Exhibit 1.01
Elbit Systems Ltd.
Conflict Minerals Report
For the Year Ended December 31, 2021
In Accordance with Rule 13p-1 under the Securities Exchange Act of 1934
A.Introduction
This Conflict Minerals Report (this “Report”) of Elbit Systems Ltd. (together with its wholly-owned subsidiaries, “Elbit Systems” or “we”) for the year ended December 31, 2021 is presented to comply with Rule 13p-1 (the “CM Rule”) under the Securities Exchange Act of 1934.
The CM Rule was adopted by the U.S. Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to “conflict minerals” under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Pursuant to Section 1502, publicly traded companies, such as Elbit Systems, must report to the SEC whether “conflict minerals” (tantalum, tin, tungsten and gold) (“3TG”) originating in the Democratic Republic of Congo (“DRC”) or adjoining countries (Angola, Burundi, The Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia) (the “Covered Countries”) are present in the products the company manufactures or contracts to manufacture, if any of the 3TG is necessary to the functionality or production of such products. The CM Rule was adopted because the sale of 3TG mined in the Covered Countries has funded armed conflicts in that region, and those conflicts have led to numerous human rights abuses and atrocities.
Unless otherwise defined herein, the terms used in this Report have the meanings ascribed to them in the CM Rule, Form SD and SEC Release No. 34-67716 issued by the SEC in 2012.
B.Company Overview
Elbit Systems Ltd. is an international high technology company engaged in a wide range of defense, homeland security and commercial programs throughout the world. We operate in the areas of aerospace, land and naval systems, command, control, communications, computers, intelligence, surveillance and reconnaissance, unmanned aircraft systems, advanced electro-optics, electro-optic space systems, electronic warfare suites, signal intelligence systems, data links and communications systems, radios, cyber-based systems and munitions. We also focus on the upgrading of existing platforms, developing new technologies for defense, homeland security and commercial applications and providing a range of support services, including training and simulation systems.
C.Applicability of the CM Rule to Elbit Systems
Elbit Systems designs, develops and manufactures a broad portfolio of sophisticated products and systems in numerous programs for our customers around the world. Such products and systems often include a range of electronic components. We purchase these components from a supply chain consisting of thousands of suppliers and/or manufacturers. We collect 3TG information from our suppliers, primarily first-tier manufacturers (i.e., manufacturers contracting directly with us) of the products or components supplied to us. Through this information and our own material engineering analyses we have determined 3TG are necessary to the functionality or production of a number of our products. Therefore, we are required to make a filing pursuant to the CM Rule because we manufacture certain products for which elements of 3TG are necessary to the product’s functionality or production.
We do not directly source any 3TG from mines, smelters or refiners, and we believe that in most cases we are many levels removed from these supply chain participants and therefore have limited influence over them. Furthermore, because of the depth, geographic diversity and ongoing changes in our supply chain, and due to competitive factors, we often have significant challenges in identifying the full supply chain from information provided by our direct suppliers. However, through the efforts described in this Report, we take measures so that our suppliers meet the expectations of our Conflict Minerals Compliance Policy, which is described below.
D.Conflict Minerals Compliance Policy
Elbit Systems’ policy is to use “conflict free” 3TG in our products, and we support industry actions to increase supply chain transparency to facilitate the ability of companies to source conflict free 3TG. Our Conflict Minerals Compliance Policy is published on our website at: www.elbitsystems.com.
Pursuant to our Conflict Minerals Compliance Policy, and as further described in this Report, we are taking measures to meet the applicable reporting obligations under the CM Rule and to enhance our supply chain due diligence and internal controls relating to 3TG. We are committed to sourcing materials from companies that share our values with respect to human rights, ethics and environmental responsibility. These supply chain values are reflected in our Supplier Code of Conduct, which can be found on our website. Our policy relating to conflict minerals is an important part of our overall practices regarding responsible supply chain management and is reflected in our Supplier Code of Conduct.
