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SD

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM SD

 

SPECIALIZED DISCLOSURE REPORT

 

 

ACCURAY INCORPORATED

(Exact name of registrant as specified in its charter)

 

Delaware
(State or other jurisdiction of incorporation or organization)

 

001-33301

 

20-8370041

(Commission File Number)

 

(IRS Employer Identification No.)

 

 

1310 Chesapeake Terrace
Sunnyvale, California 94089

(Address of principal executive offices)

(Zip Code)

 

 

Jesse Chew

Senior Vice President, General Counsel and Corporate Secretary

(408) 716-4600

(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, 2021.

 

 

 

 

 

Section 1 — Conflict Minerals Disclosure

 

Item 1.01 Conflict Minerals Disclosure and Report

 

This Form SD of Accuray Incorporated (“Accuray”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2021 to December 31, 2021. A copy of Accuray’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available on Accuray’s website at http://investors.accuray.com/financial-information/sec-filings.

 

Item 1.02 Exhibit

 

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

 

 

Section 2 — Exhibits

 

Item 2.01 Exhibits

 

The following exhibit is filed as part of this Form SD.

 

 

 

Exhibit Number

 

 

1.01

 

Conflict Minerals Report of Accuray Incorporated

 

 

 

1

 

 

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.

 

 

 

 

 

 

 

 

ACCURAY INCORPORATED

 

 

 

Date: May 27, 2022

By:

/s/ Jesse Chew

 

 

Jesse Chew

 

 

Senior Vice President, General Counsel & Corporate Secretary

 

 

 

 

 

 

 

 

 

 

2

EX-1.01

EXHIBIT 1.01

 

CONFLICT MINERALS REPORT OF ACCURAY INCORPORATED

FOR THE REPORTING PERIOD FROM JANUARY 1, 2021 TO DECEMBER 31, 2021

 

Background

 

This Conflict Minerals Report (“Report”) of Accuray Incorporated (“Accuray”) for calendar year 2021 (the “Reporting Period”) has been prepared in accordance with Rule 13p-1 and Form SD under the Securities Exchange Act of 1934, as amended (together, the “Rule”). The Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to Conflict Minerals (as defined below) as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

 

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo (“DRC”) and adjoining countries, which currently include the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

 

If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, or if it is unable to determine the country of origin of those Conflict Minerals, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.

 

Company Overview

 

Accuray is a radiation oncology company that develops, manufactures, sells and supports precise, innovative treatment solutions which set the standard of radiation therapy care with the aim of helping patients live longer, better lives. Our innovative technologies, the CyberKnife and TomoTherapy Systems, including the Radixact System, our next generation TomoTherapy platform, are designed to deliver advanced treatments, including stereotactic radiosurgery (SRS), stereotactic body radiation therapy (SBRT), intensity modulated radiation therapy (IMRT), image guided radiation therapy (IGRT), and adaptive radiation therapy. The CyberKnife Systems and the TomoTherapy Systems, including the Radixact Systems, have clinical applications that are designed to enable customers to deliver the most precise treatments while minimizing side effects and maximizing patient comfort and care. Each of these systems serves patient populations treated by the same medical specialty, radiation oncology, with advanced capabilities. Accuray is headquartered in the United States and also has primary offices in Switzerland, China, Hong Kong and Japan and conducts its business worldwide.

 

Description of the Products Covered by this Report

 

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of such product; (ii) that were manufactured, or contracted to be manufactured, by Accuray; and (iii) for which the manufacture was completed during calendar year 2021. These products, which are referred to in this Report collectively as the “Covered Products,” are the CyberKnife and TomoTherapy Systems, including the Radixact System.

 

Supply Chain Overview

 

All of Accuray’s products are complex and require the integration of a number of components from several sources. Such components are manufactured by Accuray or contract manufacturers or are otherwise purchased by Accuray from third parties. As such, Accuray is many steps removed from the mining of Conflict Minerals; Accuray does not purchase raw or unrefined Conflict Minerals, and does no purchasing in the Covered Countries. Accuray’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals. In this regard, Accuray does not purchase the Conflict Minerals directly from mines, smelters or refiners. As explained further below, Accuray must therefore rely on its suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products.

 

Reasonable Country-of-Origin Inquiry

 

Accuray has conducted a good faith RCOI regarding the Conflict Minerals that were necessary to the functionality or production of the Covered Products (the “Necessary Conflict Minerals”). This RCOI was reasonably designed to determine whether any of the Necessary Conflict Minerals originated in the Covered Countries or came from recycled or scrap sources. The RCOI comprised of the conduct described under the caption “Description of Due Diligence Measures— OECD Step 2 - Identify and Assess Risk in the Supply Chain” below. As a result of the RCOI, Accuray knows or has reason to believe that a portion of its Necessary Conflict Minerals originated or may have originated in the Covered Countries and knows or has reason to believe that those Necessary Conflict Minerals may not be from recycled or scrap sources. In response, Accuray also performed due diligence on the source and chain of custody of the Necessary Conflict Minerals to seek to determine whether the Covered Products were “DRC conflict free” (as defined in the Rule). Suppliers define the scope of their representations to us at their own discretion and, as a result, the information provided to Accuray may be provided at a company level, division level, product category level or at a product level. Therefore, as a downstream procurer of components that may or may not contain Conflict Minerals, Accuray’s RCOI efforts and due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody on Conflict Minerals.

