Exhibit 1.01
Conflict Minerals Report
For The Year Ended December 31, 2017
This Conflict Minerals Report for the reporting period from January 1, 2017 to December 31, 2017 is presented to comply with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended. Rule 13p-1 imposes certain reporting obligations on reporting companies whose manufactured or contracted to be manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict minerals” are defined as gold, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG”) for the purposes of this assessment. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.
1. Company Overview
Compass Group Diversified Holdings LLC and Compass Diversified Holdings (collectively, “CODI” or the “Company”) were formed to acquire and manage a group of small to middle market businesses and the Company was a controlling owner of nine businesses, or operating subsidiaries, at December 31, 2017. The subsidiaries are as follows: 5.11 Acquisition Corp. ("5.11" or "5.11 Tactical"), Crosman Corp. ("Crosman"), The Ergo Baby Carrier, Inc. ("Ergobaby”), Liberty Safe and Security Products, Inc. (“Liberty Safe” or “Liberty”), Fresh Hemp Foods Ltd. ("Manitoba Harvest"), Compass AC Holdings, Inc. (“ACI” or “Advanced Circuits”), AMT Acquisition Corporation (“Arnold” or “Arnold Magnetics”), Clean Earth Holdings Inc. ("Clean Earth"), and Sterno Products, LLC ("Sterno Products").
The Company’s subsidiaries are engaged in the following lines of business:
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| • | 5.11 is a leading provider of purpose-built tactical apparel and gear for law enforcement, firefighters, EMS, and military special operations as well as outdoor and adventure enthusiasts. 5.11 is a brand known for innovation and authenticity, and works directly with end users to create purpose-built apparel and gear designed to enhance the safety, accuracy, speed and performance of tactical professionals and enthusiasts worldwide. Headquartered in Irvine, California, 5.11 operates sales offices and distribution centers globally, and 5.11 products are widely distributed in uniform stores, military exchanges, outdoor retail stores, its own retail stores and on 511tactical.com. |
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| • | Crosman is a leading designer, manufacturer, and marketer of airguns, archery products, laser aiming devices and related accessories. Crosman offers its products under the highly recognizable Crosman, Benjamin and CenterPoint brands that are available through national retail chains, mass merchants, dealer and distributor networks. Crosman is headquartered in Bloomfield, New York. |
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| • | Ergobaby, headquartered in Los Angeles, California, is a designer, marketer and distributor of wearable baby carriers and accessories, blankets and swaddlers, nursing pillows, and related products. Ergobaby primarily sells its Ergobaby and Baby Tula branded products through brick-and-mortar retailers, national chain stores, online retailers, its own websites and distributors and derives more than 50% of its sales from outside of the United States. |
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| • | Liberty Safe is a designer, manufacturer and marketer of premium home, office and gun safes in North America. From its over 300,000 square foot manufacturing facility, Liberty produces a wide range of home and gun safe models in a broad assortment of sizes, features and styles. Liberty is headquartered in Payson, Utah. |
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| • | Manitoba Harvest is a pioneer and leader in the manufacture and distribution of branded, hemp-based foods and hemp-based ingredients. Manitoba Harvest’s products, which include Hemp Hearts™, Hemp Heart Bites™, and Hemp protein powders, are currently carried in over 13,000 retail stores across the U.S. and Canada. Manitoba Harvest is headquartered in Winnipeg, Manitoba. |
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| • | Advanced Circuits, an electronic components manufacturing company, is a provider of small-run, quick-turn and volume production rigid printed circuit boards. ACI manufactures and delivers custom printed circuit boards to customers primarily in North America. ACI is headquartered in Aurora, Colorado. |
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| • | Arnold is a global manufacturer of engineered magnetic solutions for a wide range of specialty applications and end-markets, including aerospace and defense, motorsport/automotive, oil and gas, medical, general industrial, electric utility, reprographics and advertising specialty markets. Arnold produces high performance permanent magnets (PMAG), precision foil products (Precision Thin Metals or "PTM") and flexible magnets |
(Flexmag) that are mission critical in motors, generators, sensors and other systems and components. Based on its long-term relationships, Arnold has built a diverse and blue-chip customer base totaling more than 2,000 clients worldwide. Arnold is headquartered in Rochester, New York.
