UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
Syneron Medical Ltd.
(Exact name of registrant as specified in charter)
Israel
(State or other jurisdiction of incorporation or organization)
001-34559
(Commission File Number)
N/A
(IRS Employer Identification No.)
Industrial Zone, Tavor Building P.O.B. 550, Yokneam Illit 20692, Israel
(Address of principal executive offices) (Zip Code)
Hugo Goldman, Chief Financial Officer
Telephone: 972-732-442200
(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:
ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.
Introduction
Syneron Medical Ltd. ("Syneron") designs, develops and markets aesthetic medical products based on various proprietary technologies, including Electro-Optical Synergy technology, which uses the synergy between electrical energy and optical energy to provide aesthetic medical treatments. Syneron products are sold primarily to physicians and other qualified practitioners, and target a variety of non-invasive aesthetic medical procedures. Syneron’s product families include, among others, products for hair removal, wrinkle reduction, rejuvenation of the skin’s appearance through the treatment of superficial benign vascular and pigmented lesions, acne treatment, treatment of leg veins, treatment for the temporary reduction in the appearance of cellulite and thigh circumference, ablation and resurfacing of the skin, laser-assisted lipolysis and topical skin-brightening products. A number of these products contain metals derived from minerals which include tantalum, tin, tungsten, and gold (“Conflict Minerals”) that are necessary to the functionality or production of such products, and it is for this reason that we are filing this Form SD.
Prior to filing this Form SD, Syneron conducted a reasonable country of origin inquiry and supply chain due diligence to determine whether the Conflict Minerals originated in the Democratic Republic of Congo and adjoining countries (“Covered Countries”). Syneron’s products contain hundreds of components that are purchased from suppliers. Syneron does not directly source Conflict Minerals, and is many levels removed from mines, smelters or refiners that produce the metals used in Syneron’s products. The supply chain for Conflict Minerals in the aesthetic medical treatment device industry is complex and lacks an established structure for product manufacturers, such as Syneron, to trace the minerals in its finished products back to their source. The reasonable country of origin inquiry and supply chain due diligence conducted by Syneron are described in more detail in the attached Conflict Minerals Report.
Syneron’s Conflict Minerals Policy is publicly available at www.investors.syneron.com/governance.
Conflict Minerals Disclosure
A copy of the Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at
www.investors.syneron.com/governance
Section 2- Exhibits
Exhibit 1.01 – Conflict Minerals Report for the Year Ended December 31, 2014.
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.
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Syneron Medical Ltd.
(Registrant)
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By:
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/s/ Amit Meridor |
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June 1, 2015 |
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Amit Meridor |
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Chief Executive Officer |
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Exhibit 1.01
Syneron Medical Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2014
This report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the "Rule"). The Rule was adopted by the Securities and Exchange Commission (the "SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold ("Conflict Minerals").
Under the Rule, a registrant whose products contain Conflict Minerals necessary to their functionality or production must perform a reasonable country of origin inquiry ("RCOI") in order to determine whether or not those Conflict Minerals originated from the Democratic Republic of the Congo or an adjoining country (the "Covered Countries"), or from recycled and scrap sources. After completion of an RCOI, an issuer with no reason to believe that the Conflict Minerals originated from the Covered Countries is required to complete a Form SD describing the RCOI.
However, a registrant with reason to believe that the Conflict Minerals in its supply chain may have originated in the Covered Countries is required to (i) complete a Form SD, and (ii) exercise due diligence on the Conflict Minerals’ source and chain of custody that conforms to a nationally or internationally recognized framework (such as the OECD Guidance, defined below), and describe these due diligence measures and the results thereof in a Conflict Minerals Report that is included as an attachment to the Form SD.
The Conflict Minerals Report presented herein has not been audited by an independent auditor.
In accordance with OECD guidance and the Rule, our Form SD, together with our CRM describing the due diligence process and the results thereof, is publicly available on our website at http://investors.syneron.com/governance.
This report has been prepared by Syneron Medical Ltd. (herein referred to as Syneron, the “Company,” “we,” “us,” or “our”) and includes information regarding the Company and its principal subsidiaries (as of December 31, 2014). It does not include information regarding subsidiaries that are of minor significance, as well as those that that are not required to be consolidated.
