ufpi_FormSD_2019

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, 2018.

 

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, 2018 to December 31, 2018. Unless the context otherwise indicates, “Universal Forest Products,” “we,” “us” and “our” refer to Universal Forest Products, Inc. and its consolidated subsidiaries.

During 2018, 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, 2018 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, 2019

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, 2018

 

Introduction

This Conflict Minerals Report (the “Report”) has been prepared by Universal Forest Products, Inc. for the period from January 1, 2018 to December 31, 2018 (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 29, 2018 filed on February 27, 2019.

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 2018. Through this process, we removed 84 suppliers from in scope for the 2018 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 5.11 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 contacted an additional two times in an escalation format. 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 15, 2019, there were 6 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 5.11 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 these 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 15, 2019, we received 232 CMRTs from 817 of our surveyed, in scope suppliers for the 2018 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, 2019, we have validated 312 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 the 3TGs in our products 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 15, 2019, 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 2018. 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 Facility Location

Smelter ID

Gold

Abington Reldan Metals, LLC

UNITED STATES

CID002708

Gold

Advanced Chemical Company

UNITED STATES

CID000015

Gold

African Gold Refinery

UGANDA

CID003185

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

CID000019

Gold

Al Etihad Gold LLC

UNITED ARAB EMIRATES

CID002560

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

CID000035

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

CID000041

Gold

AngloGold Ashanti Córrego do Sítio Mineração

BRAZIL

CID000058

Gold

Argor-Heraeus S.A.

SWITZERLAND

CID000077

Gold

Asahi Pretec Corp.

JAPAN

CID000082

Gold

Asahi Refining Canada Ltd.

CANADA

CID000924

Gold

Asahi Refining USA Inc.

UNITED STATES

CID000920

Gold

Asaka Riken Co., Ltd.

JAPAN

CID000090

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

CID000103

Gold

AU Traders and Refiners

SOUTH AFRICA

CID002850

Gold

Aurubis AG

GERMANY

CID000113

Gold

Bangalore Refinery

INDIA

CID002863

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

CID000128

Gold

Boliden AB

SWEDEN

CID000157

Gold

C. Hafner GmbH + Co. KG

GERMANY

CID000176

Gold

Caridad

MEXICO

CID000180

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

CID000185

Gold

Cendres + Métaux S.A.

SWITZERLAND

CID000189

Gold

Chimet S.p.A.

ITALY

CID000233

Gold

Chugai Mining

JAPAN

CID000264

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

CID000328

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

CID000343

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

CID002867

Gold

DODUCO Contacts and Refining GmbH

GERMANY

CID000362

Gold

Dowa

JAPAN

CID000401

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

CID003195

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

CID000359

Gold

Eco-System Recycling Co., Ltd.

JAPAN

CID000425

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

CID002561

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

CID002515

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

CID002852

Gold

Geib Refining Corporation

UNITED STATES

CID002459

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

CID002243

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

CID001909

Gold

Guangdong Jinding Gold Limited

CHINA

CID002312

Gold

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

CHINA

CID000651

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

CID000671

Gold

HeeSung

KOREA, REPUBLIC OF

CID000689

Gold

Heimerle + Meule GmbH

GERMANY

CID000694

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

CID000707

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

CID000711

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000767

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

CID000773

Gold

Hwasung CJ Co., Ltd.

KOREA, REPUBLIC OF

CID000778

Gold

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

CHINA

CID000801

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

CID000807

Gold

Istanbul Gold Refinery

TURKEY

CID000814

Gold

Italpreziosi

ITALY

CID002765

Gold

Japan Mint

JAPAN

CID000823

Gold

Jiangxi Copper Co., Ltd.

CHINA

CID000855

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

CID000927

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

CID000929

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

CID000937

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

CID002563

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

CID000956

Gold

Kazzinc

KAZAKHSTAN

CID000957

Gold

Kennecott Utah Copper LLC

UNITED STATES

CID000969

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

CID002511

Gold

Kojima Chemicals Co., Ltd.

JAPAN

CID000981

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

CID002605

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

CID001029

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

CID002865

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

CID001032

Gold

Lingbao Gold Co., Ltd.

CHINA

CID001056

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

CID001058

Gold

L'Orfebre S.A.

