Exhibit 1.01
CONFLICT MINERALS REPORT
NETGEAR, INC.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934
for the Calendar Year Ended December 31, 2021
Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to Conflict Minerals as directed by Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010. Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain Conflict Minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tungsten, tantalum, and gold (collectively, “3TG”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Covered Countries (as defined below).
If a registrant has reason to believe that any 3TGs in their supply chain may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of the 3TGs in their products, or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the 3TGs. The registrant must annually submit a Form SD and Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. NETGEAR, Inc. ("NETGEAR" or the "Company") has determined that 3TGs are necessary to the functionality or production of some of its products during the 2021 calendar year and therefore, is required to perform due diligence and file this report annually. This report is NETGEAR's CMR for the reporting calendar year ended December 31, 2021.
This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit.
Section 1 - Company Overview
NETGEAR was incorporated in Delaware in January 1996. The Company is a global networking company that delivers innovative products to consumers, businesses and service providers. The Company's products are built on a variety of proven technologies such as wireless (WiFi and LTE), Ethernet and powerline, with a focus on reliability and ease-of-use. The product line consists of wired and wireless devices that enable networking, broadband access and network connectivity. These products are available in multiple configurations to address the needs of the end-users in each geographic region in which the Company's products are sold. NETGEAR utilizes contract manufacturers, original design manufacturers and component vendors to supply components, assemblies, and finished products.
NETGEAR’s internet address is www.netgear.com. This CMR will be posted on the Company’s website with other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC.
1.1 NETGEAR Products
During 2021, NETGEAR's product portfolio was comprised of the following product categories:
| • | Ethernet switches, which are multiple port devices used to network computing devices and peripherals via Ethernet wiring; |
| • | Wireless controllers and access points, which are devices used to manage and control multiple WiFi base stations on a campus or a facility providing WiFi connections to smart phones, tablets, laptops and other computing devices; |
| • | Internet security appliances, which provide Internet access through capabilities such as anti-virus and anti-spam; |
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| • | Unified storage, which delivers file and block based data into a single shared storage system, meeting the demands of small enterprises, education, hospitality and health markets through an easy-to-use interface for managing multiple storage protocols; |
| • | Broadband modems, which are devices that convert the broadband signals into Ethernet data that feeds Internet into homes and offices; |
| • | WiFi Gateways, which are WiFi routers with an integrated broadband modem, for broadband Internet access; |
| • | WiFi Hotspots, which create mobile WiFi Internet access that utilizes 3G and 4G LTE data networks for use on the go, and at home in place of traditional wired broadband, Internet access; |
| • | WiFi routers, which create a local area network (LAN) for home or office computer, mobile and Smart Home devices to connect and share a broadband Internet connection; |
| • | WiFi range extenders, which extend the range of an existing WiFi network to eliminate WiFi dead spots; |
| • | Powerline adapters and bridges, which extend wired and WiFi Internet connections to any AC outlet using existing electrical wiring; |
| • | WiFi network adapters, which enable computing devices to be connected to the network via WiFi. |
| • | Meural, a network-connected LCD display that can download and display arts from Netgear/Meural digital library as well as any personal content that the individual has uploaded to the Netgear/Meural cloud or the LCD display |
We conducted an analysis of NETGEAR products and found that small quantities of 3TG, necessary to their functionality or production, are found in substantially all NETGEAR products.
1.2 Conflict Minerals Report
For all product categories listed under 1.1, we have been unable to conclusively determine the origin of the 3TGs that our products contain, or to conclusively determine to what extent they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. Our suppliers reported at broad levels, often with the declaration scope as “Company” in their Conflict Minerals Reporting Template (“CMRT”).
This report describes our Reasonable Country of Origin Inquiry (“RCOI”) efforts, the due diligence measures we took on the 3TG source and chain of custody, the results of our due diligence efforts, expected risk assessment and mitigation steps.
1.3 Conflict Minerals Policy
NETGEAR has published its conflict minerals policy on its webpage located at:
http://www.netgear.com/images/conflict_minerals_policy_statement.pdf
Section 2 - Reasonable Country of Origin Inquiry (“RCOI”)
To determine whether the necessary 3TG in our products originated in Covered Countries, NETGEAR retained Assent Compliance (“Assent”), a third-party service provider, to assist us in reviewing the supply chain and identifying risks. We provided a list composed of suppliers and parts associated with the in-scope products to Assent.
To collect data on the materials’ sources of origin procured by the supply chain, NETGEAR utilized the Conflict Minerals Reporting Template (“CMRT”) version 6.1 or higher to conduct a survey of all in scope Tier 1* suppliers.
