UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

 

Form SD

 

 

 

Specialized Disclosure Report

 

SodaStream International Ltd.

(Exact name of registrant as specified by its charter)

 

Israel

(State or other jurisdiction of
incorporation)

001-34929

(Commission File Number)

 

N/A

(I.R.S. Employer Identification No.)

 

Gilboa Street

Airport City 7019900

Israel

(Address of principal executive offices)

 

Daniel Birnbaum

Chief Executive Officer

Tel. +972 (3) 976-2301

(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:

 

  x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

 

 
 

 

SECTION 1 – CONFLICT MINERALS DISCLOSURE

 

Item 1.01 Conflict Minerals Disclosure and Report

 

Introduction

 

This Specialized Disclosure Form (“Form SD”) of SodaStream International Ltd. (the “Company,” “we” or “us”) is filed pursuant to Rule 13p-1 (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2014 to December 31, 2014.

 

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”) that originated in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).

 

Conclusion Based on Reasonable Country of Origin Inquiry

 

In accordance with the Rule, the Company has concluded in good faith that during the year ended December 31, 2014:

 

·Certain of the Company’s operations manufactured, or contracted to manufacture, products (the “Covered Products”) for which the Conflict Minerals are necessary to the functionality or production of those products; and

 

·Based on the Company’s good faith reasonable country of origin inquiry regarding the Conflict Minerals, which was designed to determine whether any of the Conflict Minerals contained in the Company’s Covered Products originated in the Covered Countries and whether any of the Conflict Minerals contained in the Covered Products may be from recycled or scrap sources, the Company had reason to believe that (i) the Conflict Minerals contained in its Covered Products may have originated in the Covered Countries and (ii) such Conflict Minerals may not be solely from recycled or scrap sources.

 

On the basis of these conclusions, the Company proceeded to exercise due diligence with respect to the source and chain of custody of the Conflict Minerals contained in its Covered Products and has submitted its Conflict Minerals Report (the “Report”) as an exhibit to this Form SD for the reporting period from January 1, 2014 to December 31, 2014. The Report describes the conflict minerals due diligence that the Company has designed and performed.

 

Based on the information that has been obtained, the Company has reasonably determined that countries of origin of the Conflict Minerals contained in its Covered Products include the following: Australia, Austria, Belgium, Bolivia, Brazil, Canada, China, Estonia, Germany, Hong Kong, India, Indonesia, Italy, Japan, Kazakhstan, Korea, Kyrgyzstan, Malaysia, Mexico, The Netherlands, Peru, Philippines, Poland, Russia, Saudi Arabia, Singapore, Spain, South Africa, Sweden, Switzerland, Taiwan, Thailand, Turkey, United States, Uzbekistan and Vietnam.

 

Conflict Minerals Disclosure

 

A copy of the Company’s Report is filed as Exhibit 1.01 herewith and is publicly available at http://sodastream.investorroom.com/. Unless otherwise stated in this Form SD and the attached Report, any documents, third-party materials or references to websites (including the Company’s) are not incorporated by reference in, or considered to be a part of, this Form SD and the accompanying Report.

 

1
 

 

Forward-Looking Statements

 

