UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD
Specialized Disclosure Report

Magal Security Systems Ltd.
(Exact name of Registrant as specified in its charter)

Israel
(Jurisdiction of incorporation or organization)

0-21388
(Commission file number)

P.O. Box 70, Industrial Zone, Yehud 5621617, Israel
(Address of principal executive offices)

Yaacov Vinokur, + 972-3-5391444
(Name and telephone number 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, 2019.


Item 1.01. Conflict Minerals Disclosure and Report

Magal Security Systems Ltd. (“Magal”, “the Company”, “we” or “our”) has evaluated its current product lines and determined that certain products that we manufacture or contract to manufacture contain, or may contain, tin, tungsten, tantalum, or gold ("3TG"), which are defined as “Conflict Minerals” by the United States Securities and Exchange Commission, that are necessary for the functionality or production of our products. Accordingly, Magal is filing this disclosure along with a Conflict Minerals Report to disclose the measures we have taken to determine the most reasonable country of origin of the Conflict Minerals used in our products.

Conflict Minerals Disclosure

We undertook due diligence measures regarding our minerals supply chain, including surveying our direct suppliers, attempting to determine the necessary Conflict Minerals used in our products that were manufactured or contracted to manufacture in 2019, which we purchase through our complex network of global suppliers.

We do not possess sufficient information from our suppliers or other sources to determine the country of origin, or likely country of origin of the Conflict Minerals used in our products, or to identify the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources.

A copy of Magal’s Conflict Minerals Report for the reporting period from January 1, 2019 to December 31,2019 is filed as Exhibit 1.01 hereto and is publicly available at our website under the heading “Corporate Governance” at the following link: https://magalsecurity.com/about-magal/corporate-governance. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.

Item 2.01. Exhibits

The following exhibit is filed as part of this report:

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.



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.

Magal Security Systems Ltd.

By:          /s/ Yaacov Vinokur
Yaacov Vinokur
Title:       Chief Financial Officer

May 28, 2020



Exhibit 1.01

Conflict Minerals Report

This is the Conflict Minerals Report for Magal Security Systems Ltd. (“Magal”, “the Company”, “we” or “our”), filed with the SEC pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1, 2019 to December 31, 2019. The Rule was adopted by 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 (Dodd-Frank Act). The Rule imposes certain reporting obligations on Securities and Exchange Commission (theSEC”) registrants whose manufactured or contracted to manufacture products contain, or likely contain, Conflict Minerals that are necessary for the functionality or production of those products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”) for the purposes of this assessment.
 
If a registrant cannot establish with complete certainty that the Conflict Minerals that are necessary for the manufacture or functionality of its products originated or likely originated from sources other than the Democratic Republic of the Congo or the adjoining countries (together referred to as “Covered Countries”), or that they originate from entirely recycled or scrap sources, the registrant must submit a specialized disclosure report under the Form SD that describes the steps that the registrant took to determine the origin or likely country of origin of the Conflict Minerals in its products.

If a registrant has reason to believe that the Conflict Minerals in its supply chain may have originated in Covered Countries, or if the registrant is unable to determine the likely country of origin of those Conflict Minerals, then the registrant must exercise due diligence on the Conflict Minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report (a “CMR”) as an exhibit to its Form SD to the SEC that includes a description of those due diligence measures.

Our goal in designing and implementing our Conflict Minerals risk management strategy is not to eliminate sourcing from Covered Countries, but to encourage participation with the Responsible Minerals Initiative ("RMI") and other relevant independent third-party auditing bodies, where possible.

As permitted by the Rule and the SEC, this report has not been subject to an independent private sector audit.


1.
Company Overview

Magal is a leading international provider of turn-key projects, solutions and products for physical security, as well as site management. Since 1969, we have delivered our products as well as tailor-made security solutions and turnkey projects to customers in over 100 countries under some of the most challenging conditions. We offer comprehensive integrated solutions for critical sites, which leverage our broad portfolio of homegrown PIDS (Perimeter Intrusion Detection Systems), advanced VMS (Video Management Software) with native IVA (Intelligent Video Analytics) security solutions, as well as a proprietary command and control platform.


