Axon Enterprise, Inc.
AXON ENTERPRISE, INC. (Form: SD, Received: 05/26/2017 16:23:39)


 


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM SD
Specialized Disclosure Report
 
Axon Enterprise, Inc.
(Exact name of registrant as specified in its charter)

Delaware
 (State or other jurisdiction of
 incorporation)
 
001-16391
 (Commission File Number)
 
86-0741227
 (IRS Employer
 Identification No.)

17800 N. 85 th St.
Scottsdale, Arizona 85255
(Address of principal executive offices, including zip code)

Luke S. Larson
(480) 905-2053
(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:
[x]
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.



 






Table of Contents

AXON ENTERPRISE, INC.
SPECIALIZED DISCLOSURE ON FORM SD
FOR THE ANNUAL PERIOD ENDED DECEMBER 31, 2016
TABLE OF CONTENTS


SECTION 1 – CONFLICT MINERALS DISCLOSURE

SECTION 2 – EXHIBITS
Exhibit 1.01 Conflict Minerals Report

SIGNATURES






Table of Contents

AXON ENTERPRISE, INC.
SPECIALIZED DISCLOSURE ON FORM SD
FOR THE ANNUAL PERIOD ENDED DECEMBER 31, 2016


Section 1 – Conflict Minerals Disclosure
Item 1.01
Conflict Minerals Disclosure and Report
Rule 13p-1 under the Securities Exchange Act of 1934, as amended, requires public companies to make certain disclosures if any “conflict minerals,” as defined in paragraph (d)(3) of Form SD, are necessary to the functionality or production of a product that is manufactured or contracted to be manufactured by the company. Conflict minerals include gold, wolframite, cassiterite, columbite-tantalite, tin, tungsten and tantalum. Tin, tungsten, tantalum and gold are essential in the manufacture of a variety of products of Axon Enterprise, Inc. (the “Company”). The Company describes its country of origin inquiry and the due diligence that it exercised on the source and chain of custody of the conflict minerals used in its products in the Conflict Minerals Report attached hereto as Exhibit 1.01. The Conflict Minerals Report is also available on the Company website at htttp://investor.axon.com.
 
Item 1.02
Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.


Section 2 – Exhibits
Item 2.01
Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.






Table of Contents

AXON ENTERPRISE, INC.
SPECIALIZED DISCLOSURE ON FORM SD
FOR THE ANNUAL PERIOD ENDED DECEMBER 31, 2016


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.
 
 
 
 
 
Dated: May 26, 2017
Axon Enterprise, Inc.
 
 
By:  
 /s/ LUKE S. LARSON
 
 
 
Luke S. Larson
 
 
 
President
 





EXHIBIT 1.01
AXONBWVERTICALA04.JPG
CONFLICT MINERALS REPORT

Introduction
This Report has been prepared pursuant to Rule 13p-1 (the "Rule") under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 to December 31, 2016.
This Report relates to the process undertaken for Axon Enterprise, Inc.'s ("Axon" or "the Company" or "we" or "our") products that were manufactured, or contracted to be manufactured, during calendar year 2016 and that contain gold, columbite-tantalite (coltan), cassiterite, wolframite, tantalum, tin, or tungsten (collectively, the “conflict minerals”).
Tin, tungsten, tantalum and/or gold are necessary to the functionality of a variety of Axon's products, including, but not limited to TASER X26P®, TASER X26®, TASER X2®, TASER Pulse®, TASER Bolt®, TASER M26®, replacement cartridges, Axon Flex®, Axon Flex 2®, Axon Body®, Axon Body 2®, Axon docking stations, Axon Signal®, Axon Fleet®, TASER CAM®, and related accessories. Third-party products that the Company retails but that it does not manufacture or contract to manufacture are outside the scope of this report.
When this Report uses the term “conflict-free” to describe a smelter or refiner, it means that the applicable smelters and refiners have been verified as complying with the Conflict-Free Sourcing Initiative’s Conflict-Free Smelter Program (the “CFSP”) or an equivalent third-party audit program, some of which we describe below under the heading "Design of Due Diligence Framework - Step 2: Identify and Assess Risk in the Supply Chain."

Company Overview
Axon is a developer and manufacturer of advanced conducted electrical weapons (“CEWs”) designed for use by law enforcement, military, corrections, and private security personnel, and by private individuals for personal defense. In addition, the Company has developed full technology solutions for the capture, storage and management of video/audio evidence as well as other tactical capabilities for use in law enforcement.

