Exhibit 1.01
NETLIST, INC.
Conflict Minerals Report
For The Reporting Period from January 1, 2016 to December 31, 2016
This Conflict Minerals Report (the “Report”) of Netlist , Inc. (“Netlist” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2016 to December 31, 2016 (the “Reporting Period”). As permitted by applicable guidance of the Securities and Exchange Commission, the Company did not obtain an independent private sector audit within the meaning of the Rule.
Overview of the Company and the Rule
Netlist is a leading provider of high-performance modular memory subsystems serving customers in diverse industries that require superior memory performance to empower critical business decisions. The Company has a long history of introducing disruptive new products, such as one of the first load-reduced dual in-line memory module (“LRDIMM”) based on its distributed buffer architecture, which has been adopted by the industry for DDR4 LRDIMM. The Company was also one of the first to bring NAND flash memory (“NAND flash”) to the memory channel with its NVvault® non-volatile dual in-line memory modules (“NVDIMM”) using software-intensive controllers and merging dynamic random access memory integrated circuits (“DRAM ICs” or “DRAM”) and NAND flash to solve data bottleneck and data retention challenges encountered in high-performance computing environments. The Company recently introduced a new generation of storage class memory products called HybriDIMM™ to address the growing need for real-time analytics in Big Data applications and in-memory databases.
Additionally, due to the ground-breaking product development of its engineering teams, Netlist has built a robust portfolio of over 100 issued and pending U.S. and foreign patents, many seminal, in the areas of hybrid memory, storage class memory, rank multiplication and load reduction. Since its inception, the Company has dedicated substantial resources to the development and protection of technology innovations essential to its business. The Company’s early pioneering work in these areas has been broadly adopted in industry-standard LRDIMM and in NVDIMM. Netlist’s objective is to continue to innovate in its field and invest further in its intellectual property portfolio, with the goal of monetizing its intellectual property through a combination of product sales and licensing, royalty or other revenue-producing arrangements, which may result from joint development or similar partnerships or defense of the Company’s patents through enforcement actions against parties it believes are infringing them.
The Rule requires disclosure of certain information if a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The Rule also requires such companies to conduct certain inquiries reasonably designed to determine whether such minerals originated in the countries specified in the Rule. The minerals specified in the Rule, which are collectively referred to in this Report as “Conflict Minerals,” consist of gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten. The countries specified in the Rule, which are collectively referred to in this Report as “Covered Countries,” consist of the Democratic Republic of Congo (the “DRC”) and all countries that share an international border with the DRC, which presently consists of the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
As used in this Report, the term “conflict-free” means the applicable smelter or refiner has been verified as complying with the Conflict-Free Smelter Program (the “CFSP”) of the Conflict-Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”), or an equivalent third-party audit program.
Description of the Company’s Products Covered by this Report
This Report relates to the Company’s products: (i) for which Conflict Minerals are necessary to the functionality or production of the product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during the Reporting Period.
These products, which are collectively referred to in this Report as the “Covered Products,” consist of the following:
Product Families |
| Description |
NVvault™ |
| Memory Modules |
ESPRESSVault™ |
| Memory Modules |
NAND flash |
| Memory Card |
HyperCloud® |
| Memory Module |
Third-party products that the Company sells at retail but does not manufacture or contract to manufacture are outside the scope of this Report.
Description of the Company’s Reasonable Country of Origin Inquiry
As described in this Report, the Company has determined that the following Conflict Minerals were necessary to the functionality or production of the Covered Products: gold, tantalum, tin and tungsten. As a result, the Company has conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine whether any of the Conflict Minerals necessary to the functionality or production of a Covered Product originated in the Covered Countries or may be from recycled or scrap sources.
The Company’s supply chain is complex, and there are many third parties in the supply chain between the Company and the original sources of Conflict Minerals. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on its suppliers to provide information regarding the country of origin of Conflict Minerals that are necessary to the functionality or production of the Covered Products. As a result, the Company’s RCOI primarily consisted of submitting the Conflict Minerals Reporting Template (“CMRT”) prepared under the CFSI to its suppliers that the Company determined use Conflict Minerals in the manufacture of, or in, the Covered Products in the Reporting Period. Suppliers’ responses were reviewed for completeness, reasonableness and consistency, and the Company followed up with its suppliers for corrections and clarifications as needed.
Based on the RCOI, the Company was provided insufficient information to determine whether the necessary Conflict Minerals contained in the Covered Products or used in their manufacture originated from the Covered Countries or were from recycled or scrap sources. As a result, the Company has reason to believe that some of the necessary Conflict Minerals contained in the Covered Products or used in their manufacture may have originated from the Covered Countries or may not be from recycled or scrap sources.
Description of the Company’s Due Diligence Process
Based on the results of its RCOI, the Company performed additional due diligence on the source and chain of custody of the necessary Conflict Minerals contained in the Covered Products or used in their manufacture.
The Company’s due diligence measures have been designed to conform, in all material respects, to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance 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 (collectively, the “OECD Guidance”). The OECD Guidance is an internationally recognized due diligence framework.
In accordance with the five-step OECD Guidance, the design of the Company’s due diligence includes, but is not limited to, the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out an independent third-party audit of smelter/refiner’s due diligence practices and (v) reporting on supply chain due diligence. A summary of the due diligence activities undertaken by the Company in respect of each of the five steps of the OECD Guidance is described below, although the activities described below are not all of the measures performed by the Company in the Reporting Period pursuant to the Rule and the OECD Guidance.
