EX-1.01 (Exhibit 1.01)
Conflict Minerals Report of Ormat Technologies, Inc.
For the Year Ended December 31, 2021
Introduction:
We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").
We are a leading vertically integrated company that is primarily engaged in the geothermal energy power business. Ormat is leveraging its core capabilities and global presence to expand its activity in recovered energy generation and into different energy storage services and solar photovoltaic (PV) (including hybrid geothermal and solar PV as well as energy storage plus Solar PV).
Ormat aims to become a leading global provider of renewable energy and has adopted a strategic plan to focus on several key initiatives to expand its business.
This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2021 to December 31, 2021, which has been prepared in accordance with Rule 13p-1 (“Rule 13p-1”), promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 requires every registrant that files reports with the SEC under Sections 13(a) or 15(d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and when the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the “Conflict Minerals” or “3TG”), that originate, or are likely originate, in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).
As part of Ormat's sustainability approach, our Supplier Code of Conduct and Code of Business Conduct and Ethics outlines the Company‘s overall principles and commitments to legal compliance, ethical conduct, human rights, anti-corruption, labor rights and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the “Conflict Minerals Policy”) with respect to our sourcing of Conflict Minerals, which was developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at http://www.ormat.com/social-responsibility-and-sustainability.
Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.
1. | Overview |
Company Overview
Ormat and its subsidiaries currently conduct business activities in the following three business segments:
● | Electricity Segment: In this segment, we develop, build, own and operate geothermal, solar PV and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate. |
● | Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and remote power units and provide services relating to the engineering, procurement, and construction of geothermal, and recovered energy-based power plants. |
● | Energy Storage Segment: In this segment, we own and operate grid connected In Front of the Meter (IFM) BESS facilities, which provide capacity, energy and ancillary services directly to the electric grid. We derived all of our Energy Storage segment revenues from our operations in the United States. We plan to accelerate long-term growth in the Energy Storage segment market to establish a leading position in the United States. |
Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.
For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein.
Supply Chain
In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Energy Storage Segment because neither of these segments involves the offer of products by the Company to third parties for consideration.
In connection with our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and that are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). These materials are purchased from our network of suppliers. As a downstream company that does not work directly with the smelters or refiners of the necessary Conflict Minerals, we work with our large network of international suppliers to obtain information on the likely source and chain of custody of those necessary Conflict Minerals and often there are multiple tiers between the 3TG mines and our direct suppliers. Therefore, we rely on our direct Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with information on the origin of the 3TG in the components we purchase from them that are necessary to the functionality or production of our products. In order to overcome certain challenges in receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy to our suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") reporting template for surveying suppliers, i.e. the Conflict Minerals Reporting Template ("CMRT") of at least version 6.01 or above.
2. | Reasonable Country of Origin Inquiry (RCOI) |
Ormat has conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the necessary Conflict Minerals originated, or likely originated, in the DRC or Covered Countries or originated entirely from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conduct due diligence on our mineral supply chain in order to investigate, to a reasonable degree of accuracy, the likely source and chain of custody of the necessary Conflict Minerals used in our products or product components that is sourced from our global network of suppliers.
As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated, or likely originated, in the DRC or the Covered Countries, including the following:
● | Conducted an internal assessment and analysis of our products manufactured or contracted to manufacture in 2021 to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of those products. |
● | Compiled a list of applicable suppliers based on relevant product categories that Ormat purchased from during the calendar year 2021, which list was issued using the Ormat Management System (“OMS”) by information technology developers and according to the criteria defined by the OMS manager and the purchasing manager. For calendar year 2021, the list included a total of 1,479 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1. |
● | In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2021 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") included a total of 90 suppliers for the calendar year 2021 supply chain inquiry. |
● | Contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions. |
● | Solicited information from our relevant suppliers of raw materials and components of products using the standard template of the independent third-party audit body, the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (“CMRT”). We requested that our suppliers provide at least version 6.01 of the CMRT |
● | Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses. We sent reminders to suppliers who did not respond to our requests for information or to suppliers whose responses required further clarification, as per the expectations noted above. We compared information received from our direct suppliers on their relevant smelters or refiners against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as the documented country of origin information as provided in the declarations from the suppliers. The complete list of smelters or refiners identified in the scope of our supply chain inquiry is included as Annex 1 hereto and the complete list of counties of origin, or likely countries of origin, to the best of our knowledge, is included in Annex 2 hereto. |
Currently, we do not have sufficient information from our suppliers to determine the complete list of countries of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the DRC or Covered Countries or are not entirely from recycled or scrap sources.
