Exhibit 1.01
Inogen, Inc.
Conflict Minerals Report
For The Reporting Period from January 1, 2018 to December 31, 2018
Cautionary Note Concerning Forward-Looking Statements: This Conflict Minerals Report contains forward-looking statements within the meaning of federal securities laws. These forward-looking statements include statements concerning Inogen’s objectives for its conflict minerals policy and compliance initiatives and actions it intends to take relating to conflict minerals. Forward-looking statements involve substantial risks and uncertainties that could cause actual results to differ materially from currently anticipated results. When considering forward-looking statements, you should consider, among other factors, the risk factors described in the reports and other filings that Inogen files with the United States Securities and Exchange Commission, including Inogen’s Annual Report on Form 10-K for the year ended December 31, 2018 and its subsequent Quarterly Reports on Form 10-Q. The risk factors included in these filings are not exhaustive, and risks that are not identified therein could materially affect whether Inogen realizes the results anticipated or implied by any forward-looking statements contained in this Conflict Minerals Report. Except as required by law, Inogen disclaims any obligation to update these forward-looking statements, whether as a result of new information, future events, or otherwise.
Introduction
This Conflict Minerals Report (this “Report”) for Inogen, Inc. (“Inogen” or “we” or “our”) covers the reporting period from January 1, 2018 to December 31, 2018 and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). This Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD (the “Form SD”). A copy of this Report and the Form SD are publicly available on our website at http://investor.inogen.com/. Information contained on, or that can be accessed through, our website, does not constitute part of this Report and inclusion of our website address in this Report is an inactive textual reference only.
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1502 of the Act relates to conflict minerals and requires companies subject to the Act to file a Form SD annually with the United States Securities and Exchange Commission (“SEC”) to disclose whether the minerals specified in Rule 13p-1 and their derivatives, limited to tungsten, tantalum, tin, and gold (referred to as the “3TG”), used in their products benefitted, directly or indirectly, armed groups in the Democratic Republic of the Congo and adjoining countries (collectively, the “Covered Countries”). This Report, which is an exhibit to our Form SD, describes the design and implementation of our conflict minerals due diligence measures undertaken, including a description of how these measures were designed to determine, to our knowledge, the source mines, countries of origin, and processing facilities for 3TG contained in components used in our products.
Inogen Background and Covered Products
We are a medical technology company that primarily develops, manufactures and markets innovative portable oxygen concentrators used to deliver supplemental long-term oxygen therapy to patients suffering from chronic respiratory conditions. We manufacture our Inogen One systems and Inogen At Home systems at our facility in Richardson, Texas and compressors at our facility in Goleta, California. We began production of our Inogen One G3 concentrator using a contract manufacturer, Foxconn, located in the Czech Republic in the fourth quarter of 2017. In the United States, we market and distribute our products directly to consumers, through a wide variety of direct-to-consumer marketing strategies including a physician referral model, as well as through distributors, resellers, private label partners, and home medical equipment providers. In addition, we sell through distributors, resellers, and home medical equipment providers in certain markets within Europe, the Asia-Pacific region, Latin America, the Middle East, and Africa. Our manufacturing operations require a wide variety of raw materials that we rely on third-party manufacturers to supply.
We have determined that one or more of the 3TG may be necessary to the functionality or production of the oxygen concentrators we manufactured during 2018, including our Inogen One G2, Inogen One G3, Inogen One G4 and Inogen At Home. As a result, all of our concentrators are considered “covered products” for purposes of this Report.
Our supply chain with respect to the covered products is complex, and there are many third-parties in the supply chain between the original source of the 3TG and the manufacturer of the covered products. We do not purchase raw ore or unrefined 3TG directly and make no purchases in the Covered Countries. As a result and as described more fully below, we rely on our suppliers to provide information on the origin of the conflict minerals contained in our products.
