ufpi_FormSD_2018

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)

 

 

 

 

 

Michigan

00-22684

38-1465835

(State or Other Jurisdiction

of Incorporation)

(Commission

File Number)

(IRS Employer

Identification No.)

 

 

 

2801 East Beltline, N.E.

Grand Rapids, Michigan

 

 

49525

(Address of principal executive office)

 

(Zip Code)

 

 

 

David A. Tutas

Vice President, General Counsel, and Secretary

(616) 364-6161

(Name and Telephone number, including area code, of the person to contact in connection with this report.)

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

[X]  Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.

 


 

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, 2017 to December 31, 2017. Unless the context otherwise indicates, “Universal Forest Products,” “we,” “us” and “our” refer to Universal Forest Products, Inc. and its consolidated subsidiaries.

During 2017, 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) of the Securities Exchange Act of 1934, as amended, 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 the Investor Relations section of our company website at: http://www.ufpinvestor.com/corporate-governance/highlights.  

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.

 

 


 

 

EXHIBIT INDEX

 

 

 

 

 

Exhibit

Number

Description

 

1.01

Conflict Minerals Report for the year ended December 31, 2017 as required by Items 1.01 and 1.02 of this Form.

 


 

 

 

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.

 

 

 

 

 

 

 

 

 

UNIVERSAL FOREST PRODUCTS, INC.

 

 

 

 

 

Dated: May 31, 2018

By:

/s/ Michael R. Cole

 

 

 

Michael R. Cole

 

 

Chief Financial Officer and Treasurer

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


ufpi_FormSD_Ex1.01

 

 

EXHIBIT 1.01

 

Universal Forest Products, Inc.

Conflict Minerals Report

For the Year Ended December 31, 2017

 

Introduction

This Conflict Minerals Report (the “Report”) has been prepared by Universal Forest Products, Inc. for the period from January 1, 2017 to December 31, 2017 (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 3TGs 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, wood-alternative, and outdoor living 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, 2017 filed on February 28, 2018.

 

 


 

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 2017. Through this process, we removed 27 suppliers from in scope for the 2017 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 5.01 or higher, developed by the Responsible Minerals Initiative (RMI) and The Global e-Sustainability Initiative, and the suppliers identified through the procedures above were surveyed on their sourcing of the 3TGs 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 3TGs 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 15th 2018, there were 8 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 set forth in 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, our Conflict Minerals Policy, 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.  Our Conflict Minerals Policy related to our sourcing of 3TGs is posted on our website at


 

http://www.ufpinvestor.com/corporate-governance/highlights within the “Investor Relations” section under “Corporate Governance.

Supplier engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 5.0 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.  We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.

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 RMI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:

1.

Geographic proximity to the DRC and Covered Countries;

2.

Responsible Minerals Assurance Process – RMAP; and

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:

·

Tony Goetz NV - CID002587

·

Kaloti Precious Metals - CID002563

·

Universal Precious Metals Refining Zambia - CID002854

·

Fidelity Printers and Refiners - CID002515

·

Sudan Gold Refinery - CID002567

·

African Gold Refinery Limited (AGR) – CID003185

 

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 referenced 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 3TGs 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?

G. Does your review process include corrective active management?

H. Do you verify due diligence information received from your suppliers?

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 has established 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 RMI 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/corporate-governance/highlights within the “Investor Relations” section under “Corporate Governance” and is filed with the SEC.

Results of Due Diligence

Survey results

As of May 15th 2018, we received 202 CMRTs from 698 of our surveyed, in scope suppliers for the 2017 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 Responsible Minerals Initiative (“RMI”).If a supplier indicated that the facility was certified as “Conflict-Free,” our vendor confirmed that the name was listed by RMI as a certified smelter. No violations were identified. As May 15, 2018, we have validated 316 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 RMI.

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:

·

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;

·

Engage suppliers and encourage them to provide responses at the product level;

·

Continue to invest in Conflict Minerals due diligence tools;

·

Continue to respond to legal requirements regarding 3TGs in our supply chain;

·

Continue to refine the identification of suppliers who provide us with 3TGs;

·

Implement 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

·

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 15th , 2018, 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 2017. 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 RMAP (Responsible Minerals Assurance Process) by the RMI have been noted as such in the final column on the right.