 

Due Diligence Performed

 

Design of Due Diligence

 

Accuray designed its due diligence measures to be in conformity with, in all material respects, the internationally recognized due diligence framework 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: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Framework”), consistent with Accuray’s position as a downstream purchaser. The scope of Accuray’s due diligence remained on Conflict Minerals – namely tin, tantalum, tungsten and gold (together, the “3TG”). Accuray integrated the five-step OECD Framework into its due diligence measures as described below.

 

Description of Due Diligence Measures

 

Accuray’s due diligence measures performed with respect to Covered Products included the following:

 

 

 

1.

OECD Step 1 - Establish Strong Company Management Systems

 

Conflict Minerals policy statement. Accuray has actively engaged with its customers and suppliers for several years with respect to the use of Conflict Minerals. Accuray has also adopted a policy statement regarding Conflict Minerals that outlines its commitment to prevent the use of Conflict Minerals that, directly or indirectly, finance or benefit armed groups in the Covered Countries. This statement is available on Accuray’s website at www.accuray.com/conflict-minerals-policy-statement, and suppliers are expected to follow this policy and provide Accuray with conflict-free parts and products.

 

Conflict Minerals team. Accuray’s Conflict Minerals team, consisting of a cross-functional team of individuals from Accuray’s manufacturing and supply chain teams as well as the legal team, collectively reviewed Accuray’s Conflict Mineral supply chain. The executive team at Accuray had oversight responsibility for the work done by the Conflict Minerals team. The team reported to the executive team as needed. Further, the Conflict Minerals team members have been trained regarding the Rule, Conflict Minerals and properly reviewing and validating supplier responses. In addition, Accuray engaged a third-party service provider, Assent Compliance (“Assent”) to, among other things: assist the Conflict Minerals team with management of supplier engagement; collect, process and store data from supplier responses through its online platform; review and validate supplier responses; assist with evaluating supply chain information regarding Conflict Minerals; identify potential risks; and develop and implement additional due diligence steps with regards to Conflict Minerals. As discussed in more detail below, the Conflict Minerals team worked collaboratively with Assent in connection with its due diligence efforts, including having a biweekly meeting cadence with Assent to review responses from Accuray’s suppliers who supplied components to Accuray containing Conflict Minerals during the 2021 calendar year.

 

System of controls and transparency. Accuray has developed and implemented a Supplier Code of Conduct, which describes the minimum standards of ethical and responsible conduct for Accuray’s suppliers. Suppliers are strongly encouraged to comply with this code of conduct and are expected to meet internationally-accepted principles such as the United Nations Guiding Principles on Business and Human Rights. Accuray also endeavors to require all suppliers to accept the Supplier Code of Conduct through a contractual provision in its supply agreements. Accuray may periodically evaluate a supplier’s compliance with the code to determine whether to continue the business relationship with such supplier. Failure to follow any of the provisions of such code can result in termination of any and all agreements with Accuray. In addition, Accuray used a supplier database maintained by Assent for collecting and retaining supplier responses and other information necessary to support Conflict Minerals inquiry and reporting in an effort to enhance its due diligence processes and improve the accuracy and completeness of supplier data. The Conflict Minerals team regularly reviewed the responses in the database with Assent throughout the due diligence process, including via recurrent meetings.

 

Strengthen engagement with suppliers. Accuray continues to place a strong emphasis on supplier education and training. To help suppliers understand Accuray’s expectations and its due diligence and disclosure obligations under the Rule, and to facilitate supplier responsiveness, Accuray leveraged Assent’s online resources and all in-scope suppliers were provided access to Assent’s library of Conflict Minerals training and support resources. In the event any responses were deemed invalid, Assent provided suppliers with guidance on correcting validation errors, including by providing direct feedback on their submission, directing them to appropriate training courses and having a direct dialogue with suppliers through Assent’s Supplier Experience team. Furthermore, to mitigate against invalid responses, Accuray’s suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly complete the request. Suppliers are provided guidance in their native language, if needed. Accuray believes that the combination of the Supplier Code of Conduct, its Conflict Minerals policy statement, and direct engagement with suppliers for conflict minerals training and requests constitute a strong supplier engagement program.

 

Establish a company grievance mechanism. Accuray maintains a whistleblower hotline that is available to report, confidentially and anonymously, violations of Accuray’s policies or other illegal or unethical behavior, online at www.accuray.ethicspoint.com or by phone at (800) 499-8895. Concerned parties who wish to report information regarding Accuray’s sourcing and use of Conflict Minerals in its products can do so through this existing hotline.

 

 

 

 

2.

OECD Step 2 - Identify and Assess Risk in the Supply Chain

 

To identify risks in Accuray’s supply chain, Accuray relied on suppliers to provide information on the origin of the Conflict Minerals contained in supplier products or components that are included in the Covered Products. Accuray conducted a comprehensive analysis of component suppliers of the Covered Products according to the bill of materials and compiled a list of in-scope suppliers based on the probability of any 3TG in their product. Accuray considered all such suppliers contacted to be “in scope” for purposes of its assessment.

