Exhibit 1.01
Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2015
This Conflict Minerals Report for the year ended December 31, 2015 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company” or “we”) pursuant to Rule 13p-1(the "Rule" or "Rule 13p-1") promulgated under the Securities Exchange Act of 1934, as amended, and Form SD thereunder.
The Rule was adopted by the Securities and Exchange Commission ("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. Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (“conflict minerals” or “3TG”).
In general, if an SEC registrant, like Radware, has reason to believe that any of the conflict minerals in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
This Report relates to the process undertaken for Radware products that were manufactured or contracted to be manufactured, during calendar year 2015 and that may contain 3TG minerals.
A copy of this Report as well as the Form SD that we filed with the SEC is available on our website at https://www.radware.com/corporategovernance/conflictminerals/.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in the Rule and Form SD as well as SEC Release No. 34-67716 issued by the SEC on August 22, 2012.
Except as set forth otherwise in this Report, Radware has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Radware’s Conflict Minerals Policy, may affect Radware’s future determinations under Rule 13p-1.
1. | Overview |
Company Overview
We are a leading provider of cyber security and application delivery solutions designed to ensure optimal service level for applications in virtual, cloud and software defined data centers. We offer a set of products and solutions that address data center application service level challenges and are designed to solve key challenges with applications’ availability, applications’ response time and data center availability. Our solutions provide application layer service on top of the enterprise or carrier network front ending the applications and, in general, address three primary target markets and challenges: the Distributed Denial of Service (DDoS) protection market; the Application Delivery Controllers (ADCs) market; and the Web application firewall (WAF) market. We sell our products primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, with most of our direct sales being to strategic customers.
For more information about Radware, please visit www.radware.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.
Supply Chain
We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products.
The products that we manufacture are highly complex, typically containing thousands of parts from many direct suppliers. In general, we primarily rely on third-party assembly and manufacturing vendors to provide our finished products and, in this respect, these vendors typically receive components and subassemblies included in our products from other suppliers and subcontractors.
We have relationships with a vast network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we must rely on our direct suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors in order that they may provide us with accurate information about the origin of 3TG in the components we purchase from them. In particular, many of our supplier contracts have fixed durations and we cannot unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our due diligence efforts with respect to 3TG content.
Efforts to Determine Mine or Location of Origin
We have determined that requesting our suppliers to complete the CMRT (as defined below) as well as following the steps described under Section 2 below (Due Diligence Process), represent our reasonable efforts to determine the mines or locations of origin of 3TG in our supply chain.
We developed a risk-based approach (pareto analysis) that focuses on all suppliers involved in the manufacture of the majority of our finished products that were shipped in 2015. We identified in total 193 relevant suppliers (the “Relevant Suppliers”) and engaged a third party data collection and software vendor (the "Third Party Vendor") to monitor the due diligence process and the gathering of information from all such Relevant Suppliers.
We sent letters to our Relevant Suppliers to explain the Rule and to refer them to online training materials and instructions. We also solicited information from our Relevant Suppliers using the most up to date Conflict Minerals Reporting Template (“CMRT”), an industry-standard template for conflict mineral reporting developed by the Conflict-Free Sourcing Initiative (the "CFSI").
We reviewed the responses that we received 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.
Based on these efforts, we already know that some of our products may contain conflict minerals that originated in Covered Countries and are not from recycled or scrap sources. Therefore, according to the Rule, we have engaged in the Due Diligence Process described in detail in Section 2 below.
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2. | Due Diligence Process |
2.1 | Design of Due Diligence |
Our due diligence measures have been designed to conform, in all material respects, with the due diligence framework presented by The Organisation for Economic Co-operation and Development (OECD) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten.
2.2 | Due Diligence Performed |
2.2.1 | Establish Strong Management Systems |
Corporate Policy
We have adopted a conflict minerals policy (our "Policy" or our "Conflict Minerals Policy") which is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals/.
Internal Team
We have established a management system to support supply chain due diligence related to 3TG. Our management system includes an executive steering committee headed by the Company’s VP Finance, and a team of subject matter experts from functions such as supplier management, engineering, finance and legal.
Control systems
We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the supply chain of minerals originating from conflict affected and high-risk areas.
During 2015, we reviewed our internal and external communication plan from 2014 and updated it as we deemed required.
Controls include a company-wide code of conduct that outlines expected behaviors for all our employees and as we enter into new supply contracts or renew existing supply contracts, we are adding (where feasible) a conflict minerals contract clause that requires suppliers to provide us with information about the source of 3TG and smelters.
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Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof, and suppliers and other external parties are encouraged to contact their regular sourcing channel if they wish to seek guidance on the application of this approach, or if they wish to report a suspected abuse.
Maintain records
We maintain data records relating to our due diligence efforts in the Third Party Vendor’s Conflict Minerals Reporting Dashboard Software (“CMR Dashboard”) for the duration recommended by the OECD Guidance. The CMR Dashboard stores current and former CMRT’s from suppliers to maintain traceability.