Inogen Reasonable Country of Origin Inquiry
In accordance with Rule 13p-1 and Form SD, we determined that one or more of the 3TG may be necessary to the functionality or production of our oxygen concentrators and that such 3TG are incorporated into our products during the manufacturing process. Accordingly, we undertook a reasonable country of origin inquiry (“RCOI”). This good faith RCOI was reasonably designed to determine whether any of the 3TG incorporated into our products originated in the Covered Countries.
Our RCOI consisted principally of submitting the conflict minerals reporting template (the “RMI Template”) prepared by the Responsible Minerals Initiative (“RMI”), formerly the Conflict-Free Sourcing Initiative (“CFSI”), an initiative of the Responsible Business Alliance, to suppliers of components for our products that are considered necessary to the functionality or production of our products and for which any 3TG or their derivatives may be included (“first-tier suppliers”). We reviewed all responses for completeness, reasonableness, and consistency, and we followed up for corrections and clarifications as we determined appropriate.
Inogen’s Due Diligence Process
Our due diligence measures were designed to conform, in all material respects, with the framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”). The objectives of our diligence initiative were to determine, to the best of our ability, whether one or more of the 3TG is incorporated into our products; whether any such 3TG incorporated into our products was necessary for the functionality and/or production of our products; the source and chain of custody of the 3TG necessary for the functionality and/or production of our products; and whether any such 3TG originated in the Covered Countries. In the event that 3TG from the Covered Countries which benefit armed groups are found in our supply chain, we will take appropriate actions in a timely manner to resolve the situation.
Due diligence measures that we implemented included, but were not limited, to the following:
| 1. | Establishment of Internal Management Systems |
| a. | Conflict Minerals Policy. In 2015, we adopted a written policy relating to the use of conflict minerals in our supply chain, which we reviewed and updated in 2017. We have communicated this written policy to each of our first-tier suppliers. A copy of Inogen’s Conflict Minerals Policy is publicly available at http://investor.inogen.com/govdocs. |
| b. | Internal Management to Support Supply Chain Due Diligence. The Inogen finance department has been charged with the management of our conflict minerals program, working in collaboration with members from our operations team in California and Texas and our contract manufacturer in the Czech Republic. |
| c. | Controls and Transparency. As described above, we undertook a RCOI with respect to conflict minerals in our supply chain by providing the RMI Template to each of our first-tier suppliers to gather information about their use of 3TG, the smelters and refiners in their supply chain that are included in our products, and the countries of origin for 3TG used in our products. We reviewed all responses for completeness, reasonableness, and consistency. We followed up for corrections and clarifications as we determined appropriate. |
| e. | Grievance Mechanism. Our code of conduct includes procedures for reporting violations of our policies, and we provide mechanisms for anonymous reporting of violations or concerns about the conduct of our business, including the implementation and enforcement of our Conflict Minerals Policy. |
| 2. | Identification and Assessment of Risks in the Supply Chain |
As discussed above, we identified our first-tier suppliers and relied on them to provide the necessary information about the use of 3TG in the products we purchase and incorporate into the manufacture of our oxygen concentrators, and the source of such 3TG. Similarly, our first-tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG included in our products.
| 3. | Designing and Implementing a Strategy to Respond to Identified Risks |
We will review circumstances in which certain suppliers are unable to provide us with complete or reliable responses to the RMI Template including, without limitation, considering whether to continue such contract or relationship or find a replacement supplier.
| 4. | Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We do not have a direct relationship with any smelters or refiners in our supply chain. As a result, we do not and cannot conduct any audits directly. Instead, we have supported the development and implementation of independent third-party audits of smelters such as the Responsible Minerals Assurance Program (“RMAP”) by encouraging our suppliers to purchase materials from audited, conflict-free smelters and determining whether the smelters that were used to process these minerals were validated as conflict-free by the RMAP.
| 5. | Reporting on Supply Chain Due Diligence |
We publicly filed the Form SD and this Report with the SEC. A copy of this Report and the Form SD are publicly available at http://investor.inogen.com/. This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Framework, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our products that incorporate 3TG necessary to the functionality or production of such products.