 

Accuray provided the list of all such suppliers to Assent for upload to the Assent Compliance Manager (“ACM”) and requested that each supplier complete the Conflict Minerals Reporting Template (“Template”) developed by Responsible Minerals Initiative (“RMI,” and formerly the Conflict-Free Sourcing Initiative) and return the completed Template to Assent via ACM. Accuray also periodically reviewed the supplier list to ensure that irrelevant or “out of scope” suppliers were removed from the survey process based on the most current information available. ACM is a software-as-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications, and allows suppliers to upload completed Templates directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Framework process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.

 

The Template provided a standardized method for Accuray to use in the collection of representations, statements and data from Accuray’s suppliers related to the presence, use, source and chain of custody of the Conflict Minerals in supplier parts that are incorporated in supplier products or components included in the Covered Products in order to determine whether the Necessary Conflict Minerals in supplier products or components were or were not “DRC conflict free” (as defined in the Rule). The Template requested suppliers to include the country of origin of any Conflict Minerals and the facilities used to process these minerals. Suppliers were asked to confirm whether the particular products they supply to Accuray contained any 3TGs and identify materials down to the smelter and mine. Risks associated with supplier responses are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent staff and members of the Conflict Minerals team.

 

The collection process included an introductory notification from Assent to all in-scope suppliers describing the compliance requirements and requesting completion of the Template. Assent requested that all in-scope suppliers complete the Template and made available training and educational resources to guide suppliers on best practices and the use of the Template. Assent monitored and tracked all communications for future reporting and transparency. All in-scope suppliers that were unresponsive to the initial request were contacted via e-mail or phone call several times over the course of the diligence period to encourage them to submit a valid and complete Template. Assent subjected all submitted Templates to an automated data validation to identify inaccurate submissions and contradictory answers. This data validation is based on questions within the declaration tab of the Template, which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement. All submitted Templates are accepted and classified as valid or invalid and in-scope suppliers that submitted invalid Templates were contacted regarding such Template and encouraged to resubmit a valid Template. The Conflict Minerals team monitored the status of the outreach and supplier responses through information made available via Assent.

 

Assent analyzed the responses provided by the in-scope suppliers, contacted the in-scope suppliers for additional information, and gathered other pertinent data, in order to identify and assess risks. These risk assessments are reviewed with members of the Conflict Minerals team. Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed 3TG mineral processing facilities on their Template declarations. In addition, Assent compared these facilities listed to the list of smelters and refiners consolidated by the RMI to ensure that the facilities meet the recognized definition of a 3TG processing facility that was operational during the 2021 calendar year. Assent also compared the identified smelters and facilities against lists published by the Responsible Minerals Assurance Process (“RMAP,” and formerly the Conflict-Free Smelter Program), developed by the RMI, of smelters and refiners that have been certified as conflict-free (i.e., conformant with RMAP assessment protocols) or that are “active” in the RMAP process (i.e., they have agreed to participate in the RMAP but the audit process has not yet been completed). Smelters that have completed an RMAP audit are considered to be DRC-conflict free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to in-scope suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.

 

Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined by the OECD Framework. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

 

•
Geographic proximity to the DRC and covered countries;
•
Known mineral source country of origin;
•
RMAP audit status;
•
Credible evidence of unethical or conflict sourcing; and
•
Peer assessments conducted by credible third-party sources.

 

Risk mitigation activities were initiated whenever a supplier’s Template reported facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing that supplier to take their own independent risk mitigation actions. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.

 

In addition, in-scope suppliers were evaluated by Assent on the strength of their Conflict Minerals programs based on criteria including:

 

•
Whether the supplier has a policy in place that includes DRC conflict-free sourcing;
•
Whether the supplier has implemented due diligence measures for conflict-free sourcing;
•
Whether the supplier verifies due diligence information received from its suppliers against the Company’s expectations; and
•
Whether the supplier’s verification process includes corrective action management.

 

Suppliers who Assent determines do not meet or exceed these criteria are expected to receive educational material from Assent on how to improve their Conflict Minerals programs.

 

 

 

 

3.

OECD Step 3 - Design and Implement a Strategy to Respond to Risk

 

Together with Assent, Accuray is continuing its development of a process for assessing and responding to risks identified in its supply chain. Accuray currently determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts. Potential outcomes under this risk mitigation strategy include continuing to work with the supplier while risks are addressed, suspending the relationship on a temporary basis while risk mitigation is pursued or discontinuing the relationship with the supplier where risk mitigation efforts have failed. Additional factors are taken into consideration in determining the appropriate risk mitigation strategy for certain suppliers, including supplier size and capabilities, whether alternatives are available and Accuray’s dependence on the supplier.

 

In addition to the above, Assent provides feedback on supplier submissions directly to such suppliers and educational resources are provided to assist such suppliers in corrective action methods or to improve their internal programs. Assent also communicates directly with smelters that have not yet been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.