Conflict Mineral Policy
Axon supports and respects the protection of internationally proclaimed human rights for all, including the basic human rights of our employees and workers within our supply chain. Axon is committed to respect human rights and fair labor practices.
Coinciding with this commitment, Axon is concerned about human rights violations and labor abuses, which we understand are occurring in the Democratic Republic of the Congo and adjoining countries (the “DRC region”) as a result of the civil discord there. We understand that the armed groups responsible for the conflict in the DRC region may be directly or indirectly financed by the mining and trade in certain conflict minerals.
As a result of the concern around human rights violations, the U.S. Securities and Exchange Commission ("SEC") adopted final rules to implement reporting and disclosure requirements related to conflict minerals, as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The SEC rules require public companies to disclose whether the products they manufacture or contract to manufacture contain conflict minerals that are “necessary to the functionality or production” of those products, and to conduct certain diligence and make certain disclosures regarding such minerals. Tin, tungsten, tantalum and gold are necessary to the functionality of a variety of Axon's products.
Using a documented reasonable process, we work diligently with our direct suppliers to determine the presence and origin of conflict minerals in our supply chain. Recognizing the complexity of this issue, Axon appreciates the need for broad collaboration

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 1



with all of our suppliers in our supply chain throughout this process. In our commitment to conduct our business worldwide with respect for human rights, we:
expect our direct suppliers to source materials from suppliers and smelters who also source responsibly, including, but not limited to, from legitimate, conflict-free mines in the DRC region;
expect our direct suppliers to conduct the necessary due diligence and provide us with proper verification of the country of origin and source of the materials used in the products they supply to Axon; and
reserve the right to verify information received from our suppliers.
Based on the information learned through our due diligence efforts, we continue to evaluate and make changes to supplier base and hope to make aditional progress toward ensuring responsible mineral sourcing throughout our supply chain, and improved transparency for our investors and customers.
Axon's Conflict Mineral Program
The Company's continuous engagement and accountability is leading to better data that will allow management to make meaningful decisions with respect to the Company's supply chain. While the majority of conflict minerals contained in the materials supplied to the Company are sourced by our suppliers through smelters or refiners ("SORs") in countries that the Company has determined to be of lower risk of directly or indirectly financing or benefiting armed groups, the Company acknowledges that mineral supplies may still be sourced by our suppliers from SORs in Central Africa or who acquire product from sources in Central Africa or have other contacts in that region. The Company is determined to continue making efforts to understand whether the SORs its suppliers source from in Central Africa and elsewhere have been certified as conflict-free.
Axon hardware products contain one or more conflict minerals and are within the Rule’s scope. On the basis of our “reasonable country of origin inquiry” (“RCOI”) required by the Rule and described below, we cannot exclude the possibility that some of the conflict minerals contained in our hardware products may have originated in the DRC region. For that reason, we are submitting this Conflict Minerals Report (“CMR”), which describes the conflict minerals due diligence we have performed pursuant to the Rule.
This CMR, which includes sections titled Reasonable Country of Origin Inquiry, Design of Due Diligence Framework, Description of Due Diligence Measures Performed, and Future Due Diligence Measures, is designed to meet the reporting requirements of the Rule. It is publicly available on our investor relations website at www.investor.axon.com.
Reasonable Country of Origin Inquiry
The Company's RCOI corresponds to the first and second steps of the five-step OECD Guidance further described below, as that Guidance (including its Supplements) applies to each of the conflict minerals and to Axon as a “downstream company.” The OECD Guidance provides a framework for detailed due diligence to support responsible global supply chain management of minerals, including the conflict minerals.
As a direct manufacturer, the Company does not directly source conflict minerals. We source products and components from direct suppliers, which source materials from their subtier suppliers. Our supply chain is extensive and complex with many layers of suppliers positioned between ourselves and conflict mineral smelters, refiners, and mines. Due to our extended supply chain, we rely on our direct suppliers to provide us with information concerning the sources and chains of custody of conflict minerals necessary to the functionality or production of our hardware products. The Company does not have complete information about the conflict minerals in its entire supply chain. For 2016, many direct suppliers identified smelters or refiners in their supply chain on a company-wide basis, division or product-line basis, without specifying the smelters or refiners that were relevant to products they supplied to Axon. Accordingly, the Company refers in this Conflict Minerals Report to smelters or refiners being "potentially" in our supply chain and as conflict minerals "potentially" supplied to Axon.

