. Of these 189 smelter and refiners, as of March 29, 2019:
• | 119 have received a “conflict free” certification from one of these independent third party certifying programs; |
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• | 21 have not received a “conflict free” certification but have begun participating in an independent third party certifying programs; and |
• | the remaining 49 smelter and refiner facilities have not begun participating in an independent third party certifying program. |
As noted above, based on the due diligence measures described in this Report, we have been unable to determine which of our Covered Products may contain conflict minerals provided by our 3TG Direct Suppliers that are known or thought to possibly be sourced from a Covered Country or from recycled or scrap sources and processed from a smelter or refiner not certified by an independent third party certifying program as “conflict free” Our efforts, with respect to any of our Covered Products, to identify the smelter or refiner used to process the conflict minerals contained in such Covered Products and the country of origin of the conflict minerals in such Covered Products and to determine the mine or location of origin (with the greatest possible specificity) consisted of the due diligence measures described in this Report, including our efforts to seek information from 3TG Direct Suppliers using a supply chain survey process based on the CFSI Template.
Appendix A below provides a list of the smelters and refiners identified by our 3TG Direct Suppliers as potentially used for the Covered Products that we were able to verify using CFSI’s list of known smelters and refiners. Appendix B provides a list of the countries of origin we have identified for the conflict minerals potentially contained in the Covered Products through our diligence.
Our Approach Going Forward
Since the end of the 2015 reporting period, we took, or plan to take, the following steps to improve our due diligence to further mitigate the risk that the conflict minerals in our Covered Products could directly or indirectly finance or benefit armed groups in the Covered Countries: (1) follow up with 3TG Direct Suppliers that have not responded to our survey requests or have indicated that they need additional time; (2) continue our involvement with industry groups that support conflict-free sourcing, like the CFSI; (3) monitor and track 3TG Direct Suppliers that do not meet the expectations set forth in our conflict minerals policy to evaluate their progress in meeting those expectations and improving the completeness and accuracy of the information they provide to Wesco; (4) encourage our 3TG Direct Suppliers to source from certified conflict-free sources and encourage smelters or refiners identified as being in Wesco’s supply chain to become certified as conflict-free under the CFSI or similar assessment programs; and (5) continue to consider appropriate mitigation steps for unresponsive 3TG Direct Suppliers.
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APPENDIX A
List of Identified Smelters and Refiners
* Smelter or refiner that has received a “conflict-free” designation from an independent third party audit program as of March 29, 2019.
Metal | Smelter or Refiner | Location of Smelter |
Gold | Abington Reldan Metals, LLC | UNITED STATES |
Gold | Advanced Chemical Company* | UNITED STATES |
Gold | African Gold Refinery | UGANDA |
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 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.* | UNITED STATES |
Gold | Asaka Riken Co., Ltd.* | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Aurubis AG* | GERMANY |
Gold | AU Traders and Refiners* | SOUTH AFRICA |
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 |
Gold | Chimet S.p.A.* | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd.* | REPUBLIC OF KOREA |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | Dijllah Gold Refinery FZC | GERMANY |
Gold | DSC (Do Sung Corporation)* | REPUBLIC OF KOREA |
Gold | DS PRETECH Co., Ltd.* | REPUBLIC OF KOREA |
Gold | DODUCO GmbH* | GERMANY |
Gold | Dowa* | JAPAN |
Gold | Eco-System Recycling Co., Ltd.* | JAPAN |
Gold | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Fujairah Gold FZC | RUSSIAN FEDERATION |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
Gold | Geib Refining Corporation* | UNITED STATES |
A-1
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | HeeSung Metal Ltd.* | REPUBLIC OF KOREA |
Gold | Heimerle + Meule GmbH* | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd.* | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
Gold | HwaSeong CJ Co., Ltd. | REPUBLIC OF KOREA |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CHINA |
Gold | International Precious Metal Refiners | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
Gold | Istanbul Gold Refinery* | TURKEY |
Gold | Italpreziosi* | ITALY |
Gold | Japan Mint* | JAPAN |
Gold | Jiangxi Copper 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 | UNITED ARAB EMIRATES |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc* | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC* | UNITED STATES |
Gold | KGHM Polska MiedŸ Spólka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd.* | JAPAN |
Gold | Korea Zinc Co., Ltd.* | REPUBLIC OF KOREA |
Gold | Kyrgyzaltyn JSC* | KYRGYZSTAN |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | L'Orfebre S.A.* | ANDORRA |
Gold | LS-NIKKO Copper Inc.* | REPUBLIC OF KOREA |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Marsam Metals* | BRAZIL |
Gold | Materion* | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd.* | JAPAN |
Gold | Metalor Technologies (Suzhou) Ltd.* | CHINA |
Gold | Metalor Technologies (Hong Kong) Ltd.* | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
Gold | Metalor Technologies S.A.* | SWITZERLAND |
Gold | Metalor USA Refining Corporation* | UNITED STATES |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V.* | MEXICO |
Gold | Mitsubishi Materials Corporation* | JAPAN |
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Gold | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd.* | INDIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | Morris and Watson Gold Coast | AUSTRALIA |
Gold | Moscow Special Alloys Processing Plant* | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | NH Recytech Company | REPUBLIC OF KOREA |
Gold | Nihon Material Co., Ltd.* | JAPAN |
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 |
Gold | PAMP S.A.* | SWITZERLAND |
Gold | Pease & Curren | UNITED STATES |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
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 Précinox S.A.* | SWITZERLAND |
Gold | QG Refining, LLC | UNITED STATES |
Gold | Rand Refinery (Pty) Ltd.* | SOUTH AFRICA |
Gold | Remondis Argentia B.V.* | NETHERLANDS |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint* | CANADA |
Gold | SAAMP* | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | Safimet S.p.A* | ITALY |
Gold | SAFINA A.S. | CZECH REPUBLIC |
Gold | Sai Refinery | INDIA |
Gold | Samduck Precious Metals | REPUBLIC OF KOREA |
Gold | Samwon Metals Corp. | REPUBLIC OF KOREA |
Gold | SAXONIA Edelmetalle GmbH* | GERMANY |
Gold | SEMPSA Joyería Platería S.A.* | SPAIN |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
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 | SOE Shyolkovsky Factory of Secondary Precious Metals* | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | Sudan Gold Refinery | SUDAN |
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Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
Gold | SungEel HiMetal Co., Ltd.* | REPUBLIC OF KOREA |
Gold | Tanaka Kikinzoku Kogyo K.K.* | JAPAN |
Gold | T.C.A S.p.A* | ITALY |
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* | REPUBLIC OF KOREA |
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 |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
Gold | Valcambi S.A.* | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint* | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH* | GERMANY |
Gold | Yamamoto Precious Metal Co., Ltd.* | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery* | CHINA |
Gold | 8853 S.p.A.* | ITALY |
Tantalum | Asaka Riken Co., Ltd.* | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry* | CHINA |
Tantalum | D Block Metals, LLC* | UNITED STATES |
Tantalum | Exotech Inc.* | UNITED STATES |
Tantalum | FIR Metals & Resource Ltd.* | CHINA |
Tantalum | F&X Electro-Materials Ltd.* | CHINA |
Tantalum | Global Advanced Metals Aizu* | JAPAN |
Tantalum | Global Advanced Metals Boyertown* | UNITED STATES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | CHINA |
Tantalum | H.C. Starck Co., Ltd.* | THAILAND |
Tantalum | H.C. Starck GmbH Goslar* | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
Tantalum | H.C. Starck Inc.* | UNITED STATES |
Tantalum | H.C. Starck Ltd.* | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG* | 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 |
A-4
Tantalum | KEMET Blue Metals* | MEXICO |
Tantalum | KEMET Blue Powder* | UNITED STATES |
Tantalum | LSM Brasil S.A.* | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd.* | INDIA |
Tantalum | Mineração Taboca S.A.* | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
Tantalum | Molycorp Silmet A.S.* | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
Tantalum | Power Resources Ltd.* | NORTH MACEDONIA |
Tantalum | QuantumClean* | UNITED STATES |
Tantalum | Resind Indústria e Comércio Ltda.* | BRAZIL |
Tantalum | Solikamsk Magnesium Works OAO* | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd.* | JAPAN |
Tantalum | Telex Metals* | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CHINA |
Tin | Alpha* | UNITED STATES |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
Tin | Dowa* | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
Tin | EM Vinto* | BOLIVIA |
Tin | Estanho de Rondonia S.A. | BRAZIL |
Tin | Fenix Metals* | POLAND |
Tin | Gejiu Fengming Metallurgy Chemical Plant* | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC* | 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 Nanshan* | CHINA |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
A-5
Tin | Melt Metais e Ligas S.A.* | BRAZIL |
Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
Tin | Metallic Resources, Inc.* | UNITED STATES |
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 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
Tin | Operaciones Metalurgical S.A.* | BOLIVIA |
Tin | Pongpipat Company Limited | MYANMAR |
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 Babel Surya Alam Lestari* | 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 |
Tin | PT Kijang Jaya Mandiri* | INDONESIA |
Tin | PT Menara Cipta Mulia* | INDONESIA |
Tin | PT Mitra Stania Prima* | INDONESIA |
Tin | PT O.M. Indonesia* | INDONESIA |
Tin | PT Panca Mega Persada* | INDONESIA |
Tin | PT Prima Timah Utama* | INDONESIA |
Tin | PT Rajawali Rimba Perkasa | 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 (Persero) Tbk Kundur* | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok* | INDONESIA |
Tin | PT Tinindo Inter Nusa* | INDONESIA |
Tin | PT Tirus Putra Mandiri | INDONESIA |
Tin | PT Tommy Utama* | INDONESIA |
Tin | Resind Industria e Comercio Ltda.* | BRAZIL |
Tin | Rui Da Hung* | TAIWAN |
A-6
Tin | Soft Metais Ltda.* | BRAZIL |
Tin | Super Ligas | BRAZIL |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd.* | VIETNAM |
Tin | Thaisarco* | THAILAND |
Tin | Tin Technology & Refining* | UNITED STATES |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | White Solder Metalurgia e Mineracao Ltda.* | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA |
Tin | Yunnan Tin Company Limited* | CHINA |
Tungsten | ACL Metais Eireli* | BRAZIL |
Tungsten | A.L.M.T. TUNGSTEN Corp.* | JAPAN |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
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 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CHINA |
Tungsten | H.C. Starck GmbH* | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co.KG* | 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 Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC* | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
Tungsten | Kennametal Fallon* | UNITED STATES |
Tungsten | Kennametal Huntsville* | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
Tungsten | Moliren Ltd* | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC* | UNITED STATES |
Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | VIETNAM |
Tungsten | Unecha Refractory Metals Plant* | RUSSIAN FEDERATION |
A-7
Tungsten | Wolfram Bergbau und Hütten AG* | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd.* | REPUBLIC OF KOREA |
Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CHINA |
A-8
APPENDIX B
Countries of Origin
While Wesco does not have sufficient information to conclusively determine the countries of origin for the conflict minerals in the Covered Products, the following is an aggregated list of countries of origin from which the smelters listed in Appendix A are believed to have sourced conflict minerals.
Argentina |
Armenia |
Australia |
Austria |
Azerbaijan |
Bahamas |
Barbados |
Belarus |
Belgium |
Benin |
Bolivia |
Bosnia and Herzegovina |
Botswana |
Brazil |
Bulgaria |
Burkina Faso |
Burundi |
Cambodia |
Cameroon |
Canada |
Cayman Islands |
Chile |
China |
Colombia |
Croatia |
Curacao (Dutch Antilles) |
Cyprus |
Czech Republic |
Democratic Republic of the Congo |
Denmark |
Dominican Republic |
Ecuador |
Egypt |
El Salvador |
Eritrea |
Estonia |
Ethiopia |
Fiji |
Finland |
France |
Gabon |
Gambia, The |
B-1
Georgia |
Germany |
Ghana |
Greece |
Guatemala |
Guinea |
Guyana |
Honduras |
Hong Kong |
Hungary |
Iceland |
India |
Indonesia |
Iran |
Ireland |
Israel |
Italy |
Ivory Coast |
Japan |
Jordan |
Kazakhstan |
Kenya |
Korea, Republic of |
Kosovo |
Kuwait |
Kyrgyzstan |
Laos |
Latvia |
Lebanon |
Liberia |
Libya |
Liechtenstein |
Lithuania |
Luxembourg |
Macau |
Madagascar |
Malaysia |
Mali |
Malta |
Mauritania |
Mauritius |
Mexico |
Mongolia |
Morocco |
Mozambique |
Myanmar |
Namibia |
Netherlands |
New Caledonia |
New Zealand |
B-2
Nicaragua |
Niger |
Nigeria |
Norway |
Pakistan |
Panama |
Papua New Guinea |
Peru |
Philippines |
Poland |
Portugal |
Puerto Rico |
Romania |
Russian Federation |
Rwanda |
San Marino |
Saudi Arabia |
Senegal |
Serbia |
Sierra Leone |
Singapore |
Slovakia |
Slovenia |
Solomon Islands |
South Africa |
Spain |
Suriname |
Swaziland |
Sweden |
Switzerland |
Taiwan |
Tajikistan |
Tanzania |
Thailand |
Togo |
Trinidad and Tobago |
Tunisia |
Turkey |
Uganda |
Ukraine |
United Arab Emirates |
United Kingdom of Great Britain and Northern Ireland |
United States |
Uruguay |
Uzbekistan |
Vatican City |
Venezuela |
Vietnam |
B-3
Yemen |
Zambia |
Zimbabwe |
B-4