Elbit Systems periodically publishes additional information about our commitment to responsible sourcing and engagement with our suppliers and other stakeholders in our Social Sustainability Report, which includes an overview of our activities in the areas of ethics,
corporate governance, environmental compliance, fair employment and support for our local communities. The Social Sustainability Report is published on our website.
E.Overview of the Company's Conflict Minerals Program and Reasonable Country of Origin Inquiry ("RCOI") for 2021
As part of our commitment to responsible sourcing, human rights and sustainability, it is our goal that the 3TG in our products should not, directly or indirectly, finance or benefit armed groups in the Covered Countries. Our efforts with respect to 3TG are aligned to the work of the Responsible Minerals Initiative (“RMI”), and we strive to improve the traceability in our supply chain.
Elbit Systems has a Conflict Minerals Compliance and Management Review Team (the “CM Team”) that supports compliance with the CM Rule, performs the RCOI and reports on conflict minerals. The multi-disciplinary CM Team consists of specially designated personnel from our supply chain management, quality assurance, operations, materials engineering, information technology and legal departments. The CM Team is supported by outsourced services from specialists in the conflict minerals compliance and RCOI process.
We rely on our suppliers to provide information on the origin of 3TG contained in components and parts included in our products. The identification of suppliers that are relevant to us under the CM Rule involves different geographic regions, business areas and production sites throughout our organization. The CM Team plays a leading role in coordinating the supplier identification efforts. Suppliers who were identified to be relevant for our RCOI process in 2021 were identified on the basis of criteria such as the level of supply chain activities with such supplier and the likelihood that the items furnished by the supplier contain 3TG. The processes performed and described in this Report cover more than 95% of our worldwide supply chain activities relevant to 3TG.
In our annual RCOI process for 2021, we reviewed suppliers identified to be relevant under the above-mentioned identification criteria in an effort to determine the origin of the 3TG in our products. We analyzed and followed up with inquiries as we deemed appropriate where the analysis of our survey results indicated further information may be desirable. We do not have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.
We utilized reporting templates and databases, such as approved smelter and refiner lists, of 3TG industry initiatives such as the RMI, which is aligned with the Global e-Sustainability Initiative (GeSI) and the Electronic Industry Citizenship Coalition (EICC).
F.Conflict Minerals Program Design
Our RCOI activities and other 3TG-related activities are consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten
(the “OECD Guidance”). The design of our due diligence process, including our RCOI, conforms substantially to the OECD Guidance as it relates to “downstream” purchasers of products and components. These processes are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
Step 1 - Establish Strong Company Management Systems
As mentioned above, we have a dedicated CM Team. This Team is responsible for implementing our due diligence activities, reporting on 3TG in compliance with the CM Rule and informing senior managers and our board of directors about matters relating to our conflict minerals compliance. Our compliance policies include, but are not limited to, our Code of Business Conduct and Ethics and our Supplier Code of Conduct, which set forth expected behavior for all our employees and our supply chain. The Supplier Code of Conduct includes provisions relating to conflict minerals compliance and is integrated as a standard supplement into our supplier agreements.
We have internal Conflict Minerals Compliance Guidelines that set out the activities to be taken in our due diligence process. Moreover, as indicated above, we have a published company-wide Conflict Minerals Compliance Policy.
In 2021, identification of smelters and refiners in our supply chain was made through the use of due diligence tools, including those created by the RMI such as the EICC/GeSI Conflict Minerals Reporting Template (the “Template”). The Template is a supply chain survey designed to identify, among other 3TG-related information, the smelters and refiners that process the necessary 3TG contained in our supply chain. The information from our suppliers, in combination with information from the RMI, helps us to obtain information on the origin of the 3TG processed in our supply chain. Data obtained was reviewed and analyzed by us and is retained in our company records for the five-year period required by the CM Rule.
