Exhibit 1.01
AudioCodes Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2015
| 1. | Introduction | |
This is the Conflict Minerals Report for AudioCodes Ltd. (herein referred to as “AudioCodes,” “we,” “us” or “our”) filed with the United States Securities and Exchange Commission (“SEC”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”) for the reporting period from January 1, 2015 to December 31, 2015. The Rule was adopted by the SEC to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten and gold for the purpose of this assessment.
If a registrant can establish that the conflict minerals in its products originated from sources other than the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, the registrant must submit a specialized disclosure report under Form SD that describes the steps that the registrant took to determine the origin of the conflict minerals in its products.
If a registrant has reason to believe that any of the conflict minerals in its supply chain may have originated in a Covered Country, or if the registrant is unable to determine the country of origin of those conflict minerals, then the registrant must exercise due diligence on the conflict minerals’ source and chain of custody, and the registrant must annually submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
The report presented herein is not audited by an independent private sector auditor in reliance on recent SEC guidance to the effect that the requirement of such an audit has been stayed except if the registrant elects to describe its products as “DRC conflict-free” in its Conflicts Minerals Report.
| 2. | Company Overview |
This report has been prepared by AudioCodes. The information includes the activities of all of our majority-owned subsidiaries that are required to be consolidated.
AudioCodes designs, develops and sells advanced Voice over-IP (VoIP) and converged VoIP and data networking solutions, products and applications that facilitate secured, resilient and high quality Unified Communications (UC) and Contact Center (CC) services whether deployed on-premise or delivered from the cloud. Providing IP Phones, Customer Premise Equipment (CPE), and cloud-based platforms and applications, our solutions and products are geared to meet the growing needs of enterprises and service providers realigning their operations towards the transition to All-IP networks and hosted business services.
| 3. | Products Overview |
Our principal hardware product lines are essentially classified into the following categories: session border controllers, media gateways, multi-service business routers, IP phones, survivable branch appliances, call recorders, fax servers and SOHO routers.
| 4. | Supply Chain Overview |
Because our supply chain is complex, AudioCodes relies upon our suppliers to provide information with respect to the origin of the conflict minerals contained in components and materials supplied to us, including sources of conflict minerals that are supplied to them from sub-tier suppliers. Our suppliers are expected to provide conflict minerals sourcing information to us pursuant to our Conflict Minerals Policy.
We have performed a comprehensive analysis of the components used in our products, and the role that suppliers play throughout our manufacturing and product delivery processes. We defined the scope of our conflict minerals due diligence by identifying and contacting our current suppliers that provide components or engage in manufacturing activities that are likely to contain conflict minerals. We adopted the standard Conflict Mineral Reporting Templates (“CMRT”) established by the Conflict Free Sourcing Initiative (“CFSI”), and sent our conflict minerals due diligence communication survey to these suppliers.
With respect to the Organisation for Economic Cooperation and Development (“OECD”) requirement to strengthen engagement with suppliers, we have engaged a third party data collection vendor to conduct, collect and archive suppliers’ responses. Feedback from this engagement has allowed us to render the conclusions and statements in this report.
