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SD Filing
RPM International (RPM) SDConflict minerals disclosure
Filed: 27 May 20, 4:32pm
Exhibit 1.01
Conflict Minerals Report
Introduction
The subsidiaries of RPM International Inc. (“RPM”) manufacture, market and sell various specialty chemical product lines, including high-quality specialty paints, infrastructure rehab and repair products, protective coatings, roofing systems, sealants and adhesives, focusing on the maintenance and improvement needs of the industrial, specialty and consumer markets. Our family of products includes those marketed under brand names such as API, Betumat, Carboline, CAVE, DAP,Day-Glo,Dri-Eaz, Dryvit, Ekspan, Euclid, EUCO, Expanko, Fibergrate, Fibregrid, Fibrecrete, Flecto, Flowcrete, Grupo PV, Hummervoll, illbruck, Kemtile, Key Resin, Mohawk, Prime Resins, Rust-Oleum, Specialty Polymer Coatings, Stonhard, Strathmore, TCI, Toxement, Tremco, Tuf-Strand, Universal Sealants, Viapol, Watco and Zinsser. As of May 31, 2019, our subsidiaries marketed products in approximately 171 countries and territories and operated manufacturing facilities in approximately 156 locations in the United States, Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Colombia, France, Germany, India, Italy, Malaysia, Mexico, The Netherlands, New Zealand, Norway, Poland, South Africa, South Korea, Spain, Sweden, Turkey, the United Arab Emirates and the United Kingdom. Approximately 35% of our sales are generated in international markets through a combination of exports to and direct sales in foreign countries. For the fiscal year ended May 31, 2019, we recorded net sales of $5.6 billion.
After evaluating our diverse product lines, we have determined that the products we manufacture that may contain conflict minerals are our carpet/hard surface floor cleaning equipment, structure drying and dehumidifying equipment, bridge expansion joints, structural and elastomeric bearings, and relatively small quantities of our nail polish, industrial wood finishes products, wood protection application systems and assembled applicator systems used for dispensing polyurethanes and epoxies (“Scoped Products”). After conducting a Reasonable Country of Origin Inquiry (“RCOI”) of the relevant direct raw material suppliers of our Scoped Products, and in accordance with Rule13p-1 under the Securities Exchange Act of 1934, as amended (17 CFR240.13p-1), we are filing this Conflict Minerals Report (“CMR”).
Part I. Due Diligence
A. | RCOI |
As part of our endeavors to improve efficiency and to continue to comply with the Dodd-Frank Wall Street Reform and Consumer Protection Act and its Conflict Minerals provisions (the “Regulations”), we have a Conflict Minerals Policy (our “Policy”), which is publicly available atwww.rpminc.com/ConflictMinerals/. Our Policy continues to require an initial procedure whereby all our manufacturing companies must identify which direct raw material suppliers in their supply chains during the relevant reporting period may have supplied them with material containing one or more conflict minerals (“Relevant Suppliers”). When required, a RCOI, as more fully described below, was conducted on all relevant materials from such Relevant Suppliers and the suppliers’ responses were reviewed.
Requests for information were sent to Relevant Suppliers through Assent Compliance (“Assent”), a third-party provider engaged by RPM. Assent has specific expertise in “conflict-minerals specific” supply-chain data management. Assent ensured that appropriate communications were directed at Relevant Suppliers.
Through Assent, Relevant Suppliers were asked to provide responses consistent with the information sought by the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (hereinafter referred to as the “CMRT”). Further, the CMRT includes questions about each Relevant Supplier’s conflict minerals policy and inquiries about each such supplier’s RCOI or due diligence procedures related to conflict minerals sourcing. Furthermore, the CMRT requests the identification of known smelters used to process any disclosed conflict minerals. Assent maintained and analyzed the Relevant Suppliers’ responses using data-management software and other information available to it.