In addition to historical facts, this Form SD and the attached Report contain forward-looking statements within the meaning of Section 27A of the U.S. Securities Act of 1933, as amended, Section 21E of the U.S. Securities Exchange Act of 1934, as amended, and the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. We have based these forward-looking statements on our current expectations and projections about future events. Forward-looking statements include information concerning our possible or assumed future results of operations, business strategies, financing plans, competitive position, industry environment, potential growth opportunities, potential market opportunities and the effects of competition. Forward-looking statements include all statements that are not historical facts and can be identified by terms such as “anticipates,” “believes,” “could,” “seeks,” “estimates,” “expects,” “intends,” “may,” “plans,” “potential,” “predicts,” “projects,” “should,” “will,” “would” or similar expressions that convey uncertainty of future events or outcomes and the negatives of those terms. All forward-looking statements in this Form SD and the attached Report reflect our current views about future events, are based on assumptions and are subject to risks and uncertainties that could cause our actual results to differ materially from future results expressed or implied by the forward-looking statements. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future events, results, actions, levels of activity, performance or achievements. Many of these factors are beyond our ability to control or predict. Important factors that could cause actual outcomes to differ materially from those contained in any forward-looking statement include those described in the Company’s reports, including its annual report on Form 20-F for the fiscal year ended December 31, 2014, and other forms filed by the Company with or furnished by the Company to the Securities and Exchange Commission. You should not put undue reliance on any forward-looking statements. Unless we are required to do so under U.S. federal securities laws or other applicable laws, we do not intend to update or revise any forward-looking statements.

 

Item 1.02 Exhibit

 

As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.

 

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 of SodaStream International Ltd.

 

2
 

  

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.

 

SodaStream International Ltd.

 

By: /s/ Dotan Bar-Natan   June 1, 2015
 

Dotan Bar-Natan,

Head of Legal Department

  (Date)
3



 

Exhibit 1.01

 

SodaStream International Ltd.

 

Conflict Minerals Report

For the reporting period from January 1, 2014 to December 31, 2014

 

This is the Conflict Minerals Report (the “Report”) of SodaStream International Ltd. (“SodaStream,” the Company,” “we” or “us”) for the reporting period from January 1, 2014 to December 31, 2014 (the “2014 calendar year”), which has been prepared pursuant to Rule 13p-1 (the Rule”) promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives as limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”), that originated in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).

 

SodaStream has concluded, in good faith, that during the 2014 calendar year:

 

·SodaStream manufactured, or contracted to manufacture, products as to which the Conflict Minerals are necessary to the functionality or production of those products; and

 

·based on its good faith reasonable country of origin inquiry, SodaStream has reason to believe that a portion of its necessary Conflict Minerals may have originated from the Covered Countries, and has reason to believe that its necessary Conflict Minerals may not be solely from recycled or scrap sources.

 

As a result, SodaStream is filing this Report with its Form SD to comply with the requirements of the Rule. This Report has not been subject to an independent private sector audit.

 

PART I. DESCRIPTION OF THE COMPANY’S PRODUCTS COVERED BY THIS REPORT

 

SodaStream manufactures home beverage carbonation systems that enable consumers to transform ordinary tap water easily and instantly into sparkling water and flavored sparkling water. SodaStream develops, manufactures and sells sparkling water makers and exchangeable carbon-dioxide cylinders, along with consumables including carbon-dioxide refills, reusable carbonation bottles and flavors which consumers may add to the carbonated water. As of December 31, 2014, SodaStream’s products were sold through more than 70,000 individual retail stores in 45 countries.

 

As described in this Report, during the 2014 calendar year, certain of the Company’s operations manufactured, or contracted to manufacture, products for which the Conflict Minerals are necessary to the functionality or production of those products (collectively, the “Covered Products”). Three models of SodaStream’s sparkling water makers contain electronic circuit boards and other electrical components which may comprise tin, tungsten and gold. Additionally, Conflict Minerals can be found in the brass components within certain of SodaStream’s sparkling water makers and in the brass valves on its carbon-dioxide cylinders. While brass mainly consists of copper and zinc, brass may contain trace quantities of tin as an impurity to the other metals.

 

PART II.  THE COMPANY’S DUE DILIGENCE PROCESS

 

SodaStream has established a multi-stage diligence inquiry intended to verify the possible sources of the Conflict Minerals contained in the Company’s Covered Products. The Company has designed its due diligence measures to conform to the Rule and to the five-step framework laid out by the Organization for Economic Co-operation and Development in its OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition (2013), including the related supplements on gold, tin, tantalum and tungsten (collectively, the “OECD Guidance”). Because the Company does not purchase raw or unrefined Conflict Minerals directly from mines, smelters or refiners, and makes no direct purchases of any minerals in the Covered Countries, it has tailored its due diligence to the OECD Guideline standards applicable to downstream companies.

