UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
TOWER SEMICONDUCTOR LTD.
(Exact name of registrant as specified in its charter)
|
ISRAEL
|
000-24790
|
N/A
|
||
|
(State or other jurisdiction
|
(Commission
|
(IRS Employer
|
||
|
of incorporation or organization)
|
File Number)
|
Identification No.)
|
|
Ramat Gavriel Industrial Park, P.O. Box 619,
|
|
|
|
Migdal Haemek, Israel
|
2310502
|
|
|
(Address of principal executive offices)
|
(Zip Code)
|
Nati Somekh
Telephone: +972-4-650-6109
(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, 2022.
☐ Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .
Introduction
This Specialized Disclosure Report on Form SD (“Form SD”) of Tower Semiconductor Ltd. for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Unless the context indicates otherwise, “Tower,” “we,” “us” and
“our” refers to Tower Semiconductor Ltd. and its consolidated subsidiaries as of December 31, 2022. The Rule was adopted by the Securities and Exchange Commission
(the “SEC”) to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as gold as well as
columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Rule imposes certain reporting obligations on SEC registrants for whom conflict minerals are necessary for the
functionality or production of products manufactured by the registrant or contracted by the registrant to be manufactured (such minerals are referred to as “necessary conflict minerals”). With respect to its necessary conflict minerals, the
registrant must conduct in good faith a reasonable country of origin inquiry ("RCOI") designed to determine whether any of its necessary conflict minerals originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country,
collectively defined as the “Covered Countries”. If, based on such RCOI , the registrant knows or has reason to believe that any of its necessary conflict minerals originated or may have originated in a Covered Country and knows or has reason to
believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence on the source and chain of custody of its necessary conflict minerals in order to determine whether such
necessary conflict minerals did or did not directly or indirectly finance or benefit armed groups in the Covered Countries. Products which do not contain, or are manufactured without the use of, necessary conflict minerals that directly or
indirectly finance or benefit armed groups in the Covered Countries are considered “DRC conflict free”.
We use the term “conflict free” in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose
sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries.
The content of any website referred to in this Form SD is included for general information only and is not
incorporated by reference into this document.
Company Overview
We are a pure-play independent specialty foundry dedicated to the manufacture semiconductors. Typically, pure-play foundries do not
offer products of their own, but focus on producing integrated circuits, or ICs, based on the design specifications of their customers. We manufacture ICs for our customers primarily based on third party designs. We currently offer the process
manufacture of ICs with geometries of 0.35, 0.50, 0.55, 0.60, 0.80-micron and above on 150-mm wafers, 0.35, 0.18. 0.16, 0.13 and 0.11-micron on 200-mm wafers and 65 nanometer and 45 nanometer on 300-mm wafers. We also provide design support and
complementary technical services. ICs manufactured by us are incorporated into a wide range of products in diverse markets, including consumer electronics, personal computers, communications, automotive, industrial and medical device products.
We currently operate seven manufacturing facilities ("fabs") in several geographic regions: two fabs (for 150mm and 200mm wafers)
located in Migdal Haemek, Israel, one fab (for 200mm wafers) located in Newport Beach, California, one fab (for 200mm wafers) located in San Antonio, Texas, and two
additional fabs (for 200mm and 300mm wafers) located in the Hokuriku region of Japan (we operated a third manufacturing facility in Japan which ceased operations in July
2022). We offer state-of-the-art production lines for core bulk complementary metal oxide semiconductor (CMOS) and specialized technologies such as power
management, CMOS Image Sensors (CIS), silicon-germanium bipolar CMOS (SiGe) and switch silicon-on-insulator (SOI) for radio frequency (RF) applications, high performance analog and micro-electromechanical systems (MEMS).
Overview of Tower’s Conflict Minerals Program
As a semiconductor manufacturer, we are knowledgeable of the materials needed for our production processes and products that we
manufacture. To comply with the Rule, we reviewed the products we manufactured in 2022 to determine whether conflict minerals were necessary for their
functionality or production. Based on this review, we determined that tungsten and/or tantalum were used in the manufacturing processes of most of our products and are contained in certain of our products.