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B. | Due Diligence Conducted on the Scoped Products’ 3TG Minerals Chain of Custody |
1. | Framework |
We continue to refer to the Organisation for EconomicCo-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Due Diligence Framework”) and applied that internationally recognized framework to conduct our due diligence efforts. That framework incorporated and included the RCOI procedures.
2. | Due Diligence Measures Performed |
In accordance with the OECD Due Diligence Framework, we incorporated the following measures during our due diligence of the Scoped Products:
a) | Policy: Based upon lessons learned after the Conflict Minerals process used for the calendar year 2013 and 2014 reporting periods, and based upon professional guidance received from subject-matter experts, in 2015 we revised our Policy to more effectively identify whether (1) we may have tin, tantalum, tungsten or gold (“3TG Minerals”) in any of our products and (2) if so, to identify whether any 3TG Minerals contained in our products originated from the Democratic Republic of Congo or its adjoining countries (“DRC Region”). The Policy is reviewed annually and revised when required. However, since 2015, any revisions have been largelynon-substantive in nature and have not changed the two steps identified above. The Policy is applicable to all our subsidiaries and identifies the procedures each subsidiary must use to ensure that they accurately identify whether it has any 3TG Minerals in its products, and if so how to appropriately communicate with RPM to ensure that Assent obtains the information necessary for the RCOI process. The Policy is publicly available atwww.rpminc.com/ConflictMinerals/. |
b) | Internal Management Structure: Compliance with the Policy is supervised by one of RPM’s Directors of Global Compliance. Details regarding other direct management and internal and external communication requirements are described in the Policy which is incorporated herein by reference. |
c) | Controls, Transparency, Engagement with Suppliers and Customers: Due to our decentralized operations, the Policy requires each subsidiary company to first identify whether any of its direct raw material suppliers may have provided it with products containing 3TG Minerals during the relevant reporting period. If so, then the subsidiary company must provide relevant information about that supplier to RPM. Once obtained, RPM forwards the data to Assent to conduct the RCOI and any relevant due diligence. If 3TG Minerals are identified during Assent’s inquiries, then the subsidiary company’s responsible representative coordinates with Assent to review the procedures and further information obtained by Assent. As the Scoped Products are finished products which are not known to be used as direct raw materials by any of our customers,follow-on engagement with customers was not a factor during the 2019 reporting period. |
d) | Company Level Grievance Mechanism: The Policy is applicable to all our subsidiary companies, and therefore any violation of the Policy may be reported by anyone in accordance with The Values & Expectations of 168, which is our Code of Business Conduct and Ethics (the “Code”). Options for disclosure under the Code include, but are not limited to, contacting RPM’s Hotline where permitted by law. Additionally, the Policy requires the subsidiary company’s responsible representative to report to one of RPM’s Directors of Global Compliance anynon-responsive suppliers if that information is not otherwise available to him or her. The Code is publicly available atwww.rpminc.com/about-rpm/worldwide-code-guidelines/ and instructions for the Hotline are available atwww.rpminc.com/hotline/. |
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e) | Identification and Assessment of Risk in the Supply Chain: Based upon the relatively small number of Scoped Products as compared to the rest of our product lines, as well as the relatively small percentage of the global supply of conflict minerals originating from the DRC Region, we continue to believe that the risk that any suppliers are providing any conflict minerals to us that benefit the conflict in the DRC Region is remote. However, pursuant to our Policy and as part of the RCOI process, through the use of Assent we asked Relevant Suppliers to respond to the CMRT questions. Therefore, during the RCOI process, Relevant Suppliers are asked to answer questions designed to determine whether they in fact providenon-recycled/non-scrap 3TG Minerals to our subsidiary companies and if so, whether they know which smelters processed their 3TG Minerals. Relevant Suppliers are also asked to identify what, if any, conflict-free policies and due diligence procedures they have in place. Questions related to smelters and to their due diligence procedures are required as part of applicable post-RCOI due diligence requirements, and are asked along with the RCOI questions in order to expedite the due diligence process and limit the volume of required communications with any individual supplier that may have provided 3TG Minerals that may be contained in a Scoped Product. |