1. Establishment of Strong Company Management Systems
Netlist completed a number of steps to establish and maintain its management system for addressing the sourcing of necessary Conflict Minerals in the Covered Products. These actions include:
a. Maintain and Publish a Conflict Minerals Policy: A copy of the Company’s Conflict Minerals Policy (the “Company Policy”), which was adopted in 2015, is available on the Company’s website at http://www.netlist.com/company/corporate-responsibility. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this Report.
Pursuant to the Company Policy, Netlist is committed to obtaining parts and supplies from businesses that share its values regarding human rights and ethical practices, and will work toward processes to help ensure that Netlist does not knowingly procure or use Conflict Minerals the extraction or sale of which finances or benefits armed groups (perpetrators of serious human rights abuses) in the Covered Countries. In addition, the Company Policy provides that Netlist expects its suppliers to, among other things, undertake documented due diligence and develop policies to
ensure that Conflict Minerals are being sourced only from outside the Covered Countries or from mines and smelters that have been certified by an independent third party or under a third-party audit program, such as the CFSP.
b. Internal Management to Support Supply Chain Due Diligence: Members of Netlist’s management (the “Conflict Minerals Team”) participate in the design and execution of the Company Policy and cooperate to manage and support the Company’s supply chain due diligence. The Conflict Minerals Team identified the suppliers to be contacted, and adopted and approved for use the CMRT discussed above. The Company interacts with its suppliers to obtain updated and current CMRTs and analyze the information provided by each supplier on the sourcing of the necessary Conflict Minerals contained in the Covered Products or used in their manufacture. Each response is reviewed to identify missing information and unclear responses. Netlist’s Conflict Minerals Team meets regularly to discuss the results of the Company’s due diligence efforts and appropriate follow-up measures to be taken with its suppliers.
c. Controls and Transparency to Support Supply Chain Diligence: The Company uses the CMRT to identify the smelters and refiners that are in the supply chain of each of its suppliers. The Company periodically reviews and compares this list to the list of smelters and refiners identified by the CFSI as being validated under the CFSP. This enables Netlist to identify the smelters and refiners that have been determined to be conflict-free and those that are actively progressing toward that status. The Company determined that this approach represents the most reasonable effort it can make to determine whether the necessary Conflict Minerals contained in the Covered Products or used in their manufacture are conflict-free.
d. Supplier Engagement: The Company is dependent upon its suppliers to identify the sources and status of the necessary Conflict Minerals contained in the Covered Products or used in their manufacture and to encourage each smelter and refinery in its supply chain to become an active participant in the CFSI. Netlist engages with its suppliers to strengthen its relationship with them and Netlist has communicated to its suppliers its commitment to sourcing Conflict Minerals in a manner that is CFSP-compliant.
2. Identification and Assessment of Risks in the Supply Chain
Because of Netlist’s position within its supply chain, it is difficult for Netlist to identify actors upstream from its suppliers. As discussed above, Netlist identified each of its suppliers and Netlist has relied upon them to provide it with the necessary information about the source of necessary Conflict Minerals contained in the Covered Products or used in their manufacture. Netlist’s suppliers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of such Conflict Minerals.
Netlist requested each of its suppliers to complete the CMRT and review the sourcing information provided in response to its requests for accuracy and completeness. In the event Netlist finds the responses to the CMRT unclear or incomplete, it contacts the supplier in question for additional information and clarification. Netlist makes efforts to contact each of its suppliers at least once every six months to check on the status of their continuing due diligence and to obtain updated information. The Company records all information obtained from the CMRTs to identify the smelters and refiners in its supply chain. The Company also compares the list of the smelters and refiners in its supply chain to the lists compiled by the CFSI to determine which smelters have been determined to be compliant with the CFSP.
3. Designing and Implementing a Strategy to Respond to Identified Risks
In response to its risk assessment, the Company has developed and maintained a risk management plan that establishes supplier risk management strategies, including maintaining regular communication with its suppliers, following up with suppliers as needed and obtaining information from the CFSI to identify smelters that are CFSP-compliant. This risk management plan is managed and monitored through the Company’s Conflict Minerals Team under the oversight of its manufacturing management.
In addition, Netlist has communicated to all of Netlist’s suppliers its expectation that products and components supplied to Netlist contain Conflict Minerals that do not originate from the Covered Countries or are otherwise conflict-free.
4. Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
The Company does not have a direct relationship with any smelters or refiners in its supply chain and, as a result, the Company does not directly conduct audits. Instead, Netlist will support the development and implementation of independent third-party audit programs of smelters and refiners, such as the CFSP, by encouraging its contract manufacturers and component suppliers to obtain materials from smelters and refiners that have been validated as conflict-free.
As noted above, the Company was not required to obtain, and did not obtain, an independent private sector audit within the meaning of the Rule.
5. Reporting on Supply Chain Due Diligence
Netlist is publicly filing the Form SD and this Report with the Securities and Exchange Commission, and a copy of this Report and the Form SD are publicly available on the Company’s website at http://www.netlist.com/company/corporate-responsibility. The foregoing website reference is intended to be an inactive textual reference and the contents of the Company’s website are not incorporated into this report.
This Report includes a description of the Covered Products that incorporate Conflict Minerals necessary to the functionality or production of such products, information about the Company’s RCOI methodology, the design of and activities involved in the Company’s due diligence process in conformance with the OECD Guidelines, and a list of known processing facilities in the Company’s supply chain as identified in its due diligence process.
