Exhibit 1.01
Conflict Minerals Report
For The Year Ended December 31, 2018
This Conflict Minerals Report for the reporting period from January 1, 2018 to December 31, 2018 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 ten businesses, or operating subsidiaries, at December 31, 2018. The subsidiaries are as follows: 5.11 Acquisition Corp. ("5.11" or "5.11 Tactical"), The Ergo Baby Carrier, Inc. ("Ergobaby”), Liberty Safe and Security Products, Inc. (“Liberty Safe” or “Liberty”), Fresh Hemp Foods Ltd. ("Manitoba Harvest"), Velocity Outdoor Inc. ("Velocity Outdoor"), Compass AC Holdings, Inc. (“ACI” or “Advanced Circuits”), AMT Acquisition Corporation (“Arnold” or “Arnold Magnetics”), Clean Earth Holdings Inc. ("Clean Earth"), FFI Compass Inc. ("Foam Fabricators") and Sterno CandleLamp Holdings, Inc., LLC ("Sterno").
The Company’s subsidiaries are engaged in the following lines of business:
| |
| • | 5.11 - 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. 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. |
| |
| • | Ergobaby - Headquartered in Los Angeles, California, Ergobaby is dedicated to building a global community of confident parents with smart, ergonomic solutions that enable and encourage bonding between parents and babies. Ergobaby offers a broad range of award-winning baby carriers, strollers, car seats, swaddlers, nursing pillows, and related products that fit into families’ daily lives seamlessly, comfortably and safely. Historically, Ergobaby derives more than 50% of its sales from outside of the United States. |
| |
| • | Liberty Safe - Founded in 1988, Liberty Safe is the premier designer, manufacturer and marketer of home and gun safes in North America. From its over 300,000 square foot manufacturing facility, Liberty Safe produces a wide range of home and gun safe models in a broad assortment of sizes, features and styles ranging from an entry level product to good, better and best products. Products are marketed under the Liberty brand, as well as a portfolio of licensed and private label brands, including Cabela’s, Case IH, Colt and John Deere. Liberty Safe’s products are the market share leader and are sold through an independent dealer network ("Dealer sales") in addition to various sporting goods, farm and fleet and home improvement retail outlets ("Non-Dealer sales"). Liberty has the largest independent dealer network in the industry. |
| |
| • | 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. Manitoba Harvest was sold by the Company subsequent to December 31, 2018, in February 2019. |
| |
| • | Velocity Outdoor - A leading designer, manufacturer, and marketer of airguns, archery products, laser aiming devices and related accessories, Velocity Outdoor offers its products under the highly recognizable Crosman, Benjamin, LaserMax, Ravin and CenterPoint brands that are available through national retail chains, mass merchants, dealer and distributor networks. The airgun product category consists of air rifles, air pistols and a range of accessories including targets, holsters and cases. Velocity Outdoor's other primary product categories are archery, with products including CenterPoint crossbows and the Pioneer Airbow, consumables, |
which includes steel and plastic BBs, lead pellets and CO2 cartridges, lasers for firearms, and airsoft products. In September 2018, Velocity acquired Ravin Crossbows, LLC ("Ravin" or "Ravin Crossbows"), a manufacturer and innovator of crossbows and accessories. Ravin primarily focuses on the higher-end segment of the crossbow market and has developed significant intellectual property related to the advancement of crossbow technology. Velocity Outdoor is headquartered in Bloomfield, New York.