f) | Design to Respond to Identified Risks: Through Assent’s analysis, we have procedures whereby responses from Relevant Suppliers can be identified if a response rises to the level that causes someone to believe that a 3TG Mineral from the DRC Region could be contained in one of our products. When that occurs, the entirety of the due diligence portion of the questionnaire submitted by the Relevant Supplier is evaluated by Assent, an RPM representative or the relevant subsidiary company’s conflict minerals representative, and, if needed, the Relevant Supplier is contacted in order to clarify answers and to further identify smelters, the chain of custody of the direct material and to attempt to determine whether any mineral may have benefited the conflict in the DRC Region. Furthermore, in accordance with the Policy, anynon-responsive suppliers may be ultimately considered by management of any applicable subsidiary for actions designed to mitigate any future risks ofnon-compliant behavior by a supplier that is related to conflict minerals. |
g) | Follow-up with Relevant Suppliers: During the RCOI process, we received written responses from many Relevant Suppliers of direct materials used to manufacture our Scoped Products. We used the due diligence measures described above with respect to these suppliers. As has been the case previously, a few suppliers identified smelters they believed may source from the DRC Region. However, it was difficult to determine whether the response from these suppliers was product-specific and exclusively covered products purchased by us, or whether it applied to the full spectrum of products such suppliers manufacture or sell. In fact, the initial inquiry to each supplier requests CMRTs for all supplier products. It is not until after a smelter is identified as possibly being not conflict free and sourcing from the DRC region, that further inquiries are made in an attempt to determine whether the smelter(s) in question specifically relates to the raw materials purchased by us. In each such case, the supplier was unable to confirm whether the materials we purchased were sourced from the smelter identified as possibly not being conflict-free. Therefore, it was not possible for us to determine whether the declarations of possible sourcing from the DRC Region were connected to any of our Scoped Products. |
3. | Independent Private Sector Audit |
Based upon what is known to be the latest SEC guidance, an independent private sector audit of the due diligence framework conducted by us is not required for this CMR.
4. | Risk Mitigation/FutureDue Diligence Measures |
To increase efficiency and effectiveness, during this reporting period we did not use our internally created IT Interface first used in 2013, and instead used a third-party data gathering and management tool to track and manage the responses of our operating companies. Scoped Products were then sent to Assent for the conduct of the RCOI and required due diligence. Although it remains the case that only a relatively small number of our products are Scoped Products, as we grow, the number of Scoped Products has gradually increased. However, regardless of what processes we use, and as has been historically demonstrated since the 2013 reporting period, the information gathering process and the consolidation of collected information from suppliers is difficult and obtaining meaningful and relevant answers from suppliers is a cumbersome process.
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A recurring issue that we continue to attempt to mitigate is that many suppliers continue to be overburdened with the type, detail and number of related inquiries, and therefore they continue to provide a “company-wide” response to specific inquiries (i.e., they provide responses that cover all of their products combined, rather than specific responses for the distinct products sold to our subsidiary companies). Consequently, these suppliers have difficulty and are often reluctant to address specific questions related to a particular product our subsidiary companies purchased from them. For these suppliers, many of which are distributors and not manufacturers, responses indicating that 3TG Minerals are present and may have come from the DRC region only identify that one or more of their products may have Conflict Minerals implications, but such responses do not identify whether any one or more of the materials they supplied to us contains 3TG Minerals. In effect, these suppliers “over report” the existence of 3TG Minerals and often identify smelters that may have no connection to direct raw materials we purchased from them. Therefore, such responses are not very informative or helpful. We continue to educate these suppliers and engage the purchasing representatives from our subsidiary manufacturers who have Relevant Suppliers to facilitate that education. However, education alone may be insufficient. In some instances these suppliers are not located within the U.S. and may feel as though the law is wholly inapplicable to them, are not manufacturers, deal with hundreds of suppliers and manufacturers themselves, and/or are unfamiliar with the reporting obligations of publicly traded companies in the U.S.
