EX-1.01 2 d391073dex101.htm EX-1.01

EX-1.01

Exhibit 1.01

Conflict Minerals Report of Nordson Corporation

For The Year Ended December 31, 2016

I. Introduction

Nordson Corporation (“our,” “we” or “us”) engineers, manufactures and markets differentiated products and systems used for dispensing and processing adhesives, coatings, polymers, sealants and biomaterials, and for managing fluids, testing and inspecting for quality, treating surfaces and curing. These products are supported with extensive application expertise and direct global sales and service. We serve a wide variety of consumer non-durable, consumer durable and technology end markets including packaging, nonwovens, electronics, medical, appliances, energy, transportation, building and construction, and general product assembly and finishing.

Headquartered in Westlake, Ohio, our products are marketed through a network of direct operations in more than 30 countries. Our principal manufacturing facilities are located in the United States, the People’s Republic of China, Germany, Mexico, the Netherlands, Thailand and the United Kingdom.

Pursuant to the Securities and Exchange Commission’s conflict minerals rule adopted pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”) and to the guidance provided by the Securities and Exchange Commission in its Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued on April 29, 2014, this Report was not subject to an independent private sector audit.

II. Reasonable Country of Origin Inquiry

Organisation for Economic Co-operation and Development (OECD) Step 1 – Establish strong management systems

Internal Management.

We have established a Conflict Minerals Reporting Oversight Committee. The team members include representatives from our Supply Chain Management, one of whom is our designated member of senior management, Legal, Product Compliance, Finance and Internal Audit departments. The team meets monthly. Periodic reports are made to the audit committee of the board of directors with respect to our due diligence process and compliance obligations.

We have been an active member of the Conflict-Free Sourcing Initiative (CFSI) since 2015. Through the CFSI, we participate in the Due Diligence Practices Team, which meets bi-weekly, the Smelter Engagement Team, which meets bi-weekly, and the CFSI Plenary Call, which meets monthly. In addition to our CFSI membership, we host a monthly call with representatives from select peer group companies to benchmark compliance efforts and best practices.

External Communications and Supply Chain Engagement.

Our customers can access our conflict minerals statement on our public website, www.nordson.com. Our conflict minerals statement informs customers of where we are in our Rule compliance efforts. Customer inquiries are handled on a case by case basis, utilizing the conflict minerals statement or customized responses using the conflict mineral reporting template (CMRT) developed by the CFSI, as appropriate.

Since we are an industrial equipment supplier, many of our products are not incorporated into our customers’ products and, therefore, do not fall within the scope of the Rule as applied to our customers.

In addition to our conflict minerals statement, our Conflict Minerals Policy, adopted on May 6, 2014, is available on our website, www.nordson.com. In conjunction with the adoption of the Conflict Minerals Policy, we revised our Supplier Code of Ethics, which outlines the ethical standards with which we expect our suppliers to comply, to reflect our expectations that our suppliers procure materials from sources that do not directly or indirectly support non-state armed groups. The Conflict Minerals Policy and Supplier Code of Ethics have been distributed to our suppliers.

Reasonable Country of Origin Survey Process.

We evaluated our products and determined that certain products manufactured during calendar year 2016 were manufactured with materials or components that contain, or likely contain, conflict minerals, i.e. tin, tantalum, tungsten and gold, that are necessary to the functionality or production of those products. The areas of conflict mineral usage within our supply chain were identified based on the results of previous surveys. Future surveys will focus efforts on these areas.

We identified suppliers that we believed provided materials or components containing conflict minerals. Given the size and complexity of our supply chain, we focused on our largest suppliers, ranked by the amount that we paid to each supplier.    

We surveyed our suppliers utilizing the CMRT and our supplier portal, Nordson’s Supply Chain Central (SCC). The SCC software was used by all product lines to automate surveying our suppliers, and to collect and analyze the survey data. Suppliers were provided training materials on the SCC website regarding conflict minerals and the CMRT.

As part of our grievance mechanism, we rely on CFSI to provide us with information regarding grievances shared among group members, and we encourage our suppliers to send inquiries or other information concerning conflict minerals to productcompliance@nordson.com.

For the period covered by this Report, we prioritized collection of responses from suppliers representing approximately 92% of our total direct material spend. For this group of suppliers, we had about an 82% response rate, which represents approximately 63% of our total supplier spend. Based on the information obtained pursuant to the reasonable country of inquiry process described above, we do not have sufficient information to determine the country of origin of all of the conflict minerals in our supply chain. We continue to work to improve our reasonable country of origin process as described in more detail below.

OECD Step 2 – Identify and assess risk in the supply chain

An escalation process was initiated with those surveyed suppliers who continued to be nonresponsive after the above contacts were made, or whose initial (or subsequent) response was not complete or otherwise warranted clarification or confirmation. We evaluated responses from the surveyed suppliers for plausibility, consistency, and gaps both in terms of which materials or components were stated to contain or not contain conflict minerals and the origin of such conflict minerals. We engaged certain surveyed suppliers, holding discussions and reviewing the results of their internal due diligence efforts, to ensure that our inquiries regarding conflict minerals were understood and complied with.