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 2



The charts below highlight the progress of the Company's RCOI, including the number of identified direct suppliers that participated in the Company's conflict minerals campaigns versus those who did not, as well as the status of known SORs that have been certified as conflict-free versus those that have not received such certification:
RESPONSE RATE OF IDENTIFIED DIRECT SUPPLIERS
A2016EX101_CHART-34890.JPG A2016EX101_CHART-36566.JPG
STATUS OF KNOWN SMELTERS OR REFINERS
A2016EX101_CHART-37606.JPG A2016EX101_CHART-39034.JPG
For the 2016 reporting period, the Company identified 86 direct suppliers determined to be in-scope for regulatory purposes based on the Company’s influence over the manufacturing process (i.e., meeting the manufacture or contract to manufacture criteria in Rule 13p-1) and the use of conflict minerals in materials supplied. Based on response rates received from direct suppliers, the Company identified 300 known SORs of conflict minerals contained in our products, and of those, 83% were certified as being conflict-free. The Company remains focused on its due diligence efforts in 2017 to work with our direct suppliers to verify the remaining SORs supplying conflict minerals contained in our products, and if that cannot be done, considering whether to remove them from our supply chain.

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 3



The following table illustrates the status of known SORs of conflict minerals potentially in the Company's supply chain:
Status of known smelters or refiners
 
2016
 
% of Total
Certified conflict-free
 
250

 
83
%
Not certified conflict-free
 
50

 
17

Total
 
300

 
100
%

The table below illustrates the SORs that were certified as conflict-free, by type of conflict mineral, as a percentage of total known SORs:
Status of known smelters or refiners
 
2016
 
% of Total
Tantalum
 
102

 
40
%
Gold
 
44

 
17

Tin
 
72

 
28

Tungsten
 
40

 
16

Total (a)
 
258

 
100
%
(a) While most SORs in the Company's supply chain source only one of the conflict minerals, the Company identified eight known SORs that obtained certifications for two conflict minerals. This explains the discrepancy between the 250 SORs that were certified as conflict-free in the proceeding table versus the SORs certified by type of material above.
During the due diligence process, the Company identified 64 SORs with indications of DRC region sourcing. The following table illustrates the certification status of these SORs:
Status of known smelters or refiners in DRC Region
 
2016
 
% of Total
Certified conflict-free
 
63

 
98
%
Not certified conflict-free
 
1

 
2

Total
 
64

 
100
%

Design of Due Diligence Framework

Inherent Limitations on Due Diligence Measures:  As a downstream purchaser of products which contain conflict minerals, the Company's due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. The Company's due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. The Company also relies, to a large extent, on information collected and provided by independent third party audit programs. Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. Under the Dodd-Frank Act and the Rule, a product is "DRC conflict-free" if it meets the required standard every day of the reporting year; conversely, a product would "not be found to be DRC conflict-free" if it does not meet the required standard even one day of the reporting year. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to SORs, with SORs smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use.  Since the Company does not have direct contractual relationships with SORs, it relies on our direct suppliers and the entire supply-chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. the Company directly seeks sourcing data on a periodic basis from its direct suppliers as well as certain SORs. The Company asks that the data cover the entire reporting year.
The good faith due diligence process that Axon undertook was designed in accordance with 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 (Second Edition, OECD 2013) and the related Supplements on tantalum, tin, tungsten and gold (collectively, the “OECD Guidance”). The OECD Guidance provides
practical guidance to companies throughout the supply chain on a set of actions that can be taken to ensure responsible due diligence. Aligning with the OECD’s diligence framework, the steps that Axon implemented were as follows:

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 4



Step 1: Establish Strong Corporate Management Systems
Assign accountability for the compliance efforts to a cross-functional team of legal, supply chain, engineering and finance personnel, that meet periodically throughout the year to develop a strategy for the annual conflict minerals campaign.
Employ a supply chain system of controls and transparency through the use of due diligence tools created by the Electronic Industry Citizenship Coalition ("EICC") and the Global e-Sustainability Initiative ("GeSI")'s Conflict-Free Sourcing Initiative ("CFSI"), which includes the Conflict Minerals Reporting Template ("CMRT"), a supply chain survey designed to identify the SORs that process the necessary conflict minerals contained in our products.
Feature requirements related to conflict minerals in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on conflict minerals, including participation in a supply chain survey and related due diligence activities.
Maintain records relating to our conflict minerals program in accordance with our record retention guidelines.
Step 2: Identify and Assess Risk in the Supply Chain
Identify direct suppliers that supply products that may contain conflict minerals.
Conduct a RCOI, requesting direct suppliers to identify SORs and country of origin of the conflict minerals in products they supply to Axon.
Evaluate supplier responses for plausibility, consistency and missing data. Conduct additional supplier contacts to resolve questions with respect to the initial findings to determine whether the responses were reasonable and reliable.
For those supply chains with SORs that are known or thought to be sourcing from the DRC region, additional investigation was conducted to determine the source and chain of custody of covered metals. The Company relies on the following internationally accepted audit standards to determine which SORs are considered conflict-free: the CFSP, the London Bullion Market Association Good Delivery Program and the Responsible Jewelry Council Chain-of-Custody Certification program.
If any SOR was not certified by these internationally-recognized methods, the Company attempted to contact the SOR to gain more information about its sourcing practices, including countries of origin and transfer, and whether there are any internal due diligence procedures in place or other processes that it takes to track the chain of custody on the source of its mineral ores. Relevant information to review includes: whether the SOR has a documented, effective and communicated conflict-free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. The Company also performed Internet research to determine whether there are any outside sources of information regarding the SOR’s sourcing practices. As many as three contact attempts were made to direct suppliers to gather information on mine country of origin and sourcing practices.
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Work with our direct suppliers to verify all SORs, and attempt to ensure that any SORs that were not already certified as conflict-free would enroll in a third-party audit process.
Identify and consider, to the extent feasible, alternative suppliers for materials where the supplier is uncooperative towards our goal of responsibly sourcing conflict minerals.
Provide progress reports to our President and other senior management summarizing our risk mitigation efforts.
Step 4: Third-party Audit of Smelter’s/Refiner’s Due Diligence Processes
Based on information received through the CFSP or equivalent independent third-party audit programs, as well as a third-party review of publicly available information about identified SORs, Axon has documented the country of origin information of particular known SORs. The CFSP collects evidence from SORs demonstrating that responsible sourcing procedures and systems have been implemented. The CFSP works with complementary programs in Central Africa to validate conflict-free mine sites and trade routes. Regional traceability and other third-party programs work with non-governmental organizations, government programs, and the CFSP to improve procedures and systems when incidents occur, and they communicate relevant information to program participants as it becomes available. The Company believes that independent third-party audit programs provide a reasonable basis for companies to conclude that SORs have

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 5



procedures and systems for determining if the SORs process conflict minerals that directly or indirectly finance or benefit armed groups.
Step 5: Report on Supply Chain Due Diligence
Publicly communicate our Conflict Minerals Sourcing Policy on our company website: www.investor.axon.com.
Publicly communicate the results of our annual Conflict Minerals program on our company website: www.investor.axon.com.
Description of Due Diligence Measures Performed 
Below is a description of the measures the Company performed for the 2016 reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products that we had reason to believe may have originated from the DRC region and may not have come from recycled or scrap sources:
Conducted a supply-chain survey of suppliers that we identified as possibly supplying Axon with products that contain necessary conflict minerals using the CFSI's CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of SORs that process such minerals.
Received and retained responses to the supply-chain survey within an online database.
Performed as many as seven additional follow up supply chain inquiries for supplier non-responses.
Contacted surveyed suppliers on responses to supply chain surveys that we identified contained incomplete or potentially inaccurate information to seek additional clarifying information.
Compared SORs identified by the supply chain survey against the list of facilities that have received a "conflict-free" designation from the CFSP or other independent third-party audit program.
Provided progress reports to the President and other members of senior management to communicate the status and results of our conflict minerals program.
Future Due Diligence Measures  
During the reporting period for the calendar year ending December 31, 2017, we are continuing to engage in the activities described above in "Design of Due Diligence Framework" and "Description of Due Diligence Measures Performed." In our efforts to attain a conflict-free supply chain for our products, we intend to continue to contact SORs identified in our supply chain survey process that have not yet received a "conflict-free" designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a "conflict-free" designation. Further the Company intends to advance its due diligence measures but also to mitigate and address certain risks by performing the following:
redistribute copies of our conflict minerals policy to direct suppliers;
emphasize to them our expectation that they respond fully and promptly to our information requests;
instruct them to advise us if they determine that any person or entity in their supply chain is directly or indirectly financing or benefiting armed groups in the DRC region; and
encourage them to direct all SORs in their supply chains to participate in the CFSP or a similar third-party audit program.