Smelters and Refiners in Inogen’s Supply Chain
We adopted RMI’s industry approach to trace back the origin of 3TG by identifying smelters, refineries, or recyclers and scrap supplier sources. We have leveraged industry initiatives such as the RMAP, which is a voluntary initiative in which an independent third-party audits smelters and refineries to determine if all of the minerals processed by the smelter or refiner originated from conflict free sources. Participation in the RMAP provides us with verified information about the sourcing activities of the smelters and refiners in our supply chain.
As discussed above, we submitted the RMI Template to our first-tier suppliers. Most of the responses received from our first-tier suppliers provided information at company/division levels, rather than specific product/part number levels. As a result, we were unable to determine whether or to what extent any of the 3TG reported as used by these first-tier suppliers was contained specifically in components supplied to us. We also were unable to validate whether the smelters or refiners reported by such first-tier suppliers are actually in our supply chain. Accordingly, based on information that was provided by our first-tier suppliers or that was otherwise obtained through our due diligence process, we are unable to determine and describe all facilities used to process the 3TG contained in our covered products.
Based on the information that was provided by our suppliers and otherwise obtained through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the 3TG contained in the covered products included the smelters and refiners listed in Annex A attached hereto. This table includes only facilities that are listed in the RMI Smelter Reference List as of May 30, 2019. An indication of “Compliant” in the far right column of the table indicates that the smelter or refinery has received a “conflict free” designation from an independent third-party audit program or is presently undergoing a re-audit to maintain its “conflict free” designation. An indication of “In Process” in the far right column of the table indicates that the smelter or refinery has not yet received a “conflict free” designation, but is undergoing an audit process that will determine such status. An indication of “Unknown” in the far right column of the table indicates that the smelter or refinery was not included in the RMI compliant or active lists and thus the facility’s designation is undeterminable.
Because the RMI Smelter Reference List generally did not indicate individual countries of origin of the conflict minerals processed by smelters and refiners, we were not able to determine the countries of origin of the 3TG processed by the listed smelters and refiners with greater specificity. Furthermore, as stated earlier, submission of these smelters by our first-tier suppliers does not guarantee that these smelters or refiners are present in the Company’s supply chain as our first-tier suppliers were generally only able to provide company-level RMI Templates and not able to provide product-level RMI Templates directly linking those smelters or refiners to the covered products. Therefore, based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the 3TG contained in the covered products.
The statements above are based on the RCOI process and due diligence performed in good faith by Inogen. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our 3TG status. These factors include, but are not limited to, gaps in supplier data; gaps in smelter data; errors or omissions by suppliers; errors or omissions by smelters; the definition of a smelter not being finalized at the end of the 2018 reporting period; all instances of 3TG necessary to the functionality or manufacturing of our products not yet having been identified; gaps in supplier education and knowledge; timeliness of data; public information not discovered during a reasonable search; errors in public data; language barriers and translation; supplier and smelter unfamiliarity with the protocols for identifying and sourcing potential 3TG; oversight or errors in conflict free smelter audits; Covered Countries sourced materials being declared secondary materials; companies going out of business in 2018; certification programs being not equally advanced for all industry segments and metals; and smuggling of 3TG from the Covered Countries to other countries.
We have communicated our expectations to our first-tier suppliers regarding our commitment to sourcing minerals for our products in a manner that does not, directly or indirectly, finance or benefit armed groups in the Democratic Republic of the Congo or adjoining countries. We expect to continue to increase our engagement with our relevant suppliers over the next year to build their knowledge and capacity so they are able to provide us with more complete and accurate information on the source and chain of custody of the 3TG included in components and parts purchased by us and incorporated into our products.
