EXHIBIT 1.01.2
American Railcar Industries, Inc.
Conflict Minerals Report
INTRODUCTION
This Conflict Minerals Report (“CMR”) of American Railcar Industries, Inc. (“ARI” or “the Company”) has been prepared pursuant to Rule 13p-1 and Form SD promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”) for the reporting period from January 1, 2015 to December 31, 2015 (“the Reporting Period”).
Rule 13p-1 under the Exchange Act requires the disclosure of certain information when a company manufactures or contracts to manufacture products for which “Conflict Minerals” are necessary to the functionality or production of those products. “Conflict Minerals” for the purposes of Rule 13p-1 are gold, columbite-tantalite (coltan), cassiterite, and wolframite (including their derivatives, tantalum, tin and tungsten, and other minerals or derivatives the U.S. Secretary of State may designate in the future). The “Covered Countries” for the purposes of Rule 13p-1 are the Democratic Republic of the Congo (“the DRC”), the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola.
In accordance with Securities and Exchange Commission (“SEC”) guidance, this CMR is not audited.
As required by Rule 13p-1, this CMR relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of those products; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period. These products, which are referred to in this report collectively as the “Covered Products”, include railcars and certain railcar components manufactured or sourced by our Manufacturing segment. The Company believes that only a small portion of the materials content of the Covered Products constitute Conflict Minerals necessary to their functionality and/or production.
RCOI
ARI conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the necessary Conflict Minerals used in its products. This good faith RCOI was designed to reasonably determine whether any of the necessary Conflict Minerals originated in the Covered Countries or came from recycled or scrap sources.
The Company’s primary means of determining country of origin of such Conflict Minerals was by conducting a supply chain survey. The “Conflict Minerals Committee” (as defined below), having direct knowledge and expertise with respect to ARI's supply chain composition first reviewed the listing of materials for Covered Products received during 2015 to identify those materials reasonably likely to contain Conflict Minerals. After cross-referencing the Conflict Minerals Committee's findings against prior-year RCOI and due diligence results, ARI identified fewer than 5% of the Company's direct suppliers as supplying such materials (“Potential CM Suppliers”). Potential CM Suppliers were asked to complete the Electronic Industry Citizenship Coalition/Global e-Sustainability Initiative Conflict Minerals Reporting Template (“the Template”) to identify smelters and refiners. Where applicable, the Company also inquired and/or obtained supplier policies on Conflict Minerals and made follow-up inquiries with appropriate supplier personnel.
DUE DILIGENCE PROCESS
Design of Due Diligence
Based on the Company’s RCOI, the Company was also required to exercise due diligence on the source and chain of custody of the Conflict Minerals in its products. The design of the due diligence measures described below is intended to comply in all material respects 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: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (collectively, “the OECD Guidance”). The OECD Guidance is an internationally recognized due diligence framework for identifying the source of Conflict Minerals, which includes the following steps:
Step 1: Establish strong company management systems
Step 2: Identify and assess risks in the supply chain
Step 3: Design and implement a strategy to respond to identified risks
Step 4: Carry out independent third-party audit of smelter(s)/refiner(s) due diligence practices
Step 5: Report annually on supply chain due diligence
The OECD Guidance is written for the entire mineral supply chain and therefore ARI’s due diligence measures were tailored to include steps appropriate for “downstream” companies such as the Company.
Due Diligence Measures Performed
The Company’s supply chain is complex. Numerous third-parties are involved in the network that exists between ARI's suppliers and the original sources of any Conflict Minerals. Because the Company does not purchase Conflict Minerals directly from mines, smelters or refiners, it must rely on its suppliers to provide information regarding the origin of the Conflict Minerals in ARI's products. Given this context, the Company undertook the following measures to exercise due diligence on the source and chain of custody of the Conflict Minerals in its products for the Reporting Period:
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| (i) | ARI has established a management system to support its supply chain due diligence. |
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| a. | ARI maintains an organizational structure and communication process that is intended to establish a system of transparency over its supply chain. This system is meant to help ARI obtain critical information regarding the supply chain of Conflict Minerals used in its products. |
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| b. | ARI has a company policy regarding Conflict Minerals. This policy is publicly available on the Company’s website: americanrailcar.com. Employees, suppliers and other interested parties can contact ARI regarding its Conflict Minerals policy either in writing or by phone. |
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| c. | Authority and responsibility are assigned to a multi-disciplinary team comprised of ARI's Director of Purchasing, Manager of Financial Reporting, and Manager of Internal Audit (collectively, the “Conflict Minerals Committee”). The Conflict Minerals Committee receives periodic support from its General Counsel and reports all Conflict Minerals matters directly to its Chief Financial Officer. |
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| d. | ARI has distributed communications to its suppliers making them aware of Rule 13p-1 and ARI's related policies. Conflict Minerals provisions have been incorporated into supplier contracts and purchase orders through the Company's updated standard terms and conditions as published on its website. |
