Exhibit 1.01
Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2017
This Conflict Minerals Report for the year ended December 31, 2017 (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, tungsten and Gold (“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's products that were manufactured or contracted to be manufactured, during calendar year 2017 and that may contain 3TG minerals and that are necessary to the functionality or production of the products manufactured or to the products contracted to be manufactured.
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.
As part of Radware's Labor Practice and Human Rights Policy, Radware respects the protection of human rights, including the basic human rights of employees and workers. The Company aims to uphold the human rights of those affected by its business activities, and in particular, of the workers engaged in its supply chain. Accordingly, the Company aspires to source components and materials from suppliers that share our values regarding respect for human rights, integrity and environmental responsibility, and that comply with applicable legal standards and requirements.
1. | Overview |
Company Overview
We are a provider of cyber security and application delivery solutions that help our customers to secure the digital experience for users of business-critical applications in virtual, cloud and software defined data centers. Our solutions are deployed by, among others, enterprises, carriers and cloud service providers. We offer a set of solutions that are designed to ensure application service levels are guaranteed at all times, in any operational scenario, and to optimize business operations, minimize service delivery degradation and prevent downtime. Our solutions are offered in three main categories including products, product subscriptions and services. We sell our products primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, whereas most of our direct sales are 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, although in small quantities.
The products that we manufacture are highly complex, typically containing thousands of parts from 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 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. However, as we enter into new supply contracts or renew existing supply contracts, we seek to add, where feasible, a conflict minerals contract clause that requires the relevant supplier to provide us with information about the source of 3TG and relevant smelters and refiners.
Reasonable Country of Origin Inquiry (RCOI)
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 the suppliers that represented as of December 31, 2017, in aggregate, at least 90% of our spend on the manufacturing costs of our finished products that were shipped in 2017. We identified in total 5 relevant suppliers (the “Relevant Suppliers”), compared with 184 in our Conflict Minerals Report for the year ended December 31, 2016, 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. The decrease in the number of Relevant Suppliers compared to 2016 primarily derives from accepting the CMRTs of our original design manufacturer ("ODMs") suppliers and focusing on strategic suppliers that we purchase from directly. We changed our approach and accepted the CMRTs of our ODMs based on our agreement with such ODMs pursuant to which they assumed responsibility over their sub-suppliers.
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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 version 5.01 and above (“CMRT”), an industry-standard template for conflict mineral reporting developed by the Responsible Minerals Initiative (formerly known as the Conflict-Free Sourcing Initiative, or CFSI) (the "RMI").
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. Out of the 5 Relevant Suppliers, 5 Relevant Suppliers (100%) completed and returned CMRTs to us.
Based on these efforts, we believe 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.
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 internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD") known as "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas" and related Supplements for Tin, Tantalum and Tungsten and for Gold (the “OECD Guidance”). We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners.
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") that is aimed at achieving responsible sourcing. The Policy 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 a steering committee headed by the Company's Legal Department (the “CM Steering Committee”), and a team of subject matter functions such as supplier management, operations and legal.
Supply Chain Control Systems and Transparency
We requested that all Relevant Suppliers provide information to us regarding 3TG and relevant smelters or refiners using the CMRT.
We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the sourcing of minerals originating from conflict affected and high-risk areas that are under scrutiny for human right abuses, i.e. the DRC and Covered Countries.
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Controls included a company-wide code of conduct that outlines expected behaviors from all our employees as well as engaging a Third Party Vendor to assist us in collecting and analyzing relevant data and in maintaining a smelter or refiner database.
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. 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 grievance in relation to our Conflict Minerals Policy.
Maintaining 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 five (5) year duration recommended by the OECD Guidance. The CMR Dashboard stores current and former CMRTs received from suppliers to maintain traceability and transparency.
Supplier Engagement
We maintain an electronic portal that directs suppliers to resources related to Conflict Minerals, including FAQs from the SEC.
We established a Conflict Minerals webpage to host 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.
As we enter into new supply contracts or renew existing supply contracts, we seek to add, where feasible, a conflict minerals contract clause that requires suppliers to provide us with information about the source of 3TG and relevant smelters or refiners.
