United States
Securities and Exchange Commission
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Colfax Corporation
(Exact name of registrant as specified in its charter)
| Delaware | 001-34045 | 54-1887631 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 420 National Business Parkway, 5th Floor Annapolis Junction, Maryland |
20701 | |
| (Address of principal executive offices) | (Zip Code) |
A. Lynne Puckett, Senior Vice President, General Counsel & Secretary
(301) 323-9000
(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:
| ☒ | 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 1.01 Conflict Minerals Disclosure and Report
As provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD, a Conflict Minerals Report is provided as an exhibit to this Form SD and is available at the following Internet website: http://ir.colfaxcorp.com/governance.cfm. The information contained on our website is not incorporated by reference into this Form SD or our Conflict Minerals Report and should not be considered part of this Form SD or the Conflict Minerals Report.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2—Exhibits
Item 2.01 Exhibits
| Exhibit 1.01 | – | Conflict Minerals Report for the calendar year ended December 31, 2016 |
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SIGNATURES
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 duly authorized undersigned.
| COLFAX CORPORATION | ||||||||||
| Date: May 31, 2017 | ||||||||||
| By: | /s/ Stephen Wittig |
|||||||||
| Name: | Stephen Wittig | |||||||||
| Title: | Senior Vice President, CBS and Supply Chain Strategy |
|||||||||
EXHIBIT INDEX
| Exhibit |
Description | |
| 1.01 | Conflict Minerals Report for the calendar year ended December 31, 2016 | |
Exhibit 1.01
Conflict Minerals Report
Colfax Corporation has included this Conflict Minerals Report as an exhibit to its Form SD for the period from January 1st 2016 to December 31st 2016 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is May 31, 2017.
Unless the context indicates otherwise, the terms “Colfax,” “we,” “its,” “us,” and “our” refer to Colfax Corporation and its consolidated subsidiaries. As used herein, “Conflict Minerals” or “3TG” is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten.
Forward-Looking Statements
This document contains forward-looking statements within the meaning of the federal securities laws. Any statements that do not relate to historical or current facts or matters are forward-looking statements. You can identify some of the forward-looking statements by the use of forward-looking words, such as “intend” and the like, or the use of future tense. Statements concerning current conditions may also be forward-looking if they imply a continuation of current conditions. Examples of forward-looking statements include, but are not limited to, statements concerning the additional steps that we intend to take to mitigate the risk that our necessary 3TG benefit armed groups.
Forward-looking statements are subject to risks and uncertainties that could cause actual actions or performance to differ materially from those expressed in the forward-looking statements. These risks and uncertainties include, but are not limited to, (1) the continued implementation of satisfactory traceability and other compliance measures by our direct and indirect suppliers on a timely basis or at all, (2) whether smelters and refiners and other market participants responsibly source 3TG, and (3) political and regulatory developments, whether in the Democratic Republic of the Congo (“DRC”) region, the United States or elsewhere. You are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of filing of this document. We do not intend, and undertake no obligation, to publish revised forward-looking statements to reflect events or circumstances after the date of filing of this document or to reflect the occurrence of unanticipated events.
Company and Product Information
Colfax Corporation is a diversified global industrial manufacturing and engineering company that provides gas- and fluid-handling and fabrication technology products and services to commercial and governmental customers around the world under the Howden, ESAB and Colfax Fluid Handling brand names.
Our in-scope product categories for 2016 were: (1) gas- and fluid-handling products, consisting of pumps, fluid-handling systems and controls, specialty valves, heavy-duty centrifugal and axial fans, rotary heat exchangers and gas compressors; and (2) welding equipment, cutting equipment and automated welding and cutting systems. For a further discussion of our products, see our Annual Report on Form 10-K for the year ended December 31, 2016. The information contained in our Form 10-K is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or the Form SD.
Applicability of the Conflict Minerals Rule to Our Company
We are subject to the Conflict Minerals Rule because some of the products that we manufacture contain 3TG that are necessary to their functionality or production. Our in-scope products contain tin, tantalum, tungsten and gold, although each in-scope product does not contain all four 3TG.
We generally do not source 3TG from smelters or refiners and have no direct relationships with mines, and we believe that we are in most cases many levels removed from all of these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that our sourcing practices are consistent with our Conflict Minerals Policy, which is described below, and encourage conflict free sourcing in our supply chain.
