Exhibit 1.01
Conflict Minerals Report of Woodward, Inc.
For the reporting period from January 1, 2018 to December 31, 2018
This Conflict Minerals Report (the “Report”) of Woodward, Inc. (the “Company,” “Woodward,” “we,” “us” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (“Form SD”) promulgated under the Securities Exchange Act of 1934 (the “Exchange Act”) for the reporting period January 1, 2018 to December 31, 2018 (the “Reporting Period”).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD, and as used herein, “conflict minerals” means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an “adjoining country” as defined in Form SD (collectively, the “Covered Countries”).
Woodward’s Manufactured and Contracted-to-Manufacture Products
Woodward, including our consolidated subsidiaries, manufactures and sub-contractors, manufacture products for which conflict minerals are necessary to the functionality or production of those products. We provide energy control and optimization solutions for the aerospace and industrial markets through the precise and efficient control of fluid and electrical energy, combustion, and motion. Our key focus areas within the aerospace market are propulsion system control solutions for turbine powered aircraft, actuation systems and motion control solutions. Specific products include fuel pumps, metering units, actuators, air valves, specialty valves, fuel nozzles, and thrust reverser actuation systems for turbine engines and nacelles; as well as flight deck controls (auto throttles, rudder pedal assembles, flight control assemblies), actuators, servocontrols, motors and sensors for aircraft. Within the industrial market, our key focus areas are control solutions for equipment that produce electricity using conventional or renewable energy sources; solutions for the control of power quality, distribution and storage on the electrical grid; and control solutions for power equipment used in the extraction, distribution and conversion of renewable and fossil fuels in marine, mobile, and industrial equipment applications. Specific products include power converters, actuators, valves, pumps, injectors, solenoids, ignition systems, governors, electronics and devices that measure, communicate and protect low and medium voltage electrical distribution systems.
In 2018, Woodward extended its fuel injection systems product portfolio with the acquisition of L’Orange, a world class fuel injection systems technology company, from Rolls-Royce. The acquisition formally closed on June 4, 2018; therefore, in accordance with SEC Final Rule Item 1.02, Instructions for Item 1.01 (3), Woodward L’Orange’s use of the conflict minerals, its due diligence, and other SEC Final Rule reporting requirements are not included in Woodward’s disclosure for the Reporting Period.
The Company’s Due Diligence Process
The Company’s due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Development’s (“OECD”), “OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas,” Second Edition (Third Edition as of October 2016), including applicable supplements thereto (the “OECD Guidelines”).
Woodward has implemented or is addressing each of the steps in the OECD 5-step due diligence framework as discussed or referenced below:
| 1. | Establish strong company management systems |
| A. | Company conflict minerals policy |
Woodward has developed and adopted a conflict minerals policy, Policy 9-14, Conflict Minerals (the “Conflict Minerals Policy”). The Conflict Minerals Policy affirms that the Company takes our corporate responsibility with respect to responsible sourcing seriously and that it is the Company’s goal only to use in our products conflict minerals that are sourced responsibly. The Conflict Minerals Policy provides that Woodward will take appropriate measures to ensure participants in our global supply chain exercise due diligence and comply with reporting and other compliance requirements with respect to the items Woodward procures from them. The policy is publicly available as a document link at:https://www.woodward.com/en/about/corporate-governance/compliance. The policy is formally reviewed at least annually per corporate policy requirements to determine if any revisions or enhancements are required to maintain compliance with the letter and the intent of the law. No changes were made to Woodward’s Conflict Minerals Policy as the result of its review in 2018.
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| B. | Internal management structure |
The Conflict Minerals Policy designates the Corporate Vice President of Global Supply Chain as responsible for ensuring our compliance with conflict minerals reporting requirements. Woodward’s Corporate Director, Global Trade Compliance & Associate General Counsel, serves as an advisor on conflict minerals compliance. Conflict minerals have also been a topic of discussion and review at Board of Directors meetings since September 2012.
The Company has established an internal team to manage conflict minerals engagement with our suppliers. Woodward assigned our Global Supply Chain (“GSC”) with the responsibility for conflict minerals compliance. The GSC’s Business Integration Group has been designated as the focal point for the compliance efforts, as that group has responsibility for GSC business systems, procedures, and compliance with government regulations. Woodward is subject to numerous product material compliance (“PMC”) regulations, including conflict minerals, which require enterprise-wide system and compliance processes and integrated process teams to achieve regulatory compliance requirements and social responsibility goals. The project manager and a product material compliance core team (together the “Core Team”), with other members assigned from the GSC’s Business Integration Group, and with counsel from the Legal & Compliance Department, are the Company’s team of subject matter experts and implementers. The GSC is responsible for reaching out to the Company’s supply base on an ongoing basis to collect information, including Conflict Minerals Reporting Templates (“CMRT”), regarding the presence and sourcing of conflict minerals in the products supplied to the Company. The Global Supplier Managers (commodity managers) within the GSC have also provided focused support as required. These actions have aligned existing strategic and organizational structures to address the due diligence and reporting requirements of the Securities and Exchange Commission (“SEC”) Final Rule.