 

1
 

 

OECD Guidance Step 1: Establish strong management systems for conflict minerals supply chain due diligence and reporting compliance.

 

The Company has adopted a policy relating to the Conflict Minerals (the “Policy”), which incorporates the standards set forth in the OECD Guidance. As stated in the Policy, the Company expects its suppliers to implement sourcing and due diligence practices that prevent Conflict Minerals from the Covered Countries from entering the Company’s supply chain, and to require that their own suppliers do the same. Each supplier should also cooperate with the Company when the Company inquires as to the components of the supplier’s products and the details of the supplier’s supply chain, and should promptly inform the Company whenever the supplier has determined that such components originated in the Covered Countries. The Policy is available on the Company’s website at http://sodastream.investorroom.com/CorporateGovernance.

 

The Company has also structured internal management systems to support supply chain due diligence by establishing an internal working group consisting of cross-functional team members and senior executives. The working group, which includes employees from the Company’s procurement, legal and finance departments, is charged with executing the Company’s Conflict Minerals strategy and compliance processes and with training employees outside of the team on their roles and responsibilities in connection with the compliance program. Additionally, this team corresponds regularly to assess the progress of the Company’s compliance program and periodically updates the audit committee of the board of directors (the “Audit Committee”) with respect to the Company’s due diligence efforts and ongoing compliance obligations.

 

OECD Guidance Step 2: Identify and assess risks in the Company’s supply chain.

 

Identify risk in the supply chain.

 

As explained above, the Company does not buy raw ore or unrefined Conflict Minerals directly from refiners, smelters or mines. The Company’s supply chain with respect to the Covered Products is complex, with multiple intermediaries and third parties in the supply chain between the manufacture of the Covered Products and the original sources of the necessary Conflict Minerals. The Company relies on its direct suppliers (i.e. “first-tier suppliers”) to provide information on the origin of the Conflict Minerals contained in components and materials supplied to the Company, including information about the sources of the Conflict Minerals that the first-tier suppliers obtain from their own suppliers (i.e. “second-tier suppliers”). For its diligence during the 2014 calendar year, the Company reached out to its first-tier suppliers to discuss applicable smelters and refiners of Conflict Minerals in the Company’s supply chain.

 

The first step in the Company’s due diligence process was to determine which products manufactured or contracted to be manufactured by the Company during the 2014 calendar year fell within the scope of the Rule. A description of the Covered Products appears in Part I of this Report. In tandem with its analysis of its Covered Products, the Company identified those suppliers from which it purchases components or materials for the Covered Products that may include Conflict Minerals.

 

Next, the Company provided all suppliers identified in connection with the Covered Products with a supply chain survey in the form of the latest version of the Electronic Industry Citizenship Coalition Conflict Minerals Reporting Template (the “Template”). The Company used 3.01 of the Template for most of the 2014 calendar year, and then adopted version 3.02 of the Template following its release on November 7, 2014, to the extent it was contacting suppliers at that point. The Template requires suppliers to make representations regarding (i) the country of origin for the Conflict Minerals contained in the components or products it provides to the Company, (ii) all of the smelters in the supplier’s supply chain for such Conflict Minerals, (iii) whether such smelters have been validated as being in compliance with the Conflict-Free Smelter Initiative’s (“CFSI”) Conflict Free Smelter Program (“CFSP”), (iv) whether the supplier has its own Conflict Minerals policy that requires its own direct suppliers to be DRC conflict-free and (v) whether the supplier uses the Template with its own suppliers to gather similar information.

 

2
 

 

Assess risk in the supply chain.