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 6



Determination
Based on the information provided by the Company’s direct suppliers, and the Company's own due diligence efforts with known SORs through December 31, 2016, the Company believes that the SORs listed on Appendix A below may have been used to process the conflict minerals in Axon's products.
Based on these due diligence efforts, Axon does not have sufficient information to conclusively determine the countries of origin of the conflict minerals in its products or whether such conflict minerals in its products are from recycled or scrap sources. However, based on the information provided by the Company’s direct suppliers and SORs, as well as from the CFSI and other sources, the Company believes that the countries of origin of the conflict minerals contained in its products include the countries listed in Appendix B below, as well as recycled and scrap sources.
Of the 300 SORs of conflict minerals identified for calendar year 2016, 64 SORs were identified as sources of conflict minerals from the DRC region. Of these 64, 63 were determined CFSP-compliant, with one of the 64 not having obtained certification for the conflict minerals sourced. We do not yet have complete information about the conflict minerals in our supply chain.
Axon has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers or SORs to comply with the Company's conflict minerals standards, may affect the Company's future determinations under Rule 13p-1.



Axon Enterprise, Inc. | 2016 Conflict Minerals Report | 7



Appendix A
* Denotes SORs which have received a "conflict-free" designation from an independent third party audit program.
Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Gold
Advanced Chemical Company *
United States
Gold
Aida Chemical Industries Co., Ltd. *
Japan
Gold
Al Etihad Gold *
United Arab Emirates
Gold
Allgemeine Gold-und Silberscheideanstalt A.G. *
Germany
Gold
Almalyk Mining and Metallurgical Complex (AMMC) *
Uzbekistan
Gold
AngloGold Ashanti *
Brazil
Gold
Argor-Heraeus SA *
Switzerland
Gold
Asahi Pretec Corporation *
Japan
Gold
Asahi Refining Canada Limited *
Canada
Gold
Asahi Refining USA Inc. *
United States
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 + Métaux SA *
Switzerland
Gold
Chimet S.p.A. *
Italy
Gold
Chugai Mining
Japan
Gold
Daejin Indus Co., Ltd. *
South Korea
Gold
Daye Non-Ferrous Metals Mining Ltd. *
China
Gold
DODUCO GmbH *
Germany
Gold
Dowa *
Japan
Gold
DSC (Do Sung Corporation) *
South Korea
Gold
Eco-System Recycling Co., Ltd. *
Japan
Gold
Elemetal Refining, LLC *
United States
Gold
Emirates Gold DMCC *
United Arab Emirates
Gold
Fidelity Printers and Refiners Ltd.
Zimbabwe
Gold
Gansu Seemine Material Hi-Tech Co Ltd
China
Gold
Geib Refining Corporation *
United States
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
Gold
Gujarat Gold Centre
India
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
China
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
China
Gold
Heimerle + Meule GmbH *
Germany
Gold
Heraeus Metals Hong Kong Ltd *
China
Gold
Heraeus Precious Metals GmbH & Co. KG *
Germany
Gold
Hunan Chenzhou Mining Co., Ltd.
China
Gold
HwaSeong CJ Co. Ltd
South Korea
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. *
China
Gold
Ishifuku Metal Industry Co., Ltd. *
Japan
Gold
Istanbul Gold Refinery *
Turkey
Gold
Japan Mint *
Japan

