UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_____________________________________________
FORM SD
Specialized Disclosure Report
_____________________________________________
BLUE BIRD CORPORATION
(Exact name of registrant as specified in its charter)
| | | | | | | | |
Delaware | | 001-36267 |
(State or other jurisdiction of incorporation or organization) | | (Commission File Number) |
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3920 Arkwright Road, 2nd Floor Macon, Georgia 31210 | | 31210 |
(Address of principal executive offices) | | (Zip Code) |
| | | | | | | | |
Ted Scartz | | (478) 822-2801 |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| | | | | |
☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
☐ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2023. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
In accordance with the disclosure requirements promulgated by the U.S. Securities and Exchange Commission, Blue Bird Corporation (the “Company”) has undertaken efforts to determine its conflict minerals1 reporting requirements for the period from January 1 to December 31, 2023.
The Company has filed this Specialized Disclosure Report and the associated Conflict Minerals Report, which appears as Exhibit 1.01 hereto and is publicly available on the Company’s website at http://investors.blue-bird.com/Docs.
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1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
Item 1.02 Exhibit
The Company’s Conflict Minerals Report is provided as Exhibit 1.01 hereto.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.0 Resource Extraction Issuer Disclosure and Report.
Not applicable.
Section 3 – Exhibits
Item 3.01 Exhibits
The following exhibit is filed as part of this report.
*****
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Blue Bird Corporation
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By: | /s/ Ted Scartz | | Date: June 3, 2024 |
| Ted Scartz SVP - General Counsel | | |
CONFLICT MINERALS REPORT OF
BLUE BIRD CORPORATION
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2023
I. Introduction
This is the Conflict Minerals1 Report of Blue Bird Corporation (“we,” “our,” “us,” or the “Company”) prepared for calendar year 2023 (“Reporting Period”) in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and SEC Release No. 34-67716 (August 22, 2012) under the Act (the “Adopting Release”). The reader is referred to these sources for the definitions of defined terms contained herein.
In accordance with Rule 13p-1, we undertook efforts to determine the presence and source of the conflict minerals within our products. The Company designed its efforts in conformity with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
The statements below are based on the activities performed to-date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving identification of smelters, incomplete information from industry or other third-party sources, continuing guidance regarding the U.S. Securities and Exchange Commission (“SEC”) final rules, and other issues.
II. Overview
Company Profile
We are the leading independent designer and manufacturer of school buses, with more than 601,000 buses sold since our formation in 1927.
We are subject to this rule as we have determined that, during 2023, conflict minerals were likely necessary to the functionality or production of products we manufactured or contracted to manufacture. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we conduct no purchasing activities directly in the DRC or adjoining countries.
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1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.
2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264252479-en
Conflict Minerals Policy
The Company developed a policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by the SEC rule and the Company’s expectations from its suppliers. In addition, the policy includes language encouraging suppliers to source responsibly. The policy resides on our corporate website (https://s23.q4cdn.com/152250413/files/doc_governance/Conflict-Minerals-Policy-Statement.pdf) and is included in our supplier code of conduct and terms and conditions. This policy is reviewed and updated periodically as needed.
Reasonable Country of Origin Inquiry Information
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI that indicated sourcing from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
Due Diligence Program Design
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
Step 1: Establish strong Company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
Step 5: Report annually on supply chain due diligence
III. Due Diligence Measures Performed by The Company
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
Step 1: Establish strong Company management systems
a.Conflict minerals team – The Company established a conflict minerals team that includes individuals from the relevant business units and departments, including compliance, finance, procurement, sales, and legal. The team was structured to include the involvement from those in upper management roles, including the Assistant Corporate Controller, to help ensure that critical information, including the Company’s conflict minerals policy, reached relevant employees and suppliers.
b.Conflict minerals policy – The Company adopted and published a policy establishing the expectations of our suppliers. The policy resides on our corporate website (https://s23.q4cdn.com/152250413/files/doc_governance/Conflict-Minerals-Policy-Statement.pdf).
c.Internal engagement – We developed a training program to educate employees on our conflict minerals process, the goals of our program, and our reporting obligations as a supplier and a public filer.
d.Supplier engagement – The Company communicated its conflict minerals policy and provided educational materials to our in-scope suppliers. Suppliers were informed when the request for information was initiated on the conflict minerals disclosure requirements as well as recommendations for developing, implementing, and documenting a conflict minerals compliance program. Stakeholders can communicate directly and confidentially with our compliance officer.
e.Company level grievance mechanism – As recommended by the OECD Due Diligence Guidance, the Company has a grievance mechanism in place as a risk-awareness system for conflict minerals issues. Stakeholders, internal and external, can communicate directly and confidentially with our compliance officer.
f.Records management – The Company has and will maintain records relating to our conflict minerals program in accordance with the recommended record retention guidelines of five years.