 

 

 

 

Metal

Standard Smelter Name

Smelter ID

RMI Audit Status

Gold

Abington Reldan Metals, LLC

CID002708

Not Enrolled

Gold

Advanced Chemical Company

CID000015

Conformant

Gold

Aida Chemical Industries Co., Ltd.

CID000019

Conformant

Gold

Al Etihad Gold LLC

CID002560

Conformant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

CID000035

Conformant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

CID000041

Conformant

Gold

AngloGold Ashanti Córrego do Sítio Mineração

CID000058

Conformant

Gold

Argor-Heraeus S.A.

CID000077

Conformant

Gold

Asahi Pretec Corp.

CID000082

Conformant

Gold

Asahi Refining Canada Ltd.

CID000924

Conformant

Gold

Asahi Refining USA Inc.

CID000920

Conformant

Gold

Asaka Riken Co., Ltd.

CID000090

Conformant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

CID000103

Not Enrolled

Gold

AU Traders and Refiners

CID002850

Conformant

Gold

Aurubis AG

CID000113

Conformant

Gold

Bangalore Refinery

CID002863

Active

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

CID000128

Conformant

Gold

Boliden AB

CID000157

Conformant

Gold

C. Hafner GmbH + Co. KG

CID000176

Conformant

Gold

Caridad

CID000180

Not Enrolled

Gold

CCR Refinery - Glencore Canada Corporation

CID000185

Conformant

Gold

Cendres + Métaux S.A.

CID000189

Conformant

Gold

Chimet S.p.A.

CID000233

Conformant

Gold

Chugai Mining

CID000264

Not Enrolled

Gold

Daejin Indus Co., Ltd.

CID000328

Conformant

Gold

Daye Non-Ferrous Metals Mining Ltd.

CID000343

Not Enrolled

Gold

Degussa Sonne / Mond Goldhandel GmbH

CID002867

Not Enrolled

Gold

DODUCO Contacts and Refining GmbH

CID000362

Conformant

Gold

Dowa

CID000401

Conformant

Gold

DS PRETECH Co., Ltd.

CID003195

Active

Gold

DSC (Do Sung Corporation)

CID000359

Conformant

Gold

Eco-System Recycling Co., Ltd.

CID000425

Conformant

Gold

Elemetal Refining, LLC

CID001322

Not Enrolled

Gold

Emirates Gold DMCC

CID002561

Conformant

Gold

Fidelity Printers and Refiners Ltd.

CID002515

Not Enrolled

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

CID002852

Not Enrolled

Gold

Geib Refining Corporation

CID002459

Conformant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CID002243

Conformant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CID001909

Not Enrolled

Gold

Guangdong Jinding Gold Limited

CID002312

Not Enrolled

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CID000651

Not Enrolled


 

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CID000671

Not Enrolled

Gold

HeeSung

CID000689

Conformant

Gold

Heimerle + Meule GmbH

CID000694

Conformant

Gold

Heraeus Metals Hong Kong Ltd.

CID000707

Conformant

Gold

Heraeus Precious Metals GmbH & Co. KG

CID000711

Conformant

Gold

Hunan Chenzhou Mining Co., Ltd.

CID000767

Not Enrolled

Gold

Hwasung CJ Co., Ltd.

CID000778

Not Enrolled

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CID000801

Conformant

Gold

Ishifuku Metal Industry Co., Ltd.

CID000807

Conformant

Gold

Istanbul Gold Refinery

CID000814

Conformant

Gold

Italpreziosi

CID002765

Conformant

Gold

Japan Mint

CID000823

Conformant

Gold

Jiangxi Copper Co., Ltd.

CID000855

Conformant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

CID000927

Conformant

Gold

JSC Uralelectromed

CID000929

Conformant

Gold

JX Nippon Mining & Metals Co., Ltd.

