Exhibit 1.01
Radware Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2018
This Conflict Minerals Report for the year ended December 31, 2018 (this "Report") has been prepared by Radware Ltd. (“Radware,” the “Company” or “we”) pursuant to Rule 13p-1 (the "Rule" or "Rule 13p-1") promulgated under the Securities Exchange Act of 1934, as amended, and Form SD thereunder.
The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, tungsten and Gold (“conflict minerals” or “3TG”).
In general, if an SEC registrant, like Radware, has reason to believe that any of the conflict minerals in its supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”) and that such conflict minerals may not be from recycled or scrap sources, 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 submit a Conflict Minerals Report to the SEC that includes a description of those due diligence measures.
This Report relates to the process undertaken for Radware's products that were manufactured or contracted to be manufactured during the calendar year 2018 and that may contain 3TG minerals that are necessary to the functionality or production of the products manufactured or to the products contracted to be manufactured.
A copy of this Report, as well as the Form SD that we filed with the SEC, are available on our website at https://www.radware.com/corporategovernance/conflictminerals.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in the Rule and Form SD as well as SEC Release No. 34-67716 issued by the SEC on August 22, 2012.
Except as set forth otherwise in this Report, Radware has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Radware’s Conflict Minerals Policy, may affect Radware’s future determinations under Rule 13p-1.
As part of Radware's Labor Practice and Human Rights Policy, Radware respects the protection of human rights, including the basic human rights of employees and workers. The Company aims to uphold the human rights of those affected by its business activities, and in particular, of the workers engaged in its supply chain. Accordingly, the Company aspires to source components and materials from suppliers that share our values regarding respect for human rights, integrity and environmental responsibility, and that comply with applicable legal standards and requirements. To that end, the Company upholds a Code of Conduct for Suppliers that addresses issues associated with mineral sourcing and/or conflict minerals. By upholding standards for its suppliers, Radware expresses its commitment to using minerals in its products that do not directly or indirectly finance armed conflict in the Covered Countries or to benefit armed groups.
1. | Overview |
Company Overview
We are a provider of cyber security and application delivery solutions that help our customers to secure the digital experience for users of business-critical applications in virtual, cloud and software defined data centers. Our solutions are deployed by, among others, enterprises, carriers and cloud service providers. We offer a set of solutions that are designed to ensure application service levels are guaranteed at all times, in any operational scenario, and to optimize business operations, minimize service delivery degradation and prevent downtime. Our solutions are offered in two main categories: products and customer services. Our products offering includes a range of physical or software-based products, product subscriptions and cloud-based subscriptions (or a combination of these) for enterprise and carrier data centers, as part of their information technology and application infrastructure. We sell our products primarily to independent distributors, including value added resellers (VARs), original equipment manufacturers (OEMs) and system integrators, whereas most of our direct sales are to strategic customers. For more information about Radware, please visit www.radware.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.
Supply Chain
We conducted an analysis of our products and found that small quantities of 3TG could potentially be found in our products.
The products that we manufacture are highly complex, typically containing thousands of parts from direct suppliers. In general, we primarily rely on third-party assembly and manufacturing vendors to provide our finished products and, in this respect, these vendors typically receive components and subassemblies included in our products from other suppliers and subcontractors.
We have relationships with a network of suppliers throughout the world and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we must rely on our direct suppliers to cooperate with us and work with their own upstream suppliers or sub-contractors so that they may provide us with accurate information regarding the origin of 3TG in the components we purchase from them and that are necessary to the production or functionality of our products. In particular, many of our supplier contracts have fixed durations, and we cannot unilaterally impose new contract terms or flow-down requirements that would otherwise compel these suppliers to support our due diligence efforts with respect to 3TG content. However, as we enter into new supply contracts or renew existing supply contracts, we seek to add, where feasible, a conflict minerals contract clause that requires the relevant supplier to provide us with information about the source of 3TG and relevant smelters and refiners. In attempting to determine the source of the 3TG content in our products, i.e. through our supply chain due diligence, we do not seek to eliminate sourcing from the Covered Countries, but rather to ensure that our suppliers are responsibly sourcing the necessary minerals in a fashion that does not fund or support the armed conflict ongoing in that region.
Reasonable Country of Origin Inquiry (RCOI)
We have determined that requesting our suppliers to complete the CMRT (as defined below) as well as following the steps described under Section 2 below (Due Diligence Process), represent our reasonable efforts to determine the mines or locations of origin of 3TG in our supply chain.
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We developed a risk-based approach (Pareto analysis) that focuses on the suppliers that represented as of December 31, 2018, in aggregate, at least 90% of our spend on the manufacturing costs of our finished products that were shipped in 2018. We identified in total five relevant suppliers (the “Relevant Suppliers”). We collected all relevant data from our network of suppliers in the form of the Responsible Minerals Initiatives' ("RMI") Conflict Minerals Reporting Template of at least version 5.01 or higher ("CMRT") in order to monitor the due diligence process and to gather and assess information from all such Relevant Suppliers.
We sent letters to our Relevant Suppliers to explain the Rule and to refer them to online training materials and instructions. We also solicited information from our Relevant Suppliers, using the most up to date CMRT.
We reviewed the responses that we received and followed up on what we perceived as inconsistent, incomplete, or inaccurate responses, as well as sent reminders to suppliers who did not respond to our requests for information. Out of the five Relevant Suppliers, all (100%) completed and returned CMRTs to us. We note, however, that for one Relevant Supplier, we accepted a CMRT version 5.0 from 2017 due to the fact that we used backlogged products and/or parts from this supplier containing the necessary conflict minerals from this time period and desired to accurately reflect the status of the mineral sourcing for those products and/or parts.
Based on these efforts, we have reason to believe that some of our products may contain conflict minerals that originated in Covered Countries and are not from recycled or scrap sources. Therefore, according to the Rule, we have engaged in the Due Diligence Process described in detail in Section 2 below. We are aware that there is significant overlap between our RCOI efforts and the due diligence measures that we performed, as noted below.
2. Due Diligence Process
2.1 Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the internationally recognized due diligence framework prescribed by the Organization for Economic Co-operation and Development ("OECD") known as "Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas" and related Supplements for Tin, Tantalum and Tungsten and for Gold (the “OECD Guidance”). We designed our due diligence measures according to the recommendations of the OECD Guidance for downstream companies that have no direct relationships to smelters or refiners as we believe that we are a “downstream” company.
2.2 Due Diligence Performed
2.2.1 Establish Strong Management Systems
Corporate Policy
We have adopted a conflict minerals policy (our "Policy" or our "Conflict Minerals Policy") that is aimed at achieving responsible sourcing. The Policy is publicly available on our website at https://www.radware.com/corporategovernance/conflictminerals.
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Internal Team
We have established a management system to support supply chain due diligence related to 3TG. Our management system includes a steering committee headed by the Company's Legal Department (the “CM Steering Committee”), and a team of subject matter functions such as supplier management, operations and legal.
Supply Chain Control Systems and Transparency
We requested that all Relevant Suppliers provide information to us regarding 3TG and relevant smelters or refiners using the CMRT.
We adopted, and communicated to our suppliers and to the public through our website and direct letters, our Policy for the sourcing of minerals originating from conflict affected and high-risk areas that are under scrutiny for human right abuses, namely from the Covered Countries as per the stipulations of the Rule.
We adopted a Supplier Code of Conduct in which we convey to our suppliers our expectation from our suppliers to engage in responsible sourcing practices, using verified sources where possible. The full text of our Supplier Code of Conduct is available on our website at https://www.radware.com/corporategovernance.
Controls also include a company-wide code of conduct that outlines expected behaviors from all our employees and the collection and analysis of all relevant data to maintain a smelter and refiner database. This database of records is compared against the list of smelters and refiners that have received 'conformant' or 'active' designation according to the RMI's independent smelter and refiner audit program, namely the Responsible Minerals Assurance Process ("RMAP").
Grievance Mechanism
Our Conflict Minerals Policy is available to the public on our website at https://www.radware.com/corporategovernance/conflictminerals and provides the contact details for reporting concerns or questions regarding the Policy or violations thereof. Suppliers and other external parties are encouraged to contact their regular sourcing channel if they wish to seek guidance on the application of this approach, or if they wish to report a grievance in relation to our Conflict Minerals Policy.
Maintaining Records
We maintain data records relating to our due diligence efforts for the five-year duration recommended by the OECD Guidance. Radware stores current and former CMRTs received from suppliers to maintain traceability and transparency.
Supplier Engagement
We maintain an electronic portal that directs suppliers to resources related to conflict minerals, including FAQs from the SEC.
We established a conflict minerals webpage to host our Conflict Minerals Policy and our conflict minerals reports along with their related Form SDs. Our webpage is hosted at https://www.radware.com/corporategovernance/conflictminerals.
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We provide guidance on the topic for relevant suppliers and engage in on-going outreach to our suppliers in order to collect, validate and archive supplier responses that relate to our conflict minerals due diligence process and supply chain inquiry.
As we enter into new supply contracts or renew existing supply contracts, we seek to add, where feasible, a conflict minerals contract clause that requires suppliers to provide us with information about the source of 3TG and relevant smelters or refiners.
2.2.2 Identify and Assess Risks in the Supply Chain
We approached our five Relevant Suppliers and received responses from all (100%) of the Relevant Suppliers as described in the RCOI. We reviewed and analyzed the respective CMRTs of our Relevant Suppliers and compared the information provided therein with the Standard Smelter List of Compliant and Active Smelters from the RMAP, a list issued by RMI that aims to identify smelters and refiners that have systems in place to assure the responsible sourcing of conflict minerals. We rely on these Relevant Suppliers, whose components contain 3TG, to provide us with information about the source of conflict minerals contained in the components supplied to us that are necessary to the production and/or to the functionality of our products. Our Relevant Suppliers are similarly reliant upon information provided by their suppliers.
2.2.3 Design and Implement a Strategy to Respond to Risks
We implemented the following strategy to address the results of our risk assessment described in Section 2.2.2 above. The goal of the design and implementation strategy is not to eliminate sourcing from the Covered Countries, but to encourage participation with the RMI and other relevant bodies, where possible:
· | The CM Steering Committee held meetings to review progress and assess the risks identified. |
· | We reviewed the responses that we received from Relevant Suppliers and followed up on what we perceived to be inconsistent, incomplete, or inaccurate responses, as well as sent reminders to Relevant Suppliers who did not respond to our requests for information. |
· | We sent, where applicable, follow up letters to unresponsive Relevant Suppliers and to Relevant Suppliers who declared they sourced conflict minerals from Covered Countries, asking them to complete their due diligence process in order to validate that all smelters in Covered Countries are compliant with RMI or other independent conflict-free smelter validation programs, such as the London Bullion Market (LBMA) or the Responsible Jewelry Council (RJC). |
· | Relevant senior management, including our Vice President and General Counsel, were briefed on our due diligence efforts, risk analysis results and mitigation efforts. |
· | We approached Relevant Suppliers that we identified as possibly sourcing from smelters or refiners located in the Covered Countries that did not receive a conformant or active designation from the RMI, and asked for a corrective action plan. |
2.2.4 Carry out Independent Third Party Audit of Smelters/Refiners Due Diligence Practices
We rely on industry-wide initiatives, such as RMI, to conduct risk assessments at the upstream level.
Since we do not have direct sourcing relationships with conflict mineral smelters or refiners, we did not perform direct audits of these entities within our supply chain.
2.2.5 Report on Supply Chain Due Diligence
Our supply chain conflict mineral due diligence efforts are described in this report. This Conflict Minerals Report is available on our website https://www.radware.com/corporategovernance/conflictminerals and is filed with the SEC.
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3. Results of Assessment
Based on information provided by our Relevant Suppliers as well as by RMI, the results of our due diligence investigation on the dates covered by this Report, are as follows:
· | We were successful in approaching all Relevant Suppliers. |
· | Out of the five Relevant Suppliers, all (100%) completed and returned the CMRTs to us. Based on the CMRTs we received from these Relevant Suppliers: |
o | 100% of the responses received provided data at the following levels. |
Category | Percentage of Responsive Relevant Suppliers |
Company level | 60% (3 out of 5 suppliers) |
User defined | 20% (1 out of 5 suppliers) |
Product list | 20% (1 out of 5 suppliers) |
Based on the information provided by the Relevant Suppliers as well as by RMI, as of the date of this Report, Radware believes that the facilities that may have been used to process the conflict minerals in Radware’s products may include the smelters and refiners listed in Annex I below.
Based on the information provided by the Relevant Suppliers as well as by RMI, as of the date of this Report, Radware believes that the countries of origin of the conflict minerals contained in its products may include the countries listed in Annex II below.
The information gathered from our Relevant Suppliers is not collected on a continuous, real-time basis.
In addition, Radware can only provide reasonable and good faith, yet not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals, since the information comes primarily from direct and secondary suppliers as well as from independent third party audit programs.
4. Future Risk Mitigation Efforts
We currently intend to continue working with our global supply chain to achieve responsible sourcing of minerals from conflict areas and comply with applicable regulations to the extent that they are required:
· | Continue implementing risk management measurement and follow up processes with regard to non-responsive or non-compliant suppliers. |
· | As described in our Conflict Minerals Policy, to the extent we have reason to believe that any of our suppliers that supply us with 3TG receive such minerals from sources that may support conflict in the DRC or the Covered Countries, we would encourage such suppliers to establish an alternative source of 3TG that does not support such conflict, as outlined in the OECD Guidance. Such methods are important to us as we are committed to discouraging human rights abuses. |
· | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
· | Continue to direct our suppliers through our website and direct communications to information and training resources to attempt to increase the response rate and improve the content of the supplier survey responses. |
· | Request suppliers to procure materials through validated smelters pursuant to the RMI or other approved resources and request suppliers to take mitigating actions in case they do not. |
· | Continue to validate supplier responses using information collected via independent conflict-free smelter validation programs, such RMI's RMAP program. |
· | Continue to engage in regular and ongoing risk assessment through our suppliers’ annual data submissions. |
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Annex I – List of Smelters and/or Refiners
Metal | Smelter Look-Up | Smelter Country |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Caridad | MEXICO |
Gold | Cendres + Métaux S.A. | SWITZERLAND |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Hunan Chenzhou Mining Industry Co. Ltd. | CHINA |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | CHINA |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Sabin Metal Corp. | UNITED STATES |
Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | So Accurate Group, Inc. | UNITED STATES |
Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Torecom | KOREA, REPUBLIC OF |
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Metal | Smelter Look-Up | Smelter Country |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Dowa | JAPAN |
Gold | Heraeus Ltd. Hong Kong | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Aurubis AG | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Boliden AB | SWEDEN |
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Metal | Smelter Look-Up | Smelter Country |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Chimet S.p.A. | ITALY |
Gold | Doduco | GERMANY |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | JCC | CHINA |
Gold | Asahi Refining USA Inc. | UNITED STATES |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor USA Refining Corporation | UNITED STATES |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO |
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 | Ohio Precious Metals, LLC | UNITED STATES |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
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Metal | Smelter Look-Up | Smelter Country |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox S.A. | SWITZERLAND |
Gold | Royal Canadian Mint | CANADA |
Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyería Platería S.A. | SPAIN |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN |
Gold | Shandong Gold Mine(Laizhou) Smelter Co., Ltd. | CHINA |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Henan Zhongyuan Gold Smelter of Zhongjin Gold Co. Ltd. | CHINA |
Gold | Zijin Mining Industry Corporation | CHINA |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Singway Technology Co., Ltd. | TAIWAN |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Lingbao Gold Co., Ltd. | CHINA |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Safimet S.p.A | ITALY |
Gold | Planta Recuperadora de Metales SpA | CHILE |
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Metal | Smelter Look-Up | Smelter Country |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
Gold | AU Traders and Refiners | SOUTH AFRICA |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Italpreziosi | ITALY |
Gold | L'Orfebre S.A. | ANDORRA |
Gold | SAAMP | FRANCE |
Gold | Marsam Metals | BRAZIL |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
Gold | Remondis Argentia B.V. | NETHERLANDS |
Gold | T.C.A S.p.A | ITALY |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES |
Gold | Geib Refining Corporation | UNITED STATES |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Morris and Watson | NEW ZEALAND |
Gold | SAFINA A.S. | CZECH REPUBLIC |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
Gold | Abington Reldan Metals, LLC | UNITED STATES |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
Gold | Sai Refinery | INDIA |
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Metal | Smelter Look-Up | Smelter Country |
Gold | Modeltech Sdn Bhd | MALAYSIA |
Gold | Bangalore Refinery | INDIA |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