2018 Facility and Country List
Metal |
| Smelter |
| Country |
| Compliance Status |
Gold |
| 8853 S.p.A. |
| ITALY |
| Compliant |
Gold |
| Abington Reldan Metals, LLC |
| UNITED STATES OF AMERICA |
| Unknown |
Gold |
| Advanced Chemical Company |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| African Gold Refinery |
| UGANDA |
| Unknown |
Gold |
| Aida Chemical Industries Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Al Etihad Gold Refinery DMCC |
| UNITED ARAB EMIRATES |
| Compliant |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| GERMANY |
| Compliant |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| UZBEKISTAN |
| Compliant |
Gold |
| AngloGold Ashanti Corrego do Sitio Mineracao |
| BRAZIL |
| Compliant |
Gold |
| Argor-Heraeus S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| Asahi Pretec Corp. |
| JAPAN |
| Compliant |
Gold |
| Asahi Refining Canada Ltd. |
| CANADA |
| Compliant |
Gold |
| Asahi Refining USA Inc. |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| Asaka Riken Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
| Unknown |
Gold |
| AU Traders and Refiners |
| SOUTH AFRICA |
| Compliant |
Gold |
| Aurubis AG |
| GERMANY |
| Compliant |
Gold |
| Bangalore Refinery |
| INDIA |
| Compliant |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| PHILIPPINES |
| Compliant |
Gold |
| Boliden AB |
| SWEDEN |
| Compliant |
Gold |
| C. Hafner GmbH + Co. KG |
| GERMANY |
| Compliant |
Gold |
| Caridad |
| MEXICO |
| Unknown |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
| Compliant |
Gold |
| Cendres + Metaux S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| Chimet S.p.A. |
| ITALY |
| Compliant |
Gold |
| Chugai Mining |
| JAPAN |
| In Process |
Gold |
| Daejin Indus Co., Ltd. |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
| Unknown |
Gold |
| Degussa Sonne / Mond Goldhandel GmbH |
| GERMANY |
| Unknown |
Gold |
| DODUCO Contacts and Refining GmbH |
| GERMANY |
| Compliant |
Gold |
| Dowa |
| JAPAN |
| Compliant |
Gold |
| DS PRETECH Co., Ltd. |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| DSC (Do Sung Corporation) |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| Eco-System Recycling Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Emirates Gold DMCC |
| UNITED ARAB EMIRATES |
| Compliant |
Gold |
| Fidelity Printers and Refiners Ltd. |
| ZIMBABWE |
| Unknown |
Gold |
| GCC Gujrat Gold Centre Pvt. Ltd. |
| INDIA |
| Unknown |
Gold |
| Geib Refining Corporation |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| Gold Refinery of Zijin Mining Group Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
| Unknown |
Gold |
| Guangdong Jinding Gold Limited |
| CHINA |
| Unknown |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
| Unknown |
Metal |
| Smelter |
| Country |
| Compliance Status |
| HeeSung Metal Ltd. |
| KOREA, REPUBLIC OF |
| Compliant | |
Gold |
| Heimerle + Meule GmbH |
| GERMANY |
| Compliant |
Gold |
| Heraeus Metals Hong Kong Ltd. |
| CHINA |
| Compliant |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
| Compliant |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| HwaSeong CJ CO., LTD. |
| KOREA, REPUBLIC OF |
| Unknown |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Istanbul Gold Refinery |
| TURKEY |
| Compliant |
Gold |
| Italpreziosi |
| ITALY |
| Compliant |
Gold |
| Japan Mint |
| JAPAN |
| Compliant |
Gold |
| Jiangxi Copper Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RUSSIAN FEDERATION |
| Unknown |
Gold |
| JSC Uralelectromed |
| RUSSIAN FEDERATION |
| Compliant |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
| Unknown |
Gold |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
| Unknown |
Gold |