Supply Chain Description
All of our integrated circuits are manufactured in our own fabs. Tower does not purchase any tungsten or tantalum directly from
smelters, refiners or mines, and is many steps removed in the supply chain from the mining of these necessary conflict minerals. Rather, these necessary conflict minerals are obtained via our direct suppliers, who obtain them from sources
worldwide. As a result, we rely on our direct suppliers to assist with our RCOI and due diligence efforts, including the identification of smelters and refiners for any necessary conflict minerals contained in the materials which our direct
suppliers supply to us.
SECTION 1 – CONFLICT MINERALS DISCLOSURE
Item 1.01. Conflict Minerals Disclosure and Report.
Description of Reasonable Country of Origin Inquiry ("RCOI") Efforts
As indicated, Tower concluded that during 2022 it
had manufactured products in which tungsten and/or tantalum were necessary for their functionality or production. As a result, we conducted in good faith an RCOI that was designed to reasonably determine whether any of our necessary conflict
minerals originated in the Covered Countries or were from recycled or scrap sources.
As part of the RCOI, we conducted a supply chain survey of our direct suppliers of tungsten and tantalum (and of any material used in
our manufacturing processes that contains tungsten or tantalum) to obtain country of origin information using the Conflict Minerals Reporting Template (the "Template” or “CMRT), which is a standardized survey tool published by the Responsible
Minerals Initiative (“RMI”), formerly known as the Conflict-Free Sourcing Initiative (“CFSI”). RMI operates the Responsible Mineral Assurance Process (“RMAP”, previously the Conflict Free Smelter Program), a program that identifies smelters and
refiners that produce responsibly sourced materials by using third-party auditors to independently verify that these smelters and refiners have systems in place to responsibly source minerals in conformance with RMAP standards. The Template, which
requests direct suppliers to identify the smelters, refiners and countries of origin of the necessary conflict minerals they supply to Tower, was developed to facilitate disclosure and communication of information regarding smelters and refiners
that provide material in a company’s supply chain. The Template includes among others questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In
addition, the Template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions regarding use of the questionnaire are available on RMI’s website at http://www.responsiblemineralsinitiative.org/media/docs/CMRT%206.0%20Guide_final.pdf.
We received responses from all of our direct suppliers of
tungsten and tantalum (and from all of our direct suppliers of any material used in our manufacturing processes that contain tungsten or tantalum). We then confirmed whether or not each smelter or refiner they identified as providing conflict minerals was found to be conformant with RMAP standards.
Conclusion Based on Reasonable Country of Origin Inquiry
As a result of our survey regarding 2022
activity, one out of our six direct suppliers of tungsten or any material used
in our manufacturing processes that contain tungsten indicated that they did not source from the Covered Countries. In addition, each of the six suppliers confirmed that all of the smelters or refiners they identified as suppliers of tungsten had been designated as RMAP conformant.
Regarding tantalum, all three direct suppliers of
tantalum or any material used in our manufacturing processes that contain tantalum indicated that their supply chain includes smelters or refiners sourcing
tantalum from the Covered Countries. In addition, all three suppliers confirmed that all of the smelters and refiners they identified as suppliers of tantalum had
been designated as RMAP conformant.
Because we know or have reason to believe that a certain amount of the tungsten and tantalum used in the process of manufacturing
certain of our products and/or contained in certain of our products originated or may have originated in a Covered Country, we conducted due diligence on the source and chain of custody of the tungsten and tantalum used in the production of, and/or
contained in, our products. Our due diligence was designed to conform to the Organization for Economic Cooperation and Development’s “Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas ", Third Edition (April 2016).
The due diligence measures that we performed are discussed further in the conflict minerals report filed as Exhibit 1.01 hereto.
Conflict Minerals Disclosure
This Form SD and the conflict minerals report, filed as Exhibit 1.01 hereto, are publicly available on our website at
https://ir.towersemi.com/financial-information/sec-filings;
Item 1.02. Exhibit.
The Conflict Minerals Report required by Item 1.01 of Form SD is filed as Exhibit 1.01 to this Form SD.
