Exhibit 1.01
Conflict Minerals Report
I. | Introduction |
A. | Our Business |
Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 85 divisions in 56 countries, and has prepared this Conflict Minerals Report for calendar year 2017 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the "Conflict Minerals Rule"). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.
The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as "in-scope" products). ITW’s in-scope products collectively contain all four 3TGs.
B. | Reasonable Country of Origin Inquiry and Due Diligence Overview |
As provided for in the Conflict Minerals Rule, we conducted a "reasonable country of origin inquiry" ("RCOI"), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2017.
If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we exercise due diligence on the source and chain of custody of the 3TG and include a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our products originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. This report is filed as an exhibit to our Form SD and is available on our website at http://www.itw.com/about-itw/suppliers/. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.
C. | ITW’s Position in the Supply Chain |
Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We therefore require the cooperation of our supply chain to provide information on smelters and refiners (“SORs”) as well as the origin of 3TG contained in our products, and we rely on the Responsible Minerals Initiative (the “RMI,” formerly known as the Conflict-Free Sourcing Initiative), whose mission is to help companies make sourcing decisions to improve regulatory compliance while supporting responsible sourcing from conflict-affected and high risk areas, and to manage the Responsible Minerals Assurance Process (the “RMAP”), which conducts and recognizes independent, third-party audits of SORs. We are a member of the RMI and actively participate in its initiatives, as discussed later in this Conflict Minerals Report.
D. | Responsible Sourcing Commitment |
Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) mandates compliance with all laws, and in particular prohibits use of child labor, forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, and anti-bribery laws.
E. | Smelter and Refiner and Country of Origin Information |
The Company’s in-scope products that contain 3TG that originated or might have originated from a Covered Country are described in Section IV. Product Information. Information about SORs relating to these in-scope products is described in Section V. Identified Smelters and Refiners and on Annex A. We have not found for 2017 that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not declared
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that any of our products are “DRC conflict free.” The terms "adjoining country," "armed group," and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.
F. | 2017 Program Enhancements |
For 2017, we took the following actions to enhance our RCOI and conflict minerals due diligence and mitigate sourcing risk. These actions build on further insights after several years of engaging in this process, and the 2016 enhancements described in our Conflict Minerals Report for that year.
Enhanced Identification of In-Scope Products and Suppliers
• | We enhanced training and materials for our internal 3TG compliance participants; |
Enhanced Smelter Outreach
• | We continued our participation in the RMI’s due diligence practices, multi-stakeholder and plenary teams and increased our participation in its smelter engagement team and in the Automotive Industry Action Group’s (“AIAG”) Conflict Minerals Working Group; |
General Process Enhancements
• | Additional data was made available to our internal sourcing team showing the progress of each of our locations in the RCOI process; |
• | We increased the level of assistance and support for our 3TG compliance team across the enterprise; |
• | We continued to revise and simplify our written communications and instructions to our businesses regarding supplier red flag follow-up to enhance program effectiveness; and |
• | We continued providing information and assistance at our enterprise-wide strategic sourcing conference, including a responsible sourcing training presentation covering 3TG, other materials of concern and modern slavery. |
II. | Reasonable Country of Origin Inquiry |
Our RCOI utilized management systems recommended by the first step of the Organisation for Economic Co-operation and Development's Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Third Edition) (the “OECD Guidance”), and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with these steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.
A. | Establish Strong Management Systems |
1. ITW Policies
ITW has adopted a company-wide Conflict Minerals Policy Statement (the "Conflict Minerals Policy"), which has been approved by ITW’s Chief Executive Officer and is available in seven languages on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. We also provide a copy of ITW’s Conflict Minerals Policy to every potential supplier participating in our online bid portal process whose product contains or may contain 3TG.
Our Conflict Minerals Policy states that we do not knowingly procure 3TG that originates from the Covered Countries unless they originate from mines or SORs that are certified as having followed established protocols to allow them to be considered “conflict free.” We ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing 3TG used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the SORs be certified as Conformant. The Conflict Minerals Policy encourages our suppliers to continue to support Conformant SORs in the Covered Countries and to make similar requests of their sub-suppliers. If we discover that any 3TG procured by us are produced in a Covered Country from facilities that are not Conformant, we will request that our supplier ask the facility to become Conformant or use our best efforts to transition the product to be from Conformant sources.