Findings
The Company’s efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in the Covered Products with the greatest possible specificity consisted primarily of the due diligence measures described in this Report. For the Reporting Period, the Company received responses from all of its identified in-scope suppliers.
Based on the information provided by the Company’s suppliers and otherwise obtained through the Company’s due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that may have been used to process the Conflict Minerals contained in the Covered Products include the facilities listed in Tables 1 and 2 at the end of this Report. Of the processing facilities identified by the Company’s suppliers as potentially in the Company’s supply chain for the Reporting Period, 78.7% were validated as conflict-free, 18.8% had committed to participate in the CFSP or a comparable third-party audit program but have not yet completed the program, and 2.5% have not yet committed to participate in the CFSP or a comparable third-party audit program.
The results of the Company’s due diligence measures for the Reporting Period are summarized in the charts below.
Conclusions
After exercising the due diligence measures described above, the Company determined that its NAND flash products that were manufactured, or contracted to be manufactured, by the Company during the Reporting Period were conflict-free. This determination is based on the finding that all of the processing facilities identified by the Company’s suppliers as being potentially in the supply chain for these Covered Products were conflict-free. However, the Company was provided insufficient information to conclusively determine that none of the necessary Conflict Minerals contained in the other Covered Products or used in their manufacture originated from the Covered Countries or were from recycled or scrap sources. As a result, the Company determined that the Covered Products other than NAND flash are DRC conflict undeterminable, as defined under the Rule.
Future Steps
The Company aims to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Covered Products finance or benefit armed groups in the Covered Countries:
· Redistribute copies of the Company Policy to its suppliers;
· Emphasize to its suppliers that the Company expects them to respond fully and promptly to all information requests;
· Instruct its suppliers to advise the Company if they determine that any person or entity in their supply chain is directly or indirectly financing or benefiting armed groups in the Covered Countries; and
· Encourage suppliers to direct all smelters and refiners in their supply chains to participate in the CFSP or a similar third-party audit program.
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products that contain Conflict Minerals, Netlist’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals contained in or used to manufacture the Covered Products. Since Netlist does not have direct contractual or other relationships with the mines, smelters and refiners that produce Conflict Minerals, Netlist’s due diligence processes necessarily rely on the data supplied by its direct suppliers. Those direct suppliers, in turn, rely on similar information provided within their supply chains to identify the original sources of Conflict Minerals. In addition, Netlist relies on information collected and provided by independent third-party audit programs. These sources of information may yield unreliable, inaccurate or incomplete information due to a variety of factors, including human or other errors or fraudulent actions.
Forward-Looking Statements
This Report contains forward-looking statements regarding the Company’s business, products and Conflict Minerals efforts, including steps the Company intends to take to mitigate the risk that Conflict Minerals in its products finance or benefit armed groups in the
Covered Countries. Words such as “expects,” “believes,” “aims” and similar expressions or variations of such words are intended to identify forward-looking statements, but are not the exclusive means of identifying forward-looking statements in this Report. All statements made in this Report concerning future matters that are not historical are forward-looking statements. Although forward-looking statements in this Report reflect the Company’s good faith judgment, such statements can only be based on facts and assumptions currently known by the Company. Consequently, forward-looking statements are inherently subject to risks and uncertainties, and actual results and outcomes may differ materially from the results and outcomes discussed in or anticipated or implied by the forward-looking statements. Factors that could cause or contribute to such differences in results and outcomes include, among others: the risk that information reported to the Company by its suppliers, or industry information used by the Company, may be inaccurate; the risk that mines, smelters or refiners may not participate in the CFSP, which is a voluntary initiative; as well as risks related to the Company’s compliance with government regulations and policies, which, among other risks, are discussed under “Risk Factors” in the Company’s most recent Quarterly Report on Form 10-Q. Readers are urged not to place undue reliance on forward-looking statements, which speak only as of the date of this Report. The Company undertakes no obligation to revise or update any forward-looking statements in order to reflect any event or circumstance that may arise after the date of this Report.
Conflict Minerals Processing Facilities
Table 1: CFSP-Compliant
Listed below are the 319 processing facilities identified by the Company’s suppliers as potentially in the Company’s supply chain for the Reporting Period that the CFSP has reported as compliant with its audit protocols. The location information is as reported by the CFSP as of May 12, 2017.