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| e. | ARI maintains business records relating to Conflict Minerals due diligence in accordance with the Company's existing policies and/or processes. |
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| (ii) | ARI has taken steps to identify and assess risk in its supply chain. |
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| a. | As described above, ARI identified Potential CM Suppliers in its supply chain during the Reporting Period and sent those suppliers a copy of the Template (a “Survey”). |
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| b. | Of the Potential CM Suppliers surveyed, 92% provided a Survey response and of those who provided a Survey response, 67% indicated that their products contained Conflict Minerals that did not originate from the Covered Countries and 33% indicated that their products did not contain Conflict Minerals or were made from recycled or scrap products. |
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| (iii) | ARI has designed and implemented a strategy to respond to identified risks. |
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| a. | ARI’s Conflict Minerals Committee monitors internal accountability with respect to the implementation of the supply chain due diligence process and reports its findings of the supply chain risk assessment to upper level management and the Audit Committee of ARI's Board of Directors. |
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| b. | ARI has designed and implemented a risk management plan that includes, but is not limited to, requests for Potential CM Suppliers to complete surveys and engaging in follow-up discussions with suppliers about the composition of their products and materials. In addition, the Company has incorporated Conflict Minerals language into ARI’s supplier contracts. If a supplier identifies that it has Conflict Minerals in the products or materials it supplies, it is added to the list of Potential CM Suppliers and ARI actively engages with that supplier to identify the locations of the smelter(s)/refiner(s) of those Conflict Minerals and to obtain a copy of their Conflict Mineral policies. |
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| (iv) | ARI has determined that reliance upon independent third-party audits of smelter/refiner due diligence practices by the Conflict Free Sourcing Initiative (CFSI) is appropriate. |
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| a. | ARI is a downstream company and is many steps removed from the smelters and refiners that produce the necessary Conflict Minerals contained in ARI’s products. ARI does not purchase raw minerals or ores, and does not, to the best of its knowledge, directly purchase Conflict Minerals from any of the Covered Countries. Accordingly, ARI does not perform audits or direct audits of these entities’ supply chains of Conflict Minerals. However, ARI supports industry-wide efforts and the development and implementation of independent third-party audits of smelters and refiners, such as the CFSI’s Conflict-Free Smelter Program. |
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| (v) | ARI complies with Step 5 of the OECD Guidance through its filing of this report (and the related Form SD) with the SEC and by making these materials publicly available on its website at americanrailcar.com. |
DUE DILIGENCE RESULTS AND RISK MITIGATION
Based on the information that was provided by the suppliers that ARI surveyed and otherwise obtained through the due diligence process, ARI believes that, to the extent reasonably determinable by ARI, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the 235 smelters or refiners listed in Annex I.
This list includes only facilities that are listed in the Template as “Known Smelters or Refineries”. Of these 235 Known Smelters or Refineries, 179 received a “conflict-free” designation from an independent third party audit program as of May 17, 2016.
Despite repeated efforts to obtain completed Surveys, one of the Potential CM Suppliers did not respond to ARI’s Survey requests. In addition, because the Company is several levels removed from the source of the Conflict Minerals, despite its due diligence efforts, it was unable to identify or further investigate the source of any Conflict Minerals supplied by certain suppliers who were either non-responsive or uncertain about where the Conflict Minerals used in products they supplied to the Company originated. Therefore, the Company does not have sufficient information to determine the facilities used to process, the country of origin, or mine or location of origin of every Conflict Mineral in the Covered Products.
The Company expects to continue taking the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company’s supply chain benefit armed groups in the Covered Countries:
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| (i.) | Engage with suppliers to obtain current, accurate, and complete information about the supply chain; |
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| (ii.) | Encourage suppliers to implement responsible sourcing; and |
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| (iii.) | Review “conflict-free” smelter lists from independent “conflict-free” smelter validation programs, such as CFSI’s Conflict-Free Smelter Program. |
ARI has provided information as of the date of this report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with ARI’s Conflict Minerals Policy, may affect ARI’s future determinations under Rule 13p-1.
The Company also completed a Survey for each of its requesting customers for the Reporting Period. ARI supports its customers' reporting obligations as required by Rule 13p-1.
Website addresses are included in this report for reference only. Any information contained on ARI’s website is not incorporated by reference into this report.
FORWARD-LOOKING STATEMENTS
Certain statements in this report may be “forward-looking” within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “intends,” “expects,” “plans,” “believes,” “estimates,” “anticipates,” and similar expressions are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to the Company's future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on the Company's current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by federal securities laws.
ANNEX I
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| Metal | Smelter Name | Smelter Country |
| Gold | Advanced Chemical Company | United States |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | Brazil |
| Gold | Argor-Heraeus SA | Switzerland |
| Gold | Asahi Pretec Corporation | Japan |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Aurubis AG | Germany |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Bauer Walser AG | Germany |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Caridad | Mexico |
| Gold | Cendres + Métaux SA | Switzerland |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Daejin Industry | Korea, Republic of |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Do Sung Corporation | Korea, Republic of |
| Gold | Doduco | Germany |
| Gold | Eco-System Recycling Co., Ltd. | Japan |
| Gold | FSE Novosibirsk Refinery | Russian Federation |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | China |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Ltd. Hong Kong | China |
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hwasung CJ Co., Ltd. | Korea, Republic of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Company Limited | China |
| Gold | Johnson Matthey Inc. | United States |
| Gold | Johnson Matthey Limited | Canada |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Metal Co., Ltd. | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | L' azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
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| Metal | Smelter Name | Smelter Country |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Materion | United States |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metalor Switzerland | Switzerland |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies SA | Switzerland |
| Gold | Metalor USA Refining Corporation | United States |
| Gold | Met-Mex Penoles, S.A. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ohio Precious Metals, LLC | United States |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | OJSC Kolyma Refinery | Russian Federation |
| Gold | PAMP SA | Switzerland |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Précinox SA | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Royal Canadian Mint | Canada |
| Gold | Sabin Metal Corp. | United States |
| Gold | Samduck Precious Metals | Korea, Republic of |
| Gold | SAMWON Metals Corp. | Korea, Republic of |
| Gold | Schone Edelmetaal B.V. | Netherlands |
| Gold | SEMPSA Joyería Platería SA | Spain |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | So Accurate Group, Inc. | United States |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | Tanaka Denshi Kogyo K.K | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | The Great Wall Gold and Silver Refinery of China | China |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Torecom | Korea, Republic of |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Umicore SA Business Unit Precious Metals Refining | Belgium |
| Gold | United Precious Metal Refining, Inc. | United States |
| Gold | Valcambi SA | Switzerland |
| Gold | Western Australian Mint trading as The Perth Mint | Australia |
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| Metal | Smelter Name | Smelter Country |
| Gold | Williams Advanced Materials | United States |
| Gold | Xstrata | Canada |
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Zhongjin Gold Corporation Limited | China |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | China |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China |
| Tantalum | Douluoshan Sapphire Rare Metal Co Ltd | China |
| Tantalum | Duoluoshan | China |
| Tantalum | Exotech Inc. | United States |
| Tantalum | F & X | China |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck GmbH Goslar | Germany |
| Tantalum | H.C. Starck GmbH Laufenburg | Germany |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck Inc. | United States |
| Tantalum | H.C. Starck Ltd. | Japan |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Hi-Temp | United States |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Kemet Blue Powder | United States |
| Tantalum | Mineração Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining & Smelting | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | Plansee SE Liezen | Austria |
| Tantalum | Plansee SE Reutte | Austria |
| Tantalum | QuantumClean | United States |
| Tantalum | RFH | China |
| Tantalum | Solikamsk Metal Works | Russian Federation |
| Tantalum | Taki Chemicals | Japan |
| Tantalum | Telex Metals | United States |
| Tantalum | ULBA | Kazakhstan |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tantalum | Zhuzhou Cemented Carbide | China |
| Tin | Alpha | United States |
| Tin | China Rare Metal Material Co., Ltd. | China |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tin | Cooper Santa | Brazil |
| Tin | CV Gita Pesona | Indonesia |
| Tin | CV Justindo | Indonesia |
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| Metal | Smelter Name | Smelter Country |
| Tin | CV Nurjanah | Indonesia |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | CV United Smelting | Indonesia |
| Tin | Dowa | Japan |
| Tin | EM Vinto | Bolivia |
| Tin | Empressa Nacional de Fundiciones (ENAF) | Bolivia |
| Tin | Estanho de Rondônia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Fenix Metals | Poland |
| Tin | Funsur Smelter | Peru |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Zi-Li | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Jiangxi Nanshan | China |
| Tin | Linwu Xianggui Smelter Co | China |
| Tin | Liuzhhou China Tin | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Metallo-Chimique N.V. | Belgium |
| Tin | Mineração Taboca S.A. | Brazil |
| Tin | Minsur | Peru |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | OMSA | Bolivia |
| Tin | PT Alam Lestari Kencana | Indonesia |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Bangka Kudai Tin | Indonesia |
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT BilliTin Makmur Lestari | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT Fang Di MulTindo | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Seirama Tin Investment | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
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| Metal | Smelter Name | Smelter Country |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Tambang Timah | Indonesia |
| Tin | PT Timah | Indonesia |
| Tin | PT Timah (Persero), Tbk | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | Rui Da Hung | Taiwan |
| Tin | Soft Metais Ltda. | Brazil |
| Tin | Thailand Smelting & Refining Co Ltd | Thailand |
| Tin | Thaisarco | Thailand |
| Tin | VQB Mineral and Trading Group JSC | Vietnam |
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Tin Company, Ltd. | China |
| Tin | Yunnan Tin Group (Holding) Company Limited | China |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | Japan |
| Tungsten | ATI Metalworking Products | United States |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States |
| Tungsten | GTP | United States |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck GmbH | Germany |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany |
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Kennametal Fallon | United States |
| Tungsten | Kennametal Huntsville | United States |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Wolfram Bergbau und Hütten AG | Austria |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China |