SECTION 2 – RESOURCE EXTRACTION ISSUER DISCLOSURE
Item 2.01. Resource Extraction Issuer Disclosure and Report.
Not applicable.
SECTION 3 – EXHIBITS
Item 3.01. Exhibits.
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.
Tower Semiconductor Ltd.
(Registrant)
|
By: /s/ Nati Somekh
|
May 24, 2023
|
|
Nati Somekh
Senior Vice President, Chief Legal Officer and Corporate Secretary
|
|
Exhibit 1.01
Tower Semiconductor Ltd.
Conflict Minerals Report
For the Year Ended December 31, 2022
This conflict minerals report for the year ended December 31, 2022 is presented to comply with Section 13(p) of the Securities Exchange Act of 1934 and Rule 13p-1 (the "Rule") and Form SD thereunder.
The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule
imposes certain reporting obligations on SEC registrants for whom conflict minerals are necessary for the functionality or production of products manufactured by the registrant or contracted by the registrant to be manufactured (such minerals are
referred to as “necessary conflict minerals”). "Conflict minerals" are defined as gold as well as columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tin, tantalum and tungsten (collectively referred to
as “3TG Minerals”).
With respect to its necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of its necessary conflict minerals
originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country, collectively defined as the “Covered Countries”. If, based on such inquiry, the registrant knows or has reason to believe that any of its necessary conflict minerals
originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence on the source and chain of
custody of its necessary conflict minerals in order to determine whether such necessary conflict minerals directly or indirectly finance or benefit armed groups in the Covered Countries, and it must submit a conflict minerals report as an exhibit to
its Form SD that includes a description of those due diligence measures. In accordance with the instructions and related guidance to Form SD, this conflict minerals report has not been audited by an independent private sector auditor.
The content of any website referred to in this conflict minerals report is included for general information only and is not incorporated by reference into this document.
Design and Description of Conflict Minerals Diligence Program
The due diligence efforts by Tower Semiconductor Ltd. (unless the context indicates otherwise, “Tower ,” “Company ,” “we,” “us” and “our” refers to Tower Semiconductor Ltd. and its consolidated
subsidiaries for 2022) have been designed to conform with the framework provided by 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, April 2016) (the “OECD Guidance”).
Consistent with the OECD Guidance, our due diligence in respect of 2022 consisted of a five-step process described below:
| (i) |
Establish Strong Company Management Systems
|
Tower is dedicated to corporate social responsibility and has adopted several management systems to address the issue of conflict minerals used in the production of, and/or contained in, its products, including:
| (i) |
a Company code of ethics requiring all employees, officers and directors to comply with all of the laws, rules and regulations of the U.S., Israel and other countries, as applicable (available at: https://towersemi.com/about/corporate-social-responsibility-esg/social/;
|
| (ii) |
partnership since 2014 in the Responsible Business Alliance (RBA), which provides assessment tools including a self-assessment questionnaire designed to help members identify social, environmental and ethical risks in their supply chains
and take action to put in place systems to further improve their social contribution,
|
| (iii) |
a code of ethics for suppliers requiring suppliers to conduct their business in an ethical manner and act with integrity, including by ensuring that products supplied to Tower do not contain metals derived from minerals or their
derivatives originating from conflict regions that directly or indirectly finance or benefit armed groups,
|
| (iv) |
a conflict minerals policy as described below, and
|
| (v) |
a team of Company employees, consisting of senior operations, engineering, QA, regulatory compliance and legal personnel, that oversees implementation of the Company's conflict minerals compliance strategy. In addition, senior management
of the Company, including the Senior Vice President Excellence and Quality and Reliability, VP of Procurement and the Senior Vice President, Chief Legal Officer and Corporate Secretary, are briefed on a regular basis by the Company’s
Corporate Compliance Officer about conflict minerals compliance efforts.
|
The code of ethics for suppliers and the conflict minerals policy are each available at: https://towersemi.com/about/corporate-social-responsibility-esg/social-supply-chain/.
Suppliers are required as part of the terms and conditions of their supply with the Company to comply with each such policy.
