UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
WESTINGHOUSE AIR BRAKE TECHNOLOGIES CORPORATION
(Exact name of the registrant as specified in its charter)
| Delaware | 033-90866 | 25-1615902 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 1001 Airbrake Avenue, Wilmerding, Pennsylvania | 15148 | |
| (Address of principle executive offices) | (Zip code) |
Ryan Bialas—(412) 825-1000
(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, 2013. |
Under the final rule, a company that uses any of the designated minerals is required to conduct a reasonable ‘country of origin’ inquiry that must be performed in good faith and be reasonably designed to determine whether any of its minerals originated in the covered countries or are from scrap or recycled sources.
| ITEM 1.01 | – Conflicts Minerals Disclosure and Report |
Introduction:
Westinghouse Air Brake Technologies Corporation, doing business as Wabtec Corporation, is a Delaware corporation with headquarters at 1001 Air Brake Avenue in Wilmerding, Pennsylvania. Our telephone number is 412-825-1000, and our website is located at www.wabtec.com. All references to “we”, “our”, “us”, the “Company” and “Wabtec” refer to Westinghouse Air Brake Technologies Corporation and its subsidiaries. Westinghouse Air Brake Company (“WABCO”) was formed in 1990 when it acquired certain assets and operations from American Standard, Inc., now known as Trane (“Trane”). In 1999, WABCO merged with MotivePower Industries, Inc. (“MotivePower”) and adopted the name Wabtec.
Today, Wabtec is one of the world’s largest providers of value-added, technology-based equipment and services for the global rail industry. We believe we hold approximately a 50% market share in North America for our primary braking-related equipment and a leading position in North America for most of our other product lines. Our highly engineered products, which are intended to enhance safety, improve productivity and reduce maintenance costs for customers, can be found on virtually all U.S. locomotives, freight cars, subway cars and buses, and on many of these vehicles around the world. In 2013, the Company had sales of approximately $2.6 billion and net income of about $292.2 million. In 2013 sales of aftermarket parts and services represented about 57% of total sales, while sales to customers outside of the U.S. accounted for about 48% of total sales.
We provide our products and services through two principal business segments, the Freight Segment and the Transit Segment, both of which have different market characteristics and business drivers.
The Freight Segment primarily manufacturers and services components for new and existing locomotive and freight cars, supplies railway electronics, positive train control equipment, signal design and engineering series, builds switcher locomotives, rebuilds freight locomotives and provides heat exchangers and cooling systems for rail and other industrial markets. Customers include large, publicly traded railroads, leasing companies, manufacturers of original equipment such as locomotives and freight cars, and utilities.
The Transit Segment primarily manufactures and services components for new and existing passenger transit vehicles, typically subway cars and buses, builds new commuter locomotives and refurbishes subway cars. Customers include public transit authorities and municipalities, leasing companies, and manufacturers of subway cars and buses around the world.
Following is a summary of our leading product lines in both aftermarket and original equipment across both of our business segments:
Specialty Products & Electronics:
| • | Positive Train Control equipment and electronically controlled pneumatic braking products |
| • | Railway electronics, including event recorders, monitoring equipment and end of train devices |
| • | Signal design and engineering services |
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| • | Freight car truck components |
| • | Draft gears, couplers and slack adjusters |
| • | Air compressors and dryers |
| • | Heat exchangers and cooling products for locomotives and power generation equipment |
| • | Track and switch products |
Brake Products:
| • | Railway braking equipment and related components for Freight and Transit applications |
| • | Friction products, including brake shoes and pads |
Remanufacturing, Overhaul and Build:
| • | New commuter and switcher locomotives |
| • | Transit car and locomotive overhaul and refurbishment |
Transit Products:
| • | Door and window assemblies for buses and subway cars |
| • | Accessibility lifts and ramps for buses and subway cars |
| • | Traction motors |
The following is Wabtec’s Conflict Mineral Policy, which can be found at: http://www.wabtec.com/documents/governance/WABTEC_CONFLICT_MINERALS_POLICY_v1.pdf.