CID000937

Conformant

Gold

Kaloti Precious Metals

CID002563

Not Enrolled

Gold

Kazakhmys Smelting LLC

CID000956

Not Enrolled

Gold

Kazzinc

CID000957

Conformant

Gold

Kennecott Utah Copper LLC

CID000969

Conformant

Gold

KGHM Polska Miedz Spolka Akcyjna

CID002511

Active

Gold

Kojima Chemicals Co., Ltd.

CID000981

Conformant

Gold

Korea Zinc Co., Ltd.

CID002605

Conformant

Gold

Kyrgyzaltyn JSC

CID001029

Conformant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

CID002865

Not Enrolled

Gold

L'azurde Company For Jewelry

CID001032

Not Enrolled

Gold

Lingbao Gold Co., Ltd.

CID001056

Not Enrolled

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CID001058

Not Enrolled

Gold

L'Orfebre S.A.

CID002762

Active

Gold

LS-NIKKO Copper Inc.

CID001078

Conformant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CID001093

Not Enrolled

Gold

Marsam Metals

CID002606

Conformant

Gold

Materion

CID001113

Conformant

Gold

Matsuda Sangyo Co., Ltd.

CID001119

Conformant

Gold

Metalor Technologies (Hong Kong) Ltd.

CID001149

Conformant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

CID001152

Conformant

Gold

Metalor Technologies (Suzhou) Ltd.

CID001147

Conformant

Gold

Metalor Technologies S.A.

CID001153

Conformant

Gold

Metalor USA Refining Corporation

CID001157

Conformant

Gold

Metalúrgica Met-Mex Peñoles S.A. De C.V.

CID001161

Conformant

Gold

Mitsubishi Materials Corporation

CID001188

Conformant

Gold

Mitsui Mining and Smelting Co., Ltd.

CID001193

Conformant

Gold

MMTC-PAMP India Pvt., Ltd.

CID002509

Conformant

Gold

Modeltech Sdn Bhd

CID002857

Active

Gold

Morris and Watson

CID002282

Not Enrolled

Gold

Morris and Watson Gold Coast

CID002866

Not Enrolled

Gold

Moscow Special Alloys Processing Plant

CID001204

Conformant


 

Gold

Nadir Metal Rafineri San. Ve Tic. A.Ş.

CID001220

Conformant

Gold

Navoi Mining and Metallurgical Combinat

CID001236

Not Enrolled

Gold

Nihon Material Co., Ltd.

CID001259

Conformant

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

CID002779

Conformant

Gold

Ohura Precious Metal Industry Co., Ltd.

CID001325

Conformant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

CID001326

Conformant

Gold

OJSC Novosibirsk Refinery

CID000493

Conformant

Gold

PAMP S.A.

CID001352

Conformant

Gold

Pease & Curren

CID002872

Not Enrolled

Gold

Penglai Penggang Gold Industry Co., Ltd.

CID001362

Not Enrolled

Gold

Planta Recuperadora de Metales SpA

CID002919

Conformant

Gold

Prioksky Plant of Non-Ferrous Metals

CID001386

Conformant

Gold

PT Aneka Tambang (Persero)  Tbk

CID001397

Conformant

Gold

PX Précinox S.A.

CID001498

Conformant

Gold

Rand Refinery (Pty) Ltd.

CID001512

Conformant

Gold

Refinery of Seemine Gold Co., Ltd.

CID000522

Not Enrolled

Gold

Remondis Argentia B.V.

CID002582

Active

Gold

Republic Metals Corporation

CID002510

Conformant

Gold

Royal Canadian Mint

CID001534

Conformant

Gold

SAAMP

CID002761

Conformant

Gold

Sabin Metal Corp.

CID001546

Not Enrolled

Gold

Safimet S.p.A

CID002973

Conformant

Gold

SAFINA A.S.

CID002290

Active

Gold

Sai Refinery

CID002853

Not Enrolled

Gold

Samduck Precious Metals

CID001555

Conformant

Gold

SAMWON Metals Corp.

CID001562

Not Enrolled

Gold

SAXONIA Edelmetalle GmbH

CID002777

Conformant

Gold

Schone Edelmetaal B.V.

