UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, DC 20549
FORM SD
Specialized Disclosure Report
UNIVERSAL FOREST PRODUCTS, INC.
(Exact Name of Registrant as Specified in Charter)
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Michigan |
00-22684 |
38-1465835 |
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(State or Other Jurisdiction of Incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
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2801 East Beltline, N.E. Grand Rapids, Michigan |
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49525 |
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(Address of principal executive office) |
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(Zip Code) |
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David A. Tutas |
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Vice President, General Counsel, and Secretary |
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(616) 364-6161 |
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(Name and Telephone number, including area code, of the person to contact in connection with this report.) |
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Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
[X] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016.
SECTION 1 – Conflict Minerals Disclosure
Item 1.01Conflict Minerals Disclosure and Report.
Universal Forest Products, Inc. has included the Conflict Minerals Report as an exhibit to its Form SD for the period from January 1, 2016 to December 31, 2016. Unless the context otherwise indicates, “Universal Forest Products,” “we,” “us” and “our” refer to Universal Forest Products, Inc. and its consolidated subsidiaries.
During 2016, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production (the “Covered Products”). Conflict minerals are defined in Section 13(p) as (A) gold, cassiterite, columbite-tantalite (coltan), wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively referred to as “3TGs”), or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. Accordingly, we have conducted a reasonable country of origin inquiry (“RCOI”) that was designed to determine whether any of the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.
A summary of our RCOI and steps of due diligence on the source and chain of custody of any 3TGs in our Covered Products is included in our Conflict Minerals Report, which is filed as Exhibit 1.01 to this Form SD. In addition to this, our Conflict Minerals Report and Form SD is publicly available on our company website at: http://www.ufpinvestor.com/phoenix.zhtml?c=116957&p=irol-corporateGovernance.
Forward-Looking Statements
This Form SD and the Conflict Minerals Report contains forward-looking statements which express a belief, expectation or intention, as well as those that are historical fact, and include statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” and “anticipates” and similar expressions are used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and involve certain risks, uncertainties and assumptions that are difficult to predict with regards to timing, extent, likelihood and degree of occurrence. We do not undertake to update forward-looking statements to reflect facts, circumstances, events, or assumptions that occur after the date the forward-looking statements are made. Actual results could differ materially from those included in such forward-looking statements. Investors are cautioned that all forward-looking statements involve risk and uncertainty. Undue reliance should not be placed on these forward-looking statements.
Item 1.02Exhibit.
We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Item 2.01 Exhibits.
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01. and 1.02 of Form SD.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
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UNIVERSAL FOREST PRODUCTS, INC. |
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Dated: May 31, 2017 |
By: |
/s/ Michael R. Cole |
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Michael R. Cole |
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Chief Financial Officer and Treasurer |
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EXHIBIT INDEX
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Exhibit Number |
Description |
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1.01 |
Conflict Minerals Report for the year ended December 31, 2016 as required by Items 1.01 and 1.02 of this Form. |
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EXHIBIT 1.01
Universal Forest Products, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2016
Introduction
This Conflict Minerals Report (the “Report”) has been prepared by Universal Forest Products, Inc. for the period from January 1, 2016 to December 31, 2016 (the “Reporting Period”). Unless the context otherwise indicates, “Universal Forest Products,” “we,” “us,” the “Company” and “our” mean Universal Forest Products, Inc. and its consolidated subsidiaries.
This Report is presented to comply with Rule 13p-1 promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended (the “Rule”). This Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as gold, cassiterite, columbite-tantalite, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (collectively, the “3TGs”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this Report, we have reason to believe that some of the 3TGs present in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TG from the Covered Countries and proceeded to conduct due diligence on our supplier base. The results of our RCOI and due diligence are covered below.
Company Overview
Our business
We design, manufacture and market: wood and wood-alternative products for national home centers and other retailers, structural lumber and other products for the manufactured housing industry, engineered wood components for residential and commercial construction, specialty wood packaging, components and packing materials for various industries, and customized interior fixtures used in a variety of retail stores, commercial and other structures.
For additional information, please see Item 1 (captioned “Business”) in our Form 10-K for our fiscal year ending December 31, 2016 filed on March 1, 2017.