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 1



Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Gold
Jiangxi Copper Company Limited *
China
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant *
Russia
Gold
JSC Uralelectromed *
Russia
Gold
JX Nippon Mining & Metals Co., Ltd. *
Japan
Gold
Kaloti Precious Metals
United Arab Emirates
Gold
Kazzinc *
Kazakhstan
Gold
Kennecott Utah Copper LLC *
United States
Gold
KGHM Polska Miedź Spółka Akcyjna *
Poland
Gold
Kojima Chemicals Co., Ltd. *
Japan
Gold
Korea Zinc Co., Ltd. *
South Korea
Gold
Kyrgyzaltyn JSC *
Kyrgyzstan
Gold
L'azurde Company For Jewelry
Saudi Arabia
Gold
Lingbao Gold Company Ltd.
China
Gold
Lingbao Jinyuan Tonghui Refinery Co. Ltd.
China
Gold
LS-NIKKO Copper Inc. *
South Korea
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
China
Gold
Materion *
United States
Gold
Matsuda Sangyo Co., Ltd. *
Japan
Gold
Metalor Technologies (Hong Kong) Ltd. *
China
Gold
Metalor Technologies (Singapore) Pte., Ltd. *
Singapore
Gold
Metalor Technologies (Suzhou) Co Ltd *
China
Gold
Metalor Technologies SA *
Switzerland
Gold
Metalor USA Refining Corporation *
United States
Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V *
Mexico
Gold
Mitsubishi Materials Corporation *
Japan
Gold
Mitsui Mining and Smelting Co., Ltd. *
Japan
Gold
MMTC-PAMP India Pvt., Ltd. *
India
Gold
Modeltech Sdn Bhd *
Malaysia
Gold
Morris and Watson
New Zealand
Gold
Moscow Special Alloys Processing Plant *
Russia
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş. *
Turkey
Gold
Navoi Mining and Metallurgical Combinat *
Uzbekistan
Gold
Nihon Material Co., Ltd. *
Japan
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH *
Austria
Gold
Ohura Precious Metal Industry Co., Ltd. *
Japan
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) *
Russia
Gold
OJSC Novosibirsk Refinery *
Russia
Gold
PAMP S.A. *
Switzerland
Gold
Penglai Penggang Gold Industry Co Ltd
China
Gold
Philippine Associated Smelting and Refining Corporation
Philippines
Gold
Prioksky Plant of Non-Ferrous Metals *
Russia
Gold
PT Aneka Tambang (Persero) Tbk *
Indonesia
Gold
PX Precinox SA *
Switzerland
Gold
Rand Refinery (Pty) Ltd. *
South Africa
Gold
Remondis Argentia B.V.
Netherlands
Gold
Republic Metals Corporation *
United States
Gold
Royal Canadian Mint *
Canada
Gold
SAAMP *
France
Gold
Sabin Metal Corp.
United States
Gold
SAFINA A.S.
Czech Republic
Gold
Sai Refinery
India
Gold
Samduck Precious Metals *
South Korea

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 2



Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Gold
SAMWON METALS Corp.
South Korea
Gold
SAXONIA Edelmetalle GmbH *
Germany
Gold
Schone Edelmetaal B.V. *
Netherlands
Gold
SEMPSA Joyería Platería SA *
Spain
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 Technology Co., Ltd. *
Taiwan
Gold
So Accurate Group, Inc.
United States
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals *
Russia
Gold
Solar Applied Materials Technology Corp. *
Taiwan
Gold
Sudan Gold Refinery
Sudan
Gold
Sumitomo Metal Mining Co., Ltd. *
Japan
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 Nonferrous Metals Group Holdings Co., Ltd.
China
Gold
Tony Goetz NV
Belgium
Gold
Torecom *
South Korea
Gold
Umicore Brasil Ltda. *
Brazil
Gold
Umicore Precious Metals Thailand *
Thailand
Gold
Umicore SA Business Unit Precious Metals Refining *
Belgium
Gold
United Precious Metal Refining, Inc. *
United States
Gold
Universal Precious Metals Refining Zambia
Zambia
Gold
Valcambi SA *
Switzerland
Gold
Western Australian Mint trading as The Perth Mint *
Australia
Gold
WIELAND Edelmetalle GmbH *
Germany
Gold
Yamamoto Precious Metal 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
Conghua Tantalum and Niobium Smeltry *
China
Tantalum
D Block Metals, LLC *
United States
Tantalum
Duoluoshan *
China
Tantalum
Exotech Inc. *
United States
Tantalum
F&X Electro-Materials Ltd. *
China
Tantalum
FIR Metals & Resource Ltd. *
China
Tantalum
Global Advanced Metals Aizu *
Japan
Tantalum
Global Advanced Metals Boyertown *
United States
Tantalum
Guangdong Zhiyuan New Material Co., Ltd. *
China
Tantalum
H.C. Starck Co., Ltd. *
Thailand
Tantalum
H.C. Starck Hermsdorf GmbH *
Germany
Tantalum
H.C. Starck Inc. *
United States
Tantalum
H.C. Starck Ltd. *
Japan
Tantalum
H.C. Starck Smelting GmbH & Co. KG *
Germany
Tantalum
H.C. Starck Tantalum and Niobium GmbH *
Germany
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd. *
China
Tantalum
Hi-Temp Specialty Metals, Inc. *
United States
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. *
China
Tantalum
Jiangxi Tuohong New Raw Material *
China

