EXHIBIT 1.01
DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2021
INTRODUCTION
This Conflict Minerals Report for DXP Enterprises, Inc. for calendar year 2021 was prepared in accordance with the requirements of Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act, as amended, and in connection with the required disclosure filed on specialized disclosure form (“Form SD”). Unless the context otherwise indicates, all references to DXP Enterprises, Inc., the “Company” or “we”, “us” and “our” refer to DXP Enterprises, Inc. and its consolidated subsidiaries.
Rule 13p-1 implemented Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”), and requires Securities and Exchange Commission (“SEC”) reporting companies that meet certain threshold requirements, to undertake a reasonable country of origin inquiry and supply chain due diligence on the source and chain of custody of the conflict minerals necessary to the functionality or production of any product manufactured or contracted to manufactured by the reporting company. The term “Subject Minerals” currently encompasses cassiterite, columbite-tantalite (coltan), and wolframite (or their derivatives, which are limited to tantalum, tin and tungsten) and gold (collectively referred to as “3TGs” or “Subject Minerals”).
The goal of the reasonable country of origin inquiry (“RCOI”) and supply chain due diligence is to determine whether the Subject Minerals necessary to the functionality or production of products manufactured or contracted to be manufactured by a company directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (“DRC”) or any country that shares an internationally recognized border with the DRC (collectively “Covered Countries”). The Dodd-Frank Act refers to this area as the “Covered Countries”. Reporting companies that are subject to Rule 13p-1 are required to make certain disclosures on Form SD and, in certain instances, an accompanying Conflict Minerals Report, which are filed with the SEC.
COMPANY AND PRODUCT OVERVIEW
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, chemical, petrochemical, transportation, aerospace, mining, utilities and other general industrial industries. 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. We believe that a very limited amount of sales of our products contain Subject Minerals that are necessary to their functionality or production and were attributable to products manufactured by us or contracted to be manufactured for us.
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 2021 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
We conducted a reasonable country of origin inquiry about the conflict minerals necessary to functionality or production of products manufactured by us, or contracted to be manufactured for us. DXP, with Assent’s assistance, conducted a survey of the suppliers using the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). We used Assent’s database to organize and retain supplier responses.
We identified certain suppliers that did not conform with our conflict minerals policy of providing sourcing information to us upon request. We made repeat requests to non-responsive suppliers educating and urging them to submit completed CMRTs. We also undertook additional follow-up with suppliers to obtain more complete information or to clarify responses.
We and Assent analyzed the responses that we received in an effort to determine the country of origin of the necessary conflict minerals in the products that we manufacture or contract for manufacture. Only a small number of our suppliers provided information relating to country of origin, and that information was not sufficiently detailed or product-specific for us to identify the country of origin of the necessary conflict minerals in our products to indicate whether they were from recycled or scrap sources.
As a result of the responses we received, we were able to determine that some of our products manufactured or contracted for manufacture during the reporting period may contain necessary conflict minerals that originated, or may have originated from a Covered Country and are not or may not be from recycled or scrap sources.
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 Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, 2016 and the related supplements for tin, tantalum, and tungsten, and for gold (the “OECD Guidance”). As detailed in the following sections, our due diligence process has been designed to comply with the following 5 steps of the OECD Guidance:
1. Establishment of company management systems;
2. Identification and assessment of risks in our supply chain;
3. Design and implement a strategy to respond to identified risks;
4. Utilize independent third-party audits of supply chain due diligence; and
5. Publicly report on our supply chain due diligence.
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.
Due Diligence Measures
The due diligence measures we preformed are described below.
Step 1: Establishment of Company Management Systems.
We have a Conflict Minerals team comprised of individuals in management positions across legal, finance, and supply chain backgrounds. 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 specialists 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.
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.
As an extremely important part of the supply chain, DXP has leveraged processes and educational opportunities with the assistance of Assent in order to ensure non-English speaking suppliers have access to 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. DXP engages, along with Assent, 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. 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, our Conflict Minerals Policy, and direct engagement with our suppliers for Conflict Minerals training and requests constitute a strong supplier engagement program.
DXP has established 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.
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.
Step 2: Identification and Assessment of 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.
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 2021 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.Conflict-Free Smelter Program (RMAP) audit status;
3.Credible evidence of unethical or conflict sourcing;
4.Known mineral source country of origin; and
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.
Step 3: Design and Implement a Strategy to Respond to Identified 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.
Step 4: Utilize Independent Third-Party Audits 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.
Step 5: Publicly Report on our Supply Chain Due Diligence
We have published our Form SD for the year ended December 31, 2021. 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
All final CMRT submissions were reviewed and validated by Assent to ensure no inaccuracies or gaps in data were found. There were some suppliers that were unable to correct their CMRT and as such, are listed as invalid submissions.
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 2021 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 smelters that potentially posed a risk due to the presence of some red flag indicators.
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 and Improve Due Diligence
Since January 1, 2021 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 any country that shares an internationally recognized boarder with the DRC:
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.