Part II. Information Known Regarding Chain of Custody of Scoped Products
As a result of the due diligence conducted on the Scoped Products as described in Part I, the following relevant information is provided:
A. | 3TG Minerals: Tin, Tantalum, Gold and Tungsten were all identified by Relevant Suppliers. |
B. | Smelters and Origin: Smelters Identified to by Relevant Suppliers.1 |
Gold | 8853 S.p.A. | ITALY | ||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | ||
Gold | African Gold Refinery | UGANDA | ||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||
Gold | AllgemeineGold-und Silberscheideanstalt A.G. | GERMANY | ||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||
Gold | Argor-Heraeus S.A. | SWITZERLAND | ||
Gold | Asahi Pretec Corp. | JAPAN | ||
Gold | Asahi Refining Canada Ltd. | CANADA |
1 | Assent provided relevant Smelter Validation Reports and under those reports it identified what it categorizes as“non-legitimate” entries which are defined as “entries that have not been verified to be legitimate smelters/refiners or legitimate data.” Smelter entries provided by our suppliers to Assent that are categorized asnon-legitimate entries are not listed in this CMR. |
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Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||
Gold | Asaka Riken Co., Ltd. | JAPAN | ||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
Gold | AU Traders and Refiners | SOUTH AFRICA | ||
Gold | Aurubis AG | GERMANY | ||
Gold | Bangalore Refinery | INDIA | ||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
Gold | Boliden AB | SWEDEN | ||
Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
Gold | Caridad | MEXICO | ||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | ||
Gold | Cendres + Metaux S.A. | SWITZERLAND | ||
Gold | CGR Metalloys Pvt Ltd. | INDIA | ||
Gold | Chimet S.p.A. | ITALY | ||
Gold | Chugai Mining | JAPAN | ||
Gold | DayeNon-Ferrous Metals Mining Ltd. | CHINA | ||
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||
Gold | Dowa | JAPAN | ||
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||
Gold | �� | Eco-System Recycling Co., Ltd. West Plant | JAPAN | |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | ||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
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 |
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Gold | Heimerle + Meule GmbH | GERMANY | ||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
Gold | Istanbul Gold Refinery | TURKEY | ||
Gold | Italpreziosi | ITALY | ||
Gold | Japan Mint | JAPAN | ||
Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
Gold | JSC EkaterinburgNon-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 OF AMERICA | ||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
Gold | L’azurde Company For Jewelry | SAUDI ARABIA | ||
Gold | Lingbao Gold Co., Ltd. | CHINA | ||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
Gold | L’Orfebre S.A. | ANDORRA | ||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | ||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
Gold | Marsam Metals | BRAZIL | ||
Gold | Materion | UNITED STATES OF AMERICA |
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Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
Gold | Metalor Technologies S.A. | SWITZERLAND | ||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||
Gold | MetalurgicaMet-Mex Penoles 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 | Modeltech Sdn Bhd | MALAYSIA | ||
Gold | Morris and Watson | NEW ZEALAND | ||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||
Gold | Nihon Material Co., Ltd. | JAPAN | ||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
Gold | PAMP S.A. | SWITZERLAND | ||
Gold | Pease & Curren | UNITED STATES OF AMERICA | ||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
Gold | Planta Recuperadora de Metales SpA | CHILE | ||
Gold | Prioksky Plant ofNon-Ferrous Metals | RUSSIAN FEDERATION | ||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
Gold | PX Precinox S.A. | SWITZERLAND | ||
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||
Gold | REMONDIS PMR B.V. | NETHERLANDS | ||
Gold | Royal Canadian Mint | CANADA |
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Gold | SAAMP | FRANCE | ||
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
Gold | Safimet S.p.A | ITALY | ||
Gold | SAFINA A.S. | CZECH REPUBLIC | ||
Gold | Sai Refinery | INDIA | ||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | ||
Gold | Shandong Humon Smelting 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, PROVINCE OF CHINA | ||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
Gold | Sovereign Metals | INDIA | ||
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
Gold | Sudan Gold Refinery | SUDAN | ||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