| 5. | Reasonable Country of Origin Inquiry (“RCOI”) and RCOI conclusion | |
| 5.1 | We conducted an analysis of our products and found that “conflict minerals”, as defined under the Rule (including tin, tantalum, tungsten and gold) can be found in our products and are necessary to the functionality or production of those products. Therefore, we are subject to the reporting obligations of the Rule. |
| 5.2 | A list of all the suppliers and manufacturers AudioCodes contracts with to purchase all the items constructing its products was prepared by the Purchasing Department. The list was then reviewed and non-relevant suppliers and manufacturers were deleted (suppliers/manufacturers of items which definitely do not contain tin, tantalum, tungsten or gold).The final list was evaluated by Purchasing Director and Director of Quality Assurance, Environment & Safety. |
| 5.3 | Due to the breadth and complexity of AudioCodes’ products and supply chain, it will take time for many of our suppliers to verify the origin of all conflict minerals. Using our supply chain due diligence processes and efforts, we hope to further develop transparency into our supply chain. |
| 5.4 | Steps conducted this year include: | |
| a. | Performed internal applicability assessments of products and suppliers to determine which contain or may contain necessary conflict minerals. |
| b. | Supplier engagement: |
| § | Solicitation of survey responses from relevant suppliers. |
| § | Assessment of suppliers responses - identify inconsistent, incomplete, or inaccurate responses. |
| § | Engaging Purchasing Department to directly contact and push non-responsive suppliers. |
| § | As part of our validation process, we sent training materials to suppliers, including an overview of the law and instructions on how to complete the Conflict Minerals Reporting Template, if relevant. | |
| c. | As part of our effort to identify smelters and refiners, suppliers were requested to fill CMRTs template of version 4.0 or above. |
| 5.5 | Currently, we do not have sufficient information from our suppliers to determine the country of origin of the conflict minerals used in our products or the facilities used to process those conflict minerals. Therefore, we cannot exclude the possibility that some of these conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources. Based on this result, AudioCodes conducted due diligence activities and have described these activities in this Conflict Minerals Report. |
| 6. | Due Diligence Design |
| 6.1 | Our due diligence processes and efforts have been developed in conjunction with the OECDDue Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten. |
| 7. | Due Diligence Performed |
| 7.1 | Establish Strong Company Management Systems | |
| 7.1.1 | Conflict Minerals Policy |
AudioCodes is committed to working with our global supply chain to ensure compliance with the SEC’s conflict minerals rules. Our conflict minerals policy is publicly available on our website at http://www.audiocodes.com/sustainability under the heading "Conflict Minerals”.
| 7.1.2 | Internal Team |
AudioCodes has established a task force with representatives from our Legal, Finance, Purchasing and Quality departments to implement our conflict minerals compliance policy. Senior management is briefed about the results of our due diligence efforts on a regular basis.
| 7.1.3 | Control Systems |
AudioCodes has established our due diligence compliance process and set forth documentation and record maintenance mechanisms to ensure the retention of relevant documentation in a structured electronic database. Database content enables real-time identification of all countries of origin of the minerals as well as the smelters/refiners status. Since our databases are continuously backed up, this data retention assures availability with no time limitation.
AudioCodes’ level CMRT are amended on a monthly basis, as our sub-contractor collects new and/or corrected suppliers’ reports. AudioCodes makes its latest company level CMRT available to its customers upon request.
| 7.1.4 | Supplier Engagement |
AudioCodes amended itsRequirements from AudioCodes’ Suppliers Process Specification (P-08-03E) to include a paragraph detailing our mandatory requirement to comply with the Rule and to strictly follow the framework established by the OECD. This Process Specification is referenced in each Purchase Order issued to our suppliers, and is also available in AudioCodes’ website.
| 7.1.5 | Grievance Mechanism |
Grievance mechanism & reporting are defined in the company Policy.