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 | Dowa | Japan | CID000401 |
| 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 | Industrial Refining Company | Belgium | CID002587 |
| 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. | Czechia | 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 | 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. | 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 | 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 | Value Trading | Belgium | CID003617 |
| Gold | WEEEREFINING | France | CID003615 |
| 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 | Changsha South Tantalum Niobium Co., Ltd. | China | CID000211 |
| Tantalum | D Block Metals, LLC | United States Of America | CID002504 |
| 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 | 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 | Yancheng Jinye New Material Technology Co., Ltd. | China | CID003583 |
| 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 Venus Inti Perkasa | Bangladesh | 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 | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | CID003582 |
| Tin | Fenix Metals | Poland | CID000468 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | CID003410 |
| 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 | 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 Belitung Industri Sejahtera | Indonesia | CID001421 |
| Tin | PT Bukit Timah | Indonesia | CID001428 |
| Tin | PT Cipta Persada Mulia | Indonesia | CID002696 |
| Tin | PT Menara Cipta Mulia | Indonesia | CID002835 |
| Tin | PT Mitra Stania Prima | Indonesia | CID001453 |
| Tin | PT Mitra Sukses Globalindo | Indonesia | CID003449 |
| Tin | PT Panca Mega Persada | Indonesia | CID001457 |
| | | | | | | | | | | |
| Tin | PT Prima Timah Utama | Indonesia | CID001458 |
| Tin | PT Rajawali Rimba Perkasa | Indonesia | CID003381 |
| Tin | PT Refined Bangka Tin | Indonesia | CID001460 |
| Tin | PT Sariwiguna Binasentosa | Indonesia | CID001463 |
| Tin | PT Stanindo Inti Perkasa | Indonesia | CID001468 |
| Tin | PT Sukses Inti Makmur | Indonesia | CID002816 |
| Tin | PT 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 | PT Tirus Putra Mandiri | Indonesia | CID002478 |
| Tin | PT Tommy Utama | Indonesia | CID001493 |
| Tin | Resind Industria e Comercio Ltda. | Brazil | CID002706 |
| Tin | Rui Da Hung | Taiwan, Province Of China | CID001539 |
| Tin | Soft Metais Ltda. | Brazil | CID001758 |
| Tin | Super Ligas | Brazil | CID002756 |
| Tin | Thaisarco | Thailand | CID001898 |
| Tin | Tin Technology & Refining | United States Of America | CID003325 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | CID002574 |
| Tin | 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 | Fujian Xinlu Tungsten | China | CID003609 |
| 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 | 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 | OOO “Technolom” 1 | Russian Federation | CID003614 |
| Tungsten | OOO “Technolom” 2 | Russian Federation | CID003612 |
| 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:
| | | | | |
| Country List |
| Afghanistan | |
| Åland Islands | |
| Albania | |
| American Samoa | |
| Andorra | |
| Angola | |
| Argentina | |
| Armenia | |
| Australia | |
| Austria | |
| Belarus | |
| Belgium | |
| Bermuda | |
| Bolivia (Plurinational State of) | |
| Brazil | |
| Bulgaria | |
| Burundi | |
| Cambodia | |
| Canada | |
| Central African Republic | |
| Chile | |
| China | |
| Colombia | |
| Congo | |
| Democratic Republic of Congo | |
| Djibouti | |
| Dominica | |
| Dominican Republic | |
| Ecuador | |
| Egypt | |
| Eritrea | |
| Estonia | |
| Ethiopia | |
| Finland | |
| France | |
| Germany | |
| | | | | |
| Ghana | |
| Guinea | |
| Guyana | |
| Hong Kong | |
| Hungary | |
| India | |
| Indonesia | |
| Ireland | |
| Israel | |
| Italy | |
| Japan | |
| Kazakhstan | |
| Kenya | |
| Korea | |
| Kyrgyzstan | |
| Liberia | |
| Lithuania | |
| Luxembourg | |
| Madagascar | |
| Malaysia | |
| Mali | |
| Mauritania | |
| Mexico | |
| Mongolia | |
| Morocco | |
| Mozambique | |
| Myanmar | |
| Namibia | |
| Netherlands | |
| New Zealand | |
| Niger | |
| Nigeria | |
| Panama | |
| Papua New Guinea | |
| Peru | |
| Philippines | |
| Poland | |
| Portugal | |
| Russian Federation | |
| | | | | |
| Rwanda | |
| Saudi Arabia | |
| Sierra Leone | |
| Singapore | |
| Slovakia | |
| Slovenia | |
| South Africa | |
| South Sudan | |
| Spain | |
| Sudan | |
| Suriname | |
| Sweden | |
| Switzerland | |
| Taiwan | |
| Tajikistan | |
| Tanzania | |
| Thailand | |
| Turkey | |
| Uganda | |
| United Arab Emirates | |
| United Kingdom | |
| United States | |
| Uzbekistan | |
| Vietnam | |
| Zambia | |
| Zimbabwe | |