Step 2: Identify and assess risks in the supply chain
We performed the following steps as part of our risk assessment process:
a.Identified products in scope – Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release.
b.Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers that provide materials and components for the products deemed in-scope by our conflict minerals team. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.Completed additional follow-up – The Company contacted direct suppliers multiple times to request detailed conflict minerals information. We also worked to clarify and validate the accuracy of information provided by our suppliers by responding with standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we are receiving conflict minerals information specific to our supply chain.
d.Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP completes independent, third-party audits of smelters and refiners to determine which can be validated as having systems in place that help ensure the minerals are responsibly sourced according to the OECD Due Diligence Guidance. The Company also utilized information provided by the London Bullion Market Association (“LBMA”), and Responsible Jewelry Council (“RJC”) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this report within section IV – Product Description; Processing Facilities.
e.Performed smelter due diligence with suppliers - Suppliers that reported smelters deemed to be high risk received additional communication asking them to clarify if those smelters are reflective of the purchases made and to continue due diligence on their supply chains. High risk smelters are those that have not yet undergone a third-party audit or have been deemed non-conformant to the audit standard.
Step 3: Design and implement a strategy to respond to identified risks
We performed the following steps as part of our risk management plan:
a.Reported results to senior management – The conflict minerals team reports the results of our RCOI to upper management at multiple points in time throughout the data collection period. These communications included the team’s plan to respond, as needed, to risks identified in the due diligence processes.
b.Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as any additional documentation furnished to support those responses and the suppliers’ due diligence processes. In the coming year, the resulting risk ratings will be used to develop specific supplier outreach and training to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s conflict minerals policy. These actions will include additional outreach to suppliers that failed to respond to our multiple requests for information, provided inconsistent or erroneous information, or indicated they had received responses from less than 50% of their in-scope suppliers. Our team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.
c.Provided educational materials – The Company provided each supplier with educational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). These materials are provided to suppliers at the time of the initial request for a completed CMRT. The educational material serves as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them. Throughout the process we offer assistance to our suppliers to improve the quality of the information provided to us.
d.Provided conflict minerals policy to all suppliers – After working with a supplier to obtain a CMRT, we provide them with a copy of our conflict minerals policy for their records to ensure our suppliers continue to operate in line with our expectations.
e.Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.
f.Ongoing risk monitoring – suppliers, smelters and refiners that have been identified as high-risk through our risk assessment process are tracked to assess their progress towards meeting our expectations.
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices
The Company is using information provided by independent third party audit programs, including the RMI RMAP, LBMA, and RJC, to confirm the existence and verify the OECD-conformance status of SORs identified during our due diligence.
For smelters that had not been audited as conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations from which the SOR sources to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that had not been audited as conformant to request that these suppliers contact the SORs to encourage participation in the RMAP.
Step 5: Report annually on supply chain due diligence
This Conflict Minerals Report has been filed with the SEC and is available on our website at http://investors.blue-bird.com/Docs.
IV. Product Description; Processing Facilities
Product Description – We review and present our business in two reportable segments (“segments”) - bus and parts.
Bus Segment
Our buses are sold through an extensive network of over 70 U.S. and Canadian dealer locations that, in their territories, are exclusive to our Company on Type C and Type D school buses. We also sell directly to major fleet operators, the U.S. Government, state governments and authorized dealers in certain limited foreign countries.
During our fiscal year ended September 30, 2023 (“fiscal 2023”), we sold 8,514 buses throughout the world. Refer to “Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations” of our fiscal 2023 Annual Report on Form 10-K filed with the SEC on December 11, 2023 for discussion of our unit volumes.
Approximately 99% of our buses sold in fiscal 2023 were sold through distributors and dealers. The Company holds no equity or control position in any of the distributors or dealers.
We design, engineer, manufacture, and sell three types of buses: (i) Type C school buses, (ii) Type D school buses, and (iii) specialty buses. Each of our Type C and Type D buses is manufactured and assembled on its own dedicated purpose-built chassis in Fort Valley, Georgia. Regardless of specifications, all school bus bodies that we manufacture include our signature 14-gauge one-piece steel bows roof system, complemented by a rugged and sturdy floor structure.
Specialty buses include school buses that are converted to suit applications required by the U.S. Government, state and local governments, and various customers for commercial and export markets.
The Blue Bird Micro Bird by Girardin Type A bus is produced through Micro Bird Holdings, Inc., an unconsolidated Canadian joint venture with Girardin Minibus JV Inc. (“Micro Bird”), and is sold through our dealer network. This is a smaller bus than the Type C or Type D bus and is produced on a traditional chassis provided by either Ford or GM or on an electric chassis produced by a Micro Bird subsidiary.
Parts Segment
Parts are key for routine maintenance, replacement of parts that are damaged in service, and replacement of parts that suffer from wear and tear throughout the useful life of the vehicle.
In fiscal 2023, parts sales represented 8.7% of Company net sales.
We maintain a parts distribution center in Delaware, Ohio that fills demand for our Company specific and all-makes parts. Additional demand for parts is fulfilled by drop ship and direct sales. To fulfill demand for parts that are not maintained at the distribution center, we are linked to approximately 40 suppliers that ship directly to dealers and independent service centers.
Our network of dealers and authorized repair centers operate over 200 locations to support the fleet across the U.S. and Canada, the majority of which are owned by independent operators, to complement their primary locations. Field service engineers provide technical support to our dealer network. Service engineers are strategically placed throughout the U.S. and Canada to better serve both dealers and end-customers. The network leverages our parts inventory, technical training, and online warranty network to address customer service needs.
Processing Facilities – Based on our due diligence process and the information received from our suppliers, the following facilities were identified by the Company’s suppliers as the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products manufactured by the Company in the Reporting Period. The information from our suppliers is still evolving and may contain company-level declarations. As such, this smelter list is presented in good faith as the best information we have to date. For 2023 we identified 302 SORs in our supply chain, of which 198 have been audited by the RMI as conformant with the RMAP or equivalent independent third-party audit program. This list may contain smelters that are not in our supply chain and/or there may be other smelters not yet identified in our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC improves.
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Metal | Smelter Name | Country | Smelter ID |
Gold | 8853 S.p.A. | ITALY | CID002763 |
Gold | ABC Refinery Pty Ltd. | AUSTRALIA | CID002920 |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Gold | Agosi AG | GERMANY | CID000035 |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Dowa | JAPAN | CID000401 |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
Gold | Albino Mountinho Lda. | PORTUGAL | CID002760 |
Gold | Alexy Metals | UNITED STATES OF AMERICA | CID003500 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
Gold | Augmont Enterprises Private Limited | INDIA | CID003461 |
Gold | Aurubis AG | GERMANY | CID000113 |
Gold | Bangalore Refinery | INDIA | CID002863 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
Gold | Boliden Ronnskar | SWEDEN | CID000157 |
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Metal | Smelter Name | Country | Smelter ID |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
Gold | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
Gold | Shandong Gold Smelting Co., Ltd. | CHINA | CID001916 |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Coimpa Industrial LTDA | BRAZIL | CID004010 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
Gold | Dongwu Gold Group | CHINA | CID003663 |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | CID003487 |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | CID003488 |
Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | CID003489 |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | CID003490 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Gold | GG Refinery Ltd. | TANZANIA | CID004506 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
Gold | Heraeus Germany GmbH Co. KG | GERMANY | CID000711 |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Italpreziosi | ITALY | CID002765 |
Gold | JALAN & Company | INDIA | CID002893 |
Gold | Japan Mint | JAPAN | CID000823 |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
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Metal | Smelter Name | Country | Smelter ID |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
Gold | K.A. Rasmussen | NORWAY | CID003497 |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
Gold | Kazzinc | KAZAKHSTAN | CID000957 |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
Gold | Kundan Care Products Ltd. | INDIA | CID003463 |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
Gold | LS MnM Inc. | KOREA, REPUBLIC OF | CID001078 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Gold | Marsam Metals | BRAZIL | CID002606 |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Gold | MD Overseas | INDIA | CID003548 |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | CID003557 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
Gold | MKS PAMP SA | SWITZERLAND | CID001352 |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 |
Gold | Morris and Watson | NEW ZEALAND | CID002282 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
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Metal | Smelter Name | Country | Smelter ID |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
Gold | Royal Canadian Mint | CANADA | CID001534 |
Gold | SAAMP | FRANCE | CID002761 |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
Gold | Safimet S.p.A | ITALY | CID002973 |
Gold | SAFINA A.S. | CZECHIA | CID002290 |
Gold | Sai Refinery | INDIA | CID002853 |
Gold | Sam Precious Metals | UNITED ARAB EMIRATES | CID003666 |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | CID002750 |
Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CHINA | CID004435 |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | CID002527 |
Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
Gold | Sovereign Metals | INDIA | CID003383 |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID001810 |
Gold | T.C.A S.p.A | ITALY | CID002580 |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
Tantalum | 5D Production OU | ESTONIA | CID003926 |
Tantalum | AMG Brasil | BRAZIL | CID001076 |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| | | | | | | | | | | |
Metal | Smelter Name | Country | Smelter ID |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 |
Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 |
Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 |
Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 |
Tantalum | TANIOBIS GmbH | GERMANY | CID002545 |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
Tantalum | KEMET de Mexico | MEXICO | CID002539 |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
Tantalum | PowerX Ltd. | RWANDA | CID004054 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | CID003583 |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
Tin | Aurubis Beerse | BELGIUM | CID002773 |
Tin | Aurubis Berango | SPAIN | CID002774 |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | CID002180 |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 |
Tin | CRM Synergies | SPAIN | CID003524 |
Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 |
Tin | Dowa | JAPAN | CID000402 |
Tin | DS Myanmar | MYANMAR | CID003831 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
| | | | | | | | | | | |
Metal | Smelter Name | Country | Smelter ID |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
Tin | Fenix Metals | POLAND | CID000468 |
Tin | Minsur | PERU | CID001182 |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | CID004434 |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | CID004065 |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION | CID001305 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 |
Tin | PT Sukses Inti Makmur (SIM) | INDONESIA | CID002816 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Super Ligas | BRAZIL | CID002756 |
Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN | CID004403 |
Tin | Thaisarco | THAILAND | CID001898 |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
Tungsten | Artek LLC | RUSSIAN FEDERATION | CID003553 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| | | | | | | | | | | |
Metal | Smelter Name | Country | Smelter ID |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 |
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 |
Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF | CID004060 |
Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 |
Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | CID000568 |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | CID003978 |
Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | CID000769 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
Tungsten | Kenee Mining Corporation Vietnam | VIET NAM | CID004619 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID004397 |
Tungsten | LLC Vostok | RUSSIAN FEDERATION | CID003643 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Tungsten | Masan High-Tech Materials | VIET NAM | CID002543 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM | CID004034 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA | CID004430 |
Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | CID003993 |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA | CID003662 |
V. Future Due Diligence
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers, see information as to the ultimate source of these raw materials, and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to help ensure alignment throughout the supply chain.
In addition to the actions noted elsewhere in this report, the Company will undertake the following steps during the next compliance period:
•Review the conflict minerals policy statement and update if necessary.
•Review supplier and employee training materials and update if necessary.
•Continue to collect responses from suppliers using the most recent revision of the CMRT.
•Engage with suppliers that did not provide a response in 2023 or provided incomplete responses to enhance our data collection for 2024.
•Monitor and track performance of risk mitigation efforts including the performance of suppliers deemed high-risk.
•Continue engagement with smelters by sending letters to those that have not been audited as conformant.
•Continue to send messages and encourage our suppliers to engage with smelters that have not been audited as conformant.
•Collect from suppliers product level or user-defined level responses where useful.
•Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI, and through our Company’s own coordinated outreach to smelters.
•Encourage responsible sourcing from the DRC and adjoining countries.
•Stay aware of new and related sourcing challenges that affect smelter RMI audit status.
APPENDIX I – Countries of Origin
The information provided in this Appendix is based on the information collected from the Company’s suppliers.
| | | | | | | | |
Australia | | Mozambique |
Austria | | Myanmar |
Benin | | Nicaragua |
Bolivia (Plurinational State of) | | Niger |
Brazil | | Nigeria |
Burundi | | Papua New Guinea |
Canada | | Peru |
Chile | | Philippines |
China | | Portugal |
Colombia | | Russian Federation |
Congo, Democratic Republic of the | | Rwanda |
Ethiopia | | Sierra Leone |
France | | South Africa |
Ghana | | Spain |
Guinea | | Sweden |
Guyana | | Tanzania |
Indonesia | | Thailand |
Kazakhstan | | Uganda |
South Korea | | United Kingdom of Great Britain and Northern Ireland |
Laos | | United States of America |
Madagascar | | Uzbekistan |
Malaysia | | Vietnam |
Mexico | | Zimbabwe |
Mongolia | | |
Grafico Azioni Blue Bird (NASDAQ:BLBD)
Storico
Da Dic 2024 a Gen 2025
Grafico Azioni Blue Bird (NASDAQ:BLBD)
Storico
Da Gen 2024 a Gen 2025