 

The results of the program and risk assessment are shared with the Conflict Minerals team to ensure transparency within Accuray.

 

 

 

4.

OECD Step 4 - Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices

 

As Accuray has no direct relationship with smelters or refiners in its supply chain, it did not perform or direct audits of these entities within its supply chain. Instead, Accuray relies on data collected and published by RMAP. RMAP performs an independent third-party audit program that evaluates smelter and refiner procurement activities and determines whether the smelter or refiner demonstrated that it has systems and controls in place to ensure that all materials it processed originated from conflict-free sources.

 

Assent also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.

 

 

 

5.

OECD Step 5 - Report on Supply Chain Due Diligence

As required under the Rule, Accuray has filed its Form SD, which contains this Report as an exhibit, with the SEC for the Reporting Period. Accuray expects to report annually, as required by the Rule, and has posted this Report on its website.

 

Due Diligence Outcome

 

As a result of its due diligence measures described above, Accuray received responses from 127 out of 130 (97%) in-scope suppliers that were contacted, with 122 of such suppliers providing a Template. The Conflicts Mineral team continues to follow up with 3 in-scope supplier from whom we have not yet received relevant information. Among the suppliers who responded:

 

•
41 suppliers provided a completed Template incorporating responses from 100% of suppliers in their supply chain, including the names and locations of smelters and refiners that process Conflict Minerals used in components provided by such supplier, with 7 of such suppliers providing Templates that identified materials down to the location of mine.
•
Of those suppliers that provided a Template, 29 indicated that the products supplied to Accuray did not contain any 3TG, 54 indicated that the products supplied to Accuray were “DRC conflict undeterminable,” 27 indicated that the products supplied to Accuray were “non-DRC 3TGs” and 12 indicated that the products supplied to Accuray were “DRC conflict free.”
•
Of those suppliers that provided a Template, 4 provided inconsistent or incomplete information or provided information that suggest issues continue to remain with comprehension of the topic or how to accurately complete the Template.
•
5 suppliers did not provide Templates, but instead provided policy statements or declarations stating that the products supplied to Accuray did not contain any 3TG.

.

•
39 or 80% of tungsten smelters and refiners identified are verified “conflict-free” for tungsten.
•
57 or 71% of tin smelters and refiners identified are verified “conflict-free” for tin.
•
34 or 97% of tantalum smelters and refiners identified are verified “conflict-free” for tantalum.
•
113 or 66% of gold smelters and refiners identified are verified “conflict-free” for gold.

 

Given that not all smelters identified by our suppliers were certified as “conflict free” by an independent third-party audit program, and that a number of supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain or unknown (including because certain suppliers were only able to provide responses at the company-level rather than information specific to Accuray products), Accuray was unable to precisely determine whether or not all supplier parts in its supply chain for the Covered Products contain Necessary Conflict Minerals from the Covered Countries or, in the alternative, utilized Conflict Minerals in their manufacture that either financed or benefited, directly or indirectly, armed groups in the Covered Countries. As such, Accuray’s due diligence in 2021 found that Accuray products containing or utilizing Conflict Minerals are “DRC conflict undeterminable” (as defined in the Rule).

 

The statements above are based on the RCOI process and due diligence performed in good faith by Accuray. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are not limited to, gaps in product or product content information, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers or third-party service providers, errors or omissions by smelters,

gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries' sourced materials being declared secondary materials, companies not continuing in business in 2021 or 2022, certification programs that are not equally advanced for all industry segments and metals, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.

 

Identified Smelters and Refiners

 

As a result of Accuray’s RCOI and due diligence, Accuray has compiled a list on Schedule 1 of the smelter and refiner facilities identified by its suppliers in completed Templates provided by such suppliers. Out of the 122 suppliers that provided smelter lists, 11 provided the smelters at the product level (i.e., they provided information for the particular types of products and components they supplied to Accuray), 103 provided smelters at the company level (i.e., they provided information regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components used in the Covered Products), and 8 were “user defined.” As a result, some of the smelters and refiners reported to Accuray and identified on Schedule 1 may not actually have been used to process the Necessary Conflict Minerals in the Covered Products. In addition, Accuray has taken measures to validate the sources of origin against validated audit programs intended to verify the material types and mine sources of origin for these smelters and refiners.

 

Identified Countries of Origin of Necessary Conflict Minerals

 

Accuray does not have sufficient information to reliably determine the countries of origin of all of the Necessary Conflict Minerals in the Covered Products given that certain suppliers provided inconsistent or incomplete responses or provided information at the company level. However, based on information provided by Accuray’s in-scope suppliers in completed Templates, Accuray believes that the countries of origin may include the countries listed in Schedule 2. As discussed above, because some suppliers provided information at the company level, the countries of origin of the Necessary Conflict Minerals in the Covered Products may not actually include certain of the countries in Schedule 2.

 

Efforts to Determine Mine or Location of Origin

 

Accuray’s efforts to determine the mines or locations of origin of the Necessary Conflict Minerals with the greatest possible specificity included the use of the RCOI and due diligence measures described above.