| Kazzinc |
| KAZAKHSTAN |
| Compliant |
Gold |
| Kennecott Utah Copper LLC |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| KGHM Polska Miedz Spolka Akcyjna |
| POLAND |
| Compliant |
Gold |
| Kojima Chemicals Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Korea Zinc Co., Ltd. |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| Kyrgyzaltyn JSC |
| KYRGYZSTAN |
| Compliant |
Gold |
| Kyshtym Copper-Electrolytic Plant ZAO |
| RUSSIAN FEDERATION |
| Unknown |
Gold |
| L'azurde Company For Jewelry |
| SAUDI ARABIA |
| Unknown |
Gold |
| Lingbao Gold Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| L'Orfebre S.A. |
| ANDORRA |
| Compliant |
Gold |
| LS-NIKKO Copper Inc. |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Marsam Metals |
| BRAZIL |
| Compliant |
Gold |
| Materion |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| Matsuda Sangyo Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
| Compliant |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| SINGAPORE |
| Compliant |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CHINA |
| Compliant |
Gold |
| Metalor Technologies S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| Metalor USA Refining Corporation |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| Metalurgica Met-Mex Penoles S.A. De C.V. |
| MEXICO |
| Compliant |
Gold |
| Mitsubishi Materials Corporation |
| JAPAN |
| Compliant |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| INDIA |
| Compliant |
Gold |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Unknown |
Gold |
| Morris and Watson |
| NEW ZEALAND |
| Unknown |
Gold |
| Morris and Watson Gold Coast |
| AUSTRALIA |
| Unknown |
Gold |
| Moscow Special Alloys Processing Plant |
| RUSSIAN FEDERATION |
| Compliant |
Metal |
| Smelter |
| Country |
| Compliance Status |
| Nadir Metal Rafineri San. Ve Tic. A.S. |
| TURKEY |
| Compliant | |
Gold |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
| Unknown |
Gold |
| NH Recytech Company |
| KOREA, REPUBLIC OF |
| In Process |
Gold |
| Nihon Material Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| AUSTRIA |
| Compliant |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
| RUSSIAN FEDERATION |
| Compliant |
Gold |
| OJSC Novosibirsk Refinery |
| RUSSIAN FEDERATION |
| Compliant |
Gold |
| PAMP S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| Pease & Curren |
| UNITED STATES OF AMERICA |
| Unknown |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Planta Recuperadora de Metales SpA |
| CHILE |
| Compliant |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| RUSSIAN FEDERATION |
| Compliant |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| INDONESIA |
| Compliant |
Gold |
| PX Precinox S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| QG Refining, LLC |
| UNITED STATES OF AMERICA |
| Unknown |
Gold |
| Rand Refinery (Pty) Ltd. |
| SOUTH AFRICA |
| Compliant |
Gold |
| Refinery of Seemine Gold Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| REMONDIS PMR B.V. |
| NETHERLANDS |
| Compliant |
Gold |
| Royal Canadian Mint |
| CANADA |
| Compliant |
Gold |
| SAAMP |
| FRANCE |
| Compliant |
Gold |
| Sabin Metal Corp. |
| UNITED STATES OF AMERICA |
| Unknown |
Gold |
| Safimet S.p.A |
| ITALY |
| Compliant |
Gold |
| SAFINA A.S. |
| CZECH REPUBLIC |
| Unknown |
Gold |
| Sai Refinery |
| INDIA |
| Unknown |
Gold |
| Samduck Precious Metals |
| KOREA, REPUBLIC OF |
| Unknown |
Gold |
| Samwon Metals Corp. |
| KOREA, REPUBLIC OF |
| Unknown |
Gold |
| SAXONIA Edelmetalle GmbH |
| GERMANY |
| Compliant |
Gold |
| SEMPSA Joyeria Plateria S.A. |
| SPAIN |
| Compliant |
Gold |
| Shandong Humon Smelting Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| Singway Technology Co., Ltd. |