| |
| • | Advanced Circuits - Advanced Circuits is a provider of small-run, quick-turn and volume production printed circuit boards ("PCBs") to customers throughout the United States. ACI manufactures and delivers custom printed circuit boards to customers primarily in North America. ACI is headquartered in Aurora, Colorado. |
| |
| • | Arnold - Arnold serves a variety of markets including aerospace and defense, motorsport/ automotive, oil and gas, medical, general industrial, energy, reprographics and advertising specialties. Over the course of 100+ years, Arnold has successfully evolved and adapted our products, technologies, and manufacturing presence to meet the demands of current and emerging 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. Arnold has expanded globally and built strong relationships with our customers worldwide. Arnold is the largest and, we believe, the most technically advanced U.S. manufacturer of engineered magnetic systems. Arnold is headquartered in Rochester, New York. |
| |
| • | Clean Earth - Headquartered in Hatboro, Pennsylvania, is a provider of environmental services for a variety of contaminated materials. Clean Earth provides a one-stop shop solution that analyzes, treats, documents and recycles waste streams generated in multiple end-markets such as utilities, infrastructure, chemicals, aerospace and defense, non-public/ private development, medical, industrial and dredging. |
| |
| • | Foam Fabricators - Founded in 1957 and headquartered in Scottsdale, Arizona, Foam Fabricators is a designer and manufacturer of custom molded protective foam solutions and original equipment manufacturer (OEM) components made from expanded polystyrene (EPS) and expanded polypropylene (EPP). Foam Fabricators operates 13 molding and fabricating facilities across North America and provides products to a variety of end-markets, including appliances and electronics, pharmaceuticals, health and wellness, automotive, building products and others. |
| |
| • | Sterno - Sterno is headquartered in Corona, California, is the parent company of Sterno Products, LLC ("Sterno Products"), Sterno Home Inc. ("Sterno Home"), and Rimports, LLC. Sterno is a leading manufacturer and marketer of portable food warming fuels for the hospitality and consumer markets, flameless candles and house and garden lighting for the home decor market, and wickless candle products used for home decor and fragrance systems. We made loans to, and purchased all of the equity interests in, Sterno on October 10, 2014 for approximately $160.0 million. Sterno offers a broad range of wick and gel chafing fuels, butane stoves and accessories, liquid and traditional wax candles, catering equipment and lamps through their Sterno Products division. In January 2016, Sterno acquired Northern International, Inc. ("Sterno Home"), which sells flameless candles and outdoor lighting products through the retail segment, and in February 2018, Sterno acquired Rimports, Inc. ("Rimports"), which is a manufacturer and distributor of branded and private label scented wax cubes and warmer products used for home decor and fragrance systems. |
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 2018. The Company determined that component products at seven (7) of its subsidiaries contain or may contain 3TG which are necessary to the functionality or production of their products. The seven subsidiaries and the applicable 3TG are Advanced Circuits (gold and tin), Arnold Magnetics (gold, tantalum, tin and tungsten), Ergobaby (tin), Sterno (tin and gold), 5.11 (tin and gold), Liberty (gold, tantalum, tin and tungsten) and Velocity Outdoor (tin).
Our Sterno subsidiary acquired Rimports, Inc. ("Rimports") during the year ended December 31, 2018. As permitted by the instructions to Form SD, the Company has not included Rimports in our reporting on Form SD and the Conflict Mineral report for the year ended December 31, 2018.
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, 2018 to December 31, 2018, 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 178 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 80% 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 ten 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 2017, 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:
| |
| • | worked with suppliers to obtain more complete information; |
| |
| • | followed up with suppliers that did not respond or provided inconsistent or incomplete responses; |
| |
| • | sought information regarding the smelters or refiners or smelters that processed the conflict minerals in the suppliers’ products; and |
| |
| • | 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 Jewelery 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, two (2) suppliers identified only one (1) tin smelter, resulting in a total of one (1) tin smelter being identified, and one (1) supplier identified only one (1) gold smelter resulting in one (1) gold smelter being identified by those suppliers. Based on the responses from the two (2) suppliers with only one smelter disclosed for tin and one (1) supplier with only one smelter disclosed for gold, we determined that the following smelters processed the tin or gold that is contained in certain of our products.