In addition, Woodward’s product material compliance activity, including conflict minerals, was chartered as a formal project in February 2015 to provide an established framework for the continuing evolution of an enterprise-wide set of material compliance processes and standard work. The project is under the sponsorship of an Executive Committee comprised of the Corporate Vice President of Global Supply Chain, Corporate Vice President of Information Technology, and the Corporate Vice President, General Counsel, Corporate Secretary and Chief Compliance Officer. The product material compliance project manager provides status updates and receives executive project guidance on a once per quarter basis. The project also had a Steering Committee through calendar year 2017, which served as a liaison between the core team and Woodward’s business groups. The Steering Committee consisted of a Vice-President from each Woodward business group and a director from each of Woodward’s Global Support Services organizations. This additional structure enhanced the initial guidance, awareness and execution of compliance and compliance support requirements throughout the enterprise. As of CY 2018, the Core Team, our processes and the platform and efforts of our solution provider all achieved sufficient maturity for product material compliance to be considered as a standard element of Woodward’s workflow, and the Steering Committee was dissolved. The GSC Director of Business Integration, with Core Team input and support, briefed the GSC leadership during quarterly reviews held during the course of the 2018 campaign. The GSC also kept the members of the Executive Committee informed of operations, issues and progress during scheduled one-on-one meetings with each of them. Additionally, during calendar year 2018, the product material compliance project manager kept the engineering leadership of business units involved in active campaigns informed as to their status progress and plans on a weekly basis.
| C. | System of controls and transparency over the mineral supply chain |
Our existing business systems, WISE and SAP, provide controls over our supply chain. They currently provide:
| • | Identification of the end item products we provide to each of our customers; |
| • | Shipping transaction history, to assist in bounding our sales/shipments by calendar year as required by the SEC Final Rule; |
| • | A bill of material (“BOM”) identifying all of the components and materials in each of our end item products; |
| • | A purchasing history of each of our purchased components and raw materials and the identification of the suppliers used for these purchases; |
| • | A receiving inspection function that accepts or rejects purchased components and raw materials based upon whether the purchased items meet or do not meet the specification requirements (including specified material requirements) of the associated drawing or other specification documents. This is accomplished by a combination of direct measurements / inspections of the actual parts, or by reviewing the existence and completeness of formal supplier certifications to selected specifications, such as certifying proper use of specified aluminum or steel specifications. |
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We continued the implementation of the Assent Compliance Platform (“ACP”) software application and the Assent services to automate much of the Company’s product materials compliance efforts. In addition, Woodward continues to maintain full membership with the Aerospace Industries Association (“AIA”), the IPC – the Association Connecting Electronics Industries, and the Conflict Free Sourcing Initiative (“CFSI”). In October 2017, CFSI was rebranded as the Responsible Materials Initiative (“RMI”) and will be so noted for all 2018 related activity.
| D. | Strengthen Company engagement with suppliers |
The Company is committed to conducting business in a socially responsible manner and is determined to partner with suppliers who are similarly committed. Woodward has and continues to significantly enhance its engagement with its suppliers regarding conflict minerals requirements. Our purchase order and supplier agreement terms and conditions were modified in mid-2013 to require our suppliers to support our conflict minerals reporting. Woodward continued to revise supplier contract terms and conditions in 2015 with the goal of obtaining full material disclosure (substance, content-by-weight, raw material smelter sources) to increase the traceability of materials from each supplier.
By accepting a Woodward purchase order or a purchase release to a supplier agreement, a seller to Woodward:
“…warrants and certifies that it complies with Section 1502 of the Dodd Frank Act and the Conflict Minerals Regulations and Final Rules issued by the U.S. Securities and Exchange Commission, and any subsequent rules and regulations related thereto (“Conflict Minerals Regulations”), and has implemented compliant processes to ensure its suppliers are in compliance with the Conflict Minerals Regulations.
Where Seller does not have direct and formal reporting requirements under the Conflict Minerals Regulations, and upon request by Buyer, Seller agrees to provide due diligence and Responsible Country of Origin Inquiry (“RCOI”) information under this Agreement to Buyer in support of Buyer’s reporting requirements (the “RCOI Requirements”). Further, Seller shall promptly comply with all requests by Buyer to provide documentation, and other substantiating data and assurances with respect to its compliance with Conflict Minerals Regulations and the RCOI Requirements as Buyer may deem necessary from time to time. In the event: (a) Buyer deems Seller is not in compliance with the Conflict Minerals Regulations or the RCOI Requirements, (b) Buyer is not satisfied with the outcome of any review of Seller documentation and/or data or otherwise, or (c) Seller does not provide the documentation, other data and/or other further assurances to Buyer as requested by Buyer, Buyer shall have the right to terminate this Order or any portion thereof without penalty or further liability to Seller.”
