Exhibit 1.01
Conflict Minerals Report of Materion Corporation
for the Reporting Period from January 1, 2017 to December 31, 2017
Overview
This Conflict Minerals Report (this “Report”) of Materion Corporation (including its consolidated subsidiaries, “we”, “Materion” or the “Company”) has been prepared pursuant to Rule 13p-1 (the “Rule”) as promulgated under the Securities Exchange Act of 1934 for the reporting period from January 1, 2017 to December 31, 2017 (the “Reporting Period”).
Forward-looking statements contained in this Report are made based on known events and circumstances at the time of release, and as such, are subject in the future to unforeseen uncertainties and risks. Statements in this Report which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements related to the Company’s compliance efforts and expected actions identified in this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other matters, the Company’s customers' requirements to use certain suppliers, the Company’s suppliers' responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to implement improvements in its conflict minerals program and the Company’s ability to identify and mitigate related risks in its supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see the Company’s other filings with the Securities and Exchange Commission (“SEC”), including its Annual Report on Form 10-K for the year ended December 31, 2017 and subsequent Quarterly Reports on Form 10-Q. The Company makes these statements as of the date of this disclosure, and undertakes no obligation to update them unless otherwise required by law.
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. The SEC defines “conflict minerals” as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold and (d) wolframite (the metal ore from which tungsten is extracted), 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 such term is defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (collectively, the “Covered Countries”).
The Company’s operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the “products”). As required by the Rule, the Company has conducted a good faith, reasonable country of origin inquiry (“RCOI”) regarding the
conflict minerals included in the products during the Reporting Period to determine whether any such conflict minerals originated in the Covered Countries and/or whether any of the conflict minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence regarding the sources of the conflict minerals. The results of the Company’s RCOI regarding the conflict minerals, as well as the Company’s additional due diligence regarding the sources of such conflict minerals, are contained in this Report, which is publicly available at www.materion.com. The content on, or accessible through, any web site referred to in this Report is not incorporated by reference into this Report unless expressly noted.
Materion, through its wholly owned subsidiaries, is an integrated producer of high-performance advanced engineered materials used in a variety of electrical, electronic, thermal and structural applications. Our products are sold into numerous end markets, including consumer electronics, industrial components, defense, medical, automotive electronics, telecommunications infrastructure, energy, commercial aerospace, science, services, and appliance.
Our businesses are organized under four reportable segments: Performance Alloys and Composites, Advanced Materials, Precision Coatings, and Other. Our Other reportable segment includes unallocated corporate costs.
Performance Alloys and Composites
The Performance Alloys and Composites ("PAC") segment is comprised of the following three reporting units: Performance Alloys, Beryllium & Composites, and Technical Materials.
Performance Alloys is the largest PAC business and produces beryllium and non-beryllium containing alloy products in strip, bulk, and other custom shapes at manufacturing facilities in the United States, Europe, and Asia. This business also operates the world's largest bertrandite ore mine and refinery, which is located in Utah, providing feedstock hydroxide for its beryllium and beryllium alloy businesses and external sales.
Beryllium & Composites manufactures beryllium, beryllium aluminum, aluminum metal matrix composites, beryllia ceramics, and bulk metallic glass materials in rod, plate, bar, strip, and customized shapes.
Technical Materials produces strip metal products with clad inlay and overlay metals, including precious and base metals electroplated systems, electron beam welded systems, contour profiled systems and solder-coated metal systems.
Advanced Materials
Advanced Materials produces advanced chemicals, microelectronics packaging, precious metal, non-precious metal and specialty metal products, including vapor deposition targets, frame lid assemblies, clad and precious metal pre-forms, high temperature braze materials, and ultra-pure wire. These products are used in semiconductor logic and
memory, medical, energy, lighting, defense, optics and wireless communications applications within the consumer electronics, industrial components, and telecommunications infrastructure end markets. Advanced Materials also has metal recovery operations and in-house refining that allow for the recycling of precious metals.
Precision Coatings
The Precision Coatings segment includes the following reporting units:
Precision Optics produces sputter-coated precision thin film coatings and optical filter materials. Based in Westford, Massachusetts, the group has manufacturing facilities in the United States and China.