 

Future Due Diligence and Risk Mitigation

 

Accuray expects to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the Necessary Conflict Minerals in Accuray’s products benefit armed groups in the Covered Countries:

1.
Accuray intends to continue to enhance supplier communication and engagement to improve the effectiveness of the due diligence procedures described above as well as the accuracy and completeness of the data received from such diligence through continued emphasis on the importance of compliance with our conflict minerals reporting expectations and continued use of Assent and its services, including directing suppliers to training resources.
2.
Accuray intends to continue to encourage its suppliers to implement responsible sourcing by using Conflict Minerals only from smelters or refiners that have been certified as conflict-free through the RMAP.
3.
Accuray intends to continue to compare smelters and refiners identified through the due diligence process against lists of facilities that have received a third-party “conflict free” designation and track those that have not received such a designation.
4.
Accuray intends to continue to enforce including contractual provisions in supplier contracts regarding compliance with its Supplier Code of Conduct, as well as work to to include such a provision in the terms and conditions of each purchase order issued.
5.
Accuray intends to increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.
6.
Accuray intends to continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of such efforts through its publicly filed reports with the SEC.

 

Inherent Limitations on Due Diligence Measures

 

Accuray’s supply chain with respect to the Covered Products is complex, and its procurement and manufacturing process is significantly removed from the sourcing, mining, smelting and refining of Conflict Minerals. As a result, Accuray does not have direct contractual relationships with smelters, refiners or mines, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of Conflict Minerals. Moreover, Accuray believes that the smelters and refiners of the Conflict Minerals are best situated to identify the sources of Conflict Minerals and, therefore, has taken steps to identify the applicable smelters and refiners of Necessary Conflict Minerals in Accuray’s supply chain by using the Template. However, tracing these minerals to their sources is a challenge that requires Accuray to rely on its direct suppliers in its efforts to achieve supply chain transparency, including obtaining information regarding the origin of the Necessary Conflict Minerals. The information provided by suppliers may be inaccurate or incomplete or subject to other irregularities. In addition, because of the Accuray’s relative location within the supply chain in relation to the actual extraction and transport of Conflict Minerals, its ability to verify the accuracy of information reported by suppliers is limited.

 

Cautionary Note on Forward-looking Statements

 

This Report includes forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended. All statements other than statements of historical facts contained in this Report, including without limitation, statements regarding the Company’s intentions and expectations regarding further supplier engagement, due diligence and risk mitigation efforts and strategy, are forward-looking statements. In some cases, you can identify forward-looking statements by terminology such as “believe,” “will,” “may,” “seek,” “estimate,” “continue,” “anticipate,” “evaluate,” “intend,” “should,” “plan,” “expect,” “predict,” “could,” “potentially” and similar expressions that convey uncertainty of future events or outcomes. These forward looking statements are subject to risks and uncertainties that could cause actual results and events to differ materially and adversely from those anticipated or implied which include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and Accuray’s ability to verify the accuracy or completeness of any supply chain information provided by suppliers or others, and the other risks identified above under the caption “Due Diligence Outcome.” Accuray undertakes no obligation to revise or publicly release the results of any revision to these forward-looking statements, except as required by law. Subsequent events may affect Accuray’s future determinations under the Rule. Accuray’s due diligence and reporting obligations under the Rule may change in the future and its ability to implement certain processes or obtain information from its suppliers may differ materially from those anticipated or implied in this Report. Given these risks and uncertainties, readers are cautioned not to place undue reliance on such forward-looking statements.

 

Schedule 1

 

Smelter and Refiner Information

 

Based on the information that was provided by Accuray’s suppliers in completed Templates, Accuray believes that, to the extent reasonably determinable by Accuray, the facilities that may have been used to process the Necessary Conflict Minerals contained in the Covered Products included the smelters and refiners identified below. However, as noted above, where Accuray’s suppliers provided information on a division- or company-wide basis regarding all Conflict Minerals used in every component and product they manufacture rather than responses specific to the types of products and components supplied to Accuray for use in the Covered Products, the smelters and refiners reported to Accuray by those suppliers may not actually have been used to process the Necessary Conflict Minerals in the Covered Products.

 

Metal

Standard Smelter Name

Smelter Location

 Smelter ID

 RMI Audit Status (*)

Tungsten

A.L.M.T. Corp.

JAPAN

CID000004

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Conformant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

CID000058

Conformant

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Conformant

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Conformant

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Conformant

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

CID000105

Conformant

Gold

Aurubis AG

GERMANY

CID000113

Conformant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Conformant

Gold

Boliden AB

SWEDEN

CID000157

Conformant

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Conformant

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Conformant

Gold

Cendres + Metaux S.A.

SWITZERLAND

CID000189

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Conformant

Gold

Chimet S.p.A.

ITALY

CID000233

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Conformant

Gold

Chugai Mining

JAPAN

CID000264

Conformant

Tin

Alpha

UNITED STATES OF AMERICA

CID000292

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

Not Enrolled

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Conformant

Gold

Dowa

JAPAN

CID000401

Conformant

Tin

Dowa

JAPAN

CID000402

Conformant

 

Gold

Eco-System Recycling Co., Ltd. East Plant

JAPAN

CID000425

Conformant

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

CID000438

Conformant

Tin

Estanho de Rondonia S.A.