2.
Supply Chain and Product Overview

Based on our multi-decade industry experience and interaction with customers, we have developed a comprehensive set of solutions and products, optimized for perimeter, outdoor and general security applications. Our broad portfolio of critical infrastructure protection and site protection technologies includes a variety of smart barriers and fences, fence mounted sensors, virtual gates, buried and concealed detection systems and sophisticated sensors for sub-surface intrusion such as to secure pipelines, as well as advanced video analytics software and video management systems. Our turnkey solutions are typically integrated and managed by sophisticated modular command and control software, supported by expert systems for real-time decision support.


Our products often require the use of tin, tantalum and gold, or 3TG, as defined, which fall under the definition of Conflict Minerals, per the Rule.

Our supply chain is global and complex, and there are multiple tiers between our Company and the sources or mines of the Conflict Minerals that are necessary to the functionality or production of our products. Therefore, the Company or its suppliers purchase 3TG-related materials after processing by Smelters or Refiners (“SoRs”).   Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components that are included in our products.


3.
Reasonable Country of Origin Inquiry

In order to conduct a Reasonable Country of Origin Inquiry (“RCOI”) on the source or origin, or the likely country of origin, of Conflict Minerals that are necessary to the functionality or production of our products, we developed a risk-based approach that focuses on suppliers involved in manufacturing the relevant abovementioned products that contain or use the necessary Conflict Minerals. We identified 37 relevant suppliers that we concluded provide us with products and components that contain or may contain 3TG necessary to functionality or production of our products, and which accounted for 90% of all applicable materials purchased by Magal in 2019.

Utilizing the Responsible Minerals Initiative's (“RMI”), formerly the Conflict Free Sourcing Initiative’s, standard Conflict Minerals Reporting Template (“CMRT”) of, at a minimum version 5.10, and the services of a third-party data management provider, we surveyed the relevant suppliers that supply us, or likely supply us, with products or product components that contain, or likely contain the necessary Conflict Minerals. As noted, we do not purchase the necessary Conflict Minerals directly from the facilities that process the 3TG, given our constitution as a downstream company, and therefore we purchase the 3TG from our direct suppliers, who also purchase these minerals from their own upstream suppliers, or the SoRs themselves. Additionally, we sent letters to our relevant suppliers, informing them of the Rule and the Company's Conflict Minerals Policy. We reviewed the responses and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information or did not provide adequate responses per information compared against Third Party Audit bodies’, such as the RMI’s, lists of conformant and active SoRs. We received responses from 89% of the suppliers we approached.

The majority of suppliers from which we requested information indicated in their response that the information provided was at a company level (73%). Based on those responses, the majority of suppliers and manufacturers were unable to accurately report the SoRs that were part of their supply chain and that were applicable to the components or products that were sold to us in 2019.

Based on information obtained in the RCOI, and considering the complexities of our supply chain, we do not have sufficient information from our suppliers to determine the country of origin, or likely country of origin, of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in Covered Countries and are not from recycled or scrap sources.

In accordance with the Rule, Magal undertook due diligence on the source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of its products during 2019. There is significant overlap between the RCOI efforts and the due diligence measures employed.

2


4.
Design of Our Due Diligence

Based on the findings of our RCOI, we designed our mineral supply chain due-diligence process in reference to the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance (2016) for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and its related Supplements for 3TG.
 
Magal has processes in place for the purpose of exercising due diligence on its supply chain. The design of the due diligences processes conforms with the OECD Guidance as it relates to downstream purchasers of products and components. The due diligence processes are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.


5.
Due Diligence Performance

Step 1 - Establish strong company management systems:


-
Our Conflict Minerals Policy is publicly available on our website at the following link: https://magalsecurity.com/about-magal/corporate-governance.

-
We established a team of individuals from various functions (Operations, Legal and Finance) within the organization to support the process of supply chain due diligence. The team meets to assess identified risks and determine follow up actions.

-
Magal maintains a system of controls and transparency over the mineral supply chain through use of the RMI's CMRT reporting template of, at a minimum, version 5.10. Due to the large size and global spread of our supply chain, we have also contracted a service provider to enhance the supplier data collection process and to help minimize sourcing risks.

-
We maintain records relating to our Conflict Minerals program for a period of at least 5 years.

-
We enable employees, suppliers and other stakeholders to report any concerns relating to our Conflict Minerals program through our grievance mechanism. Contact details for concerns or questions are provided in our Conflict Mineral Policy that is publicly available at our website under the heading “Corporate Governance” and at the following link: https://magalsecurity.com/about-magal/corporate-governance.

Step 2 - Identify and assess risk in the supply chain:


-
We mapped and evaluated our family of products. Magal mapped the relevant agents and suppliers, as well as the manufacturers that sell to these agents and suppliers in order to identify relevant suppliers for the supply chain inquiry.

-
We surveyed our suppliers using, at a minimum, version 5.10 of the CMRT (as detailed above in "Reasonable Country of Origin" section). We compared the SoRs identified by our suppliers against the lists of facilities that have received a conformant or active designation by the RMI's Responsible Minerals Assurance Process (“RMAP”) smelter or refiner validation program or other independent third-party audit programs. We contacted suppliers that did not respond or provided inadequate responses.

-
Due to our size, the breadth and complexity of our products and the constant evolution of our supply chain, it is difficult to identify the relevant SoRs in our supply chain. We do not purchase Conflict Minerals directly from mines or the SoRs, and there are many tiers in the supply chain between us and the original source of the Conflict Minerals.  As a result, we rely on our direct suppliers and manufacturers to provide information regarding the origin of any Conflict Minerals. This challenge brings us to engage a service provider to assist in certain aspects of the process.

3

 
Step 3 - Design and implementation of a strategy to respond to identified risks:


-
We reviewed the survey responses, assessed the risks identified and implemented a strategy to respond to those risks.

o
We followed up on inconsistent, incomplete, or inaccurate responses, as well as sent reminders to certain suppliers who did not respond to our requests for information.

o
Relevant senior management was briefed about our due diligence efforts, risk analysis results and mitigation efforts.

o
Our team, led by our CFO, assessed identified risks and determined follow up actions.

o
Some suppliers that source uncertified SoRs or uncertified SoRs from Covered Countries, according to Third Party Audit bodies, such as the RMAP, were contacted and were asked to submit more information about their sourcing practices, including a corrective action plan.


-
Supply chain due diligence is a dynamic process and requires on-going risk monitoring. To ensure the effectiveness of risk management, after implementation of our strategy, we review and address the identified risks.

Step 4 - Carry Out Independent Third-Party Audit of SoRs’ Due Diligence Practices:
 
Magal does not have a direct relationship with 3TG SoRs and is significantly removed from the SoRs that process the Conflict Minerals. As such, we do not perform direct audits of SoRs in our supply chain, but rather rely on due diligence performed by organizations such as the RMI and compare SoR data received with the RMI's Standard Smelter List of SoRs conformant and active in the RMAP program.
 
Step 5 - Report Annually on Supply Chain Due Diligence:

We currently, subject to SEC guidelines, report annually on our supply chain due diligence through Form SD. Our reports on Form SD are publicly available at https://magalsecurity.com/about-magal/corporate-governance.


6.
Results for the 2019 Calendar Year

Based on the results of our due diligence thus far, we believe it is likely that years of engagement and communication of expectations through many tiers of the supply chain will be necessary before information returned to downstream companies, such as ours, may be considered accurate and complete.

In addition, the following factors materially affect the results of our assessment:

 
 
We are dependent on information received from our direct suppliers to conduct our good faith RCOI process;
 
 
We do not have a direct relationship with 3TG SoRs, nor do we perform direct audits of the other entities in our supply chain;
 
 
We have a varied supplier base with differing levels of resources and sophistication, and many of our suppliers are not themselves subject to the Rule;
 
 
The information our suppliers provide us with is often incomplete and requires significant follow-up;
 
 
Most suppliers provided responses at a company or divisional level, and not at a product level specific to the materials and components we use in the subject products;
 
 
Certain suppliers were unable or unwilling to specify the SoRs used for materials and components supplied to us;
 
 
Our ability to influence cooperation from certain suppliers was limited as we were multiple tiers away from the SoRs in the supply chain; and
 
 
The information gathered from our suppliers is not obtained on a continuous, real-time basis.

We conducted a supply-chain survey of 37 of our direct suppliers that we identified may contribute necessary Conflict Minerals to our products. The overall response rate to this survey was 89%.

4

Response analysis:

Out of the total responses received, 33 responses were defined as complete responses and 4 responses were incomplete or inconsistent.

Declaration scope:
 
Based on the responses that we received, most of our suppliers delivered declaration in company level as shown below:

Company level
73%
User-defined
15%
Products list
12%

As such, Magal was unable to identify the country of origin of the Conflict Minerals used in the Company’s products in 2019.
 
Based on the information provided by our suppliers, we believe that the facilities that may have been used to process the Conflict Minerals in our products may include the SoRs listed in Exhibit A below. Based on our due diligence efforts, we do not have sufficient information to determine the countries of origin, or likely countries of origin, of the Conflict Minerals in our products or whether the Conflict Minerals in our products are from entirely recycled or scrap sources. Pursuant to the Rule, this report is not subject to an independent private sector audit.


7.
Conclusion

Due to the breadth and scope of our product categories, the resulting complexity of our supply chain, and the human and financial resources available to us, we acknowledge that the process of successfully tracing all of the Conflict Minerals used in our manufactured or contracted to manufacture products to their country of origin will take additional time and resources. Moving forward, subject to the legal requirements and any changes to the Rule, we will continue to implement commercially reasonable processes to improve the quantity and quality of supplier responses.
 
Failure to obtain reliable information from any level of our supply chain could materially impact our future ability to report on the presence of Conflict Minerals with any degree of certainty. There can be no assurance that our suppliers will continue to cooperate with diligence inquiries and requests for certifications or provide documentation or other evidence that we consider reliable or provided to us within a time frame sufficient to allow us to make our own assessment following appropriate further diligence measures, if any. The information provided in this Conflict Mineral Report speaks only as of its date. Subsequent events, including future guidelines by the SEC, and the inability or unwillingness of participants in our supply chain to provide complete and accurate information requested, may affect our future determinations under the Rule.
 
Cautionary Statement about Forward-Looking Statements

Statements in this Conflict Minerals Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our customers’ requirements to use certain suppliers, our suppliers’ responsiveness and cooperation with our due diligence efforts, our ability to implement improvements in our Conflict Minerals program and our ability to identify and mitigate related risks in our supply chain. It is possible that the COVID-19 shut-down has also impacted the quality and number of supplier responses to our conflict minerals inquiries. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the SEC, including our Annual Report on Form 20-F for the year ended December 31, 2019. We caution that undue reliance should not be placed on these forward-looking statements, which speak only as of the date of this report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.

5


Exhibit A
 
List of identified certified SoRs
 
Metal
Smelter or Refiner (SoR) Name
Smelter or Refiner (SoR) Country
Gold
8853 S.p.A.
ITALY
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
African Gold Refinery
UGANDA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
Aurubis AG
GERMANY
Gold
Bangalore Refinery
INDIA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
Boliden AB
SWEDEN
Gold
C. Hafner GmbH + Co. KG
GERMANY
Gold
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
CGR Metalloys Pvt Ltd.
INDIA
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
Daye Not Certifiedn-Ferrous Metals Mining Ltd.
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA

6



Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Hunan Guiyang yinxing Not Certifiednferrous Smelting Co., Ltd.
CHINA
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Italpreziosi
ITALY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
JSC Ekaterinburg Not Certifiedn-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
L'Orfebre S.A.
ANDORRA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Marsam Metals
BRAZIL
Gold
Materion
UNITED STATES OF AMERICA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
Metalor TechNot Certifiedlogies (Hong Kong) Ltd.
CHINA
Gold
Metalor TechNot Certifiedlogies (Singapore) Pte., Ltd.
SINGAPORE
Gold
Metalor TechNot Certifiedlogies (Suzhou) Ltd.
CHINA
Gold
Metalor TechNot Certifiedlogies S.A.
SWITZERLAND
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
Metalurgica Met-Mex PeNot Certifiedles S.A. De C.V.
MEXICO
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
Morris and Watson
NEW ZEALAND
Gold
Morris and Watson Gold Coast
AUSTRALIA
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
NH Recytech Company
KOREA, REPUBLIC OF