Large Area Coatings produces high-performance sputter-coated precision flexible thin film materials. Based in Windsor, Connecticut, the business manufactures and distributes coated and converted thin film material solutions primarily for medical testing and diagnosis applications.
Other
The Other segment is comprised of unallocated corporate costs.
Description of Materion's Reasonable Country of Origin Inquiry
Materion has performed a good faith RCOI regarding the conflict minerals that were in our supply chain between January 1, 2017 and December 31, 2017 to determine whether any of the conflict minerals originated in the Covered Countries and whether any of the conflict minerals may be from recycled or scrap sources, in accordance with the Rule and related guidance provided by the SEC.
The Company’s global supply chain is complex. In the course of its business operations, the Company may purchase materials and metals containing conflict minerals. These materials and metals may, in turn, be included in the Company’s products. Because the Company does not normally purchase conflict minerals directly from mines, smelters or refiners, there are many third parties in the supply chain between the Company and the original sources of conflict minerals. As a result, the Company relies on its direct suppliers to provide information regarding the origin of any conflict minerals that are included in its products. In accordance with the framework in the Organization for Economic Co-operation and Development Due Diligence Guidelines for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidelines”), and related guidance provided by the SEC, the Company worked with its direct suppliers to identify, where possible, the smelters and/or refiners and countries of origin of the conflict minerals.
Prior to the Reporting Period, the Company worked to identify direct materials suppliers that it believed could potentially provide materials or metals containing conflict minerals (collectively, the “Identified Suppliers”). The Company then surveyed all the Identified Suppliers to determine whether each such Identified Supplier was supplying materials or metals to the Company that contained conflict minerals and, if so, to determine the source of such conflict minerals. The Company’s surveys required Identified Suppliers to, among other matters, confirm the source of any conflict minerals contained in materials or metals supplied to the Company and to provide any updates regarding such responses.
The Company, with respect to the Reporting Period, reasonably determined that certain of its products described above under “Overview” contain conflict minerals necessary to the functionality or production of such products.
For the Reporting Period, the Company sought and obtained representations from all 55 Identified Suppliers from whom the Company sought such representations. Such representations included, from all Identified Suppliers, Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”) indicating the facility at which the conflict minerals were processed.
Based on the information obtained pursuant to the RCOI process described above, the Company has concluded, in good faith, that it does not have sufficient information with respect to the Reporting Period to determine the country of origin of all of the conflict minerals.
Due Diligence
For the Reporting Period, Materion performed due diligence from September 2017 through May 2018 to determine the source and chain of custody necessary to determine conflict minerals in the Company’s product offerings. Materion designed its due diligence measures to conform in all material respects with the OECD Guidelines. This process included building conflict minerals awareness across the supply base and the survey of all Identified Suppliers that were known to or may have provided products containing metal and /or conflict minerals.
Materion occupies a “downstream” position in the supply chain and followed the principles outlined in the OECD Guidelines for downstream companies with no direct relationships to smelters or refiners. In this context, “downstream” refers to the supply chain from smelters and refiners to retailers and includes companies such as ours, as well as product and component manufacturers and retailers. A summary of Materion’s due diligence activities in line with the OECD Guidelines is outlined below.