2.2.2 | Identify and Assess Risks in the Supply Chain |
We approached our 5 Relevant Suppliers and received responses from 5 Relevant Suppliers representing 100% of the Relevant Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our Relevant Suppliers and compared the information provided therein with the Standard Smelter List of Compliant and Active Smelters from the Responsible Minerals Assurance Process (RMAP), a list issued by RMI that aims to identify smelters and refiners that have systems in place to assure the sourcing of 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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2.2.3 | Design and Implement a Strategy to Respond to Risks |
We implemented the following strategy to address the results of our risk assessment described in Section 2.2.2 above. The goal of the design and implementation strategy is not to eliminate sourcing from the DRC and Covered Countries, but to encourage participation with the RMI and other relevant bodies, where possible:
· | The CM Steering Committee held meetings to review progress and assess the risks identified. |
· | 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, where applicable, follow up letters to unresponsive Relevant Suppliers and to Relevant Suppliers who declared they sourced 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 RMI or other independent conflict free smelter validation programs, such as the London Bullion Market (LBMA) or the Responsible Jewelry Council (RJC). |
· | Relevant senior management, including our Vice President and General Counsel, was briefed on our due diligence efforts, risk analysis results and mitigation efforts. |
· | We approached Relevant Suppliers that we identified as possibly sourcing from smelters or refiners located in the Covered Countries that did not receive a conflict free designation from the RMI, and asked for a corrective action plan. |
2.2.4 | Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices |
We rely on industry-wide initiatives, such as RMI, to conduct risk assessments 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 |
Our supply chain conflict mineral due diligence efforts are described in this report. This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals/ and is filed with the SEC.
3. | Results of Assessment |
Based on information provided by our Relevant Suppliers as well as by RMI, the results of our due diligence investigation on the dates covered by this Report, are as follows:
· | We were successful in approaching all Relevant Suppliers. |
· | Out of the 5 Relevant Suppliers, 5 Relevant Suppliers (100%) completed and returned the CMRTs to us. Based on the CMRTs we received from these Relevant Suppliers (the "Responsive Relevant Suppliers"): |
o | 100% of the responses received provided data at a company or user-defined level. None 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 | 80% (4 out of 5 suppliers) |
User defined | 20% (1 out of 5 suppliers) |
Product list | 0% (0 out of 5 suppliers) |
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· | We identified 306 smelters or refiners that may be involved in our supply chain, out of which 83% are either recognized as conflict free by RMI (each a “Compliant Smelter”) or are committed to undergo an RMAP audit. Analysis of information about these 306 smelters is provided in the following diagrams: |
Based on the information provided by the Responsive Relevant Suppliers as well as by RMI, 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 RMI, as of the date of this Report, Radware believes that the 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 collected on a continuous, real-time basis.
In addition, Radware can only provide reasonable and good faith, yet 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 or origin of the 3TG included in its products.
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4. | Future Risk Mitigation Efforts |
We currently intend to continue working with our global supply chain to achieve responsible sourcing of minerals from conflict areas and comply with applicable regulations to the extent that they are required:
· | Continue implementing risk management measurement and follow up processes with regard to non-responsive or non-compliant suppliers. |
· | As described in our Conflict Minerals Policy, to the extent we have reason to believe that any of our suppliers supply 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 outlined in the OECD Guidance. Such methods are important to us as we are committed to discouraging human rights abuses. |
· | 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 pursuant to the RMI or other approved resources and request our suppliers to take mitigating actions in case they do not. |
· | Continue to validate supplier responses using information collected via independent conflict free smelter validation programs, such RMI's RMAP program. |
· | Continue to engage in regular and ongoing risk assessment through our suppliers’ annual data submissions. |
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Annex I – List of Smelters
Metal | Smelter Look-Up | Smelter Country |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | 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 + Metaux S.A. | SWITZERLAND |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
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 | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