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ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions and bribery. The Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.
We do not support a general embargo of sourcing from the Covered Countries, and our Conflict Minerals Policy encourages our suppliers to continue to source from responsible sources in those countries.
2. Cross Functional Committee
ITW has a cross-functional responsible sourcing committee (the “Committee”). The Committee is headed by ITW’s Vice President of Global Strategic Sourcing & Environmental Health and Safety, who reports to ITW’s Vice Chairman, and includes dedicated employees and representatives from strategic sourcing, environmental, legal, internal audit, IT, corporate communications and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets as needed to discuss the 3TG compliance process, modern slavery and related developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.
3. Internal Training
We maintain an intranet conflict minerals website which contains resources, instructions and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including training videos regarding our RCOI and due diligence process, and can be accessed by all ITW businesses for reference. Our businesses are instructed to view at least one of the training sessions. Training was also presented to attendees of ITW’s global sourcing conference.
4. Supplier Engagement and Training
In addition to our Conflict Minerals Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” with its suppliers obligates suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements. We also include conflict minerals screening questions into incoming supplier bids.
Our supplier invitation letters are translated into eight languages. ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier meetings and other interactions. The training is intended to help ensure the quality and completeness of the Conflict Minerals Reporting Templates (“CMRTs”) received from suppliers. We also post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information. See http://www.itw.com/about-itw/suppliers/.
5. Records Retention
ITW retains its conflict minerals related records for at least five years. These records generally are maintained in an electronic format.
6. Grievance Mechanism
ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Conflict Minerals Policy.
A link to the Helpline is included in our Conflict Minerals Policy on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.
As an RMI member, we also support the use of the RMI’s grievance mechanism for reporting grievances relating to SORs and the RMAP.
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B. Identify and Assess Risk in the Supply Chain
Our RCOI process was used to survey our potential in-scope suppliers to identify and assess 3TG sourcing risk in our supply chain for the 2017 reporting cycle.
All ITW businesses were requested to identify suppliers furnishing components, parts or products containing or likely to contain 3TG or to confirm that their products do not contain 3TG. Those with products containing or likely to contain 3TG were asked to survey the “80” suppliers (i.e., suppliers representing a significant amount of spend) from that supplier population (we refer to the surveyed suppliers for 2017 as the “Suppliers”). The purpose of the survey was to determine whether 3TG in the components, parts or products from the Suppliers originated or may have originated from a Covered Country and were not from recycled or scrap sources. Businesses were instructed to survey the Suppliers using the then latest version of the RMI’s CMRT. The CMRT requests information regarding 3TG included in suppliers’ products, SOR identity and location, suppliers’ RCOI processes and other information about the suppliers’ 3TG policies and practices. We instructed our businesses to concentrate their outreach on larger suppliers, since these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.
ITW has an established protocol for its supplier inquiry process and uses a third party software vendor to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).
For 2017, as mentioned above, our businesses were asked to focus their efforts on their larger suppliers that likely had products containing 3TG. As a result, we sent 2,366 requests in eight languages to the Suppliers to provide us with a completed CMRT, as compared to 4,113 requests sent for 2016. A number of our businesses source different products from the same Supplier, which means the total number of unique suppliers is less than the number of Suppliers queried. We received 1,244 CMRTs from the Suppliers surveyed, as compared to 1,768 received for 2016. Our response rate increased from approximately 43% to 52% year-over-year.
The CM System issued automatic weekly follow-up reminders to non-responding Suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.
Our protocol also includes a follow-up process to investigate any CMRTs received that raised “red flags”. See Section III. Due Diligence for a description of the follow-up process.
Our Supplier responses identified 253 SORs verified by the RMI as Conformant. We determined that 214 of these Conformant SORs sourced exclusively from outside the Covered Countries, including in whole or in part from recycled or scrap sources. Our determination was based on country of origin information the RMI has obtained through the RMAP that is made available to RMI members.
Our Supplier responses identified an additional 9 SORs that were listed as “Active” (as later defined in Section III.B.) by the RMI and 52 that were on the Smelter Look-up tab of the CMRT but were not Conformant or Active.
A member of our conflict minerals team participated on the RMI’s Smelter Engagement Team, and, for the 52 SORs that were not listed as Conformant or Active with the RMI, we either asked them to become Conformant or instructed our businesses to request that their suppliers remove them from their supply chains.
Based on the results of our RCOI, we were required to conduct due diligence, as described below.
III. | Due Diligence |
A. | Design Framework |
ITW´s conflict minerals due diligence process is designed in conformance with the related third, fourth and fifth steps of the OECD Guidance.
B. | Due Diligence Activities |
Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant
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to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2017 program enhancements discussed in Section I. Introduction.
Design and implement a strategy to respond to identified risks
The SOR information provided by Suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter Look-up tab list in the CMRT. SOR information also was reviewed against the lists of Conformant, Active and other SORs not listed as Conformant or Active and country-of-origin information provided by the RMI and contained in the CM System. “Conformant” SORs have been audited and found conformant with the RMAP assessment protocols, including through mutual recognition and those that are listed as “re-audit in process.” “Active” SORs are those that are taking action to become Conformant.
CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country or that contained inconsistent SOR information triggered a “red flag” in the CM System, and communications with the flagged Suppliers were escalated. Businesses and their respective flagged Suppliers indicating 3TG from a source within a Covered Country were asked to provide additional information, and our businesses were given written guidance and instructions for these Supplier communications. The escalated Supplier responses were evaluated on a case-by-case basis. Suppliers with CMRTs containing inconsistent SOR information were asked to resubmit a corrected CMRT.
In addition, we either reached out directly to the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant, or instructed our businesses to request that their Suppliers remove them from their supply chains. SORs that were categorized by the RMI as “not applicable” were not addressed in our outreach efforts, as the RMI has determined that these are either not SORs or not in operation. To the extent that identified SORs are not Conformant, we also seek to exercise leverage over these SORs to become Conformant through our participation in and support of the RMI and its Smelter Engagement Team. We also utilize information provided by the RMI to its members to monitor SOR improvement.
In 2017, we continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness.
Our 3TG compliance team reported the findings from its RCOI and due diligence process to our Vice President of Global Strategic Sourcing, and these results were in turn discussed with senior management.
Carry out independent third party audit of supply chain diligence at identified points in the supply chain
The Company continued its membership in the RMI for 2017. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the RMI’s RMAP to perform third-party audits of SORs.
Report annually on supply chain due diligence
We describe our supply chain due diligence efforts in our Conflict Minerals Report. We prepare this report annually, post it on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website. We also mention our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report, which is available on our website at https://itw-csr.com/.
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IV. | Product Information |
For 2017, our in-scope products that contain 3TG that originated or might have originated from a Covered Country included products in each of the categories below:
Arc welding and cutting equipment and consumables | Inspection equipment |
Automotive components | LEDs |
Catalysts | Marking and coding equipment |
Commercial cooking equipment | Measuring equipment |
Commercial food equipment | Mixers |
Commercial refrigerators | Motors |
Cutting equipment | Printers and dispensers |
Electrical devices | Production equipment |
Electronic components | Sealants |
Electronic equipment | Sealing equipment |
Fastening tools | Soldering equipment |
Flow control meters | Switches, capacitors and electronics |
Household appliances | Testing equipment |
Industrial equipment | Welding hardware |
Industrial ovens | Wire |
Industrial warewashers |
V. | Identified Smelters and Refiners |
Our Supplier responses identified 253 SORs that were on the RMI Conformant list, 9 that were listed as Active with the RMI and 52 that were on the Smelter Look-up tab list of the CMRT but not Conformant or Active with the RMI. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as SORs that were on the Smelter Look-up tab list contained in the CM System as of March 26, 2018, which are those entities identified to us that we were able to determine were SORs. Entities identified by our Suppliers that are not on Annex A have been submitted to the RMI to support their ongoing effort to identify and audit all 3TG SORs.
Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products. The information that we received from most of our Suppliers was made at a company or user defined level, rather than at a product level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed in Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, since we do not have a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain and because we surveyed only the larger suppliers of products containing or potentially containing 3TG.
Annex A includes information concerning the locations of the SORs listed. We applied the information made available to RMI members regarding the countries of origin of these SORs and have not found for 2017 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.”
VI. | Additional Risk Mitigation |
In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take or continue the following steps in respect of our 2018 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:
• | Continue to analyze and review our current processes to improve their effectiveness and efficiency. |
• | Continue to analyze spend data against supplier response data to identify inconsistencies and areas of potential enhanced focus for supplier outreach efforts. |
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• | Engage with Suppliers that provided incomplete responses or that did not provide responses for 2017 to help ensure that they will provide requested information for 2018. |
• | Continue to enhance supplier communication and training to improve RCOI and due diligence data accuracy and completion. |
• | Continue to seek to influence non-Conformant SORs in our supply chain to obtain a Conformant certification. |
• | Continue our membership in the RMI and participation in its Plenary, Multi-Stakeholder, Due Diligence and Smelter Engagement Teams and support the RMI’s RMAP program. |
• | Continue our membership and participation in the Automotive Industry Action Group’s (AIAG) Conflict Minerals Working Group. |
• | Continue to submit to the RMI facilities identified by our Suppliers that are not on the Smelter Look-up tab list, to support the RMI's ongoing effort to identify and audit all 3TG SORs. |
VII. | Forward Looking Statements |
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to identify improvements to our due diligence processes, to engage with our suppliers, and to take other actions regarding our product sourcing. These statements are subject to certain risks, uncertainties and other factors, including but not limited to, incomplete information from industry or other third party sources, continuing guidance regarding the Conflict Minerals Rule, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.
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Annex A to Exhibit 1.01 |
RMI Smelters and Refiners |
Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status | ||||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant | ||||
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Conformant | ||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant | ||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant | ||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant | ||||
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant | ||||
Gold | Asahi Pretec Corp. | JAPAN | Conformant | ||||
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant | ||||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant | ||||
Gold | AU Traders and Refiners | SOUTH AFRICA | Conformant | ||||
Gold | Aurubis AG | GERMANY | Conformant | ||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant | ||||
Gold | Boliden AB | SWEDEN | Conformant | ||||
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant | ||||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant | ||||
Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant | ||||
Gold | Chimet S.p.A. | ITALY | Conformant | ||||
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Conformant | ||||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant | ||||
Gold | Dowa | JAPAN | Conformant | ||||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant | ||||
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant | ||||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant | ||||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant | ||||
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Conformant | ||||
Gold | Heimerle + Meule GmbH | GERMANY | Conformant | ||||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant | ||||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant | ||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant | ||||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant | ||||
Gold | Istanbul Gold Refinery | TURKEY | Conformant | ||||
Gold | Italpreziosi | ITALY | Conformant | ||||
Gold | Japan Mint | JAPAN | Conformant | ||||
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
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Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Conformant | ||||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Conformant | ||||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant | ||||
Gold | Kazzinc | KAZAKHSTAN | Conformant | ||||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant | ||||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant | ||||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Conformant | ||||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant | ||||
Gold | Marsam Metals | BRAZIL | Conformant | ||||
Gold | Materion | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant | ||||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant | ||||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant | ||||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant | ||||
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant | ||||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant | ||||
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant | ||||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | ||||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant | ||||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Conformant | ||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant | ||||
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant | ||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant | ||||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant | ||||
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Conformant | ||||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Conformant | ||||
Gold | PAMP S.A. | SWITZERLAND | Conformant | ||||
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant | ||||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Conformant | ||||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant | ||||
Gold | PX Precinox S.A. | SWITZERLAND | Conformant | ||||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant | ||||
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Royal Canadian Mint | CANADA | Conformant | ||||
Gold | SAAMP | FRANCE | Conformant | ||||
Gold | Safimet S.p.A | ITALY | Conformant | ||||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant | ||||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Conformant | ||||
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Conformant |
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Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant | ||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant | ||||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant | ||||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant | ||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Conformant | ||||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant | ||||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant | ||||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant | ||||
Gold | T.C.A S.p.A | ITALY | Conformant | ||||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant | ||||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant | ||||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant | ||||
Gold | Torecom | KOREA, REPUBLIC OF | Conformant | ||||
Gold | Umicore Brasil Ltda. | BRAZIL | Conformant | ||||
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant | ||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant | ||||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant | ||||
Gold | Valcambi S.A. | SWITZERLAND | Conformant | ||||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant | ||||
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant | ||||
Gold | Yamakin Co., Ltd. | JAPAN | Conformant | ||||
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant | ||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant | ||||
Gold | Bangalore Refinery | INDIA | Active | ||||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Active | ||||
Gold | L'Orfebre S.A. | ANDORRA | Active | ||||
Gold | Modeltech Sdn Bhd | MALAYSIA | Active | ||||
Gold | Remondis Argentia B.V. | NETHERLANDS | Active | ||||
Gold | SAFINA A.S. | CZECH REPUBLIC | Active | ||||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List | ||||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Smelter Look-up List | ||||
Gold | Caridad | MEXICO | On Smelter Look-up List | ||||
Gold | Chugai Mining | JAPAN | On Smelter Look-up List | ||||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | On Smelter Look-up List | ||||
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List | ||||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | On Smelter Look-up List | ||||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | On Smelter Look-up List | ||||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Smelter Look-up List | ||||
Gold | Guangdong Jinding Gold Limited | CHINA | On Smelter Look-up List |
10
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | On Smelter Look-up List | ||||
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Smelter Look-up List | ||||
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Smelter Look-up List | ||||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | On Smelter Look-up List | ||||
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | On Smelter Look-up List | ||||
Gold | Lingbao Gold Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Morris and Watson | NEW ZEALAND | On Smelter Look-up List | ||||
Gold | Morris and Watson Gold Coast | AUSTRALIA | On Smelter Look-up List | ||||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | On Smelter Look-up List | ||||
Gold | Pease & Curren | UNITED STATES OF AMERICA | On Smelter Look-up List | ||||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | On Smelter Look-up List | ||||
Gold | Sai Refinery | INDIA | On Smelter Look-up List | ||||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | On Smelter Look-up List | ||||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | On Smelter Look-up List | ||||
Gold | Sudan Gold Refinery | SUDAN | On Smelter Look-up List | ||||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Gold | Tony Goetz NV | BELGIUM | On Smelter Look-up List | ||||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | On Smelter Look-up List | ||||
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | On Smelter Look-up List | ||||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant | ||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant | ||||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant | ||||
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant | ||||
Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant | ||||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant | ||||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant | ||||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant | ||||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
11
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | H.C. Starck Ltd. | JAPAN | Conformant | ||||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | ||||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant | ||||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant | ||||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant | ||||
Tantalum | KEMET Blue Metals | MEXICO | Conformant | ||||
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conformant | ||||
Tantalum | LSM Brasil S.A. | BRAZIL | Conformant | ||||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant | ||||
Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant | ||||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant | ||||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant | ||||
Tantalum | NPM Silmet AS | ESTONIA | Conformant | ||||
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Conformant | ||||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant | ||||
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant | ||||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant | ||||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant | ||||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant | ||||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant | ||||
Tantalum | Duoluoshan | CHINA | On Smelter Look-up List | ||||
Tin | Alpha | UNITED STATES OF AMERICA | Conformant | ||||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant | ||||
Tin | China Tin Group Co., Ltd. | CHINA | Conformant | ||||
Tin | CV Ayi Jaya | INDONESIA | Conformant | ||||
Tin | CV Dua Sekawan | INDONESIA | Conformant | ||||
Tin | CV Gita Pesona | INDONESIA | Conformant | ||||
Tin | CV Tiga Sekawan | INDONESIA | Conformant | ||||
Tin | CV United Smelting | INDONESIA | Conformant | ||||
Tin | CV Venus Inti Perkasa | INDONESIA | Conformant | ||||
Tin | Dowa | JAPAN | Conformant | ||||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
12
Tin | Fenix Metals | POLAND | Conformant | ||||
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant | ||||
Tin | Gejiu Jinye Mineral Company | CHINA | Conformant | ||||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant | ||||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant | ||||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant | ||||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant | ||||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant | ||||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant | ||||
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conformant | ||||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant | ||||