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Product, smelter and refiner information in respect of 2016 is described under “Product Information” below and on Annex A. For 2016, each of our in-scope products contained 3TG content for which we were unable to determine the origin. None of the necessary 3TG contained in our in-scope products were determined by us to directly or indirectly finance or benefit armed groups in the DRC or an adjoining country. However, we did not conclude that any of our products were “DRC conflict free.” The terms “adjoining country,” “armed group” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
Our Conflict Minerals Policy
We are committed to being a responsible corporate citizen and are opposed to human rights abuses such as are occurring in the DRC. To this end, we have adopted and communicated to our suppliers and the public a company policy (the “Conflict Minerals Policy”) for the supply chain of 3TG.
The Conflict Minerals Policy includes, but is not limited to, our expectations that:
| 1. | The components, parts and products supplied to us are DRC conflict free within the meaning of the Conflict Minerals Rule; |
| 2. | Our suppliers define, implement and communicate to sub-suppliers their own 3TG policy consistent with our Conflict Minerals Policy and the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”); and |
| 3. | Our suppliers implement policies, procedures and frameworks that are consistent with the OECD Guidance and require their direct and indirect sub-suppliers to do the same, and that our suppliers otherwise work with sub-suppliers to ensure traceability of 3TG. |
We do not embargo sourcing of 3TG from the DRC region and encourage our suppliers to continue to source responsibly from the region, from sources that do not support conflict.
Reasonable Country of Origin Inquiry Information
As required by the Conflict Minerals Rule, for 2016, we conducted a “reasonable country of origin inquiry.” For our reasonable country of origin inquiry, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the OECD Guidance, which are discussed below.
Our inquiry included approximately 12,233 suppliers (the “Suppliers”) that we identified as having provided us with components, parts or products that contain 3TG or that we believe may have provided us with components, parts or products that contain 3TG. For 2016, the Suppliers identified to us 317 smelters and refiners that processed or may have processed the necessary 3TG contained in our in-scope products, as shown and described under Annex A below. These smelters and refiners include 246 smelters and refiners identified as “Compliant” and 13 identified as “Active,” each as defined in Annex A. This information is based primarily on company-level declarations from Suppliers. Accordingly, many of these smelters and refiners may not be part of our supply chain, as we generally were not able to collect data at the product-level.
Based on the results of our reasonable country of origin inquiry, we conducted due diligence for 2016. These due diligence efforts are discussed below.
Due Diligence Program Design
Design Framework
We designed our due diligence measures relating to 3TG to conform with, in all material respects, the criteria set forth in the OECD Guidance, Third Edition, including the related Supplements for tin, tantalum and tungsten and for gold (hereinafter referred to as the “OECD Guidance”).
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Selected Elements of Design Framework
The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our program design are discussed below. However, these are not all of the elements of the program that we have put in place to help ensure that the 3TG contained in our in-scope products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the five steps. Selected due diligence measures that we took in respect of 2016 are discussed under “Due Diligence Program Execution.”
| 1. | OECD Guidance Step One: “Establish strong company management systems” |
| a. | We have a Conflict Minerals Policy. We communicate the policy internally to our sourcing teams and to selected suppliers. The Conflict Minerals Policy also is posted on our website at http://ir.colfaxcorp.com/documentdisplay.cfm?DocumentID=13304. The information contained on our website is not incorporated by reference into this Conflict Minerals Report or our Form SD and should not be considered part of this Conflict Minerals Report or the Form SD. |
| b. | We have a team of senior staff under the Senior Vice President, Colfax Business System (“CBS”) and Supply Chain and General Counsel charged with managing our 3TG compliance strategy. The working group also includes representatives from each business platform. We supplement our compliance efforts with specialist outside counsel. |
| c. | Selected internal personnel are educated on the Conflict Minerals Rule, the OECD Guidance, our compliance plan and the procedures for reviewing and validating supplier responses to our inquiries. |
| d. | We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the Conflict-Free Sourcing Initiative (the “CFSI”) to identify smelters and refiners in our supply chain. The CMRT requests suppliers to provide information concerning the usage and source of 3TG in their products, as well as information concerning their related compliance efforts. We utilize a third-party service provider (the “Service Provider”) to conduct our supplier outreach and follow-up, as well as for the review and validation of supplier responses. |
| e. | We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, for at least five years. |
| f. | The Service Provider provides training and educational materials to suppliers to enhance the quality of responses. During 2016, we also conducted supplier webcasts to further inform our supply base of our expectations and program goals, which were attended by a broad range of suppliers. |
| g. | We have contractual terms relating to 3TG, which are incorporated into selected supplier contracts. |
| h. | We have a mechanism for employees, suppliers and other interested parties to report violations of our Conflict Minerals Policy. The contact information for our grievance mechanism is www.colfaxcorp.ethicspoint.com. |
| 2. | OECD Guidance Step Two: “Identify and assess risk in the supply chain” |
| a. | We request in writing, through the Service Provider, that suppliers provide us with a completed CMRT. The Service Provider follows up by email or phone on our behalf with suppliers that do not respond to the request within the specified time frame. |
| b. | The Service Provider on our behalf reviews supplier responses against its written review criteria to identify incomplete responses, potential errors and inaccuracies in the CMRTs that are received from suppliers. The Service Provider follows up by email or phone with suppliers that submit an incomplete response or a response that it concludes contains errors or inaccuracies. |
| c. | Smelter and refiner information provided by suppliers is reviewed by the Service Provider against the smelters and refiners listed on the Smelter Reference List tab of the CMRT and the list of known processing facilities published by the U.S. Department of Commerce (the “Commerce Department List”). To the extent that a smelter or refiner identified by a supplier is not on either of these lists, the Service Provider may take additional steps to attempt to determine whether the listed entity is a smelter or refiner. |
| d. | Smelter and refiner information also is reviewed against the lists of Compliant and Active smelters and |
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| refiners and country of origin information published by the CFSI. To the extent that a smelter or refiner identified by a supplier is not listed as Compliant by the CFSI, the Service Provider undertakes an additional review to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the DRC or an adjoining country. The Service Provider attempts to reach out to the smelter or refiner directly and conducts research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of its 3TG. |
| e. | The Service Provider evaluates suppliers’ due diligence processes and policies based on the suppliers’ responses to certain of the questions in the CMRT. These questions ask suppliers about their internal processes regarding 3TG. |
| f. | We take steps to gather additional information from suppliers whose responses lead us to believe additional information is warranted to help ensure that our supply chain is responsibly sourcing 3TG. This may include requesting product-specific CMRTs or other information. |
| 3. | OECD Guidance Step Three: “Design and implement a strategy to respond to identified risks” |
| a. | Our 3TG compliance team reviews the reports and evaluations prepared by the Service Provider and liaises with appropriate members of senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence. |
| b. | We undertake additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries, and respond via supplier follow-up, commercial escalation or other commensurate means to the risks identified via these reviews. |
| 4. | OECD Guidance Step Four: “Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain” |
In connection with our due diligence, we utilize and rely on information made available by the CFSI concerning independent third-party audits of smelters and refiners to assess smelter and refiner due diligence.
| 5. | OECD Guidance Step Five: “Report on supply chain due diligence” |
We file a Form SD and Conflict Minerals Report with the Securities and Exchange Commission and make these filings available on our website at http://ir.colfaxcorp.com/sec.cfm.
Due Diligence Program Execution
We performed the following due diligence measures in respect of 2016. These are not all of the measures that we took in furtherance of our Conflict Minerals Policy and 3TG compliance program or pursuant to the Conflict Minerals Rule and the OECD Guidance. For a discussion of the design of our due diligence measures, see “Due Diligence Program Design.”