III. Due Diligence Framework

Our due diligence process has been designed to conform, in all material respects relevant to the disclosure requirements under the Rule, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

IV. Due Diligence Undertaken

OECD Step 3 – Design and implement a strategy to respond to identified risks

We supported audits of conflict mineral smelters and refiners conducted by third parties through our participation in the CFSI. Suppliers were evaluated based on their smelter and refiner information obtained from CMRT declarations. If supplier information indicated that they used conflict minerals from the Democratic Republic of the Congo or an adjoining country, then we used the flagship program of the CFSI, the Conflict-Free Smelter Program (CFSP) and general public information to determine a smelter or refiner’s conflict minerals program status.

If, through our smelters lists, we discover that certain of our products contain conflict minerals that finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country, or we cannot definitively deem a product to be free of conflict minerals that finance or benefit armed groups in the Democratic Republic of the Congo or an adjoining country, we will analyze the adverse impact of this determination pursuant to the standards set forth in our Conflict Minerals Policy and Supplier Code of Ethics.

Findings regarding the compiled supply chain information through the processes described above will be reported to our executive officer committee. Identified areas of risk in our supply chain will be subject to a risk management plan developed pursuant to our Supplier Code of Ethics and Conflict Minerals Policy. Such risk management plan may include continuing trade throughout the course of measurable risk mitigation efforts, temporarily suspending trade while pursuing ongoing measurable risk mitigation, or disengaging with a supplier after failed attempts at mitigation or where we deem risk mitigation not feasible or unacceptable.

Once our risk management plan is implemented, we will track performance of our risk mitigation efforts and report the results back to our executive officer committee. For risks requiring additional mitigation, or after a change of circumstances, we will undertake additional fact and risk assessments.

V. Results of Due Diligence Undertaken

OECD Step 4 – Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain

We will rely on third party assurances and certifications. For example, if a supplier provides the name of a smelter or source mine, we would compare that reply to the listing of smelters from the CFSP thereby relying on the program’s processes.

OECD Step 5 – Report on supply chain due diligence

We have taken the information gathered through the above-described due diligence process and compiled this Report. In the future, we will take such information and compile it in a Report or in our specialized disclosure report as required by the Rule, whichever is applicable.

No instances were found where it was necessary to implement risk mitigation or any corrective actions to suppliers in 2016. All smelters or refiners identified as sourcing from the Democratic Republic of the Congo or an adjoining country were found to be compliant with the relevant CFSP assessment protocol or other accepted industry assessment program.

VI. Smelter and Refiner Disclosures

Schedule 1 lists the CFSI verified smelters and refiners identified by collection of supplier conflict mineral reporting templates where sourcing is unknown. Please note these reported smelters and refiners have not been verified as contributing to components or parts that are in our products.

Schedule 2 lists the countries of the direct and indirect sourcing for compliant smelters reported by the CFSI.

VII. Future Improvements

We intend to undertake the following steps during the next compliance period:

• Continue to provide conflict minerals information to all suppliers included in our conflict mineral survey process.

• Continue to engage with relevant trade associations to define and improve best practices.

• Continue to support the CFSI through our membership and participation in subcommittees.

• Direct suppliers to the CFSI organization for information.

Schedule 1

ID		Metal		Name		Country
CID000103		Gold		Atasay Kuyumculuk Sanayi Ve Ticaret A.S.		TURKEY
CID000180		Gold		Caridad		MEXICO
CID000189		Gold		Cendres & M		SWITZERLAND
CID000197		Gold		Chalco Yunnan Copper Co. Ltd		CHINA
CID000264		Gold		Chugai Mining		JAPAN
CID000278		Tin		CNMC (Guangxi) PGMA Co. Ltd.		CHINA
CID000307		Tin		CV JusTindo		INDONESIA
CID000343		Gold		Daye Non-Ferrous Metals Mining Ltd.		CHINA
CID000345		Tungsten		Dayu Weiliang Tungsten Co., Ltd.		CHINA
CID000448		Tin		ATM ESTANHO IND COM IMP EXP LTDA		BRAZIL
CID000522		Gold		Gansu Seemine Material Hi-Tech Co Ltd		CHINA
CID000555		Tin		Gegjiu Zili Mining&Smel Ting Co.,Ltd.		CHINA
CID000651		Gold		Guoda Safina High-Tech Environmental Refinery Co., Ltd.		CHINA
CID000671		Gold		Hangzhou Fuchunjiang Smelting Co., Ltd.		CHINA
CID000689		Gold		Heesung Catalysts		Unknown
CID000760		Tin		Huichang Jinshunda Tin Co. Ltd		CHINA
CID000767		Gold		Hunan Chenzhou Mining Co., Ltd.		CHINA
CID000778		Gold		HwaSeong CJ Co., Ltd.		KOREA (REPUBLIC OF)
CID000942		Tin		Gejiu Kai Meng Industry and Trade LLC		CHINA
CID000956		Gold		Kazakhmys Smelting LLC		KAZAKHSTAN
CID001032		Gold		L’ azurde Company For Jewelry		SAUDI ARABIA
CID001056		Gold		Lingbao Gold Co., Ltd.		CHINA
CID001058		Gold		Lingbao Jinyuan Tonghui Refinery Co. Ltd.		CHINA
CID001093		Gold		Luoyang Zijin Yinhui Gold Refinery Co., Ltd.		CHINA
CID001231		Tin		Jiangxi Nanshan		CHINA
CID001236		Gold		Navoi Mining and Metallurgical Combinat		UZBEKISTAN
CID001322		Gold		Elemetal Refining, LLC		UNITED STATES OF AMERICA
CID001362		Gold		Penglai Penggang Gold Industry Co Ltd		CHINA
CID001546		Gold		Sabin		UNITED STATES
CID001562		Tin		Samwha Non Ferrous Metal Co. Ltd		KOREA, REPUBLIC OF
CID001619		Gold		Shandong Tiancheng Biological Gold Co Ltd.		CHINA
CID001754		Gold		Accurate Refining Group		UNITED STATES
CID001908		Tin		Gejiu City , the cloud new colored electrolytic Co., Ltd.		CHINA
CID001909		Gold		Great Wall Precious Metals Co., Ltd. of CBPM		CHINA
CID001947		Gold		Anhui Tongling non-ferrous Pioneer Metals Corporation		CHINA
CID002158		Tin		Wind Yunnan Nonferrous Metals Co.,Ltd.		CHINA
CID002282		Gold		Morris and Watson		NEW ZEALAND
CID002290		Gold		SAFINA A.S.		CZECH REPUBLIC

CID002312		Gold		Guangdong Jinding Gold Co.,Ltd		CHINA
CID002313		Tungsten		Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.		CHINA
CID002479		Tin		PT Wahana Parkit Jaya		INDONESIA
CID002507		Tantalum		Phoenix Metal Ltd		RWANDA
CID002511		Gold		KGHM Polska Mied? Sp		POLAND
CID002515		Gold		Fidelity Printers and Refiners Ltd.		ZIMBABWE
CID002536		Tungsten		Ganzhou Yatai Tungsten Co., Ltd.		CHINA
CID002563		Gold		Kaloti Precious Metals		UNITED ARAB EMIRATES
CID002567		Gold		Sudan Gold Refinery		SUDAN
CID002572		Tin		Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company		VIET NAM
CID002573		Tin		NGHE TIN NON-FERROUS METAL		VIET NAM
CID002574		Tin		Tuyen Quang Non-Ferrous Metals Joint Stock Company		VIET NAM
CID002582		Gold		Remondis Argentia B.V.		NETHERLANDS
CID002587		Gold		Tony Goetz NV		BELGIUM
CID002615		Gold		TOO Tau-Ken-Altyn		KAZAKHSTAN
CID002647		Tungsten		Jiangxi Dayu Longxintai Tungsten Co., Ltd.		CHINA
CID002696		Tin		PT Cipta Persada Mulia		INDONESIA
CID002703		Tin		An Vinh Joint Stock Mineral Processing Company		VIET NAM
CID002708		Gold		Abington Reldan Metals, LLC		UNITED STATES OF AMERICA
CID002756		Tin		Super Ligas		BRAZIL
CID002761		Gold		SAAMP		FRANCE
CID002825		Tin		An Thai Minerals Co., Ltd.		VIET NAM
CID002833		Tungsten		ACL Metais Eireli		BRAZIL
CID002852		Gold		Gujarat Gold Centre		INDIA
CID002853		Gold		Sai Refinery		INDIA
CID002854		Gold		Universal Precious Metals Refining Zambia		ZAMBIA
CID002857		Gold		Modeltech Sdn Bhd		MALAYSIA
CID002858		Tin		Modeltech Sdn Bhd		MALAYSIA
CID002863		Gold		BALORE REFINERSGA		INDIA
CID002865		Gold		Kyshtym Copper-Electrolytic Plant ZAO		RUSSIAN FEDERATION
CID002867		Gold		Degussa		GERMANY

Schedule 2

DRC; Burundi; Rwanda; Mozambique; Uganda; South Africa; Austria; Cambodia; Japan; Mexico; Spain; United Kingdom of Great Britain and Northern Ireland; Uzbekistan; Benin; Burkina Faso; Canada; Chile; Ecuador; Eritrea; Ghana; Guatemala; Honduras; Mali; Nicaragua; Panama; Senegal; Togo; Argentina; Colombia; Indonesia; Laos; Mongolia; Myanmar; Peru; Portugal; Vietnam; Australia; Bolivia (Plurinational State of); Brazil; China; Ethiopia; France; Guinea; Guyana; India; Madagascar; Malaysia; Namibia; Nigeria; Russian Federation; Sierra Leone; Thailand; United States of America; and Zimbabwe.