In 2016, Woodward continued to conduct one-on-one contact sessions with suppliers to address their inquiries and provide guidance where needed. Development of Woodward-specific formal supplier training courses continues and determination of appropriate Woodward course delivery methods are under discussion. Through our contract with Assent, our suppliers have access to an extensive suite of training videos, slide decks, how-to manuals and regulation guidance documents. Our suppliers also have access to online chat with an Assent specialist if they have difficulties or questions while preparing their responses. In late 2016 and throughout 2017 and 2018, Woodward participated in multiple Assent Compliance supplier summits and conferences, inviting our regional suppliers to these and providing additional guidance for our joint use of ACP in the campaign process.
| E. | Establish a company level, or industry-wide, grievance mechanism as an early warning risk-awareness system |
Woodward has a comprehensive ethics awareness compliance policy, annual training and contact mechanisms for members’ concerns or ethics grievances. This allows and encourages members to either contact their leader, or anyone in a leadership position, Human Resources, the Company’s Chief Compliance Officer, any other Company Officer, any member of the Company’s Board of Directors, or a hotline / ethics help line (both telephonic and web based) that is managed by an externally contracted agency, which allows for anonymous input if a reporting member so chooses. The details are described in Woodward Policy 01-14 – Woodward Code of Business Conduct and Ethics and in the annual member and leader ethics trainings. Investigations of alleged violations are handled by a Company level Business Conduct Oversight Committee and by the Audit Committee of the Board of Directors.
Direct suppliers to Woodward may contact their Global Supplier Manager at Woodward for resolution if they believe elements of Woodward direction may cause them to be noncompliant with Woodward’s stated social responsibility goals and compliance requirements. Woodward GSC members are also available to help our direct suppliers with compliance issues they may have with their suppliers regarding our flow down contract requirements. Suppliers’ conflict minerals representatives may also contact Woodward’s product material compliance project manager, who will facilitate the appropriate guidance or resolution regarding such issues. In 2018, the Woodward Core Team continued its assessment of the feasibility of incorporating social responsibility matters such as conflict minerals compliance into our existing ethics and compliance infrastructure. This assessment is taking an extended duration and will continue into 2019 due to the 2018 acquisition of L’Orange into Woodward and due to a number of changes in or retirements of senior leaders.
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| 2. | Identify and assess risks in the supply chain |
Woodward is a downstream manufacturer. As such, Woodward does not control the origin or composition of many of the materials provided by our suppliers. Consequently, we ask our suppliers to inquire, identify, and conduct data collection and due diligence activities, which in turn are fundamental elements of our due diligence activities. Woodward conducts analyses of the data collected from our first-tier suppliers for accuracy and completeness in order to identify and assess risks in the Woodward supply chain. This includes:
| • | The initial smelter checklist analysis contained in the CMRT |
| • | Assent validation of SOR lists in the supplier CMRTs, using an extensive database consisting of the RMI, Responsible Jewelry Network, and London Bullion Market Association validated SOR lists, and the results of Assent’s extensive internal and independent SOR validation efforts |
| • | The indirect analysis input that Woodward has acquired as a result of submitting interim roll-up CMRTs to our customers and receiving analysis results from the various software applications they use |
In 2015, Woodward started (on a manual basis) to use both the publicly available RMI SOR list, and the RMI compliance and country of origin databases available through our RMI membership. In 2016, 2017 and 2018 we continued that approach and applied it to the roll-up Woodward CMRT that ACP generated from our valid supplier CMRTs. As it becomes available via RMI or ACP, Woodward intends to utilize the certification results of sources certified to the Fairtrade Standard for Gold and Precious Metals.
For suppliers’ smelter inputs that are still undetermined (i.e., the source has not been confirmed as a smelter, or its conflict-free sourcing status has not been identified through the above validation programs), ACP automatically provides a corrective action request to suppliers having such inputs. Assent and Woodward jointly work with suppliers needing additional assistance to correct or eliminate these undetermined inputs as appropriate.