| TAIWAN, PROVINCE OF CHINA |
| Compliant |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RUSSIAN FEDERATION |
| Compliant |
Gold |
| Solar Applied Materials Technology Corp. |
| TAIWAN, PROVINCE OF CHINA |
| Compliant |
Gold |
| State Research Institute Center for Physical Sciences and Technology |
| LITHUANIA |
| Unknown |
Gold |
| Sudan Gold Refinery |
| SUDAN |
| Unknown |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| SungEel HiMetal Co., Ltd. |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| T.C.A S.p.A |
| ITALY |
| Compliant |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| JAPAN |
| Compliant |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
| Compliant |
Gold |
| Tokuriki Honten Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
| Unknown |
Metal |
| Smelter |
| Country |
| Compliance Status |
| Tony Goetz NV |
| BELGIUM |
| Unknown | |
Gold |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
| Unknown |
Gold |
| Torecom |
| KOREA, REPUBLIC OF |
| Compliant |
Gold |
| Umicore Brasil Ltda. |
| BRAZIL |
| Compliant |
Gold |
| Umicore Precious Metals Thailand |
| THAILAND |
| Compliant |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| BELGIUM |
| Compliant |
Gold |
| United Precious Metal Refining, Inc. |
| UNITED STATES OF AMERICA |
| Compliant |
Gold |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
| Unknown |
Gold |
| Valcambi S.A. |
| SWITZERLAND |
| Compliant |
Gold |
| Western Australian Mint (T/a The Perth Mint) |
| AUSTRALIA |
| Compliant |
Gold |
| WIELAND Edelmetalle GmbH |
| GERMANY |
| Compliant |
Gold |
| Yamakin Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Yokohama Metal Co., Ltd. |
| JAPAN |
| Compliant |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
| Unknown |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CHINA |
| Compliant |
Tantalum |
| Asaka Riken Co., Ltd. |
| JAPAN |
| Compliant |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| D Block Metals, LLC |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| Exotech Inc. |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| F&X Electro-Materials Ltd. |
| CHINA |
| Compliant |
Tantalum |
| FIR Metals & Resource Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Global Advanced Metals Aizu |
| JAPAN |
| Compliant |
Tantalum |
| Global Advanced Metals Boyertown |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| Guangdong Rising Rare Metals-EO Materials Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| H.C. Starck Co., Ltd. |
| THAILAND |
| Compliant |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| GERMANY |
| Compliant |
Tantalum |
| H.C. Starck Inc. |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| H.C. Starck Ltd. |
| JAPAN |
| Compliant |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
| Compliant |
Tantalum |
| H.C. Starck Tantalum and Niobium GmbH |
| GERMANY |
| Compliant |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| CHINA |
| Compliant |
Tantalum |
| Jiujiang Janny New Material Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| KEMET Blue Metals |
| MEXICO |
| Compliant |
Tantalum |
| KEMET Blue Powder |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| LSM Brasil S.A. |
| BRAZIL |
| Compliant |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| INDIA |
| Compliant |
Tantalum |
| Mineracao Taboca S.A. |
| BRAZIL |
| Compliant |
Tantalum |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
| Compliant |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| NPM Silmet AS |
| ESTONIA |
| Compliant |
Metal |
| Smelter |
| Country |
| Compliance Status |
| Power Resources Ltd. |
| NORTH MACEDONIA, REPUBLIC OF |
| Compliant | |
Tantalum |
| QuantumClean |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| Resind Industria e Comercio Ltda. |
| BRAZIL |
| Compliant |
Tantalum |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
| Compliant |
Tantalum |
| Taki Chemical Co., Ltd. |
| JAPAN |
| Compliant |
Tantalum |
| Telex Metals |
| UNITED STATES OF AMERICA |
| Compliant |
Tantalum |
| Ulba Metallurgical Plant JSC |
| KAZAKHSTAN |
| Compliant |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CHINA |
| Compliant |
Tantalum |
| Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Alpha |
| UNITED STATES OF AMERICA |
| Compliant |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
| Unknown |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Chifeng Dajingzi Tin Industry Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| China Tin Group Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| CV Dua Sekawan |
| INDONESIA |
| Compliant |
Tin |
| CV Gita Pesona |
| INDONESIA |
| Compliant |
Tin |
| CV United Smelting |
| INDONESIA |
| Compliant |
Tin |
| CV Venus Inti Perkasa |
| INDONESIA |
| Compliant |
Tin |
| Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| CHINA |
| In Process |
Tin |
| Dowa |
| JAPAN |
| Compliant |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
| Unknown |
Tin |
| EM Vinto |
| BOLIVIA (PLURINATIONAL STATE OF) |
| Compliant |
Tin |
| Estanho de Rondonia S.A. |
| BRAZIL |
| Unknown |
Tin |
| Fenix Metals |
| POLAND |
| Compliant |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| CHINA |
| Compliant |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
| Compliant |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CHINA |
| Compliant |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Jiangxi New Nanshan Technology Ltd. |
| CHINA |
| Compliant |
Tin |
| Magnu's Minerais Metais e Ligas Ltda. |
| BRAZIL |
| Compliant |
Tin |
| Malaysia Smelting Corporation (MSC) |
| MALAYSIA |
| Compliant |
Tin |
| Melt Metais e Ligas S.A. |
| BRAZIL |
| Compliant |
Tin |
| Metallic Resources, Inc. |
| UNITED STATES OF AMERICA |
| Compliant |
Tin |
| Metallo Belgium N.V. |
| BELGIUM |
| Compliant |
Tin |
| Metallo Spain S.L.U. |
| SPAIN |
| Compliant |
Tin |
| Mineracao Taboca S.A. |
| BRAZIL |
| Compliant |
Tin |
| Minsur |
| PERU |
| Compliant |
Tin |
| Mitsubishi Materials Corporation |
| JAPAN |
| Compliant |
Tin |
| Modeltech Sdn Bhd |
| MALAYSIA |
| Compliant |
Metal |
| Smelter |
| Country |
| Compliance Status |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Unknown | |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| THAILAND |
| Compliant |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| PHILIPPINES |
| Compliant |
Tin |
| Operaciones Metalurgical S.A. |
| BOLIVIA (PLURINATIONAL STATE OF) |
| Compliant |
Tin |
| Pongpipat Company Limited |
| MYANMAR |
| Unknown |
Tin |
| PT Aries Kencana Sejahtera |
| INDONESIA |
| Compliant |
Tin |
| PT Artha Cipta Langgeng |
| INDONESIA |
| Compliant |
Tin |
| PT ATD Makmur Mandiri Jaya |
| INDONESIA |
| Compliant |
Tin |
| PT Babel Inti Perkasa |
| INDONESIA |
| Compliant |
Tin |
| PT Babel Surya Alam Lestari |
| INDONESIA |
| Compliant |
Tin |
| PT Bangka Prima Tin |
| INDONESIA |
| Compliant |
Tin |
| PT Bangka Serumpun |
| INDONESIA |
| Compliant |
Tin |
| PT Bangka Tin Industry |
| INDONESIA |
| Compliant |
Tin |
| PT Belitung Industri Sejahtera |
| INDONESIA |
| Compliant |
Tin |
| PT Bukit Timah |
| INDONESIA |
| Compliant |
Tin |
| PT DS Jaya Abadi |
| INDONESIA |
| Compliant |
Tin |
| PT Inti Stania Prima |
| INDONESIA |
| Compliant |
Tin |
| PT Kijang Jaya Mandiri |
| INDONESIA |
| Compliant |
Tin |
| PT Menara Cipta Mulia |
| INDONESIA |
| Compliant |
Tin |
| PT Mitra Stania Prima |