BRAZIL

CID000448

Conformant

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Conformant

Tin

Fenix Metals

POLAND

CID000468

Conformant

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Non Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Conformant

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

CID000568

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

Conformant

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Conformant

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

CID000801

Conformant

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Conformant

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Conformant

Gold

Japan Mint

JAPAN

CID000823

Conformant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Conformant

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Conformant

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

CID000920

Conformant

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Conformant

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Non Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Non Conformant

Gold

Kazzinc

KAZAKHSTAN

CID000957

Conformant

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

CID000966

Conformant

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

CID000969

Conformant

 

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Conformant

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Conformant

Tantalum

LSM Brasil S.A.

BRAZIL

CID001076

Conformant

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Conformant

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Conformant

Gold

Materion

UNITED STATES OF AMERICA

CID001113

Conformant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Conformant

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

CID001142

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Conformant

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Conformant

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

CID001157

Conformant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

CID001161

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Conformant

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Conformant

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Conformant

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Conformant

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Conformant

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Conformant

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Non Conformant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

CID001220

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Conformant

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Conformant

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Conformant

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

CID001314

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Conformant

 

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

CID001326

Non Conformant

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

CID001337

Conformant

Gold

PAMP S.A.

SWITZERLAND

CID001352

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

Non Conformant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Conformant

Tin

PT Artha Cipta Langgeng

INDONESIA

CID001399

Conformant

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Conformant

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Conformant

Tin

PT Timah Tbk Kundur

INDONESIA

CID001477

Conformant

Gold

PX Precinox S.A.

SWITZERLAND

CID001498

Conformant

Tantalum

QuantumClean

UNITED STATES OF AMERICA

CID001508

Conformant

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Conformant

Tantalum

Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

CID001522

Conformant

Gold

Royal Canadian Mint

CANADA

CID001534

Conformant

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

CID001539

Conformant

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Conformant

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

CID001585

Conformant

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001756

Non Conformant

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Conformant

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

CID001761

Conformant

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Conformant

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Conformant

Tantalum

Taki Chemical Co., Ltd.

JAPAN

CID001869

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Conformant

Tantalum

Telex Metals

UNITED STATES OF AMERICA

CID001891

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Conformant

 

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Not Enrolled

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

CID001916

Conformant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Conformant

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Conformant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Conformant

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

CID001993

Conformant

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Conformant

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

CID002030

Conformant

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

CID002036

Conformant

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

CID002044

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Conformant

Gold

Yamakin Co., Ltd.

JAPAN

CID002100

Conformant

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Conformant

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Conformant

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Conformant

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

CID002318

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

CID002320

Conformant

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Conformant

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

CID002459

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Conformant

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Not Enrolled

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Conformant

 

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Conformant

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Conformant

Tantalum

KEMET Blue Metals

MEXICO

CID002539

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002542

Conformant

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIET NAM

CID002543

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

Conformant

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

CID002548

Conformant

Tantalum

H.C. Starck Ltd.

JAPAN

CID002549

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

CID002551

Conformant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

CID002557

Conformant

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Conformant

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

CID002589

Conformant

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Conformant

Tin

Resind Industria e Comercio Ltda.

BRAZIL

CID002706

Conformant

Tin

Metallo Belgium N.V.

BELGIUM

CID002773

Conformant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Conformant

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

CID000015

Conformant

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

Not Enrolled

Gold

Caridad

MEXICO

CID000180

Not Enrolled

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID000197

Not Enrolled

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Conformant

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Conformant

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

CID000281

Not Enrolled

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID000309

Active

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID000522

Not Enrolled

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Conformant

 

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

CID000651

Not Enrolled

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

Not Enrolled

Gold

LT Metal Ltd.

KOREA, REPUBLIC OF

CID000689

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

Not Enrolled

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

CID000773

Not Enrolled

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

CID000778

Not Enrolled

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

Not Enrolled

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

Not Enrolled

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Non Conformant

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

Not Enrolled

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001056

Not Enrolled

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

Not Enrolled

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Not Enrolled

Tin

Minsur

PERU

CID001182

Conformant

Tin

Novosibirsk Processing Plant Ltd.

RUSSIAN FEDERATION

CID001305

Conformant

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Not Enrolled

Tin

PT Babel Inti Perkasa

INDONESIA

CID001402

Conformant

Tin

PT Babel Surya Alam Lestari

INDONESIA

CID001406

Conformant

Tin

PT Bukit Timah

INDONESIA

CID001428

Conformant

Tin

PT Prima Timah Utama

INDONESIA

CID001458

Conformant

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID001468

Conformant

Tin

PT Timah Tbk Mentok

INDONESIA

CID001482

Conformant

Tin

PT Tinindo Inter Nusa

INDONESIA

CID001490

Conformant

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

CID001546

Not Enrolled

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

CID001562

Not Enrolled

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001619

Not Enrolled

Gold

Super Dragon Technology Co., Ltd.

CHINA

CID001810

Not Enrolled

Tin

Thaisarco

THAILAND

CID001898

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID001947

Not Enrolled

 

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Conformant

Tin

VQB Mineral and Trading Group JSC

VIET NAM

CID002015

Not Enrolled

Tin

Yunnan Tin Company Limited

CHINA

CID002180

Conformant

Gold

Morris and Watson

NEW ZEALAND

CID002282

Not Enrolled

Gold

SAFINA A.S.

CZECHIA

CID002290

Conformant

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Not Enrolled

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

CID002313

Not Enrolled

Tin

CV Venus Inti Perkasa

INDONESIA

CID002455

Active

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Conformant

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Conformant

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

CID002504

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Conformant

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

Not Enrolled

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID002516

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Conformant

Gold

Shandong Humon Smelting Co., Ltd.

CHINA

CID002525

Not Enrolled

Gold

Shenzhen Zhonghenglong Real Industry Co., Ltd.

CHINA

CID002527

Not Enrolled

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Conformant

Tantalum

H.C. Starck Co., Ltd.

THAILAND

CID002544

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

Conformant

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

CID002560

Conformant

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Conformant

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

CID002562

Not Enrolled

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

Not Enrolled

Gold

Sudan Gold Refinery

SUDAN

CID002567

Not Enrolled

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

CID002572

Non Conformant

 

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002573

Not Enrolled

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002574

Not Enrolled

Gold

T.C.A S.p.A

ITALY

CID002580

Conformant

Gold

REMONDIS PMR B.V.

NETHERLANDS

CID002582

Conformant

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

CID002584

Not Enrolled

Gold

Industrial Refining Company

BELGIUM

CID002587

Non Conformant

Gold

Shirpur Gold Refinery Ltd.

INDIA

CID002588

Not Enrolled

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Conformant

Gold

Marsam Metals

BRAZIL

CID002606

Conformant

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Conformant

Tungsten

China Molybdenum Co., Ltd.

CHINA

CID002641

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Conformant

Tin

PT Cipta Persada Mulia

INDONESIA

CID002696

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID002703

Not Enrolled

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Conformant

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

CID002708

Non Conformant

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Conformant

Tin

Super Ligas

BRAZIL

CID002756

Active

Gold

SAAMP

FRANCE

CID002761

Conformant

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Conformant

Gold

8853 S.p.A.

ITALY

CID002763

Conformant

Gold

Italpreziosi

ITALY

CID002765

Conformant

Tin

Metallo Spain S.L.U.

SPAIN

CID002774

Conformant

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Conformant

Tin

PT Sukses Inti Makmur

INDONESIA

CID002816

Active

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

CID002830

Conformant

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Conformant

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

CID002834

Conformant

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Conformant

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

CID002845

Conformant

 

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Non Conformant

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Active

Gold

Sai Refinery

INDIA

CID002853

Not Enrolled

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Non Conformant

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Non Conformant

Gold

Bangalore Refinery

INDIA

CID002863

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

Not Enrolled

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

Not Enrolled

Gold

Pease & Curren

UNITED STATES OF AMERICA

CID002872

Not Enrolled

Gold

JALAN & Company

INDIA

CID002893

Not Enrolled

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

CID002918

Conformant

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Conformant

Gold

Safimet S.p.A

ITALY

CID002973

Conformant

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

CID003116

Conformant

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID003153

Not Enrolled

Gold

African Gold Refinery

UGANDA

CID003185

Not Enrolled

Gold

Gold Coast Refinery

GHANA

CID003186

Not Enrolled

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Conformant

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Conformant

Tin

Pongpipat Company Limited

MYANMAR

CID003208

Not Enrolled

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

CID003324

Not Enrolled

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Conformant

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

CID003348

Not Enrolled

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

CID003356

Non Conformant

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

CID003379

Conformant

Tin

PT Rajawali Rimba Perkasa

INDONESIA

CID003381

Conformant

Gold

CGR Metalloys Pvt Ltd.

INDIA

CID003382

Not Enrolled

Gold

Sovereign Metals

INDIA

CID003383

Not Enrolled

Tin

Luna Smelter, Ltd.

RWANDA

CID003387

Conformant

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

CID003388

Conformant

 

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

CID003397

Non Conformant

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

CID003401

Conformant

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

CID003407

Conformant

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

CID003408

Conformant

Tin

Precious Minerals and Smelting Limited

INDIA

CID003409

Non Conformant

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

CHINA

CID003410

Not Enrolled

Tungsten

NPP Tyazhmetprom LLC

RUSSIAN FEDERATION

CID003416

Active

Tungsten

GEM Co., Ltd.

CHINA

CID003417

Conformant

Gold

C.I Metales Procesados Industriales SAS

COLOMBIA

CID003421

Active

Gold

Eco-System Recycling Co., Ltd. North Plant

JAPAN

CID003424

Conformant

Gold

Eco-System Recycling Co., Ltd. West Plant

JAPAN

CID003425

Conformant

Tungsten

Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.

BRAZIL

CID003427

Active

Tin

PT Mitra Sukses Globalindo

INDONESIA

CID003449

Active

Gold

Augmont Enterprises Private Limited

INDIA

CID003461

Active

Gold

Kundan Care Products Ltd.