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| • | Clean Earth provides environmental services for a variety of contaminated materials including soils dredged materials, hazardous waste and drill cuttings. Clean Earth analyzes, treats, documents and recycles waste streams generated in multiple end markets such as power, construction, oil and gas, medical, infrastructure, industrial and dredging. Clean Earth is headquartered in Hatsboro, Pennsylvania and operates 18 facilities in the eastern United States. |
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| • | Sterno is a manufacturer and marketer of portable food warming fuel and creative table lighting solutions for the food service industry and flameless candles and outdoor lighting products for consumers. Sterno's products include wick and gel chafing fuels, butane stoves and accessories, liquid and traditional wax candles, catering equipment and outdoor lighting products. Sterno is headquartered in Corona, California. |
2. Description of the Company's Products Covered by this Report
This Report relates to products: (i) for which 3TG are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2017. The Company determined that component products at six (6) of its subsidiaries contain or may contain 3TG which are necessary to the functionality or production of their products. The six subsidiaries and the applicable 3TG are Advanced Circuits (gold and tin), Arnold Magnetics (gold, tantalum, tin and tungsten), Ergobaby (tin), Sterno Products (tin and gold), 5.11 (tin and gold) and Liberty (gold, tantalum, tin and tungsten).
The Company acquired Crosman during the year ended December 31, 2017. As permitted by the instructions to the Form SD, the Company has not included Crosman in our reporting on Form SD and the Conflict Mineral report for the year-ended December 31, 2017.
3. Reasonable Country of Origin Inquiry
The Company conducted an analysis of its subsidiaries’ products and found that small quantities of necessary 3TG are contained in some of its subsidiaries’ products. Therefore, for the reporting period from January 1, 2017 to December 31, 2017, the Company conducted a good faith reasonable country of origin inquiry (“RCOI”) which was reasonably designed to determine whether any of the necessary 3TG contained in its subsidiaries’ products originated in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") or came from recycled or scrap sources. “Necessary 3TG” are 3TG that are necessary to the functionality or production of products that the Company’s subsidiaries manufacture or that the Company’s subsidiaries contract with others to manufacture for us.
The Company used the Conflict Minerals Reporting Template (“CMRT”) developed by the Conflict-Free Sourcing Initiative to request information from its subsidiaries’ suppliers about their supply chain and to gather information about the country of origin of its necessary 3TG. The Company identified approximately 152 direct suppliers that potentially supplied the Company necessary 3TG and requested each of them to complete a CMRT. The Company received responses (by either a letter or completed CMRT) from approximately 92% of these suppliers and reviewed the responses for completeness and accuracy. When the Company determined that its suppliers’ CMRT responses contained information the Company believed to be incomplete or inaccurate, the Company followed up with those suppliers to seek additional information or clarification about those responses.
Based on the Company’s supplier responses, the Company does not have sufficient information to determine whether the products it manufactured or contracted for manufacture during the reporting period contain necessary 3TG that originated, or may have originated, in the Covered Countries and are not or may not be from recycled or scrap sources. Accordingly, and out of an abundance of caution, the Company performed due diligence in an effort to determine the source and chain of custody of these necessary 3TG.
4. Due Diligence
Due Diligence Design
With respect to the period covered, the design of the due diligence process conforms in all material respects with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High
Risk Areas, Third Edition, 2016, as further set out in the specific guidance for downstream companies contained in the Supplement on Tin, Tantalum, and Tungsten and the Supplement for Gold (hereinafter, collectively, the “OECD Guidance”).