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our RCOI process is described in our Form SD.
| 3. | Design and implement a strategy to respond to identified risks |
| A. | Report findings of the supply chain risk assessment, including conflict minerals compliance, to the designated senior management of the Company |
In addition to the product material compliance project core team or its leader reporting to the Executive Committee and to Global Supply Chain as identified in 1B above, in 2018 Woodward, with significant Assent support, continued to conduct one-on-one supplier contacts and perform assessments on supplier-provided SOR data as described in the Woodward Calendar Year 2018 Due Diligence Results section of this Conflict Minerals Report.
| • | Woodward conducts monthly supplier reviews by commodity grouping with the Corporate Vice President of Global Supply Chain and the commodity directors. |
| • | The periodic reviews conducted by each business group president include a review of supply chain issues for that business group. |
| • | A strategic planning review and a mid-year review are presented by the corporate executive staff to the Company’s Chief Executive Officer and the Company’s Chief Financial Officer to provide, at the highest level of management, strategic oversight of our supply chain strategies and performance. |
| B. | Devise and adopt a risk management plan |
Woodward has several formal procedures and tools relative to risk management that form a solid foundation for our planned improvement actions to incorporate specific conflict minerals aspects of risk management. These existing procedures include but are not limited to our supplier approval process, our purchasing procedures, our purchase order and supplier agreement terms and conditions (described in Due Diligence section 1D above), our supplier registration portal and our Parts Transition Process, and possible software solutions. In addition, our Assent Compliance Platform and services perform a risk assessment and risk rating on each received supplier CMRT.
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| C. | Implement the risk mitigation plan |
Woodward is continuing to develop a risk management and mitigation plan providing for actions to be taken should Woodward determine if any conflict minerals are sourced from conflict-affected areas of Covered Countries. This started with Woodward being a co-signer, with more than 40 companies, to an annual letter started in 2017 and coordinated by Assent. This letter was sent to every SOR that has not completed or that was not actively participating in an independent third-party audit, and was sent to enable the assessment of the use of conflict-free sourcing practices. We are currently extending this risk mitigation to include letters to our suppliers.
| D. | Undertake additional fact finding and risk assessments for risks requiring mitigation, or after a change in circumstances |
In 2018, Woodward continued to engage in additional fact finding and risk assessments to identify risks requiring mitigation or after a change in circumstances. These activities are described above. The enhanced inquiry and assessment activities discussed for RCOI in our Form SD also provide additional and refined findings for risk identification and assessment. These activities are discussed in the RCOI Improvement Actions Continuing or Planned section at the end of our Form SD.
| 4. | Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain |
Woodward is significantly downstream in the supply chain from smelters and refiners. In order to obtain SOR information, Woodward seeks information from our upstream suppliers and from third party data aggregating services. Woodward joined the EICC/ GeSI CFSI (now RMI) in late 2015 to leverage the CFSI (now RMI) Conflict Free Smelter audit program and the resulting audit data from that program. We will also leverage any equivalent audit data that may be obtained through Woodward’s memberships in the AIA and IPC.
| 5. | Report annually on supply chain due diligence |
The Form SD is posted as one of our many required SEC filings as a document link at https://ir.woodward.com/financials/sec-filings/default.aspx. The Conflict Minerals Report, when required, is also posted as a document link at https://www.woodward.com/en/about/corporate-governance/compliance. These postings are completed within one business week of the filing of these documents with the SEC. Also in compliance with the SEC Final Rule, Woodward’s Conflict Minerals Policy, Policy 09-14, is posted as a document link athttps://www.woodward.com/en/about/corporate-governance/compliance. Woodward has published a Sustainability Report, which summarizes our Conflict Minerals Policy and provides the context of conflict minerals compliance and objectives within our overall sustainability goals, initiatives and practices. The Sustainability Report is available as a document link at https://www.woodward.com/en/about/social-responsibility.
Woodward Calendar Year 2018 Due Diligence Results
Woodward Conflict Minerals Data Requests and Supplier Responses (the Due Diligence in Acquiring Supplier Data)
Woodward initiated its 2018 campaign via ACP with suppliers managed in our SAP ERP system on February 27, 2019, and with the suppliers managed in our WISE ERP system on March 4, 2019, requesting both Conflict Minerals Reporting Templates (“CMRTs”) and updated contact data. The initiation of this campaign was later than planned due to the effort required to support other urgent Woodward material compliance campaigns. However, we are benefiting from the earlier ongoing industry activity that generate data that could be used by Woodward to perform our RCOIs. This is the second reporting year that Woodward is requesting part-level CMRTs if they are readily available or producible. If suppliers cannot provide part-level CMRTs, then we would continue to accept company level CMRTs. We are using the suppliers’ CMRTs to identify if they had a parent company, their parent company contact data if applicable, and whether their conflict minerals reporting was from a corporate or business group level. This is to further improve our inquiry approach in future reporting years. Follow-up inquiries were sent to current non-respondents via ACP on March 11 and 25. Escalation follow-ups were sent as personalized e-mails from our Assent Supplier Engagement Team on April 8, 22 and 29. Follow-up with suppliers submitting incomplete or incorrect CMRTs also started March 11. Woodward’s supplier CMRT response status as of May 2, 2019 was:
Total # of Supplier records – 1,823
Total # of emails sent – 5 separate follow-up inquiries on a 2-week interval to non-responsive suppliers
Total # of CMRTs received – 1,163 (63.8%) versus 609 (51.7%) in 2017
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Total # of valid CMRTs received – 1,038 (“valid” indicates Excel file CMRT with no checker-tab-indicated errors) (56.9%) versus 565 (47.9%) in 2017
Our total completion rate is 12% better than last year’s statistics and represents our best response rate to date. This is in part due to a 1-month earlier campaign start than last year, and in part due to Assent’s global supplier matching efforts of previously received industry data as noted above. The campaign with our SAP-managed suppliers, which started one week earlier than our campaign for our WISE-managed suppliers, achieved a 80% response rate, a significant improvement over last year’s campaign (65%). There were 202 of our supplier CMRT responses at the Woodward-requested part or part-family level, compared to 79 last year. Woodward was unable to reach its internal 75% or better completion target for calendar year 2018. We believe two factors contributed significantly to this. The first is an apparent decrease in supplier interest in the conflict minerals program (despite the participation rate increase) based on the nature of numerous supplier responses to our CMRT requests. The second, based on a number of supplier responses, suggests that some upstream supplier / manufacturers believe that they only need to address sales for the current reporting year, following the SEC Final Rule guidelines. However, Woodward and other downstream customers in many cases use components purchased in prior years within the products that they introduce into the stream of commerce during the current reporting year. That results in a downstream supplier need for CMRT data from prior timeframes.