Our products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in certain of our products within our segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period. Our broad and complex range of products may contain 3TGs within the following components: non-lumber items sold to retailers (e.g. fencing systems and components, solar powered post caps, and doorbells), industrial products (e.g. pallets, skids, crates, specialty wood or alternative material packaging, and strapping), structural lumber products for the site-built market (e.g. roof trusses, floor trusses, and wall panels), and interior fixtures (e.g. shelving, display cases, and lighting).
Description of RCOI
We began our scoping process by extracting a list of our suppliers that provide us with products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party service provider. This supplier list was then uploaded to our third-party service provider’s software platform that allows us to store and manage supplier requests and documentation.
From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed provided items to Universal Forest Products that were used in final products in the year 2016. Through this process, we removed 31 suppliers from in scope for the 2016 reporting period.
Our third-party service provider then conducted the supplier survey portion of the RCOI utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 4.20, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, and the suppliers identified through the procedures above were surveyed on their sourcing of the 3TG that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by those facilities.
During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform. Non-responsive suppliers were contacted a minimum of three times and then were also guided by our service provider’s team in one on one communications. This included four follow ups in order to encourage their response via CMRTs. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party service provider have provided training to suppliers though webinars, videos, documentation, and one-on-one discussions.
The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 1, 2017, there were 13 invalid submissions that were not corrected by suppliers.
Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.
Due Diligence
Design of due diligence
We have designed our due diligence procedures 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 and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the “Guidance”).
Our conflict minerals due diligence process includes the five steps as defined by the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by us is outlined below.
Due diligence performed
Establish Strong Company Management Systems
Internal team
We have organized a Conflict Minerals Committee comprised of individuals in the legal department, including a senior attorney. As needed, other management personnel from multiple departments participate and/or assist the Conflict Minerals Committee. The Conflict Minerals Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and overseeing the program.
We have also taken on other management systems that include the use of a third-party vendor. Through our vendor’s tool we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
Control systems
Controls include, but are not limited to, our Code of Business Conduct and Ethics, regular monitoring of changes in applicable laws, regulations, and guidance, whistleblower mechanisms, regular training of key employee groups, and on-site visits and audits of our suppliers.
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.10 or higher and a third-party vendor’s software reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products.
Grievance mechanism
We maintain several methods in which employees or third parties may notify us of potential issues with our conflict minerals program, including an anonymous employee hotline, email resources both internally and on our website, direct phone numbers, and our open door policy.
Maintain records
We maintain company-wide document retention policies. These policies extend to the documentation accumulated in performing our 3TG due diligence procedures and requires that documentation will be retained for a period of five (5) years.
Identify and Assess Risks in the Supply Chain
It is important to note that Universal Forest Products has relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
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1. |
Geographic proximity to the DRC and Covered Countries; |
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2. |
Conflict-Free Smelter Program (CFSP) audit status; |
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3. |
Known or plausible evidence of unethical or conflict sourcing. |
Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
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Tony Goetz NV - CID002587 |
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Kaloti Precious Metals - CID002563 |
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Phoenix Metals - CID002507 |
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Universal Precious Metals Refining Zambia - CID002854 |
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Fidelity Printers and Refiners - CID002515 |
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Sudan Gold Refinery - CID002567 |
When these facilities are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Universal Forest Products, and escalating up to removal of these high risk smelters from our supply chain.
As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. If necessary, suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
We also calculate supplier risk based on the chances that the supplier provides 3TG that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach, and it does not meet the goals or spirit of the Rule. However, evaluating and tracking the strength of the program does meet the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are the following items from the CMRT:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
When suppliers meet or exceed the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. We store all of this information and will continue to assess our suppliers’ program strength and monitor any improvements or changes.
Design and Implement a Strategy to Respond to Identified Risks
Universal Forest Products is in the process of establishing a Conflict Minerals Policy that outlines our expectations for suppliers. If these expectations are not met, the business relationship with that supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, Universal Forest Products will assess the supplier relationship and encourage that supplier to establish an
alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not that supplier can be replaced.
Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with smelters and refiners of Conflict Minerals and therefore do not perform or direct audits of these entities. In connection with our due diligence, we utilized information made available by the CFSI concerning independent third-party audits of smelters and refiners.
