EXHIBIT 1.01
DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2020
Introduction
This Conflict Minerals Report (“Report”) has been prepared by management of DXP for the period from January 1, 2020 to December 31, 2020 (“Reporting Period”). Unless the context otherwise indicates, "DXP", “Company”, "we", "us", and "our" means DXP Enterprises, Inc. and its majority owned subsidiaries and any entities that are required to be consolidated.
This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing Conflict Minerals (as hereinafter defined) that are necessary to the functionality or production of their products. The term Conflict Minerals is defined to mean: (A) cassiterite, columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are currently limited to tin, tantalum, tungsten and gold (collectively the “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 country that shares an internationally recognized border with the DRC (collectively “Covered Countries”). DXP designed its due diligence measures to conform in all material respects with the internationally recognized due diligence framework in The Organization of Economic Co-Operation and Development.
DXP has reason to believe that some 3TGs may be present in its supply chain that may have originated in any of the Covered Countries. Therefore, we performed a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs in our products originated from any Covered Countries. This Report describes the measures DXP took to exercise due diligence on the source and chain of custody of the Conflict Minerals, the Company products that may contain 3TGs and are therefore in the scope of the Company’s Conflict Minerals program, the facilities that may have processed the 3TGs that may be necessary to the functionality or production of one or more products, and the efforts DXP took to determine the mine or location of origin of those 3TGs. Although we are unable to determine the origins of all 3TGs in our products, only some of our products fall within the scope of the Rule because they may contain one or more of the 3TGs.
Company and Product Overview
Our business
DXP Enterprises, Inc. is headquartered in Houston Texas and is a diversified industrial distribution company that conducts business in three business segments: Service Centers, Supply Chain Services and Innovative Pumping Solutions. DXP is engaged in the business of distributing maintenance, repair, and operating products, equipment and services to energy and industrial customers. The Service Centers provide a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, industrial supply, safety product and service categories. We currently serve as a first-tier distributor of more than 1,000,000 items. These items are for use primarily by customers engaged in the oil and gas, food and beverage, petrochemical, transportation and other general industrial industries. Other industries served by our Service Centers include mining, construction, chemical, municipal, agricultural and pulp and paper. The Innovative Pumping Solutions segment provides integrated, custom pump skid packages, pump remanufacturing and manufactures branded private label pumps it manufactures. The Supply Chain Services segment manages all or part of its customers’ supply chains, including procurement and inventory management.
Description of Products
For the purposes of this Report, we reviewed our supply base in order to determine the suppliers of materials/components that may possibly contain some 3TGs. Some of our suppliers have reported to us that some of our products that may be necessary to the functionality or production of products that we manufactured or contracted to
manufacture during the 2020 Reporting Period may contain 3TGs. DXP is unsure of the presence of 3TGs in our products, however, based on the Conflict Minerals Reporting Template (“CMRT”) we received from suppliers, the presence of 3TGs may be in some of their products. Many of our suppliers completed their CMRTs at the company, business unit or entity level basis. Due to this we are unable to definitively conclude which 3TGs, if any, are present in any products that were supplied to us.
Reasonable Country of Origin Inquiry
To determine whether necessary 3TGs in our products originated in Covered Countries, we retained Assent Compliance (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. We provided a list composed of suppliers and parts associated with the in-scope products to Assent for upload to the Assent Compliance Manager (“ACM”). We could not determine definitively the presence or absence of Conflict Minerals in all parts and products supplied to us for our products.
To collect data on the materials’ sources of origin procured by the supply chain, DXP utilized the CMRT version 6.1 or higher to conduct a survey of all our in-scope suppliers.
During the supplier survey, DXP contacted suppliers via the ACM, a software-as-a-service (“SaaS”) platform provided by Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. The ACM also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health score based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this Report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.
Via the ACM and the Assent team, we requested that all suppliers to complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. Assent monitored and tracked all communications in the ACM for future reporting and transparency. In order to increase the response level, Assent provided our suppliers with a stated deadline and followed up with both “reminder” and “late” notices.
Our program continues to include 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. This data evaluation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Assent’s multilingual Supplier Experience team. Since some suppliers may remain unresponsive to feedback DXP tracks program gaps to account for future improvement opportunities. As of December 31, 2020 there were 15 invalid supplier submissions that could not be corrected.
As of December 31, 2020 there were 2569 suppliers in scope of the conflict minerals program and 849 provided a completed CMRT. Our total response rate for this reporting year was 34%. Based on the findings through the RCOI process, DXP was able to determine the countries of origin for a portion of the 3TGs in our products. As such, we continued to perform further due diligence on the source and chain of custody of the minerals in question.
Due Diligence
Design of Due Diligence
With the assistance of Assent, we have designed our due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due
diligence that are described by the OECD Guidance. DXP continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.
Due diligence requires our necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by us. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.
Due Diligence Performed
Establishing Strong Company Management Systems
Internal Compliance Team
We have a Conflict Minerals Team comprised of individuals in management positions across legal, finance, and procurement. This Team leads our Conflict Minerals compliance effort and is responsible for implementing the Conflict Minerals compliance strategy.
We also use Assent to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we may undertake with suppliers in regard to Conflict Minerals.
We leverage Assent’s Managed Services in order to work with dedicated program specialist who support our conflict minerals program. DXP communicates regularly with the Assent team in order to receive updates on program status. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.
Control Systems
DXP expects all of its suppliers to have policies and procedures in place to ensure that 3TGs used in the production of the products sold to us are DRC conflict-free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. We rely upon our direct suppliers to provide information on the origin of any 3TGs contained in components and materials supplied, including sources of 3TGs that were supplied to us and that were supplied to them from lower tier suppliers.
Supplier Engagement
We have a good relationship with Tier 1 direct suppliers. As an extremely important part of the supply chain, DXP has leveraged processes and educational opportunities in order to ensure non-English speaking suppliers have access a free platform to unload their CMRT’s, help desk support and other multilingual resources. Our suppliers are able to leverage Assent’s team of supplier support specialists to ensure they receive appropriate support and understand how to properly file a CMRT. Suppliers are provided guidance in their native language, if needed.
DXP engages with suppliers to request a valid CMRT for the products that they supply to us. With respect to the OECD requirement to strengthen engagement with suppliers, we have developed an internal procedure that includes steps of supplier engagement escalation such as corrective actions. Feedback from this engagement has allowed us to oversee improvements in supplier responses and supplier compliance for this initiative.
We continue to place a strong emphasis on supplier education and training. To accomplish this, Assent’s online resources are leveraged, and all in-scope suppliers have been provided with access to their library of conflict minerals training and support resources.
We believe that the combination of our Code of Conduct, Conflict Minerals Policy, and direct engagement with our suppliers for Conflict Minerals training and requests constitute a strong supplier engagement program.
\Grievance Mechanisms
DXP has established multiple grievance mechanisms whereby employees and suppliers can report violations of DXP’s policies, including Conflict Minerals. Suppliers and others outside of DXP may contact us anonymously to report grievances via a dedicated email address that is published in our Conflicts Minerals Policy and in our Code of Conduct. In addition, our employees may anonymously report suspected violations using the same dedicated email address, dxpe.ethicspoint.com, or our anonymous third-party conduct help line at (888) 307-4308, as published in our Conflicts Minerals Policy and in our Code of Conduct.
Maintain Records
We have adopted a policy to retain relevant documents with Assent for a period of five years. Through Assent, a document retention policy to retain Conflict Minerals related documents, including supplier responses to CMRTs and the sources identified within each reporting period, has been implemented. We store all the information and findings from this process in a database than can be audited by internal and external parties.
Identifying and Assessing Risks in the Supply Chain
Due to our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain it is difficult to identify actors upstream from our direct suppliers. Risks associated with supplier CMRT content are identified automatically in the ACM based on criteria established for supplier responses. These risks are addressed by Assent staff, who contacts the supplier, gathers pertinent data and performs an assessment of the supplier’s Conflict Minerals status.
Risks at the supplier level may include non-responsive suppliers, incomplete CMRTs, or CMRTs that are submitted at a company, business unit or division level. In those cases we are unable to determine if all of the specified smelters and refiners were used for 3TGs in the products supplied to us.
Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were identified by assessing the due diligence practices and status of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners consolidated by the RMI to ensure that the facilities met the recognized definition of a 3TGs processing facility that was operation during the 2020 calendar year.
Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RAMP”). DXP does not have a direct relationship with smelters and refiners, and does not perform direct audits of these entities within their pre-supply chain. Smelters that have completed a RMAP audit are considered to be DRC-conflict free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard or they are considered non-conformant by RMAP, follow-ups are made to suppliers reporting those facilities. Smelters are then assessed for the potential for sourcing risk.
Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter or refiner poses to the supply chain by identifying red flags. These factors include, but are not limited to:
1.Geographic proximity to the Covered Countries.
2.RMAP audit status.
3.Credible evidence of unethical or conflict sourcing.
4.Known mineral source country of origin.
5.Peer assessments conducted by credible third-party sources.
Risk mitigation activities are initiated whenever a supplier’s CMRT reported facilities of concern. Through Assent, suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing the supplier to take their own independent risk mitigation actions. Examples include the submission of a product specific CMRT to better identify the connection to products that they supply to us. Suppliers are given clear performance objectives within reasonable time frames with the ultimate goal of progressive elimination of these smelters of concern from the supply chain. In addition, suppliers are guided to the educational materials on mitigating the risks identified through the data collection process.
Suppliers are also evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies.
Designing and Implementing a Strategy to Respond to Risks
Together with Assent, we developed processes to access and respond to the risks identified in the supply chain. We have a risk management plan, through which our Conflict Minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules and our expectations.
Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. We will engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance. Assent also communicates directly with smelters that have not been determined to be conformant with the RMAP in order to request sourcing information and encourage their involvement with the RMI program.
Carry Out Independent Third-Party Audit of Supply Chain Due Diligence
We do not have a direct relationship with any 3TG smelters and refiners of Conflict Minerals and we do not perform or direct audits of these entities within the supply chain. Instead, we rely upon third-party audits of smelters and refiners conducted as part of RMAP. RAMP uses independent private sector auditors, and audits the source, including the mines of origin, and the chain of custody of the Conflict Minerals used by smelters and refiners that agree to participate in the program.
Report Annually on Supply Chain Due Diligence
We have published our Form SD for the year ended December 31, 2020. Form SD and this Report is available on our website at www.dxpe.com within the “Investors” section under “Investor Relations” > “Financial Information “ > “SEC Filings”. Information found on or accessed through our website is not consider part of this Report and is not incorporated herein by reference. We have also publicly filed our Form SD and this Report with the U.S. Securities and Exchange Commission.
Results of Due Diligence
Survey results
For the 2020 reporting year Assent received CMRTs from 849 suppliers. All final CMRT submissions were reviewed and validated by Assent to ensure no inaccuracies or gaps in data were found. There were 15 suppliers that were unable to correct their CMRT and as such, are listed as invalid submissions.
Smelters and Refiners
Attached as Appendix A is a table that lists all the smelters and refiners identified by our responsive direct suppliers that may have been used to process the Conflict Minerals necessary to the functionality or production of our Covered Products during the 2020 calendar year. This list may contain more facilities than are actually linked to the
Company’s Covered Products. Alternatively, this list may not include all applicable facilities as not all of our suppliers were able to provide the required information at this time. Those that have been validated as compliant under RAMP by the RMI, have been noted as such in the final column on the right in Appendix A. From the responses received, Assent identified 5 smelters that potentially posed a risk due to the presence of some red flag indicators.
Countries of Origin
Appendix B is an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RAMP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by us, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.
Steps to be Taken To Mitigate Risk
Since January 1, 2020 we have taken or we intend to take, the following steps to improve due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC or adjoining countries:
1.Continue to evaluate upstream sources through a broader set of tools to evaluate risk.
2.Engage with suppliers more closely and provide more information and training resources regarding responsible sourcing of 3TGs.
3.Encourage suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
4.Following OECD Guidance process, increase the emphasis on clean and validated smelter and refiner information from the supply chain through feedback and detailed smelter analysis.
Smelter & Refiner Risk Evaluation
Understanding the risks associated with the smelters and refiners potentially providing material into our supply chain is an important part of the due diligence process. Through Assent, comprehensive and ongoing analysis is conducted by Assent’s smelter library manager to assess sourcing risk. This information is used to:
1.Provide supplier feedback.
2.Determine the health of our overall program.
3.Conduct outreach to smelters, refiners and their respective associations.
4.Provide detailed analysis in this Report.
The following risk categories are used for smelter evaluation and risk determination:
1.Geo-Risk.
2.Audit Status.
3.Sourcing Risk.
Appendix A Refiners and Smelters List:
| | | | | | | | | | | |
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID |
Gold | 8853 S.p.A. | ITALY | CID002763 |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Gold | African Gold Refinery | UGANDA | CID003185 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
Gold | Alexy Metals | UNITED STATES OF AMERICA | CID003500 |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | 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 OF AMERICA | 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 | Augmont Enterprises Private Limited | INDIA | CID003461 |
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 | C.I Metales Procesados Industriales SAS | COLOMBIA | CID003421 |
Gold | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
| | | | | | | | | | | |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 |
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. East Plant | JAPAN | CID000425 |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | CID003487 |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | CID003488 |
Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | CID003489 |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | CID003490 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
Gold | Gold Coast Refinery | GHANA | CID003186 |
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 | 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 | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Italpreziosi | ITALY | CID002765 |
Gold | JALAN & Company | INDIA | CID002893 |
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 | K.A. Rasmussen | NORWAY | CID003497 |
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 OF AMERICA | 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 | Kundan Care Products Ltd. | INDIA | CID003463 |
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 | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Gold | Marsam Metals | BRAZIL | CID002606 |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Gold | MD Overseas | INDIA | CID003548 |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | CID003557 |
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 OF AMERICA | CID001157 |
Gold | Metalurgica Met-Mex Penoles 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 | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | 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 | Ogussa Osterreichische 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 OF AMERICA | 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 Precinox 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 PMR B.V. | NETHERLANDS | CID002582 |
Gold | Royal Canadian Mint | CANADA | CID001534 |
Gold | SAAMP | FRANCE | CID002761 |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | 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 | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | CID003529 |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
Gold | Sellem Industries Ltd. | MAURITANIA | CID003540 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
| | | | | | | | | | | |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | CID002527 |
Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
Gold | Sovereign Metals | INDIA | CID003383 |
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 HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
Gold | Super Dragon Technology Co., Ltd | TAIWAN, PROVINCE OF CHINA | CID001810 |
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 Precious Metals Thailand | THAILAND | CID002314 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| | | | | | | | | | | |
Gold | Yamakin 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 OF AMERICA | CID002504 |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | 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 OF AMERICA | CID002557 |
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 OF AMERICA | 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 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 | 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 | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | CID002847 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
Tin | Alpha | UNITED STATES OF AMERICA | 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | CID003486 |
Tin | CRM Synergies | SPAIN | CID003524 |
Tin | CV Ayi Jaya | INDONESIA | CID002570 |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 |
Tin | Dowa | JAPAN | CID000402 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
| | | | | | | | | | | |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
Tin | Fenix Metals | POLAND | CID000468 |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 |
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 Co., Ltd. | CHINA | CID003116 |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
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 OF AMERICA | 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 | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | CID001305 |
| | | | | | | | | | | |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 |
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 Serumpun | INDONESIA | CID003205 |
Tin | PT Bukit Timah | INDONESIA | CID001428 |
Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 |
Tin | PT Masbro Alam Stania | INDONESIA | CID003380 |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 |
Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 |
Tin | PT Timah Nusantara | INDONESIA | CID001486 |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 |
Tin | Super Ligas | BRAZIL | CID002756 |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 |
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 | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
Tin | Yunnan Tin Company Limited | CHINA | CID002180 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
Tungsten | Artek LLC | RUSSIAN FEDERATION | CID003553 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
Tungsten | China Molybdenum Co., Ltd. | CHINA | CID002641 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 |
Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 |
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 | GEM Co., Ltd. | CHINA | CID003417 |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | 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 Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
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 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 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
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 |
Appendix B Country of Origin List:
Afghanistan
Albania
Angola
Argentina
Armenia
Australia
Austria
Belarus
Belgium
Bermuda
Bolivia
Brazil
Bulgaria
Burundi
Cambodia
Canada
Central African Republic
Chile
China
Colombia
Czech Republic
Djibouti
Dominican Republic
DRC or an adjoining country (Covered Countries)
Ecuador
Egypt
England
Estonia
Ethiopia
Finland
France
Germany
Ghana
Guinea
Guyana
Hungary
India
Indonesia
Ireland
Israel
Italy
Ivory Coast
Japan
Kazakhstan
Kenya
Kyrgyzstan
Laos
Liberia
Lithuania
Luxembourg
Madagascar
Malaysia
Mali
Mauritania
Mexico
Mongolia
Morocco
Mozambique
Myanmar
Namibia
Netherlands
New Zealand
Niger
Nigeria
Papua New Guinea
Peru
Philippines
Poland
Portugal
Republic Of Korea
Russia
Rwanda
Saudi Arabia
Sierra Leone
Singapore
Slovakia
Slovenia
South Africa
Spain
Sudan
Suri
Suriname
Sweden
Switzerland
Tanzania
Thailand
Turkey
Uganda
United Arab Emirates
United Kingdom
USA
Uzbekistan
Vietnam
Zambia
Zimbabwe