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
1 |
| Advanced Chemical Company |
| UNITED STATES OF AMERICA |
| Gold |
2 |
| Aida Chemical Industries Co., Ltd. |
| JAPAN |
| Gold |
3 |
| Al Etihad Gold Refinery DMCC |
| UNITED ARAB EMIRATES |
| Gold |
4 |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| GERMANY |
| Gold |
5 |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| UZBEKISTAN |
| Gold |
6 |
| AngloGold Ashanti Córrego do Sítio Mineração |
| BRAZIL |
| Gold |
7 |
| AngloGold Ashanti Córrego do Sítio Mineração |
| BRAZIL |
| Gold |
8 |
| Argor-Heraeus S.A. |
| SWITZERLAND |
| Gold |
9 |
| Asahi Pretec Corp. |
| JAPAN |
| Gold |
10 |
| Asahi Refining Canada Ltd. |
| CANADA |
| Gold |
11 |
| Asahi Refining USA Inc. |
| UNITED STATES OF AMERICA |
| Gold |
12 |
| Asaka Riken Co., Ltd. |
| JAPAN |
| Gold |
13 |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
| Gold |
14 |
| AU Traders and Refiners |
| SOUTH AFRICA |
| Gold |
15 |
| Aurubis AG |
| GERMANY |
| Gold |
16 |
| Bangalore Refinery |
| INDIA |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
17 |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| PHILIPPINES |
| Gold |
18 |
| Boliden AB |
| SWEDEN |
| Gold |
19 |
| C. Hafner GmbH + Co. KG |
| GERMANY |
| Gold |
20 |
| Caridad |
| MEXICO |
| Gold |
21 |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
| Gold |
22 |
| Cendres + Métaux S.A. |
| SWITZERLAND |
| Gold |
23 |
| Chimet S.p.A. |
| ITALY |
| Gold |
24 |
| Chugai Mining |
| JAPAN |
| Gold |
25 |
| Daejin Indus Co., Ltd. |
| KOREA (REPUBLIC OF) |
| Gold |
26 |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
| Gold |
27 |
| DODUCO GmbH |
| GERMANY |
| Gold |
28 |
| Dowa |
| JAPAN |
| Gold |
29 |
| DSC (Do Sung Corporation) |
| KOREA (REPUBLIC OF) |
| Gold |
30 |
| Eco-System Recycling Co., Ltd. |
| JAPAN |
| Gold |
31 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
32 |
| Emirates Gold DMCC |
| UNITED ARAB EMIRATES |
| Gold |
33 |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CHINA |
| Gold |
34 |
| Geib Refining Corporation |
| UNITED STATES OF AMERICA |
| Gold |
35 |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
36 |
| Guangdong Jinding Gold Limited |
| CHINA |
| Gold |
37 |
| Gujarat Gold Centre |
| INDIA |
| Gold |
38 |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
| Gold |
39 |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
| Gold |
40 |
| Heimerle + Meule GmbH |
| GERMANY |
| Gold |
41 |
| Heraeus Ltd. Hong Kong |
| CHINA |
| Gold |
42 |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
| Gold |
43 |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
| Gold |
44 |
| HwaSeong CJ Co., Ltd. |
| KOREA (REPUBLIC OF) |
| Gold |
45 |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CHINA |
| Gold |
46 |
| Ishifuku Metal Industry Co., Ltd. |
| JAPAN |
| Gold |
47 |
| Istanbul Gold Refinery |
| TURKEY |
| Gold |
48 |
| Japan Mint |
| JAPAN |
| Gold |
49 |
| Jiangxi Copper Co., Ltd. |
| CHINA |
| Gold |
50 |
| Asahi Refining USA Inc. |
| UNITED STATES OF AMERICA |
| Gold |
51 |
| Asahi Refining Canada Ltd. |
| CANADA |
| Gold |
52 |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RUSSIAN FEDERATION |
| Gold |
53 |
| JSC Uralelectromed |
| RUSSIAN FEDERATION |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
54 |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
| Gold |
55 |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
| Gold |
56 |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
| Gold |
57 |
| Kazzinc |
| KAZAKHSTAN |
| Gold |
58 |
| Kennecott Utah Copper LLC |
| UNITED STATES OF AMERICA |
| Gold |
59 |
| KGHM Polska Miedź Spółka Akcyjna |
| POLAND |
| Gold |
60 |
| Kojima Chemicals Co., Ltd. |
| JAPAN |
| Gold |
61 |
| Korea Zinc Co., Ltd. |
| KOREA (REPUBLIC OF) |
| Gold |
62 |
| Kyrgyzaltyn JSC |
| KYRGYZSTAN |
| Gold |
63 |
| L’azurde Company For Jewelry |
| SAUDI ARABIA |
| Gold |
64 |
| Lingbao Gold Co., Ltd. |
| CHINA |
| Gold |
65 |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
| Gold |
66 |
| LS-NIKKO Copper Inc. |
| KOREA (REPUBLIC OF) |
| Gold |
67 |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
| Gold |
68 |
| Materion |
| UNITED STATES OF AMERICA |
| Gold |
69 |
| Matsuda Sangyo Co., Ltd. |
| JAPAN |
| Gold |
70 |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
| Gold |
71 |
| Metalor Technologies S.A. |
| SWITZERLAND |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
72 |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
| Gold |
73 |
| Metalor Technologies (Singapore) Pte., Ltd. |
| SINGAPORE |
| Gold |
74 |
| Metalor Technologies (Suzhou) Ltd. |
| CHINA |
| Gold |
75 |
| Metalor Technologies S.A. |
| SWITZERLAND |
| Gold |
76 |
| Metalor USA Refining Corporation |
| UNITED STATES OF AMERICA |
| Gold |
77 |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| MEXICO |
| Gold |
78 |
| Mitsubishi Materials Corporation |
| JAPAN |
| Gold |
79 |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
| Gold |
80 |
| MMTC-PAMP India Pvt., Ltd. |
| INDIA |
| Gold |
81 |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Gold |
82 |
| Morris and Watson |
| NEW ZEALAND |
| Gold |
83 |
| Moscow Special Alloys Processing Plant |
| RUSSIAN FEDERATION |
| Gold |
84 |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| TURKEY |
| Gold |
85 |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