| INDONESIA |
| Compliant |
Tin |
| PT Panca Mega Persada |
| INDONESIA |
| Compliant |
Tin |
| PT Premium Tin Indonesia |
| INDONESIA |
| Compliant |
Tin |
| PT Prima Timah Utama |
| INDONESIA |
| Compliant |
Tin |
| PT Rajawali Rimba Perkasa |
| INDONESIA |
| Compliant |
Tin |
| PT Rajehan Ariq |
| INDONESIA |
| Compliant |
Tin |
| PT Refined Bangka Tin |
| INDONESIA |
| Compliant |
Tin |
| PT Sariwiguna Binasentosa |
| INDONESIA |
| Compliant |
Tin |
| PT Stanindo Inti Perkasa |
| INDONESIA |
| Compliant |
Tin |
| PT Sukses Inti Makmur |
| INDONESIA |
| Compliant |
Tin |
| PT Sumber Jaya Indah |
| INDONESIA |
| Compliant |
Tin |
| PT Timah Tbk Kundur |
| INDONESIA |
| Compliant |
Tin |
| PT Timah Tbk Mentok |
| INDONESIA |
| Compliant |
Tin |
| PT Tinindo Inter Nusa |
| INDONESIA |
| Compliant |
Tin |
| PT Tirus Putra Mandiri |
| INDONESIA |
| Compliant |
Tin |
| PT Tommy Utama |
| INDONESIA |
| Compliant |
Tin |
| Resind Industria e Comercio Ltda. |
| BRAZIL |
| Compliant |
Tin |
| Rui Da Hung |
| TAIWAN, PROVINCE OF CHINA |
| Compliant |
Tin |
| Soft Metais Ltda. |
| BRAZIL |
| Compliant |
Tin |
| Super Ligas |
| BRAZIL |
| Unknown |
Tin |
| Thaisarco |
| THAILAND |
| Compliant |
Tin |
| Tin Technology & Refining |
| UNITED STATES OF AMERICA |
| Compliant |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
| Unknown |
Tin |
| White Solder Metalurgia e Mineracao Ltda. |
| BRAZIL |
| Compliant |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
| Compliant |
Tin |
| Yunnan Tin Company Limited |
| CHINA |
| Compliant |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| JAPAN |
| Compliant |
Tungsten |
| ACL Metais Eireli |
| BRAZIL |
| Compliant |
Metal |
| Smelter |
| Country |
| Compliance Status |
| Asia Tungsten Products Vietnam Ltd. |
| VIET NAM |
| Compliant | |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Ganzhou Haichuang Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Global Tungsten & Powders Corp. |
| UNITED STATES OF AMERICA |
| Compliant |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
| Compliant |
Tungsten |
| H.C. Starck Tungsten GmbH |
| GERMANY |
| Compliant |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CHINA |
| Compliant |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Hunan Litian Tungsten Industry Co., Ltd. |
| CHINA |
| In Process |
Tungsten |
| Hydrometallurg, JSC |
| RUSSIAN FEDERATION |
| Compliant |
Tungsten |
| Japan New Metals Co., Ltd. |
| JAPAN |
| Compliant |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| CHINA |
| Unknown |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Jiangxi Xianglu Tungsten Co., Ltd. |
| CHINA |
| Unknown |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Kennametal Fallon |
| UNITED STATES OF AMERICA |
| Compliant |
Tungsten |
| Kennametal Huntsville |
| UNITED STATES OF AMERICA |
| Compliant |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Masan Tungsten Chemical LLC (MTC) |
| VIET NAM |
| Compliant |
Tungsten |
| Moliren Ltd. |
| RUSSIAN FEDERATION |
| Compliant |
Tungsten |
| Niagara Refining LLC |
| UNITED STATES OF AMERICA |
| Compliant |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| PHILIPPINES |
| Compliant |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CHINA |
| Compliant |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| VIET NAM |
| Compliant |
Tungsten |
| Unecha Refractory metals plant |
| RUSSIAN FEDERATION |
| Compliant |
Tungsten |
| Wolfram Bergbau und Hutten AG |
| AUSTRIA |
| Compliant |
Tungsten |
| Woltech Korea Co., Ltd. |
| KOREA, REPUBLIC OF |
| Compliant |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CHINA |
| Compliant |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CHINA |
| Compliant |
