Exhibit 1.01
Luminex Corporation
Conflict Minerals Report
For The Year Ended December 31, 2018
This report for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). For the purposes of the required good faith reasonable country of origin inquiry (RCOI), Luminex continued to receive supply chain responses through April 30, 2019. The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are currently limited to tin, tantalum and tungsten (3TG). These requirements apply to registrants regardless of the geographic origin of the conflict minerals and whether or not they fund armed conflict.
If a registrant can establish that the conflict minerals originated from sources other than the Democratic Republic of the Congo (DRC) or an adjoining country (the Covered Countries), or did come from recycled and scrap sources, they must submit a Form SD which describes the RCOI completed.
If a registrant has reason to believe that any of the conflict minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody that conforms to a nationally or internationally recognized framework. The registrant must annually file a report, a Conflict Minerals Report (CMR), with the SEC that includes a description of those due diligence measures.
As permitted by applicable guidance of the SEC, Luminex has not obtained an independent private sector audit of this report within the meaning of the Rule.
1. Company Overview
This report has been prepared by Luminex Corporation (herein referred to as “Luminex,” the “Company,” “we,” “us,” or “our”) and (except as otherwise specified herein) includes the activities of all subsidiaries that are required to be consolidated.
Luminex develops, manufactures and sells proprietary biological testing technologies and products with applications throughout the life sciences and diagnostics industries. These industries depend on a broad range of tests, called bioassays, to perform diagnostic tests and conduct life science research.
2. Products Overview
Luminex’s products are classified in the following categories: instruments, consumables, assays and reagents. We conducted an internal analysis of our products and found that conflict minerals are found in our instruments and assays. Our internal analysis determined that our consumables and reagents do not contain conflict minerals as they are made up of reagent grade or better chemicals and biological reagents not intentionally containing conflict minerals and they could contain only trace amounts of conflict minerals as a contaminant.
3. Supply Chain Overview
Luminex relies upon our suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from sub-tier suppliers. Our suppliers are requested to provide the 3TG sourcing information to us per our Conflict Minerals Policy.
In addition, we have performed an appropriate assessment of our instrument components, and the role that suppliers play throughout our manufacturing processes. We defined the scope of our conflict minerals due diligence by identifying, and using a third party service provider to reach out to our current suppliers that provide instrument and assay components or assemblies. We adopted the standard conflict minerals reporting templates established by the Responsible Minerals Initiative (formerly Conflict-Free Sourcing Initiative) (RMI), and using a third party service provider, delivered our conflict minerals due diligence communication survey to these suppliers.
We have historically purchased many of the components and raw materials used in our products from numerous suppliers worldwide. As we do not source directly from smelters or mines, we are working with our suppliers and third party service providers to understand the sources of the metals contained in our products. We rely upon our direct suppliers and third party service providers to provide information on the origin of the 3TG contained in instrument and assay components and materials supplied to us - including sources of 3TG that are supplied to them from their upstream supply chain sources. Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or our contracts renew, we are seeking to add provisions that require suppliers to provide information about the source of conflict minerals and smelters. It will take a number of years to implement appropriate flow-down clauses in our supplier contracts. In the meantime, as described below, we are working with suppliers and third party service providers to obtain 3TG sourcing information.
4. RCOI
We conducted an assessment of our products and found that 3TG substances can be found in Luminex’s instruments such as our ARIES®, LX 100/200™, FLEXMAP 3D®, MAGPIX® and Verigene® products, including Verigene assays, herein referred to as our “Covered Products”. Based upon our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of all of the 3TG in our Covered Products. However, based on the information provided by our suppliers, we have reason to believe that some of the 3TG contained in our Covered Products may have originated from Covered Countries or may not be from recycled or scrap sources.
In accordance with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the Rule, this report is publicly available on our website at www.luminexcorp.com/about-luminex/corporate-responsibility/.
5. Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the five-step internationally recognized framework in OECD Guidance and the related supplements for 3TG. The subsections below describe our due diligence process based on the OECD Guidance.
Step 1: Establish Strong Company Management Systems
Luminex has adopted a Conflict Minerals Policy, which is posted on our website at www.luminexcorp.com/about-luminex/corporate-responsibility/.
Internal Team
Luminex has established a management system for conflict minerals that is led by the CFO and Vice President of Regulatory and Clinical Affairs as well as executive-level representatives and a team of individuals from relevant functions such as quality assurance, purchasing, document control, IT, and manufacturing engineering. This team is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a periodic basis.
Control Systems
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Luminex employees and our requests that suppliers provide us with conflict mineral information, including the completion of the RMI Conflict Minerals Reporting Template (the RMI CMRT Template).
Supplier Engagement
With respect to the OECD due diligence guidance to strengthen engagement with suppliers, we are utilizing a third party servicer provider and our Purchasing department to contact suppliers in a supporting role to our Quality Assurance and Regulatory department. We have developed a supplier communication package to educate our suppliers of the information required of them. As we enter into new contracts, or our contracts renew, we seek to add provisions that require suppliers to provide information about the source of conflict minerals.
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other manufacturers. We rely upon the following industry-wide initiatives to disclose upstream actors in the supply chain: RMI, the ITRI Tin Supply Chain Initiative (iTSCi) and the Public Private Alliance for Responsible Minerals Trade (PPA).
Grievance Mechanism
We have multiple longstanding grievance mechanisms whereby employees and suppliers can report violations of Luminex’s policies. Our Technical Support department receives complaints and inquiries from customers, suppliers and partners for all Luminex supported products. Technical Support documents all customer communications, triages complaints as required, and leads investigations for issue resolution.
Maintain Records
We have a policy to retain relevant records. Luminex uses a third party service provider’s database at this time to maintain reviewable business records.
Luminex has implemented PLM Product Governance and Compliance software to manage and retain compliance data related to conflict minerals utilizing both internal and external resources. This will also allow Luminex to show the long-term evolution and improvement of its program to its shareholders.
Step 2: Identify and Assess Risk in the Supply Chain
Because of 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. We have identified over 102 direct and indirect instrument and assay component suppliers. We rely upon these suppliers, whose components may contain 3TG, to provide us with information about the source of any conflict minerals contained in the components supplied to us. Both our direct and indirect suppliers are similarly reliant upon information provided by their suppliers. Many of the largest suppliers are also SEC registrants and subject to the Rule. When we identify a risk in the supply chain, we will generally engage with our direct supplier and develop a time frame in which the risk can be mitigated, which may include taking appropriate steps to transition procurement from a different supplier.
Step 3: Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, Luminex has instituted a risk management plan, through which risks are identified and mitigations developed. The conflict minerals program is implemented, managed and monitored through the RCOI due diligence plan.
As described above, we utilize many upstream resources in the following industry-wide initiatives to disclose upstream actors in the supply chain, including the Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative (EICC-GeSI), RMI, the iTSCi and the PPA.
As part of our risk management plan, we have contracted with a third party service provider to use their software and services to conduct our RCOI. For 2018, these services involved sending the RMI CMRT Template to our instrument and assay component direct and indirect suppliers. The RMI CMRT Template contains instructions, definitions and a questionnaire that must be completed by an appropriate supplier representative. We communicate with our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. To date, we have found no instances where it determined to be necessary to terminate a contract or find a replacement supplier in response to our RCOI.
Step 4: Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
In connection with our due diligence, we used information made available by the RMI concerning independent third-party audits of smelters and refiners but did not, and are not required to, obtain our own independent private sector audit of this report.
Step 5: Report on Supply Chain Due Diligence
In accordance with the OECD Guidance and the Rule, this report is publicly available on our website at www.luminexcorp.com/about-luminex/corporate-responsibility/.
6. Due Diligence Process and Results
Request Information
Through our use of a third party service provider’s software and services, we conducted a survey of those suppliers described above using the RMI CMRT Template. The RMI CMRT Template includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters its suppliers use. In addition, the RMI CMRT Template contains questions about the origin of conflict minerals included in a company’s products, as well as supplier due diligence. Written instructions and recorded training videos illustrating the use of the tool are available on RMI website.
Survey Responses
Luminex surveyed our identified instrument and assay component suppliers. Through our third party service provider, we received responses from approximately 65% of the suppliers surveyed. Our third party service provider reviewed the responses against criteria developed to determine which responses required further engagement with our suppliers. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the RMI CMRT Template. In the future, we, along with our third party service provider, will work directly with these suppliers to provide revised responses.
A majority of the responses received provided data at a company or divisional level. Some were unable to specify all the smelters or refiners used for components supplied to Luminex. With the exception of a few suppliers, we are unable to determine whether any of the conflict minerals reported by the suppliers were contained in components or parts supplied to us or to validate that any of these smelters or refiners are actually in our supply chain.
Efforts to determine mine or location of origin
Through our use of guidance proposed by RMI and iTSCi, the OECD implementation programs, and requesting our suppliers to complete the RMI CMRT Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents a reasonable process to determine the mines or locations of origin of the 3TG in our supply chain.
Smelters or Refiners
Supplier responses included the names of 412 entities listed by our suppliers as smelters or refiners. Approximately 26% of the entities listed by our suppliers as smelters or refiners were unable to be validated as in fact being smelters or refiners. Luminex believes that, to the extent reasonably determinable by Luminex, the facilities that were used to process the 3TG contained in the Covered Products included 305 facilities that were listed in the RMI CMRT Template as “known smelters or refineries,” or in the United States Department of Commerce’s global list of “all known conflict mineral processing facilities worldwide” (collectively, Known Smelters or Refineries). Of these 305 Known Smelters or Refineries, 225 had received a “conflict free” designation from an independent third party audit program as of April 30, 2019. Based on these due diligence efforts, Luminex does not have sufficient information to determine all the facilities used to process necessary 3TG or to determine the mines or countries of origin of the 3TG contained in all of the Covered Products or whether the 3TG in all of the Covered Products are from recycled or scrap sources. Luminex continues to work with suppliers throughout its supply chain to re-validate, improve, and refine their reported information, taking into account supply chain fluctuations and other changes in status or scope and relationships over time.
Luminex believes that, to the extent reasonably determinable, the facilities that were used to process the 3TG contained in the Covered Products included the smelters and refiners listed in the table below. This table includes only facilities that are Known Smelters or Refineries.
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Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Gold | | CID000015 | | Advanced Chemical Company | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID000019 | | Aida Chemical Industries Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID000035 | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY | | RMAP Compliant |
Gold | | CID000041 | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN | | RMAP Compliant |
Gold | | CID000058 | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL | | RMAP Compliant |
Gold | | CID000077 | | Argor-Heraeus S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID000082 | | Asahi Pretec Corp. | | JAPAN | | RMAP Compliant |
Gold | | CID000090 | | Asaka Riken Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID000103 | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY | | Known |
Gold | | CID000113 | | Aurubis AG | | GERMANY | | RMAP Compliant |
Gold | | CID000128 | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES | | RMAP Compliant |
Gold | | CID000157 | | Boliden AB | | SWEDEN | | RMAP Compliant |
Gold | | CID000176 | | C. Hafner GmbH + Co. KG | | GERMANY | | RMAP Compliant |
Gold | | CID000180 | | Caridad | | MEXICO | | Known |
Gold | | CID000185 | | CCR Refinery - Glencore Canada Corporation | | CANADA | | RMAP Compliant |
Gold | | CID000189 | | Cendres + Metaux S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID000197 | | Yunnan Copper Industry Co., Ltd. | | CHINA | | Known |
Gold | | CID000233 | | Chimet S.p.A. | | ITALY | | RMAP Compliant |
Gold | | CID000264 | | Chugai Mining | | JAPAN | | Known |
Gold | | CID000328 | | Daejin Indus Co., Ltd. | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID000343 | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA | | Known |
Gold | | CID000359 | | DSC (Do Sung Corporation) | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID000362 | | DODUCO Contacts and Refining GmbH | | GERMANY | | RMAP Compliant |
Gold | | CID000401 | | Dowa | | JAPAN | | RMAP Compliant |
Gold | | CID000425 | | Eco-System Recycling Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID000493 | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID000522 | | Refinery of Seemine Gold Co., Ltd. | | CHINA | | Known |
Gold | | CID000651 | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CHINA | | Known |
Gold | | CID000671 | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA | | Known |
Gold | | CID000689 | | HeeSung Metal Ltd. | | KOREA, REPUBLIC OF | | Known |
Gold | | CID000694 | | Heimerle + Meule GmbH | | GERMANY | | RMAP Compliant |
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Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Gold | | CID000707 | | Heraeus Metals Hong Kong Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID000711 | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY | | RMAP Compliant |
Gold | | CID000767 | | Hunan Chenzhou Mining Co., Ltd. | | CHINA | | Known |
Gold | | CID000778 | | HwaSeong CJ Co., Ltd. | | KOREA, REPUBLIC OF | | Known |
Gold | | CID000801 | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID000807 | | Ishifuku Metal Industry Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID000814 | | Istanbul Gold Refinery | | TURKEY | | RMAP Compliant |
Gold | | CID000823 | | Japan Mint | | JAPAN | | RMAP Compliant |
Gold | | CID000855 | | Jiangxi Copper Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID000920 | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID000924 | | Asahi Refining Canada Ltd. | | CANADA | | RMAP Compliant |
Gold | | CID000927 | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | RUSSIAN FEDERATION | | Known |
Gold | | CID000929 | | JSC Uralelectromed | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID000937 | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID000956 | | Kazakhmys Smelting LLC | | KAZAKHSTAN | | Known |
Gold | | CID000957 | | Kazzinc | | KAZAKHSTAN | | RMAP Compliant |
Gold | | CID000969 | | Kennecott Utah Copper LLC | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID000981 | | Kojima Chemicals Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001029 | | Kyrgyzaltyn JSC | | KYRGYZSTAN | | RMAP Compliant |
Gold | | CID001032 | | L'azurde Company For Jewelry | | SAUDI ARABIA | | Known |
Gold | | CID001056 | | Lingbao Gold Co., Ltd. | | CHINA | | Known |
Gold | | CID001058 | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA | | Known |
Gold | | CID001078 | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID001093 | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA | | Known |
Gold | | CID001113 | | Materion | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID001119 | | Matsuda Sangyo Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001147 | | Metalor Technologies (Suzhou) Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID001149 | | Metalor Technologies (Hong Kong) Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID001152 | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE | | RMAP Compliant |
Gold | | CID001153 | | Metalor Technologies S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID001157 | | Metalor USA Refining Corporation | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID001161 | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO | | RMAP Compliant |
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Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Gold | | CID001188 | | Mitsubishi Materials Corporation | | JAPAN | | RMAP Compliant |
Gold | | CID001193 | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001204 | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID001220 | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY | | RMAP Compliant |
Gold | | CID001236 | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN | | Known |
Gold | | CID001259 | | Nihon Material Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001322 | | Elemetal Refining, LLC | | UNITED STATES OF AMERICA | | Known |
Gold | | CID001325 | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001326 | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID001352 | | PAMP S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID001362 | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA | | Known |
Gold | | CID001386 | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID001397 | | PT Aneka Tambang (Persero) Tbk | | INDONESIA | | RMAP Compliant |
Gold | | CID001498 | | PX Precinox S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID001512 | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA | | RMAP Compliant |
Gold | | CID001534 | | Royal Canadian Mint | | CANADA | | RMAP Compliant |
Gold | | CID001546 | | Sabin Metal Corp. | | UNITED STATES OF AMERICA | | Known |
Gold | | CID001555 | | Samduck Precious Metals | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID001562 | | Samwon Metals Corp. | | KOREA, REPUBLIC OF | | Known |
Gold | | CID001573 | | Schone Edelmetaal B.V. | | NETHERLANDS | | RMAP Compliant |
Gold | | CID001585 | | SEMPSA Joyeria Plateria S.A. | | SPAIN | | RMAP Compliant |
Gold | | CID001619 | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CHINA | | Known |
Gold | | CID001622 | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID001736 | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID001756 | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION | | RMAP Compliant |
Gold | | CID001761 | | Solar Applied Materials Technology Corp. | | TAIWAN, PROVINCE OF CHINA | | RMAP Compliant |
Gold | | CID001798 | | Sumitomo Metal Mining Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001875 | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN | | RMAP Compliant |
Gold | | CID001909 | | Great Wall Precious Metals Co., Ltd. of CBPM | | CHINA | | Known |
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Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Gold | | CID001916 | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID001938 | | Tokuriki Honten Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID001947 | | Tongling Nonferrous Metals Group Co., Ltd. | | CHINA | | Known |
Gold | | CID001955 | | Torecom | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID001977 | | Umicore Brasil Ltda. | | BRAZIL | | RMAP Compliant |
Gold | | CID001980 | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM | | RMAP Compliant |
Gold | | CID001993 | | United Precious Metal Refining, Inc. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Gold | | CID002003 | | Valcambi S.A. | | SWITZERLAND | | RMAP Compliant |
Gold | | CID002030 | | Western Australian Mint (T/a The Perth Mint) | | AUSTRALIA | | RMAP Compliant |
Gold | | CID002100 | | Yamakin Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID002129 | | Yokohama Metal Co., Ltd. | | JAPAN | | RMAP Compliant |
Gold | | CID002224 | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA | | RMAP Compliant |
Gold | | CID002243 | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA | | RMAP Compliant |
Gold | | CID002282 | | Morris and Watson | | NEW ZEALAND | | Known |
Gold | | CID002290 | | SAFINA A.S. | | CZECH REPUBLIC | | Known |
Gold | | CID002312 | | Guangdong Jinding Gold Limited | | CHINA | | Known |
Gold | | CID002314 | | Umicore Precious Metals Thailand | | THAILAND | | RMAP Compliant |
Gold | | CID002459 | | Geib Refining Corporation | | UNITED STATES OF AMERICA | | Known |
Gold | | CID002509 | | MMTC-PAMP India Pvt., Ltd. | | INDIA | | RMAP Compliant |
Gold | | CID002511 | | KGHM Polska Miedz Spolka Akcyjna | | POLAND | | Known |
Gold | | CID002515 | | Fidelity Printers and Refiners Ltd. | | ZIMBABWE | | Known |
Gold | | CID002516 | | Singway Technology Co., Ltd. | | TAIWAN, PROVINCE OF CHINA | | RMAP Compliant |
Gold | | CID002560 | | Al Etihad Gold LLC | | UNITED ARAB EMIRATES | | RMAP Compliant |
Gold | | CID002561 | | Emirates Gold DMCC | | UNITED ARAB EMIRATES | | RMAP Compliant |
Gold | | CID002563 | | Kaloti Precious Metals | | UNITED ARAB EMIRATES | | Known |
Gold | | CID002567 | | Sudan Gold Refinery | | SUDAN | | Known |
Gold | | CID002580 | | T.C.A S.p.A | | ITALY | | RMAP Compliant |
Gold | | CID002582 | | Remondis Argentia B.V. | | Netherlands | | Known |
Gold | | CID002587 | | Tony Goetz NV | | BELGIUM | | Known |
Gold | | CID002605 | | Korea Zinc Co., Ltd. | | KOREA, REPUBLIC OF | | RMAP Compliant |
Gold | | CID002606 | | Marsam Metals | | BRAZIL | | Known |
Gold | | CID002615 | | TOO Tau-Ken-Altyn | | KAZAKHSTAN | | Known |
Gold | | CID002708 | | Abington Reldan Metals, LLC | | UNITED STATES OF AMERICA | | Known |
Gold | | CID002761 | | SAAMP | | FRANCE | | Known |
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Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Gold | | CID002762 | | L'Orfebre S.A. | | ANDORRA | | Known |
Gold | | CID002763 | | 8853 S.p.A. | | ITALY | | RMAP Compliant |
Gold | | CID002765 | | Italpreziosi | | ITALY | | Known |
Gold | | CID002777 | | SAXONIA Edelmetalle GmbH | | GERMANY | | RMAP Compliant |
Gold | | CID002778 | | WIELAND Edelmetalle GmbH | | GERMANY | | RMAP Compliant |
Gold | | CID002779 | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA | | RMAP Compliant |
Gold | | CID002850 | | AU Traders and Refiners | | SOUTH AFRICA | | RMAP Compliant |
Gold | | CID002852 | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA | | Known |
Gold | | CID002853 | | Sai Refinery | | INDIA | | Known |
Gold | | CID002854 | | Universal Precious Metals Refining Zambia | | ZAMBIA | | Known |
Gold | | CID002857 | | Modeltech Sdn Bhd | | MALAYSIA | | Known |
Gold | | CID002863 | | Bangalore Refinery | | INDIA | | Known |
Gold | | CID002865 | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION | | Known |
Gold | | CID002866 | | Morris and Watson Gold Coast | | AUSTRALIA | | Known |
Gold | | CID002867 | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY | | Known |
Gold | | CID002872 | | Pease & Curren | | UNITED STATES OF AMERICA | | Known |
Gold | | CID002918 | | SungEel HiMetal Co., Ltd. | | KOREA, REPUBLIC OF | | Known |
Gold | | CID002919 | | Planta Recuperadora de Metales SpA | | CHILE | | Known |
Gold | | CID002973 | | Safimet S.p.A | | ITALY | | Known |
Gold | | CID003153 | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA | | Known |
Gold | | CID003185 | | African Gold Refinery | | UGANDA | | Known |
Gold | | CID003189 | | NH Recytech Company | | KOREA, REPUBLIC OF | | Known |
Gold | | CID003195 | | DS PRETECH Co., Ltd. | | KOREA, REPUBLIC OF | | Known |
Gold | | CID003324 | | QG Refining, LLC | | UNITED STATES OF AMERICA | | Known |
Tantalum | | CID000211 | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID000291 | | Guangdong Rising Rare Metals-EO Materials Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID000456 | | Exotech Inc. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID000460 | | F&X Electro-Materials Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID000616 | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID000914 | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID000917 | | Jiujiang Tanbre Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID001076 | | LSM Brasil S.A. | | BRAZIL | | RMAP Compliant |
|
| | | | | | | | |
Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Tantalum | | CID001163 | | Metallurgical Products India Pvt., Ltd. | | INDIA | | RMAP Compliant |
Tantalum | | CID001175 | | Mineracao Taboca S.A. | | BRAZIL | | RMAP Compliant |
Tantalum | | CID001200 | | NPM Silmet AS | | ESTONIA | | RMAP Compliant |
Tantalum | | CID001277 | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID001508 | | QuantumClean | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID001522 | | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID001769 | | Solikamsk Magnesium Works OAO | | RUSSIAN FEDERATION | | RMAP Compliant |
Tantalum | | CID001869 | | Taki Chemical Co., Ltd. | | JAPAN | | RMAP Compliant |
Tantalum | | CID001891 | | Telex Metals | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID001969 | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN | | RMAP Compliant |
Tantalum | | CID002492 | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID002504 | | D Block Metals, LLC | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID002505 | | FIR Metals & Resource Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID002506 | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID002508 | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID002512 | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA | | RMAP Compliant |
Tantalum | | CID002539 | | KEMET Blue Metals | | MEXICO | | RMAP Compliant |
Tantalum | | CID002544 | | H.C. Starck Co., Ltd. | | THAILAND | | RMAP Compliant |
Tantalum | | CID002545 | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY | | RMAP Compliant |
Tantalum | | CID002547 | | H.C. Starck Hermsdorf GmbH | | GERMANY | | RMAP Compliant |
Tantalum | | CID002548 | | H.C. Starck Inc. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID002549 | | H.C. Starck Ltd. | | JAPAN | | RMAP Compliant |
Tantalum | | CID002550 | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY | | RMAP Compliant |
Tantalum | | CID002557 | | Global Advanced Metals Boyertown | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID002558 | | Global Advanced Metals Aizu | | JAPAN | | RMAP Compliant |
Tantalum | | CID002568 | | KEMET Blue Powder | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tantalum | | CID002707 | | Resind Industria e Comercio Ltda. | | BRAZIL | | RMAP Compliant |
Tantalum | | CID002842 | | Jiangxi Tuohong New Raw Material | | CHINA | | RMAP Compliant |
Tantalum | | CID002847 | | Power Resources Ltd. | | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | | RMAP Compliant |
Tantalum | | CID003191 | | Jiujiang Janny New Material Co., Ltd. | | CHINA | | RMAP Compliant |
Tin | | CID000228 | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA | | RMAP Compliant |
|
| | | | | | | | |
Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Tin | | CID000278 | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA | | Known |
Tin | | CID000292 | | Alpha | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tin | | CID000306 | | CV Gita Pesona | | INDONESIA | | RMAP Compliant |
Tin | | CID000309 | | PT Aries Kencana Sejahtera | | INDONESIA | | RMAP Compliant |
Tin | | CID000313 | | PT Premium Tin Indonesia | | INDONESIA | | RMAP Compliant |
Tin | | CID000315 | | CV United Smelting | | INDONESIA | | RMAP Compliant |
Tin | | CID000438 | | EM Vinto | | BOLIVIA (PLURINATIONAL STATE OF) | | RMAP Compliant |
Tin | | CID000448 | | Estanho de Rondonia S.A. | | BRAZIL | | Known |
Tin | | CID000468 | | Fenix Metals | | POLAND | | RMAP Compliant |
Tin | | CID000538 | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA | | RMAP Compliant |
Tin | | CID000555 | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA | | Known |
Tin | | CID000760 | | Huichang Jinshunda Tin Co., Ltd. | | CHINA | | Known |
Tin | | CID000942 | | Gejiu Kai Meng Industry and Trade LLC | | CHINA | | Known |
Tin | | CID001070 | | China Tin Group Co., Ltd. | | CHINA | | RMAP Compliant |
Tin | | CID001105 | | Malaysia Smelting Corporation (MSC) | | MALAYSIA | | RMAP Compliant |
Tin | | CID001142 | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tin | | CID001182 | | Minsur | | PERU | | RMAP Compliant |
Tin | | CID001231 | | Jiangxi New Nanshan Technology Ltd. | | CHINA | | Known |
Tin | | CID001314 | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND | | RMAP Compliant |
Tin | | CID001337 | | Operaciones Metalurgical S.A. | | BOLIVIA (PLURINATIONAL STATE OF) | | RMAP Compliant |
Tin | | CID001399 | | PT Artha Cipta Langgeng | | INDONESIA | | RMAP Compliant |
Tin | | CID001402 | | PT Babel Inti Perkasa | | INDONESIA | | RMAP Compliant |
Tin | | CID001419 | | PT Bangka Tin Industry | | INDONESIA | | RMAP Compliant |
Tin | | CID001421 | | PT Belitung Industri Sejahtera | | INDONESIA | | RMAP Compliant |
Tin | | CID001428 | | PT Bukit Timah | | INDONESIA | | RMAP Compliant |
Tin | | CID001434 | | PT DS Jaya Abadi | | INDONESIA | | RMAP Compliant |
Tin | | CID001448 | | PT Karimun Mining | | INDONESIA | | RMAP Compliant |