Report on Supply Chain Due Diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at http://www.ufpinvestor.com/phoenix.zhtml?c=116957&p=irol-corporateGovernance within the “Investor Relations” section under “Corporate Governance” and is filed with the SEC.
Results of Due Diligence
Survey results
As of May 1, 2017, we received CMRTs from 33% of our surveyed, in scope suppliers for the 2016 year.
As described above, Universal Forest Products surveys our supply chain and reviews all responses against set criteria that has been developed to determine whether further communication is needed. These criteria include: nonresponsiveness, incomplete responses and overall inconsistencies. Those that provided us with a CMRT were also asked to submit smelter and/or refiner information. The results of this are discussed in the Smelters and Refiners section below.
Smelters and refiners
Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to the scope of these CMRTs, we are unable to conclude which of the 3TGs (if any) have actually been included in parts or products that they supplied to us, nor are we able to determine from which of the processing facilities they listed the 3TGs originated. Many of the responses provided by a supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners (“SORs”). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid, and our third-party service provider follows up on these, urging suppliers to resubmit the form and include smelter information. Even with that further request, there are still suppliers that are unable to provide SORs used for the materials supplied to us.
For all responses that indicated a SOR, our third-party consultant compared the facilities listed to the list of SORs maintained by the Conflict-Free Sourcing Initiative (“CFSI”). If a supplier indicated that the facility was certified as “Conflict-Free,” our vendor confirmed that the name was listed by CFSI as a certified smelter. No violations were identified. As May 1, 2017, we have validated 308 smelters or refiners, and our third-party service provider is working to validate the additional smelter/refiner entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and CFSI.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional SOR names and country of origin of the necessary 3TGs in this Report at this time. We will continue to work with our suppliers to obtain SOR information at the product level.
Future Steps to be Taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. As we further develop our program and
procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:
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Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of our 3TGs with the greatest specificity possible; |
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Engage suppliers and encourage them to provide responses at the product level; |
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Continue to invest in Conflict Minerals due diligence tools; |
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Continue to respond to legal requirements regarding 3TGs in our supply chain; |
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Continue to refine the identification of suppliers who provide us with 3TGs; |
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Implementing a strategy to respond to identified risk, including but not limited to, potential action to be taken against suppliers that do not respond to our requests or do not provide reasonable information to support our due diligence activities; and |
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Engage any of our suppliers found to be supplying us with 3TGs from sourcing that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict. |
Appendix A:
The table below lists, as of May 1, 2017, the smelters or refiners identified by our responsive suppliers that may have been used to process the conflict minerals necessary to the functionality or production of our products during 2016. As described above, this list may contain more facilities than are actually linked to the Company’s products. In addition, this list may not include all applicable facilities as not all of our suppliers were able to provide SOR information at this time. Those smelters or refiners that have been validated as compliant under the CFSP (Conflict Free Smelter Protocol) by the CFSI have been noted as such in the final column on the right.