*NETGEAR’s definition of Tier 1 Supplier - ODM (Original Design Manufacturer), CM (Contract Manufacturer) and NETGEAR’s AVL (Approved Vendor List) with whom NETGEAR has placed purchase order directly. This excludes the following suppliers: Suppliers where strategic purchasing only performs a reference price check; Plastics and software suppliers; Packaging suppliers; and Suppliers whose materials declarations confirm gold, tantalum, tin and tungsten are not contained in the applicable component.
During the supplier survey, the Company contacted suppliers via platform provided by third-party Assent that enables users to complete and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment, and management. The platform also provides functionality that meets the OECD Guidance process expectations by evaluating the quality of each supplier response and assigning a health status based on the supplier’s declaration of process engagement. Additionally, the metrics provided in this report, as well as the step-by-step process for supplier engagement and upstream due diligence investigations performed, are managed through this platform.
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NETGEAR requested that all suppliers complete a CMRT. Training and education to guide suppliers on best practices and the use of this template was included. All communications in the third-party’s platform for future reporting and transparency are monitored and tracked. NETGEAR directly contacted suppliers that were unresponsive to third-party’s communications during the diligence process and requested these suppliers complete the CMRT and submit it to our third-party.
The Company’s program continues to include automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on questions within the declaration tab of the CMRT which helps to identify areas that require further classification or risk assessment, as well as understand the due diligence efforts of the Tier 1 suppliers. The results of this data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require clarification or improvement.
All submitted forms are accepted and classified as valid or invalid so that data is retained. Suppliers are contacted regarding invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validation errors in the form of feedback to their CMRT submission, training courses and direct engagement help through Third Party’s multilingual Supplier Experience team.
As of March, 1st, 2022, there were 17 suppliers in scope of the conflict minerals program and all of them provided a completed CMRT. NETGEAR’s total response rate for this reporting year was 100%.
Based on the findings through the RCOI process, the Company was able to determine the countries of origin for a large portion of the 3TGs in its products. As such, NETGEAR continued to perform further due diligence on the source and chain of custody of the minerals in question.
Section 3 - Conflict Minerals Due Diligence Program
NETGEAR designed its due diligence measures to conform, in all material respects, with the framework in the OECD Guidance and the related supplements. The program aligns with the five steps for due diligence that are described by the OECD Guidance and the Company continues to evaluate market expectations for data collection and reporting to achieve continuous improvement opportunities.
Due diligence requires the Company’s necessary reliance on data provided by direct suppliers and third-party audit programs. There is a risk of incomplete or inaccurate data as the process cannot fully be owned by the Company. However, through continued outreach and process validation, this aligns with industry standards and market expectations for downstream companies’ due diligence.
Summarized below are the components of Company’s program as they relate to the five-step framework set forth in the OECD Guidance:
3.1 Establish strong company management systems
| • | Adopted and publicly communicated a conflict minerals company policy which is posted on NETGEAR website at http://www.netgear.com/images/conflict_minerals_policy_statement.pdf. |
| • | As a member of the RBA (Responsible Business Alliance, previously known as the EICC or the Electronic Industry Citizenship Coalition), required that our suppliers and contract manufacturers acknowledge and implement the RBA’s Code of Conduct, which includes an obligation to conduct due diligence regarding conflict minerals. |
| • | Assembled internal conflict minerals team, with representation from NETGEAR’s Operations, Legal, Procurement, Finance and Internal Audit. |
| • | Established a system of controls through the use of Supplier Code of Conduct and transparency over NETGEAR’s conflict minerals supply chain by engaging Tier 1 suppliers and requesting relevant information through the use of a third-party supplier management vendor which utilized due diligence tools created by the Responsible Minerals Initiative (“RMI”), including the CMRT. |
| • | Provided updates on our conflict minerals due diligence progress and status to certain members of NETGEAR’s senior management. |
| • | Educated and trained those personnel responsible to work on NETGEAR’s Conflict Minerals Program. This includes internal team members and suppliers. |
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| • | Established a grievance mechanism to allow employees, suppliers, and others to report suspected non-compliance with legal requirement and/or suspected non-compliance with NETGEAR’s Code of Ethics and Supplier Code of Conduct. These policies are publicly available at http://www.netgear.com/about/corporate-social-responsibility/ethics/. |
| • | Established an internal audit to review conflict minerals due diligence process against NETGEAR’s documented procedure and data accuracy in NETGEAR CMRT. |