Supplier Response Assessment (Smelter Determination Due Diligence)
ACP generated an integrated roll-up CMRT from all valid supplier CMRTs received as of May 2, 2019. This resulted in the 321 SOR (the same number as in 2017) with RMI identification numbers listed in the table below who provide through our supply chain conflict minerals used in Woodward’s products:
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| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Gold | Smelter Not Listed | ITALY | CID002763 | RMI | ||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | RMI | ||||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 | RMI | ||||
| Gold | African Gold Refinery | UGANDA | CID003185 | RMI | ||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | RMI | ||||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | CID002560 | RMI | ||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | RMI | ||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | RMI | ||||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | RMI | ||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | RMI | ||||
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 | RMI | ||||
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | RMI | ||||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | RMI | ||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | RMI | ||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | RMI | ||||
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | RMI | ||||
| Gold | Aurubis AG | GERMANY | CID000113 | RMI | ||||
| Gold | Bangalore Refinery | INDIA | CID002863 | RMI | ||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | RMI | ||||
| Gold | Boliden AB | SWEDEN | CID000157 | RMI | ||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | RMI | ||||
| Gold | Caridad | MEXICO | CID000180 | RMI | ||||
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA | CID000185 | RMI | ||||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | RMI | ||||
| Gold | Chimet S.p.A. | ITALY | CID000233 | RMI | ||||
| Gold | Chugai Mining | JAPAN | CID000264 | RMI | ||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | RMI | ||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | RMI | ||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | RMI | ||||
| Gold | Smelter Not Listed | UNITED ARAB EMIRATES | CID003348 | RMI | ||||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | RMI | ||||
| Gold | Dowa | JAPAN | CID000401 | RMI | ||||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 | RMI | ||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | RMI | ||||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 | RMI | ||||
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| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | RMI | ||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | RMI | ||||
| Gold | Smelter Not Listed | UNITED ARAB EMIRATES | CID002584 | RMI | ||||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | RMI | ||||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 | RMI | ||||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | RMI | ||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | RMI | ||||
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | RMI | ||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | RMI | ||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | RMI | ||||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | RMI | ||||
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | RMI | ||||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | RMI | ||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | RMI | ||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | RMI | ||||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 | RMI | ||||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 | RMI | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | RMI | ||||
| Gold | Smelter Not Listed | UNITED ARAB EMIRATES | CID002562 | RMI | ||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | RMI | ||||
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 | RMI | ||||
| Gold | Italpreziosi | ITALY | CID002765 | RMI | ||||
| Gold | Japan Mint | JAPAN | CID000823 | RMI | ||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | RMI | ||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | RMI | ||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | RMI | ||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | RMI | ||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | RMI | ||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | RMI | ||||
| Gold | Kazzinc | KAZAKHSTAN | CID000957 | RMI | ||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | RMI | ||||
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| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | RMI | ||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | RMI | ||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | RMI | ||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | RMI | ||||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | RMI | ||||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | CID001032 | RMI | ||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | RMI | ||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | RMI | ||||
| Gold | L’Orfebre S.A. | ANDORRA | CID002762 | RMI | ||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | RMI | ||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | RMI | ||||
| Gold | Marsam Metals | BRAZIL | CID002606 | RMI | ||||
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 | RMI | ||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | RMI | ||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | RMI | ||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | RMI | ||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | RMI | ||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | RMI | ||||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | RMI | ||||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | RMI | ||||
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | RMI | ||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | RMI | ||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | RMI | ||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | RMI | ||||
| Gold | Morris and Watson | NEW ZEALAND | CID002282 | RMI | ||||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | CID002866 | RMI | ||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | RMI | ||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | RMI | ||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | RMI | ||||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | RMI | ||||
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | RMI | ||||
9
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | RMI | ||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | RMI | ||||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | RMI | ||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | RMI | ||||
| Gold | PAMP S.A. | SWITZERLAND | CID001352 | RMI | ||||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 | RMI | ||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | RMI | ||||
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | RMI | ||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | RMI | ||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | RMI | ||||
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | RMI | ||||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 | RMI | ||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | RMI | ||||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | RMI | ||||
| Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 | RMI | ||||
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | CID002510 | RMI | ||||
| Gold | Royal Canadian Mint | CANADA | CID001534 | RMI | ||||
| Gold | SAAMP | FRANCE | CID002761 | RMI | ||||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 | RMI | ||||
| Gold | Safimet S.p.A | ITALY | CID002973 | RMI | ||||
| Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | RMI | ||||
| Gold | Sai Refinery | INDIA | CID002853 | RMI | ||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | RMI | ||||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 | RMI | ||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | RMI | ||||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | RMI | ||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | RMI | ||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | RMI | ||||
| Gold | Smelter Not Listed | CHINA | CID002525 | RMI | ||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | RMI | ||||
10
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 | RMI | ||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | RMI | ||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | RMI | ||||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | RMI | ||||
| Gold | Sudan Gold Refinery | SUDAN | CID002567 | �� | RMI | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | RMI | ||||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 | RMI | ||||
| Gold | T.C.A S.p.A | ITALY | CID002580 | RMI | ||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | RMI | ||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | RMI | ||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | RMI | ||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | RMI | ||||
| Gold | Tony Goetz NV | BELGIUM | CID002587 | RMI | ||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | RMI | ||||
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | RMI | ||||
| Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | RMI | ||||
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | RMI | ||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | RMI | ||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 | RMI | ||||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 | RMI | ||||
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 | RMI | ||||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | RMI | ||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | RMI | ||||
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 | RMI | ||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | RMI | ||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | RMI | ||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | RMI | ||||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 | RMI | ||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | RMI | ||||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | RMI | ||||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 | RMI | ||||
11
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | RMI | ||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | RMI | ||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | RMI | ||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | RMI | ||||
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 | RMI | ||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | RMI | ||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | RMI | ||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | RMI | ||||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 | RMI | ||||
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | RMI | ||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | RMI | ||||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | RMI | ||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | RMI | ||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | RMI | ||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | RMI | ||||
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | CID003191 | RMI | ||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | RMI | ||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | RMI | ||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | RMI | ||||
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 | RMI | ||||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 | RMI | ||||
| Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | RMI | ||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | RMI | ||||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | RMI | ||||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | RMI | ||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | RMI | ||||
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 | RMI | ||||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 | RMI | ||||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 | RMI | ||||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | RMI | ||||
12
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | RMI | ||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | RMI | ||||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | RMI | ||||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 | RMI | ||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | RMI | ||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | RMI | ||||
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | RMI | ||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | RMI | ||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | RMI | ||||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | RMI | ||||
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | RMI | ||||
| Tin | CV Ayi Jaya | INDONESIA | CID002570 | RMI | ||||
| Tin | CV Dua Sekawan | INDONESIA | CID002592 | RMI | ||||
| Tin | CV Gita Pesona | INDONESIA | CID000306 | RMI | ||||
| Tin | CV Tiga Sekawan | INDONESIA | CID002593 | RMI | ||||
| Tin | CV United Smelting | INDONESIA | CID000315 | RMI | ||||
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | RMI | ||||
| Tin | Smelter Not Listed | CHINA | CID003356 | RMI | ||||
| Tin | Dowa | JAPAN | CID000402 | RMI | ||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | RMI | ||||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 | RMI | ||||
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | RMI | ||||
| Tin | Fenix Metals | POLAND | CID000468 | RMI | ||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | RMI | ||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | RMI | ||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | RMI | ||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | RMI | ||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | RMI | ||||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | RMI | ||||
13
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 | RMI | ||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | RMI | ||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | RMI | ||||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | RMI | ||||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | RMI | ||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | RMI | ||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | RMI | ||||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | RMI | ||||
| Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | RMI | ||||
| Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | RMI | ||||
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | RMI | ||||
| Tin | Minsur | PERU | CID001182 | RMI | ||||