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Metal |
Standard Smelter Name |
Smelter Facility Location |
CFSI Audit Status |
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Gold |
Advanced Chemical Company |
UNITED STATES |
Compliant |
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Gold |
Aida Chemical Industries Co., Ltd. |
JAPAN |
Compliant |
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Gold |
Al Etihad Gold Refinery DMCC |
UNITED ARAB EMIRATES |
Compliant |
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Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
GERMANY |
Compliant |
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Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
UZBEKISTAN |
Compliant |
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Gold |
AngloGold Ashanti Córrego do Sítio Mineração |
BRAZIL |
Compliant |
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Gold |
Argor-Heraeus S.A. |
SWITZERLAND |
Compliant |
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Gold |
Asahi Pretec Corp. |
JAPAN |
Compliant |
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Gold |
Asahi Refining Canada Ltd. |
CANADA |
Compliant |
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Gold |
Asahi Refining USA Inc. |
UNITED STATES |
Compliant |
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Gold |
Asaka Riken Co., Ltd. |
JAPAN |
Compliant |
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Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
TURKEY |
Not Enrolled |
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Gold |
AU Traders and Refiners |
SOUTH AFRICA |
Compliant |
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Gold |
AURA-II |
UNITED STATES |
Not Enrolled |
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Gold |
Aurubis AG |
GERMANY |
Compliant |
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Gold |
Bangalore Refinery |
INDIA |
Active |
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Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
PHILIPPINES |
Compliant |
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Gold |
Boliden AB |
SWEDEN |
Compliant |
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Gold |
C. Hafner GmbH + Co. KG |
GERMANY |
Compliant |
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Gold |
Caridad |
MEXICO |
Not Enrolled |
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Gold |
CCR Refinery - Glencore Canada Corporation |
CANADA |
Compliant |
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Gold |
Cendres + Métaux S.A. |
SWITZERLAND |
Active |
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Gold |
Chimet S.p.A. |
ITALY |
Compliant |
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Gold |
Chugai Mining |
JAPAN |
Not Enrolled |
|
Gold |
Daejin Indus Co., Ltd. |
KOREA, REPUBLIC OF |
Compliant |
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Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CHINA |
Not Enrolled |
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Gold |
DODUCO GmbH |
GERMANY |
Compliant |
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Gold |
Dowa |
JAPAN |
Compliant |
|
Gold |
DSC (Do Sung Corporation) |
KOREA, REPUBLIC OF |
Compliant |
|
Gold |
Eco-System Recycling Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Elemetal Refining, LLC |
UNITED STATES |
Compliant |
|
Gold |
Emirates Gold DMCC |
UNITED ARAB EMIRATES |
Compliant |
|
Gold |
Fidelity Printers and Refiners Ltd. |
ZIMBABWE |
Not Enrolled |
|
Gold |
Gansu Seemine Material Hi-Tech Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Geib Refining Corporation |
UNITED STATES |
Active |
|
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CHINA |
Not Enrolled |
|
Gold |
Guangdong Jinding Gold Limited |
CHINA |
Not Enrolled |
|
Gold |
Gujarat Gold Centre |
INDIA |
Not Enrolled |
|
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Heimerle + Meule GmbH |
GERMANY |
Compliant |
|
Gold |