Step 1: Establish strong company management systems:
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| • | Materion has adopted a formal policy that reflects its goal of achieving a "DRC Conflict Free" determination over time; |
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| • | Materion maintains a governance model to oversee the implementation and ongoing management of the Conflict Minerals Compliance Program. The governance model consists of two groups: the Steering Committee and Core Team, and various work products. The objective is to develop, document and maintain a governance structure that enables sustainable compliance and actively mitigates the risk of not meeting regulatory requirements; |
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| • | Materion maintains a process to evaluate raw materials, parts and suppliers in the supply chain for potential conflict minerals risk; |
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| • | Materion communicates its policy regarding conflict minerals to existing and new suppliers including through language in supplier contract terms and conditions, flow down language in all United States Government contracts and the Materion Supplier Code of Conduct; |
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| • | Materion continues to leverage SAP systematic and Quality Management procedural controls to prevent transactions with non-conforming conflict mineral suppliers; |
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| • | Materion has established long-term relationships with suppliers and closely manages the pool of suppliers eligible to be utilized; and, |
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| • | Materion provides a feedback mechanism on its website available to all interested parties to provide information or voice their concerns regarding its sourcing and use of conflict minerals in its products. |
Step 2: Identify and assess risks in the supply chain:
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| • | On an annual basis, Materion evaluates raw materials and parts that are known or are likely to contain conflict minerals using a risk-based approach; |
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| • | Each compliance year, Materion requires suppliers to complete a CMRT. Materion has a 100% response rate for three consecutive years; |
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| • | Materion engages Identified Suppliers in one-on-one individualized capability training to all identified suppliers to enable them to improve their understanding of the regulation and their responsibility as a Materion supplier; |
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| • | Materion conducts a review of supplier responses to determine that all required questions and sections of the CMRT were completed, followed up with any supplier that did not complete all required questions, and verified the CMRT had an acceptable Effective Date and appropriate CMRT version; |
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| • | Materion reviews the survey responses and validates them for completeness and sufficiency; |
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| • | Materion reviews aggregated supplier survey responses and reports key metrics as part of the monthly conflict minerals reporting process; and, |
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| • | Materion conducts an annual review of summary smelter information to determine if the smelter is certified as conflict free or presented a "red flag" as defined by the OECD Guidelines. To make the determination of each smelter's conflict status, Materion relies upon information provided by the RMI. RMI conducts a Responsible Minerals Assurance Process (RMAP), in which it certifies smelters and refiners worldwide as being conformant/conflict free after confirming specific information, including country of origin for conflict |
minerals that the smelter/refiner may purchase for its operations. RMI makes available to the public the list of smelters/refiners that have been certified by RMI as conformant/conflict free.
Step 3: Design and implement a strategy to respond to identified risks:
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| • | Annually, Materion completes an OECD Gap Analysis, at the end of each compliance year's due diligence, and provides a summary of the identified risks and gaps to the Steering Committee with recommended action plans to reduce risks and close gaps; |
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| • | Materion maintains a risk mitigation strategy with the goal of systematically reducing the extend of exposure to certain risk and the likelihood of its occurrence; |
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| • | Materion maintains a risk mitigation plan and monitors execution. New supplier onboarding includes requirements for all suppliers to provide a current CMRT and an agreement to respond to annual conflict minerals surveys; |
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| • | Materion continues to systematically and procedurally limit purchasing with suppliers based on their unresponsiveness to conflict minerals inquiries; |
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| • | Materion places additional restrictions on smelter sources based on non-conflict mineral related customer requirements; and, |
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| • | Additional fact finding, risk assessments and changes in circumstances take place as part of Materion's annual review of its Conflict Minerals Compliance Playbook. |
Step 4: Carry out independent third-party audit of smelter/refiner's due diligence practices:
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| • | In accordance with the OECD Guidelines, Materion participates and contributes through industry organizations to enhance transparency and traceability in the supply chain and supports independent third-party audits of smelters/refiners; and, |
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| • | Materion is not in a position to audit smelter/refiners directly. Materion does, however, reach out to smelters, identified by their suppliers, to request that they participate in the RMI initiative and become certified as Conformant/Conflict-Free and Materion’s gold recycling operation in Buffalo, New York is a RMI certified Conformant/Conflict Free for gold. |
Step 5: Report annually on supply chain due diligence:
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| • | Annually, Materion performs due diligence in their conflict minerals supply chain, maintains a process to summarize, review and approve compliance results, complete the Form SD and the Conflict Minerals Report and timely file the Form SD and any Conflict Minerals Report with the SEC. |
Continuous Improvement of Supply Chain Due Diligence
The Company expects to continue to maintain its supply chain due diligence efforts including:
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| • | Continue to assess the presence of conflict minerals in its supply chain as new products are introduced; |
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| • | Continue to require suppliers to identify the conflict minerals contained in the products they supply and when requested on an annual basis, to provide current, accurate and complete information on the smelters/refiners used in the manufacture of materials supplied to Materion; |
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| • | Continue to compare RCOI results to information collected via independent conflict free smelter validation programs such as the RMAP; |
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| • | Continue to contact smelters identified as a result of the RCOI process and request their participation in obtaining a "conformant/conflict free" designation from an industry program such as the RMAP; and |
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| • | Ability to respond to customer requests to limit smelters active in the supply chain due to non RMI concerns. |
Determination
Based on the process described above, Materion achieved a 100% response rate from the 57 direct material suppliers identified as supplying raw materials or parts containing conflict minerals with an increase in smelters reporting conflict-free from 90% to 91%.
Base on the information provided by Materion suppliers utilized during 2017, Materion believes that the facilities that may have been used to process conflict minerals in Materion’s products included the smelters and refiners lists in Appendix I. The suppliers’ responses included Conformant/Conflict Free, Known and Unknown smelters, but based on the absence of reliable information on the Unknown smelters, only the Conformant/Conflict Free Active and Known smelters have been included.
Based on the due diligence efforts and the absence of full supply chain visibility throughout the supply base, Materion is unable to determine the origin of the conflict minerals and does not have sufficient information to conclusively determine the countries of origin of conflict minerals contained in Materion’s products.
Appendix I: Smelters Identified in the Materion Supply Chain
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| Smelter ID | Metal | Smelter Name | Smelter Country | CFSI Verified |
| CID000015 | Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| CID000019 | Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| CID000035 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
| CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| CID000077 | Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| CID000082 | Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| CID000924 | Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| CID000920 | Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| CID000090 | Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| CID000113 | Gold | Aurubis AG | GERMANY | Conformant |
| CID000128 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| CID000157 | Gold | Boliden AB | SWEDEN | Conformant |
| CID000176 | Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| CID000233 | Gold | Chimet S.p.A. | ITALY | Conformant |
| CID002224 | Gold | China Henan Zhongyuan Gold Smelter | CHINA | Conformant |
| CID000401 | Gold | Dowa | JAPAN | Conformant |
| CID000425 | Gold | Eco-System Recycling Co., Ltd. | JAPAN | Conformant |
| CID001322 | Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | Known |
| CID002459 | Gold | Geib Refining Corporation | UNITED STATES | Conformant |
| CID000694 | Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| CID000707 | Gold | Heraeus Ltd. Hong Kong | CHINA | Conformant |
| CID000711 | Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
| CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| CID000814 | Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| CID000969 | Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| CID000981 | Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| CID001078 | Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| CID001113 | Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| CID001119 | Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| CID001149 | Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| CID001152 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| CID001153 | Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| CID001157 | Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
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| CID001161 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| CID001188 | Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| CID001259 | Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| CID001352 | Gold | PAMP S.A. | SWITZERLAND | Conformant |
| CID001512 | Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| CID002510 | Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Conformant |
| CID001534 | Gold | Royal Canadian Mint | CANADA | Conformant |
| CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| CID001761 | Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
| CID001916 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
| CID001938 | Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| CID001977 | Gold | Umicore Brasil Ltda. | BRAZIL | Conformant |
| CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| CID001993 | Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002003 | Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| CID002100 | Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Conformant |
| CID002129 | Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| CID000291 | Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Conformant |
| CID000456 | Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Conformant |
| CID000460 | Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| CID002558 | Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| CID002544 | Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
| CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| CID002548 | Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002549 | Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
| CID002550 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| CID002545 | Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
| CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
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| CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| CID000917 | Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | Conformant |
| CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID002539 | Tantalum | KEMET Blue Metals | MEXICO | Conformant |
| CID002568 | Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Conformant |
| CID000973 | Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Conformant |
| CID001076 | Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
| CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| CID001175 | Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| CID001200 | Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| CID001508 | Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| CID002707 | Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| CID001522 | Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| CID001769 | Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
| CID001869 | Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| CID001891 | Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| CID001969 | Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| CID002508 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| CID002307 | Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Conformant |
| CID002232 | Tantalum | Zhuzhou Cemented Carbide Group | CHINA | Known |
| CID000292 | Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| CID002703 | Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Known |
| CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Active |
| CID001070 | Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| CID000278 | Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Known |