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | RMI | ||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | RMI | ||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | RMI | ||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | RMI | ||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | RMI | ||||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | RMI | ||||
| Tin | Pongpipat Company Limited | MYANMAR | CID003208 | RMI | ||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | RMI | ||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | RMI | ||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | RMI | ||||
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | RMI | ||||
| Tin | Smelter Not Listed | INDONESIA | CID001406 | RMI | ||||
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | RMI | ||||
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 | RMI | ||||
| Tin | PT Bangka Tin Industry | INDONESIA | CID001419 | RMI | ||||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 | RMI | ||||
| Tin | PT Bukit Timah | INDONESIA | CID001428 | RMI | ||||
| Tin | PT DS Jaya Abadi | INDONESIA | CID001434 | RMI | ||||
| Tin | PT Inti Stania Prima | INDONESIA | CID002530 | RMI | ||||
| Tin | PT Karimun Mining | INDONESIA | CID001448 | RMI | ||||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 | RMI | ||||
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | RMI | ||||
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | RMI | ||||
14
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tin | PT Panca Mega Persada | INDONESIA | CID001457 | RMI | ||||
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 | RMI | ||||
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 | RMI | ||||
| Tin | Smelter Not Listed | INDONESIA | CID003381 | RMI | ||||
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | RMI | ||||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 | RMI | ||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | RMI | ||||
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | RMI | ||||
| Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 | RMI | ||||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 | RMI | ||||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 | RMI | ||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | RMI | ||||
| Tin | Smelter Not Listed | INDONESIA | CID002478 | RMI | ||||
| Tin | PT Tommy Utama | INDONESIA | CID001493 | RMI | ||||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | RMI | ||||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 | RMI | ||||
| Tin | Soft Metais Ltda. | BRAZIL | CID001758 | RMI | ||||
| Tin | Super Ligas | BRAZIL | CID002756 | RMI | ||||
| Tin | Smelter Not Listed | VIET NAM | CID002834 | RMI | ||||
| Tin | Thaisarco | THAILAND | CID001898 | RMI | ||||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | RMI | ||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | RMI | ||||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 | RMI | ||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | RMI | ||||
| Tin | Yunnan Tin Company Limited | CHINA | CID002180 | RMI | ||||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 | RMI | ||||
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | RMI | ||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | RMI | ||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | RMI | ||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | RMI | ||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | RMI | ||||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | RMI | ||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | RMI | ||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | RMI | ||||
15
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | RMI | ||||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 | RMI | ||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | RMI | ||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | RMI | ||||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | RMI | ||||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | RMI | ||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | RMI | ||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 | RMI | ||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | RMI | ||||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 | RMI | ||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | RMI | ||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | RMI | ||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | RMI | ||||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 | RMI | ||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | RMI | ||||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | RMI | ||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | RMI | ||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | RMI | ||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | RMI | ||||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | RMI | ||||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 | RMI | ||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | RMI | ||||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 | RMI | ||||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | RMI | ||||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 | RMI | ||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | RMI | ||||
16
| Metal (*) | Smelter Look-up (*) | Smelter Country (*) | Smelter Identification | Source of Smelter Identification Number | ||||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 | RMI | ||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | RMI | ||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | RMI | ||||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | RMI | ||||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | RMI | ||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | RMI | ||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | RMI | ||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | RMI | ||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | RMI | ||||
We then used RMI’s SOR compliance status and mine country of origin data available to Woodward as a RMI member with the following summary results: as of May 2, 2019, of the 321 identified SORs, 317 were eligible for RMI audit. 252 of the SORs were determined by RMI to be “Conformant” (follows DRC Conflict Free protocols as determined by audit or by a specific membership), 7 are designated as “Active, and 41 other SORs are in communication, in vetting or awaiting outreach with RMI for audits. Mine country of origin data was not available for three of the 252 Conformant SORs. Nine others were audited by the Responsible Jewelry Council (“RJC”), but whose mine country of origin was not disclosed to RMI. RMI found 6 SORs on Woodward’s list to be non-conformant; we will conduct further investigations to pinpoint the suppliers using these SORs and determine if that use relates to any items we procure from those suppliers. The Woodward due diligence process via ACP and Assent services have also identified specific suppliers that source from one or more of 7 different SORs that are categorized as “high risk” based on their sourcing practices and relationships. Woodward will conduct an outreach to these suppliers via Assent to request that they encourage these SORs to participate in a third party audit program, and/or to encourage and facilitate these suppliers’ migration to alternate, acceptable SORs. Finally, Assent services teams acting on behalf of Woodward identified suppliers who listed one or both of two SORs which are on trade sanctions lists. Both of these subsequently ceased operations; therefore, 3TG is no longer available for purchase from them. However, residual stock from them may still be in supplier inventories and subject to disclosure.