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 | Tony Goetz NV | BELGIUM | ||
Gold | TOOTau-Ken-Altyn | KAZAKHSTAN | ||
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 OF AMERICA |
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Gold | Valcambi S.A. | SWITZERLAND | ||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||
Gold | WIELAND Edelmetalle GmbH | GERMANY | ||
Gold | Yamakin Co., Ltd. | JAPAN | ||
Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | ||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | ||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | ||
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 OF AMERICA | ||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | ||
Tantalum | H.C. Starck Ltd. | JAPAN | ||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
Tantalum | Jiangxi Tuohong New Raw Material | 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 | LSM Brasil S.A. | BRAZIL | ||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
Tantalum | Mineracao Taboca S.A. | BRAZIL |
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Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
Tantalum | NPM Silmet AS | ESTONIA | ||
Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | ||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | ||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | ||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | ||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
Tin | Alpha | UNITED STATES OF AMERICA | ||
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | ||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||
Tin | China Tin Group Co., Ltd. | CHINA | ||
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
Tin | Dowa | JAPAN | ||
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | ||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Estanho de Rondonia S.A. | BRAZIL | ||
Tin | Fenix Metals | POLAND | ||
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | CHINA | ||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
Tin | Guangdong HanheNon-Ferrous Metal Co., Ltd. | CHINA | ||
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
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Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
Tin | Ma’anshan Weitai Tin Co., Ltd. | 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 | Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
Tin | Metallo Belgium N.V. | BELGIUM | ||
Tin | Metallo Spain S.L.U. | SPAIN | ||
Tin | Mineracao Taboca S.A. | BRAZIL | ||
Tin | Minsur | PERU | ||
Tin | Mitsubishi Materials Corporation | JAPAN | ||
Tin | Modeltech Sdn Bhd | MALAYSIA | ||
Tin | Nghe TinhNon-Ferrous Metals Joint Stock Company | VIETNAM | ||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
Tin | Pongpipat Company Limited | MYANMAR | ||
Tin | Precious Minerals and Smelting Limited | INDIA | ||
Tin | PT Artha Cipta Langgeng | INDONESIA | ||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
Tin | PT Menara Cipta Mulia | INDONESIA | ||
Tin | PT Mitra Stania Prima | INDONESIA | ||
Tin | PT Refined Bangka Tin | INDONESIA | ||
Tin | PT Timah Tbk Kundur | INDONESIA | ||
Tin | PT Timah Tbk Mentok | INDONESIA | ||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
Tin | Soft Metais Ltda. | BRAZIL | ||
Tin | Super Ligas | BRAZIL | ||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM | ||
Tin | Thaisarco | THAILAND | ||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||
Tin | Tuyen QuangNon-Ferrous Metals Joint Stock Company | VIETNAM |
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Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||
Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | CHINA | ||
Tin | Yunnan Tin Company Limited | CHINA | ||
Tin | Yunnan YunfanNon-ferrous Metals Co., Ltd. | CHINA | ||
Tungsten | A.L.M.T. Corp. | JAPAN | ||
Tungsten | ACL Metais Eireli | BRAZIL | ||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | ||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | China Molybdenum Co., Ltd. | CHINA | ||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Hunan Litian Tungsten Industry 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’anNon-ferrous Metals Co., Ltd. | CHINA | ||
Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
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Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | ||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | ||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | ||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIETNAM | ||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | ||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | ||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | ||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | ||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
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