While our principal purchasing activities were conducted through our facilities in Israel and the U.S., during 2021 our activities also included 3TG compliance processes at our subsidiaries located in other countries, including RCOI and training activities.
We have grievance mechanisms under which employees and suppliers can report violations of our policies. This includes a whistleblower process for the reporting of alleged violations of laws or our Code of Business Conduct and Ethics, including issues relating to corruption, involving questionable accounting or auditing matters or which otherwise may seriously affect significant interests of Elbit Systems. This process is overseen by the Elbit Systems Chief Ethics Officer and by the Chair of the Audit and Financial Statements Review Committee of the Elbit Systems Board of Directors. Our Conflict Minerals Compliance
Policy and our Supplier Code of Conduct also contain reporting mechanisms for reports to applicable Elbit Systems’ management personnel.
Step 2 - Identification and Assessment of Risks in the Supply Chain
Our CM Team leads a process to identify and assess 3TG-related risks. We attempt to focus this process on the most relevant level in our 3TG supply chain, which is the smelters and refiners. As stated above, we require our suppliers to provide identification information relating to smelters and refiners in our supply chain.
During 2021, suppliers meeting our applicable 3TG criteria were requested by us to provide information on 3TG in their supply chains through completing and submitting the Template. Suppliers were provided with support material, including the generally available RMI instructions and training illustrating the use of the tool that is available on RMI’s website. To support the quality of the response and a high response rate, the responses received were analyzed on an ongoing basis and followed up as deemed appropriate by members of the CM Team. Supplier responses were reviewed against risk level criteria developed or utilized by us to determine: (1) the risk level applicable to the supplier regarding 3TG and (2) which responses require further engagement with our suppliers, such as when the responses from suppliers were incomplete. Certain suppliers were contacted via e-mail or telephone to improve the quality of responses and increase the response rate.
Step 3 - Design and Implementation of a Strategy to Respond to Identified Risks
Under the third step of the OECD Guidance framework companies are encouraged to design and implement a strategy to respond to identified risks. Our due diligence is an ongoing process, both proactive and reactive, where suppliers are evaluated against our conflict mineral risk categories on a continuous basis to facilitate conflict mineral compliance in the suppliers’ processes.
Our due diligence process categorizes suppliers’ responses regarding 3TG under one of the following six conflict mineral risk categories (“DRC or an adjoining country” has the same meaning in this context as “Covered Countries”):
1.No 3TG - 3TG is not intentionally added to the product and not necessary to the production of the product.
2.Free/Not From DRC - The 3TG being used in the product do not originate from the DRC or an adjoining country.
3.Active/Conformant - The 3TG being used in the product originate from the DRC or an adjoining country; however, the smelters and refiners have been designated as “conformant” (formerly “complaint”) or “active” by the RMI under its Responsible Minerals Assurance Process (“RMAP”).
4.Undetermined/Not from DRC - The 3TG being used in the product do not originate from the DRC or an adjoining country, but to date the supplier has not provided
complete information on all of its sources of supply.
5.Undetermined/from DRC - The 3TG being used in the product originate from the DRC or an adjoining country; however, the smelters and refiners have been designated as “conformant” or “active” under the RMAP, and to date the supplier has not provided complete information on all of its sources of supply.
6.Undefined from DRC - The 3TG being used in the product originate from the DRC or an adjoining country, and the smelters and refiners have not been designated as “conformant” or “active” under the RMAP.
During 2021, we used this risk-based approach and followed up with suppliers.
We continuously worked to improve our due diligence processes with respect to 3TG, mainly focusing on the quality of data received from suppliers surveyed. This included communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. It also included follow-up communications with suppliers regarding RCOI issues.
Step 4 - Carry Out Independent Third Party Audit of Supply Chain Due Diligence and Identification Points in the Supply Chain
In the fourth step we focus on review of smelters’ and refiners’ 3TG practices. Since, as mentioned above, there are generally many tiers of suppliers between Elbit Systems and the smelters and refiners in the supply chain, we have not performed our own audits of smelters or refiners.