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 3



Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd. *
China
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited *
China
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. *
China
Tantalum
KEMET Blue Metals *
Mexico
Tantalum
Kemet Blue Powder *
United States
Tantalum
King-Tan Tantalum Industry Ltd. *
China
Tantalum
LSM Brasil S.A. *
Brazil
Tantalum
Metallurgical Products India Pvt., Ltd. *
India
Tantalum
Mineração Taboca S.A. *
Brazil
Tantalum
Mitsui Mining and Smelting Co., Ltd. *
Japan
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd. *
China
Tantalum
NPM Silmet AS *
Estonia
Tantalum
Power Resources Ltd. *
Macedonia
Tantalum
QuantumClean *
United States
Tantalum
Resind Indústria e Comércio Ltda. *
Brazil
Tantalum
RFH Tantalum Smeltry Co., Ltd. *
China
Tantalum
Solikamsk Magnesium Works OAO *
Russia
Tantalum
Taki Chemical Co., Ltd. *
Japan
Tantalum
Telex Metals *
United States
Tantalum
Tranzact, Inc. *
United States
Tantalum
Ulba Metallurgical Plant JSC *
Kazakhstan
Tantalum
XinXing Haorong Electronic Material Co., Ltd. *
China
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd. *
China
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd. *
China
Tin
Alpha *
United States
Tin
An Thai Minerals Company Limited
Vietnam
Tin
An Vinh Joint Stock Mineral Processing Company
Vietnam
Tin
Brand IMLI *
Indonesia
Tin
Chenzhou Yunxiang Mining and Metallurgy Company Limited *
China
Tin
China Tin Group Co., Ltd. *
China
Tin
CNMC (Guangxi) PGMA Co. Ltd.
China
Tin
Cooperativa Metalurgica de Rondônia Ltda. *
Brazil
Tin
CV Ayi Jaya *
Indonesia
Tin
CV Dua Sekawan *
Indonesia
Tin
CV Gita Pesona *
Indonesia
Tin
CV Nurjanah
Indonesia
Tin
CV Serumpun Sebalai *
Indonesia
Tin
CV Tiga Sekawan *
Indonesia
Tin
CV United Smelting *
Indonesia
Tin
CV Venus Inti Perkasa *
Indonesia
Tin
Dowa *
Japan
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Vietnam
Tin
Elmet S.L.U. *
Spain
Tin
EM Vinto *
Bolivia
Tin
Estanho de Rondônia S.A.
Brazil
Tin
Fenix Metals *
Poland
Tin
Gejiu Fengming Metallurgy Chemical Plant *
China
Tin
Gejiu Jinye Mineral Company *
China
Tin
Gejiu Kai Meng Industry and Trade LLC *
China
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd. *
China
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. *
China
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
China