Based on these results, Ormat conducted due diligence activities and described these activities in this Report.
3. | Due Diligence Framework |
We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (2016) and related Supplements (the “OECD Due Diligence Guidance”). We design our due diligence measures according to the recommendations of the OECD Due Diligence Guidance for downstream companies that have no direct relationships to smelters or refiners.
4. | Due Diligence Measures |
Our due diligence efforts for the reporting period from January 1, 2021 to December 31, 2021 included the following steps as prescribed by the OECD Due Diligence Guidance:
4.1 | Establish strong Company management systems for Conflict Minerals supply chain due diligence and reporting compliance |
The Company implemented the following measures:
● | Established a cross-functional Conflict Minerals steering committee comprised of representatives from procurement, legal and finance departments to direct the overall efforts of the Conflict Minerals compliance program, with the Senior Vice President of Finance as the process owner. |
● | Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and the Covered Countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach, as outlined in our Human Rights & Labor Policy, regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters or refiners that have been validated as being “conformant” or “active” by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the DRC, or Covered Countries. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: http://www.ormat.com/social-responsibility-and-sustainability. |
● | Maintain a grievance mechanism through which concerns and violations of the Conflict Minerals Policy can be reported to Ormat: |
● | online via our website www.ormat.com; or |
● | by electronic mail to the following address: ormat@ormat.com. |
● | Strengthened our engagement with suppliers by referring suppliers to training materials that included an overview of the applicable SEC rules and instructions on how to respond to the survey. |
● | Required our suppliers to provide us the information required to perform our analysis of Conflict Minerals. |
● | Implemented a requirement to maintain records relating to Conflict Minerals due diligence and responsible mineral sourcing for a minimum of five years. |
4.2 | Identify and assess risks in the supply chain |
To identify risks in our supply chain, we undertook the following measures:
● | We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, when aiming to move towards the goal of responsible sourcing of Conflict Minerals to ensure that the purchase and sourcing of such minerals does not benefit or fund the armed conflict and human rights abuses on-going in the DRC, Covered Countries, or in other conflict-affected areas. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers’ characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk. |
● | As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2021. We have determined that, out of the responses received, 65.4% of Ormat's relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals. |
● | Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up. We identified the smelters or refiners that are likely a part of our mineral supply chain by conducting a supply chain survey using the CMRT (at least version 6.01 or higher), requesting suppliers to identify relevant smelters or refiners and country of origin, or likely country of origin, of the Conflict Minerals in products supplied to Ormat in 2021. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP’s “conformant” and “active” designations. The RMAP is a program in which the RMI works with independent third-party auditors or cross-certification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program. |
● | A smelter or refiner is considered RMAP “conformant” if the audited smelter or refiner has successfully completed an RMAP audit and maintains good standing in the program, through a continual validation process. These smelters or refiners have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support their sourcing activities. |
● | Smelters and refiners labeled as RMAP “active” by the RMI represent smelters and refiners that have committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment. The RMI notes on the active smelters list the names of any smelters or refiners that have left the “active” or “conformant” list and intend to re-enter the program. |
● | Downstream smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process. |
4.3 | Design and implement a strategy to respond to identified risks |
To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:
● | Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter or refiner level (e.g., by using a recent version of the CMRT). |
● | Ormat's senior management, including the CEO, CFO, President Head of Products and Operations, EVP Electricity Segment, EVP Energy Storage and Business Development, and the Legal Counsel and Chief Compliance Officer, was updated with the risk analysis and risk management actions and outcomes. |
● | Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification. |
● | Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information. |
● | Should the Company find uncertified smelters or refiners in its suppliers’ responses, it will follow up with the supplier and ask for further clarifications or corrective action plans |
Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.
4.4 Carry out independent third-party audit of smelter/refiner’s due diligence practices
We do not typically have direct relationships with 3TG smelters or refiners of Conflict Minerals and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on independent third-party audit body and cross- industry initiatives, such as those led by the RMI, to conduct smelter or refiner due diligence.