Wabtec Conflict Minerals Policy
Wabtec Corporation (“Wabtec”) has developed and implemented this policy to provide guidance concerning the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. The matters covered in the policy are of the utmost importance to Wabtec and are essential to the Company’s ability to conduct business in a global marketplace at the highest ethical and legal standards.
The ongoing conflict in the Democratic Republic of the Congo (“DRC”) is fueled in part from the trade of “conflict minerals”, which are defined as tantalum, tin, tungsten, and gold or any of their derivatives.
Wabtec is committed to avoiding the use of conflict minerals that directly or indirectly finance or benefit armed groups in the DRC or adjoining countries.
Wabtec is committed to complying with the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502, which requires companies to inquire into the origin of conflict minerals in their supply chains and report on the reasonable inquiry or due diligence they conduct to determine whether their purchase supported armed groups in the DRC.
Wabtec does not procure minerals directly and only a fraction of the world’s minerals originate from the DRC, but we are incorporating the principles of this policy into our supplier contracts and will work with our suppliers to increase transparency, ensuring responsible procurement by our suppliers and sub-suppliers, and to drive positive channels throughout the supply chain.
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Wabtec suppliers of products that contain tantalum, tin, tungsten or gold which is necessary for production or functionality of the product will be expected to perform due diligence and provide the mineral source country.
Wabtec reserves the right to conduct audits to ensure our supply chain remains compliant with the Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502. If Wabtec identifies a reasonable risk that a supplier is violating our commitments set forth in this policy, we require them to commit to and implement a corrective action plan within a reasonable timeline and will conduct on-site assessments as necessary.
Section 1 – Conflict Minerals Disclosures
In accordance with the execution of this policy, Wabtec has concluded in good faith that during 2013, with respect to any product manufactured or contracted to be manufactured by Wabtec; that Wabtec is unable to determine after performing “reasonable country of origin inquiries” whether or not tin, tantalum, tungsten, or gold (“3TG”) included in Wabtec products originate from the Democratic Republic of the Congo or adjoining countries (“DRC”).
Wabtec’s reasonable country of origin inquiry (“RCOI”) employed measures to determine whether the necessary 3TG in Wabtec products originate from the Covered Countries (“DRC”). Wabtec’s primary means of determining country of origin of necessary 3TG was by conducting supply-chain survey with direct suppliers utilizing the Electronic Industry Citizenship Coalition and The Global e-Sustainability Initiative Template (“EICC/GeSI Conflict Minerals Reporting Template”).
A summary of all supply-chain survey respondents can be found on our Conflict Minerals Report.
| ITEM 1.02 | – Exhibit |
In accord with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), Wabtec has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report and both reports are posted to: http://www.wabtec.com/documents/governance
Item 2.01 Exhibits
List below the following exhibit filed as part of this report.
Exhibit 1.02 – Conflict Minerals Report as required by Item 1.01 and 1.02 of this Form.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| WESTINGHOUSE AIR BRAKE TECHNOLOGIES CORPORATION |
| (Registrant) |
| /s/ Patrick D. Dugan | June 2, 2014 | |||||
| By | Patrick D. Dugan Senior Vice President Finance and Chief Financial Officer |
(Date) | ||||
| * | Print name and title of the registrant’s signing executive officer under his or her signature. |
Page 5 of 18
Exhibit 1.02
Conflict Minerals Report of Wabtec Corporation
In Accord with Rule 13p-1 under the Securities Exchange Act of 1934
This is the Conflict Minerals Report of Wabtec for the calendar year 2013 (excepting conflict minerals that, prior to January 31, 2013, were located outside of the supply chain) in accord with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). Numerous terms in this Report are defined in Rule 13p-1 and Form SD and the reader is referred to those sources and to 1934 Act Release No. 34-67716 (August 22, 2012) for such definitions.
In accord with Rule 13p-1, Wabtec undertook due diligence to seek to determine whether the necessary 3TG in the Specialty Products and Electronics; Brake Products; Remanufacturing, Overhaul and Build; and Transit Products business segments originated from the DRC and adjoining countries. Wabtec designed its due diligence measures to be in conformity, in all material respects, with the recognized OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”).