 

SodaStream received responses from all of the suppliers to its request for information. SodaStream analyzed the survey responses to evaluate the level of compliance exercised by each surveyed supplier, and, to the extent possible, by upstream suppliers, with the Company’s Policy. The information received from suppliers was also reviewed against the CFSI’s Conflict-Free Smelter list. To compile its list, the CFSI employs independent third-party auditors to audit the source, including mines of origin and chain of custody, of the Conflict Minerals processed by smelters and refiners which agree to undergo an audit. SodaStream determined whether smelters and refiners identified in its supply chain qualified as “conflict-free” on the CFSI Conflict-Free Smelter list. SodaStream also designated smelter or refiners as “active,” where applicable, according to the CFSI Conflict-Free Smelter list.

 

A smelter or refiner is considered “conflict-free” on the CFSI Conflict-Free Smelter list if (i) the audited smelter or refiner adheres to the CFSP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals and (ii) the independent auditor verifies separately that the smelter’s or refiner’s Conflict Minerals originated from conflict-free sources. The CFSI Conflict-Free Smelter list provides the names, locations and links to conflict minerals policies of all smelters and refiners deemed compliant with the CFSP’s assessment protocols. Smelters and refiners labeled as “active” have committed to undergo an audit which remains in progress. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase, but may not retain their “active” status if they are unresponsive to requests for re-audit or corrective action past a certain time.

 

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

 

In light of the complexity of the Company’s and its suppliers’ supply chains, the Company is currently unable to assess adequately all of the risks in its supply chain. However, since the end of the 2014 calendar year, the Company has worked to mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries. Specific steps the Company has taken and continues to take to manage risks include:

 

·continuing to engage with manufacturers and suppliers to obtain current, accurate and complete information about the supply chain;
·continuing to improve due diligence efforts to ensure responsible sourcing in compliance with SodaStream’s Policy; and

·in coordination with the legal and other relevant teams, reviewing contractual engagement procedures with suppliers who, following the above process, failed to comply with SodaStream’s Policy for consideration of possible corrective actions, including cancellation of contracts and future engagements.

 

OECD Guidance Step 4: Carry out independent third-party audit of smelter/refiner due diligence practices.

 

Due to the Company’s position in the supply chain, the Company does not have a direct relationship with smelters and refiners, nor does it perform direct audits of the smelters and refiners that provide its supply chain with the Conflict Minerals contained in the Company’s Covered Products. The Company relies upon industry efforts to influence smelters and refiners to undergo audits and become certified through the CFSP.

 

OECD Guidance Step 5: Report annually on supply chain due diligence.

 

The Company has filed with the Securities and Exchange Commission its specialized disclosure report on Form SD, which includes this Report as Exhibit 1.01, for the reporting period in the 2014 calendar year. In accordance with OECD Guidance and the Rule, the Company has also made these disclosures available on its website at http://sodastream.investorroom.com/.

 

3
 

 

PART III. THE COMPANY’S DUE DILIGENCE FINDINGS AND CONCLUSIONS

 

Following the process outlined above, as of December 31, 2014, 38% of SodaStream’s suppliers to whom a Template was sent have not been able to verify the origin of all of the Conflict Minerals incorporated into the components and materials they supply to SodaStream. Therefore, after exercising its due diligence, the Company was unable to determine conclusively the origin of all of the Conflict Minerals contained in the Covered Products.

 

However, based on the information that was provided by the Company’s suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed in Appendix A attached to this Report.

 

PART IV. IMPLEMENTATION OF STRATEGIES TO RESPOND TO IDENTIFIED RISKS AND FUTURE STEPS

 

The Company plans to continue to educate suppliers about their role in the Company’s conflict minerals compliance program and to engage its suppliers to obtain current, accurate and complete information about the supply chain. Since the Company’s supply chain due diligence processes could assist in mitigating the possible risk that the necessary Conflict Minerals in the Company’s products could benefit armed groups in the Covered Countries, the Company intends to monitor the performance and efficiency of its due diligence efforts and to establish procedures designed to incorporate any new risks into the risk management plan, ensure responsible sourcing in compliance with its Policy and increase transparency in its supply chain.