The Company’s conflict minerals policy states, in part, that the Company:
| • |
Avoids the use of conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries;
|
| • |
Expects its suppliers to have in place policies and due diligence procedures that will ensure that products and components that they supply containing conflict minerals, including conflict minerals from Covered Countries, are in fact
"conflict-free", meaning that they do not directly or indirectly finance or benefit armed groups in Covered Countries;
|
| • |
Requires the Company's direct suppliers to provide it with annual declarations regarding their use of conflict minerals (utilizing a format described below);
|
| • |
Reserves the right to take appropriate action to enforce its conflict minerals policy, including discontinuing purchases from suppliers that fail to comply; and
|
| • |
Is committed to responsible sourcing of conflict minerals throughout its supply chain and to continued compliance with applicable SEC rules and regulations in this area.
|
The conflict minerals policy also directs any questions about such policy to the Company's Corporate Compliance Officer.
In addition to the measures described above and in order to provide transparency within our supply chain, we have adopted the Conflict Minerals Reporting Template (the "Template” or “CMRT”) to
directly survey our suppliers. The CMRT is a standardized survey tool published by the Responsible Minerals Initiative (“RMI”), formerly known as the Conflict-free Sourcing Initiative (“CFSI”). RMI operates the Responsible Mineral Assurance Process
(“RMAP”, previously the Conflict Free Smelter Program), a program that identifies smelters and refiners that produce responsibly sourced materials by using third-party auditors to independently verify that these smelters and refiners have systems in
place to responsibly source minerals in conformance with RMAP standards.
We also include provisions in our terms and conditions attached to each purchase order we issue that require our suppliers of 3TG Minerals to (i) submit a completed CMRT in January of each year,
which covers the previous calendar year, and (ii) supply only conflict-free materials to Tower. Suppliers are encouraged to use only refiners and smelters who are RMAP conformant, and, after receiving completed CMRTs from suppliers, we confirm that
such refiners and smelters are in fact designated as RMAP conformant.
All responses from suppliers are recorded and stored in an electronic database and are maintained for a minimum of five years.
| (ii) |
Identify and Assess Risk in the Supply Chain
|
We identified two primary risks regarding our suppliers, as follows: (i) not receiving timely or accurate information, and (ii) difficulty in replacing a supplier should we determine that such
supplier obtained or appears to have obtained conflict minerals from sources that support armed conflict in the Covered Countries.
Because we do not purchase tungsten and tantalum directly from smelters, refiners or mines and are many steps removed in the supply chain from mining of such tungsten and tantalum, we focus our
efforts on surveying our direct suppliers who were required to survey their own suppliers (i.e., our upstream suppliers) in order to receive the required information. As indicated above, we use the Template to conduct such a survey of each of our
direct suppliers in order to identify and receive information regarding smelters and refiners of tungsten and tantalum in our supply chain.
Following an annual distribution of the Template to our direct suppliers of tungsten and/or tantalum or any material used in our manufacturing processes that contains tungsten and/or tantalum, we
ensure to receive responses with completed CMRT from all of our suppliers. Templates submitted by such direct suppliers are reviewed for reasonableness and for missing or incomplete data, and we contact such direct suppliers as necessary to obtain
clarifications or additional information where needed. Thereafter, we compare the smelters or refiners identified by those suppliers in their submitted Templates with the list of facilities designated by RMI as RMAP conformant to ensure compliance.
As disclosed on our website and in our code of ethics for suppliers, our ethics helpline is available for suppliers to report any violations of the law or violations of our codes of ethics.
| (iii) |
Design and Implement a Strategy to Respond to Identified Risks
|
Per the Company’s conflict minerals policy, we expect suppliers to have in place due diligence policies and procedures that ensure that materials that it supplies to Tower containing 3TG Minerals are
in fact "conflict-free", meaning that they do not directly or indirectly finance or benefit armed groups in the Covered Countries. If at any time the Company is not satisfied with a supplier's Template responses or believes that adequate policies and
procedures are not in place, it reserves the right to take appropriate action to enforce its conflict minerals policy, including discontinuing purchases from such suppliers.
In addition, conflict minerals findings are reported regularly to Tower’s Corporate Compliance Officer who is responsible for collecting and reviewing all relevant conflict minerals data and
formulating a proposed corporate strategy to address any risks identified by such review.
By taking these steps, we manage the risks associated with our supply chain by:
| - |
engaging with suppliers to obtain current, accurate and complete information about the suppliers’ supply chains; and
|
| - |
encouraging suppliers to implement responsible sourcing and work with smelters and refiners which have obtained a “conflict-free” designation from a third-party auditor such as under RMAP.
|
Finally, we have established an escalation process to contact suppliers upon obtaining any information that indicates that such suppliers may be sourcing necessary conflict minerals from any of the
Covered Countries without a "conflict free" designation. Steps considered by the Company in such instances may include requiring a contracted supplier to find an alternative source for the necessary 3TG Minerals for use in products or components
supplied to the Company, or, if appropriate, in light of all relevant circumstances, seeking an alternate source of supply and suspending or terminating the Company’s contractual relationship with such supplier.
| (iv) |
Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices
|
The Template provided to our suppliers requests information on the smelters and refiners used to provide the tungsten and tantalum in our products. We do not typically have a direct relationship with
smelters and refiners of such minerals and are unable to perform or direct audits of these entities within our supply chain. Instead, we compare information regarding refiners and smelters provided by our suppliers in their Template with lists of
refiners and smelters designated by RMI as RMAP conformant in order to ensure compliance.
| (v) |
Report Annually on Supply Chain Due Diligence
|
This conflict minerals report is available on our website at https://ir.towersemi.com/financial-information/sec-filings and has also been filed with the SEC.
Results of our Due Diligence Measures
We believe that following the OECD Guidance and usage of the Template RMAP represents reasonable and reliable ways to gather information on the source of conflict minerals in our products.
Inherent Limitations on Due Diligence Measures
Our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals in our products. Our due diligence
processes are based on the data received from our direct suppliers of tungsten and/or tantalum or any material used in our manufacturing processes that contains tungsten and/or tantalum, which in turn is based on information received by those
suppliers seeking similar data within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected through the RMAP and designations made by RMI as part of RMAP,
which may not yield accurate and complete information or make accurate designations in all cases.
Supplier Chain Survey Responses
As a result of our survey regarding 2022 activity, the three direct suppliers of tantalum and/or any material used in our manufacturing processes that contains tantalum indicated that their supply
chain includes smelters or refiners sourcing from the Covered Countries, as did five of our six direct suppliers of tungsten and/or any material used in our manufacturing processes that contains tungsten. However, each of the smelters and refiners
identified by such suppliers as sourcing tantalum or tungsten from Covered Countries has been designated as RMAP conformant.
The table below lists the facilities identified by our direct suppliers which, to the extent known, may have processed the tantalum and/or tungsten used in our products or in our manufacturing
processes in 2022. All of the below listed facilities have been designated as RMAP conformant.
Tantalum:
|
Changsha South Tantalum Niobium Co., Ltd.
|
CHINA
|
|
D Block Metals, LLC
|
UNITED STATES OF AMERICA
|
|
F&X Electro-Materials Ltd.
|
CHINA
|
|
FIR Metals & Resource Ltd.
|
CHINA
|
|
Global Advanced Metals Aizu
|
JAPAN
|
|
Global Advanced Metals Boyertown
|
UNITED STATES OF AMERICA
|
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CHINA
|
|
Jiangxi Tuohong New Raw Material
|
CHINA
|
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
CHINA
|
|
Jiujiang Tanbre Co., Ltd.
|
CHINA
|
|
Materion Newton Inc.
|
UNITED STATES OF AMERICA
|
|
Metallurgical Products India Pvt., Ltd.
|
INDIA
|
|
Mitsui Mining and Smelting Co., Ltd.
|
JAPAN
|
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CHINA
|
|
NPM Silmet AS
|
Estonia
|
|
TANIOBIS Co., Ltd.
|
THAILAND
|
|
TANIOBIS GmbH
|
GERMANY
|
|
TANIOBIS Japan Co., Ltd.