7



Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC "The Gulidov KrasNot Certifiedyarsk Not Certifiedn-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
OJSC Not Certifiedvosibirsk Refinery
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
Gold
Pease & Curren
UNITED STATES OF AMERICA
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Planta Recuperadora de Metales SpA
CHILE
Gold
Prioksky Plant of Not Certifiedn-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX PreciNot Certifiedx S.A.
SWITZERLAND
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
REMONDIS PMR B.V.
NETHERLANDS
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
Safimet S.p.A
ITALY
Gold
SAFINA A.S.
CZECHIA
Gold
Sai Refinery
INDIA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway TechNot Certifiedlogy Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials TechNot Certifiedlogy Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sovereign Metals
INDIA
Gold
State Research Institute Center for Physical Sciences and TechNot Certifiedlogy
LITHUANIA
Gold
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
T.C.A S.p.A
ITALY
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Gold
Tongling Not Certifiednferrous Metals Group Co., Ltd.
CHINA
Gold
Tony Goetz NV
BELGIUM
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
Torecom
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND


8


Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
FIR Metals & Resource Ltd.
CHINA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Not Certifiednferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
NPM Silmet AS
ESTONIA
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM


9

Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
Empressa Nacional de Fundiciones (ENAF)
BOLIVIA
Tin
Estanho de Rondonia S.A.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.”
CHINA
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Not Certifiedn-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Gejiu Yunxin Not Certifiednferrous Electrolysis Co., Ltd.
CHINA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
Guangdong Hanhe Not Certifiedn-Ferrous Metal Co., Ltd.
CHINA
Tin
Guanyang Guida Not Certifiednferrous Metal Smelting Plant
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi New Nanshan TechNot Certifiedlogy Ltd.
CHINA
Tin
Ma'anshan Weitai Tin Co., Ltd.
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 OF AMERICA
Tin
Metallo Spain S.L.U.
SPAIN
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Nghe Tinh Not Certifiedn-Ferrous Metals Joint Stock Company
VIET NAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
OMSA
BOLIVIA
Tin
Pongpipat Company Limited
MYANMAR
Tin
Precious Minerals and Smelting Limited
INDIA
Tin
PT Aries Kencana Sejahtera
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 Prima Tin
INDONESIA
Tin
PT Bangka Serumpun
INDONESIA


10


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 Inti Stania Prima
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Menara Cipta Mulia
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Rajawali Rimba Perkasa
INDONESIA
Tin
PT Rajehan Ariq
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Tambang Timah
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tirus Putra Mandiri
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Smelter Not Certifiedt listed
BELGIUM
Tin
Soft Metais Ltda.
BRAZIL
Tin
Super Ligas
BRAZIL
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Tin
Thaisarco
THAILAND
Tin
Tin TechNot Certifiedlogy & Refining
UNITED STATES OF AMERICA
Tin
Toboca/ Paranapenema
BRAZIL
Tin
Tuyen Quang Not Certifiedn-Ferrous Metals Joint Stock Company
VIET NAM
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Not Certifiedn-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tin
Yunnan Yunfan Not Certifiedn-ferrous Metals Co., Ltd.
CHINA
Tungsten
A.L.M.T. Corp.
JAPAN
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
China Molybdenum Tungsten Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA


11


Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
Hunan Chunchang Not Certifiednferrous Metals Co., Ltd.
CHINA
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Minmetals Gao'an Not Certifiedn-ferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Tonggu Not Certifiedn-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
South-East Not Certifiednferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA

12

 
Exhibit B
 
Countries of Origin of the Conflict Minerals
 
Based on Magal's Conflict Minerals due diligence efforts, the SoRs listed above may process Conflict Minerals in one or more of the following countries of origin:
 
Reported countries of origin
ANDORRA
AUSTRALIA
AUSTRIA
BELGIUM
BOLIVIA
BRAZIL
CANADA
CHILE
CHINA
CZECHIA
ESTONIA
FRANCE
GERMANY
INDIA
INDONESIA
ITALY
JAPAN
KAZAKHSTAN
KOREA, REPUBLIC OF
KYRGYZSTAN
LITHUANIA
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
MALAYSIA
MEXICO
MYANMAR
NETHERLANDS
NEW ZEALAND
PERU
PHILIPPINES
POLAND
RUSSIAN FEDERATION
SAUDI ARABIA
SINGAPORE
SOUTH AFRICA
SPAIN
SUDAN
SWEDEN
SWITZERLAND
TAIWAN, PROVINCE OF CHINA
THAILAND
TURKEY
UGANDA
UNITED ARAB EMIRATES
UNITED STATES OF AMERICA
UZBEKISTAN
VIET NAM
ZAMBIA
ZIMBABWE

13