Heraeus Ltd. Hong Kong |
CHINA |
Compliant |
|
Gold |
Heraeus Precious Metals GmbH & Co. KG |
GERMANY |
Compliant |
|
Gold |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Hwasung CJ Co., Ltd. |
KOREA, REPUBLIC OF |
Not Enrolled |
|
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CHINA |
Compliant |
|
Gold |
Ishifuku Metal Industry Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Istanbul Gold Refinery |
TURKEY |
Compliant |
|
Gold |
Japan Mint |
JAPAN |
Compliant |
|
Gold |
Jiangxi Copper Co., Ltd. |
CHINA |
Compliant |
|
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
JSC Uralelectromed |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
JX Nippon Mining & Metals Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Kaloti Precious Metals |
UNITED ARAB EMIRATES |
Not Enrolled |
|
Gold |
Kazakhmys Smelting LLC |
KAZAKHSTAN |
Not Enrolled |
|
Gold |
Kazzinc |
KAZAKHSTAN |
Compliant |
|
Gold |
Kennecott Utah Copper LLC |
UNITED STATES |
Compliant |
|
Gold |
KGHM Polska Miedź Spółka Akcyjna |
POLAND |
Active |
|
Gold |
Kojima Chemicals Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Korea Zinc Co., Ltd. |
KOREA, REPUBLIC OF |
Compliant |
|
Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
Compliant |
|
Gold |
L'azurde Company For Jewelry |
SAUDI ARABIA |
Not Enrolled |
|
Gold |
Lingbao Gold Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
LS-NIKKO Copper Inc. |
KOREA, REPUBLIC OF |
Compliant |
|
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Materion |
UNITED STATES |
Compliant |
|
Gold |
Matsuda Sangyo Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CHINA |
Compliant |
|
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
SINGAPORE |
Compliant |
|
Gold |
Metalor Technologies (Suzhou) Ltd. |
CHINA |
Compliant |
|
Gold |
Metalor Technologies S.A. |
SWITZERLAND |
Compliant |
|
Gold |
Metalor USA Refining Corporation |
UNITED STATES |
Compliant |
|
Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
MEXICO |
Compliant |
|
Gold |
Mitsubishi Materials Corporation |
JAPAN |
Compliant |
|
Gold |
Mitsui Mining and Smelting Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
MMTC-PAMP India Pvt., Ltd. |
INDIA |
Compliant |
|
Gold |
Modeltech Sdn Bhd |
MALAYSIA |
Not Enrolled |
|
Gold |
Morris and Watson |
NEW ZEALAND |
Not Enrolled |
|
Gold |
Moscow Special Alloys Processing Plant |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. |
TURKEY |
Compliant |
|
Gold |
Navoi Mining and Metallurgical Combinat |
UZBEKISTAN |
Active |
|
Gold |
Nihon Material Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
AUSTRIA |
Compliant |
|
Gold |
Ohura Precious Metal Industry Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
OJSC Novosibirsk Refinery |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
PAMP S.A. |
SWITZERLAND |
Compliant |
|
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Prioksky Plant of Non-Ferrous Metals |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
PT Aneka Tambang (Persero) Tbk |
INDONESIA |
Compliant |
|
Gold |
PX Précinox S.A. |
SWITZERLAND |
Compliant |
|
Gold |
Rand Refinery (Pty) Ltd. |
SOUTH AFRICA |
Compliant |
|
Gold |
Remondis Argentia B.V. |
NETHERLANDS |
Not Enrolled |
|
Gold |
Republic Metals Corporation |
UNITED STATES |
Compliant |
|
Gold |
Royal Canadian Mint |
CANADA |
Compliant |
|
Gold |
SAAMP |
FRANCE |
Not Enrolled |
|
Gold |
Sabin Metal Corp. |
UNITED STATES |
Not Enrolled |
|
Gold |
SAFINA A.S. |
CZECH REPUBLIC |
Not Enrolled |
|
Gold |
Sai Refinery |
INDIA |
Not Enrolled |
|
Gold |
Samduck Precious Metals |
KOREA, REPUBLIC OF |
Compliant |
|
Gold |
SAMWON Metals Corp. |
KOREA, REPUBLIC OF |
Not Enrolled |
|
Gold |
SAXONIA Edelmetalle GmbH |
GERMANY |
Compliant |
|
Gold |
Schone Edelmetaal B.V. |
NETHERLANDS |
Compliant |
|
Gold |
SEMPSA Joyería Platería S.A. |
SPAIN |
Compliant |
|
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CHINA |
Compliant |
|
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CHINA |