|
JAPAN
|
|
TANIOBIS Smelting GmbH & Co. KG
|
GERMANY
|
|
Telex Metals
|
UNITED STATES OF AMERICA
|
|
Ulba Metallurgical Plant JSC
|
KAZAKHSTAN
|
|
XIMEI RESOURCES (GUANGDONG) LIMITED
|
CHINA
|
|
Yanling Jincheng Tantalum & Niobium Co., Ltd.
|
CHINA
|
Tungsten:
|
A.L.M.T. Corp.
|
JAPAN
|
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CHINA
|
|
Fujian Ganmin RareMetal Co., Ltd.
|
CHINA
|
|
Ganzhou Haichuang Tungsten Co., Ltd.
|
CHINA
|
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CHINA
|
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CHINA
|
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CHINA
|
|
Global Tungsten & Powders Corp.
|
UNITED STATES OF AMERICA
|
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CHINA
|
|
H.C. Starck Tungsten GmbH
|
GERMANY
|
|
Hunan Chenzhou Mining Co., Ltd.
|
CHINA
|
|
Hunan Jintai New Material Co., Ltd.
|
CHINA
|
|
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
|
CHINA
|
|
Japan New Metals Co., Ltd.
|
JAPAN
|
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
CHINA
|
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CHINA
|
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CHINA
|
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CHINA
|
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CHINA
|
|
Kennametal Huntsville
|
UNITED STATES OF AMERICA
|
|
Lianyou Metals Co., Ltd.
|
Taiwan, Province Of China
|
|
Malipo Haiyu Tungsten Co., Ltd.
|
CHINA
|
|
Masan High-Tech Materials
|
VIET NAM
|
|
Niagara Refining LLC
|
UNITED STATES OF AMERICA
|
|
TANIOBIS Smelting GmbH & Co. KG
|
GERMANY
|
|
Wolfram Bergbau und Hutten AG
|
Austria
|
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CHINA
|
|
Xiamen Tungsten Co., Ltd.
|
CHINA
|
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
|
CHINA
|
In addition, our suppliers provided us with information regarding the countries of origin of the tantalum and tungsten supplied by certain of the above smelters and refiners, a list of which is
provided below. Our suppliers did not provide specific country of origin information for certain smelters and refiners. Due to the incompleteness of this information, Tower is unable at this time to determine and describe in this report a complete
list of specific countries of origin of such conflict minerals.
|
Angola-
Argentina-
Australia-
Austria-
Belgium-
Bolivia-
Brazil-
Burundi-
Cambodia-
Canada-
Central African Republic-
Chile-
China-
Colombia-
Democratic Republic of Congo-
Djibouti-
Ecuador-
Egypt-
Estonia-
Erithrea
Ethiopia-
France-
Georgia
Germany-
Ghana-
Guinea-
Guyana-
|
Hungary-
India-
Indonesia-
Ireland-
Israel-
Italy-
Japan-
Katanga-
Kazakhstan-
Korea-
Lichtenstein
Luxembourg-
Madagascar-
Malaysia-
Mexico-
Mongolia-
Mozambique-
Myanmar-
Namibia-
Netherlands-
Nigeria-
Panama
Papua New Guinea-
Peru-
|
Philippines-
Portugal-
Russian Federation-
Rwanda-
Saudi Arabia
Sierra Leone-
Singapore-
Slovenia-
South Africa-
South Sudan-
Spain-
Sudan-
Suriname-
Switzerland-
Taiwan-
Tanzania-
Thailand-
Turkey
United Kingdom-
United States-
Vietnam-
Zambia-
Zimbabwe-
|
Future Due Diligence Measures
For the calendar year ending December 31, 2022, we have engaged in the due diligence process described above. We will also continue to attempt to validate supplier responses using information
collected through independent conflict-free smelter validation programs, such as that of RMAP, and will take measures as needed to address any potential risks that are identified through these due diligence efforts.
This Form SD and conflict minerals report includes certain “forward-looking” statements within the meaning of Section 21E of the Securities Exchange Act of 1934. The use of the words “projects,”
“expects,” “may,” “plans” or “intends,” or words of similar import, identifies a statement as “forward-looking”. There can be no assurance, however, that actual results will not differ materially from our expectations or projections.