| 1. | The Service Provider requested that the Suppliers provide us with a completed CMRT. Requests were sent to approximately 12,233 Suppliers. The Service Provider followed up by email or phone with Suppliers that did not respond to the request within a specified time frame. All non-responsive Suppliers were followed up with at least three times with a request to complete the CMRT. |
| 2. | The Service Provider reviewed the responses received from the Suppliers based on its written review criteria for completeness, errors and inaccuracies. The Service Provider generally followed up by email or phone with the Suppliers that submitted a response that triggered specified quality issues relating to completeness and accuracy. |
| 3. | To the extent that a completed response identified a smelter or refiner, the Service Provider reviewed that information against the lists of Compliant and Active smelters published by the CFSI. 246 of the identified smelters and refiners were listed as Compliant by the CFSI and 13 were listed as Active, as of May 4th, 2017. Please see Annex A below for further information regarding the smelters and refiners identified to us through our reasonable county of origin inquiry and due diligence. |
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| 4. | To the extent that a smelter or refiner identified by a Supplier was not listed as Compliant by the CFSI, the Service Provider attempted to reach out to the smelter or refiner directly and conducted research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of the sources of its 3TG. |
| 5. | Our 3TG compliance team reviewed the reports and evaluations prepared by the Service Provider and liaised with members of our senior management in our legal and supply chain teams, including our Senior Vice President, CBS and Supply Chain and General Counsel, regarding the results of our diligence. |
| 6. | We undertook additional internal reviews with our legal and supply chain teams on a periodic basis using the information provided by the Service Provider, our suppliers and our independent inquiries. |
Identified Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed on Annex A below either as part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2016. Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our suppliers for accurate smelter and refiner information and our due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope products.
We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us or our Service Provider with a completed CMRT, and through the other activities described herein that were taken by us or the Service Provider. From the responses that we received, the Service Provider identified 6 smelters that were not listed as Compliant that potentially pose a risk because of the location of their facilities. For suppliers that identified these smelters of concern on their CMRT, we created a new escalation plan.
Future Risk Mitigation Efforts
We intend to take the following additional steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups in the DRC and its adjoining countries. These steps are in addition to the steps that we took in respect of 2016, which we intend to continue to take in respect of 2017 to the extent applicable.
| 1. | Engage with applicable Suppliers that provided incomplete responses or that did not provide responses for 2016 to help ensure that they provide requested information for 2016. |
| Ø | Provide additional outreach to Suppliers with non-compliant responses |
| Ø | Conduct further training for Suppliers |
| Ø | Work to identify improved contacts for non-respondents |
| 2. | Encourage the continuing development and progress of traceability measures at Suppliers that indicated for 2016 that the source of 3TG was unknown or undeterminable. |
| 3. | Continue communicating to suppliers our sourcing expectations, including through the dissemination of the Conflict Minerals Policy to them and required adherence to contractual sourcing requirements. |
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Annex A
Capitalized terms used and not otherwise defined in this Annex have the meanings set forth in the Conflict Minerals Report of which this Annex is a part.
Smelters and Refiners
In connection with our reasonable country of origin inquiry or due diligence, as applicable, the Suppliers identified to us the smelters and refiners listed below as either being part of our supply chain or as potentially having processed the necessary 3TG contained in our in-scope products in 2016. Please see the notes that accompany the tables for additional information concerning the information in the tables.
Summary Smelter and Refiner Information
| Metal |
Compliant |
Active |
On Reference List Only |
Total | ||||
| Tantalum |
45 | 0 | 2 | 47 | ||||
| Tin |
68 | 5 | 11 | 84 | ||||
| Tungsten |
40 | 0 | 5 | 45 | ||||
| Gold |
93 | 8 | 40 | 141 | ||||
| Totals |
246 | 13 | 58 | 317 |
Smelter and Refiner Names and Status
| Metal |
Standard Smelter Name |
Facility Location |
CFSI Audit Status | |||
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Active | |||
| Gold | Advanced Chemical Company | UNITED STATES | Compliant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Compliant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Compliant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Reference List Only |
A-1
| Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant | |||
| Gold | AURA-II | UNITED STATES | On Reference List Only | |||
| Gold | Aurubis AG | GERMANY | Compliant | |||
| Gold | Bangalore Refinery | INDIA | Active | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
| Gold | Boliden AB | SWEDEN | Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
| Gold | Caridad | MEXICO | On Reference List Only | |||
| Gold | CCR Refinery—Glencore Canada Corporation | CANADA | Compliant | |||
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Active | |||
| Gold | Chimet S.p.A. | ITALY | Compliant | |||
| Gold | Chugai Mining | JAPAN | On Reference List Only | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Reference List Only | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | On Reference List Only | |||
| Gold | DODUCO GmbH | GERMANY | Compliant | |||
| 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 | On Reference List Only | |||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | On Reference List Only | |||
| Gold | Geib Refining Corporation | UNITED STATES | Active | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Reference List Only | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | On Reference List Only | |||
| Gold | Gujarat Gold Centre | INDIA | On Reference List Only | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Reference List Only | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | On Reference List Only | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant |
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| 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 | On Reference List Only | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | On Reference List Only | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Reference List Only | |||
| Gold | L’Orfebre S.A. | ANDORRA | On Reference List Only | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Gold | Morris and Watson | NEW ZEALAND | On Reference List Only |
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| Gold | Morris and Watson Gold Coast | AUSTRALIA | On Reference List Only | |||
| 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 | Pease & Curren | UNITED STATES | On Reference List Only | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Gold | Republic Metals Corporation | UNITED STATES | Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Compliant | |||
| Gold | SAAMP | FRANCE | On Reference List Only | |||
| Gold | Sabin Metal Corp. | UNITED STATES | On Reference List Only | |||
| Gold | SAFINA A.S. | CZECH REPUBLIC | On Reference List Only | |||
| Gold | Sai Refinery | INDIA | On Reference List Only | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant | |||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only |
A-4
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant | |||
| Gold | Sudan Gold Refinery | SUDAN | On Reference List Only | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | Active | |||
| 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 | On Reference List Only | |||
| Gold | Tony Goetz NV | BELGIUM | Active | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 |
A-5
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 |
A-6
| 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 | On Reference List Only | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant |
A-7
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| Tin | PT Karimun Mining | INDONESIA | Compliant | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant |
A-8
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only | |||
| 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 | On Reference List Only |
A-9
| 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 | On Reference List Only | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | On Reference List Only | |||
| 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 | Unecha Refractory metals plant | RUSSIAN FEDERATION | 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 |
A-10
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
We note the following in connection with the information contained in the foregoing tables:
| (a) | The smelters and refiners reflected in the tables were identified by the Suppliers to us as potentially being part of our 2016 supply chain. However, not all of the included smelters and refiners are believed by us to have processed the necessary 3TG contained in our in-scope products, since most Suppliers reported to us at a “company level” the 3TG contained in all of their products, not just those in the products that they sold to us. Some Suppliers also may have reported to us smelters and refiners that were not in our supply chain due to over-inclusiveness in the information received from their suppliers or for other reasons. The smelters and refiners reflected above may not be all of the smelters and refiners in our supply chain, since many Suppliers were unable to identify all of the smelters and refiners used to process the necessary 3TG content contained in our in-scope products and not all of the Suppliers responded to our inquiries. |
| (b) | All compliance status information in the tables is as of May 4, 2017. |
| (c) | “Compliant” means that a smelter or refiner was listed as compliant with the Conflict-Free Smelter Program’s (“CSFP”) assessment protocols, including through mutual recognition and those indicated as “Re-audit in process,” as publicly reported by the CFSI. Included smelters and refiners were not necessarily Compliant for all or part of 2016 and may not continue to be Compliant for any future period. |
| (d) | “Active” means that the smelter or refiner was listed as having submitted a signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts to the CFSP or the smelter has agreed to complete a CFSP validation audit within two years of membership issuance by the Tungsten Industry – Council Minerals Council, in each case according to information published by the CFSI. |
| (e) | A smelter or refiner is listed as “On Reference List Only” if it was not Compliant or Active. |
| (f) | The compliance status in both tables are based on information published by the CFSI, without independent verification by us. |
| (g) | The tables include only entities that are listed as verified smelters on the Smelter Reference List tab of the CMRT, Revision 4.20, or that are listed on the Commerce Department List. |
| (h) | Smelter and refiner country location is based on information published by the CFSI, without independent verification by us. |
Country of Origin Information
The identified countries of origin of the 3TG processed by the Compliant smelters and refiners listed in the table above may have included the countries in the categories listed below, based on information provided by the Service Provider. We have not been able to reliably determine the country of origin of any of the other smelters or refiners listed in the table. The countries below are categorized by risk.
L1 - Countries that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, 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 and Zimbabwe.
L2 - Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique and South Africa.
A-11
L3 - The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC - The Democratic Republic of the Congo.
Alternatively, or in addition, some of the Compliant smelters and refiners may have sourced from recycled or scrap sources.
A-12