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SD

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

Specialized Disclosure Report

 

SIGHT SCIENCES, INC.

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

 

 Delaware

 001-40587

  80-0625749

(State or other jurisdiction of

(Commission

  (IRS Employer

incorporation or organization)

  File Number)

 Identification No.)

 

4040 Campbell Ave, Suite 100

Menlo Park, CA

94025

(Address of principal executive offices)

(Zip code)

 

Jeremy Hayden

877 -266 - 1144

(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, 2023.

 

Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended __________.

 

 

 

SECTION 1 – Conflict Minerals Disclosure

Item 1.01 – Conflicts Minerals Disclosure and Report

Sight Sciences, Inc. has issued a Conflict Minerals Disclosure for the period from January 1, 2023 to December 31, 2023. A copy of the Conflict Minerals Report is filed herewith as Exhibit 1.01 and is available at www.investors.sightsciences.com under the "SEC Filings" link.

Item 1.02 – Exhibit

A copy of the Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 hereto

SECTION 2 – Exhibits

Item 2.01 – Exhibits

The following exhibit is filed as part of this report.

 

Exhibit No.

 

Description

 

 

 

1.01

 

Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form SD.

 

 

SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

Sight Sciences, Inc.

(Registrant)

 

 

By:

/s/ Jeremy Hayden

Name:

Jeremy Hayden

Title:

Chief Legal Officer

Date:

May 31, 2024

 

EX-1.01

Exhibit 1.01

CONFLICT MINERALS REPORT OF

SIGHT SCIENCES, INC.

FOR THE REPORTING PERIOD FROM

JANUARY 1 TO DECEMBER 31, 2023

 

I.
Introduction

This is the Conflict Minerals Report1 of Sight Sciences, Inc. (“we,” “our,” “us,” “Sight Sciences,” or the “Company”) prepared for calendar year 2023 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and SEC Release No. 34-67716 (August 22, 2012) under the Act (the “Adopting Release”). The reader is referred to these sources for the definitions of defined terms contained herein.

In accordance with Rule 13p-1, we undertook efforts to determine the presence and source of the conflict minerals within our products. The Company designed its efforts in conformity with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.

The statements below are based on the activities performed to date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the SEC final rules, and other issues.

II.
Overview

Company Profile

Our mission is to develop transformative, interventional technologies that allow eyecare provides to procedurally elevate the standards of care – empowering people to keep seeing. We are passionate about improving patients’ lives by helping them to preserve their sight. Our business philosophy is grounded in the following principles: comprehensively understanding disease physiology; developing products and transformative technologies that are intended to preserve, protect, or restore natural physiological functionality to diseased eyes; commercializing products with high quality clinical evidence that can elevate the standard of care; providing intuitive, interventional solutions to ophthalmologists and optometrists (together, "eyecare professionals" or "ECPs"); and delivering compelling value to all stakeholders, including patients, providers and third-party payors such as Medicare and commercial insurers. Our objective is to appropriately create an interventional mindset in eyecare, whereby our minimally invasive procedural technologies may be used earlier in the disease treatment, supplanting conventional approaches and elevating the standard of care for eyecare patients.

We are subject to this rule as we have determined that, during 2023, conflict minerals were likely necessary to the functionality or production of products we manufactured or contracted to manufacture. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we conduct no purchasing activities directly in the DRC or adjoining countries.

Conflict Minerals Policy

1

 

Exhibit 1.01

The Company developed a conflict minerals policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by the SEC rule and the Company’s expectations from its suppliers. In addition, the policy includes language about our expectation that our suppliers have policies and programs in place to conduct responsible conflict minerals sourcing within their own supply chains in accordance with the OECD Guidance. We require our in-scope suppliers to complete and promptly provide us with a current Conflict Minerals Reporting Template upon request and demonstrate that they are working to source conflict minerals from smelters and refiners that have completed an industry-standard third-party audit. The policy resides on our corporate website (https://investors.sightsciences.com/corporate-governance/governance-overview). This policy is reviewed and updated periodically as needed.

Reasonable Country of Origin Inquiry Information

We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.

The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI which indicated sourcing from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are described further in this Conflict Minerals Report.

Due Diligence Program Design

The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:

Step 1: Establish strong company management systems

Step 2: Identify and assess risks in the supply chain

Step 3: Design and implement a strategy to respond to identified risks

Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices

Step 5: Report annually on supply chain due diligence

III.
Due Diligence Measures Performed by The Company

The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.