| Gold |
86 |
| Nihon Material Co., Ltd. |
| JAPAN |
| Gold |
87 |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| AUSTRIA |
| Gold |
88 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
89 |
| Ohura Precious Metal Industry Co., Ltd. |
| JAPAN |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
90 |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| RUSSIAN FEDERATION |
| Gold |
91 |
| OJSC Novosibirsk Refinery |
| RUSSIAN FEDERATION |
| Gold |
92 |
| PAMP S.A. |
| SWITZERLAND |
| Gold |
93 |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
| Gold |
94 |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
| Gold |
95 |
| Western Australian Mint trading as The Perth Mint |
| AUSTRALIA |
| Gold |
96 |
| Prioksky Plant of Non-Ferrous Metals |
| RUSSIAN FEDERATION |
| Gold |
97 |
| PT Aneka Tambang (Persero) Tbk |
| INDONESIA |
| Gold |
98 |
| PX Précinox S.A. |
| SWITZERLAND |
| Gold |
99 |
| Rand Refinery (Pty) Ltd. |
| SOUTH AFRICA |
| Gold |
100 |
| Remondis Argentia B.V. |
| NETHERLANDS |
| Gold |
101 |
| Republic Metals Corporation |
| UNITED STATES OF AMERICA |
| Gold |
102 |
| Royal Canadian Mint |
| CANADA |
| Gold |
103 |
| SAAMP |
| FRANCE |
| Gold |
104 |
| Sabin Metal Corp. |
| UNITED STATES OF AMERICA |
| Gold |
105 |
| SAFINA A.S. |
| CZECH REPUBLIC |
| Gold |
106 |
| Sai Refinery |
| INDIA |
| Gold |
107 |
| Samduck Precious Metals |
| KOREA (REPUBLIC OF) |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
108 |
| Samwon Metals Corp. |
| KOREA (REPUBLIC OF) |
| Gold |
109 |
| SAXONIA Edelmetalle GmbH |
| GERMANY |
| Gold |
110 |
| Schone Edelmetaal B.V. |
| NETHERLANDS |
| Gold |
111 |
| SEMPSA Joyería Platería S.A. |
| SPAIN |
| Gold |
112 |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
| Gold |
113 |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CHINA |
| Gold |
114 |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CHINA |
| Gold |
115 |
| Singway Technology Co., Ltd. |
| TAIWAN, PROVINCE OF CHINA |
| Gold |
116 |
| So Accurate Group, Inc. |
| UNITED STATES OF AMERICA |
| Gold |
117 |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RUSSIAN FEDERATION |
| Gold |
118 |
| Solar Applied Materials Technology Corp. |
| TAIWAN, PROVINCE OF CHINA |
| Gold |
119 |
| Sumitomo Metal Mining Co., Ltd. |
| JAPAN |
| Gold |
120 |
| T.C.A S.p.A |
| ITALY |
| Gold |
121 |
| Tanaka Kikinzoku Kogyo K.K. |
| JAPAN |
| Gold |
122 |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
| Gold |
123 |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
| Gold |
124 |
| Tokuriki Honten Co., Ltd. |
| JAPAN |
| Gold |
125 |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
| Gold |
126 |
| Tony Goetz NV |
| BELGIUM |
| Gold |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
127 |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
| Gold |
128 |
| Torecom |
| KOREA (REPUBLIC OF) |
| Gold |
129 |
| Umicore Brasil Ltda. |
| BRAZIL |
| Gold |
130 |
| Umicore Precious Metals Thailand |
| THAILAND |
| Gold |
131 |
| Umicore S.A. Business Unit Precious Metals Refining |
| BELGIUM |
| Gold |
132 |
| United Precious Metal Refining, Inc. |
| UNITED STATES OF AMERICA |
| Gold |
133 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
134 |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
| Gold |
135 |
| Valcambi S.A. |
| SWITZERLAND |
| Gold |
136 |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
| Gold |
137 |
| Western Australian Mint trading as The Perth Mint |
| AUSTRALIA |
| Gold |
138 |
| WIELAND Edelmetalle GmbH |
| GERMANY |
| Gold |
139 |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
| Gold |
140 |
| Yamamoto Precious Metal Co., Ltd. |
| JAPAN |
| Gold |
141 |
| Yokohama Metal Co., Ltd. |
| JAPAN |
| Gold |
142 |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
| Gold |
143 |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CHINA |
| Gold |
144 |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CHINA |
| Gold |
145 |
| Changsha South Tantalum Niobium Co., Ltd. |
| CHINA |
| Tantalum |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
146 |
| Conghua Tantalum and Niobium Smeltry |
| CHINA |
| Tantalum |
147 |
| D Block Metals, LLC |
| UNITED STATES OF AMERICA |
| Tantalum |
148 |
| Duoluoshan |
| CHINA |
| Tantalum |
149 |
| Exotech Inc. |
| UNITED STATES OF AMERICA |
| Tantalum |
150 |
| F&X Electro-Materials Ltd. |
| CHINA |
| Tantalum |
151 |
| FIR Metals & Resource Ltd. |
| CHINA |
| Tantalum |
152 |
| Global Advanced Metals Aizu |
| JAPAN |
| Tantalum |
153 |
| Global Advanced Metals Boyertown |
| UNITED STATES OF AMERICA |
| Tantalum |
154 |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CHINA |
| Tantalum |
155 |
| H.C. Starck Co., Ltd. |
| THAILAND |
| Tantalum |
156 |
| H.C. Starck GmbH Goslar |
| GERMANY |
| Tantalum |
157 |
| H.C. Starck GmbH Laufenburg |
| GERMANY |
| Tantalum |
158 |
| H.C. Starck Hermsdorf GmbH |
| GERMANY |
| Tantalum |
159 |
| H.C. Starck Inc. |
| UNITED STATES OF AMERICA |
| Tantalum |
160 |
| H.C. Starck Ltd. |
| JAPAN |
| Tantalum |
161 |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
| Tantalum |
162 |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CHINA |
| Tantalum |
163 |
| Hi-Temp Specialty Metals, Inc. |
| UNITED STATES OF AMERICA |
| Tantalum |
164 |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CHINA |
| Tantalum |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
165 |
| Jiangxi Tuohong New Raw Material |
| CHINA |
| Tantalum |
166 |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CHINA |
| Tantalum |
167 |
| Jiujiang Tanbre Co., Ltd. |
| CHINA |
| Tantalum |
168 |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CHINA |
| Tantalum |
169 |
| KEMET Blue Metals |
| MEXICO |
| Tantalum |
170 |
| KEMET Blue Powder |
| UNITED STATES OF AMERICA |
| Tantalum |
171 |
| King-Tan Tantalum Industry Ltd. |
| CHINA |
| Tantalum |
172 |
| LSM Brasil S.A. |
| BRAZIL |
| Tantalum |
173 |
| Metallurgical Products India Pvt., Ltd. |
| INDIA |
| Tantalum |
174 |
| Mineração Taboca S.A. |
| BRAZIL |
| Tantalum |
175 |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
| Tantalum |
176 |
| Molycorp Silmet A.S. |
| ESTONIA |
| Tantalum |
177 |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CHINA |
| Tantalum |
178 |
| Plansee SE Liezen |
| AUSTRIA |
| Tantalum |
179 |
| Plansee SE Reutte |
| AUSTRIA |
| Tantalum |
180 |
| Power Resources Ltd. |
| MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
| Tantalum |
181 |
| QuantumClean |
| UNITED STATES OF AMERICA |
| Tantalum |
182 |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
| Tantalum |
183 |
| RFH Tantalum Smeltry Co., Ltd. |
| CHINA |
| Tantalum |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
184 |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
| Tantalum |
185 |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
| Tantalum |
186 |
| Taki Chemical Co., Ltd. |
| JAPAN |
| Tantalum |
187 |
| Telex Metals |
| UNITED STATES OF AMERICA |
| Tantalum |
188 |
| Tranzact, Inc. |
| UNITED STATES OF AMERICA |
| Tantalum |
189 |
| Ulba Metallurgical Plant JSC |
| KAZAKHSTAN |
| Tantalum |
190 |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CHINA |
| Tantalum |
191 |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CHINA |
| Tantalum |
192 |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CHINA |
| Tantalum |
193 |
| Alpha |
| UNITED STATES OF AMERICA |
| Tin |
194 |
| An Thai Minerals Co., Ltd. |
| VIET NAM |
| Tin |
195 |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
| Tin |
196 |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CHINA |
| Tin |
197 |
| China Tin Group Co., Ltd. |
| CHINA |
| Tin |
198 |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CHINA |
| Tin |
199 |
| Cooperativa Metalurgica de Rondônia Ltda. |
| BRAZIL |
| Tin |
200 |
| CV Ayi Jaya |
| INDONESIA |
| Tin |
201 |
| CV Dua Sekawan |
| INDONESIA |
| Tin |
202 |
| CV Gita Pesona |
| INDONESIA |
| Tin |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
203 |
| CV Serumpun Sebalai |
| INDONESIA |
| Tin |
204 |
| CV Tiga Sekawan |
| INDONESIA |
| Tin |
205 |
| CV United Smelting |
| INDONESIA |
| Tin |
206 |
| CV Venus Inti Perkasa |
| INDONESIA |
| Tin |
207 |
| Dowa |
| JAPAN |
| Tin |
208 |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
| Tin |
209 |
| Elmet S.L.U. |
| SPAIN |
| Tin |
210 |
| EM Vinto |
| BOLIVIA (PLURINATIONAL STATE OF) |
| Tin |
211 |
| Estanho de Rondônia S.A. |
| BRAZIL |
| Tin |
212 |
| Fenix Metals |
| POLAND |
| Tin |
213 |
| Gejiu Fengming Metallurgy Chemical Plant |
| CHINA |
| Tin |
214 |
| Gejiu Jinye Mineral Company |
| CHINA |
| Tin |
215 |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
| Tin |
216 |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CHINA |
| Tin |
217 |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
| Tin |
218 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
| Tin |
219 |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CHINA |
| Tin |
220 |
| HuiChang Hill Tin Industry Co., Ltd. |
| CHINA |
| Tin |
221 |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
| Tin |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
222 |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| CHINA |
| Tin |
223 |
| Magnu’s Minerais Metais e Ligas Ltda. |
| BRAZIL |
| Tin |
224 |
| Malaysia Smelting Corporation (MSC) |
| MALAYSIA |
| Tin |
225 |
| Melt Metais e Ligas S.A. |
| BRAZIL |
| Tin |
226 |
| Metallic Resources, Inc. |
| UNITED STATES OF AMERICA |
| Tin |
227 |
| Metallo-Chimique N.V. |
| BELGIUM |
| Tin |
228 |
| Mineração Taboca S.A. |
| BRAZIL |
| Tin |
229 |
| Minsur |
| PERU |
| Tin |
230 |
| Mitsubishi Materials Corporation |
| JAPAN |
| Tin |
231 |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Tin |
232 |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CHINA |
| Tin |
233 |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Tin |
234 |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| THAILAND |
| Tin |
235 |
| O.M. Manufacturing Philippines, Inc. |
| PHILIPPINES |
| Tin |
236 |
| Operaciones Metalurgical S.A. |
| BOLIVIA (PLURINATIONAL STATE OF) |
| Tin |
237 |
| Phoenix Metal Ltd. |
| RWANDA |
| Tin |
238 |
| PT Aries Kencana Sejahtera |
| INDONESIA |
| Tin |
239 |
| PT Artha Cipta Langgeng |
| INDONESIA |
| Tin |
240 |
| PT ATD Makmur Mandiri Jaya |
| INDONESIA |
| Tin |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
241 |
| PT Babel Inti Perkasa |
| INDONESIA |
| Tin |
242 |
| PT Bangka Prima Tin |
| INDONESIA |
| Tin |
243 |
| PT Bangka Tin Industry |
| INDONESIA |
| Tin |
244 |
| PT Belitung Industri Sejahtera |
| INDONESIA |
| Tin |
245 |
| PT Bukit Timah |
| INDONESIA |
| Tin |
246 |
| PT Cipta Persada Mulia |
| INDONESIA |
| Tin |
247 |
| PT DS Jaya Abadi |
| INDONESIA |
| Tin |
248 |
| PT Eunindo Usaha Mandiri |
| INDONESIA |
| Tin |
249 |
| PT Inti Stania Prima |
| INDONESIA |
| Tin |
250 |
| PT Justindo |
| INDONESIA |
| Tin |
251 |
| PT Karimun Mining |
| INDONESIA |
| Tin |
252 |
| PT Kijang Jaya Mandiri |
| INDONESIA |
| Tin |
253 |
| PT Mitra Stania Prima |
| INDONESIA |
| Tin |
254 |
| PT O.M. Indonesia |
| INDONESIA |
| Tin |
255 |
| PT Panca Mega Persada |
| INDONESIA |
| Tin |
256 |
| PT Prima Timah Utama |
| INDONESIA |
| Tin |
257 |
| PT Refined Bangka Tin |
| INDONESIA |
| Tin |
258 |
| PT Stanindo Inti Perkasa |
| INDONESIA |
| Tin |
259 |
| PT Sukses Inti Makmur |
| INDONESIA |
| Tin |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
260 |
| PT Sumber Jaya Indah |
| INDONESIA |
| Tin |
261 |
| PT Timah (Persero) Tbk Kundur |
| INDONESIA |
| Tin |
262 |
| PT Timah (Persero) Tbk Mentok |
| INDONESIA |
| Tin |
263 |
| PT Tinindo Inter Nusa |
| INDONESIA |
| Tin |
264 |
| PT Tommy Utama |
| INDONESIA |
| Tin |
265 |
| PT Wahana Perkit Jaya |
| INDONESIA |
| Tin |
266 |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
| Tin |
267 |
| Rui Da Hung |
| TAIWAN, PROVINCE OF CHINA |
| Tin |
268 |
| Soft Metais Ltda. |
| BRAZIL |
| Tin |
269 |
| Thaisarco |
| THAILAND |
| Tin |
270 |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Tin |
271 |
| VQB Mineral and Trading Group JSC |
| VIET NAM |
| Tin |
272 |
| White Solder Metalurgia e Mineração Ltda. |
| BRAZIL |
| Tin |
273 |
| Yunnan Tin Company Limited |
| CHINA |
| Tin |
274 |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
| Tin |
275 |
| ACL Metais Eireli |
| BRAZIL |
| Tungsten |
276 |
| A.L.M.T. TUNGSTEN Corp. |
| JAPAN |
| Tungsten |
277 |
| Asia Tungsten Products Vietnam Ltd. |
| VIET NAM |
| Tungsten |
278 |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CHINA |
| Tungsten |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
279 |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
280 |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
281 |
| Dayu Weiliang Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
282 |
| Fujian Jinxin Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
283 |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CHINA |
| Tungsten |
284 |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CHINA |
| Tungsten |
285 |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CHINA |
| Tungsten |
286 |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
287 |
| Global Tungsten & Powders Corp. |
| UNITED STATES OF AMERICA |
| Tungsten |
288 |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
289 |
| H.C. Starck GmbH |
| GERMANY |
| Tungsten |
290 |
| H.C. Starck Smelting GmbH & Co.KG |
| GERMANY |
| Tungsten |
291 |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
| Tungsten |
292 |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CHINA |
| Tungsten |
293 |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CHINA |
| Tungsten |
294 |
| Hydrometallurg, JSC |
| RUSSIAN FEDERATION |
| Tungsten |
295 |
| Japan New Metals Co., Ltd. |
| JAPAN |
| Tungsten |
296 |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CHINA |
| Tungsten |
297 |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
298 |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
299 |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CHINA |
| Tungsten |
300 |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CHINA |
| Tungsten |
301 |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CHINA |
| Tungsten |
302 |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| CHINA |
| Tungsten |
303 |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
304 |
| Kennametal Fallon |
| UNITED STATES OF AMERICA |
| Tungsten |
305 |
| Kennametal Huntsville |
| UNITED STATES OF AMERICA |
| Tungsten |
306 |
| Malipo Haiyu Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
307 |
| Moliren Ltd |
| RUSSIAN FEDERATION |
| Tungsten |
308 |
| Niagara Refining LLC |
| UNITED STATES OF AMERICA |
| Tungsten |
309 |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| VIET NAM |
| Tungsten |
310 |
| Philippine Chuangxin Industrial Co., Inc. |
| PHILIPPINES |
| Tungsten |
311 |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CHINA |
| Tungsten |
312 |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| VIET NAM |
| Tungsten |
313 |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| VIET NAM |
| Tungsten |
314 |
| Wolfram Bergbau und Hütten AG |
| AUSTRIA |
| Tungsten |
315 |
| Woltech Korea Co., Ltd. |
| KOREA (REPUBLIC OF) |
| Tungsten |
316 |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CHINA |
| Tungsten |
No |
| Smelter Reference List (*) |
| Smelter Country (*) |
| Metal (*) |
317 |
| Xiamen Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
318 |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CHINA |
| Tungsten |
319 |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
Table2: Not CFSP-Validated
Listed below are the 68 processing facilities identified by the Company’s suppliers as potentially in the Company’s supply chain for the Reporting Period that have not been validated as CFSP-compliant. The “Active” column indicates whether the processing facility has committed to participate in the CFSP or a comparable third-party audit program. The location information and “Active” status are as reported by the CFSP as of May 12, 2017.