 

4
 

 

 

Appendix A

Currently Known Smelter and Refinery List

 

Metal   Standard Smelter Names   Country of
Smelter
Facility
  Conflict-Free
Smelter
Initiative
Smelter
Status
             
Tungsten   A.L.M.T. Corp.   Japan   Conflict-Free
             
Gold   Aida Chemical Industries Co. Ltd.   Japan   Conflict-Free
             
Gold   Allgemeine Gold- und Silberscheideanstalt A.G.   Germany   Conflict-Free
             
Gold   Almalyk Mining and Metallurgical Complex (AMMC)   Uzbekistan   Unknown
             
Tin   Alpha   USA   Conflict-Free
             
Tin   Amalgamated Metals Corporation   Peru   Conflict-Free
             
Gold   AngloGold Ashanti Córrego do Sítio Minerção   Brazil   Conflict-Free
             
Gold   Argor-Heraeus SA   Switzerland   Conflict-Free
             
Gold   Asahi Pretec Corporation   Japan   Conflict-Free
             
Gold   Asaka Riken Co Ltd   Japan   Active
             
Gold   Atasay Kuyumculuk Sanayi Ve Ticaret A.S.   Turkey   Conflict-Free
             
Gold   Aurubis AG   Germany   Conflict-Free
             
Gold   Bangko Sentral ng Pilipinas (Central Bank of the Philippines)   Philippines   Unknown
             
Gold   Boliden AB   Sweden   Conflict-Free
             
Gold   Caridad   Mexico   Unknown
             
Gold   CCR Refinery – Glencore Canada Corporation   Canada   Conflict-Free
             
Gold   Cendres & Métaux SA   Switzerland   Active
             
Gold   Chimet S.p.A.   Italy   Conflict-Free
             
Tin   China Tin Group Co., Ltd.   China   Active
             
Tungsten   Chongyi Zhangyuan Tungsten Co Ltd   China   Conflict-Free
             
Tin   CNMC (Guangxi) PGMA Co. Ltd.   China   Conflict-Free
             
Tantulum   Conghua Tantalum and Niobium Smeltry   China   Conflict-Free
             
Tin   Cooper Santa   Brazil   Conflict-Free
             
Tin   CV Serumpun Sebalai   Indonesia   Unknown
             

A-1
 

 