Supplier Engagement
We requested that all Relevant Suppliers provide information to us regarding 3TG and smelters using the CMRT.
We maintain an electronic portal which directs suppliers to resources related to Conflict Minerals, including FAQs from the SEC.
We established a Conflict Minerals webpage to host our CMRT, our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs.
We have also engaged the Third Party Vendor to provide training and outreach to suppliers, as well as to conduct, collect, validate and archive supplier responses.
2.2.2 | Identify and assess risk in the supply chain |
We reviewed and analyzed the respective CMRT’s of our Relevant Suppliers and compared the information provided therein with the Compliant Smelter List of the Conflict Free Smelter Program, a list issued by the CFSI which aims to identify smelters and refiners that have systems in place to assure sourcing of only conflict-free materials. We rely on these Relevant Suppliers, whose components contain 3TG, to provide us with information about the source of conflict minerals contained in the components supplied to us. Our Relevant Suppliers are similarly reliant upon information provided by their suppliers.
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We identified and assessed two primary risks in our supply chain relating to our suppliers:
· | The risk of not receiving on time accurate information from the suppliers with respect to their sourcing of Conflict Minerals. |
· | The risk of not being able to replace a supplier, should we determine that there exists a risk of the supplier sourcing Conflict Minerals from sources that contribute to human rights abuses. |
The result of such risk assessment was the segmentation of our Relevant Suppliers into 3 levels of risks: high, medium and low to assist us with our risk mitigation efforts described in Section 2.2.3 below.
2.2.3 | Design and Implement a Strategy to Respond to Risks |
We implemented the following strategy. In so doing we focused our efforts based on the results of our risk assessment described in Section 2.2.2 above:
· | We reviewed the responses that we received and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to Relevant Suppliers who did not respond to our requests for information. |
· | We sent follow up letters to non-responding Relevant Suppliers and to Relevant Suppliers who declared they are sourcing conflict minerals from Covered Countries, asking them to complete their due diligence process in order to validate that all smelters in Covered Countries are compliant with the CFSI or other independent conflict free smelter validation program. |
· | Relevant senior management is briefed about our due diligence efforts, risk analysis results and mitigation efforts on a regular basis. |
2.2.4 | Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices |
We rely on industry-wide initiatives, such as the CFSI, to conduct risk assessment at the upstream level.
Since we do not have direct sourcing relationships with conflict mineral smelters or refiners, we did not perform direct audits of these entities within our supply chain.
2.2.5 | Report on supply chain due diligence |
This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals/ and is filed with the SEC.
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3. | Results of Assessment |
Based on information provided by our Relevant Suppliers as well as by CFSI, the results of our due diligence investigation as of the date of this Report are as follows:
· | We were successful in approaching almost all Relevant Suppliers. |
· | Out of the 193 Relevant Suppliers, 143 Relevant Suppliers (74.1%) completed and returned the CMRT’s to us. Based on the CMRT’s we received from these Relevant Suppliers (the "Responsive Relevant Suppliers"): |
· | Approximately 84.60% of the responses received provided data at a company or divisional level. All of the remaining Responsive Relevant Suppliers declared that information was provided at a product level, as shown in the following table: |
Category | Percentage of Responsive Relevant Suppliers |
Company level | 69.2% (99 from 143 suppliers) |
User defined | 15.4% (22 from 143 suppliers) |
Product list | 15.4% (22 from 143 suppliers) |
· | Most of our Responsive Relevant Suppliers were classified as "DD in Process from DRC" (see comment (e) below, based on an analysis of the returned CMRT’s, as shown in the following table: |
Category | Percentage of Responsive Relevant Suppliers |
Suppliers which were classified as “Not from DRC” (a) | 11.2% (16 from 143 suppliers) |
Suppliers which were classified as “DRC CFSP Compliant” (b) | 16.8% (24 from 143 suppliers) |
Suppliers which were classified as “Free no 3TG” (c) | 5.6% (8 from 143 suppliers) |
Suppliers which were classified as “DD in Process not from DRC” (d) | 11.2% (16 from 143 suppliers) |
Suppliers which were classified as “DD in Process from DRC” (e) | 55.2% (79 from 143 suppliers) |
(a) | Generally means that these suppliers were sourcing minerals from countries other than the Covered Countries. |
(b) | Generally means that the 3TG minerals being used in the products provided originate from Covered Countries but the smelters are approved by the CFSI Conflict Free Smelter Program |
(c) | Generally means that 3TG minerals are not necessary for the functionality or production of the products provided by these Responsive Relevant Suppliers. |
(d) | Generally means that, as of the date of this Report, the 3TG being used in the products supplied to Radware by these manufacturers do not originate from Covered Countries but such Responsive Relevant Suppliers have not yet concluded their due diligence process so this determination can potentially change. |
(e) | Generally means that, as of the date of this Report, such Responsive Relevant Suppliers discovered that 3TG they use in the products they provide Radware originate from Covered Countries and the smelters are approved by the CFSI program, but such Responsive Relevant Suppliers have not yet concluded their due diligence process so this determination can potentially change. |
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· | At least 45.50% of our Responsive Relevant Suppliers are also SEC registrants and are generally subject to the Rule themselves. |
· | Approximately 76.80% of our Responsive Relevant Suppliers stated to us that they implemented due diligence measures consistent with the OECD Guidance. |
· | Approximately 90.2% of our Responsive Relevant Suppliers stated to us that they have a policy in place that addresses conflict minerals sourcing. |
Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the facilities that may have been used to process the conflict minerals in Radware’s products may include the smelters and refiners listed in Annex I below.