| • | Identified business records relating to conflict minerals due diligence, including records of due diligence processes, findings and resulting decisions, that will be retained in accordance with our records retention policies. |
3.2 Identify and manage risk in the supply chain
| • | Identified relevant Tier 1 suppliers that supplied products containing 3TG. |
| • | Requested such suppliers to provide information regarding smelters or refiners in our supply chain by using the CMRT. |
| • | Reviewed supplier responses for completeness and accuracy. |
| • | Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRT declarations. |
| • | Compared information in supplier responses with the list of 3TG processing facilities that received a “conflict-free” designation, produced by the RMAP (Responsible Minerals Assurance Process). |
| • | Each facility that meets the RMI definition of a smelter or refiner of a 3TG is assessed according to red flag indicators defined in the OECD Guidance. To determine the level of risk that each smelter posed to the supply chain the Company assessed following criteria: geographic proximity to the Covered Countries, known mineral source country of origin, RMAP audit status, credible evidence of unethical or conflict sourcing, and Peer assessments conducted by credible third-party sources. |
| • | Contacted non-responsive suppliers, requesting their responses. |
| • | Provided suppliers with feedback on responses containing errors, inconsistencies or incomplete information and encouraged them to resubmit a valid response. |
| • | Evaluated suppliers on the strength of their internal conflict minerals programs, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program is based on certain questions in the CMRT related to the suppliers’ conflict minerals practices and policies. |
3.3 Design and implement a strategy to respond to risk
| • | Conducted regular conflict minerals team meetings to review, among other things, NETGEAR’s conflict minerals program, any potential or actual risks identified during due diligence, and the status of supplier responses. |
| • | Reported progress during the team meeting or quarterly basis to our Chief Operations Officer |
| • | Identified high risk smelters in NETGEAR’s supply chain by using smelter database from the RMI that includes information on smelter’s chain of custody of minerals. NETGEAR’s smelter risk calculation is based on the following criteria: |
| ◦ | Geographic proximity to the DRC and covered countries; |
| ◦ | Known mineral source country of origin; |
| ◦ | RMAP audit status; |
| ◦ | Credible evidence of unethical or conflict sourcing; and |
| ◦ | Peer Assessments conducted by credible third-party sources. |
| • | Through the use of the Company’s third-party service provider, contacted non-RMAP facilities to encourage them to join the program and undergo an audit |
| • | Implemented an escalation plan for non-responsive suppliers and/or address incomplete or inaccurate supply chain information. |
| • | Requested that certain suppliers remove specific smelters or refiners from their supply chain that we deemed to be high-risk or invalid. |
| • | Engaged any suppliers whom we have reason to believe are supplying the Company with 3TGs from sources that may be considered a red-flag and encourage them to establish alternative sources of 3TGs. |
| • | Informed non-responsive suppliers that we will assess, and potentially withhold, future business with them if they do not provide their supply chain conflict minerals information using the CMRT. |
| • | Conducted Conflict Minerals Program due diligence process audit of NETGEAR’s ODM partners. |
3.4 Audit of smelter/refiner’s due diligence practices
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| • | Relied on the RMAP, the London Bullion Market Association, and the Responsible Jewellery Council to coordinate third-party audits of smelters and refiners to validate the sourcing practices of such facilities in our supply chain. |
| • | Provided indirect financial support for such third-party audits through our continued membership in the RBA and RMI. |
| • | Participated in RBA & RMI work groups, including smelter engagement and outreach. |
| • | NETGEAR designated third-party also directly contacts smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. NETGEAR is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance. |
3.5 Report annually on supply chain due diligence
| • | NETGEAR has published the Form SD for the year ended December 31, 2021. This report is available on the Investor Relations pages of our website at http://investor.netgear.com/sec.cfm. |
| • | . Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein. NETGEAR has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission. |
| • | This year the Company has also considered impacts from the European Union Conflict Minerals Rule when disclosing details with regards to due diligence efforts. The Company will continue to expand efforts both for transparency through the data collection process and risk evaluation, as well as the disclosure of efforts through the form of public report. |
Section 4 - Due Diligence Results
NETGEAR does not have direct contractual relationships with smelters and refiners, therefore, we relied on our direct suppliers and the entire supply chain to gather and provide specific information on 3TGs used in NETGEAR products.
4.1 Supply Chain Outreach Results
Supply chain outreach is required to identify the upstream sources of origin of tin, tantalum, tungsten and gold. Following the industry standard process, CMRTs are sent to and requested from Tier 1 suppliers, who are expected to follow this process until the smelter and refiner sources are identified. The following is the result of the outreach conducted by NETGEAR for the 2021 reporting year.
Supply Chain Outreach Metrics
Number of In-Scope Suppliers | Response Rate | Valid Response Rate |
17 | 100% | 100% |
Upstream Data Transparency
All smelters and refiners listed by suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are attached in Appendix A. As is a common practice when requests are sent upstream in the supply chain, those who purchase materials from smelters may not be able to discern exactly which company’s product lines the materials may end up in. As a result, those providing the smelters and refiners have the practice to list all smelters and refiners they may purchase from within the reporting period. Therefore, the smelters or refiners (as sources) listed in Appendix A are likely to be more comprehensive than the list of smelters or refiners which actually processed the 3TGs contained in the Company’s products.
Suppliers that identified these specific smelters of concern on their CMRT were contacted in accordance with the OECD Guidance to inform them of the potential for risk, and to evaluate whether or not these smelters could be connected to NETGEAR’s products. The suppliers were asked to complete a user-defined or product-level CMRT specific to the materials, products or piece parts purchased by NETGEAR, rather than a company-level CMRT, to better identify the
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connection to products that they supply to NETGEAR. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were removed from the scope of data collection.
Status | Number of Identified Smelters and Refiners |
RMAP Conformant | 230 |
RMAP Active | 20 |
Not Enrolled | 14 |
Non-Conformant | 12 |
Countries of Origin
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. As mentioned in the above section, it is understood that many responses may provide more data than can be directly linked to products sold by NETGEAR, therefore, Appendix B may contain more countries than those that the Company’s products are being sourced from.
Section 5 - Risk Mitigation and Due Diligence Improvement Plan
5.1 Inherent limitation on due diligence measures
Because of our manufacturing business model, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals in the products we contract to manufacture. Given our place in the supply chain, we have no direct relationships with smelters, refiners, and therefore possess no independent means of determining the source and origin of conflict mineral ores processed by smelters or refiners. Our due diligence processes are based on the necessity of seeking data from our suppliers and component manufacturers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third-party audit programs.
5.2 Steps to be taken to mitigate risk and improve Due Diligence Process
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:
| • | Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework. |
| • | Engage with Tier 1 suppliers supplying us with 3TG from sources that support conflict in any covered country to establish an acceptable alternative source of 3TG. |
| • | Increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of conflict-free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program. |
| • | Emphasize the need for cooperation and support by our Tier 1 suppliers by implementing more direct Netgear-led escalations throughout the program. |
| • | Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers and follow up with suppliers who appear to have gaps in their internal processes for conflict minerals. |
| • | Engage with our suppliers more closely and provide suppliers with more information and training resources regarding responsible sourcing of 3TGs. |
| • | Engage Tier 1 suppliers to encourage smelters or refiners in supply chain, not yet identified by the RMAP or equivalent independent third-party audit, to undergo smelter audits and verify compliance. |
| • | Support our third-party service provider in their smelter due diligence activities by signing a letter to be sent to smelters who have yet to enroll in RMAP, encouraging them to do so. |
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5.3 Smelter & Refiner Risk Evaluation
Understanding the risks associated with the smelters and refiners potentially providing material into NETGEAR’s supply chain is an important part of the due diligence process. Through our third-party service provider Assent, comprehensive and ongoing analysis is conducted to assess sourcing risk. This information is used to:
• | Provide supplier feedback. |
• | Determine the health of the Company’s overall program. |
• | Conduct outreach to smelters, refiners, and their respective associations. |
• | Provide detailed analysis in this report. |
The following risk categories are used for smelter evaluation and risk determination:
• | Geo-Risk |
| • | Did the mineral originate from or has been transported through a conflict-affected area as defined by Section 1502 of the Dodd-Frank Act (the DRC and its nine adjoining countries; Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia)? |
• | Audit Status |
| • | Has the refiner’s due diligence practices been audited against a standard in conformance with the OECD Guidance? |
| • | Assent relies on the RMI audit standard, including cross-recognition of the London Bullion Market Association (“LBMA”) Good Delivery Program and the Responsible Jewelry Council Chain of Custody Certification, which are developed according to global standards, including the OECD Guidance. |
• | Sourcing Risk |
| • | Has evidence of any other red flag that is supported by credible sources been identified? |
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Table A
Smelter & Refiners Reported to be in Supply Chain of NETGEAR
Below list of smelters and refiners have been identified by our Tier 1 suppliers and may have been used in processing of necessary 3TGs contained in NETGEAR products:
Smelter ID | Mineral | Standard Smelter Name | Smelter Facility Location |
CID000015 | Gold | Advanced Chemical Company | United States Of America |
CID000019 | Gold | Aida Chemical Industries Co., Ltd. | Japan |
CID000035 | Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany |
CID000041 | Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
CID000058 | Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
CID000077 | Gold | Argor-Heraeus S.A. | Switzerland |
CID000082 | Gold | Asahi Pretec Corp. | Japan |
CID000090 | Gold | Asaka Riken Co., Ltd. | Japan |
CID000113 | Gold | Aurubis AG | Germany |
CID000128 | Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
CID000157 | Gold | Boliden AB | Sweden |
CID000176 | Gold | C. Hafner GmbH + Co. KG | Germany |
CID000185 | Gold | CCR Refinery - Glencore Canada Corporation | Canada |
CID000189 | Gold | Cendres + Metaux S.A. | Switzerland |
CID000233 | Gold | Chimet S.p.A. | Italy |
CID000264 | Gold | Chugai Mining | Japan |
CID000359 | Gold | DSC (Do Sung Corporation) | Korea, Republic Of |
CID000362 | Gold | DODUCO Contacts and Refining GmbH | Germany |
CID000401 | Gold | Dowa | Japan |
CID000425 | Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
CID000493 | Gold | OJSC Novosibirsk Refinery | Russian Federation |
CID000689 | Gold | LT Metal Ltd. | Korea, Republic Of |
CID000694 | Gold | Heimerle + Meule GmbH | Germany |
CID000707 | Gold | Heraeus Metals Hong Kong Ltd. | China |
CID000711 | Gold | Heraeus Precious Metals GmbH & Co. KG | Germany |
CID000801 | Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
CID000807 | Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
CID000814 | Gold | Istanbul Gold Refinery | Turkey |
CID000823 | Gold | Japan Mint | Japan |
CID000855 | Gold | Jiangxi Copper Co., Ltd. | China |
CID000920 | Gold | Asahi Refining USA Inc. | United States Of America |
CID000924 | Gold | Asahi Refining Canada Ltd. | Canada |
CID000929 | Gold | JSC Uralelectromed | Russian Federation |
CID000937 | Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
CID000957 | Gold | Kazzinc | Kazakhstan |
CID000969 | Gold | Kennecott Utah Copper LLC | United States Of America |
CID000981 | Gold | Kojima Chemicals Co., Ltd. | Japan |
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CID001078 | Gold | LS-NIKKO Copper Inc. | Korea, Republic Of |
CID001113 | Gold | Materion | United States Of America |
CID001119 | Gold | Matsuda Sangyo Co., Ltd. | Japan |
CID001147 | Gold | Metalor Technologies (Suzhou) Ltd. | China |
CID001149 | Gold | Metalor Technologies (Hong Kong) Ltd. | China |
CID001152 | Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
CID001153 | Gold | Metalor Technologies S.A. | Switzerland |
CID001157 | Gold | Metalor USA Refining Corporation | United States Of America |
CID001161 | Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
CID001188 | Gold | Mitsubishi Materials Corporation | Japan |
CID001193 | Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
CID001204 | Gold | Moscow Special Alloys Processing Plant | Russian Federation |
CID001220 | Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
CID001236 | Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
CID001259 | Gold | Nihon Material Co., Ltd. | Japan |
CID001325 | Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
CID001326 | Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
CID001352 | Gold | PAMP S.A. | Switzerland |
CID001386 | Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
CID001397 | Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
CID001498 | Gold | PX Precinox S.A. | Switzerland |
CID001512 | Gold | Rand Refinery (Pty) Ltd. | South Africa |
CID001534 | Gold | Royal Canadian Mint | Canada |
CID001555 | Gold | Samduck Precious Metals | Korea, Republic Of |
CID001585 | Gold | SEMPSA Joyeria Plateria S.A. | Spain |
CID001622 | Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
CID001736 | Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