CID001573

Conformant

Gold

SEMPSA Joyería Platería S.A.

CID001585

Conformant

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CID001619

Not Enrolled

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CID001622

Conformant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CID001736

Conformant

Gold

Singway Technology Co., Ltd.

CID002516

Conformant

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

CID001756

Conformant

Gold

Solar Applied Materials Technology Corp.

CID001761

Conformant

Gold

State Research Institute Center for Physical Sciences and Technology

CID003153

Not Enrolled

Gold

Sudan Gold Refinery

CID002567

Not Enrolled

Gold

Sumitomo Metal Mining Co., Ltd.

CID001798

Conformant

Gold

SungEel HiTech

CID002918

Conformant

Gold

T.C.A S.p.A

CID002580

Conformant

Gold

Tanaka Kikinzoku Kogyo K.K.

CID001875

Conformant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CID001916

Conformant

Gold

Tokuriki Honten Co., Ltd.

CID001938

Conformant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CID001947

Not Enrolled

Gold

Tony Goetz NV

CID002587

Not Enrolled


 

Gold

TOO Tau-Ken-Altyn

CID002615

Not Enrolled

Gold

Torecom

CID001955

Conformant

Gold

Umicore Brasil Ltda.

CID001977

Conformant

Gold

Umicore Precious Metals Thailand

CID002314

Conformant

Gold

Umicore S.A. Business Unit Precious Metals Refining

CID001980

Conformant

Gold

United Precious Metal Refining, Inc.

CID001993

Conformant

Gold

Universal Precious Metals Refining Zambia

CID002854

Not Enrolled

Gold

Valcambi S.A.

CID002003

Conformant

Gold

Western Australian Mint trading as The Perth Mint

CID002030

Conformant

Gold

WIELAND Edelmetalle GmbH

CID002778

Conformant

Gold

Yamamoto Precious Metal Co., Ltd.

CID002100

Conformant

Gold

Yokohama Metal Co., Ltd.

CID002129

Conformant

Gold

Yunnan Copper Industry Co., Ltd.

CID000197

Not Enrolled

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CID002224

Conformant

Tantalum

Asaka Riken Co., Ltd.

CID000092

Conformant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CID000211

Conformant

Tantalum

D Block Metals, LLC

CID002504

Conformant

Tantalum

Duoluoshan

CID000410

Not Enrolled

Tantalum

Exotech Inc.

CID000456

Conformant

Tantalum

F&X Electro-Materials Ltd.

CID000460

Conformant

Tantalum

FIR Metals & Resource Ltd.

CID002505

Conformant

Tantalum

Global Advanced Metals Aizu

CID002558

Conformant

Tantalum

Global Advanced Metals Boyertown

CID002557

Conformant

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CID000291

Conformant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CID000616

Conformant

Tantalum

H.C. Starck Co., Ltd.

CID002544

Conformant

Tantalum

H.C. Starck Hermsdorf GmbH

CID002547

Conformant

Tantalum

H.C. Starck Inc.

CID002548

Conformant

Tantalum

H.C. Starck Ltd.

CID002549

Conformant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

CID002550

Conformant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

CID002545

Conformant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CID002492

Conformant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CID002512

Conformant

Tantalum

Jiangxi Tuohong New Raw Material

CID002842

Conformant

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CID000914

Conformant

Tantalum

Jiujiang Tanbre Co., Ltd.

CID000917

Conformant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CID002506

Conformant

Tantalum

KEMET Blue Metals

CID002539

Conformant

Tantalum

KEMET Blue Powder

CID002568

Conformant

Tantalum

King-Tan Tantalum Industry Ltd.

CID000973

Conformant

Tantalum

LSM Brasil S.A.

CID001076

Conformant

Tantalum

Metallurgical Products India Pvt., Ltd.

CID001163

Conformant

Tantalum

Mineracao Taboca S.A.

CID001175

Conformant

Tantalum

Mitsui Mining and Smelting Co., Ltd.

CID001192

Conformant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CID001277

Conformant

Tantalum

NPM Silmet AS

CID001200

Conformant

Tantalum

Power Resources Ltd.