Due Diligence Measures Performed
The Company undertook due diligence at each of its subsidiaries that have component products that contain or may contain necessary 3TG to determine the source and chain of custody of the necessary 3TG contained in the products manufactured by or contracted for manufacture by the Company’s subsidiaries. Summarized below are the components of the 3TG due diligence program the Company undertook as they relate to the five-step framework set forth in the OECD Guidance:
1. OECD Step #1: Establish and maintain strong company management systems
Our operations are reported in eight business segments, therefore, we established a single point of contact to assist in implementing a 3TG program. Each segment that manufactures or distributes products that contain necessary 3TG had its own designated specific personnel to coordinate the 3TG diligence, oversee the implementation and execution of a program and coordinate directly with its affected suppliers, if applicable. The affected segments used the CMRT developed by the Conflict-Free Sourcing Initiative as a mechanism to request that suppliers provide information about the source and chain of custody of the necessary 3TG contained in products supplied to each of the affected segments. For suppliers that did not respond to the Company's source and chain of custody inquiry (or provided limited response) for calendar year 2016, the Company submitted that supplier name to the executive management of the applicable subsidiary for review. The Company maintains a conflict minerals policy regarding the sourcing of conflict minerals, which is publicly available on the Company’s website at: http://ir.compassequity.com/corporate-governance.cfm. The content of any website referred to in this Report is not incorporated by reference in this Report.
2. OECD Step #2: Identifying and assessing risk in the supply chain
To identify risks related to necessary 3TG in its products, the Company took the following actions:
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| • | worked with suppliers to obtain more complete information; |
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| • | followed up with suppliers that did not respond or provided inconsistent or incomplete responses; |
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| • | sought information regarding the smelters or refiners or smelters that processed the conflict minerals in the suppliers’ products; and |
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| • | analyzed the supplier’s responses against the Company's conflict minerals policy and against the list of smelters and refiners on the CFSI website to determine whether the smelters received a "compliant" or "active" designations from the Conflict Free Smelter Program ("CFSP"). |
3. OECD Step #3: Design and implement a strategy to respond to identified risks
Results of the Company’s supplier responses were reported to the senior management of the Company, specifically our Chief Financial Officer . The Company continued a risk management plan of attempting to disengage with a supplier where the Company deems risk mitigation unfeasible or unacceptable, and where, in the Company’s opinion, such disengagement would not likely harm the supply chain for a particular product.
4. OECD Step #4: Carry out an independent third party audit of smelter's/ refiner’s due diligence practices
As an owner of downstream companies, the Company relies on audits by independent third parties, including audits of smelters and refiners reported by the CFSP. The Company also relies on the certification processes of the London Bullion Market Association, The Responsible Jewellery Council, and the Tungsten Industry - Conflict Minerals Council.
5. OECD Step #5: Report annually on supply chain due diligence
The Company reports on our conflict minerals due diligence annually by making our Form SD and this Report publicly available on our Company website at: http://ir.compassequity.com/sec.cfm and filing the Form SD (with this Report) with the Securities and Exchange Commission ("SEC").
5. Results of Review
As an owner of downstream companies, the Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG contained in its subsidiaries’ products. The Company relies on the information collected and provided by its subsidiaries’ direct suppliers and publicly available information regarding independent third party audit programs.
Facilities Used to Process the Necessary 3TG
The Company requested smelter information from the suppliers of each of its subsidiaries that were determined to have component products that contain or may contain 3TG which are necessary to the functionality or production of their products. Based on the responses from our direct suppliers, eighteen (18) suppliers identified only one (1) tin smelter, resulting in a total of nine (9) tin smelters being identified. One (1) supplier identified only one (1) tungsten smelter resulting in a total of one (1) tungsten supplier being identified. Based on the responses from the eleven (11) suppliers with only one smelter disclosed for tin or tungsten, we determined that the following smelters processed the tin or tungsten that is contained in certain of our products.