CID001756 | Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
CID001761 | Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China |
CID001798 | Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
CID001875 | Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
CID001916 | Gold | The Refinery of Shandong Gold Mining Co., Ltd. | China |
CID001938 | Gold | Tokuriki Honten Co., Ltd. | Japan |
CID001955 | Gold | Torecom | Korea, Republic Of |
CID001980 | Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
CID001993 | Gold | United Precious Metal Refining, Inc. | United States Of America |
CID002003 | Gold | Valcambi S.A. | Switzerland |
CID002030 | Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
CID002100 | Gold | Yamakin Co., Ltd. | Japan |
CID002129 | Gold | Yokohama Metal Co., Ltd. | Japan |
CID002224 | Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
CID002243 | Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
CID002290 | Gold | SAFINA A.S. | Czechia |
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CID002314 | Gold | Umicore Precious Metals Thailand | Thailand |
CID002459 | Gold | Geib Refining Corporation | United States Of America |
CID002509 | Gold | MMTC-PAMP India Pvt., Ltd. | India |
CID002511 | Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
CID002516 | Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China |
CID002560 | Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
CID002561 | Gold | Emirates Gold DMCC | United Arab Emirates |
CID002580 | Gold | T.C.A S.p.A | Italy |
CID002582 | Gold | REMONDIS PMR B.V. | Netherlands |
CID002605 | Gold | Korea Zinc Co., Ltd. | Korea, Republic Of |
CID002606 | Gold | Marsam Metals | Brazil |
CID002615 | Gold | TOO Tau-Ken-Altyn | Kazakhstan |
CID002761 | Gold | SAAMP | France |
CID002762 | Gold | L'Orfebre S.A. | Andorra |
CID002763 | Gold | 8853 S.p.A. | Italy |
CID002765 | Gold | Italpreziosi | Italy |
CID002777 | Gold | SAXONIA Edelmetalle GmbH | Germany |
CID002778 | Gold | WIELAND Edelmetalle GmbH | Germany |
CID002779 | Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
CID002863 | Gold | Bangalore Refinery | India |
CID002918 | Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of |
CID002919 | Gold | Planta Recuperadora de Metales SpA | Chile |
CID002973 | Gold | Safimet S.p.A | Italy |
CID003424 | Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
CID003425 | Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
CID000343 | Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
CID001029 | Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
CID001909 | Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
CID002850 | Gold | AU Traders and Refiners | South Africa |
CID003421 | Gold | C.I Metales Procesados Industriales SAS | Colombia |
CID003575 | Gold | Metal Concentrators SA (Pty) Ltd. | South Africa |
CID002852 | Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
CID003189 | Gold | NH Recytech Company | Korea, Republic Of |
CID003461 | Gold | Augmont Enterprises Private Limited | India |
CID003500 | Gold | Alexy Metals | United States Of America |
CID003529 | Gold | Sancus ZFS (L’Orfebre, SA) | Colombia |
CID003615 | Gold | WEEEREFINING | France |
CID000103 | Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
CID000197 | Gold | Yunnan Copper Industry Co., Ltd. | China |
CID000522 | Gold | Refinery of Seemine Gold Co., Ltd. | China |
CID000651 | Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
CID000767 | Gold | Hunan Chenzhou Mining Co., Ltd. | China |
CID000773 | Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
CID000927 | Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
10
CID001362 | Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
CID003382 | Gold | CGR Metalloys Pvt Ltd. | India |
CID002562 | Gold | International Precious Metal Refiners | United Arab Emirates |
CID000211 | Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China |
CID000456 | Tantalum | Exotech Inc. | United States Of America |
CID000460 | Tantalum | F&X Electro-Materials Ltd. | China |
CID000616 | Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
CID000914 | Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
CID000917 | Tantalum | Jiujiang Tanbre Co., Ltd. | China |
CID001076 | Tantalum | LSM Brasil S.A. | Brazil |
CID001163 | Tantalum | Metallurgical Products India Pvt., Ltd. | India |
CID001175 | Tantalum | Mineracao Taboca S.A. | Brazil |
CID001192 | Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
CID001200 | Tantalum | NPM Silmet AS | Estonia |
CID001277 | Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
CID001508 | Tantalum | QuantumClean | United States Of America |
CID001522 | Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
CID001769 | Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
CID001869 | Tantalum | Taki Chemical Co., Ltd. | Japan |
CID001891 | Tantalum | Telex Metals | United States Of America |
CID001969 | Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
CID002492 | Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
CID002504 | Tantalum | D Block Metals, LLC | United States Of America |
CID002505 | Tantalum | FIR Metals & Resource Ltd. | China |
CID002506 | Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
CID002508 | Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
CID002512 | Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
CID002539 | Tantalum | KEMET Blue Metals | Mexico |
CID002544 | Tantalum | H.C. Starck Co., Ltd. | Thailand |
CID002545 | Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
CID002547 | Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
CID002548 | Tantalum | H.C. Starck Inc. | United States Of America |
CID002549 | Tantalum | H.C. Starck Ltd. | Japan |
CID002550 | Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
CID002557 | Tantalum | Global Advanced Metals Boyertown | United States Of America |
CID002558 | Tantalum | Global Advanced Metals Aizu | Japan |
CID002707 | Tantalum | Resind Industria e Comercio Ltda. | Brazil |
CID002842 | Tantalum | Jiangxi Tuohong New Raw Material | China |
CID003583 | Tantalum | Yancheng Jinye New Material Technology Co., Ltd. | China |
CID000228 | Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
CID000292 | Tin | Alpha | United States Of America |
CID000402 | Tin | Dowa | Japan |
CID000438 | Tin | EM Vinto | Bolivia (Plurinational State Of) |
CID000468 | Tin | Fenix Metals | Poland |
11
CID000538 | Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
CID000555 | Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
CID000942 | Tin | Gejiu Kai Meng Industry and Trade LLC | China |
CID001070 | Tin | China Tin Group Co., Ltd. | China |
CID001105 | Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
CID001142 | Tin | Metallic Resources, Inc. | United States Of America |
CID001173 | Tin | Mineracao Taboca S.A. | Brazil |
CID001182 | Tin | Minsur | Peru |
CID001191 | Tin | Mitsubishi Materials Corporation | Japan |
CID001231 | Tin | Jiangxi New Nanshan Technology Ltd. | China |
CID001314 | Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
CID001337 | Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) |
CID001399 | Tin | PT Artha Cipta Langgeng | Indonesia |
CID001402 | Tin | PT Babel Inti Perkasa | Indonesia |
CID001406 | Tin | PT Babel Surya Alam Lestari | Indonesia |
CID001453 | Tin | PT Mitra Stania Prima | Indonesia |
CID001458 | Tin | PT Prima Timah Utama | Indonesia |
CID001460 | Tin | PT Refined Bangka Tin | Indonesia |
CID001463 | Tin | PT Sariwiguna Binasentosa | Indonesia |
CID001468 | Tin | PT Stanindo Inti Perkasa | Indonesia |
CID001477 | Tin | PT Timah Tbk Kundur | Indonesia |
CID001482 | Tin | PT Timah Tbk Mentok | Indonesia |
CID001486 | Tin | PT Timah Nusantara | Indonesia |
CID001490 | Tin | PT Tinindo Inter Nusa | Indonesia |
CID001539 | Tin | Rui Da Hung | Taiwan, Province Of China |
CID001758 | Tin | Soft Metais Ltda. | Brazil |
CID001898 | Tin | Thaisarco | Thailand |
CID001908 | Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
CID002036 | Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
CID002158 | Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
CID002180 | Tin | Yunnan Tin Company Limited | China |
CID002455 | Tin | CV Venus Inti Perkasa | Indonesia |
CID002468 | Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
CID002500 | Tin | Melt Metais e Ligas S.A. | Brazil |
CID002503 | Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
CID002517 | Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
CID002706 | Tin | Resind Industria e Comercio Ltda. | Brazil |
CID002773 | Tin | Metallo Belgium N.V. | Belgium |
CID002774 | Tin | Metallo Spain S.L.U. | Spain |
CID002834 | Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam |
CID002835 | Tin | PT Menara Cipta Mulia | Indonesia |
CID002844 | Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
CID003116 | Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
CID003190 | Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
12
CID003205 | Tin | PT Bangka Serumpun | Indonesia |
CID003325 | Tin | Tin Technology & Refining | United States Of America |
CID003379 | Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
CID003381 | Tin | PT Rajawali Rimba Perkasa | Indonesia |
CID003387 | Tin | Luna Smelter, Ltd. | Rwanda |
CID003397 | Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
CID003449 | Tin | PT Mitra Sukses Globalindo | Indonesia |
CID000309 | Tin | PT Aries Kencana Sejahtera | Indonesia |
CID000448 | Tin | Estanho de Rondonia S.A. | Brazil |
CID002756 | Tin | Super Ligas | Brazil |
CID001305 | Tin | Novosibirsk Processing Plant Ltd. | Russian Federation |
CID003486 | Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil |
CID003524 | Tin | CRM Synergies | Spain |
CID003582 | Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
CID003208 | Tin | Pongpipat Company Limited | Myanmar |
CID003409 | Tin | Precious Minerals and Smelting Limited | India |