Compliant |
|
Gold |
Singway Technology Co., Ltd. |
TAIWAN |
Compliant |
|
Gold |
So Accurate Group, Inc. |
UNITED STATES |
Not Enrolled |
|
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
RUSSIAN FEDERATION |
Compliant |
|
Gold |
Solar Applied Materials Technology Corp. |
TAIWAN |
Compliant |
|
Gold |
Sumitomo Metal Mining Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
T.C.A S.p.A |
ITALY |
Compliant |
|
Gold |
Tanaka Kikinzoku Kogyo K.K. |
JAPAN |
Compliant |
|
Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
CHINA |
Compliant |
|
Gold |
Tokuriki Honten Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Tony Goetz NV |
BELGIUM |
Active |
|
Gold |
TOO Tau-Ken-Altyn |
KAZAKHSTAN |
Not Enrolled |
|
Gold |
Torecom |
KOREA, REPUBLIC OF |
Compliant |
|
Gold |
Umicore Brasil Ltda. |
BRAZIL |
Compliant |
|
Gold |
Umicore Precious Metals Thailand |
THAILAND |
Compliant |
|
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
BELGIUM |
Compliant |
|
Gold |
United Precious Metal Refining, Inc. |
UNITED STATES |
Compliant |
|
Gold |
Universal Precious Metals Refining Zambia |
ZAMBIA |
Not Enrolled |
|
Gold |
Valcambi S.A. |
SWITZERLAND |
Compliant |
|
Gold |
Western Australian Mint trading as The Perth Mint |
AUSTRALIA |
Compliant |
|
Gold |
WIELAND Edelmetalle GmbH |
GERMANY |
Compliant |
|
Gold |
Yamamoto Precious Metal Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Yokohama Metal Co., Ltd. |
JAPAN |
Compliant |
|
Gold |
Yunnan Copper Industry Co., Ltd. |
CHINA |
Not Enrolled |
|
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CHINA |
Compliant |
|
Gold |
Zijin Mining Group Co., Ltd. Gold Refinery |
CHINA |
Compliant |
|
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Conghua Tantalum and Niobium Smeltry |
CHINA |
Compliant |
|
Tantalum |
D Block Metals, LLC |
UNITED STATES |
Compliant |
|
Tantalum |
Duoluoshan |
CHINA |
Compliant |
|
Tantalum |
Exotech Inc. |
UNITED STATES |
Compliant |
|
Tantalum |
F&X Electro-Materials Ltd. |
CHINA |
Compliant |
|
Tantalum |
FIR Metals & Resource Ltd. |
CHINA |
Compliant |
|
Tantalum |
Global Advanced Metals Aizu |
JAPAN |
Compliant |
|
Tantalum |
Global Advanced Metals Boyertown |
UNITED STATES |
Compliant |
|
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
H.C. Starck Co., Ltd. |
THAILAND |
Compliant |
|
Tantalum |
H.C. Starck GmbH Goslar |
GERMANY |
Compliant |
|
Tantalum |
H.C. Starck GmbH Laufenburg |
GERMANY |
Not Enrolled |
|
Tantalum |
H.C. Starck Hermsdorf GmbH |
GERMANY |
Compliant |
|
Tantalum |
H.C. Starck Inc. |
UNITED STATES |
Compliant |
|
Tantalum |
H.C. Starck Ltd. |
JAPAN |
Compliant |
|
Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
GERMANY |
Compliant |
|
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Hi-Temp Specialty Metals, Inc. |
UNITED STATES |
Compliant |
|
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Jiangxi Tuohong New Raw Material |
CHINA |
Compliant |
|
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
KEMET Blue Metals |
MEXICO |
Compliant |
|
Tantalum |
KEMET Blue Powder |
UNITED STATES |
Compliant |
|
Tantalum |
King-Tan Tantalum Industry Ltd. |
CHINA |
Compliant |
|
Tantalum |
LSM Brasil S.A. |
BRAZIL |
Compliant |
|
Tantalum |
Metallurgical Products India Pvt., Ltd. |
INDIA |
Compliant |
|
Tantalum |
Mineração Taboca S.A. |
BRAZIL |
Compliant |
|
Tantalum |
Mitsui Mining & Smelting |
JAPAN |
Compliant |
|
Tantalum |
Molycorp Silmet A.S. |
ESTONIA |
Compliant |
|
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Plansee SE Liezen |
AUSTRIA |
Not Enrolled |
|
Tantalum |
Plansee SE Reutte |
AUSTRIA |
Compliant |
|
Tantalum |
Power Resources Ltd. |
MACEDONIA |
Compliant |
|
Tantalum |
QuantumClean |
UNITED STATES |
Compliant |
|
Tantalum |
Resind Indústria e Comércio Ltda. |
BRAZIL |
Compliant |
|
Tantalum |
RFH Tantalum Smeltry Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Solikamsk Magnesium Works OAO |
RUSSIAN FEDERATION |
Compliant |
|
Tantalum |
Taki Chemicals |
JAPAN |
Compliant |