As a result of our due diligence efforts Wabtec has concluded in good faith that during 2013, with respect to any product manufactured or contracted to be manufactured by Wabtec; that Wabtec is unable to determine whether or not the 3TG included in our products originated from the Covered Countries.
This Report has not been subject to an independent private sector audit as allowed under Rule 13p-1, which provides a temporary accommodation for the first two reporting years.
Wabtec’s due diligence measures included:
| • | Conducted a supply-chain survey with direct suppliers using the EICC/GeSI Conflict Minerals Reporting Template to identify the smelters and refiners who contribute refined 3TG to Wabtec products. |
| • | The identified smelters and refiners resulting from the supply chain survey were compared to the facilities found on the Conflict-Free Smelter Program (“CFSP”) list published by the Conflict-Free Sourcing Initiative (“CFSI”). |
| • | Conflict minerals records are retained per our record retention protocol. |
| • | Standard language regarding conflict minerals has been integrated into our supplier contracts ensuring due diligence participation and compliance. |
As a result of Wabtec’s due diligence efforts, we have identified and obtained sourcing information on 250 of the smelters, refiners and distributors who contribute to our Specialty and Electronic; Brake Products; Remanufacturing, Overhaul and Build; and Transit Products business segments. Of the 250 identified smelters, refiners and distributors, 58 are found on the CFSP as of May 20, 2014. The following is a summary of all supply-chain survey respondents.
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3TG PRODUCTION FACILITY COUTNRY OF ORIGIN
| 3TG |
Countries of origin may include the following | |
| Tantalum |
UKN; NON-DRC; CN; US; DE; JP; KZ; AU; ID; IN | |
| Tin |
UKN; NON-DRC; US; BO; ID; MY; BR; PE; TH; CN; JP; RU; DE; BE ; CZ; FR; KR ; TW; TH | |
| Tungsten |
UKN; NON-DRC; US; CN; AU; CA; DE; JP; KR | |
| Gold |
UKN; NON-DRC; JP;AU; DE; UZ; BR; CH; TR; SE; MX; KR; IT; CL; ES; RU; HK; CA; US; KG; KZ; SA; CN; BE; TW; NL; PH | |
| *“UKN” – Unknown; “NON-DRC” – Responses received from Suppliers stating that the 3TG included in the procured items did not originate from the DRC or adjoining countries | ||
IDENTIFIED SMELTERS, REFINERS AND DISTRIBUTORS OBTAINED THROUGH RCOI SURVEY
| 3TG |
Smelter |
Country |
CFSI Conflict Free Smelter Program Participant | |||
| Gold | AGR Matthey | Australia | ||||
| Gold | AIDA Chemical Industries Co.,Ltd | Japan | ||||
| Gold | Air products | Germany | ||||
| Gold | Allgemeine Gold- & Silberscheideanstalt | Germany | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | ||||
| Gold | AngloGold Ashanti Mineração Ltda | Brazil | Yes | |||
| Gold | Argor Heraeus | Switzerland | ||||
| Gold | Asahi Pretec Corp | Japan | ||||
| Gold | Asaka Riken Co Ltd | Japan | ||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | ||||
| Gold | Aurubis AG | Germany | ||||
| Gold | Aurubis AG | Japan | ||||
| Gold | Boliden AB | Sweden | ||||
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| Gold | Cendres & Métaux SA | Switzerland | ||||
| Gold | CHALCO Yunnan Copper Co. Ltd. | China | ||||
| Gold | Chimet SpA | Italy | Yes | |||
| Gold | China Golddeal | China | ||||
| Gold | China National Non-ferrous | Japan | ||||
| Gold | China’s Shangdong Gold Mining Co., Ltd | China | ||||
| Gold | Chroma New Material Corp. | China | ||||