ANDORRA

CID002762

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

CID001078

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

CID001093

Gold

Marsam Metals

BRAZIL

CID002606

Gold

Materion

UNITED STATES

CID001113

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

CID001119

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

CID001149

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

CID001152

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

CID001147

Gold

Metalor Technologies S.A.

SWITZERLAND

CID001153

Gold

Metalor USA Refining Corporation

UNITED STATES

CID001157

Gold

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

MEXICO

CID001161

Gold

Mitsubishi Materials Corporation

JAPAN

CID001188

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001193

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

CID002509

Gold

Modeltech Sdn Bhd

MALAYSIA

CID002857

Gold

Morris and Watson

NEW ZEALAND

CID002282

Gold

Morris and Watson Gold Coast

AUSTRALIA

CID002866

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

CID001204

Gold

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

TURKEY

CID001220

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

CID001236

Gold

NH Recytech Company

KOREA, REPUBLIC OF

CID003189

Gold

Nihon Material Co., Ltd.

JAPAN

CID001259

Gold

Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

CID002779

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

CID001325

Gold

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

RUSSIAN FEDERATION

CID001326

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

CID000493

Gold

PAMP S.A.

SWITZERLAND

CID001352

Gold

Pease & Curren

UNITED STATES

CID002872

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

CID001362

Gold

Planta Recuperadora de Metales SpA

CHILE

CID002919

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

CID001386

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

CID001397

Gold

PX Précinox S.A.

SWITZERLAND

CID001498

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

CID003324

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

CID001512

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

CID000522

Gold

Remondis Argentia B.V.

NETHERLANDS

CID002582

Gold

Republic Metals Corporation

UNITED STATES

CID002510

Gold

Royal Canadian Mint

CANADA

CID001534

Gold

SAAMP

FRANCE

CID002761

Gold

Sabin Metal Corp.

UNITED STATES

CID001546

Gold

Safimet S.p.A

Italy

CID002973

Gold

SAFINA A.S.

CZECH REPUBLIC

CID002290

Gold

Sai Refinery

INDIA

CID002853

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

CID001555

Gold

SAMWON Metals Corp.

KOREA, REPUBLIC OF

CID001562

Gold

SAXONIA Edelmetalle GmbH

GERMANY

CID002777

Gold

SEMPSA Joyería Platería S.A.

SPAIN

CID001585

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

CID001619

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

CID001622

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

CID001736

Gold

Singway Technology Co., Ltd.

TAIWAN

CID002516

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

CID001756

Gold

Solar Applied Materials Technology Corp.

TAIWAN

CID001761

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

CID003153

Gold

Sudan Gold Refinery

SUDAN

CID002567

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

CID001798

Gold

SungEel HiTech

KOREA, REPUBLIC OF

CID002918

Gold

T.C.A S.p.A

ITALY

CID002580

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

CID001875

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

CID001916

Gold

Tokuriki Honten Co., Ltd.

JAPAN

CID001938

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

CID001947

Gold

Tony Goetz NV

BELGIUM

CID002587

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

CID002615

Gold

Torecom

KOREA, REPUBLIC OF

CID001955

Gold

Umicore Brasil Ltda.

BRAZIL

CID001977

Gold

Umicore Precious Metals Thailand

THAILAND

CID002314

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

CID001980

Gold

United Precious Metal Refining, Inc.

UNITED STATES

CID001993

Gold

Universal Precious Metals Refining Zambia

ZAMBIA

CID002854

Gold

Valcambi S.A.

SWITZERLAND

CID002003

Gold

Western Australian Mint trading as The Perth Mint

AUSTRALIA

CID002030

Gold

WIELAND Edelmetalle GmbH

GERMANY

CID002778

Gold

Yamamoto Precious Metal Co., Ltd.

JAPAN

CID002100

Gold

Yokohama Metal Co., Ltd.

JAPAN

CID002129

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

CID000197

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

CID002224

Tantalum

Asaka Riken Co., Ltd.

JAPAN

CID000092

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

CID000211

Tantalum

D Block Metals, LLC

UNITED STATES

CID002504

Tantalum

Exotech Inc.

UNITED STATES

CID000456

Tantalum

F&X Electro-Materials Ltd.

CHINA

CID000460

Tantalum

FIR Metals & Resource Ltd.

CHINA

CID002505

Tantalum

Global Advanced Metals Aizu

JAPAN

CID002558

Tantalum

Global Advanced Metals Boyertown

UNITED STATES

CID002557

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

CID000291

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

CID000616

Tantalum

H.C. Starck Co., Ltd.

THAILAND

CID002544

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

CID002547

Tantalum

H.C. Starck Inc.

UNITED STATES

CID002548

Tantalum

H.C. Starck Ltd.

JAPAN

CID002549

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

CID002550

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

CID002545

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

CID002492

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

CID002512

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

CID002842

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

CID003191

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

CID000914

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

CID000917

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

CID002506

Tantalum

KEMET Blue Metals

MEXICO

CID002539

Tantalum

KEMET Blue Powder

UNITED STATES

CID002568

Tantalum

LSM Brasil S.A.

BRAZIL

CID001076

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

CID001163

Tantalum

Mineracao Taboca S.A.

BRAZIL

CID001175

Tantalum

Mitsui Mining and Smelting Co., Ltd.

JAPAN

CID001192

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

CID001277

Tantalum

NPM Silmet AS

ESTONIA

CID001200

Tantalum

Power Resources Ltd.

MACEDONIA

CID002847

Tantalum

QuantumClean

UNITED STATES

CID001508

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

CID002707

Tantalum

RFH Tantalum Smeltry Co., Ltd.

CHINA

CID001522

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

CID001769

Tantalum

Taki Chemicals

JAPAN

CID001869

Tantalum

Telex Metals

UNITED STATES

CID001891

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

CID001969

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

CID002508

Tin

Alpha

UNITED STATES

CID000292

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

CID002703

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

CID000228

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

CID003190

Tin

China Tin Group Co., Ltd.

CHINA

CID001070

Tin

CV Ayi Jaya

INDONESIA

CID002570

Tin

CV Dua Sekawan

INDONESIA

CID002592

Tin

CV Gita Pesona

INDONESIA

CID000306

Tin

CV Tiga Sekawan

INDONESIA

CID002593

Tin

CV United Smelting

INDONESIA

CID000315

Tin

CV Venus Inti Perkasa

INDONESIA

CID002455

Tin

Dowa

JAPAN

CID000402

Tin

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

VIET NAM

CID002572

Tin

EM Vinto

BOLIVIA

CID000438

Tin

Estanho de Rondônia S.A.

BRAZIL

CID000448

Tin

Fenix Metals

POLAND

CID000468

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

CID002848

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

CID000942

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

CID000538

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

CID001908

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

CID000555

Tin

Guangdong Hanhe Non-ferrous Metal Limited Company

CHINA

CID003116

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

CID002849

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

CID002844

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

CID000760

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

CID001231

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

CID002468

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

CID001105

Tin

Melt Metais e Ligas S.A.

BRAZIL

CID002500

Tin

Metallic Resources, Inc.

UNITED STATES

CID001142

Tin

Metallo Belgium N.V.

BELGIUM

CID002773

Tin

Metallo Spain S.L.U.

SPAIN

CID002774

Tin

Mineracao Taboca S.A.

BRAZIL

CID001173

Tin

Minsur

PERU

CID001182

Tin

Mitsubishi Materials Corporation

JAPAN

CID001191

Tin

Modeltech Sdn Bhd

MALAYSIA

CID002858

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002573

Tin

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

THAILAND

CID001314

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

CID002517

Tin

Operaciones Metalurgical S.A.