|
Tantalum |
Telex Metals |
UNITED STATES |
Compliant |
|
Tantalum |
Tranzact, Inc. |
UNITED STATES |
Compliant |
|
Tantalum |
Ulba Metallurgical Plant JSC |
KAZAKHSTAN |
Compliant |
|
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. |
CHINA |
Compliant |
|
Tantalum |
Zhuzhou Cemented Carbide Group Co., Ltd. |
CHINA |
Compliant |
|
Tin |
Alpha |
UNITED STATES |
Compliant |
|
Tin |
An Thai Minerals Co., Ltd. |
VIET NAM |
Not Enrolled |
|
Tin |
An Vinh Joint Stock Mineral Processing Company |
VIET NAM |
Not Enrolled |
|
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CHINA |
Compliant |
|
Tin |
China Tin Group Co., Ltd. |
CHINA |
Compliant |
|
Tin |
CNMC (Guangxi) PGMA Co., Ltd. |
CHINA |
Not Enrolled |
|
Tin |
Cooperativa Metalurgica de Rondônia Ltda. |
BRAZIL |
Compliant |
|
Tin |
CV Ayi Jaya |
INDONESIA |
Compliant |
|
Tin |
CV Dua Sekawan |
INDONESIA |
Compliant |
|
Tin |
CV Gita Pesona |
INDONESIA |
Compliant |
|
Tin |
CV Serumpun Sebalai |
INDONESIA |
Compliant |
|
Tin |
CV Tiga Sekawan |
INDONESIA |
Compliant |
|
Tin |
CV United Smelting |
INDONESIA |
Compliant |
|
Tin |
CV Venus Inti Perkasa |
INDONESIA |
Compliant |
|
Tin |
Dowa |
JAPAN |
Compliant |
|
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
VIET NAM |
Active |
|
Tin |
Elmet S.L.U. |
SPAIN |
Compliant |
|
Tin |
EM Vinto |
BOLIVIA |
Compliant |
|
Tin |
Estanho de Rondônia S.A. |
BRAZIL |
Not Enrolled |
|
Tin |
Fenix Metals |
POLAND |
Compliant |
|
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CHINA |
Compliant |
|
Tin |
Gejiu Jinye Mineral Company |
CHINA |
Compliant |
|
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CHINA |
Active |
|
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CHINA |
Compliant |
|
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CHINA |
Active |
|
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CHINA |
Not Enrolled |
|
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CHINA |
Compliant |
|
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CHINA |
Compliant |
|
Tin |
Huichang Jinshunda Tin Co., Ltd. |
CHINA |
Not Enrolled |
|
Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
CHINA |
Compliant |
|
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
BRAZIL |
Compliant |
|
Tin |
Malaysia Smelting Corporation (MSC) |
MALAYSIA |
Compliant |
|
Tin |
Melt Metais e Ligas S.A. |
BRAZIL |
Compliant |
|
Tin |
Metallic Resources, Inc. |
UNITED STATES |
Compliant |
|
Tin |
Metallo-Chimique N.V. |
BELGIUM |
Compliant |
|
Tin |
Mineração Taboca S.A. |
BRAZIL |
Compliant |
|
Tin |
Minsur |
PERU |
Compliant |
|
Tin |
Mitsubishi Materials Corporation |
JAPAN |
Compliant |
|
Tin |
Modeltech Sdn Bhd |
MALAYSIA |
Not Enrolled |
|
Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. |
CHINA |
Active |
|
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Not Enrolled |
|
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
THAILAND |
Compliant |
|
Tin |
O.M. Manufacturing Philippines, Inc. |
PHILIPPINES |
Compliant |
|
Tin |
Operaciones Metalurgical S.A. |
BOLIVIA |
Compliant |
|
Tin |
Phoenix Metal Ltd. |
RWANDA |
Not Enrolled |
|
Tin |
PT Aries Kencana Sejahtera |
INDONESIA |
Compliant |
|
Tin |
PT Artha Cipta Langgeng |
INDONESIA |
Compliant |
|
Tin |
PT ATD Makmur Mandiri Jaya |
INDONESIA |
Compliant |
|
Tin |
PT Babel Inti Perkasa |
INDONESIA |
Compliant |
|
Tin |
PT Bangka Prima Tin |
INDONESIA |
Compliant |
|
Tin |
PT Bangka Tin Industry |
INDONESIA |
Compliant |
|
Tin |
PT Belitung Industri Sejahtera |
INDONESIA |
Compliant |
|
Tin |
PT Bukit Timah |
INDONESIA |
Compliant |
|
Tin |
PT Cipta Persada Mulia |
INDONESIA |
Compliant |
|
Tin |
PT DS Jaya Abadi |
INDONESIA |
Compliant |
|
Tin |
PT Eunindo Usaha Mandiri |
INDONESIA |
Compliant |
|
Tin |
PT Inti Stania Prima |
INDONESIA |
Compliant |
|
Tin |
PT Justindo |
INDONESIA |
Not Enrolled |
|
Tin |
PT Karimun Mining |
INDONESIA |
Compliant |
|
Tin |
PT Kijang Jaya Mandiri |
INDONESIA |
Compliant |
|
Tin |
PT Mitra Stania Prima |