| Gold | Chugai Mining | Japan | ||||
| Gold | Codelco | Chile | ||||
| Gold | Cooper Santa | Japan | ||||
| Gold | CS | Japan | ||||
| Gold | Daye Nonferrous | China | ||||
| Gold | Degutea | Japan | ||||
| Gold | Dowa Kogyo k.k | Japan | Yes | |||
| Gold | Dowa Metals & Mining Co. Ltd | Japan | Yes | |||
| Gold | EBARA-UDYLITE | Russian Federation | ||||
| Gold | FSE Novosibirsk Refinery | Russian Federation | ||||
| Gold | Furukawa Electric | Saudi Arabia | ||||
| Gold | Ganzhou Hongfei W&Mo Materials Co., Ltd. | China | ||||
| Gold | Global Tungsten & Powders Corp | Japan | ||||
| Gold | Guangxi Pinggui PGMA Co. Ltd. | Netherlands | ||||
| Gold | Harima Smelter | Japan | ||||
| Gold | HC Stark | Japan | ||||
| Gold | Heesung Catalysts Corp. | Taiwan | ||||
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| Gold | Heesung Metal Ltd. | Sweden | ||||
| Gold | Heimerle + Meule GmbH | Germany | Yes | |||
| Gold | Heraeus Germany | Germany | Yes | |||
| Gold | Heraeus Hong Kong | Hong Kong | Yes | |||
| Gold | Heraeus limited | Hong Kong | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Yes | |||
| Gold | Heraeus Technology Center | China | ||||
| Gold | Heraeus Technology Center | Hong Kong | ||||
| Gold | Heraus | Russian Federation | ||||
| Gold | Hisikari Mine | Japan | ||||
| Gold | Hitachi Cable | Switzerland | ||||
| Gold | Hitachi Ltd. | Switzerland | ||||
| Gold | Huichang Shun Tin, Kam Industries, Ltd. | Uzbekistan | ||||
| Gold | Hunan Chenzhou Mining Group Co. Ltd. | China | ||||
| Gold | Hunan Chun-chang Non-ferrous Smelting & Concentrating Co., Ltd. | China | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | ||||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Yes | |||
| Gold | Ishifuku Tokyo Melters | Japan | ||||
| Gold | Istanbul Gold Refinery | Turkey | Yes | |||
| Gold | Japan Mint | Japan | ||||
| Gold | Jiangxi Copper Company Limited | China | ||||
| Gold | Jiangxi Tungsten Industry Group Co., Ltd | Japan | ||||
| Gold | Jinlong Copper Co., Ltd. | Japan | ||||
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| Gold | Johnson Matthey Canada | Canada | Yes | |||
| Gold | Johnson Matthey Inc | United States | Yes | |||
| Gold | Johnson Matthey Limited | Canada | Yes | |||
| Gold | Johnson Matthey USA | United States | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | ||||
| Gold | JSC Uralectromed | Russian Federation | ||||
| Gold | JX Nippon Mining & Metals Co., Ltd | Japan | Yes | |||
| Gold | Kazzinc Ltd | Kazakhstan | ||||
| Gold | Kee Shing | Japan | ||||
| Gold | Kennecott Utah Copper | United States | Yes | |||
| Gold | Kojima Chemicals Co. Ltd | Japan | Yes | |||
| Gold | Kyocera | China | ||||
| Gold | Kyocery | Switzerland | ||||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | ||||
| Gold | L’ azurde Company For Jewelry | Saudi Arabia | ||||
| Gold | La Caridad | Mexico | ||||
| Gold | Laybold | Russian Federation | ||||
| Gold | Lingao Gold | China | ||||
| Gold | LS Nikko | Korea, Republic of | Yes | |||
| Gold | Luoyang ZIJIN YINHUI Gold Smelting Co. Ltd. | China | ||||
| Gold | Materion Advanced Metals | United States | Yes | |||
| Gold | Matsuda Sangyo Co. Ltd | Japan | Yes | |||
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| Gold | Metallurgical Products India Pvt Ltd. | Brazil | ||||
| Gold | Metalor | United States | Yes | |||
| Gold | Metalor Technologies (Hong Kong) Ltd | Hong Kong | Yes | |||
| Gold | Metalor Technologies SA | Switzerland | Yes | |||