Tin | | CID001453 | | PT Mitra Stania Prima | | INDONESIA | | RMAP Compliant |
Tin | | CID001457 | | PT Panca Mega Persada | | INDONESIA | | RMAP Compliant |
Tin | | CID001458 | | PT Prima Timah Utama | | INDONESIA | | RMAP Compliant |
Tin | | CID001460 | | PT Refined Bangka Tin | | INDONESIA | | RMAP Compliant |
Tin | | CID001463 | | PT Sariwiguna Binasentosa | | INDONESIA | | RMAP Compliant |
Tin | | CID001468 | | PT Stanindo Inti Perkasa | | INDONESIA | | RMAP Compliant |
Tin | | CID001471 | | PT Sumber Jaya Indah | | INDONESIA | | RMAP Compliant |
Tin | | CID001477 | | PT Timah (Persero) Tbk Kundur | | INDONESIA | | RMAP Compliant |
|
| | | | | | | | |
Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Tin | | CID001482 | | PT Timah (Persero) Tbk Mentok | | INDONESIA | | RMAP Compliant |
Tin | | CID001490 | | PT Tinindo Inter Nusa | | INDONESIA | | RMAP Compliant |
Tin | | CID001493 | | PT Tommy Utama | | INDONESIA | | RMAP Compliant |
Tin | | CID001539 | | Rui Da Hung | | TAIWAN, PROVINCE OF CHINA | | RMAP Compliant |
Tin | | CID001758 | | Soft Metais Ltda. | | BRAZIL | | RMAP Compliant |
Tin | | CID001898 | | Thaisarco | | THAILAND | | RMAP Compliant |
Tin | | CID001908 | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA | | Known |
Tin | | CID002036 | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL | | RMAP Compliant |
Tin | | CID002158 | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA | | Known |
Tin | | CID002180 | | Yunnan Tin Company Limited | | CHINA | | RMAP Compliant |
Tin | | CID002455 | | CV Venus Inti Perkasa | | INDONESIA | | RMAP Compliant |
Tin | | CID002468 | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL | | RMAP Compliant |
Tin | | CID002500 | | Melt Metais e Ligas S.A. | | BRAZIL | | RMAP Compliant |
Tin | | CID002503 | | PT ATD Makmur Mandiri Jaya | | INDONESIA | | RMAP Compliant |
Tin | | CID002517 | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES | | RMAP Compliant |
Tin | | CID002530 | | PT Inti Stania Prima | | INDONESIA | | RMAP Compliant |
Tin | | CID002570 | | CV Ayi Jaya | | INDONESIA | | RMAP Compliant |
Tin | | CID002572 | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIET NAM | | Known |
Tin | | CID002573 | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIET NAM | | Known |
Tin | | CID002574 | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIET NAM | | Known |
Tin | | CID002592 | | CV Dua Sekawan | | INDONESIA | | RMAP Compliant |
Tin | | CID002593 | | CV Tiga Sekawan | | INDONESIA | | RMAP Compliant |
Tin | | CID002703 | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM | | Known |
Tin | | CID002756 | | Super Ligas | | BRAZIL | | Known |
Tin | | CID002773 | | Metallo Belgium N.V. | | BELGIUM | | RMAP Compliant |
Tin | | CID002774 | | Metallo Spain S.L.U. | | SPAIN | | RMAP Compliant |
Tin | | CID002776 | | PT Bangka Prima Tin | | INDONESIA | | RMAP Compliant |
Tin | | CID002816 | | PT Sukses Inti Makmur | | INDONESIA | | RMAP Compliant |
Tin | | CID002829 | | PT Kijang Jaya Mandiri | | INDONESIA | | RMAP Compliant |
Tin | | CID002835 | | PT Menara Cipta Mulia | | INDONESIA | | RMAP Compliant |
Tin | | CID002844 | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA | | RMAP Compliant |
Tin | | CID002848 | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA | | RMAP Compliant |
|
| | | | | | | | |
Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Tin | | CID002849 | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA | | RMAP Compliant |
Tin | | CID002859 | | Gejiu Jinye Mineral Company | | CHINA | | RMAP Compliant |
Tin | | CID002870 | | PT Lautan Harmonis Sejahtera | | INDONESIA | | RMAP Compliant |
Tin | | CID003116 | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA | | Known |
Tin | | CID003190 | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA | | RMAP Compliant |
Tin | | CID003205 | | PT Bangka Serumpun | | INDONESIA | | RMAP Compliant |
Tin | | CID003208 | | Pongpipat Company Limited | | MYANMAR | | Known |
Tin | | CID003325 | | Tin Technology & Refining | | UNITED STATES OF AMERICA | | Known |
Tungsten | | CID000004 | | A.L.M.T. TUNGSTEN Corp. | | JAPAN | | RMAP Compliant |
Tungsten | | CID000105 | | Kennametal Huntsville | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tungsten | | CID000218 | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID000258 | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID000499 | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID000568 | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tungsten | | CID000769 | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID000825 | | Japan New Metals Co., Ltd. | | JAPAN | | RMAP Compliant |
Tungsten | | CID000875 | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID000966 | | Kennametal Fallon | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tungsten | | CID001889 | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIET NAM | | RMAP Compliant |
Tungsten | | CID002044 | | Wolfram Bergbau und Hutten AG | | AUSTRIA | | RMAP Compliant |
Tungsten | | CID002082 | | Xiamen Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002095 | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002313 | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | CHINA | | Known |
Tungsten | | CID002315 | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002316 | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002317 | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002318 | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002319 | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002320 | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA | | RMAP Compliant |
|
| | | | | | | | |
Mineral | | Smelter ID | | Smelter Name | | Location | | Smelter Class (1) |
Tungsten | | CID002321 | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002494 | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002513 | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002536 | | Ganzhou Yatai Tungsten Co., Ltd. | | CHINA | | Known |
Tungsten | | CID002541 | | H.C. Starck Tungsten GmbH | | GERMANY | | RMAP Compliant |
Tungsten | | CID002543 | | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | | VIET NAM | | RMAP Compliant |
Tungsten | | CID002551 | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002579 | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA | | RMAP Compliant |
Tungsten | | CID002589 | | Niagara Refining LLC | | UNITED STATES OF AMERICA | | RMAP Compliant |
Tungsten | | CID002645 | | Ganzhou Haichuang Tungsten Industry Co., Ltd. | | CHINA | | Known |
Tungsten | | CID002647 | | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | | CHINA | | Known |
Tungsten | | CID002649 | | Hydrometallurg, JSC | | RUSSIAN FEDERATION | | RMAP Compliant |
Tungsten | | CID002724 | | Unecha Refractory metals plant | | RUSSIAN FEDERATION | | RMAP Compliant |
Tungsten | | CID002815 | | South-East Nonferrous Metal Company Limited of Hengyang City | | CHINA | | RMAP Compliant |
Tungsten | | CID002827 | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES | | RMAP Compliant |
Tungsten | | CID002830 | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA | | RMAP Compliant |
Tungsten | | CID002833 | | ACL Metais Eireli | | BRAZIL | | Known |
Tungsten | | CID002843 | | Woltech Korea Co., Ltd. | | KOREA, REPUBLIC OF | | RMAP Compliant |
Tungsten | | CID002845 | | Moliren Ltd. | | RUSSIAN FEDERATION | | RMAP Compliant |
Tungsten | | CID003182 | | Hunan Litian Tungsten Industry Co., Ltd. | | CHINA | | Known |
| | | | | | | | |
(1) | | RMAP Compliant indicates smelters or refiners that are conformant with the Responsible Mineral Assurance Process standards. Smelters or refiners with a “re-audit in process” are still considered RMAP Compliant. |
7. Steps to Improve Due Diligence
We intend to take the following steps to continue to improve the due diligence conducted to mitigate risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:
| |
a. | Continue our efforts to include conflict minerals provisions in new or renewed supplier contracts. |
| |
b. | Continue to engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
| |
c. | Continue to engage any of our suppliers found to be supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country to establish an alternative source of 3TG that does not support such conflict. |
| |
d. | Continue to improve our best practices and build leverage over the supply chain in accordance with the OECD Guidance and other relevant trade associations. |
| |
e. | Continue due diligence on new businesses acquired to assess the risk of conflict minerals in the acquired business supply chain. |
Forward-looking Statements
This report contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements made in this report, other than statements of historical fact, are forward-looking statements. You can identify these statements from use of the words “may,” “should,” “could,” “potential,” “continue,” “plan,” “forecast,” “estimate,” “project,” “believe,” “intent,” “anticipate,” “expect,” “target,” “is likely,” “will,” or the negative of these terms, and similar expressions. These statements are made pursuant to the safe harbor provisions of the Private Securities Litigation Reform Act of 1995. We believe that our expectations are based on reasonable assumptions. However, these forward-looking statements involve known and unknown risks, uncertainties and other important factors that could cause our actual results, performance or achievements, or industry results, to differ materially from our expectations of future results, performance or achievements expressed or implied by these forward-looking statements. You should not place undue reliance on any forward-looking statements. Excepts as otherwise required by applicable laws, we undertake no obligation to publicly update or revise any forward-looking or other statements included in this report, whether as a result of new information, future events, changed circumstances or any other reason.