BOLIVIA

CID001337

Tin

Pongpipat Company Limited

MYANMAR

CID003208

Tin

PT Aries Kencana Sejahtera

INDONESIA

CID000309

Tin

PT Artha Cipta Langgeng

INDONESIA

CID001399

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

CID002503

Tin

PT Babel Inti Perkasa

INDONESIA

CID001402

Tin

PT Babel Surya Alam Lestari

INDONESIA

CID001406

Tin

PT Bangka Prima Tin

INDONESIA

CID002776

Tin

PT Bangka Serumpun

INDONESIA

CID003205

Tin

PT Bangka Tin Industry

INDONESIA

CID001419

Tin

PT Belitung Industri Sejahtera

INDONESIA

CID001421

Tin

PT Bukit Timah

INDONESIA

CID001428

Tin

PT DS Jaya Abadi

INDONESIA

CID001434

Tin

PT Inti Stania Prima

INDONESIA

CID002530

Tin

PT Kijang Jaya Mandiri

INDONESIA

CID002829

Tin

PT Menara Cipta Mulia

INDONESIA

CID002835

Tin

PT Mitra Stania Prima

INDONESIA

CID001453

Tin

PT Panca Mega Persada

INDONESIA

CID001457

Tin

PT Premium Tin Indonesia

INDONESIA

CID000313

Tin

PT Prima Timah Utama

INDONESIA

CID001458

Tin

PT Refined Bangka Tin

INDONESIA

CID001460

Tin

PT Sariwiguna Binasentosa

INDONESIA

CID001463

Tin

PT Stanindo Inti Perkasa

INDONESIA

CID001468

Tin

PT Sukses Inti Makmur

INDONESIA

CID002816

Tin

PT Sumber Jaya Indah

INDONESIA

CID001471

Tin

PT Timah (Persero) Tbk Kundur

INDONESIA

CID001477

Tin

PT Timah (Persero) Tbk Mentok

INDONESIA

CID001482

Tin

PT Tinindo Inter Nusa

INDONESIA

CID001490

Tin

PT Tirus Putra Mandiri

INDONESIA

CID002478

Tin

PT Tommy Utama

INDONESIA

CID001493

Tin

Resind Industria e Comercio Ltda.

BRAZIL

CID002706

Tin

Rui Da Hung

TAIWAN

CID001539

Tin

Soft Metais Ltda.

BRAZIL

CID001758

Tin

Super Ligas

Brazil

CID002756

Tin

Thaisarco

THAILAND

CID001898

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

CID003325

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

CID002574

Tin

White Solder Metalurgia e Mineração Ltda.

BRAZIL

CID002036

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

CID002158

Tin

Yunnan Tin Company Limited

CHINA

CID002180

Tungsten

A.L.M.T. TUNGSTEN Corp.

JAPAN

CID000004

Tungsten

ACL Metais Eireli

BRAZIL

CID002833

Tungsten

Asia Tungsten Products Vietnam Ltd.

VIET NAM

CID002502

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

CID002513

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

CID000258

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

CID000499

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

CID002645

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

CID000875

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

CID002315

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

CID002494

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

CID002536

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES

CID000568

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

CID000218

Tungsten

H.C. Starck Smelting GmbH & Co.KG

GERMANY

CID002542

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

CID002541

Tungsten

Hunan Chenzhou Mining Co., Ltd.

CHINA

CID000766

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

CID002579

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

CID000769

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

CID003182

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

CID002649

Tungsten

Japan New Metals Co., Ltd.

JAPAN

CID000825

Tungsten

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

CHINA

CID002551

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

CID002647

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

CID002321

Tungsten

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

CHINA

CID002313

Tungsten

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

CHINA

CID002318

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

CID002317

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

CID002316

Tungsten

Kennametal Fallon

UNITED STATES

CID000966

Tungsten

Kennametal Huntsville

UNITED STATES

CID000105

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

CID002319

Tungsten

Moliren Ltd

RUSSIAN FEDERATION

CID002845

Tungsten

Niagara Refining LLC

UNITED STATES

CID002589

Tungsten

Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC

VIET NAM

CID002543

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

CID002827

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

CID002815

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

CID001889

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

CID002724

Tungsten

Wolfram Bergbau und Hütten AG

AUSTRIA

CID002044

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

CID002843

Tungsten

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

CHINA

CID002320

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

CID002082

Tungsten

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

CHINA

CID002830

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

CID002095

 

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 list is based, in part, on company level responses, and therefore, it is not certain which of these countries of origin can be linked to our products, nor is this list likely a complete list.

Sample List:

Argentina

Eritrea

Mauritania

Slovakia

Botswana

Honduras

Nicaragua

Tanzania

Brazil

India

Niger

Thailand

Burkina Faso

Indonesia

Nigeria

Togo

Canada

Ivory Coast

Peru

Uganda

Colombia

Kyrgyzstan

Puerto Rico

United States of America

Congo, Democratic Republic of the

Laos

Russian Federation

Uruguay

Cyprus

Lebanon

Rwanda

Uzbekistan

Dominican Republic

Madagascar

Saudi Arabia

Venezuela