| Gold | Metalor USA Refining Corporation | United States | Yes | |||
| Gold | Met-Mex Peñoles, S.A. | Mexico | ||||
| Gold | Mitsubishi Electric Metecs Co., Ltd. | China | ||||
| Gold | Mitsubishi Materials | China | ||||
| Gold | Mitsubishi Materials Corporation | Japan | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Yes | |||
| Gold | Mitui Kinzoku co Ltd. | Japan | ||||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | ||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | ||||
| Gold | Nanchang Cemented Carbide Limited Liability Company | Japan | ||||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | ||||
| Gold | Neomax Hitachi | Germany | ||||
| Gold | Nihon Material Co. LTD | Japan | Yes | |||
| Gold | Niihama Nickel Refinery | Japan | ||||
| Gold | Nippon Mining | Japan | ||||
| Gold | Nippon Steel | Switzerland | ||||
| Gold | Ohio Precious Metals LLC. | United States | Yes | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Russian Federation | ||||
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| Gold | OJSC Kolyma Refinery | Russian Federation | ||||
| Gold | Pan Pacific Copper Co Ltd., | Korea, Republic of | ||||
| Gold | PBT | Russian Federation | ||||
| Gold | Perth Mint (Western Australia Mint) | Australia | Yes | |||
| Gold | Pure Technology | Indonesia | ||||
| Gold | RedRing Solder (M) Sdn. Bhd | Russian Federation | ||||
| Gold | Royal Canadian Mint | Canada | Yes | |||
| Gold | SABIN | Japan | ||||
| Gold | Sabin Metal Corp. | United States | ||||
| Gold | Sabin Metals | Japan | ||||
| Gold | Samhwa non-ferrorus Metal ind.co.ltd | Italy | ||||
| Gold | SEMPSA | Spain | Yes | |||
| Gold | Senju Metal Industry Co. | Japan | ||||
| Gold | Senju Metal Industry Co. (SMIC) | Spain | ||||
| Gold | SENJU METAL INDUSTRY CO.,LTD. | Australia | ||||
| Gold | SENJU METAL INDUSTRY CO.,LTD. | Switzerland | ||||
| Gold | SGS | Russian Federation | ||||
| Gold | Shandong Gold Mining (Laizhou) | China | ||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co. Ltd. | China | ||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | China | ||||
| Gold | Shandong Zhaoyuan Gold Argentine refining company limited | China | ||||
Page 12 of 18
| Gold | Shenmao | Taiwan | ||||
| Gold | Shenmao | United States | ||||
| Gold | Sintron, Shenmao Solder (M) Sdn Bhd | Russian Federation | ||||
| Gold | So Accurate Refing Group | United States | ||||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | ||||
| Gold | Sumimoto | Japan | ||||
| Gold | Suzhou Xingrui Noble | China | ||||
| Gold | TaeguTec | Japan | ||||
| Gold | Taki Chemical Co., Ltd. | Brazil | ||||
| Gold | Tamura | Japan | ||||
| Gold | Tanaka Kikinnzoku Kogyo K.K. | Japan | Yes | |||
| Gold | TANAKA KIKINZOKU HANBAI K.K. | Japan | Yes | |||
| Gold | Technic Inc. | Mexico | ||||
| Gold | The Great Wall Gold and Silver Refinery of China | China | ||||
| Gold | The Perth Mint | Australia | ||||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | China | ||||
| Gold | Tongling Nonferrous Metal Group Co. Ltd | China | ||||
| Gold | UBS | Canada | ||||
| Gold | Umicore Precious Metals Refining | Belgium | ||||
| Gold | Umicore SA | Belgium | Yes | |||
| Gold | Unit Timah Kundur PT Tambang | Kazakhstan | ||||
| Gold | United Precious Metal Refining Inc. | United States | Yes | |||
| Gold | United Refining | Japan | ||||
| Gold | Xiamen Golden Egret Special Alloy Co. Ltd. (GESAC) | Taiwan | ||||
Page 13 of 18
| Gold | YOKOHAMA METAL CO.,LTD. | Japan | ||||