Based on the information provided by the Responsive Relevant Suppliers as well as by CFSI, as of the date of this Report, Radware believes that the mine countries of origin of the conflict minerals contained in its products may include the countries listed in Annex II below.
The information gathered from our Responsive Relevant Suppliers is not on a continuous, real-time basis.
In addition, Radware can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information comes primarily from direct and secondary suppliers as well as from independent third party audit programs.
Lastly, given that most of our Responsive Relevant Suppliers were unable to provide information at product level, Radware cannot clearly identify the source of origin of the 3TG included in its products.
4. | Steps to be taken to mitigate risk |
We intend taking the following steps to improve the due diligence conducted to further mitigate the risk that the 3TG in our products finance or benefit armed groups in the Covered Countries:
· | Continue implementing follow up processes with regard to high-risk, non-responsive or non-compliant suppliers. |
· | As described in our Conflict Minerals Policy, to the extent we will have reason to believe that any of our suppliers who are supplying us with 3TG, receive such minerals from sources that may support conflict in the DRC or any adjoining country, we would encourage such suppliers to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD Guidance. |
· | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
· | Continue to direct our suppliers through our website and direct communications to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
· | Request suppliers to procure materials through validated smelters and take mitigating actions in case they do not. |
· | Continue to validate supplier responses using information collected via independent conflict free smelter validation programs, such as the CFSI. |
· | Continue to engage in regular ongoing risk assessment through our suppliers’ annual data submissions. |
· | Respond to risks based on the level of risk of the Relevant Supplier according to the segmentation we performed in the step described in Section 2.2.2 above. |
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Annex I – List of Smelters
Metal | Smelter Name | Smelter Country |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
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 Córrego do Sítio Mineração | BRAZIL |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
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 | Aurubis AG | GERMANY |
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. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | DODUCO GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Elemetal Refining, LLC | UNITED STATES |
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Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Faggi Enrico S.p.A. | ITALY |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Geib Refining Corporation | UNITED STATES |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Ltd. Hong Kong | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Company Limited | CHINA |
Gold | JSC Ekaterinburg Non-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 |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Company Limited | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
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Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) 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 | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
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) | RUSSIAN FEDERATION |
Gold | PAMP SA | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox SA | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint | CANADA |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
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 | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
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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 | Torecom | KOREA, REPUBLIC OF |
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 | 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 |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | 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 GmbH Goslar | GERMANY |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | JiuJiang JinXin Nonferrous 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 |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
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Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | Mineração Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining & Smelting | JAPAN |
Tantalum | Molycorp Silmet A.S. | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Plansee SE Liezen | AUSTRIA |
Tantalum | Plansee SE Reutte | AUSTRIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | 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 | CHINA |
Tin | Alpha | UNITED STATES |
Tin | An Thai Minerals Company Limited | VIET NAM |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | 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 | PT Justindo | INDONESIA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | CV Serumpun Sebalai | 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 | VIET NAM |
Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
Tin | EM Vinto | BOLIVIA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Feinhütte Halsbrücke GmbH | GERMANY |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
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Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Linwu Xianggui Ore Smelting 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 | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgical S.A. | BOLIVIA |
Tin | Phoenix Metal Ltd. | RWANDA |
Tin | PT Alam Lestari Kencana | INDONESIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Bangka Kudai Tin | INDONESIA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT BilliTin Makmur Lestari | 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 Fang Di MulTindo | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | PT Seirama Tin Investment | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Sukses Inti Makmur | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
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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 |
Tin | Thaisarco | THAILAND |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | VQB Mineral and Trading Group JSC | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck GmbH | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals 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 Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
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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 | Niagara Refining LLC | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
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Annex II – List of Mine Countries of Origin
Gold | Tantalum | Tin | Tungsten |
Australia | Australia | Bangka Island | China |
Belgium | Brazil | Bolivia | |
Canada | Canada | Brazil | |
Chile | China | China | |
China | Ethiopia | Indonesia | |
Germany | Japan | Malaysia | |
Hong Kong | Mozambique | Peru | |
Japan | Russia | USA | |
Korea, Republic of | Rwanda | ||
Mexico | USA | ||
South Africa | Zimbabwe | ||
Switzerland | |||
Taiwan |
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