CID002858 | Tin | Modeltech Sdn Bhd | Malaysia |
CID002816 | Tin | PT Sukses Inti Makmur | Indonesia |
CID000004 | Tungsten | A.L.M.T. Corp. | Japan |
CID000105 | Tungsten | Kennametal Huntsville | United States Of America |
CID000218 | Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
CID000258 | Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
CID000568 | Tungsten | Global Tungsten & Powders Corp. | United States Of America |
CID000766 | Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
CID000769 | Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | China |
CID000825 | Tungsten | Japan New Metals Co., Ltd. | Japan |
CID000875 | Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
CID000966 | Tungsten | Kennametal Fallon | United States Of America |
CID002044 | Tungsten | Wolfram Bergbau und Hutten AG | Austria |
CID002082 | Tungsten | Xiamen Tungsten Co., Ltd. | China |
CID002315 | Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
CID002316 | Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
CID002317 | Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
CID002318 | Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
CID002319 | Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
CID002320 | Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
CID002321 | Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
CID002494 | Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
CID002502 | Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam |
CID002513 | Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
CID002541 | Tungsten | H.C. Starck Tungsten GmbH | Germany |
CID002542 | Tungsten | H.C. Starck Smelting GmbH & Co. KG | Germany |
CID002543 | Tungsten | Masan Tungsten Chemical LLC (MTC) | Viet Nam |
13
CID002551 | Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
CID002589 | Tungsten | Niagara Refining LLC | United States Of America |
CID002641 | Tungsten | China Molybdenum Co., Ltd. | China |
CID002645 | Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China |
CID002649 | Tungsten | Hydrometallurg, JSC | Russian Federation |
CID002724 | Tungsten | Unecha Refractory metals plant | Russian Federation |
CID002827 | Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
CID002830 | Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
CID002833 | Tungsten | ACL Metais Eireli | Brazil |
CID002845 | Tungsten | Moliren Ltd. | Russian Federation |
CID003388 | Tungsten | KGETS Co., Ltd. | Korea, Republic Of |
CID003401 | Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China |
CID003407 | Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China |
CID003408 | Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
CID003427 | Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
CID003416 | Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
CID003417 | Tungsten | GEM Co., Ltd. | China |
CID003468 | Tungsten | Cronimet Brasil Ltda | Brazil |
CID003609 | Tungsten | Fujian Xinlu Tungsten | China |
CID003612 | Tungsten | OOO “Technolom” 2 | Russian Federation |
CID003614 | Tungsten | OOO “Technolom” 1 | Russian Federation |
14
Countries of Origin
Below list of countries that declared smelters are known to source from:
| • |
| • | Armenia |
| • | Australia |
| • | Austria |
| • | Azerbaijan |
| • | Benin |
| • | Bolivia |
| • | Bolivia (Plurinational State of) |
| • | Botswana |
| • | Brazil |
| • | Bulgaria |
| • | Burkina Faso |
| • | Burundi |
| • | Canada |
| • | Chile |
| • | China |
| • | Colombia |
| • | Costa Rica |
| • | Cote d'Ivoire |
| • | Cuba |
| • | Cyprus |
| • | Democratic Republic of the Congo |
| • | Dominican Republic |
| • | Ecuador |
| • | Eritrea |
| • | Ethiopia |
| • | Fiji |
| • | Finland |
| • | France |
| • | French Guiana |
| • | Georgia |
| • | Germany |
| • | Ghana |
| • | Guatemala |
| • | Guinea |
| • | Guyana |
| • | Honduras |
| • | India |
| • | Indonesia |
| • | Ivory Coast |
| • | Japan |
| • | Kazakhstan |
| • | Kenya |
| • | Krygyzstan |
| • | Laos |
| • | Liberia |
| • | Madagascar |
| • | Malaysia |
| • | Mali |
| • | Mauritania |
| • |
| • | Mongolia |
| • | Montenegro |
| • | Morocco |
| • | Mozambique |
| • | Myanmar |
| • | Namibia |
| • | New Zealand |
| • | Nicaragua |
| • | Niger |
| • | Nigeria |
| • | Oman |
| • | Papua New Guinea |
| • | Peru |
| • | Philippines |
| • | Portugal |
| • | Russian Federation |
| • | Rwanda |
| • | Saudi Arabia |
| • | Senegal |
| • | Serbia |
| • | Sierra Leone |
| • | Singapore |
| • | Slovakia |
| • | Solomon Islands |
| • | South Africa |
| • | South Korea |
| • | Spain |
| • | Sudan |
| • | Suriname |
| • | Swaziland |
| • | Sweden |
| • | Taiwan |
| • | Tajikistan |
| • | Tanzania |
| • | Thailand |
| • | Turkey |
| • | Uganda |
| • | United Kingdom of Great Britain and Northern Ireland |
| • | United States of America |
| • | Uruguay |
| • | Uzbekistan |
| ��� | Venezuela |
| • | Vietnam |
| • | Zambia |
| • | Zimbabwe |
15