| Gold | Yoo Chang Metal Industries Co Ltd. | Taiwan | ||||
| Gold | Yunnan Tin Group (Holding) Company Limited (YTCL) | Switzerland | ||||
| Gold | Yuntinic Chemical GmbH | Kyrgyzstan | ||||
| Gold | Zhaojin refining | Taiwan | ||||
| Gold | Zhongjin Gold Corporation Limited | China | ||||
| Gold | Zijin Mining Group Co. Ltd | China | ||||
| Tantalum | Cabot Corporation | United States | ||||
| Tantalum | Duoluoshan | China | Yes | |||
| Tantalum | Exotech Inc. | United States | Yes | |||
| Tantalum | F&X | China | Yes | |||
| Tantalum | Gannon & Scott | United States | Yes | |||
| Tantalum | Global Advanced Metals | United States | ||||
| Tantalum | H.C. Starck GmbH | Germany | Yes | |||
| Tantalum | Hi-Temp | United States | Yes | |||
| Tantalum | Jiujiang Tambre | China | ||||
| Tantalum | Mitsui Mining & Smelting | Japan | ||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Yes | |||
| Tantalum | Niotan | United States | Yes | |||
| Tantalum | Plansee | Austria | ||||
| Tantalum | Ulba | Kazakhstan | ||||
| Tin | Complejo Metalurico Vinto S.A. | Bolivia | Yes | |||
| Tin | Cookson | United States | ||||
| Tin | Cooper Santa | Brazil | ||||
Page 14 of 18
| Tin | CV DS Jaya Abadi | Indonesia | ||||
| Tin | CV Duta Putra Bangka | Indonesia | ||||
| Tin | CV JusTindo | Indonesia | ||||
| Tin | CV Makmur Jaya | Indonesia | ||||
| Tin | CV Nurjanah | Indonesia | ||||
| Tin | CV Prima Timah Utama | Indonesia | ||||
| Tin | CV Serumpun Sebalai | Indonesia | ||||
| Tin | CV United Smelting | Indonesia | ||||
| Tin | EM VINTO | Bolivia | ||||
| Tin | Empresa Metallurgica Vinto | Bolivia | ||||
| Tin | Empressa Nacional de Fundiciones (ENAF) | Bolivia | ||||
| Tin | Funsur Smelter | Peru | ||||
| Tin | Gejiu Non-ferrous | China | ||||
| Tin | Gejiu Zi-Li | China | Yes | |||
| Tin | Gejiu Zili Metallurgy Co. | China | ||||
| Tin | Gold Bell Group | China | ||||
| Tin | Jean Goldschmidt International | Belgium | ||||
| Tin | Jiangxi Nanshan | China | ||||
| Tin | Keeling & Walker | Peru | ||||
| Tin | Liuzhou China Tin | China | ||||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Yes | |||
| Tin | Metallic Resources Inc | United States | ||||
| Tin | Metallo Chimique | Belgium | ||||
| Tin | Mineração Taboca S.A. | Brazil | ||||
| Tin | Minsur | Brazil | Yes | |||
Page 15 of 18
| Tin | Minsur S.A. Tin Metal | Peru | Yes | |||
| Tin | Mitsubishi Materials Corporation | Japan | ||||
| Tin | Nathan Trotter & Co., Inc. | United States | Yes | |||
| Tin | Novosibirsk | Russian Federation | ||||
| Tin | OMSA | Bolivia | ||||
| Tin | PT Alam Lestari Kencana | Indonesia | Yes | |||
| Tin | PT Artha Cipta Langgeng | Indonesia | ||||
| Tin | PT Babel Inti Perkasa | Indonesia | ||||
| Tin | PT Babel Surya Alam Lestari | Indonesia | ||||
| Tin | PT Bangka Kudai Tin | Indonesia | ||||
| Tin | PT Bangka Putra Karya | Indonesia | ||||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | ||||
| Tin | PT Belitung Industri Sejahtera | Indonesia | ||||
| Tin | PT BilliTin Makmur Lestari | Indonesia | ||||
| Tin | PT Bukit Timah | Indonesia | ||||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Yes | |||
| Tin | PT Fang Di MulTindo | Indonesia | ||||
| Tin | PT HP Metals Indonesia | Indonesia | ||||
| Tin | PT Koba Tin | Indonesia | ||||
| Tin | PT Mitra Stania Prima | Indonesia | ||||
| Tin | PT Refined Banka Tin | Indonesia | ||||
| Tin | PT Sariwiguna Binasentosa | Indonesia | ||||
| Tin | PT Stanindo Inti Perkasa | Indonesia | ||||