We reviewed the data received from our suppliers with respect to smelters and refiners and compared such information against the lists of facilities that have received either an “active” or “conformant” designation from the RMI or otherwise appeared on the RMI’s Smelter Reference List.
Although we are not currently required to conduct an Independent Private Sector Audit under the CM Rule, during 2021 we continued to take steps, such as enhancing our internal controls, to prepare us for such an audit in the future, if applicable.
Step 5 - Report on Supply Chain Due Diligence
In compliance with the fifth step of reporting on supply chain due diligence, and in accordance with the CM Rule, during 2021 we continued to make our Conflict Minerals Report available on our website.
G.2021 Conflict Minerals Program Results
For the calendar year 2021, our due diligence was conducted at the supplier level, mainly first-tier manufacturers. The response rate among suppliers surveyed exceeded 75%. Among the supplier responses, we identified 324 smelters or refiners as listed in Annex 1 hereto, as potential sources of 3TG that were reported to be in the supply chain through the end of the 2021 calendar year, that were designated by RMI as “active” or “conformant” or otherwise appeared on the RMI’s Smelter Reference List.
We believe that the facilities that may have been used to process the 3TG in Elbit Systems’ products in 2021 include the smelters and refiners listed in Annex 1 hereto. There were also a few additional potential high risk smelters for which we continued our RCOI review.
H.Future Activities
We are continuing to refine and expand the list of participating smelters and refiners. We believe that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the locations of origin of the 3TG in our supply chain.
During 2022, we plan to continue to review and evolve our due diligence and RCOI processes with respect to 3TG. During 2022 we expect to: (1) evaluate possible further updates of our Conflict Mineral Compliance Policy and Guidelines; (2) continue to follow-up on incomplete or unreceived responses from suppliers; (3) further develop the collaboration with suppliers for purposes of continued improvement of the supplier response rate and the reliability and quality of information provided; (4) further refine the criteria for our due diligence and supplier selection processes; (5) further enhance our internal control processes and activities; (6) continue to evaluate the impact of our new Enterprise Resources Planning (“ERP”) system on our RCOI process; (7) expand our awareness and training activities; (8) implement the RCOI process with respect to recently acquired subsidiaries; (9) continue expansion of our RCOI activities to parts of our organization that are outside Israel and the U.S; and (10) continue to take mitigating steps with respect to high risk suppliers.
I.Forward Looking Statements
Certain of the matters discussed in this Report, including in particular our due diligence processes and future activities, include forward-looking statements. Readers of this Report are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of unanticipated events.
The information included on our website and other materials referenced in this Report is not incorporated by reference in this Report.