Tin   CV United Smelting   Indonesia   Conflict-Free
             
Gold   Daye Non-Ferrous Metals Mining Ltd.   China   Unknown
             
Tungsten   Dayu Weiliang Tungsten Co., Ltd.   China   Conflict-Free
             
Gold   Dowa   Japan   Conflict-Free
             
Tantalum   Duoluoshan   China   Conflict-Free
             
Tin   EM Vinto   Bolivia   Conflict-Free
             
Tin   Estanho de Rondônia S.A.   Brazil   Unknown
             
Tantalum   Exotech Inc.   USA   Conflict-Free
             
Tantalum   F&X Electro-Materials Ltd.   China   Conflict-Free
             
Tin   Fenix Metals   Poland   Active
             
Gold   FSE Novosibirsk Refinery   Russia   Unknown
             
Tungsten   Fujian Jinxin Tungsten Co., Ltd.   China   Conflict-Free
             
Tungsten   Ganzhou Huaxing Tungsten Products Co., Ltd.   China   Conflict-Free
             
Tungsten   Ganzhou Non-ferrous Metals Smelting Co., Ltd.   China   Conflict-Free
             
Tungsten   Ganzhou Seadragon W & Mo Co., Ltd.   China   Conflict-Free
             
Tin   Gejiu Non-Ferrous Metal Processing Co. Ltd.   China   Conflict-Free
             
Tin   Gejiu Zi-Li   China   Unknown
             
Tantalum   Global Advanced Metals Boyertown   USA   Conflict-Free
             
Tungsten   Global Tungsten & Powders Corp.   USA   Conflict-Free
             
Gold   Guangdong Jinding Gold Limited   China   Unknown
             
Tungsten   Guangdong Xianglu Tungsten Industry Co., Ltd.   China   Conflict-Free
             
Tungsten   HC Starck GmbH   Germany   Conflict-Free
             
Gold   Heimerle + Meule GmbH   Austria   Conflict-Free
             
Gold   Heraeus Ltd. Hong Kong   China   Conflict-Free
             
Gold   Heraeus Precious Metals GmbH & Co. KG   Germany   Conflict-Free
             
Tantalum   Hi-Temp Speciality Metals Inc   USA   Conflict-Free
             
Tin   Huichang Jinshunda Tin Co. Ltd   China   Unknown
             
Tungsten   Hunan Chenzhou Mining Group Co, Ltd   China   Conflict-Free
             
Gold   Hunan Chenzhou Mining Industry Co. Ltd   China   Unknown
             
Tungsten   Hunan Chunchang Nonferrous Smelting & Concentrating Co., Ltd.   China   Unknown
             

A-2
 

 

Gold   Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited   China   Unknown
             
Gold   Ishifuku Metal Industry Co., Ltd.   Japan   Conflict-Free
             
Gold   Istanbul Gold Refinery   Turkey   Conflict-Free
             
Gold   Japan Mint   Japan   Conflict-Free
             
Tungsten   Japan New Metals Co Ltd   Japan   Conflict-Free
             
Gold   Jiangxi Copper Company Limited   China   Unknown
             
Tin   Jiangxi Nanshan   China   Unknown
             
Tantulum   JiuJiang JinXin Nonferrous Metals Co., Ltd.   China   Conflict-Free
             
Tantulum   Jiujiang Tanbre Co., Ltd.   China   Conflict-Free
             
Gold   Johnson Matthey Inc   USA   Conflict-Free
             
Gold   JSC Ekaterinburg Non-Ferrous Metal Processing Plant   Russia   Conflict-Free
             
Gold   JSC Uralectromed   Russia   Conflict-Free
             
Gold   JX Nippon Mining & Metals Co., Ltd.   Japan   Conflict-Free
             
Tin   Kai Unita Trade Limited Liability Company   China   Unknown
             
Gold   Kazzinc   Kazakhstan   Conflict-Free
             
Tantulum   Kemet Blue Powder   USA   Conflict-Free
             
Tungsten   Kennametal Fallon   USA   Conflict-Free
             
Tungsten   Kennametal Huntsville   USA   Conflict Free
             
Gold   Kennecott Utah Copper LLC   USA   Conflict-Free
             
Tantulum   King-Tan Tantalum Industry Ltd   China   Conflict-Free
             
Gold   Kojima Chemicals Co., Ltd   Japan   Conflict-Free
             
Gold   Korea Metal Co. Ltd   Korea   Unknown
             
Gold   Kyrgyzaltyn JSC   Kyrgyzstan   Unknown
             
Gold   L'azurde Company For Jewelry   Saudi Arabia   Conflict-Free
             
Gold   Lingbao Jinyuan Tonghui Refinery Co. Ltd.   China   Unknown
             
Tin   Linwu Xianggui Smelter Co   China   Unknown
             
Tin   Liuzhou China Tin Group Co   China   Active
             
Tantalum   LSM Brasil S.A.   Brazil   Conflict-Free
             
Gold   LS-NIKKO Copper Inc.   Korea   Conflict-Free
             
Tin   Malaysia Smelting Corporation (MSC)   Malaysia   Conflict-Free
             

A-3
 

 