CID002847

Conformant


 

Tantalum

QuantumClean

CID001508

Conformant

Tantalum

Resind Industria e Comercio Ltda.

CID002707

Conformant

Tantalum

RFH Tantalum Smeltry Co., Ltd.

CID001522

Conformant

Tantalum

Solikamsk Magnesium Works OAO

CID001769

Conformant

Tantalum

Taki Chemicals

CID001869

Conformant

Tantalum

Telex Metals

CID001891

Conformant

Tantalum

Ulba Metallurgical Plant JSC

CID001969

Conformant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CID002508

Conformant

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd.

CID002307

Conformant

Tin

Alpha

CID000292

Conformant

Tin

An Vinh Joint Stock Mineral Processing Company

CID002703

Not Enrolled

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CID000228

Conformant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CID003190

Active

Tin

China Tin Group Co., Ltd.

CID001070

Conformant

Tin

CNMC (Guangxi) PGMA Co., Ltd.

CID000278

Not Enrolled

Tin

CV Ayi Jaya

CID002570

Conformant

Tin

CV Dua Sekawan

CID002592

Conformant

Tin

CV Gita Pesona

CID000306

Conformant

Tin

CV Tiga Sekawan

CID002593

Conformant

Tin

CV United Smelting

CID000315

Conformant

Tin

CV Venus Inti Perkasa

CID002455

Conformant

Tin

Dowa

CID000402

Conformant

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

CID002572

Not Enrolled

Tin

EM Vinto

CID000438

Conformant

Tin

Estanho de Rondônia S.A.

CID000448

Not Enrolled

Tin

Fenix Metals

CID000468

Conformant

Tin

Gejiu Fengming Metallurgy Chemical Plant

CID002848

Conformant

Tin

Gejiu Jinye Mineral Company

CID002859

Conformant

Tin

Gejiu Kai Meng Industry and Trade LLC

CID000942

Conformant

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CID000538

Conformant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CID001908

Conformant

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CID000555

Not Enrolled

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

CID003116

Conformant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CID002849

Conformant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CID002844

Conformant

Tin

Huichang Jinshunda Tin Co., Ltd.

CID000760

Conformant

Tin

Jiangxi Ketai Advanced Material Co., Ltd.

CID000244

Conformant

Tin

Jiangxi New Nanshan Technology Ltd.

CID001231

Conformant

Tin

Magnu's Minerais Metais e Ligas Ltda.

CID002468

Conformant

Tin

Malaysia Smelting Corporation (MSC)

CID001105

Conformant

Tin

Melt Metais e Ligas S.A.

CID002500

Conformant

Tin

Metallic Resources, Inc.

CID001142

Conformant

Tin

Metallo Belgium N.V.

CID002773

Conformant

Tin

Metallo Spain S.L.U.

CID002774

Conformant

Tin

Mineracao Taboca S.A.

CID001173

Conformant

Tin

Minsur

CID001182

Conformant


 

Tin

Mitsubishi Materials Corporation

CID001191

Conformant

Tin

Modeltech Sdn Bhd

CID002858

Active

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

CID002573

Not Enrolled

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

CID001314

Conformant

Tin

O.M. Manufacturing Philippines, Inc.

CID002517

Conformant

Tin

Operaciones Metalurgical S.A.