INDONESIA |
Compliant |
|
Tin |
PT O.M. Indonesia |
INDONESIA |
Compliant |
|
Tin |
PT Panca Mega Persada |
INDONESIA |
Compliant |
|
Tin |
PT Prima Timah Utama |
INDONESIA |
Compliant |
|
Tin |
PT Refined Bangka Tin |
INDONESIA |
Compliant |
|
Tin |
PT Sariwiguna Binasentosa |
INDONESIA |
Compliant |
|
Tin |
PT Stanindo Inti Perkasa |
INDONESIA |
Compliant |
|
Tin |
PT Sukses Inti Makmur |
INDONESIA |
Compliant |
|
Tin |
PT Sumber Jaya Indah |
INDONESIA |
Compliant |
|
Tin |
PT Timah (Persero) Tbk Kundur |
INDONESIA |
Compliant |
|
Tin |
PT Timah (Persero) Tbk Mentok |
INDONESIA |
Compliant |
|
Tin |
PT Tinindo Inter Nusa |
INDONESIA |
Compliant |
|
Tin |
PT Tommy Utama |
INDONESIA |
Compliant |
|
Tin |
PT Wahana Perkit Jaya |
INDONESIA |
Compliant |
|
Tin |
Resind Indústria e Comércio Ltda. |
BRAZIL |
Compliant |
|
Tin |
Rui Da Hung |
TAIWAN |
Compliant |
|
Tin |
Soft Metais Ltda. |
BRAZIL |
Compliant |
|
Tin |
Thaisarco |
THAILAND |
Compliant |
|
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
VIET NAM |
Not Enrolled |
|
Tin |
VQB Mineral and Trading Group JSC |
VIET NAM |
Compliant |
|
Tin |
White Solder Metalurgia e Mineração Ltda. |
BRAZIL |
Compliant |
|
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CHINA |
Active |
|
Tin |
Yunnan Tin Company Limited |
CHINA |
Compliant |
|
Tungsten |
A.L.M.T. TUNGSTEN Corp. |
JAPAN |
Compliant |
|
Tungsten |
ACL Metais Eireli |
BRAZIL |
Not Enrolled |
|
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
VIET NAM |
Compliant |
|
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Dayu Weiliang Tungsten Co., Ltd. |
CHINA |
Not Enrolled |
|
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. |
CHINA |
Not Enrolled |
|
Tungsten |
Global Tungsten & Powders Corp. |
UNITED STATES |
Compliant |
|
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
H.C. Starck GmbH |
GERMANY |
Compliant |
|
Tungsten |
H.C. Starck Smelting GmbH & Co.KG |
GERMANY |
Compliant |
|
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CHINA |
Compliant |
|
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Hydrometallurg, JSC |
RUSSIAN FEDERATION |
Compliant |
|
Tungsten |
Japan New Metals Co., Ltd. |
JAPAN |
Compliant |
|
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
CHINA |
Not Enrolled |
|
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CHINA |
Not Enrolled |
|
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Kennametal Fallon |
UNITED STATES |
Compliant |
|
Tungsten |
Kennametal Huntsville |
UNITED STATES |
Compliant |
|
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Moliren Ltd |
RUSSIAN FEDERATION |
Compliant |
|
Tungsten |
Niagara Refining LLC |
UNITED STATES |
Compliant |
|
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
VIET NAM |
Compliant |
|
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
PHILIPPINES |
Compliant |
|
Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City |
CHINA |
Compliant |
|
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
VIET NAM |
Compliant |
|
Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. |
VIET NAM |
Compliant |
|
Tungsten |
Wolfram Bergbau und Hütten AG |
AUSTRIA |
Compliant |
|
Tungsten |
Woltech Korea Co., Ltd. |
KOREA, REPUBLIC OF |
Compliant |
|
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Xiamen Tungsten Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CHINA |
Compliant |
|
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CHINA |
Compliant |
Country of Origin List:
This list below sets out possible countries of origin of 3TGs used in the manufacture of products containing conflict minerals that are necessary to the functionality or production of our products. The list is based on publicly available information, our reasonable country of origin investigation, and other due diligence. For the reasons described in the Report, however, these possible countries of origin cannot necessarily be linked to our products:
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.