Gold   Materion   USA   Conflict-Free
             
Gold   Matsuda Sangyo Co., Ltd.   Japan   Conflict-Free
             
Tin   Metallo-Chimique N.V.   Belgium   Conflict-Free
             
Tantalum   Metallurgical Products India (Pvt.) Ltd.   India   Conflict-Free
             
Gold   Metalor Technologies (Hong Kong) Ltd   China   Conflict-Free
             
Gold   Metalor Technologies (Singapore) Pte. Ltd.   Singapore   Conflict-Free
             
Gold   Metalor Technologies (Suzhou) Ltd   China   Unknown
             
Gold   Metalor Technologies SA   Switzerland   Conflict-Free
             
Gold   Metalor USA Refining Corporation   USA   Conflict-Free
             
Gold   Met-Mex Peñoles, S.A.   Mexico   Conflict-Free
             
Tantalum   Mineração Taboca S.A.   Brazil   Conflict-Free
             
Tin   Minsur   Peru   Conflict-Free
             
Tin   Mitsubishi Materials Corporation   Japan   Conflict-Free
             
Gold   Mitsui Mining and Smelting Co., Ltd.   Japan   Conflict-Free
             
Tantalum   Molycorp Silmet A.S.   Estonia   Conflict-Free
             
Gold   Moscow Special Alloys Processing Plant   Russia   Unknown
             
Gold   Nadir Metal Rafineri San. Ve Tic. A.Ş.   Turkey   Conflict-Free
             
Gold   Navoi Mining and Metallurgical Combinat   Uzbekestan   Unknown
             
Gold   Nihon Material Co. Ltd   Japan   Conflict-Free
             
Tantalum   Ningxia Orient Tantalum Industry Co., Ltd.   China   Conflict-Free
             
Tin   Novosibirsk Integrated Tin Works   Russia   Unknown
             
Tin   O.M. Manufacturing (Thailand) Co., Ltd.   Thailand   Active
             
Gold   Ohio Precious Metals, LLC   USA   Conflict-Free
             
Gold   OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)   Russia   Conflict-Free
             
Gold   OJSC Kolyma Refinery   Russia   Unknown
             
Tin   Operaciones Metalurgical S.A.   Bolivia   Conflict-Free
             
Gold   PAMP SA   Switzerland   Conflict-Free
             
Tantalum   Plansee SE Liezen   Austria   Conflict-Free
             
Gold   Prioksky Plant of Non-Ferrous Metals   Russia   Unknown
             
Gold   PT Aneka Tambang (Persero) Tbk   Indonesia   Conflict-Free
             

A-4
 

 

Tin   PT Artha Cipta Langgeng   Indonesia   Conflict-Free
             
Tin   PT Babel Inti Perkasa   Indonesia   Conflict-Free
             
Tin   PT Bangka Putra Karya   Indonesia   Conflict-Free
             
Tin   PT Bangka Tin Industry   Indonesia   Conflict-Free
             
Tin   PT Bukit Timah   Indonesia   Conflict-Free
             
Tin   PT DS Jaya Abadi   Indonesia   Conflict-Free
             
Tin   PT Eunindo Usaha Mandiri   Indonesia   Conflict-Free
             
Tin   PT Koba Tin   Indonesia   Unknown
             
Tin   PT Mitra Stania Prima   Indonesia   Unknown
             
Tin   PT Prima Timah Utama   Indonesia   Conflict-Free
             
Tin   PT Refined Bangka Tin   Indonesia   Conflict-Free
             
Tin   PT Sariwiguna Binasentosa   Indonesia   Conflict-Free
             
Tin   PT Stanindo Inti Perkasa   Indonesia   Conflict-Free
             
Tin   PT Tambang Timah   Indonesia   Conflict-Free
             
Tin   PT Timah (Persero), Tbk   Indonesia   Conflict-Free
             
Tin   PT Tinindo Inter Nusa   Indonesia   Conflict-Free
             
Gold   PX Précinox SA   Switzerland   Conflict-Free
             
Gold   Rand Refinery (Pty) Ltd   South Africa   Conflict-Free
             
Tantalum   RFH Tantalum Smeltry Co., Ltd   China   Conflict-Free
             
Gold   Royal Canadian Mint   Canada   Conflict-Free
             
Tin   Rui Da Hung   Taiwan   Active
             
Gold   Sabin Metal Corp.   USA   Unknown
             
Gold   Samwon Metals Corp.   Korea   Unknown
             
Gold   Schone Edelmetaal B.V.   The Netherlands   Conflict-Free
             
Gold   SEMPSA Joyería Platería SA   Spain   Conflict-Free
             
Gold   Shandong Zhaojin Gold & Silver Refinery Co. Ltd   China   Conflict-Free
             
Tantalum   Shanghai Jiangxi Metals Co. Ltd   China   Unknown
             
Gold   SOE Shyolkovsky Factory of Secondary Precious Metals   Russia   Active
             
Gold   Solar Applied Materials Technology Corp.   Taiwan   Conflict-Free
             
Tantalum   Solikamsk Magnesium Works OAO   Russia   Conflict-Free
             

A-5
 

 

Gold   Sumitomo Metal Mining Co., Ltd.   Japan   Conflict-Free
             
Tantalum   Taki Chemicals   Japan   Conflict-Free
             
Gold   Tanaka Kikinzoku Kogyo K.K.   Japan   Conflict-Free
             
Tantalite   Tantalite Resources (Pty) Ltd   South Africa   Unknown
             
Tungsten   Tejing (Vietnam) Tungsten Co., Ltd.   Vietnam   Conflict-Free
             
Tantalum   Telex Metals   USA   Conflict-Free
             
Tin   Thailand Smelting & Refining Co.,Ltd.   Thailand   Conflict-Free
             
Gold   The Great Wall Gold and Silver Refinery of China   China   Unknown
             
Gold   The Refinery of Shandong Gold Mining Co. Ltd   China   Conflict-Free
             
Gold   Tokuriki Honten Co., Ltd   Japan   Conflict-Free
             
Gold   Tongling Nonferrous Metals Group Co.,Ltd   China   Unknown
             
Gold   Torecom   Korea   Unknown
             
Tantalum   Ulba Metallurgical Plant JSC   Kazakhstan   Conflict-Free
             
Gold   Umicore Brasil Ltda   Brazil   Conflict-Free
             
Gold   Umicore SA Business Unit Precious Metals Refining   Belgium   Conflict-Free
             
Gold   United Precious Metal Refining, Inc.   USA   Conflict-Free
             
Gold   Valcambi SA   Switzerland   Conflict-Free
             
Tungsten   Vietnam Youngsun Tungsten Industry Co., Ltd   Vietnam   Conflict-Free
             
Gold   Western Australian Mint trading as The Perth Mint   Australia   Conflict-Free
             
Tin   White Solder Metalurgia e Mineração Ltda.   Brazil   Conflict-Free
             
Tungsten   Wolfram Bergbau und Hütten AG   Austria   Conflict-Free
             
Tungsten   Xiamen Tungsten (H.C.) Co., Ltd.   China   Conflict-Free
             
Tungsten   Xiamen Tungsten Co., Ltd   China   Conflict-Free
             
Gold   Yokohama Metal Co Ltd   Japan   Active
             
Tin   Yunnan Chengfeng Non-ferrous Metals Co, Ltd   China   Active
             
Tin   Yunnan Tin Group (Holding) Company Limited   China   Conflict-Free
             
Gold   Zhongyuan Gold Smelter of Zhongjin Gold Corporation   China   Conflict-Free
             
Tantalum   Zhuzhou Cemented Carbide   China   Conflict-Free
             
Gold   Zijin Mining Group Co. Ltd   China   Conflict-Free

 

A-6

 

Sodastream International Ltd. - Ordinary Shares (delisted) (NASDAQ:SODA)
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