Syneron designs, develops and markets aesthetic medical products based on various proprietary technologies, including Electro-Optical Synergy technology, which uses the synergy between electrical energy and optical energy to provide aesthetic medical treatments. Syneron products are sold primarily to physicians and other qualified practitioners, and target a variety of non-invasive aesthetic medical procedures, including, among others, hair removal, wrinkle reduction, rejuvenation of the skin’s appearance through the treatment of superficial benign vascular and pigmented lesions, acne treatment, treatment of leg veins, and treatment for the temporary reduction in the appearance of cellulite and thigh circumference, ablation and resurfacing of the skin, laser-assisted lipolysis and topical skin-brightening products.
After determining that a number of our products contain Conflict Minerals that are necessary to their functionality or production, we examined the supply chain for our products and components thereof, first as part of an RCOI and then in greater depth as part of due diligence efforts.
In general, the supply chain for Conflict Minerals in the aesthetic medical treatment device industry is complex and lacks an established structure for product manufacturers, such as Syneron, to trace the minerals in its finished products back to their source. In addition, we do not generally make direct purchases of Conflict Minerals, and are many levels removed from the mines, smelters or refiners that produce the metals used in our products, which contain hundreds of components that are purchased from suppliers and assembled into Company products.
Further, contracts with our suppliers are frequently in force for long periods of time, and we cannot unilaterally impose new contract terms and requirements. In order to address the challenge of performing supply chain diligence under these circumstances, we relied on our direct suppliers to provide information on the origin of the Conflict Minerals contained in the products and components supplied to us, including the sources of Conflict Minerals that are supplied to them from their suppliers.
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3.
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Reasonable Country of Origin Inquiry (RCOI)
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As part of the RCOI, Syneron examined its products to identify the suppliers of all Syneron products or components that are used in Syneron products. We did not believe that it was practicable to conduct a survey of all our direct suppliers, and therefore concluded that a reasonable approach would be to survey suppliers which represented the majority of our product and component-related expenditures in 2014.
To determine which direct suppliers to target, we first compiled a list of all of the Company’s suppliers (including those from the Company's principal subsidiaries but not those from subsidiaries that are of minor significance, or from subsidiaries that are not required to be consolidated). Next we removed from this list those suppliers that were neither product-related nor component-related, or were otherwise exempted by the Rule (for example, suppliers that provide product packaging were removed from the list). We then ranked the suppliers that remained in terms of our 2014 expenditures, and selected the largest 82 suppliers representing in excess of 90% of those expenditures.
Our RCOI process was reasonably designed to trace the origins of Conflict Minerals in our products, and to attempt to determine whether these minerals came from the Covered Countries. The key steps of the RCOI were as follows: to identify and engage relevant suppliers; data collection, management, and quality assurance; and to conduct an assessment to determine whether further due diligence was required.
Identifying and Engaging Relevant Suppliers
Contact information, such as names, telephone numbers and email addresses, for relevant individuals at Syneron’s direct suppliers was assembled to ensure that we engaged with the optimal individual(s) within each supplier organization and to establish effective lines of communication.
Once appropriate points of contact within direct suppliers were identified, Syneron provided each such supplier with background information regarding the SEC's Conflict Minerals regulations, and requested that each supplier complete the Conflict Minerals Reporting Template ("CMRT”), which is published by the Conflict-Free Sourcing Initiative (“CFSI”). Syneron provided instructions on completing the CMRT and emphasized the importance of receiving timely and accurate information. Internally, Syneron defined an escalation process for non-responsive suppliers, which included sending several follow-up email requests, followed by phone call reminders.
Requested Information
We conducted a survey of those suppliers described above using the CMRT. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide minerals as part of a company’s supply chain. The CMRT includes questions regarding whether the components from the supplier include Conflict Minerals necessary to the functionality or production of the product, whether the Conflict Minerals originate in Covered Countries, the identity and locations of the smelters and refiners who supplied the Conflict Minerals, as well as the supplier's Conflict Minerals policy and due diligence efforts. Written instructions and examples on the use of the tool are available at www.conflictfreesourcing.org/conflict-minerals-reporting-template/training/. The CMRT is used by many companies in their due diligence efforts related to Conflict Minerals.
Data Collection, Management and Quality Assurance
As part of the RCOI process, Syneron began the process of collecting data from suppliers as provided in response to the CMRT. In many cases, multiple telephone and/or email contacts were required to further the data collection process.
Assessment Regarding Further Due Diligence
Completed CMRTs were reviewed for reasonableness and for missing or incomplete data. Verifying responses and obtaining additional information frequently required several rounds of follow-up with the supplier and revisions to the CMRT. Reporting tools were used to track the answers provided by suppliers to determine which items were finalized and which remained to be addressed.
The results of the RCOI were inconclusive, and we were unable with reasonable assurance to determine the origin of the Conflict Minerals in our products. As a result, we could not exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries. For this reason, we determined to exercise due diligence on the source and chain of custody of the Conflict Minerals in our products, with our due diligence conforming to a nationally or internationally recognized framework (such as the OECD Guidance), and to submit to the SEC a Conflict Minerals Report describing these due diligence efforts as an exhibit to Form SD for calendar year 2014.
(A) Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework provided 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 Areas ("OECD Guidance") and related OECD supplements for gold, tin, tantalum and tungsten.
(B) Due Diligence Measures Undertaken
Management System
Syneron has established a management system for addressing the issue of Conflict Minerals in our products. That management system includes a Conflict Minerals Policy, which is posted on our website at www.investors.syneron.com/governance. In addition, our management system includes the establishment of a team of Company employees, consisting of senior operations, engineering, and legal personnel. The team is responsible for implementing our overall Conflict Minerals compliance strategy, including oversight of RCOI and due diligence efforts. Senior management is briefed about the team's effort, including results of our due diligence, on a regular basis, and relevant documentation of such efforts is retained by the Company. Suppliers, employees or others may contact the Company regarding the Conflict Minerals Policy by using contact information provided in such policy.
Identify and assess risk in the supply chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. As a result, we chose to focus our efforts on surveying our direct suppliers, who were asked to survey their own suppliers (i.e., our upstream suppliers) in order to receive similar information.
We segmented our suppliers into three levels of risk and we assessed two primary risks in our supply chain relating to our suppliers: (i) not receiving timely and accurate information from a supplier with respect to its sourcing of Conflict Minerals; and (ii) difficulty in replacing a supplier, should we determine that such supplier obtained or appears to have obtained Conflict Minerals from sources that contribute to armed conflict in the Covered Countries.
Strategy to Respond to Supplier Risks
As described in our Conflict Minerals Policy, Syneron expects its suppliers to evaluate the source of any Conflict Minerals contained in products or components they provide to us and to provide us with the results of that evaluation. Numerous efforts are made to obtain this information from our suppliers, including follow-up mails and telephone calls where applicable responses are identified as incomplete, inconsistent or inaccurate. In addition, we compare smelters and refiners identified by our supply chain survey against lists of facilities that have received a third-party “conflict free” designation in order to track those that have not received such a designation. Finally, our senior management is updated on the findings of our supply chain risk assessment.
Supply Chain Due Diligence at Identified Points in the Supply Chain
The CMRT provided to our suppliers requests information on the smelters and refiners used to provide the tantalum, tin, tungsten, and gold in our products. We do not typically have a direct relationship with smelters and refiners of such minerals and are unable to perform or direct audits of these entities within our supply chain. Instead, we compared information regarding refiners and smelters provided by our suppliers in their CMRT with lists of refiners and smelters certified by the CFSI as "conflict free”.
Report Annually on Supply Chain Due Diligence
This Conflict Minerals Report, which constitutes our annual report on our Conflict Minerals due diligence, is available on our website at www.investors.syneron.com/governance and is filed with the SEC.
We received CMRT responses from approximately 61 out of 82 suppliers surveyed (representing approximately 74% of the suppliers surveyed). We reviewed the responses for completion and consistency, and worked directly with the suppliers who responded, as necessary, to provide revised responses with corrected information.
Respondents identified 272 entities listed as smelters or refiners, a list of which is attached hereto as Annex I. Of these, 167 (representing 61% of the total) were identified as "conflict-free" by CFSI.
In addition, a portion of our suppliers provided us with information regarding the countries of origin of the Conflict Minerals, a list of which is attached hereto as Annex II. However, other suppliers indicated that they do not source from Covered Countries, but were unable to identify specific smelters or refiners, or country of origin information. On account of this incomplete information, Syneron is unable at this time to determine and describe in this report a complete list of either the facilities used to process the Conflict Minerals used in its products or the countries of origin of such Conflict Minerals.
Information gathered from our suppliers is not done on a continuous, real-time basis, but rather done as part of an annual survey. For this reason, and because we gathered information from others (i.e., direct suppliers and independent third party audit programs), the Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals.
6. Continuous Improvement Efforts to Mitigate Risk
We will consider taking the following steps to improve the due diligence that we conduct to further mitigate any risk that the Conflict Minerals in our products could benefit armed groups in the Covered Countries:
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Periodically engage with suppliers to attempt to increase the response rate to our inquiries and to improve the content of the supplier responses, including responses that were identified as incomplete, inconsistent or inaccurate.