Step 1: Establish strong company management systems

a.
Conflict minerals team – The Company established a conflict minerals team that includes individuals from the relevant business units and departments, including compliance, IT, procurement, sales, and legal. The team was structured to include the involvement from those in upper management roles, including VP Corporate Finance, Chief Legal Officer, VP IT and Director of Global Supply Chain, to help ensure that critical information, including the Company’s Conflict Minerals Policy, reached relevant employees and suppliers.

2

 

Exhibit 1.01

b.
Conflict Minerals Policy – The Company adopted and published a Conflict Minerals Policy establishing the expectations of our suppliers. The Conflict Minerals Policy resides on our corporate website (https://investors.sightsciences.com/corporate-governance/governance-overview). The Company’s supplier agreement template terms and conditions require suppliers to comply with the applicable conflict minerals laws, rules, and regulations governing conflict minerals.
c.
Supplier engagement – The Company communicated its conflict minerals policy and provided educational materials to our in-scope suppliers. Suppliers were informed when the request for information was initiated on the conflict minerals disclosure requirements as well as recommendations for developing, implementing, and documenting a conflict minerals compliance program.
d.
Company level grievance mechanism – As recommended by the OECD Due Diligence Guidance, the Company has a grievance mechanism in place as a risk-awareness system for conflict minerals issues. Stakeholders, internal and external, can communicate directly and confidentially with our compliance officer.
e.
Records management – The Company will maintain records relating to our conflict minerals program in accordance with the recommended record retention guidelines of five years.

Step 2: Identify and assess risks in the supply chain

We performed the following steps as part of our risk assessment process:

a.
Identified products in scope – Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release.
b.
Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide materials and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.
Completed additional follow-up – The Company contacted our direct suppliers multiple times to request detailed conflict minerals information. We also worked to clarify and validate the accuracy of information provided by our suppliers by responding with standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we are receiving conflict minerals information specific to our supply-chain.
d.
Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP completes independent, third-party audits of smelters and refiners to determine which can be validated as having systems in place that help ensure the minerals are responsibly sourced according to the OECD Due Diligence Guidance. The company also utilized information provided by the London Bullion Market Association (LBMA), and Responsible Jewelry Council (RJC) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this report within section IV – Product Description; Processing Facilities.
e.
Performed smelter due diligence with suppliers - Suppliers that reported smelters deemed to be high risk received an additional communication asking them to clarify if those smelters are reflective of the purchases made and to continue due diligence on their supply chains. High risk smelters are those that have not yet undergone a third-party audit or have been deemed non-conformant.

Step 3: Design and implement a strategy to respond to identified risks

We performed the following steps as part of our risk management plan:

3

 

Exhibit 1.01

a.
Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to upper management at multiple points in time throughout the data collection period which included the team’s plan to respond to risks identified in the due diligence processes.
b.
Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as, any additional documentation furnished to support those responses and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s conflict minerals policy. This includes additional outreach to suppliers who failed to respond to our multiple requests for information, suppliers who provided inconsistent or erroneous information, and suppliers who indicated they had received responses from less than 50% of their in-scope suppliers. Our team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.
Provided educational materials – The Company provided each supplier with educational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). The educational material serves as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them. Throughout the process we offer assistance to our suppliers to improve the quality of the information provided to us.
d.
Provided conflict minerals policy to suppliers - After working with a supplier to obtain as CMRT, we provide them with a copy of our conflict minerals policy for their records to ensure our suppliers continue to operate in line with our expectations.
e.
Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.

Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices

The Company is using information provided by independent third-party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence and verify the OECD-conformance status of SORs identified during our due diligence.

For SORs that had not been audited as conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations the SOR sources from to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that had not been audited as conformant to request that these suppliers contact the SORs to encourage participation in the RMAP.

Step 5: Report annually on supply chain due diligence

Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website at https://investors.sightsciences.com/financial-information/sec-filings.

IV.
Product Description; Processing Facilities

Product Description – We have focused our initial product development efforts on the treatment of two of the world’s most prevalent and underserved eye diseases, glaucoma and dry eye disease, or DED. We have designed OMNI®, SION® and TearCare® to be interventional ophthalmology devices.

OMNI® Surgical System

4

 

Exhibit 1.01

The OMNI Surgical System (“OMNI”) is a handheld, single use, therapeutic device for minimally invasive glaucoma surgery, or MIGS. OMNI is an implant-free, minimally invasive technology indicated in the United States for canaloplasty (microcatheterization and transluminal viscodilation of Schlemm’s canal) followed by trabeculotomy (cutting of trabecular meshwork) to reduce intraocular pressure in adult patients with primary open-angle glaucoma, and CE Marked in the European Economic Area for the catheterization and transluminal viscodilation of Schlemm’s canal and the cutting of trabecular meshwork to reduce intraocular pressure in adult patients with open-angle glaucoma.