No |
| Smelter |
| Smelter Country (*) |
| Metal (*) |
| Active |
1 |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
| Gold |
| x |
2 |
| Bangalore Refinery |
| INDIA |
| Gold |
| x |
3 |
| Caridad |
| MEXICO |
| Gold |
| x |
4 |
| Cendres + Métaux S.A. |
| SWITZERLAND |
| Gold |
| x |
5 |
| Chugai Mining |
| JAPAN |
| Gold |
| x |
6 |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
| Gold |
| x |
7 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
| x |
8 |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CHINA |
| Gold |
| x |
9 |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
| Gold |
| x |
10 |
| Guangdong Jinding Gold Limited |
| CHINA |
| Gold |
| x |
11 |
| Gujarat Gold Centre |
| INDIA |
| Gold |
| x |
12 |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
| Gold |
| x |
13 |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
| Gold |
| x |
14 |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
| Gold |
| x |
15 |
| HwaSeong CJ Co., Ltd. |
| KOREA (REPUBLIC OF) |
| Gold |
| x |
16 |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
| Gold |
| x |
17 |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
| Gold |
| x |
18 |
| KGHM Polska Miedź Spółka Akcyjna |
| POLAND |
| Gold |
| x |
19 |
| L’azurde Company For Jewelry |
| SAUDI ARABIA |
| Gold |
| x |
20 |
| Lingbao Gold Co., Ltd. |
| CHINA |
| Gold |
| x |
21 |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
| Gold |
| x |
22 |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
| Gold |
| x |
23 |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Gold |
| x |
24 |
| Morris and Watson |
| NEW ZEALAND |
| Gold |
| x |
25 |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
| Gold |
| x |
26 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
| x |
27 |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
| Gold |
| x |
No |
| Smelter |
| Smelter Country (*) |
| Metal (*) |
| Active |
28 |
| Remondis Argentia B.V. |
| NETHERLANDS |
| Gold |
| x |
29 |
| SAAMP |
| FRANCE |
| Gold |
| x |
30 |
| Sabin Metal Corp. |
| UNITED STATES OF AMERICA |
| Gold |
| x |
31 |
| SAFINA A.S. |
| CZECH REPUBLIC |
| Gold |
| x |
32 |
| Sai Refinery |
| INDIA |
| Gold |
| x |
33 |
| Samwon Metals Corp. |
| KOREA (REPUBLIC OF) |
| Gold |
| x |
34 |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
| Gold |
| x |
35 |
| So Accurate Group, Inc. |
| UNITED STATES OF AMERICA |
| Gold |
| x |
36 |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
| Gold |
| x |
37 |
| Tony Goetz NV |
| BELGIUM |
| Gold |
| x |
38 |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
| Gold |
| x |
39 |
| Elemetal Refining, LLC |
| UNITED STATES OF AMERICA |
| Gold |
| x |
40 |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
| Gold |
| x |
41 |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
| Gold |
| x |
42 |
| H.C. Starck GmbH Laufenburg |
| GERMANY |
| Tantalum |
|
|
43 |
| Plansee SE Liezen |
| AUSTRIA |
| Tantalum |
|
|
44 |
| Plansee SE Reutte |
| AUSTRIA |
| Tantalum |
|
|
45 |
| Tranzact, Inc. |
| UNITED STATES OF AMERICA |
| Tantalum |
|
|
46 |
| An Thai Minerals Co., Ltd. |
| VIET NAM |
| Tin |
| x |
47 |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
| Tin |
| x |
48 |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CHINA |
| Tin |
| x |
49 |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
| Tin |
| x |
50 |
| Estanho de Rondônia S.A. |
| BRAZIL |
| Tin |
| x |
51 |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
| Tin |
| x |
52 |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
| Tin |
| x |
53 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
| Tin |
| x |
54 |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
| Tin |
| x |
55 |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Tin |
| x |
56 |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CHINA |
| Tin |
| x |
57 |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Tin |
| x |
No |
| Smelter |
| Smelter Country (*) |
| Metal (*) |
| Active |
58 |
| Phoenix Metal Ltd. |
| RWANDA |
| Tin |
|
|
59 |
| PT Cipta Persada Mulia |
| INDONESIA |
| Tin |
|
|
60 |
| PT Justindo |
| INDONESIA |
| Tin |
|
|
61 |
| PT Wahana Perkit Jaya |
| INDONESIA |
| Tin |
|
|
62 |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Tin |
| x |
63 |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
| Tin |
| x |
64 |
| ACL Metais Eireli |
| BRAZIL |
| Tungsten |
| x |
65 |
| Dayu Weiliang Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
| x |
66 |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
| x |
67 |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CHINA |
| Tungsten |
| x |
68 |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CHINA |
| Tungsten |
| x |