4.5 Report annually on supply chain due diligence
Our Conflict Minerals Policy was adopted with a view to assuring compliance with Section 1502 of the Dodd Frank Act, which requires the filing of a Form SD and this Report with the SEC and disclosure of them on its publicly available Internet website. The Company's Conflict Minerals Reports can be viewed at: https://d18rn0p25nwr6d.cloudfront.net/CIK-0001296445/f4ff3164-7606-4d15-ac83-7643b36391cd.pdf
5 | The Company’s Due Diligence Findings and Conclusions |
We conducted a supply-chain survey of the 90 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2021. The overall response rate to this survey was approximately 52%. The responses included the names and locations of smelters or refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations (see Annex 2).
As a downstream purchaser of products which contain Conflict Minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the Conflict Minerals. Our supply chain is complex and there are multiple tiers between the Company and the mines or facilities that process the necessary Conflict Minerals. Accordingly, we rely on our suppliers to provide information on the origin of the Conflict Minerals contained in components that are supplied to us to be included in our products.
We also rely, to a large extent, on information collected and provided by responsible mineral sourcing validation programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire calendar year covered by the Report, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.
Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were unable to conclusively determine all of the specific smelters or refiners that were part of the supply chain of the components sold to Ormat in 2021. In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG in the Covered Products or their countries of origin. The below shows the RMAP status of smelters or refiners our suppliers identified in response to our due diligence, with the location of such smelters or refiners included in Annex 1. The Company cannot be certain that these smelters and refiners were in fact in the Company’s supply chain during the period covered by this Report.
Smelters or refiners verified as RMAP “Conformant” or “Active”:
Tantalum | 34 of 37 (91.89%) |
Tin | 55 of 73 (75.34%) |
Tungsten | 43 of 48 (89.58%) |
Gold | 106 of 172 (61.63%) |
Total | 238 of 330 (72.1%) |
Status of identified smelters or refiners:
RMAP Status | Number |
RMAP “Conformant” | 224 |
RMAP “Active” | 14 |
Not RMAP “Conformant” or “Active” | 92 |
Total | 330 |
6. Steps to be taken to mitigate risk
The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve its methods and processes for identifying the source or likely source of the Conflict Minerals contained in its Covered Products. The Company plans to continue to inform suppliers of their role in the Company’s Conflict Minerals compliance program and to engage its suppliers to obtain current, accurate and complete information regarding their mineral supply chains. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.
Specific steps the Company has taken and continues to take to manage risks include:
● | Continue to work with our global supply chain to obtain current, accurate and complete information about the supply chain, ensure responsible sourcing, while also assuring compliance with certain international regulations. |
● | Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys and requests for information. |
● | Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy. |
● | Continue to include or attempt to include a conflict minerals flow-down clause in new or renewed supplier contracts. |
Cautionary Note Concerning Forward- Looking Statements
Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward- looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include those associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on our ability to verify the accuracy or completeness of any supply chain information provided by suppliers and other factors discussed under the heading "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on February 25, 2022 and other documents subsequently filed with or furnished to the U.S. Securities and Exchange Commission. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.
Annex 1- Smelter or Refiner Names in Supply Chain
Metal | Smelter Name | Smelter Country | Smelter Status |
Gold | 8853 S.p.A. | ITALY | Conformant |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Active |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
Gold | African Gold Refinery | UGANDA | Uncertified |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Alexy Metals | UNITED STATES OF AMERICA | Active |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Uncertified |
Gold | AU Traders and Refiners | SOUTH AFRICA | Uncertified |
Gold | Augmont Enterprises Private Limited | INDIA | Active |
Gold | Aurubis AG | GERMANY | Conformant |
Gold | Bangalore Refinery | INDIA | Conformant |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
Gold | Boliden AB | SWEDEN | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | Active |
Gold | Caridad | MEXICO | Uncertified |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
Gold | CGR Metalloys Pvt Ltd. | INDIA | Uncertified |
Gold | Chimet S.p.A. | ITALY | Conformant |
Gold | Chugai Mining | JAPAN | Conformant |
Gold | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Active |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Uncertified |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Uncertified |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | Uncertified |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | Uncertified |
Gold | Dowa | JAPAN | Conformant |
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Uncertified |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | Uncertified |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | Uncertified |
Gold | Emerald Jewel Industry India Limited (Unit 3) | India | Uncertified |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | Uncertified |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Uncertified |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | Uncertified |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Active |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
Gold | Gold Coast Refinery | GHANA | Uncertified |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Uncertified |
Gold | Guangdong Jinding Gold Limited | CHINA | Uncertified |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Uncertified |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Uncertified |
Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Conformant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Uncertified |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Uncertified |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Uncertified |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | Uncertified |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | Conformant |
Gold | Italpreziosi | ITALY | Conformant |
Gold | Japan Mint | JAPAN | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Uncertified |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Uncertified |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
Gold | K.A. Rasmussen | NORWAY | Uncertified |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Uncertified |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Uncertified |
Gold | Kazzinc | KAZAKHSTAN | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Kundan Care Products Ltd. | INDIA | Uncertified |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Uncertified |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Uncertified |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Uncertified |
Gold | Lingbao Gold Co., Ltd. | CHINA | Uncertified |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Uncertified |
Gold | L'Orfebre S.A. | ANDORRA | Conformant |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Uncertified |
Gold | Marsam Metals | BRAZIL | Conformant |
Gold | Materion | UNITED STATES OF AMERICA | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
Gold | MD Overseas | INDIA | Uncertified |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | Uncertified |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
Gold | Modeltech Sdn Bhd | MALAYSIA | Uncertified |
Gold | Morris and Watson | NEW ZEALAND | Uncertified |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Uncertified |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Uncertified |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Uncertified |
Gold | PAMP S.A. | SWITZERLAND | Conformant |
Gold | Pease & Curren | UNITED STATES OF AMERICA | Uncertified |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Uncertified |
Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Uncertified |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | Uncertified |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Uncertified |
Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
Gold | Royal Canadian Mint | CANADA | Conformant |
Gold | SAAMP | FRANCE | Conformant |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Uncertified |
Gold | Safimet S.p.A | ITALY | Conformant |
Gold | SAFINA A.S. | CZECHIA | Conformant |
Gold | Sai Refinery | INDIA | Uncertified |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Uncertified |
Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | Active |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Uncertified |
Gold | Sellem Industries Ltd. | MAURITANIA | Uncertified |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Uncertified |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Uncertified |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
Gold | Shirpur Gold Refinery Ltd. | INDIA | Uncertified |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
Gold | Smelter Not Listed | JAPAN | Conformant |
Gold | Smelter Not Listed | JAPAN | Conformant |
Gold | Smelter Not Listed | CHINA | Uncertified |
Gold | Smelter Not Listed | INDIA | Uncertified |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Uncertified |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
Gold | Sovereign Metals | INDIA | Uncertified |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Uncertified |
Gold | Sudan Gold Refinery | SUDAN | Uncertified |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Gold | T.C.A S.p.A | ITALY | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Uncertified |
Gold | Tony Goetz NV | BELGIUM | Uncertified |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
Gold | Valcambi S.A. | SWITZERLAND | Conformant |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Uncertified |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | Uncertified |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Uncertified |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Conformant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
Tantalum | H.C. Starck Ltd. | JAPAN | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | Conformant |
Tantalum | LSM Brasil S.A. | BRAZIL | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tantalum | Mitsui Mining & Smelting | JAPAN | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | Conformant |
Tantalum | PRG Dooel | NORTH MACEDONIA | Uncertified |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Uncertified |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
Tin | CRM Synergies | SPAIN | Conformant |
Tin | CV Ayi Jaya | Indonesia | Uncertified |
Tin | CV Venus Inti Perkasa | INDONESIA | Active |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Uncertified |
Tin | Dowa | JAPAN | Conformant |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Uncertified |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
Tin | Estanho de Rondonia S.A. | BRAZIL | Conformant |
Tin | Fenix Metals | POLAND | Conformant |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Uncertified |
Tin | Gejiu Fengming Metallurgy Chemical Plant | China | Uncertified |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Uncertified |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Uncertified |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | Uncertified |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
Tin | Minsur | PERU | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | Uncertified |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Uncertified |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
Tin | Pongpipat Company Limited | MYANMAR | Uncertified |
Tin | Precious Minerals and Smelting Limited | INDIA | Uncertified |
Tin | PT Aries Kencana Sejahtera | Indonesia | Active |
Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
Tin | PT Bangka Serumpun | INDONESIA | Conformant |
Tin | PT Lautan Harmonis Sejahtera | Indonesia | Uncertified |
Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
Tin | PT Mitra Sukses Globalindo | INDONESIA | Active |
Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
Tin | PT Timah Nusantara | INDONESIA | Active |
Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
Tin | PT Tinindo Inter Nusa | Indonesia | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
Tin | Smelter Not Listed | RUSSIAN FEDERATION | Conformant |
Tin | Smelter Not Listed | INDONESIA | Conformant |
Tin | Smelter Not Listed | INDONESIA | Conformant |
Tin | Smelter Not Listed | INDONESIA | Conformant |
Tin | Smelter Not Listed | INDONESIA | Conformant |
Tin | Smelter Not Listed | RWANDA | Conformant |
Tin | Smelter Not Listed | INDONESIA | Uncertified |
Tin | Soft Metais Ltda. | BRAZIL | Conformant |
Tin | Super Ligas | BRAZIL | Active |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant |
Tin | Thaisarco | THAILAND | Conformant |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Uncertified |
Tin | VQB Mineral and Trading Group JSC | Viet Nam | Uncertified |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
Tin | Yunnan Tin Company, Ltd. | CHINA | Conformant |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Uncertified |
Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
Tungsten | Artek LLC | RUSSIAN FEDERATION | Uncertified |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
Tungsten | Chaozhou Xianglu Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | China Molybdenum Co., Ltd. | CHINA | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Uncertified |
Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
Tungsten | GEM Co., Ltd. | CHINA | Conformant |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Uncertified |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Uncertified |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Tungsten Industry Group Co. Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | Conformant |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | Conformant |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | Active |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
Tungsten | Smelter Not Listed | BRAZIL | Active |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
Tungsten | WBH,Wolfram [Austria] | AUSTRIA | Conformant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Uncertified |
Tungsten | Xiamen H.C. | CHINA | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
Annex 2- Reasonable Country of Origin (RCOI) Inquiry Results*
GOLD | TANTALUM | TIN | TUNGSTEN |
ITALY | JAPAN | BELGIUM | AUSTRIA |
ANDORRA | BRAZIL | BOLIVIA (PLURINATIONAL STATE OF) | BRAZIL |
AUSTRALIA | CHINA | BRAZIL | CHINA |
AUSTRIA | ESTONIA | CHINA | GERMANY |
BELGIUM | GERMANY | INDIA | JAPAN |
BRAZIL | INDIA | INDONESIA | KOREA, REPUBLIC OF |
CANADA | JAPAN | JAPAN | PHILIPPINES |
CHILE | KAZAKHSTAN | MALAYSIA | RUSSIAN FEDERATION |
CHINA | MEXICO | MYANMAR | TAIWAN, PROVINCE OF CHINA |
COLOMBIA | NORTH MACEDONIA | PERU | UNITED STATES OF AMERICA |
CZECHIA | RUSSIAN FEDERATION | PHILIPPINES | VIET NAM |
FRANCE | THAILAND | POLAND | |
GERMANY | UNITED STATES OF AMERICA | RUSSIAN FEDERATION | |
GHANA | RWANDA | ||
INDIA | SPAIN | ||
INDONESIA | TAIWAN, PROVINCE OF CHINA | ||
ITALY | THAILAND | ||
JAPAN | UNITED STATES OF AMERICA | ||
KAZAKHSTAN | VIET NAM | ||
KOREA, REPUBLIC OF | |||
KYRGYZSTAN | |||
LITHUANIA | |||
MALAYSIA | |||
MAURITANIA | |||
MEXICO | |||
NETHERLANDS | |||
NEW ZEALAND | |||
NORWAY | |||
PHILIPPINES | |||
POLAND | |||
RUSSIAN FEDERATION | |||
SAUDI ARABIA |
SINGAPORE | |||
SOUTH AFRICA | |||
SPAIN | |||
SUDAN | |||
SWEDEN | |||
SWITZERLAND | |||
TAIWAN, PROVINCE OF CHINA | |||
THAILAND | |||
TURKEY | |||
UGANDA | |||
UNITED ARAB EMIRATES | |||
UNITED STATES OF AMERICA | |||
UZBEKISTAN | |||
ZIMBABWE |
* As some smelters or refiners did not provide complete information on the location of mine in their CMRTs, and the Company was not able to establish with complete certainty, based on the suppliers’ 3TG sourcing information, the exact location for the processing of the minerals. Therefore, we have listed in the RCOI the closest indication provided as to the source of Conflict Minerals (i.e. the smelter or refiner country as reported in our relevant suppliers' CMRT declarations, if provided).