Gold | Morris and Watson Gold Coast | AUSTRALIA |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
Gold | Pease & Curren | UNITED STATES |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Tony Goetz NV | BELGIUM |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA |
Gold | African Gold Refinery | UGANDA |
Gold | NH Recytech Company | KOREA, REPUBLIC OF |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tantalum | Kemet Blue Powder | UNITED STATES |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
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Metal | Smelter Look-Up | Smelter Country |
Tantalum | H.C. Starck Inc. | UNITED STATES |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | Duoluoshan | CHINA |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | LSM Brasil S.A. | BRAZIL |
Tantalum | Mineração Taboca S.A. | BRAZIL |
Tantalum | Mitsui Mining & Smelting | JAPAN |
Tantalum | Molycorp Silmet A.S. | ESTONIA |
Tantalum | Taki Chemicals | JAPAN |
Tantalum | Telex Metals | UNITED STATES |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | D Block Metals, LLC | UNITED STATES |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | Tranzact, Inc. | UNITED STATES |
Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA |
Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
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Metal | Smelter Look-Up | Smelter Country |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
Tantalum | Asaka Riken Co., Ltd. | JAPAN |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Kai Unita Trade Limited Liability Company | CHINA |
Tin | Jiangxi Nanshan | CHINA |
Tin | PT Karimun Mining | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | EM Vinto | BOLIVIA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Operaciones Metalurgical S.A. | BOLIVIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Tin | Thaisarco | THAILAND |
Tin | Yunnan Tin Company Limited | CHINA |
Tin | Metallo-Chimique N.V. | BELGIUM |
14
Metal | Smelter Look-Up | Smelter Country |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES |
Tin | Cooper Santa | BRAZIL |
Tin | CV Gita Pesona | INDONESIA |
Tin | PT Justindo | INDONESIA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | Dowa | JAPAN |
Tin | Fenix Metals | POLAND |
Tin | Yunnan Geiju Zili Metallurgy Co. Ltd. | CHINA |
Tin | GuangXi China Tin | CHINA |
Tin | Metallic Resources, Inc. | UNITED STATES |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | PT Sumber Jaya Indah | INDONESIA |
Tin | PT Tinindo Inter Nusa | INDONESIA |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | VQB Mineral and Trading Group JSC | VIETNAM |
Tin | White Solder Metalurgica | BRAZIL |
15
Metal | Smelter Look-Up | Smelter Country |
Tin | Yunnan Chengfeng | CHINA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | CV Ayi Jaya | INDONESIA |
Tin | PT Cipta Persada Mulia | INDONESIA |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
Tin | Elmet S.L.U. | SPAIN |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
Tin | PT Bangka Serumpun | INDONESIA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
Tin | PT Menara Cipta Mulia | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | PT Sukses Inti Makmur | INDONESIA |
Tin | CV Tiga Sekawan | INDONESIA |
16
Metal | Smelter Look-Up | Smelter Country |
Tin | CV Dua Sekawan | INDONESIA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | Super Ligas | BRAZIL |
Tin | PT O.M. Indonesia | INDONESIA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Gejiu Jinye Mineral Company | CHINA |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
Tin | Pongpipat Company Limited | MYANMAR |
Tin | Tin Technology & Refining | UNITED STATES |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | H.C. Starck GmbH | GERMANY |
17
Metal | Smelter Look-Up | Smelter Country |
Tungsten | ALMT Corp | JAPAN |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM |
Tungsten | Niagara Refining LLC | UNITED STATES |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
Tungsten | ACL Metais Eireli | BRAZIL |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
18
Annex II – Country of Origin Inquiry (COO)
Gold | Tantalum | Tin | Tungsten |
ANDORRA | BRAZIL | BELGIUM | AUSTRIA |
AUSTRALIA | CHINA | BOLIVIA | BRAZIL |
AUSTRIA | ESTONIA | BRAZIL | CHINA |
BELGIUM | GERMANY | CHINA | GERMANY |
BRAZIL | INDIA | INDONESIA | JAPAN |
CANADA | JAPAN | JAPAN | KOREA, REPUBLIC OF |
CHILE | KAZAKHSTAN | MALAYSIA | PHILIPPINES |
CHINA | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | MYANMAR | RUSSIAN FEDERATION |
CZECH REPUBLIC | MEXICO | PERU | UNITED STATES |
FRANCE | RUSSIAN FEDERATION | PHILIPPINES | VIETNAM |
GERMANY | THAILAND | POLAND | |
INDIA | UNITED STATES | SPAIN | |
INDONESIA | TAIWAN | ||
ITALY | THAILAND | ||
JAPAN | UNITED STATES | ||
KAZAKHSTAN | VIETNAM | ||
KOREA, REPUBLIC OF | |||
KYRGYZSTAN | |||
LITHUANIA | |||
MALAYSIA | |||
MEXICO | |||
NETHERLANDS | |||
NEW ZEALAND | |||
PHILIPPINES | |||
POLAND | |||
RUSSIAN FEDERATION | |||
SAUDI ARABIA | |||
SINGAPORE | |||
SOUTH AFRICA | |||
SPAIN | |||
SWEDEN | |||
SWITZERLAND | |||
TAIWAN | |||
THAILAND | |||
TURKEY | |||
UGANDA | |||
UNITED ARAB EMIRATES | |||
UNITED STATES | |||
UZBEKISTAN | |||
ZAMBIA |
19