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b.
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Continue to conduct and report annually on supply chain due diligence for the applicable Conflict Minerals.
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c.
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Request any supplier found to be supplying us with Conflict Minerals from sources that support armed conflict in Covered Countries to establish an alternative source of Conflict Minerals that does not support such conflict.
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d.
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Validate supplier responses regarding smelters and refiners using information collected from reliable industry certification programs.
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e.
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Compare smelters and refiners identified by our supply chain survey against lists of facilities that have received a third-party “conflict free” designation in order to track those that have not received such a designation.
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f.
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Compare smelters/refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation.
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g.
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Report to senior management on the findings of our supply chain risk assessment.
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Caution Concerning Forward-Looking Statements
Any statements contained in this report regarding future expectations, beliefs, goals, plans or prospects constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Further, any statements that are not statements of historical fact (including statements containing the words "believes," "anticipates," "plans," "expects," "may," "will," "would," "intends," "estimates" and similar expressions) should also be considered to be forward-looking statements. The forward-looking statements included herein are based on current expectations and beliefs that involve a number of known and unknown risks and uncertainties. Examples of forward-looking statements in this document include statements relating to our future plans. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. There are a number of factors that could cause events to differ materially from those indicated by the forward-looking statements in this document, including the risks associated with our suppliers not cooperating fully or at all with our efforts. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.
ANNEX I
Smelters or refiners as identified by responding suppliers
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Metal
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Smelter Name
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Smelter Country
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Gold
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Advanced Chemical Company
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UNITED STATES
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Gold
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Aida Chemical Industries Co. Ltd.
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JAPAN
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Gold
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Aktyubinsk Copper Company TOO
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RUSSIAN FEDERATION
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G.
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GERMANY
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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UZBEKISTAN
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Gold
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AngloGold Ashanti Córrego do Sítio Minerção
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BRAZIL
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Gold
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Argor-Heraeus SA
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SWITZERLAND
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Gold
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Asahi Pretec Corporation
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JAPAN
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Gold
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Asaka Riken Co Ltd
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JAPAN
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Gold
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
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TURKEY
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Gold
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Aurubis AG
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GERMANY
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
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PHILIPPINES
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Gold
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Bauer Walser AG
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GERMANY
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Gold
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Boliden AB
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SWEDEN
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Gold
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C. Hafner GmbH + Co. KG
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GERMANY
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Gold
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Caridad
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MEXICO
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Gold
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CCR Refinery – Glencore Canada Corporation
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CANADA
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Gold
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Cendres + Métaux SA
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SWITZERLAND
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Gold
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Chimet S.p.A.
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ITALY
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Gold
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China National Gold Group Corporation
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CHINA
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Gold
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Chugai Mining
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JAPAN
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Gold
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Codelco
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CHILE
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Gold
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Colt Refining
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UNITED STATES
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Gold
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Daejin Indus Co. Ltd
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KOREA, REPUBLIC OF
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Gold
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DaeryongENC
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KOREA, REPUBLIC OF
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Gold
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Daye Non-Ferrous Metals Mining Ltd.
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CHINA
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Gold
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Do Sung Corporation
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KOREA, REPUBLIC OF
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Gold
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Doduco
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GERMANY
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Gold
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Dowa
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JAPAN
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Gold
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Eco-System Recycling Co., Ltd.
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JAPAN
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Gold
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FSE Novosibirsk Refinery
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RUSSIAN FEDERATION
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Gold
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Gansu Seemine Material Hi-Tech Co Ltd
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CHINA
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Gold
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Geib Refining Corporation
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UNITED STATES
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Gold
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Guangdong Jinding Gold Limited
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CHINA
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Gold
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Hangzhou Fuchunjiang Smelting Co., Ltd.
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CHINA
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Gold
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Heimerle + Meule GmbH
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GERMANY
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Gold
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Heraeus Ltd. Hong Kong
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HONG KONG
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Gold
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Heraeus Precious Metals GmbH & Co. KG
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GERMANY
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Gold
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Hunan Chenzhou Mining Group Co., Ltd.
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CHINA
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Gold
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Hwasung CJ Co. Ltd
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KOREA, REPUBLIC OF
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Gold
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Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
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CHINA
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Gold
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Ishifuku Metal Industry Co., Ltd.