Annex 1
List of Smelters and Refiners
| | | | | | | | | | | |
RMI Smelter Identification | Metal | Smelter Name | Smelter Country |
| CID002708 | Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| CID002852 | Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| CID003421 | Gold | C.I Metales Procesados Industriales SAS | COLOMBIA |
| CID003461 | Gold | Augmont Enterprises Private Limited | INDIA |
| CID003500 | Gold | Alexy Metals | UNITED STATES OF AMERICA |
| CID003529 | Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| CID003615 | Gold | WEEEREFINING | FRANCE |
| CID000309 | Tin | PT Aries Kencana Sejahtera | INDONESIA |
| CID001486 | Tin | PT Timah Nusantara | INDONESIA |
| CID002455 | Tin | CV Venus Inti Perkasa | INDONESIA |
| CID002756 | Tin | Super Ligas | BRAZIL |
| CID003449 | Tin | PT Mitra Sukses Globalindo | INDONESIA |
| CID003486 | Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| CID003416 | Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| CID003427 | Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| CID003612 | Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| CID003614 | Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| CID000015 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| CID000019 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| CID000035 | Gold | Agosi AG | GERMANY |
| CID000041 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| CID000077 | Gold | Argor-Heraeus S.A. | SWITZERLAND |
| CID000082 | Gold | Asahi Pretec Corp. | JAPAN |
| CID000090 | Gold | Asaka Riken Co., Ltd. | JAPAN |
| CID000113 | Gold | Aurubis AG | GERMANY |
| CID000128 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| CID000157 | Gold | Boliden AB | SWEDEN |
| CID000176 | Gold | C. Hafner GmbH + Co. KG | GERMANY |
| | | | | | | | | | | |
| CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| CID000189 | Gold | Cendres + Metaux S.A. | SWITZERLAND |
| CID000233 | Gold | Chimet S.p.A. | ITALY |
| CID000264 | Gold | Chugai Mining | JAPAN |
| CID000359 | Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| CID000401 | Gold | Dowa | JAPAN |
| CID000425 | Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| CID000689 | Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| CID000694 | Gold | Heimerle + Meule GmbH | GERMANY |
| CID000707 | Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| CID000711 | Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| CID000801 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| CID000814 | Gold | Istanbul Gold Refinery | TURKEY |
| CID000823 | Gold | Japan Mint | JAPAN |
| CID000855 | Gold | Jiangxi Copper Co., Ltd. | CHINA |
| CID000920 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| CID000924 | Gold | Asahi Refining Canada Ltd. | CANADA |
| CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| CID000957 | Gold | Kazzinc | KAZAKHSTAN |
| CID000969 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| CID000981 | Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| CID001078 | Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| CID001113 | Gold | Materion | UNITED STATES OF AMERICA |
| CID001119 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| CID001147 | Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| CID001149 | Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| CID001152 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| CID001153 | Gold | Metalor Technologies S.A. | SWITZERLAND |
| CID001157 | Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| CID001161 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| CID001188 | Gold | Mitsubishi Materials Corporation | JAPAN |
| CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| | | | | | | | | | | |
| CID001220 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| CID001236 | Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| CID001259 | Gold | Nihon Material Co., Ltd. | JAPAN |
| CID001325 | Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| CID001352 | Gold | PAMP S.A. | SWITZERLAND |
| CID001397 | Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| CID001498 | Gold | PX Precinox S.A. | SWITZERLAND |
| CID001512 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| CID001534 | Gold | Royal Canadian Mint | CANADA |
| CID001555 | Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| CID001736 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| CID001761 | Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| CID001916 | Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
| CID001938 | Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| CID001955 | Gold | Torecom | KOREA, REPUBLIC OF |
| CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| CID001993 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| CID002003 | Gold | Valcambi S.A. | SWITZERLAND |
| CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
| CID002100 | Gold | Yamakin Co., Ltd. | JAPAN |
| CID002129 | Gold | Yokohama Metal Co., Ltd. | JAPAN |
| CID002224 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| CID002243 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| CID002290 | Gold | SAFINA A.S. | CZECHIA |
| CID002314 | Gold | Umicore Precious Metals Thailand | THAILAND |
| CID002459 | Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| CID002509 | Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| CID002511 | Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| CID002516 | Gold | Singway Technology Co., Ltd. | TAIWAN |
| | | | | | | | | | | |
| CID002560 | Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| CID002561 | Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| CID002580 | Gold | T.C.A S.p.A | ITALY |
| CID002582 | Gold | REMONDIS PMR B.V. | NETHERLANDS |
| CID002605 | Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| CID002606 | Gold | Marsam Metals | BRAZIL |
| CID002615 | Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| CID002761 | Gold | SAAMP | FRANCE |
| CID002762 | Gold | L'Orfebre S.A. | ANDORRA |
| CID002765 | Gold | Italpreziosi | ITALY |
| CID002778 | Gold | WIELAND Edelmetalle GmbH | GERMANY |
| CID002779 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| CID002863 | Gold | Bangalore Refinery | INDIA |
| CID002918 | Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| CID002919 | Gold | Planta Recuperadora de Metales SpA | CHILE |
| CID002973 | Gold | Safimet S.p.A | ITALY |
| CID003189 | Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| CID003424 | Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| CID003425 | Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| CID003575 | Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| CID000460 | Tantalum | F&X Electro-Materials Ltd. | CHINA |
| CID000616 | Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| CID000917 | Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| CID001076 | Tantalum | AMG Brasil | BRAZIL |
| CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| CID001175 | Tantalum | Mineracao Taboca S.A. | BRAZIL |
| CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| CID001200 | Tantalum | NPM Silmet AS | ESTONIA |
| CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| CID001508 | Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| CID001522 | Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| | | | | | | | | | | |
| CID001769 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| CID001869 | Tantalum | Taki Chemical Co., Ltd. | JAPAN |
| CID001891 | Tantalum | Telex Metals | UNITED STATES OF AMERICA |
| CID001969 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| CID002504 | Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
| CID002505 | Tantalum | FIR Metals & Resource Ltd. | CHINA |
| CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| CID002508 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| CID002539 | Tantalum | KEMET de Mexico | MEXICO |
| CID002544 | Tantalum | TANIOBIS Co., Ltd. | THAILAND |
| CID002545 | Tantalum | TANIOBIS GmbH | GERMANY |
| CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| CID002548 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| CID002549 | Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN |
| CID002550 | Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| CID002557 | Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| CID002558 | Tantalum | Global Advanced Metals Aizu | JAPAN |
| CID002707 | Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| CID003583 | Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| CID000292 | Tin | Alpha | UNITED STATES OF AMERICA |
| CID000402 | Tin | Dowa | JAPAN |
| CID000438 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| CID000448 | Tin | Estanho de Rondonia S.A. | BRAZIL |
| CID000468 | Tin | Fenix Metals | POLAND |
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| CID001070 | Tin | China Tin Group Co., Ltd. | CHINA |
| | | | | | | | | | | |
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| CID001142 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| CID001173 | Tin | Mineracao Taboca S.A. | BRAZIL |
| CID001182 | Tin | Minsur | PERU |
| CID001191 | Tin | Mitsubishi Materials Corporation | JAPAN |
| CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| CID001305 | Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| CID001337 | Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| CID001399 | Tin | PT Artha Cipta Langgeng | INDONESIA |
| CID001406 | Tin | PT Babel Surya Alam Lestari | INDONESIA |
| CID001453 | Tin | PT Mitra Stania Prima | INDONESIA |
| CID001458 | Tin | PT Prima Timah Utama | INDONESIA |
| CID001460 | Tin | PT Refined Bangka Tin | INDONESIA |
| CID001468 | Tin | PT Stanindo Inti Perkasa | INDONESIA |
| CID001477 | Tin | PT Timah Tbk Kundur | INDONESIA |
| CID001482 | Tin | PT Timah Tbk Mentok | INDONESIA |
| CID001490 | Tin | PT Tinindo Inter Nusa | INDONESIA |
| CID001539 | Tin | Rui Da Hung | TAIWAN |
| CID001758 | Tin | Soft Metais Ltda. | BRAZIL |
| CID001898 | Tin | Thaisarco | THAILAND |
| CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| CID002180 | Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| CID002468 | Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| CID002706 | Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| CID002773 | Tin | Metallo Belgium N.V. | BELGIUM |
| CID002774 | Tin | Metallo Spain S.L.U. | SPAIN |
| CID002834 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM |
| CID002835 | Tin | PT Menara Cipta Mulia | INDONESIA |
| | | | | | | | | | | |
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| CID003205 | Tin | PT Bangka Serumpun | INDONESIA |
| CID003325 | Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| CID003379 | Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| CID003381 | Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| CID003387 | Tin | Luna Smelter, Ltd. | RWANDA |
| CID003524 | Tin | CRM Synergies | SPAIN |
| CID003582 | Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| CID000105 | Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| CID000966 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| | | | | | | | | | | |
| CID002541 | Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| CID002542 | Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| CID002543 | Tungsten | Masan High-Tech Materials | VIETNAM |