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| Metal | Official Smelter Name | CESI Smelter ID | Smelter Country |
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| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | China |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 | China |
| Tin | Alpha | CID000292 | United States of America |
| Tin | China Tin Group Co., Ltd. | CID001070 | China |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CID001231 | China |
| Tin | Thaiarco | CID001898 | Thailand |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | China |
| Tin | Yunnan Tin Company Limited | CID002180 | China |
| Tin | An Thai Minerals Co., Ltd. | CID002825 | Viet Nam |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002320 | China |
In the other responses received from our direct suppliers, each supplier named more than one (1) smelter or refiner in their response for each metal. This lack of detail from the rest of our suppliers prevented the Company from being able to determine whether a particular smelter or refiner named in their responses processed the necessary 3TG in the Company's products. Accordingly, the Company is unable to disclose any other facilities used to produce the necessary 3TG in its products. However, Table 1 attached to this Report lists the smelters and refiners provided to the Company by its other direct suppliers that may have processed necessary 3TG in its subsidiaries’ product lines.
Country of Origin
Based on the responses provided by the Company’s suppliers described directly above, the responses did not provide sufficiently detailed information for us to identify the country of origin of the necessary 3TG in the Company’s products. Accordingly, the Company is unable to disclose the country of origin of the necessary 3TG in its products.
Efforts to determine mine or location
The Company has determined that the most reasonable effort it can make to determine the mines or locations of origin of its necessary 3TG to the greatest possible specificity is to seek information from its direct suppliers about the smelters and refiners and the countries of origin of the necessary 3TG in its products and urge that its suppliers do the same with their direct suppliers. The Company must rely on its direct and indirect suppliers to provide the information about the mine or location of origin of the necessary 3TG in its products. As a result of the lack of information obtained from the Company’s subsidiaries’ suppliers, the Company was unable to determine the mine or location of the necessary conflict minerals in its subsidiaries’ product lines.
6. Risk Mitigation / Steps to Improve Due Diligence Measures
The Company currently intends to take steps to improve its due diligence and mitigate the risk that the Company’s necessary 3TG benefit or finance armed groups, including:
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| • | Evaluating current direct suppliers based on their responsiveness to the 2017 calendar year's data collection effort. We expect to submit the names of those suppliers who provide products with risk of possible 3TG content that required responses and whose responses were limited or non-existent for calendar year 2017 to the executive management of the applicable subsidiary for review. |
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| • | Reaching out to suppliers earlier in the process and asking them to complete the CMRT. |
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| • | Improving, to the extent possible, the percentage of supplier provided responses to the request to complete the CMRT. |
7. Independent Private Sector Audit
Based on the existing guidance from the SEC, this report has not been audited, nor is an Independent Private Sector Audit required for this Report.
8. Forward-Looking Statements
This Report may contain certain forward-looking statements, including those made under the “Risk Mitigation / Steps to Improve Due Diligence Measures” section. Words such as “believes,” “expects,” “projects,” and “future” or similar expressions, are intended to identify forward-looking statements. These forward-looking statements are subject to the inherent uncertainties in predicting future results and conditions. These statements are subject to a variety of uncertainties, unknown risks and other factors concerning the Company’s operations and business environment, which are difficult to predict and are beyond the control of the Company. Factors that could adversely affect our future performance include (1) those described under the heading “Risk Factors” in Item 1A of Part I of our Annual Report on Form 10-K for the year ended December 31, 2017, (2) the responsible sourcing of 3TG in our supply chain by our direct and indirect suppliers and (3) the effectiveness of traceability systems used by our direct and indirect suppliers to determine the source and chain of custody of 3TG contained in our supply chain. Except as required by law, CODI undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.
Table 1 - List of smelters and refiners that may have processed necessary 3TG of the Company’s subsidiaries
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| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
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| Gold | | Advanced Chemical Company | | UNITED STATES |
| Gold | | Aida Chemical Industries Co. Ltd. | | JAPAN |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN |
| Gold | | AngloGold Ashanti Córrego do Sítio Mineração | | BRAZIL |
| Gold | | Argor-Heraeus SA | | SWITZERLAND |
| Gold | | Asahi Pretec Corp. | | JAPAN |
| Gold | | Asahi Refining Canada Limited | | CANADA |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY |
| Gold | | Aurubis AG | | GERMANY |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| Gold | | Bauer Walser AG | | GERMANY |
| Gold | | Boliden AB | | SWEDEN |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| Gold | | Caridad | | MEXICO |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA |
| Gold | | Cendres + Métaux SA | | SWITZERLAND |
| Gold | | Chimet S.p.A. | | ITALY |
| Gold | | Chugai Mining | | JAPAN |
| Gold | | Daejin Indus Co., Ltd. | | KOREA, REPUBLIC OF |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA |
| Gold | | Do Sung Corporation | | KOREA, REPUBLIC OF |
| Gold | | DODUCO GmbH | | GERMANY |
| Gold | | Dowa | | JAPAN |
| Gold | | Eco-System Recycling | | JAPAN |
| Gold | | Elemetal Refining, LLC | | UNITED STATES |
| Gold | | Faggi Enrico S.p.A. | | ITALY |
| Gold | | Gansu Seemine Material Hi-Tech Co., Ltd. | | CHINA |
| Gold | | Geib Refining Corporation | | UNITED STATES |
| Gold | | Great Wall Precious Metals Co., Ltd. of CBPM | | CHINA |
| Gold | | Guangdong Jinding Gold Limited | | CHINA |
| Gold | | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | | CHINA |
| Gold | | Hangzhou Fuchunjiang Smelting Co., Ltd. | | CHINA |
| Gold | | Heimerle + Meule GmbH | | GERMANY |
| Gold | | Heraeus Ltd. Hong Kong | | CHINA |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Gold | | Hwasung CJ Co., Ltd. | | KOREA, REPUBLIC OF |
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| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | | CHINA |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN |
| Gold | | Istanbul Gold Refinery | | TURKEY |
| Gold | | Japan Mint | | JAPAN |
| Gold | | Jiangxi Copper Company Limited | | CHINA |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | RUSSIAN FEDERATION |
| Gold | | JSC Uralelectromed | | RUSSIAN FEDERATION |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN |
| Gold | | Kazzinc | | KAZAKHSTAN |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN |
| Gold | | Korea Metal Co., Ltd. | | KOREA, REPUBLIC OF |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN |
| Gold | | L' azurde Company For Jewelry | | SAUDI ARABIA |
| Gold | | Lingbao Gold Company Limited | | CHINA |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA |
| Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF |
| Gold | | Materion | | UNITED STATES |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| Gold | | Metahub Industries Sdn. Bhd. | | MALAYSIA |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA |
| Gold | | Metalor Technologies SA | | SWITZERLAND |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES |
| Gold | | Mitsubishi Materials Corporation | | JAPAN |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.Ş. | | TURKEY |
| Gold | | Nihon Material Co., Ltd. | | JAPAN |
| Gold | | Ohio Precious Metals, LLC | | UNITED STATES |
| Gold | | Ogussa Osterreichische Gold - und Silber-Scheideanstalt GmbH | | AUSTRIA |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet) | | RUSSIAN FEDERATION |
| Gold | | OJSC Kolyma Refinery | | RUSSIAN FEDERATION |
| Gold | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION |
| Gold | | PAMP SA | | SWITZERLAND |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA |
| Gold | | PX Précinox SA | | SWITZERLAND |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA |
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| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Gold | | Republic Metals Corporation | | UNITED STATES |
| Gold | | Royal Canadian Mint | | CANADA |
| Gold | | Sabin Metal Corp. | | UNITED STATES |
| Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF |
| Gold | | SAMWON Metals Corp. | | KOREA, REPUBLIC OF |
| Gold | | Schone Edelmetaal B.V. | | NETHERLANDS |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CHINA |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA |
| Gold | | So Accurate Group, Inc. | | UNITED STATES |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA |
| Gold | | Tokuriki Honten Co., Ltd. | | JAPAN |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | CHINA |
| Gold | | Torecom | | KOREA, REPUBLIC OF |
| Gold | | Umicore Brasil Ltda. | | BRAZIL |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM |
| Gold | | Umicore Precious Metals Thailand | | THAILAND |
| Gold | | United Precious Metal Co., Ltd. | | UNITED STATES |
| Gold | | Valcambi SA | | SWITZERLAND |
| Gold | | Western Australian Mint trading as The Perth Mint | | AUSTRALIA |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY |
| Gold | | Yamamoto Precious Metal Co., Ltd. | | JAPAN |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN |
| Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA |
| Gold | | Zijin Mining Group Co., Ltd. Gold Refinery | | CHINA |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| Tantalum | | Conghua Tantalum and Niobium Smeltry | | CHINA |
| Tantalum | | Duoluoshan | | CHINA |
| Tantalum | | Exotech Inc. | | UNITED STATES |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck GmbH Goslar | | GERMANY |
| Tantalum | | H.C. Starck GmbH Laufenburg | | GERMANY |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES |
| Tantalum | | H.C. Starck Ltd. | | JAPAN |
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| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tantalum | | H.C. Starck Smelting GmbH & Co.KG | | GERMANY |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA |
| Tantalum | | Hi-Temp Specialty Metals, Inc. | | UNITED STATES |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA |
| Tantalum | | KEMET Blue Metals | | MEXICO |
| Tantalum | | KEMET Blue Powder | | UNITED STATES |
| Tantalum | | King-Tan Tantalum Industry Ltd. | | CHINA |
| Tantalum | | LSM Brasil S.A. | | BRAZIL |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | INDIA |
| Tantalum | | Mineração Taboca S.A. | | BRAZIL |
| Tantalum | | Mitsui Mining & Smelting | | JAPAN |
| Tantalum | | Molycorp Silmet A.S. | | ESTONIA |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
| Tantalum | | Plansee SE Liezen | | AUSTRIA |
| Tantalum | | Plansee SE Reutte | | AUSTRIA |
| Tantalum | | QuantumClean | | UNITED STATES |
| Tantalum | | RFH Tantalum Smeltry Co., Ltd. | | CHINA |
| Tantalum | | Solikamsk Magnesium Works OAO | | RUSSIAN FEDERATION |
| Tantalum | | Taki Chemicals | | JAPAN |
| Tantalum | | Telex Metals | | UNITED STATES |
| Tantalum | | Tranzact, Inc. | | UNITED STATES |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN |
| Tantalum | | Yichun Jin Yang Rare Metal Co., Ltd. | | CHINA |
| Tantalum | | Zhuzhou Cemented Carbide | | CHINA |
| Tin | | Alpha | | UNITED STATES |
| Tin | | An Thai Minerals Co., Ltd. | | VIET NAM |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA |
| Tin | | China Tin Group Co., Ltd. | | CHINA |
| Tin | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA |
| Tin | | Cooperativa Metalurgica de Rondônia Ltda. | | BRAZIL |
| Tin | | CV Ayi Jaya | | INDONESIA |
| Tin | | CV Gita Pesona | | INDONESIA |
| Tin | | CV Serumpun Sebalai | | INDONESIA |
| Tin | | CV Venus Inti Perkasa
| | INDONESIA |
| Tin | | CV United Smelting | | INDONESIA |
| Tin | | Dowa | | JAPAN |
| Tin | | EM Vinto | | BOLIVIA |
| Tin | | Estanho de Rondônia S.A. | | BRAZIL |
| Tin | | Feinhutte Halsbrucke GmbH | | GERMANY |
| Tin | | Fenix Metals | | POLAND |
| Tin | | Ganzhou Liansheng Metallurgical Products Co. Ltd. | | CHINA |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA |
| Tin | | Jiangxi Ketai Advanced Material Co., Ltd. | | CHINA |
| Tin | | Linwu Xianggui Ore Smelting Co., Ltd. | | CHINA |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA |
| Tin | | Melt Metais e Ligas S.A. | | BRAZIL |
| Tin | | Metahub Industries Sdn. Bhd. | | MALAYSIA |
| Tin | | Metallic Resources, Inc. | | UNITED STATES |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Metallo-Chimique N.V. | | BELGIUM |
| Tin | | Mineração Taboca S.A. | | BRAZIL |
| Tin | | Minsur | | PERU |
| Tin | | Mitsubishi Materials Corporation | | JAPAN |
| Tin | | Nankang Nanshan Tin Manufactory Co. Ltd. | | CHINA |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIET NAM |
| Tin | | Novosibirsk Processing Plant Ltd. | | RUSSIAN FEDERATION |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| Tin | | O.M Manufacturing Philippines, Inc. | | PHILIPPINES |
| Tin | | Operaciones Metalurgical S.A. | | BOLIVIA |
| Tin | | PT Alam Lestari Kencana | | INDONESIA |
| Tin | | PT Aries Kencana Sejahtera | | INDONESIA |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA |
| Tin | | PT Babel Inti Perkasa | | INDONESIA |
| Tin | | PT Bangka Kudai Tin | | INDONESIA |
| Tin | | PT Bangka Prima Tin | | INDONESIA |
| Tin | | PT Bangka Putra Karya | | INDONESIA |
| Tin | | PT Bangka Timah Utama Sejahtera | | INDONESIA |
| Tin | | PT Bangka Tin Industry | | INDONESIA |
| Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| Tin | | PT BilliTin Makmur Lestari | | INDONESIA |
| Tin | | PT Bukit Timah | | INDONESIA |
| Tin | | PT DS Jaya Abadi | | INDONESIA |
| Tin | | PT Eunindo Usaha Mandiri | | INDONESIA |
| Tin | | PT Fang Di MulTindo | | INDONESIA |
| Tin | | PT Inti Stania Prima | | INDONESIA |
| Tin | | PT Justindo | | INDONESIA |
| Tin | | PT Karimun Mining | | INDONESIA |
| Tin | | PT Menara Cipta Mulia | | INDONESIA |
| Tin | | PT Mitra Stania Prima | | INDONESIA |
| Tin | | PT Panca Mega Persada | | INDONESIA |
| Tin | | PT Pelat Timah Nusantara Tbk | | INDONESIA |
| Tin | | PT Prima Timah Utama | | INDONESIA |
| Tin | | PT Refined Bangka Tin | | INDONESIA |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| Tin | | PT Sukses Inti Makmur | | INDONESIA |
| Tin | | PT Sumber Jaya Indah | | INDONESIA |
| Tin | | PT Timah (Persero) Tbk Kundur | | INDONESIA |
| Tin | | PT Timah (Persero) Tbk Mentok | | INDONESIA |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA |
| Tin | | PT Tirus Putra Mandiri | | INDONESIA |
| Tin | | PT Tommy Utama | | INDONESIA |
| Tin | | PT Wahana Perkit Jaya | | INDONESIA |
| Tin | | Rui Da Hung | | TAIWAN |
| Tin | | Soft Metais Ltda. | | BRAZIL |
| Tin | | Thaisarco | | THAILAND |
| Tin | | VQB Mineral and Trading Group JSC | | VIET NAM |
| Tin | | White Solder Metalurgia e Mineração Ltda. | | BRAZIL |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA |
| Tin | | Yunnan Tin Group (Holding) Company Limited | | CHINA |
| Tungsten | | A.L.M.T. TUNGSTEN Corp. | | JAPAN |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Dayu Weiliang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganxian Shirui New Material Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES |
| Tungsten | | HC Starck GmBH | | GERMANY |
| Tungsten | | H.C. Starck Smelting GmbH & Co.KG | | GERMANY |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products | | CHINA |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Company, Ltd. | | CHINA |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Kennametal Fallon | | UNITED STATES |
| Tungsten | | Kennametal Huntsville | | UNITED STATES |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Mitsui Mining & Smelting | | JAPAN |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tungsten | | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | | VIET NAM |
| Tungsten | | Pobedit, JSC | | RUSSIAN FEDERATION |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIET NAM |
| Tungsten | | Vietnam Youngsun Tungsten Industry Co., Ltd. | | VIET NAM |
| Tungsten | | Wolfram Bergbau und Hütten AG | | AUSTRIA |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA |