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JAPAN
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Gold
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Istanbul Gold Refinery
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TURKEY
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Gold
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Japan Mint
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JAPAN
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Gold
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Jiangxi Copper Company Limited
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CHINA
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Gold
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Johnson Matthey Inc
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UNITED STATES
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Gold
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Johnson Matthey Ltd
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CANADA
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Gold
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JSC Ekaterinburg Non-Ferrous Metal Processing Plant
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RUSSIAN FEDERATION
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Gold
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JSC Uralelectromed
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RUSSIAN FEDERATION
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Gold
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JX Nippon Mining & Metals Co., Ltd.
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JAPAN
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Gold
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Kazzinc Ltd
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KAZAKHSTAN
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Gold
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Kennecott Utah Copper LLC
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UNITED STATES
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Gold
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Kojima Chemicals Co., Ltd
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JAPAN
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Gold
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Korea Metal Co. Ltd
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KOREA, REPUBLIC OF
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Gold
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Kyrgyzaltyn JSC
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KYRGYZSTAN
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Gold
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L' azurde Company For Jewelry
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SAUDI ARABIA
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Gold
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Lingbao Gold Company Limited
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CHINA
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Gold
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Lingbao Jinyuan Tonghui Refinery Co. Ltd.
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CHINA
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Gold
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LS-NIKKO Copper Inc.
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KOREA, REPUBLIC OF
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Gold
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Luoyang Zijin Yinhui Metal Smelt Co Ltd
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CHINA
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Gold
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Materion
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UNITED STATES
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Gold
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Matsuda Sangyo Co., Ltd.
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JAPAN
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Gold
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Metalor Technologies (Hong Kong) Ltd
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HONG KONG
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Gold
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Metalor Technologies (Singapore) Pte. Ltd.
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SINGAPORE
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Gold
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Metalor Technologies (Suzhou) Ltd.
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CHINA
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Gold
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Metalor Technologies SA
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SWITZERLAND
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Gold
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Metalor USA Refining Corporation
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UNITED STATES
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Gold
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Met-Mex Peñoles, S.A.
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MEXICO
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Gold
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Mitsubishi Materials Corporation
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JAPAN
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Gold
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Mitsui Mining and Smelting Co., Ltd.
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JAPAN
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Gold
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Moscow Special Alloys Processing Plant
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RUSSIAN FEDERATION
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Gold
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Nadir Metal Rafineri San. Ve Tic. A.Ş.
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TURKEY
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Gold
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Navoi Mining and Metallurgical Combinat
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UZBEKISTAN
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Gold
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Nihon Material Co. LTD
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JAPAN
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Gold
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Ohio Precious Metals, LLC
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UNITED STATES
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Gold
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Ohura Precious Metal Industry Co., Ltd
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JAPAN
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Gold
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet)
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RUSSIAN FEDERATION
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Gold
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OJSC Kolyma Refinery
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RUSSIAN FEDERATION
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Gold
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PAMP SA
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SWITZERLAND
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Gold
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Penglai Penggang Gold Industry Co Ltd
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CHINA
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Gold
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Prioksky Plant of Non-Ferrous Metals
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RUSSIAN FEDERATION
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Gold
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PT Aneka Tambang (Persero) Tbk
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INDONESIA
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Gold
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PX Précinox SA
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SWITZERLAND
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Gold
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Rand Refinery (Pty) Ltd
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SOUTH AFRICA
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Gold
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Royal Canadian Mint
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CANADA
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Gold
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Sabin Metal Corp.
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UNITED STATES
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Gold
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Samduck Precious Metals
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KOREA, REPUBLIC OF
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Gold
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SAMWON METALS Corp.
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KOREA, REPUBLIC OF
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Gold
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Schone Edelmetaal
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NETHERLANDS
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Gold
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SEMPSA Joyería Platería SA
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SPAIN
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Gold
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Shandong Tarzan Bio-Gold Co Ltd
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CHINA
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Gold
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Shandong Zhaojin Gold & Silver Refinery Co. Ltd
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CHINA
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Gold
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Shandong zhongkuang group co., LTD
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CHINA
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Gold
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Shenzhen Zhonghenglong Real Industry Co.,Ltd.
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CHINA
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Gold
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Sichuan Tianze Precious Metals Co., Ltd
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CHINA
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Gold
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Singway Technology Co., Ltd.
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TAIWAN
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Gold
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So Accurate Group, Inc.
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UNITED STATES
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Gold
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SOE Shyolkovsky Factory of Secondary Precious Metals
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RUSSIAN FEDERATION
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|
Gold
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Solar Applied Materials Technology Corp.
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TAIWAN
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|
Gold
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Sumitomo Metal Mining Co., Ltd.
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JAPAN
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|
Gold
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Super Dragon Technology Co., Ltd.