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| CID002589 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| CID002641 | Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| CID002645 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| CID002649 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| CID002724 | Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| CID002833 | Tungsten | ACL Metais Eireli | BRAZIL |
| CID002845 | Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| CID003388 | Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| CID003401 | Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| CID003407 | Tungsten | Lianyou Metals Co., Ltd. | TAIWAN |
| CID003408 | Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| CID003417 | Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. | CHINA |
| CID003468 | Tungsten | Cronimet Brasil Ltda | BRAZIL |
| CID003609 | Tungsten | Fujian Xinlu Tungsten | CHINA |
| CID000103 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| CID000180 | Gold | Caridad | MEXICO |
| CID000197 | Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| CID000343 | Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| CID000362 | Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| CID000493 | Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| CID000522 | Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| CID000651 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| CID000671 | Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| CID000767 | Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| CID000773 | Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| CID000778 | Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| | | | | | | | | | | |
| CID000927 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| CID000929 | Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| CID000956 | Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| CID001029 | Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| CID001032 | Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| CID001056 | Gold | Lingbao Gold Co., Ltd. | CHINA |
| CID001058 | Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| CID001093 | Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| CID001204 | Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| CID001326 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| CID001362 | Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| CID001386 | Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| CID001546 | Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| CID001562 | Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| CID001619 | Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| CID001756 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| CID001909 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| CID001947 | Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| CID002282 | Gold | Morris and Watson | NEW ZEALAND |
| CID002312 | Gold | Guangdong Jinding Gold Limited | CHINA |
| CID002525 | Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| CID002527 | Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| CID002562 | Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| CID002563 | Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| CID002584 | Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| CID002587 | Gold | Industrial Refining Company | BELGIUM |
| CID002588 | Gold | Shirpur Gold Refinery Ltd. | INDIA |
| CID002777 | Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| CID002850 | Gold | AU Traders and Refiners | SOUTH AFRICA |
| CID002853 | Gold | Sai Refinery | INDIA |
| | | | | | | | | | | |
| CID002857 | Gold | Modeltech Sdn Bhd | MALAYSIA |
| CID002865 | Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| CID002867 | Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| CID002872 | Gold | Pease & Curren | UNITED STATES OF AMERICA |
| CID002893 | Gold | JALAN & Company | INDIA |
| CID003153 | Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| CID003186 | Gold | Gold Coast Refinery | GHANA |
| CID003324 | Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
| CID003348 | Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| CID003382 | Gold | CGR Metalloys Pvt Ltd. | INDIA |
| CID003383 | Gold | Sovereign Metals | INDIA |
| CID003463 | Gold | Kundan Care Products Ltd. | INDIA |
| CID003487 | Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| CID003488 | Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| CID003489 | Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| CID003490 | Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| CID003497 | Gold | K.A. Rasmussen | NORWAY |
| CID003540 | Gold | Sellem Industries Ltd. | MAURITANIA |
| CID003548 | Gold | MD Overseas | INDIA |
| CID003557 | Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| CID003617 | Gold | Value Trading | BELGIUM |
| CID000456 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| CID002015 | Tin | VQB Mineral and Trading Group JSC | VIETNAM |
| CID002500 | Tin | Melt Metais e Ligas S.A. | BRAZIL |
| CID002572 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
| CID002573 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| CID002574 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| CID002703 | Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
| | | | | | | | | | | |
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| CID002858 | Tin | Modeltech Sdn Bhd | MALAYSIA |
| CID003356 | Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| CID003409 | Tin | Precious Minerals and Smelting Limited | INDIA |
| CID003410 | Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| CID000281 | Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| CID002313 | Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| CID003553 | Tungsten | Artek LLC | RUSSIAN FEDERATION |
| CID002763 | Gold | 8853 S.p.A. | ITALY |
| CID000004 | Tungsten | A.L.M.T. Corp. | JAPAN |