INDIA

CID003463

Not Enrolled

Tungsten

Cronimet Brasil Ltda

BRAZIL

CID003468

Conformant

Tin

CRM Synergies

SPAIN

CID003524

Conformant

Tin

PT Belitung Industri Sejahtera

INDONESIA

CID001421

Not Enrolled

Tin

PT Panca Mega Persada

INDONESIA

CID001457

Not Enrolled

Tin

PT Sariwiguna Binasentosa

INDONESIA

CID001463

Conformant

Tin

PT Timah Nusantara

INDONESIA

CID001486

Active

Tin

PT Tommy Utama

INDONESIA

CID001493

Not Enrolled

Tin

PT Tirus Putra Mandiri

INDONESIA

CID002478

Not Enrolled

Tin

CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda

BRAZIL

CID003486

Active

Gold

Emerald Jewel Industry India Limited (Unit 1)

INDIA

CID003487

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 2)

INDIA

CID003488

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 3)

INDIA

CID003489

Not Enrolled

Gold

Emerald Jewel Industry India Limited (Unit 4)

INDIA

CID003490

Not Enrolled

Gold

K.A. Rasmussen

NORWAY

CID003497

Not Enrolled

Gold

Alexy Metals

UNITED STATES OF AMERICA

CID003500

Active

 

Gold

Sancus ZFS (L’Orfebre, SA)

COLOMBIA

CID003529

Active

Gold

Sellem Industries Ltd.

MAURITANIA

CID003540

Not Enrolled

Gold

MD Overseas

INDIA

CID003548

Not Enrolled

Tungsten

Artek LLC

RUSSIAN FEDERATION

CID003553

Not Enrolled

Gold

Metallix Refining Inc.

UNITED STATES OF AMERICA

CID003557

Not Enrolled

Tantalum

Yancheng Jinye New Material Technology Co., Ltd.

CHINA

CID003583

Conformant

Gold

Metal Concentrators SA (Pty) Ltd.

SOUTH AFRICA

CID003575

Conformant

Tin

Fabrica Auricchio Industria e Comercio Ltda.

BRAZIL

CID003582

Conformant

Gold

WEEEREFINING

FRANCE

CID003615

Active

Gold

Value Trading

BELGIUM

CID003617

Not Enrolled

Tin

PT Masbro Alam Stania

INDONESIA

CID003380

Active

Tungsten

Fujian Xinlu Tungsten

CHINA

CID003609

Conformant

Tungsten

OOO “Technolom” 2

RUSSIAN FEDERATION

CID003612

Active

Tungsten

OOO “Technolom” 1

RUSSIAN FEDERATION

CID003614

Active

 

 

* “Conformant” means the smelter or refiner is conformant with RMAP assessment protocols as reported by the RMI. “Active” means the smelter or refiner is active in the RMAP process (i.e., it has agreed to participate in the RMAP but the audit process has not yet been completed). “Non-Conformant” means the smelter or refiner is a known metal processor based on information available from the RMI but has not been certified as conflict-free through the RMAP and is not active in the RMAP process. “Not Enrolled” means that the smelter or refiner is not currently enrolled in a third party conflict-free sourcing audit program.

 

Schedule 2

 

Country of Origin of Conflict Minerals Information

 

Accuray does not have sufficient information to reliably determine the countries of origin of all of the Necessary Conflict Minerals in the Covered Products because certain suppliers provided inconsistent or incomplete responses. Furthermore, the country of origin information Accuray received from suppliers may be broader than the countries of origin information actually attributed to the Necessary Conflict Minerals in Covered Products because some suppliers provided information at the company level. As such, based on the limitations described above and information provided by the Company’s in-scope suppliers in completed Templates, the Company believes that the countries of origin may include the following countries:

 

 

Afghanistan

Åland Islands

Albania

American Samoa

Andorra

Angola

Argentina

Armenia

Australia

Austria

Belarus

Belgium

Bermuda

Bolivia (Plurinational State of)

Brazil

Bulgaria

Burundi

Cambodia

Canada

Central African Republic

Chile

China

Colombia

Congo

Democratic Republic of Congo

Djibouti

Dominica

Dominican Republic

Ecuador

Egypt

Eritrea

Estonia

Ethiopia

Finland

France

Germany

Ghana

Guinea

Guyana

Hong Kong

Hungary

India

Indonesia

Ireland

Israel

Italy

Japan

Kazakhstan

Kenya

Korea

Kyrgyzstan

Liberia

Lithuania

Luxembourg

Madagascar

Malaysia

Mali

Mauritania

Mexico

Mongolia

Morocco

Mozambique

Myanmar

Namibia

Netherlands

New Zealand

Niger

Nigeria

Panama

Papua New Guinea

Peru

Philippines

Poland

Portugal

Russian Federation

Rwanda

Saudi Arabia

Sierra Leone

Singapore

Slovakia

Slovenia

South Africa

South Sudan

Spain

Sudan

Suriname

Sweden

Switzerland

Taiwan

Tajikistan

Tanzania

Thailand

Turkey

Uganda

United Arab Emirates

United Kingdom

United States

Uzbekistan

Vietnam

Zambia

Zimbabwe