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TAIWAN
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|
Gold
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Tanaka Kikinzoku Kogyo K.K.
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JAPAN
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|
Gold
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The Great Wall Gold and Silver Refinery of China
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CHINA
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|
Gold
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THE HUTTI GOLD MINES CO.LTD
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INDIA
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|
Gold
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The Refinery of Shandong Gold Mining Co. Ltd
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CHINA
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|
Gold
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Tokuriki Honten Co., Ltd
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JAPAN
|
|
Gold
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Tongling nonferrous Metals Group Co.,Ltd
|
CHINA
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|
Gold
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Torecom
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KOREA, REPUBLIC OF
|
|
Gold
|
Umicore Brasil Ltda
|
BRAZIL
|
|
Gold
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Umicore Precious Metals Thailand
|
THAILAND
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|
Gold
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Umicore SA Business Unit Precious Metals Refining
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BELGIUM
|
|
Gold
|
United Precious Metal Refining, Inc.
|
UNITED STATES
|
|
Gold
|
Valcambi SA
|
SWITZERLAND
|
|
Gold
|
Valcambi SA Corp.
|
SWITZERLAND
|
|
Gold
|
Western Australian Mint trading as The Perth Mint
|
AUSTRALIA
|
|
Gold
|
YAMAMOTO PRECIOUS METAL CO., LTD.
|
JAPAN
|
|
Gold
|
Yantai country Safeina high-tech environmental Refining Ltd.
|
CHINA
|
|
Gold
|
Yokohama Metal Co Ltd
|
JAPAN
|
|
Gold
|
Yoo Chang Metal Inc.
|
KOREA, REPUBLIC OF
|
|
Gold
|
Yunnan Copper Industry Co Ltd
|
CHINA
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
|
CHINA
|
|
Gold
|
Zhuzhou Smelting Group Co., Ltd.
|
CHINA
|
|
Gold
|
Zijin Mining Group Co. Ltd
|
CHINA
|
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd.
|
CHINA
|
|
Tantalum
|
Conghua Tantalum and Niobium Smeltry
|
CHINA
|
|
Tantalum
|
D Block Metals, LLC
|
UNITED STATES
|
|
Tantalum
|
Duoluoshan
|
CHINA
|
|
Tantalum
|
Exotech Inc.
|
UNITED STATES
|
|
Tantalum
|
F&X Electro-Materials Ltd.
|
CHINA
|
|
Tantalum
|
Global Advanced Metals Aizu
|
JAPAN
|
|
Tantalum
|
Global Advanced Metals Boyertown
|
UNITED STATES
|
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd.
|
CHINA
|
|
Tantalum
|
H.C. Starck Co., Ltd.
|
THAILAND
|
|
Tantalum
|
H.C. Starck GmbH Goslar
|
GERMANY
|
|
Tantalum
|
H.C. Starck GmbH Laufenburg
|
GERMANY
|
|
Tantalum
|
H.C. Starck Hermsdorf GmbH
|
GERMANY
|
|
Tantalum
|
H.C. Starck Inc.
|
UNITED STATES
|
|
Tantalum
|
H.C. Starck Ltd.
|
JAPAN
|
|
Tantalum
|
H.C. Starck Smelting GmbH & Co.KG
|
GERMANY
|
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd.
|
CHINA
|
|
Tantalum
|
Hi-Temp
|
UNITED STATES
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd.
|
CHINA
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd.
|
CHINA
|
|
Tantalum
|
KEMET Blue Metals
|
MEXICO
|
|
Tantalum
|
KEMET Blue Powder
|
UNITED STATES
|
|
Tantalum
|
King-Tan Tantalum Industry Ltd
|
CHINA
|
|
Tantalum
|
LSM Brasil S.A.
|
BRAZIL
|
|
Tantalum
|
Metallurgical Products India (Pvt.) Ltd.
|
INDIA
|
|
Tantalum
|
Mineração Taboca S.A.
|
BRAZIL
|
|
Tantalum
|
Mitsui Mining & Smelting
|
JAPAN
|
|
Tantalum
|
Molycorp Silmet A.S.
|
ESTONIA
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd.
|
CHINA
|
|
Tantalum
|
Plansee SE Liezen
|
AUSTRIA
|
|
Tantalum
|
Plansee SE Reutte
|
AUSTRIA
|
|
Tantalum
|
QuantumClean
|
UNITED STATES
|
|
Tantalum
|
RFH Tantalum Smeltry Co., Ltd
|
CHINA
|
|
Tantalum
|
Shanghai Jiangxi Metals Co. Ltd
|
CHINA
|
|
Tantalum
|
Solikamsk Magnesium Works OAO
|
RUSSIAN FEDERATION
|
|
Tantalum
|
Taki Chemicals
|
JAPAN
|
|
Tantalum
|
Telex
|
UNITED STATES
|
|
Tantalum
|
Ulba
|
KAZAKHSTAN
|
|
Tantalum
|
Yichun Jin Yang Rare Metal Co., Ltd
|
CHINA
|
|
Tantalum
|
Zhuzhou Cement Carbide
|
CHINA
|
|
Tin
|
Alpha
|
UNITED STATES
|
|
Tin
|
China Rare Metal Materials Company
|
CHINA
|
|
Tin
|
China Tin Group Co., Ltd.
|
CHINA
|
|
Tin
|
CNMC (Guangxi) PGMA Co. Ltd.
|
CHINA
|
|
Tin
|
Cooper Santa
|
BRAZIL
|
|
Tin
|
CV Gita Pesona
|
INDONESIA
|
|
Tin
|
CV JusTindo
|
INDONESIA
|
|
Tin
|
CV Makmur Jaya
|
INDONESIA
|
|
Tin
|
CV Nurjanah
|
INDONESIA
|
|
Tin
|
CV Serumpun Sebalai
|
INDONESIA
|
|
Tin
|
CV United Smelting
|
INDONESIA
|
|
Tin
|
Dowa
|
JAPAN
|
|
Tin
|
EM Vinto
|
BOLIVIA
|
|
Tin
|
Estanho de Rondônia S.A.
|
BRAZIL
|
|
Tin
|
Feinhütte Halsbrücke GmbH
|
GERMANY
|
|
Tin
|
Fenix Metals
|
POLAND
|
|
Tin
|
Gejiu Kai Meng Industry and Trade LLC
|
CHINA
|
|
Tin
|
Gejiu Non-Ferrous Metal Processing Co. Ltd.
|
CHINA
|
|
Tin
|
Gejiu Zi-Li
|
CHINA
|
|
Tin
|
Huichang Jinshunda Tin Co. Ltd
|
CHINA
|
|
Tin
|
Hunan Xianghualing Tin Co. ltd
|
CHINA
|
|
Tin
|
Jean GOLDSCHMIDT INTERNATIONAL S.A.
|
BELGIUM
|
|
Tin
|
Jiangxi Nanshan
|
CHINA
|
|
Tin
|
Linwu Xianggui Smelter Co
|
CHINA
|
|
Tin
|
Magnu's Minerais Metais e Ligas LTDA
|
BRAZIL
|
|
Tin
|
Malaysia Smelting Corporation (MSC)
|
MALAYSIA
|
|
Tin
|
Melt Metais e Ligas S/A
|
BRAZIL
|
|
Tin
|
Metallic Resources Inc
|
UNITED STATES
|
|
Tin
|
Metallo Chimique
|
BELGIUM
|
|
Tin
|
Mineração Taboca S.A.
|
BRAZIL
|
|
Tin
|
Minmetals Ganzhou Tin Co. Ltd.
|
CHINA
|
|
Tin
|
Minsur
|
PERU
|
|
Tin
|
Mitsubishi Materials Corporation
|
JAPAN
|
|
Tin
|
Nathan Trotter & Co., Inc.
|
UNITED STATES
|
|
Tin
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company
|
VIET NAM
|
|
Tin
|
Novosibirsk Integrated Tin Works
|
RUSSIAN FEDERATION
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
THAILAND
|
|
Tin
|
O.M. Manufacturing Philippines, Inc.
|
PHILIPPINES
|
|
Tin
|
OMSA
|
BOLIVIA
|
|
Tin
|
PT Alam Lestari Kencana
|
INDONESIA
|
|
Tin
|
PT Artha Cipta Langgeng
|
INDONESIA
|
|
Tin
|
PT ATD Makmur Mandiri Jaya
|
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 Tin Industry
|
INDONESIA
|
|
Tin
|
PT Belitung Industri Sejahtera
|
INDONESIA
|
|
Tin
|
PT Bukit Timah
|
INDONESIA
|
|
Tin
|
PT DS Jaya Abadi
|
INDONESIA
|
|
Tin
|
PT Eunindo Usaha Mandiri
|
INDONESIA
|
|
Tin
|
PT Fang Di MulTindo
|
INDONESIA
|
|
Tin
|
PT HP Metals Indonesia
|
INDONESIA
|
|
Tin
|
PT Karimun Mining
|
INDONESIA
|
|
Tin
|
PT Koba Tin
|
INDONESIA
|
|
Tin
|
PT Mitra Stania Prima
|
INDONESIA
|
|
Tin
|
PT Prima Timah Utama
|
INDONESIA
|
|
Tin
|
PT REFINED BANGKA TIN
|
INDONESIA
|
|
Tin
|
PT Sariwiguna Binasentosa
|
INDONESIA
|
|
Tin
|
PT Stanindo Inti Perkasa
|
INDONESIA
|
|
Tin
|
PT Tambang Timah
|
INDONESIA
|
|
Tin
|
PT Timah (Persero), Tbk
|
INDONESIA
|
|
Tin
|
PT Tinindo Inter Nusa
|
INDONESIA
|
|
Tin
|
Rui Da Hung
|
TAIWAN
|
|
Tin
|
Soft Metais, Ltda.
|
BRAZIL
|
|
Tin
|
Thaisarco
|
THAILAND
|
|
Tin
|
UNITED SMELTER
|
INDONESIA
|
|
Tin
|
VQB Mineral and Trading Group JSC
|
VIET NAM
|
|
Tin
|
White Solder Metalurgia e Mineração Ltda.
|
BRAZIL
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd.
|
CHINA
|
|
Tin
|
YunNan GeJiu Jin Ye Mineral Co.,Ltd
|
CHINA
|
|
Tin
|
YunNan Gejiu Yunxin Electrolyze Limited
|
CHINA
|
|
Tin
|
Yunnan Tin Company, Ltd.
|
CHINA
|
|
Tungsten
|
A.L.M.T. Corp.
|
JAPAN
|
|
Tungsten
|
Asia Tungsten Products Vietnam Ltd.
|
VIET NAM
|
|
Tungsten
|
Chengdu Hongbo Industrial co,Ltd
|
CHINA
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd.
|
CHINA
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Dayu Jincheng Tungsten Industry Co., Ltd.
|
CHINA
|
|
Tungsten
|
Dayu Weiliang Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Ganzhou Haichuang W Co., Ltd
|
CHINA
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd.
|
CHINA
|
|
Tungsten
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
|
CHINA
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd.
|
CHINA
|
|
Tungsten
|
Global Tungsten & Powders Corp.
|
UNITED STATES
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
H.C. Starck GmbH
|
GERMANY
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co.KG
|
GERMANY
|
|
Tungsten
|
Hunan Chenzhou Mining Group Co., Ltd.
|
CHINA
|
|
Tungsten
|
Hunan Chuangda Tungsten & Vanadium Co., Ltd.
|
CHINA
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd.
|
CHINA
|
|
Tungsten
|
Japan New Metals Co., Ltd.
|
JAPAN
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
|
CHINA
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
CHINA
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
CHINA
|
|
Tungsten
|
Jiangxi Yaosheng Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Kennametal Fallon
|
UNITED STATES
|
|
Tungsten
|
Kennametal Huntsville
|
UNITED STATES
|
|
Tungsten
|
Luoyang Mudu Tungsten & Molybdenum Technology Co., Ltd.
|
CHINA
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
|
VIET NAM
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
VIET NAM
|
|
Tungsten
|
Vietnam Youngsun Tungsten Industry Co., Ltd
|
VIET NAM
|
|
Tungsten
|
Wolfram Bergbau und Hütten AG
|
AUSTRIA
|
|
Tungsten
|
Wolfram Company CJSC
|
RUSSIAN FEDERATION
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd.
|
CHINA
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd.
|
CHINA
|
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
CHINA
|
ANNEX II
Countries of origin of Conflict Minerals as identified by responding suppliers
Australia
Austria
Belgium
Bolivia
Brazil
Canada
Chile
China
Estonia
Germany
Hong Kong
India
Indonesia
Italy
Japan
Kazakhstan
Korea, Republic of
Kyrgyzstan
Malaysia
Mexico
Netherlands
Peru
Philippines
Poland
Portugal
Russia
Saudi Arabia
Singapore
South Africa
Spain
Sweden
Switzerland
Taiwan
Thailand
Turkey
United States
Uzbekistan
Vietnam
16
Syneron Medical Ltd. - Ordinary Shares (NASDAQ:ELOS)
Gráfica de Acción Histórica
De Jul 2024 a Ago 2024
Syneron Medical Ltd. - Ordinary Shares (NASDAQ:ELOS)
Gráfica de Acción Histórica
De Ago 2023 a Ago 2024