| 7.2 | Identify and Assess Risk in the Supply Chain |
| 7.2.1 | AudioCodes' risk analysis efforts address the information assessed within the risk analysis tool. For example: while trying to move towards the goal of being a conflict minerals free company, we assessed two primary risks in our supply chain: (1) the risk of not receiving on time accurate information from the supplier; and (2) the risk of not being able to replace a supplier. The result was the segmentation of the suppliers into 3 levels of risks: high, medium and low, allowing the Company to focus its risk mitigation efforts according to the supplier level of risk. |
| 7.2.2 | Segmenting our suppliers based on the above risk levels yielded 7.3% of high risk suppliers. Our sub-contractor was consequently instructed to give highest priority to those suppliers in his data collection activity. |
| 7.2.3 | A risk assessment matrix was developed to further define the risk of each CMRT received, based on its content and completeness. This tool enabled us to engage Purchasing Department to urge and push reluctant suppliers and to focus our escalation efforts. |
| 7.2.4 | To the best of our efforts, we have identified most of the smelters/refineries in our supply chain. |
| 7.3 | Design and Implement Strategy to Respond to Risks |
| 7.3.1 | Suppliers are requested to supply their conflict minerals compliance declarations using the CMRT template. Such declarations are reviewed by AudioCodes (or its assigned sub-contractor) and verified for completeness and inconsistency. |
| 7.3.2 | Any declaration determined to be inconsistent or missing data is returned to the supplier to correct and complete. |
| 7.3.3 | Under this activity we also track smelters/refiners that have not received a conflict-free designation based on the CFSI/CFSP or other independent third party validation program, and also compare smelters/refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation. |
| 7.3.4 | Red Flags analysis on the topics listed below were defined to better identify suspicious behavior and activities: |
| a. | Data completion |
| b. | Locations of mineral origin |
| c. | Existence of Company Policy |
| 7.3.5 | Escalation policy was documented and implemented which defines how to handle non-responsive and problematic suppliers. The Policy defines the conditions under which Purchasing will consider suspending or discontinuing engagement with such suppliers. | |
| 7.3.6 | Management was informed of the risk analysis efforts and results, as well as of the actions taken consequently. |
| 7.4 | Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Point in the Supply Chain |
| 7.4.1 | AudioCodes does not have a direct relationship with smelters and refiners of conflict minerals, nor do we perform direct audits of these entities that provide our supply chain with conflict minerals. However, we do rely upon the industry efforts and tools (for example, the CFSI Conflict Minerals Reporting Template) in our evaluations. |
| 7.5 | Report Annually on Supply Chain Due Diligence |
| 7.5.1 | AudioCodes’ CMRT is amended on a monthly basis and is available to all requestors. The company’s annual Conflict Minerals Report is downloadable from AudioCodes’ website, at http://www.audiocodes.com/sustainability under the heading "Conflict Minerals”, and filed with the SEC on Form SD. |
| 8. | Results of Assessments |
| 8.1 | Survey Responses |
| 8.1.1 | Because of our size, the breadth and complexity of our products, and constant changes to our supply chain, it is difficult to identify entities downstream from our direct suppliers. We are relying on our direct suppliers to provide us with information about the source of conflict minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. |
| 8.1.2 | Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, a few suppliers were unable to accurately report which specific smelters were part of the supply chain of the components that were sold to AudioCodes in 2015. Therefore, we are not able to determine the facilities that processed the conflict minerals in such products. |
| 8.1.3 | We received responses from more than 80% of the suppliers surveyed. We reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the Template. We are working directly with these suppliers to have them provide revised responses. |
| 8.1.4 | Most CMRTs were reported at the company level, see table below. | |
| Declaration Scopes of Delivered Consolidated Manufacturers | |
| Reported at company level | 86% |
| Reported user defined | 7% |
| Reported product list/product | 8% |
| 8.1.5 | As of today, the 80% responses received from our suppliers can be further categorized as in the table below. CMRTs with major issues are CMRTs with significant incompleteness, inaccuracy, or contradictory information submitted. For example, tantalum, tin, gold, or tungsten was declared used but no smelters were entered for these metals. |
| Consolidated Manufacturers Sub-Collection Status | |
| MFRs delivered satisfactory CMRT | 27% |
| MFRs delivered CMRT with major issues | 57% |
| MFRs whose CMRT was escalated* | 7% |
| MFRs still in process | 9% |
| * | MFR with at least one or multiple escalations (no major issues). Escalated by the subcontractor to AudioCodes to supply better/correct contact information, to contact the manufacturer directly or otherwise, due to manufacturer’s poor responsiveness. |
| 8.1.6 | The smelters analysis of those above 80% responsive manufacturers is given below. The list of smelters is set forth in the attached Appendix A. The list of mines’ countries of origin is set forth in the attached Appendix B. |
| Smelters Analysis | |
| With certification | |
| Certified smelters - CFSP/RJC/LBMA/DMCC (a) | 67% |
| Non-certified smelters - CFSP/RJC/LBMA/DMCC (a)(b) | 33% |
| Legitimacy of smelters (out of the total number of smelters analyzed) | |
Number of alleged smelters- FSI/RJC/LBMA/DMCC/DOC/APPLE/INTEL/GS (a) | 94% |
| Unknown smelters | 6% |
| (a) | Initials of credible sources for conflict minerals information (organizations or company names). |
| (b) | Out of the 33% non-certified smelters, 35% are smelters in the Active list of CFSI (committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs). |
| 8.1.7 | Based on the information obtained through the due diligence process, AudioCodes does not have sufficient information as yet to determine the country of origin of all the conflict minerals contained in our products. |
| 8.1.8 | The large majority of the responses received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used for components supplied to AudioCodes. We are therefore unable to determine whether any of the conflict minerals reported by the suppliers were contained in components or parts supplied to us or to validate that any of these smelters or refiners are actually in our supply chain. |
| 8.1.9 | Information gathered from our suppliers is not on a continuous, real-time basis, (since according to the Rule a product would “not be found to be DRC conflict free” if it does not meet the required standard for even one day of the reporting year). |
| 8.1.10 | The Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information comes from: direct and secondary suppliers and independent third party audit programs. |
| 8.2 | Efforts to Determine Country of Origin of Mine or Conflict Minerals |
| 8.2.1 | Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting a methodology based on the OECD guidelines and the CFSI template, we have determined that the information we gathered from the smelters and refiners in our supply chain represents the most reasonable known mine of origin information available to us. |
| 9. | Continuous Improvement Efforts to Mitigate Risks |
| 9.1 | AudioCodes will engage with suppliers who may be sourcing from non-conflict free smelters to move towards using conflict free smelters within a reasonable time frame. The time frame will be dependent on the criticality of the specific component and the availability of alternative suppliers. |
| 9.2 | AudioCodes will continue implementing risk mitigation actions such as: follow up letters to high risk non responsive suppliers; and follow up letters to suppliers with conflict minerals from the Covered Countries from non-certified smelters. |
| 9.3 | AudioCodes will require suppliers to report their status using the latest CMRT revision and updated smelters list. |
| 10. | Cautionary Statement Concerning Forward-Looking Statements |
This Report contains “forward-looking statements” within the meaning of U.S. federal securities laws. These forward-looking statements can generally be identified as such because the context of the statement will include words such as “may”, “will,” “intends,” “plans,” “believes,” “anticipates,” “expects,” “estimates,” “predicts,” “potential,” “continue,” or “opportunity,” the negative of these words or words of similar import. Examples of forward-looking statements include statements relating to our future plans, and any other statement that does not directly relate to any historical or current fact. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. Forward-looking statements are subject to risks, uncertainties and other factors that could cause actual results to differ materially from those stated in such statements. As a result, these statements speak only as of the date they are made and we undertake no obligation to update or revise any forward-looking statement, except as required by U.S. federal securities laws.
Appendix A: Smelters list
1. Gold
| Metal | Smelter Name | Smelter country |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold- und Silberscheideanstalt A.G. | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Asahi Refining Canada Limited | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AURA-II | UNITED STATES |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Bauer Walser AG | GERMANY |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA |
| Gold | Cendres + Métaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | China Tin Group Co., Ltd. | CHINA |
| Gold | Chugai Mining | JAPAN |
| Gold | Colt Refining | UNITED STATES |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | DODUCO GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Faggi Enrico S.p.A. | ITALY |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | Geib Refining Corporation | UNITED STATES |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Ltd Hong Kong | HONG KONG |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | Ishifuku Metal Industry Co . Ltd | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Gold | Johnson Matthey Inc | UNITED STATES |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd | JAPAN |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | Kojima Chemical Co., Ltd. | JAPAN |
| Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Company Limited | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Smelting Co. Ltd | CHINA |
| Gold | Materion | UNITED STATES |
| Gold | Matsuda Sangyo Co. Ltd | JAPAN |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Gold | Metalor Technologies (Hong Kong) | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MMTC-PAMP India Pvt. Ltd | INDIA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohio Precious Metals | UNITED STATES |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Penglai Penggang Gold Industry Co Ltd | CHINA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Précinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Remondis Argentia B.V. | NETHERLANDS |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
| Gold | Sanmenxia Lingbao Jinyuan Mining Co., Ltd. | CHINA |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN |
| Gold | Shandong Guoda gold 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 | Singway Technology Co., Ltd. | TAIWAN |
| Gold | So Accurate Group, Inc. | UNITED STATES |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Co. | TAIWAN |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | Sumitomo Metal Mining Co. Ltd. | JAPAN |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling nonferrous Metals Group Co.,Ltd | CHINA |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Valcambi S.A. | SWITZERLAND |
| Gold | Western Australian Mint | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Yunnan Copper Industry Co Ltd | CHINA |
| Gold | Zhejiang Suijin | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
2. Tantalum
| Metal | Smelter Name | Smelter country |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | E.S.R. Electronics | UNITED STATES |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co, Ltd | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metal do | JAPAN |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Tantalite Resources | SOUTH AFRICA |
| Tantalum | Telex Metals | UNITED STATES |
| Tantalum | Tranzact, Inc. | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | Zhuzhou Cemented Carbide | CHINA |
3. Tin
| Metal | Smelter Name | Smelter country |
| Tin | Alpha | UNITED STATES |
| Tin | An Thai Minerals Company Limited | VIET NAM |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | CNMC (Guangxi) PGMA Co. Ltd | CHINA |
| Tin | Cookson | UNITED STATES |
| Tin | Cooper Santa | BRAZIL |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Dua Sekawan | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
| Tin | EM Vinto | BOLIVIA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Guangxi Crystal Union Photoelectric Materials CO.,LTD | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Linwu Xianggui Mineral Smelting Co.,Ltd | CHINA |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA |
| Tin | Liuzhou China Tin | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Material Corporation | JAPAN |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| Tin | O. M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | OMSA | BOLIVIA |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | PHONON MEIWA INC. | JAPAN |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Donna Kembara Jaya | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Fang Di MulTindo | INDONESIA |
| Tin | PT HANJAYA PERKASA METALS | INDONESIA |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | PT Justindo | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Seirama Tin Investment | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Tambang Timah | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Tin | PT. DS Jaya Abadi | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda | BRAZIL |
| Tin | RT Refined Banka Tin | INDONESIA |
| Tin | Rui Da Hung | TAIWAN |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-Ferrous Metals Co Ltd | CHINA |
| Tin | Yunnan Tin Company, Ltd. | CHINA |
| Tin | Yunnan Tin Group (Holding) Co., Ltd. | CHINA |
4. Tungsten
| Metal | Smelter Name | Smelter country |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | ATI Tungsten Materials | UNITED STATES |
| Tungsten | Chenzhou Diamond Tungsten Products Co,. Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.? | CHINA |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
| Tungsten | Ganzhou Grand Sea W & Mo Group Co Ltd | CHINA |
| Tungsten | Ganzhou Huaxin Tungsten Products Ltd | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Niagara Refining LLC | UNITED STATES |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | CHINA |
Appendix B: Mines Country of Origin
| Australia |
| Belgium |
| Bolivia |
| Brazil |
| Canada |
| China |
| Ethiopia |
| Germany |
| Hong Kong |
| India |
| Indonesia |
| Japan |
| Kazakhstan |
| Korea, Republic of |
| Malaysia |
| Mozambique |
| Namibia |
| Nigeria |
| Peru |
| Poland |
| Portugal |
| Russia |
| Rwanda |
| Sierra Leone |
| South Africa |
| South Korea |
| Spain |
| Switzerland |
| Taiwan |
| Thailand |
| United States |
| Uzbekistan |
| Zimbabwe |