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Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
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 |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
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Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | PAMP S.A. | 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 Precinox S.A. | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Royal Canadian Mint | CANADA |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
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Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyeria Plateria S.A. | 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 | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Morris and Watson | NEW ZEALAND |
Gold | SAFINA A.S. | CZECH REPUBLIC |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
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Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Sudan Gold Refinery | SUDAN |
Gold | T.C.A S.p.A | ITALY |
Gold | Remondis Argentia B.V. | NETHERLANDS |
Gold | Tony Goetz NV | BELGIUM |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Marsam Metals | BRAZIL |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
Gold | SAAMP | FRANCE |
Gold | Italpreziosi | ITALY |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
Gold | Sai Refinery | INDIA |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Bangalore Refinery | INDIA |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
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Gold | SungEel HiTech | KOREA, REPUBLIC OF |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tantalum | Duoluoshan | CHINA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck 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 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
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 OF AMERICA |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
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Tantalum | Mineracao Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | NPM Silmet AS | ESTONIA |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Dua Sekawan | INDONESIA |
Tin | CV Gita Pesona | 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 | VIET NAM |
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Tin | Elmet S.L.U. | SPAIN |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Estanho de Rondonia 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 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
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 OF AMERICA |
Tin | Metallo-Chimique N.V. | BELGIUM |
Tin | Mineracao Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
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 |
15
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
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 DS Jaya Abadi | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
Tin | PT Menara Cipta Mulia | 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 Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
16
Tin | PT Tommy Utama | INDONESIA |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Super Ligas | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan 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 OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
17
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 OF AMERICA |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
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Annex II – Country of Origin Inquiry (COO)
Gold | Tantalum | Tin | Tungsten |
AFGHANISTAN | AUSTRALIA | ARGENTINA | AUSTRALIA |
ALBANIA | BOLIVIA | AUSTRIA | BOLIVIA |
ARGENTINA | BRAZIL | BELGIUM | CANADA |
AUSTRALIA | BURUNDI | BOLIVIA | CHINA |
AUSTRIA | CANADA | BRAZIL | DEMOCRATIC REPUBLIC OF CONGO |
AZERBAIJAN | CHINA | BURUNDI | INDONESIA |
BELGIUM | DEMOCRATIC REPUBLIC OF CONGO | CAMBODIA | MOZAMBIQUE |
BERMUDA | ETHIOPIA | CANADA | PERU |
BOLIVIA | GERMANY | CHILE | PORTUGAL |
BRAZIL | INDIA | CHINA | RUSSIAN FEDERATION |
BULGARIA | JAPAN | COLOMBIA | SPAIN |
BURKINA FASO | KAZAKHSTAN | ECUADOR | UNITED STATES OF AMERICA |
CAMBODIA | MOZAMBIQUE | ETHIOPIA | VIETNAM |
CANADA | NAMIBIA | GERMANY | |
CHILE | NIGERIA | GUYANA | |
CHINA | PORTUGAL | HUNGARY | |
DOMINICAN REPUBLIC | RUSSIAN FEDERATION | INDIA | |
ECUADOR | RWANDA | INDONESIA | |
ETHIOPIA | SIERRA LEONE | JAPAN | |
FINLAND | SPAIN | KAZAKHSTAN | |
GERMANY | THAILAND | LAOS | |
GHANA | UNITED STATES OF AMERICA | LUXEMBOURG | |
GUINEA | VIETNAM | MALAYSIA |
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GUYANA | MONGOLIA | ||
HUNGARY | MYANMAR | ||
INDIA | NAMIBIA | ||
INDONESIA | PAPUA NEW GUINEA | ||
IRELAND | PERU | ||
ITALY | PORTUGAL | ||
JAPAN | RUSSIAN FEDERATION | ||
KAZAKHSTAN | RWANDA | ||
KENYA | TAIWAN | ||
KYRGYZSTAN | THAILAND | ||
LAOS | THE REPUBLIC OF KOREA | ||
LIBERIA | UGANDA | ||
LUXEMBOURG | UNITED STATES OF AMERICA | ||
MALAYSIA | VIET NAM | ||
MAURITANIA | |||
MEXICO | |||
MONGOLIA | |||
MOZAMBIQUE | |||
MYANMAR | |||
NAMIBIA | |||
PERU | |||
RUSSIAN FEDERATION | |||
SINGAPORE | |||
SOUTH AFRICA |
20
SPAIN | |||
SWEDEN | |||
SWITZERLAND | |||
TAIWAN | |||
TANZANIA | |||
THE NETHERLANDS | |||
THE REPUBLIC OF KOREA | |||
TURKEY | |||
UNITED KINGDOM | |||
UNITED STATES OF AMERICA | |||
UZBEKISTAN | |||
VIETNAM | |||
ZIMBABWE |
21