| Tin | PT Sumber Jaya Indah | Indonesia | ||||
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| Tin | PT Tambang Timah | Indonesia | ||||
| Tin | PT Timah | Indonesia | Yes | |||
| Tin | PT Timah Nusantara | Indonesia | Yes | |||
| Tin | PT Tinindo Inter Nusa | Indonesia | ||||
| Tin | PT Yinchendo Mining Industry | Japan | ||||
| Tin | Smelting Branch of Yunnan Tin Company Limited | China | ||||
| Tin | Thailand Smelting and Refining Co. Ltd. | Thailand | ||||
| Tin | Thaisarco | Thailand | ||||
| Tin | White Solder Metalurgia | Brazil | Yes | |||
| Tin | Yunnan Chengfeng Non-Ferrous Metals Co Ltd | China | ||||
| Tin | Yunnan Tin Company Limited | China | ||||
| Tin | Yuntinic Resources Inc. | China | Yes | |||
| Tungsten | ATI Firth Sterling | United States | ||||
| Tungsten | ATI Metalworking Products | United States | ||||
| Tungsten | Chaozhou Xianglu Tungsten Industry Co Ltd | China | ||||
| Tungsten | China Minmetals Corp | China | ||||
| Tungsten | Chongyi Zhangyuan Tungsten Co Ltd | China | ||||
| Tungsten | Ganzhou Grand Sea W & Mo Group Co Ltd | China | ||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co. Ltd. | China | ||||
| Tungsten | Ganzhou Sea Dragon | China | ||||
| Tungsten | Ganzhou Sinda W&Mo Co. Ltd. | China | ||||
| Tungsten | Global Tungsten & Powders Corp | United States | ||||
| Tungsten | Hunan Chenzhou Mining Group Co | China | Yes | |||
| Tungsten | Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | China | ||||
Page 17 of 18
| Tungsten | Jiangxi Tungsten Industry Co Ltd | China | ||||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | ||||
| Tungsten | Wolfram Company CJSC | Russian Federation | ||||
| Tungsten | Xiamen Tungsten Co Ltd | China | ||||
On the basis of the due diligence measures described above, Wabtec is unable to determine whether or not the 3TG contained in various components/materials which contribute to Specialty Products and Electronic; Brake Products; Remanufacturing, Overhaul and Build; and Transit Products business segments originated from the DRC or adjoining countries. Wabtec is making this determination because it does not have sufficient information from suppliers or other sources to conclude whether the necessary 3TG originated in the Covered Countries and, whether the necessary 3TG were from recycle or scrap sources.
Further, Wabtec as a purchaser is many steps removed from the mining of the conflict minerals; Wabtec does not purchase raw ore or unrefined tin, tantalum, tungsten or gold, and does no purchasing in the Covered Countries. The origin of 3TG cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other 3TG containing derivatives. The smelters and refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores.
Wabtec will undertake the following steps during the next compliance periods to improve the due diligence conducted to further mitigate the risk that its necessary 3TG do not benefit armed groups, including:
| • | Increase the response rate of the suppliers’ supply chain surveys |
| • | Continue to compare RCOI results to information collected via independent conflict free smelter validation programs such as the CFSI Conflict Free Smelter program. |
| • | Contacting smelters identified as a result of the RCOI process and requesting their participation in obtaining a “conflict free” designation from an industry program such as the CFSI Conflict Free Smelter program. |
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