| CID002570 | Tin | CV Ayi Jaya | INDONESIA | Conformant |
| CID002592 | Tin | CV Dua Sekawan | INDONESIA | Conformant |
| CID000306 | Tin | CV Gita Pesona | INDONESIA | Conformant |
| CID000313 | Tin | CV Serumpun Sebalai | INDONESIA | Known |
| CID002593 | Tin | CV Tiga Sekawan | INDONESIA | Conformant |
| CID000315 | Tin | CV United Smelting | INDONESIA | Conformant |
| CID002455 | Tin | CV Venus Inti Perkasa | INDONESIA | Conformant |
| CID000402 | Tin | Dowa | JAPAN | Conformant |
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| CID002572 | Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Known |
| CID002774 | Tin | Elmet S.L.U. | SPAIN | Conformant |
| CID000438 | Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| CID000448 | Tin | Estanho de Rondonia S.A. | BRAZIL | Known |
| CID000468 | Tin | Fenix Metals | POLAND | Conformant |
| CID002848 | Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Conformant |
| CID002859 | Tin | Gejiu Jinye Mineral Company | CHINA | Conformant |
| CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Conformant |
| CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
| CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Known |
| CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| CID002849 | Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Conformant |
| CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Undertaking Corrective Action |
| CID000760 | Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Conformant |
| CID001482 | Tin | INDONESIAN STATE TIN CORPORATION MENTOK SMELTER | INDONESIA | Conformant |
| CID000244 | Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Conformant |
| CID002468 | Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| CID001105 | Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| CID002500 | Tin | Melt Metais e Ligas S.A. | BRAZIL | Conformant |
| CID001142 | Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| CID002773 | Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| CID001173 | Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| CID001182 | Tin | Minsur | PERU | Conformant |
| CID001191 | Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| CID002858 | Tin | Modeltech Sdn Bhd | MALAYSIA | Active |
| CID001231 | Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active |
| CID002573 | Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Known |
| CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| CID001337 | Tin | OMSA | BOLIVIA | Conformant |
| CID003208 | Tin | Pongpipat Company Limited | MYANMAR | Known |
|
| | | | |
| CID000309 | Tin | PT Aries Kencana Sejahtera | INDONESIA | Conformant |
| CID001399 | Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| CID002503 | Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| CID001402 | Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
| CID002776 | Tin | PT Bangka Prima Tin | INDONESIA | Conformant |
| CID003205 | Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| CID001419 | Tin | PT Bangka Tin Industry | INDONESIA | Conformant |
| CID001421 | Tin | PT Belitung Industri Sejahtera | INDONESIA | Conformant |
| CID001428 | Tin | PT Bukit Timah | INDONESIA | Conformant |
| CID001434 | Tin | PT DS Jaya Abadi | INDONESIA | Conformant |
| CID001438 | Tin | PT Eunindo Usaha Mandiri | INDONESIA | Conformant |
| CID002530 | Tin | PT Inti Stania Prima | INDONESIA | Conformant |
| CID001448 | Tin | PT Karimun Mining | INDONESIA | Conformant |
| CID002829 | Tin | PT Kijang Jaya Mandiri | INDONESIA | Conformant |
| CID002870 | Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Conformant |
| CID002835 | Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| CID001453 | Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| CID002757 | Tin | PT O.M. Indonesia | INDONESIA | Conformant |
| CID001457 | Tin | PT Panca Mega Persada | INDONESIA | Conformant |
| CID001458 | Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| CID001460 | Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| CID001463 | Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
| CID001468 | Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| CID002816 | Tin | PT Sukses Inti Makmur | INDONESIA | Conformant |
| CID001471 | Tin | PT Sumber Jaya Indah | INDONESIA | Conformant |
| CID001477 | Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Conformant |
| CID001490 | Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
| CID001493 | Tin | PT Tommy Utama | INDONESIA | Conformant |
| CID002706 | Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| CID001539 | Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| | Tin | Smelter not listed | HONG KONG | Conformant |
| CID001758 | Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| CID002756 | Tin | Super Ligas | BRAZIL | Known |
| CID001898 | Tin | Thailand Smelting & Refining Co Ltd | THAILAND | Conformant |
| CID002574 | Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Known |
| CID002015 | Tin | VQB Mineral and Trading Group JSC | VIET NAM | Known |
| CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| CID002180 | Tin | Yunnan Tin Company Limited | CHINA | Conformant |
| CID000004 | Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Conformant |
| CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| CID000105 | Tungsten | ATI Metalworking Products | UNITED STATES OF AMERICA | Conformant |
|
| | | | |
| CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| CID000499 | Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Conformant |
| CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| CID000568 | Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| CID002541 | Tungsten | H.C. Starck GmbH | GERMANY | Conformant |
| CID002542 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
| CID000769 | Tungsten | Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd. | CHINA | Conformant |
| CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| CID002579 | Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Conformant |
| CID002649 | Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| CID000825 | Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| CID002535 | Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| CID000966 | Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| CID002589 | Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| CID002543 | Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Conformant |
| CID001889 | Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Conformant |
| CID002011 | Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Conformant |
| CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| CID002095 | Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Conformant |