|
| | | |
| Metal | Official Smelter Name | CESI Smelter ID | Smelter Country |
| | | | |
| Gold | Jiangxi Copper Company Limited | CID000855 | CHINA |
| Tin | Thaiarco | CID001898 | Thailand |
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:
| |
| • | Evaluating current direct suppliers based on their responsiveness to the 2018 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 2018 to the executive management of the applicable subsidiary for review. |
| |
| • | Reaching out to suppliers earlier in the process and asking them to complete the CMRT. |
| |
| • | 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, 2018, (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
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| | | | | |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES |
| Gold | | Advanced Chemical Company | | UNITED STATES |
| Gold | | Aida Chemical Industries Co. Ltd. | | JAPAN |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| Gold | | Al Etihad Gold LLC | | UNITED ARAB EMIRATES |
| 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 | | AU Traders and Refiners | | SOUTH AFRICA |
| Gold | | Aurubis AG | | GERMANY |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| Gold | | Bangalore Refinery | | INDIA |
| 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 | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA |
| 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 Co., Ltd. | | JAPAN |
| Gold | | Elemetal Refining, LLC | | UNITED STATES |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA |
| 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 | | HeeSung Metal Ltd. | | KOREA, REPUBLIC OF |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| 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 |
| 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 | | Italpreziosi | | ITALY |
| 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 | | Kazakhmys Smelting LLC | | KAZAKHSTAN |
| Gold | | Kazzinc | | KAZAKHSTAN |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | POLAND |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN |
| Gold | | Korea Zinc Co., Ltd. | | KOREA, REPUBLIC OF |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION |
| Gold | | L' azurde Company For Jewelry | | SAUDI ARABIA |
| Gold | | L'Orfebre S.A. | | ANDORRA |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA |
| Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA |
| Gold | | Marsam Metals | | BRAZIL |
| Gold | | Materion | | UNITED STATES |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| 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 | | MMTC-PAMP India Pvt., Ltd. | | INDIA |
| Gold | | Modeltech Sdn Bhd | | MALAYSIA |
| Gold | | Morris and Watson | | NEW ZEALAND |
| Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.Ş. | | TURKEY |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Gold | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN |
| Gold | | Nihon Material Co., Ltd. | | JAPAN |
| 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 Novosibirsk Refinery | | RUSSIAN FEDERATION |
| Gold | | PAMP S.A. | | SWITZERLAND |
| Gold | | Pease and Curren | | UNITED STATES |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE |
| 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 |
| Gold | | Refinery of Seemine Gold Co., Ltd | | CHINA |
| Gold | | REMONDIS PMR B.V. | | NETHERLANDS |
| Gold | | Republic Metals Corporation | | UNITED STATES |
| Gold | | Royal Canadian Mint | | CANADA |
| Gold | | Safimet S.p.A. | | ITALY |
| Gold | | SAAMP | | FRANCE |
| Gold | | Sabin Metal Corp. | | UNITED STATES |
| Gold | | SAFINA A.S. | | CZECHIA |
| Gold | | Sai Refinery | | INDIA |
| Gold | | Samduck Precious Metals | | KOREA, REPUBLIC OF |
| Gold | | Samwon Metals Corp. | | KOREA, REPUBLIC OF |
| Gold | | SAXONIA Edelmetalle GmbH | | GERMANY |
| 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 | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA |
| Gold | | Singway Technology Co., Ltd. | | TAIWAN, PROVINCE OF 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 | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN |
| Gold | | SungEel HiMetal Co., Ltd. | | KOREA, REPUBLIC OF |
| Gold | | T.C.A. S.p.A | | ITALY |
| 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 |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Gold | | TOO Tau-Ken-Altyn | | KAZAKHSTAN |
| 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 | | Yamakin Co., Ltd. | | JAPAN |
| 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 | | Asaka Riken Co., Ltd. | | JAPAN |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| Tantalum | | Conghua Tantalum and Niobium Smeltry | | CHINA |
| Tantalum | | D Block Metals, LLC | | UNITED STATES |
| Tantalum | | Duoluoshan | | CHINA |
| Tantalum | | Exotech Inc. | | UNITED STATES |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | Guangdong Rising Rare Metals-EO Materials Ltd. | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | 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 |
| Tantalum | | H.C. Starck Smelting GmbH & Co.KG | | GERMANY |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA |
| Tantalum | | Hi-Temp Specialty Metals, Inc. | | UNITED STATES |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | KEMET Blue Metals | | MEXICO |