Smelter or Refiner Mine Country of Origin Results
Collectively, the 240 of the 252 Conformant SORs for which RMI had sourcing data obtain their minerals from the following mine countries of origin, depending on the Conflict Mineral of interest. The below list for gold is a combination of the country of origin findings by the RMI and the mined material country of origin data provided by the London Bullion Market Association (“LBMA”) to the RMI:
Gold:
Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Level 1 countriesare not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. | Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold. | Level 3 countries are defined as the DRC and its nine adjoining countries. | ||
| Argentina | Kenya | Tanzania | ||
| Armenia | South Africa | Zambia | ||
| Australia | ||||
| Azerbaijan | ||||
| Benin | ||||
| Bolivia (Plurinational State of) | ||||
| Botswana | ||||
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Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Brazil | ||||
| Burkina Faso | ||||
| Canada | ||||
| Chile | ||||
| China | ||||
| Colombia | ||||
| Cyprus | ||||
| Dominican Republic | ||||
| Ecuador | ||||
| Egypt | ||||
| Eritrea | ||||
| Ethiopia | ||||
| Finland | ||||
| Georgia | ||||
| Ghana | ||||
| Guatemala | ||||
| Guinea | ||||
| Guyana | ||||
| Honduras | ||||
| Indonesia | ||||
| Iran | ||||
| Ivory Coast | ||||
| Kazakhstan | ||||
| Kyrgyzstan | ||||
| Laos | ||||
| Lebanon | ||||
| Malaysia | ||||
| Mali | ||||
| Mauritania | ||||
| Mauritius | ||||
| Mexico | ||||
| Mongolia | ||||
| Morocco | ||||
| Namibia | ||||
| Nicaragua | ||||
| Niger | ||||
| Papua New Guinea | ||||
| Peru | ||||
| Phillipines | ||||
| Puerto Rico | ||||
| Russian Federation | ||||
| Saudi Arabia | ||||
| Senegal | ||||
| Slovakia | ||||
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Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Solomon Islands | ||||
| Spain | ||||
| Suriname | ||||
| Swaziland | ||||
| Sweden | ||||
| Thailand | ||||
| Togo | ||||
| Turkey | ||||
| Uruguay | ||||
| United States of America | ||||
| Uzbekistan | ||||
| Zimbabwe | ||||
Tantalum:
Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Level 1 countries are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. | Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold. | Level 3 countries are defined as the DRC and its nine adjoining countries. | ||
| Australia | Mozambique | Burundi | ||
| Austria | Rwanda | |||
| Bolivia (Plurinational State of) | ||||
| Brazil | Congo, Democratic Republic of the | |||
| China | ||||
| Colombia | ||||
| Ethiopia | ||||
| Guinea | ||||
| India | ||||
| Madagascar | ||||
| Malaysia | ||||
| Nigeria | ||||
| Russian Federation | ||||
| Sierra Leone | ||||
| Thailand | ||||
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Tin:
Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Level 1 countries are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. | Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold. | Level 3 countries are defined as the DRC and its nine adjoining countries. | ||
| Australia | Burundi | |||
| Bolivia (Plurinational State of) | Rwanda | |||
| Brazil | Uganda | |||
| China | ||||
| Colombia | Congo, Democratic Republic of the | |||
| Guinea | ||||
| Indonesia | ||||
| Laos | ||||
| Malaysia | ||||
| Mongolia | ||||
| Myanmar | ||||
| Nigeria | ||||
| Peru | ||||
| Portugal | ||||
| Russian Federation | ||||
| Taiwan | ||||
| Thailand | ||||
| United Kingdom of Great Britain and Northern Ireland | ||||
| Venezuela | ||||
Tungsten:
Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Level 1 countriesare not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. | Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold. | Level 3 countries are defined as the DRC and its nine adjoining countries. | ||
| Australia | Burundi | |||
| Bolivia | Rwanda | |||
| Brazil | ||||
| China | Congo, Democratic Republic of the | |||
| Colombia | ||||
| Guinea | ||||
| Indonesia | ||||
| Laos | ||||
| Malaysia | ||||
| Mongolia | ||||
| Myanmar | ||||
| Nigeria | ||||
20
Level 1 countries: | Level 2 countries: | Level 3 countries: | ||
| Peru | ||||
| United Kingdom of Great Britain and Northern Ireland | ||||
| Russian Federation | ||||
| Taiwan | ||||
| Thailand | ||||
| United States of America | ||||
Concluding Statement
Woodward continues to make significant year-over-year progress relative to supplier conflict minerals risk analysis, SOR identification and mine COI through improvements in our due diligence activity, our greater use of the Assent Compliance platform and services, and our association memberships. In calendar year 2018, we received the greatest percent responses, number of suppliers responding, and number of part level responses since we began reporting. Also, the combined availability of RMI and LBMA audit results provided Woodward the most comprehensive mine COI data to date. However, since Woodward has not yet achieved a 100% supplier response rate, as virtually all of our supplier responses are still at a company level and not yet focused on Woodward specific parts, and because complete SOR conflict status and mine COI data is not yet available from centralized sources specializing in the collection and assessment of such data, Woodward does not have sufficiently complete or discriminating data at this time to confirm the conflict-free or may-not-be-conflict-free status of any of its product families or individual products. We have also found that significant number of our supplier respondents have supply chains using SOR categorized as high risk, and we will continue to actively address this issue to mitigate and eventually eliminate such usage. Woodward is continuing its efforts and progress in 2019-2020 on improvement actions described above.
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