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, 2015. |
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.
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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 2015, the Company had sales of approximately $3.3 billion and net income of about $398.6 million. In 2015, sales of aftermarket parts and services represented about 62% of total sales, while sales to customers outside of the U.S. accounted for about 47% 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 manufactures and services components for new and existing locomotive and freight cars, supplies railway electronics, positive train control equipment, signal design and engineering services, 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. As discussed previously, demand in the freight market is primarily driven by rail traffic, and deliveries of new locomotives and freight cars. In 2015, the Freight Segment accounted for 62% of our total sales, with about 81% of its sales in North America and the remainder to international customers. In 2015, slightly more than half of the Freight Segment’s sales were in aftermarket.
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. As discussed previously, demand in the transit market is primarily driven by government funding at all levels and passenger ridership. In 2015, the Transit Segment accounted for 38% of our total sales, with about 39% of its sales in North America and the remainder to international customers. About two-thirds of the Transit Segment’s sales are in the aftermarket with the remainder in the original equipment market.
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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 |
| • | 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:
https://wabtec.com/uploads/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.
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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.
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 2015, with respect to any product manufactured or contracted to be manufactured by Wabtec; that Wabtec is unable to definitively 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.
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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: https://wabtec.com/secedgar.
Item 2.01 Exhibits
List below the following exhibit filed as part of this report.
Exhibit 1.01 – 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 |
May, 31, 2016 | |||||||||
| By | Patrick D. Dugan | (Date) | ||||||||
| Senior Vice President Finance | ||||||||||
| and Chief Financial Officer | ||||||||||
| * | Print name and title of the registrant’s signing executive officer under his or her signature. |
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Exhibit 1.01
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 2015. 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 2015, with respect to any product manufactured or contracted to be manufactured by Wabtec; that Wabtec is unable to definitively 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.
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 193 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 193 identified smelters, refiners and distributors, 150 are found on the CFSP as of May 31, 2016. 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; AT; BR; CN; EE; DE; IN; JP; KZ; RU; US | |
| Tin | UKN; NON-DRC; BE; BO; BR; CN; ID; JP; MY; PE; RU; TW; TH; US | |
| Tungsten | UKN; NON-DRC; AT; CN; DE; JP; US; VN | |
| Gold | UKN; NON-DRC; AU; BE; CA; CN; DE; ID; IT; JP; KZ; KR; KG; MX; NL; PH; RU; SA; SG; ZA; ES; SE; CH; TW; TR; US; UZ | |
| *“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 | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes | |||
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes | |||
| Gold | Asahi Pretec Corporation | JAPAN | Yes | |||
| Gold | Asahi Refining Canada Limited | CANADA | Yes | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes | |||
| Gold | Aurubis AG | GERMANY | Yes | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes | |||
| Gold | Bauer Walser AG | GERMANY | ||||
| Gold | Boliden AB | SWEDEN | Yes | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes | |||
| Gold | Caridad | MEXICO | ||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes | |||
| Gold | Cendres + Métaux SA | SWITZERLAND | ||||
| Gold | Chimet S.p.A. | ITALY | Yes | |||
| Gold | Chugai Mining | JAPAN | ||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
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| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | ||||
| Gold | DODUCO GmbH | GERMANY | Yes | |||
| Gold | Dowa | JAPAN | Yes | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes | |||
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||
| Gold | Heimerle + Meule GmbH | GERMANY | Yes | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | Japan Mint | JAPAN | Yes | |||
| Gold | Jiangxi Copper Company Limited | CHINA | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes | |||
| Gold | Kazzinc | KAZAKHSTAN | Yes | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes | |||
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||
| Gold | L’ azurde Company For Jewelry | SAUDI ARABIA | ||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||
| Gold | Materion | UNITED STATES | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes | |||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes |
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| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | Yes | |||
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | ||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes | |||
| Gold | PAMP SA | SWITZERLAND | Yes | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes | |||
| Gold | PX Précinox SA | SWITZERLAND | Yes | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes | |||
| Gold | Royal Canadian Mint | CANADA | Yes | |||
| Gold | Sabin Metal Corp. | UNITED STATES | ||||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | ||||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | ||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes | |||
| Gold | Valcambi SA | SWITZERLAND | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes | |||
| Tantalum | Duoluoshan | CHINA | Yes |
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| Tantalum | Exotech Inc. | UNITED STATES | Yes | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes | |||
| Tantalum | QuantumClean | UNITED STATES | Yes | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes | |||
| Tantalum | Taki Chemicals | JAPAN | Yes | |||
| Tantalum | Telex Metals | UNITED STATES | Yes | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes | |||
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes | |||
| Tin | Alpha | UNITED STATES | Yes | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Yes | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | ||||
| Tin | CV Serumpun Sebalai | INDONESIA | Yes | |||
| Tin | CV United Smelting | INDONESIA | Yes | |||
| Tin | EM Vinto | BOLIVIA | Yes | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | ||||
| Tin | Fenix Metals | POLAND | Yes | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes |
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| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | ||||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes | |||
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tin | Minsur | PERU | Yes | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Bangka Kudai Tin | INDONESIA | ||||
| Tin | PT Bangka Putra Karya | INDONESIA | ||||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes | |||
| Tin | PT Bukit Timah | INDONESIA | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes | |||
| Tin | PT Justindo | INDONESIA | Yes | |||
| Tin | PT Karimun Mining | INDONESIA | ||||
| Tin | PT Mitra Stania Prima | INDONESIA | Yes | |||
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | ||||
| Tin | PT Refined Bangka Tin | INDONESIA | Yes | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes | |||
| Tin | Rui Da Hung | TAIWAN | Yes | |||
| Tin | Soft Metais Ltda. | BRAZIL | Yes | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | ||||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | ||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes |
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| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Yes | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||
| Tungsten | Kennametal Fallon | UNITED STATES | ||||
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
On the basis of the due diligence measures described above, Wabtec is unable to definitively 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 supplier compliance by requiring answering the RCOI via Wabtec’s Supply Chain Compliance software which will increase the response rate and quality of the suppliers’ supply chain surveys; and aid in determining if further due diligence is required. |
| • | Continue to compare RCOI results to information collected via independent conflict free smelter validation programs such as the CFSI Conflict Free Smelter program. |
| • | When a supplier is found not to be utilizing a CFSI certified smelter or refiner, Wabtec will send a notification requesting the supplier to convert to a certified smelter or refiner. |
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