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant | ||||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant | ||||
Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant | ||||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant | ||||
Tin | Metallo Belgium N.V. | BELGIUM | Conformant | ||||
Tin | Metallo Spain S.L.U. | SPAIN | Conformant | ||||
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant | ||||
Tin | Minsur | PERU | Conformant | ||||
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant | ||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant | ||||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant | ||||
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant | ||||
Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant | ||||
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant | ||||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant | ||||
Tin | PT Babel Inti Perkasa | INDONESIA | Conformant | ||||
Tin | PT Bangka Prima Tin | INDONESIA | Conformant | ||||
Tin | PT Bangka Tin Industry | INDONESIA | Conformant | ||||
Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant | ||||
Tin | PT Bukit Timah | INDONESIA | Conformant | ||||
Tin | PT DS Jaya Abadi | INDONESIA | Conformant | ||||
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant | ||||
Tin | PT Inti Stania Prima | INDONESIA | Conformant | ||||
Tin | PT Karimun Mining | INDONESIA | Conformant | ||||
Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant | ||||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant | ||||
Tin | PT Menara Cipta Mulia | INDONESIA | Conformant | ||||
Tin | PT Mitra Stania Prima | INDONESIA | Conformant | ||||
Tin | PT O.M. Indonesia | INDONESIA | Conformant | ||||
Tin | PT Panca Mega Persada | INDONESIA | Conformant | ||||
Tin | PT Premium Tin Indonesia | INDONESIA | Conformant | ||||
Tin | PT Prima Timah Utama | INDONESIA | Conformant | ||||
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
13
Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant | ||||
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant | ||||
Tin | PT Sukses Inti Makmur | INDONESIA | Conformant | ||||
Tin | PT Sumber Jaya Indah | INDONESIA | Conformant | ||||
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant | ||||
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Conformant | ||||
Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant | ||||
Tin | PT Tommy Utama | INDONESIA | Conformant | ||||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant | ||||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant | ||||
Tin | Soft Metais Ltda. | BRAZIL | Conformant | ||||
Tin | Thaisarco | THAILAND | Conformant | ||||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant | ||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant | ||||
Tin | Yunnan Tin Company Limited | CHINA | Conformant | ||||
Tin | Modeltech Sdn Bhd | MALAYSIA | Active | ||||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Smelter Look-up List | ||||
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | On Smelter Look-up List | ||||
Tin | Estanho de Rondonia S.A. | BRAZIL | On Smelter Look-up List | ||||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List | ||||
Tin | Super Ligas | BRAZIL | On Smelter Look-up List | ||||
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List | ||||
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant | ||||
Tungsten | ACL Metais Eireli | BRAZIL | Conformant | ||||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant | ||||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant | ||||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant | ||||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant | ||||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant | ||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant | ||||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant | ||||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
14
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant | ||||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant | ||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant | ||||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant | ||||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant | ||||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant | ||||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Conformant | ||||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant | ||||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant | ||||
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant | ||||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant | ||||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant | ||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant | ||||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Active | ||||
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Active | ||||
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List | ||||
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Look-up List |
Country of Origin Information
The countries of origin of the 3TG processed by the Conformant SORs listed above may have included minerals from the respective countries listed below. The listed countries of origin are derived from information made available by the RMI to its members. Except for the DRC, the RMI does not indicate individual countries of origin of the 3TG processed by Conformant SORs. Instead, the RMI indicates country of origin by category. Conformant SORs listed above sourced minerals directly and/or indirectly (second tier smelter) from one or more of the following categories: L1, countries not identified as conflict regions or plausible areas of smuggling or export of 3TG from the DRC and its nine adjoining countries; L2, countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG; L3, which includes the DRC and its nine adjoining countries; and/or the DRC.
L1: Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, the Russian Federation, Senegal, Sierra Leone, Spain, Thailand, Togo, the
15
United Kingdom of Great Britain and Northern Ireland, the United States of America, Uzbekistan, Vietnam, Zimbabwe
L2: Mozambique, South Africa
L3: Burundi, Rwanda, Uganda
DRC: Democratic Republic of the Congo
In addition, according to information made available by the RMI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.
Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant SORs, we were not able to determine the countries of origin of the 3TG processed by the listed Conformant SORs with greater specificity. In addition, for some of the listed Conformant SORs, origin information is not disclosed. We did not determine the countries of origin of the 3TG processed by any other SORs listed on this Annex A.
16