SION® Surgical Instrument

The SION Surgical Instrument (“SION”) is registered with the FDA as a Class I 510(k) exempt device. SION’s bladeless design, micro-engineered and precision manufactured using specialized lasers, excises trabecular meshwork without cutting in ophthalmic surgical procedures. SION grasps and removes diseased tissue as the surgeon sweeps the instrument around Schlemm’s canal with a single smooth motion. The bladeless technology of SION was developed with leading ophthalmic surgeons to improve safety and ease of use by eliminating the need to navigate sharp instrumentation within the eye’s anterior chamber and iridocorneal angle anatomy.

TearCare® System

The TearCare® System is intended for the application of localized heat therapy in adult patients with evaporative dry eye disease due to meibomian gland dysfunction (“MGD”), when used in conjunction with manual expression of the meibomian glands. The TearCare System includes a pair of single-use SmartLids, the first wearable, highly conformant, precision heating device for the eyelids. SmartLids™ allow for eyes to be open and blink during the thermal portion of the process and are software-controlled, delivering precise heat to the tarsal plates of the eyelids directly overlying the meibomian glands while continuously monitoring temperature and communicating 144 times per second with the SmartHub™, a compact, finely calibrated power source and control unit which can make instantaneous adjustments to ensure delivery of the desired amount of heat and therapeutic temperature level.

Processing Facilities – Based on our due diligence process and the information received from our suppliers, the following facilities were identified by the Company’s suppliers as the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products manufactured by the Company in the calendar year ended December 31, 2023. The information from our suppliers is still evolving and may contain company-level declarations. As such, this smelter list is presented in good faith as the best information we have to date. For 2023 we identified 211 SORs in our supply chain, 182 have been audited as conformant with the RMAP. This list may contain smelters that are not in our supply chain and/or there may be other smelters not yet identified in our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC when (or if) we receive updated information.

5

 

Exhibit 1.01

https://cdn.kscope.io/37dcdca1c5c5f1839acfdec0f43c1a2e-img84062850_0.jpg 

https://cdn.kscope.io/37dcdca1c5c5f1839acfdec0f43c1a2e-img84062850_1.jpg 

6

 

Exhibit 1.01

https://cdn.kscope.io/37dcdca1c5c5f1839acfdec0f43c1a2e-img84062850_2.jpg 

https://cdn.kscope.io/37dcdca1c5c5f1839acfdec0f43c1a2e-img84062850_3.jpg 

Metal

Smelter Name

Country

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

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

CID002560

7

 

Exhibit 1.01

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

Aurubis AG

GERMANY

CID000113

Gold

Bangalore Refinery

INDIA

CID002863

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Gold

Cendres + Metaux S.A.

SWITZERLAND

CID000189

Gold

Chimet S.p.A.

ITALY

CID000233

Gold

Chugai Mining

JAPAN

CID000264

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

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Gold

Heraeus Germany GmbH Co. KG

GERMANY

CID000711

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Gold

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

CHINA

CID000801

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Gold

Italpreziosi

ITALY

CID002765

Gold

Japan Mint

JAPAN

CID000823

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Gold

JSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Gold

Kazzinc

KAZAKHSTAN

CID000957

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID000969

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

8

 

Exhibit 1.01

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Gold

LS MnM Inc.

KOREA, REPUBLIC OF

CID001078

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

CID000689

Gold

Marsam Metals

BRAZIL

CID002606

Gold

Materion

UNITED STATES OF AMERICA

CID001113

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

CID003575

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

MKS PAMP SA

SWITZERLAND

CID001352

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

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

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

REMONDIS PMR B.V.

NETHERLANDS

CID002582

Gold

Royal Canadian Mint

CANADA

CID001534

Gold

SAAMP

FRANCE

CID002761

Gold

Safimet S.p.A

ITALY

CID002973

Gold

SAFINA A.S.

CZECHIA

CID002290

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

9

 

Exhibit 1.01

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

CID001585

Gold

Shandong Gold Smelting Co., Ltd.

CHINA

CID001916

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

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

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

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

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Tantalum

AMG Brasil

BRAZIL

CID001076

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

CID002504

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

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

10

 

Exhibit 1.01

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Tantalum

KEMET de Mexico

MEXICO

CID002539

Tantalum

Materion Newton Inc.