| Tantalum | | KEMET Blue Powder | | UNITED STATES |
| Tantalum | | King-Tan Tantalum Industry Ltd. | | CHINA |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| 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 | | NPM Silmet AS | | ESTONIA |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
| Tantalum | | Power Resources Ltd. | | MACEDONIA |
| Tantalum | | QuantumClean | | UNITED STATES |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| 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 | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| Tantalum | | Yichun Jin Yang Rare Metal Co., Ltd. | | CHINA |
| Tin | | Alpha | | UNITED STATES |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM |
| 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 | | China Tin Lai Ben Smelter Co., Ltd. | | CHINA |
| Tin | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA |
| Tin | | Cooperativa Metalurgica de Rondônia Ltda. | | BRAZIL |
| Tin | | CV Ayi Jaya | | INDONESIA |
| Tin | | CV Dua Sekawan | | INDONESIA |
| Tin | | CV Gita Pesona | | INDONESIA |
| Tin | | CV Serumpun Sebalai | | INDONESIA |
| Tin | | CV Tiga Sekawan | | INDONESIA |
| Tin | | CV Venus Inti Perkasa | | INDONESIA |
| Tin | | CV United Smelting | | INDONESIA |
| Tin | | CV Venus Inti Perkasa | | INDONESIA |
| Tin | | Dowa | | JAPAN |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIET NAM |
| Tin | | EM Vinto | | BOLIVIA |
| Tin | | Estanho de Rondônia S.A. | | BRAZIL |
| Tin | | Fenix Metals | | POLAND |
| Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA |
| Tin | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA |
| Tin | | Gejie Jinye Mineral Company | | 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 | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA |
| Tin | | Jiangxi Ketai Advanced Material 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 | | Metallic Resources, Inc. | | UNITED STATES |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Metallo Spain S.L.U. | | SPAIN |
| Tin | | Mineração Taboca S.A. | | BRAZIL |
| Tin | | Minsur | | PERU |
| Tin | | Mitsubishi Materials Corporation | | JAPAN |
| Tin | | Modeltech Sdn Bhd | | MALAYSIA |
| Tin | | Nankang Nanshan Tin Manufactory Co. Ltd. | | CHINA |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIET NAM |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| Tin | | O.M Manufacturing Philippines, Inc. | | PHILIPPINES |
| Tin | | Operaciones Metalurgical S.A. | | BOLIVIA |
| 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 Tin Industry | | INDONESIA |
| Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| Tin | | PT Bukit Timah | | INDONESIA |
| Tin | | PT DS Jaya Abadi | | INDONESIA |
| Tin | | PT Eunindo Usaha Mandiri | | INDONESIA |
| Tin | | PT Inti Stania Prima | | INDONESIA |
| Tin | | PT Justindo | | INDONESIA |
| Tin | | PT Karimun Mining | | INDONESIA |
| Tin | | PT Kijang Jaya Mandiri | | INDONESIA |
| Tin | | PT Lautan Harmonis Sejahtera | | INDONESIA |
| Tin | | PT Menara Cipta Mulia | | INDONESIA |
| Tin | | PT Mitra Stania Prima | | INDONESIA |
| Tin | | PT Panca Mega Persada | | INDONESIA |
| Tin | | PT Prima Timah Utama | | INDONESIA |
| Tin | | PT Refined Bangka Tin | | INDONESIA |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| Tin | | PT Sukses Inti Makmur | | INDONESIA |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tin | | PT Sumber Jaya Indah | | INDONESIA |
| Tin | | PT Tambang Timah | | 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 | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tin | | Rui Da Hung | | TAIWAN |
| Tin | | Soft Metais Ltda. | | BRAZIL |
| Tin | | Super Ligas | | BRAZIL |
| Tin | | Thaisarco | | THAILAND |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIET NAM |
| 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 | | ACL Metais Eireli | | BRAZIL |
| Tungsten | | A.L.M.T. TUNGSTEN Corp. | | JAPAN |
| Tungsten | | Asia Tungsten Products Vietnam, Ltd. | | VIET NAM |
| 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 | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Yatai Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA |
| 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 | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA |
| Tungsten | | Hunan Litian Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Company, Ltd. | | CHINA |
|
| | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xiushui Xianggan Nonferrous Metals 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 | | Moliren Ltd. | | RUSSIAN FEDERATION |
| Tungsten | | Niagara Refining LLC | | UNITED STATES |
| Tungsten | | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | | VIET NAM |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILLIPINES |
| Tungsten | | South-East Nonferrous Metal Company Limited of Hengyang City | | CHINA |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIET NAM |
| Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION |
| Tungsten | | Vietnam Youngsun Tungsten Industry Co., Ltd. | | VIET NAM |
| Tungsten | | Wolfram Bergbau und Hütten AG | | AUSTRIA |
| Tungsten | | Woltech Korea Co., Ltd. | | KOREA, REPUBLIC OF |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA |
