Exhibit 1.01
L3 Technologies, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2018
L3 Technologies, Inc. (referred to herein as “L3,” the “Company,” “we,” “us,” or “our”) has prepared this Conflict Minerals Report (“CMR”) for the year ended December 31, 2018 to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). Rule 13p-1 was adopted by the U.S. Securities and Exchange Commission (the “SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The information in this CMR includes the activities of L3 and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.
Based upon our analysis of the broad range of L3’s communication and electronic systems and products, we have determined that L3 manufactures or contracts to manufacture certain products that contain cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG”) necessary to the functionality or production of such products.
Accordingly, as required by Rule 13p-1, we conducted, in good faith, a reasonable country of origin inquiry to determine whether any of the 3TG contained in our products originated in the Democratic Republic of the Congo or Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (the “Covered Countries”) or were from recycled or scrap sources. Based on this reasonable country of origin inquiry, we had reason to believe that the 3TG contained in our products may have originated in the Covered Countries or may not be from scrap or recycled sources. We therefore exercised due diligence on the source and chain of custody of such 3TG in conformance with the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance (the “OECD Guidance”) for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. After conducting such due diligence, we are unable to determine, with the greatest possible specificity, the facilities used to process the 3TG contained in our products or the country of origin of such 3TG. A description of our efforts to determine the mine or location of origin of the 3TG contained in our products is described below under “Due Diligence Measures.”
As permitted by Rule 13p-1 and the SEC’s April 29, 2014 statement relating to Rule 13p-1,1 this Report has not been subject to an independent private sector audit.
This report is available on our website at https://www.l3t.com/investor-relations/corporate-governance
| I. | Company and Product Overview |
L3 is a prime contractor in Intelligence, Surveillance and Reconnaissance (ISR) systems, aircraft sustainment (including modifications and fleet management of special mission aircraft), simulation and training, night vision and image intensification equipment, and security and detection systems. L3 is also a leading provider of a broad range of communication, electronic and sensor systems used on military, homeland security and commercial platforms. Our customers include the U.S. Department of Defense (DoD) and its prime contractors, U.S. Government intelligence agencies, the U.S. Department of Homeland Security, foreign governments, and domestic and foreign commercial customers.
We have the following three reportable segments: ISR Systems, Communications and Networked Systems and Electronic Systems.
| 1 | Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule, Keith F. Higgins, Director, SEC Division of Corporation Finance, April 29, 2014 |
The businesses in our ISR Systems segment provide products and services for the global ISR mission solutions from seabed to space and Command, Control and Communications markets, specializing in signals intelligence and multi-intelligence platforms, including engineering, modernization and sustainment solutions for military and various government aircraft, ground support equipment and other platforms.
The businesses in our Communications and Networked Systems segment provide network and communication systems, secure communications products, radio frequency components, satellite communication terminals and space, microwave and telemetry products.
The businesses in our Electronic Systems segment provide a broad range of products and services, including components, products, subsystems, systems and related services to military and commercial customers.
| II. | Due Diligence Measures |
We designed our due diligence measures to conform, in all material respects, with the framework in the OECD Guidance. L3 has a broad product portfolio and a supply chain that is global, complex and has multiple tiers. As a downstream purchaser, we rely on our direct suppliers to provide information with respect to the origin of 3TG contained in our products, including sources of 3TG that are supplied to our direct suppliers by lower tier suppliers. In almost all cases, the information relating to the 3TG contained in our products that we received as part of our due diligence process was obtained from lower tier suppliers. These sources of information may yield inaccurate or incomplete information. Due diligence measures, no matter how well designed and operated, can provide only reasonable, not absolute, assurance, that the due diligence objectives are met.
Our due diligence process included the following:
| ● | Steering Committee, Work Plan and Control Systems. We have a Cross Functional Steering Committee (CFSC) which is responsible for implementing our 3TG compliance strategy at the corporate and division levels. Our CFSC includes various corporate executive level members of L3 representing supply chain and procurement, legal, finance and accounting, information technology, quality, internal audit, and contracts. The CFSC is also supplemented by resources from L3 divisions located on site where the sourcing of materials takes place. The CFSC has developed a phased approach for determining the sourcing of 3TG contained in our products and has created work instructions that outline the responsibilities and processes to be used to conduct due diligence on the source of 3TG contained in our products. |
| ● | Risk Management Plan and Controls. We conduct a risk management plan that includes our 3TG compliance program and have implemented a number of controls designed to provide reasonable assurance that our 3TG compliance strategy is appropriately implemented, managed and monitored. We also have a number of longstanding grievance mechanisms in place pursuant to which employees and suppliers can report violations of 3TG compliance strategy or provide early-warning of potential violations. These policies and procedures are outlined in our Code of Ethics available on our website at https://www.l3t.com/code-of-ethics-and-business-conduct. |
| ● | Supplier Engagement and Education. We notified our suppliers of our 3TG reporting requirements under Rule 13p-1 and our expectation that our suppliers would report 3TG supply-chain information to enable our compliance with the reporting requirements under Rule 13p-1. We also engaged with our suppliers to further educate them on the 3TG reporting requirements and provided training resources and answers to frequently asked questions. |
| ● | Participation in Industry Wide Programs and Initiatives. We participate in industry-wide initiatives, including the Aerospace Industry Association’s Conflict Minerals Working Group (“AIA”), to define and create standardized procedures for supply chain mapping and identify and certify socially responsible smelters and refiners. We leveraged this industry experience and evolving “best practices” in creating our own due diligence procedures and processes. We also support and are members of an industry initiative that audits smelters’ and refiners’ due diligence activities. That industry initiative is the Responsible Minerals Initiative (RMI) (formerly, the Conflict-Free Sourcing Initiative), which was founded in 2008 by the Electronic Industry Citizenship Coalition (EICC) and The Global e-Sustainability Initiative (GeSI). |
| ● | Survey of Direct Suppliers. During 2018 we surveyed direct suppliers to L3 regarding the source of 3TG contained in our products using a questionnaire (the “L3 Questionnaire”) based upon the template developed by the EICC and GeSI, known as the Conflict Minerals Reporting Template (the “CMRT Template”). The CMRT Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. The CMRT Template includes questions regarding a company’s policy with respect to 3TG sourcing, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the CMRT Template contains questions about the origin of 3TG contained in a company’s products, as well as supplier due diligence. The L3 Questionnaire also enables us to track and consolidate supply chain responses within an electronic database tool used across all of our divisions. |
| ● | Assessment of and Follow-up on Supplier Response. We reviewed the supplier responses using criteria developed by us to determine which responses required follow-up with our suppliers and/or suggested an increased risk that the supplier may have provided 3TG that originated in the Covered Countries. This criteria assisted us in identifying responses from suppliers that were untimely, incomplete or inconsistent with other reported data. To the extent ambiguities or inconsistencies existed, we solicited updated or more comprehensive responses from our suppliers. We also conducted additional follow-up with suppliers who had not responded to our initial requests to provide 3TG information. |
| III. | Due Diligence Results |
We received responses from approximately 65% of the suppliers surveyed in 2018. The large majority of the supplier responses, however, did not isolate or represent with specificity which smelters or refiners in their supply chain had supplied the 3TG contained in our products. Accordingly, we were unable to validate with specificity the facilities used to process the 3TG or the country of origin of the 3TG.
The supplier responses identified 291 known smelters and refiners that were reported to be in our supply chain for the period from January 1, 2018 to December 31, 2018. Of those 291 smelters and refiners, 233 have been verified as conflict-free or in the audit process. The following table presents the number of identified smelters or refiners verified as conflict-free or in the audit process by mineral.
| Identified smelters or refiners verified as conflict-free or in the audit process | |
| Tantalum | 22 of 22 (100%) |
| Tin | 70 of 77 (91%) |
| Tungsten | 40 of 43 (93%) |
| Gold | 101 of 149 (68%) |
| Total | 233 of 291 (80%) |
The data on which we relied for certain statements in this CMR was obtained through our membership in the RMI (RMI member LCOM).
Based on the information provided by L3’s suppliers, L3 believes that the facilities that may have been used to process the 3TG in our products include the smelters and refiners listed in Annex I below. However, L3 is unable to ascertain sufficient information to conclusively determine which of these smelters or refiners, if any, provided 3TG that may be contained in our products.
| IV. | Steps to Mitigate Future Risk That 3TG in Our Products Benefit Armed Groups |
As provided in our 3TG Statement (available on our website at https://www.l3t.com/suppliers/conflict-minerals), L3 is committed to compliance with Rule 13p-1 and is dedicated to the implementation of comprehensive due diligence processes to meet its obligations. L3 also believes in the responsible sourcing of materials and will continue its efforts to ensure a conflict-free supply chain to the extent reasonably practicable.
Consistent with our 3TG Statement, we expect to continue to take the following steps to comply with our future obligations under Rule 13p-1 and, to the extent reasonably possible, mitigate the risk that 3TG contained in our products benefit armed groups in the Covered Countries:
| • | Mandate or Encourage 3TG Flow-Clauses in Supply Contracts. We intend to continue to include the L3 Conflict Minerals Clause, which requires suppliers to provide 3TG sourcing and smelter information, as part of our standard Terms and Conditions of Purchase in new or renewed supplier contracts. |
| • | Engage Suppliers. We plan to continue to engage with suppliers and direct them to training resources in order to improve the response rate, completeness and accuracy of our supplier survey responses. If we identify suppliers who are sourcing 3TG from the Covered Countries, we intend to negotiate with them to mitigate the risk that such 3TG benefits armed groups and/or to establish alternative sources of 3TG that do not support such groups. If these efforts prove unsuccessful, we may, when reasonably practicable, terminate the contract or find a replacement supplier. |
| • | Coordinate with Industry Associations. We expect to continue to participate in industry group efforts to define and improve best practices for 3TG supply chain mapping and induce 3TG smelters and refiners to adopt socially responsible business practices. For example, we have been involved in the AIA’s efforts to encourage certain smelters and gold refiners that supply 3TG that may be used in products manufactured by the U.S. aerospace and defense industry to conduct due diligence in accordance with the OECD Guidance and become validated as a conflict-free smelter or refiner. |
| • | Commit Resources and Management Attention. We expect our CFSC will continue to be dedicated to implementing and executing our 3TG compliance strategy at the corporate and division levels with the assistance of resources from L3 divisions located on site where the sourcing of materials takes place. We anticipate that we will continue to devote resources and personnel to the work of this committee and support its approach for determining the sourcing of 3TG contained in our products and the related work plan. |
| • | Maintain Risk Management Plan, Controls and Grievance Mechanisms. We plan to refine our risk management plan and controls over time to ensure that our 3TG compliance strategy is appropriately implemented, managed and monitored. We also intend to address, as appropriate, complaints or concerns expressed through our grievance mechanisms with respect to our 3TG compliance efforts. |
Additionally, we entered into an Agreement and Plan of Merger, dated as of October 12, 2018 (the “Merger Agreement”), by and among L3, Harris Corporation, a Delaware corporation (“Harris”), and Leopard Merger Sub Inc., a Delaware corporation and a wholly owned subsidiary of Harris. The merger is expected to close in mid-calendar year 2019, subject to satisfaction of customary closing conditions, including receipt of regulatory approvals. We intend to evaluate our conflict mineral compliance program as part of the integration-planning activities related to L3’s proposed merger with Harris.
Forward-Looking Statements
Certain of the matters discussed in this CMR, including in particular, efforts to mitigate risks that 3TG contained in our products could benefit armed groups in the Covered Countries, include forward-looking statements. Readers of this document 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 anticipated events.