UNITED STATES OF AMERICA

CID002548

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

RFH Yancheng Jinye New Material Technology Co., Ltd.

CHINA

CID003583

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Tantalum

Taki Chemical Co., Ltd.

JAPAN

CID001869

Tantalum

TANIOBIS Co., Ltd.

THAILAND

CID002544

Tantalum

TANIOBIS GmbH

GERMANY

CID002545

Tantalum

TANIOBIS Japan Co., Ltd.

JAPAN

CID002549

Tantalum

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID002550

Tantalum

Telex Metals

UNITED STATES OF AMERICA

CID001891

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Tantalum

XIMEI RESOURCES (GUANGDONG) LIMITED

CHINA

CID000616

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID001522

Tin

Alpha

UNITED STATES OF AMERICA

CID000292

Tin

Aurubis Beerse

BELGIUM

CID002773

Tin

Aurubis Berango

SPAIN

CID002774

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

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

CID003486

Tin

CRM Synergies

SPAIN

CID003524

Tin

Dowa

JAPAN

CID000402

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000438

Tin

Estanho de Rondonia S.A.

BRAZIL

CID000448

Tin

Fenix Metals

POLAND

CID000468

11

 

Exhibit 1.01

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

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

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

Mineracao Taboca S.A.

BRAZIL

CID001173

Tin

Minsur

PERU

CID001182

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Tin

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

THAILAND

CID001314

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Tin

PT Mitra Sukses Globalindo

INDONESIA

CID003449

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

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001539

Tin

Thaisarco

THAILAND

CID001898

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

CID002036

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

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

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Tungsten

China Molybdenum Tungsten Co., Ltd.

CHINA

CID002641

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Tungsten

Cronimet Brasil Ltda

BRAZIL

CID003468

Tungsten

Fujian Xinlu Tungsten Co., Ltd.

CHINA

CID003609

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

12

 

Exhibit 1.01

Tungsten

Global Tungsten & Powders LLC

UNITED STATES OF AMERICA

CID000568

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Tungsten

Hubei Green Tungsten Co., Ltd.

CHINA

CID003417

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Tungsten

Hunan Jintai New Material Co., Ltd.

CHINA

CID000769

Tungsten

Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch

CHINA

CID002513

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

CHINA

CID002318

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000966

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID000105

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Tungsten

Masan High-Tech Materials

VIET NAM

CID002543

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

CID002845

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

CID002589

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Tungsten

TANIOBIS Smelting GmbH & Co. KG

GERMANY

CID002542

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

CID002044

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002320

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

 

 

V.
Future Due Diligence

We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when relevant changes in facts or circumstances are

13

 

Exhibit 1.01

identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to help ensure alignment throughout the supply chain.

In addition to those above, the Company will undertake the following steps during the next compliance period:

•
Review the conflict minerals policy statement and update if necessary.
•
Review supplier training materials and update if necessary.
•
Continue to collect responses from suppliers using the most recent revision of the CMRT.
•
Engage with suppliers that did not provide a response in 2023 or provided incomplete responses to enhance our data collection for 2024.
•
Monitor and track performance of risk mitigation efforts.
•
Continue engagement with smelters by sending letters to those that have not been audited as conformant.
•
Continue to send messages to our suppliers to engage with smelters that have not been audited as conformant.
•
Collect from suppliers product-level or user-defined level responses where useful.
•
Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI, and through our Company’s own coordinated outreach to smelters.
•
Encourage responsible sourcing from the DRC and adjoining countries.
•
Stay aware of new and related sourcing challenges that affect smelter audit status.

 

 

 

 

1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.

2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264252479-en

 

 

 

14

 

Exhibit 1.01

APPENDIX I – Countries of Origin

The information provided in this Appendix is based on the information collected from the Company’s suppliers.

 

Australia

Mozambique

Austria

Myanmar

Benin

Nicaragua

Bolivia (Plurinational State of)

Niger

Brazil

Nigeria

Burundi

Papua New Guinea

Canada

Peru

Chile

Philippines

China

Portugal

Colombia

Russian Federation

Congo, Democratic Republic of the

Rwanda

Ethiopia

Sierra Leone

France

South Africa

Ghana

Spain

Guinea

Sweden

Guyana

Tanzania

Indonesia

Thailand

Kazakhstan

Uganda

South Korea

United Kingdom of Great Britain and Northern Ireland

Laos

United States of America

Madagascar

Uzbekistan

Malaysia

Vietnam

Mexico

Zimbabwe

Mongolia

 

 

15