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 4



Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Tin
Guanyang Guida Nonferrous Metal Smelting Plant *
China
Tin
HuiChang Hill Tin Industry Co., Ltd. *
China
Tin
Huichang Jinshunda Tin Co. Ltd
China
Tin
Jiangxi Ketai Advanced Material 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
Tin
Metallo-Chimique N.V. *
Belgium
Tin
Mineração Taboca S.A. *
Brazil
Tin
Minsur *
Peru
Tin
Mitsubishi Materials Corporation *
Japan
Tin
Modeltech Sdn Bhd
Malaysia
Tin
Nankang Nanshan Tin Co., Ltd.
China
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
Vietnam
Tin
O.M. Manufacturing (Thailand) Co., Ltd. *
Thailand
Tin
O.M. Manufacturing Philippines, Inc. *
Philippines
Tin
Operaciones Metalurgical S.A. *
Bolivia
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 Bangka Prima Tin *
Indonesia
Tin
PT Bangka Tin Industry *
Indonesia
Tin
PT Belitung Industri Sejahtera *
Indonesia
Tin
PT Bukit Timah *
Indonesia
Tin
PT Cipta Persada Mulia *
Indonesia
Tin
PT DS Jaya Abadi *
Indonesia
Tin
PT Eunindo Usaha Mandiri *
Indonesia
Tin
PT Inti Stania Prima *
Indonesia
Tin
PT Justindo
Indonesia
Tin
PT Karimun Mining *
Indonesia
Tin
PT Kijang Jaya Mandiri *
Indonesia
Tin
PT Mitra Stania Prima *
Indonesia
Tin
PT O.M. Indonesia *
Indonesia
Tin
PT Panca Mega Persada *
Indonesia
Tin
PT Prima Timah Utama *
Indonesia
Tin
PT Refined Bangka Tin *
Indonesia
Tin
PT Sariwiguna Binasentosa *
Indonesia
Tin
PT Stanindo Inti Perkasa *
Indonesia
Tin
PT Sukses Inti Makmur *
Indonesia
Tin
PT Sumber Jaya Indah *
Indonesia
Tin
PT TAMBANG TIMAH
Indonesia
Tin
PT Timah (Persero) Tbk Kundur *
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
PT WAHANA PERKIT JAYA *
Indonesia
Tin
Resind Indústria e Comércio Ltda. *
Brazil
Tin
Rui Da Hung *
Taiwan
Tin
Soft Metais Ltda. *
Brazil

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 5



Subject Mineral
Smelter or Refiner Name
Country location of Smelter or Refiner
Tin
Thaisarco *
Thailand
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
Vietnam
Tin
VQB Mineral and Trading Group JSC *
Vietnam
Tin
White Solder Metalurgia e Mineração Ltda. *
Brazil
Tin
Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. *
China
Tin
Yunnan Tin Group (Holding) Company Limited *
China
Tungsten
A.L.M.T. Corp. *
Japan
Tungsten
ACL Metais Eireli
Brazil
Tungsten
Asia Tungsten Products Vietnam Ltd. *
Vietnam
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd. *
China
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd. *
China
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
China
Tungsten
Fujian Jinxin 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
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
China
Tungsten
Global Tungsten & Powders Corp. *
United States
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 Nonferrous Metals Co., Ltd. *
China
Tungsten
Hydrometallurg, JSC *
Russia
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 Non-ferrous Metals Co., Ltd.
China
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. *
China
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd. *
China
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. *
China
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd. *
China
Tungsten
Kennametal Fallon *
United States
Tungsten
Kennametal Huntsville *
United States
Tungsten
Malipo Haiyu Tungsten Co., Ltd. *
China
Tungsten
Moliren Ltd *
Russia
Tungsten
Niagara Refining LLC *
United States
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC *
Vietnam
Tungsten
Philippine Chuangxin Industrial Co., Inc. *
Philippines
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City *
China
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd. *
Vietnam
Tungsten
Unecha Refractory Metals Plant *
Russia
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd. *
Vietnam
Tungsten
Wolfram Bergbau und Hütten AG *
Austria
Tungsten
Woltech Korea Co., Ltd. *
South Korea
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

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | A- 6



APPENDIX B
Angola *
Malaysia
Argentina
Mali
Armenia
Mexico
Australia
Mongolia
Austria
Morocco
Belarus
Mozambique
Belgium
Myanmar
Bermuda
Namibia
Bolivia
Netherlands
Brazil
New Zealand
Burundi *
Niger
Cambodia
Nigeria
Canada
Papua New Guinea
Central African Republic *
Peru
Chile
Philippines
China
Poland
Colombia
Portugal
Czech Republic
Republic of the Congo *
Democratic Republic of the Congo *
Russia
Djibouti
Rwanda *
Ecuador
Saudi Arabia
Egypt
Sierra Leone
Estonia
Singapore
Ethiopia
Slovakia
Finland
South Africa
France
South Korea
Germany
South Sudan *
Ghana
Spain
Guinea
Suriname
Guyana
Sweden
Hong Kong
Switzerland
Hungary
Taiwan
India
Tajikistan
Indonesia
Tanzania *
Ireland
Thailand
Israel
Turkey
Italy
Uganda *
Japan
United Arab Emirates
Jersey
United Kingdom
Kazakhstan
United States
Kenya
Uzbekistan
Kyrgyzstan
Vietnam
Laos
Zambia *
Luxembourg
Zimbabwe
Madagascar
 
 
 
* The DRC or Adjoining Countries

Axon Enterprise, Inc. | 2016 Conflict Minerals Report | B- 1