ANNEX I
Subject Mineral | | Smelter or Refiner Name | | Country Location of Smelter or Refiner |
| | Tantalum | | LSM Brasil S.A. | | BRAZIL |
| | Tantalum | | Mineracao Taboca S.A. | | BRAZIL |
| | Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| | Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| | Tantalum | | Guangdong Rising Rare Metals-EO Materials Ltd. | | CHINA |
| | Tantalum | | F&X Electro-Materials Ltd. | | CHINA |
| | Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| | Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| | Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA |
| | Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
| | Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA |
| | Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA |
| | Tantalum | | FIR Metals & Resource Ltd. | | CHINA |
| | Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA |
| | Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| | Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA |
| | Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA |
| | Tantalum | | Jiujiang Janny New Material Co., Ltd. | | CHINA |
| | Tantalum | | NPM Silmet AS | | ESTONIA |
| | Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY |
| | Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY |
| | Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| | Tin | | CV Gita Pesona | | INDONESIA |
| | Tin | | PT Aries Kencana Sejahtera | | INDONESIA |
| | Tin | | PT Premium Tin Indonesia | | INDONESIA |
| | Tin | | CV United Smelting | | INDONESIA |
| | Tin | | PT Artha Cipta Langgeng | | INDONESIA |
| | Tin | | PT Babel Inti Perkasa | | INDONESIA |
| | Tin | | PT Babel Surya Alam Lestari | | INDONESIA |
| | Tin | | PT Bangka Tin Industry | | INDONESIA |
| | Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| | Tin | | PT Bukit Timah | | INDONESIA |
| | Tin | | PT DS Jaya Abadi | | INDONESIA |
| | Tin | | PT Mitra Stania Prima | | INDONESIA |
| | Tin | | PT Panca Mega Persada | | INDONESIA |
| | Tin | | PT Prima Timah Utama | | INDONESIA |
| | Tin | | PT Refined Bangka Tin | | INDONESIA |
| | Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| | Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| | Tin | | PT Sumber Jaya Indah | | INDONESIA |
| | Tin | | PT Timah Tbk Kundur | | INDONESIA |
| | Tin | | PT Timah Tbk Mentok | | INDONESIA |
| | Tin | | PT Tinindo Inter Nusa | | INDONESIA |
| | Tin | | PT Tommy Utama | | INDONESIA |
| | Tin | | CV Venus Inti Perkasa | | INDONESIA |
| | Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA |
| | Tin | | PT Inti Stania Prima | | INDONESIA |
| | Tin | | CV Dua Sekawan | | INDONESIA |
| | Tin | | PT Rajehan Ariq | | INDONESIA |
| | Tin | | PT Bangka Prima Tin | | INDONESIA |
| | Tin | | PT Sukses Inti Makmur | | INDONESIA |
| | Tin | | PT Kijang Jaya Mandiri | | INDONESIA |
| | Tin | | PT Menara Cipta Mulia | | INDONESIA |
| | Tin | | PT Bangka Serumpun | | INDONESIA |
| | Tin | | Dowa | | JAPAN |
| | Tin | | Mitsubishi Materials Corporation | | JAPAN |
| | Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA |
| | Tin | | Modeltech Sdn Bhd | | MALAYSIA |
| | Tin | | Pongpipat Company Limited | | MYANMAR |
| | Tin | | Minsur | | PERU |
| | Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES |
| | Tin | | Fenix Metals | | POLAND |
| | Tin | | Metallo Spain S.L.U. | | SPAIN |
| | Tin | | Rui Da Hung | | TAIWAN, PROVINCE OF CHINA |
| | Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| | Tin | | Thaisarco | | THAILAND |
| | Tin | | Alpha | | UNITED STATES OF AMERICA |
| | Tin | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA |
| | Tin | | Tin Technology & Refining | | UNITED STATES OF AMERICA |
| | Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIET NAM |
| | Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIET NAM |
| | Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIET NAM |
| | Tin | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM |
| | Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA |
| | Tin | | Metallo Belgium N.V. | | BELGIUM |
| | Tin | | EM Vinto | | BOLIVIA (PLURINATIONAL STATE OF) |
| | Tin | | Operaciones Metalurgicas S.A. | | BOLIVIA (PLURINATIONAL STATE OF) |
| | Tin | | Estanho de Rondonia S.A. | | BRAZIL |
| | Tin | | Mineracao Taboca S.A. | | BRAZIL |
| | Tin | | Soft Metais Ltda. | | BRAZIL |
| | Tin | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL |
| | Tin | | Magnu’s Minerais Metais e Ligas Ltda. | | BRAZIL |
| | Tin | | Melt Metais e Ligas S.A. | | BRAZIL |
| | Tin | | Resind Industria e Comercio Ltda. | | BRAZIL |
| | Tin | | Super Ligas | | BRAZIL |
| | Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA |
| | Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA |
| | Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA |
| | Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA |
| | Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA |
| | Tin | | China Tin Group Co., Ltd. | | CHINA |
| | Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA |
| | Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA |
| | Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA |
| | Tin | | Yunnan Tin Company Limited | | CHINA |
| | Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA |
| | Tin | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA |
| | Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA |
| | Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA |
| | Gold | | MMTC-PAMP India Pvt., Ltd. | | INDIA |
| | Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA |
| | Gold | | Sai Refinery | | INDIA |
| | Gold | | Bangalore Refinery | | INDIA |
| | Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA |
| | Gold | | Chimet S.p.A. | | ITALY |
| | Gold | | T.C.A S.p.A | | ITALY |
| | Gold | | Italpreziosi | | ITALY |
| | Gold | | Safimet S.p.A | | ITALY |
| | Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN |
| | Gold | | Asahi Pretec Corp. | | JAPAN |
| | Gold | | Asaka Riken Co., Ltd. | | JAPAN |
| | Gold | | Chugai Mining | | JAPAN |
| | Gold | | Dowa | | JAPAN |
| | Gold | | Eco-System Recycling Co., Ltd. | | JAPAN |
| | Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN |
| | Gold | | Japan Mint | | JAPAN |
| | Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN |
| | Gold | | Kojima Chemicals Co., Ltd. | | JAPAN |
| | Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| | Gold | | Mitsubishi Materials Corporation | | JAPAN |
| | Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| | Gold | | Nihon Material Co., Ltd. | | JAPAN |
| | Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN |
| | Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN |
| | Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN |
| | Gold | | Tokuriki Honten Co., Ltd. | | JAPAN |
| | Gold | | Yamakin Co., Ltd. | | JAPAN |
| | Gold | | Yokohama Metal Co., Ltd. | | JAPAN |
| | Gold | | Kazakhmys Smelting LLC | | KAZAKHSTAN |
| | Gold | | Kazzinc | | KAZAKHSTAN |
| | Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN |
| | Gold | | TOO Tau-Ken-Altyn | | KAZAKHSTAN |
| | Gold | | Daejin Indus Co., Ltd. | | KOREA, REPUBLIC OF |
| | Gold | | DSC (Do Sung Corporation) | | KOREA, REPUBLIC OF |
| | Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF |
| | Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF |
| | Gold | | Samwon Metals Corp. | | KOREA, REPUBLIC OF |
| | Gold | | Torecom | | KOREA, REPUBLIC OF |
| | Gold | | Korea Zinc Co., Ltd. | | KOREA, REPUBLIC OF |
| | Gold | | HeeSung Metal Ltd. | | KOREA, REPUBLIC OF |
| | Gold | | HwaSeong CJ CO., LTD. | | KOREA, REPUBLIC OF |
| | Gold | | SungEel HiMetal Co., Ltd. | | KOREA, REPUBLIC OF |
| | Gold | | NH Recytech Company | | KOREA, REPUBLIC OF |
| | Gold | | DS PRETECH Co., Ltd. | | KOREA, REPUBLIC OF |
| | Gold | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA |
| | Gold | | Modeltech Sdn Bhd | | MALAYSIA |
| | Gold | | Caridad | | MEXICO |
| | Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO |
| | Gold | | REMONDIS PMR B.V. | | NETHERLANDS |
| | Gold | | Morris and Watson | | NEW ZEALAND |
| | Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| | Gold | | KGHM Polska Miedz Spolka Akcyjna | | POLAND |
| | Gold | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION |
| | Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | RUSSIAN FEDERATION |
| | Gold | | JSC Uralelectromed | | RUSSIAN FEDERATION |
| | Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION |
| | Gold | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | RUSSIAN FEDERATION |
| | Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION |
| | Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION |
| | Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION |
| | Gold | | L’azurde Company For Jewelry | | SAUDI ARABIA |
| | Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE |
| | Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA |
| | Gold | | AU Traders and Refiners | | SOUTH AFRICA |
| | Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN |
| | Gold | | Kaloti Precious Metals | | UNITED ARAB EMIRATES |
| | Gold | | Sudan Gold Refinery | | SUDAN |
| | Gold | | Boliden AB | | SWEDEN |
| | Gold | | Argor-Heraeus S.A. | | SWITZERLAND |
| | Gold | | Cendres + Metaux S.A. | | SWITZERLAND |
| | Gold | | Metalor Technologies S.A. | | SWITZERLAND |
| | Gold | | PAMP S.A. | | SWITZERLAND |
| | Gold | | PX Precinox S.A. | | SWITZERLAND |
| | Gold | | Valcambi S.A. | | SWITZERLAND |
| | Gold | | Solar Applied Materials Technology Corp. | | TAIWAN, PROVINCE OF CHINA |
| | Gold | | Singway Technology Co., Ltd. | | TAIWAN, PROVINCE OF CHINA |
| | Gold | | Umicore Precious Metals Thailand | | THAILAND |
| | Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY |
| | Gold | | Istanbul Gold Refinery | | TURKEY |
| | Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY |
| | Gold | | African Gold Refinery | | UGANDA |
| | Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES |
| | Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES |
| | Gold | | Advanced Chemical Company | | UNITED STATES OF AMERICA |
| | Gold | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA |
| | Gold | | Kennecott Utah Copper LLC | | UNITED STATES OF AMERICA |
| | Gold | | Materion | | UNITED STATES OF AMERICA |
| | Gold | | Metalor USA Refining Corporation | | UNITED STATES OF AMERICA |
| | Gold | | Sabin Metal Corp. | | UNITED STATES OF AMERICA |
| | Gold | | United Precious Metal Refining, Inc. | | UNITED STATES OF AMERICA |
| | Gold | | Geib Refining Corporation | | UNITED STATES OF AMERICA |
| | Gold | | Abington Reldan Metals, LLC | | UNITED STATES OF AMERICA |
| | Gold | | Pease & Curren | | UNITED STATES OF AMERICA |
| | Gold | | QG Refining, LLC | | UNITED STATES OF AMERICA |
| | Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN |
| | Gold | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN |
| | Gold | | Universal Precious Metals Refining Zambia | | ZAMBIA |
| | Gold | | Fidelity Printers and Refiners Ltd. | | ZIMBABWE |
| | Gold | | L’Orfebre S.A. | | ANDORRA |
| | Gold | | Western Australian Mint (T/a The Perth Mint) | | AUSTRALIA |
| | Gold | | Morris and Watson Gold Coast | | AUSTRALIA |
| | Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA |
| | Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM |
| | Gold | | Tony Goetz NV | | BELGIUM |
| | Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL |
| | Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA |
| | Gold | | Umicore Brasil Ltda. | | BRAZIL |
| | Gold | | Marsam Metals | | BRAZIL |
| | Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA |
| | Gold | | Asahi Refining Canada Ltd. | | CANADA |
| | Gold | | Royal Canadian Mint | | CANADA |
| | Gold | | Planta Recuperadora de Metales SpA | | CHILE |
| | Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA |
| | Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA |
| | Gold | | Refinery of Seemine Gold Co., Ltd. | | CHINA |
| | Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CHINA |
| | Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA |
| | Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA |
| | Gold | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| | Gold | | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | | CHINA |
| | Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA |
| | Gold | | Jiangxi Copper Co., Ltd. | | CHINA |
| | Gold | | Lingbao Gold Co., Ltd. | | CHINA |
| | Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA |
| | Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA |
| | Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA |
| | Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA |
| | Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA |
| | Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CHINA |
| | Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA |
| | Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA |
| | Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | CHINA |
| | Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA |
| | Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | CHINA |
| | Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA |
| | Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA |
| | Gold | | Guangdong Jinding Gold Limited | | CHINA |
| | Gold | | SAFINA A.S. | | CZECH REPUBLIC |
| | Gold | | SAAMP | | FRANCE |
| | Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| | Gold | | Aurubis AG | | GERMANY |
| | Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| | Gold | | DODUCO Contacts and Refining GmbH | | GERMANY |
| | Gold | | Heimerle + Meule GmbH | | GERMANY |
| | Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY |
| | Gold | | SAXONIA Edelmetalle GmbH | | GERMANY |
| | Gold | | WIELAND Edelmetalle GmbH | | GERMANY |
| | Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY |
| | Tungsten | | A.L.M.T. Corp. | | JAPAN |
| | Tungsten | | Japan New Metals Co., Ltd. | | JAPAN |
| | Tungsten | | Woltech Korea Co., Ltd. | | KOREA, REPUBLIC OF |
| | Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES |
| | Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION |
| | Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION |
| | Tungsten | | Moliren Ltd. | | RUSSIAN FEDERATION |
| | Tungsten | | Kennametal Huntsville | | UNITED STATES OF AMERICA |
| | Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA |
| | Tungsten | | Kennametal Fallon | | UNITED STATES OF AMERICA |
| | Tungsten | | Niagara Refining LLC | | UNITED STATES OF AMERICA |
| | Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIET NAM |
| | Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIET NAM |
| | Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIET NAM |
| | Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA |
| | Tungsten | | ACL Metais Eireli | | BRAZIL |
| | Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| | Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA |
| | Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| | Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | | CHINA |
| | Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| | Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| | Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| | Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA |
| | Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA |
| | Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | Jiangxi Xianglu Tungsten Co., Ltd. | | CHINA |
| | Tungsten | | South-East Nonferrous Metal Company Limited of Hengyang City | | CHINA |
| | Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |
| | Tungsten | | Hunan Litian Tungsten Industry Co., Ltd. | | CHINA |
| | Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY |
| | Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
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