CID001337

Conformant

Tin

PT Aries Kencana Sejahtera

CID000309

Conformant

Tin

PT Artha Cipta Langgeng

CID001399

Conformant

Tin

PT ATD Makmur Mandiri Jaya

CID002503

Conformant

Tin

PT Babel Inti Perkasa

CID001402

Conformant

Tin

PT Bangka Prima Tin

CID002776

Conformant

Tin

PT Bangka Tin Industry

CID001419

Conformant

Tin

PT Belitung Industri Sejahtera

CID001421

Conformant

Tin

PT Bukit Timah

CID001428

Conformant

Tin

PT DS Jaya Abadi

CID001434

Conformant

Tin

PT Eunindo Usaha Mandiri

CID001438

Conformant

Tin

PT Inti Stania Prima

CID002530

Conformant

Tin

PT Karimun Mining

CID001448

Conformant

Tin

PT Kijang Jaya Mandiri

CID002829

Conformant

Tin

PT Lautan Harmonis Sejahtera

CID002870

Conformant

Tin

PT Menara Cipta Mulia

CID002835

Conformant

Tin

PT Mitra Stania Prima

CID001453

Conformant

Tin

PT O.M. Indonesia

CID002757

Conformant

Tin

PT Panca Mega Persada

CID001457

Conformant

Tin

PT Premium Tin Indonesia

CID000313

Conformant

Tin

PT Prima Timah Utama

CID001458

Conformant

Tin

PT Refined Bangka Tin

CID001460

Conformant

Tin

PT Sariwiguna Binasentosa

CID001463

Conformant

Tin

PT Stanindo Inti Perkasa

CID001468

Conformant

Tin

PT Sukses Inti Makmur

CID002816

Conformant

Tin

PT Sumber Jaya Indah

CID001471

Conformant

Tin

PT Timah  (Persero)  Tbk Kundur

CID001477

Conformant

Tin

PT Timah  (Persero)  Tbk Mentok

CID001482

Conformant

Tin

PT Tinindo Inter Nusa

CID001490

Conformant

Tin

PT Tommy Utama

CID001493

Conformant

Tin

Resind Industria e Comercio Ltda.

CID002706

Conformant

Tin

Rui Da Hung

CID001539

Conformant

Tin

Soft Metais Ltda.

CID001758

Conformant

Tin

Super Ligas

CID002756

Not Enrolled

Tin

Thaisarco

CID001898

Conformant

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

CID002574

Not Enrolled

Tin

White Solder Metalurgia e Mineração Ltda.

CID002036

Conformant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CID002158

Conformant

Tin

Yunnan Tin Company Limited

CID002180

Conformant

Tungsten

A.L.M.T. TUNGSTEN Corp.

CID000004

Conformant

Tungsten

ACL Metais Eireli

CID002833

Conformant

Tungsten

Asia Tungsten Products Vietnam Ltd.

CID002502

Conformant


 

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CID002513

Conformant

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CID000258

Conformant

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CID000499

Conformant

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CID002645

Active

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CID000875

Conformant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CID002315

Conformant

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CID002494

Conformant

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CID002536

Not Enrolled

Tungsten

Global Tungsten & Powders Corp.

CID000568

Conformant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CID000218

Conformant

Tungsten

H.C. Starck Smelting GmbH & Co.KG

CID002542

Conformant

Tungsten

H.C. Starck Tungsten GmbH

CID002541

Conformant

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CID000766

Conformant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CID002579

Conformant

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CID000769

Conformant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CID003182

Conformant

Tungsten

Hydrometallurg, JSC

CID002649

Conformant

Tungsten

Japan New Metals Co., Ltd.

CID000825

Conformant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CID002551

Conformant

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CID002647

Not Enrolled

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CID002321

Conformant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CID002313

Not Enrolled

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CID002318

Conformant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CID002317

Conformant

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CID002535

Conformant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CID002316

Conformant

Tungsten

Kennametal Fallon

CID000966

Conformant

Tungsten

Kennametal Huntsville

CID000105

Conformant

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CID002319

Conformant

Tungsten

Moliren Ltd

CID002845

Conformant

Tungsten

Niagara Refining LLC

CID002589

Conformant

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

CID002543

Conformant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

CID002827

Conformant

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CID002815

Conformant

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

CID001889

Conformant

Tungsten

Unecha Refractory metals plant

CID002724

Conformant

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd.

CID002011

Conformant

Tungsten

Wolfram Bergbau und Hütten AG

CID002044

Conformant

Tungsten

Woltech Korea Co., Ltd.

CID002843

Conformant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CID002320

Conformant

Tungsten

Xiamen Tungsten Co., Ltd.

CID002082

Conformant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CID002830

Conformant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CID002095

Conformant

 

 

 

 


 

Country of Origin List:

 

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

List: Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe