Exhibit 1.01
CONFLICT MINERALS REPORT OF PHILIP MORRIS INTERNATIONAL INC. FOR THE YEAR ENDED DECEMBER 31, 20171
INTRODUCTION
Philip Morris International Inc. is a Virginia holding company incorporated in 1987. Our subsidiaries and affiliates and their licensees are engaged in the manufacture and sale of cigarettes, other tobacco products and other nicotine-containing products in markets outside of the United States of America.
This Conflict Minerals Report (the “Report”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”) for the reporting period from January 1 to December 31, 2017.
Conflict Minerals are defined by the Securities and Exchange Commission (“SEC”) as cassiterite, columbite-tantalite, wolframite and gold, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, “3TGs”). During the reporting period, we contracted to manufacture the following products:
• | Platform 1 - a precisely controlled heating device, commercialized under the IQOS brand name, into which a specially designed and proprietary tobacco unit is inserted and heated to create an aerosol, as well as related accessories and parts; and |
• | Platform 4 - battery powered e-vapor products that produce an aerosol by vaporizing a nicotine-containing liquid solution; the current generation technology products are commercialized under the Nicolites, Nicocigs and Vivid brand names, and the new e-vapor technology products are commercialized using both the Nicocigs and MESH brand names. |
In this report, we refer to Platform 1 and Platform 4 products as “Covered Products.”
In 2017, we sourced the Covered Products from only three direct suppliers (the “Direct Suppliers”). The electronic components of the Covered Products contain one or more 3TGs; such 3TGs are necessary for the functionality or production of the Covered Products.
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1 In this report, “PMI,” “Company,” “we,” “us,” and “our” refers to Philip Morris International Inc. and its subsidiaries.
We have implemented policies, procedures and a due diligence process to determine whether any of the 3TGs contained in the Covered Products are sourced from the Democratic Republic of the Congo (“DRC”) or any of its adjoining countries (“Covered Countries”) and finance armed conflict in the region. In order to support the economic activity in the region, we have communicated to our Direct Suppliers that we do not discourage them from sourcing 3TGs from the Covered Countries under our Conflict Minerals Policy (“Policy”), so long as they are determined to be “DRC conflict-free.”
We are far removed from the sources of ores from which the 3TGs contained in the Covered Products are procured and the smelters and refiners that process those ores (“SORs”). Therefore, the efforts to identify the countries of origin for the 3TGs reflect both (i) our downstream position in the supply chain2; and (ii) the applicable OECD guidance described below.
DUE DILIGENCE MEASURES
A. Design of Our Due Diligence Measures
Our Conflict Minerals due diligence was performed in line with the internationally recognized due diligence framework provided by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Guidance”), as applicable for 3TGs and downstream companies (as the term “downstream companies” is defined in the OECD Guidance). Our due diligence measures in relation to Covered Products included:
1. Establishing Company management systems and forming a dedicated cross-functional team for carrying out Conflict Minerals supply chain due diligence and reporting compliance;
2. Identifying and assessing Conflict Minerals risks in our supply chain;
3. Designing and implementing strategies to respond to Conflict Minerals risks to the extent identified;
4. Encouraging the reliance by our Direct Suppliers on an independent third-party audit protocol for assessing the due diligence practices of SORs relevant to Covered Products; and
5. Reporting on our supply chain due diligence activities, as required by Rule 13p-1.
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2 As a result of our downstream position in the supply chain, our due diligence processes are based on the necessity of seeking data from our Direct Suppliers and those suppliers seeking similar information in their supply chains to identify the original sources of the necessary Conflict Minerals. We also rely, to a large extent, on information collected and provided by third-party validation programs. Such sources may yield inaccurate or incomplete information.
B. Due Diligence Program Elements
1. Management Systems
Conflict Minerals Policy
We adopted our Conflict Minerals Policy and communicated it to our Direct Suppliers to help achieve responsible sourcing of 3TGs in our supply chain. We are committed to operating with integrity and are focused on the responsible sourcing of 3TGs. Our Policy is subject to regular reviews, is attached to this Report as Appendix A, and is publicly available on our website at: http://www.pmi.com/eng/sustainability/conflict_minerals/Pages/conflict_minerals_report.aspx.
Internal Team
Under the management of our Senior Vice President, Operations, we have established a cross-functional Conflict Minerals Team, with the expertise in sourcing, operations, sustainability, finance, corporate affairs and law. In addition, the Conflict Minerals Team has access to specialists working in various functions throughout PMI.
The Conflict Minerals Team has the overall responsibility for developing and implementing our Conflict Minerals compliance strategy, as well as for reviewing the ongoing progress and effectiveness of the Conflict Minerals reporting.
As part of our organizational framework, our Product Regulation and Compliance Department verifies ingredients and materials used in our direct materials. During this process, any Conflict Minerals reporting and compliance issues are analyzed and addressed by the Conflict Minerals Team.
Members of the team also interact with our Direct Suppliers to further improve the quality of the Conflict Minerals reporting.
Our senior management is informed of the results of our due diligence efforts, supply chain integrity and relationships with our Direct Suppliers.
Control System and Supply Chain Transparency
PMI’s control system and supply chain transparency combines internal activities, collaboration with our Direct Suppliers and reliance on the information published by industry programs such as the Responsible Minerals Initiative (“RMI”).
We relied on the RMI Conflict Minerals Reporting Template (“CMRT”) that was sent to our Direct Suppliers to collect and retain the necessary information on the chain of custody of the 3TGs contained in the Covered Products, including information about the SORs.
The CMRT is generally regarded as the most widely-used standard form to collect information about Conflict Minerals through the supply chain and was developed by several of the world’s leading consumer electronics companies.
Supplier Engagement and Other Compliance Efforts
Our agreements pertaining to the supply of Covered Products include Conflict Minerals-related provisions that are consistent with our Policy, and that recognize the need for cooperation by our Direct Suppliers in respect of Conflict Minerals reporting. We require our Direct Suppliers to comply with our due diligence requests and encourage them to participate in industry-wide or material-specific supply chain mapping initiatives.
In addition, as we stated in the Conflict Minerals report for the period ended December 31, 2016 (the “2016 Report”), in 2017 we undertook the following efforts to further improve due diligence and supplier engagement:
• | We train our employees on compliance with our Conflict Minerals policy and the underlying regulations. In addition, in 2017, we developed standardized web-based employee training programs that address the sourcing of minerals, which will be available to our employees worldwide in 2018 and will be mandatory for those employees who are responsible for procurement. |
• | Our employees communicated our Policy to our Direct Suppliers, our commitment to responsible sourcing, compliance expectations and information requirements, including grievance mechanisms. These communications focused on further improving the understanding of the Conflict Minerals regulation in our Direct Suppliers’ supply chain; reviewing the due diligence process in terms of accuracy and timeliness of responses, and fostering efforts to improve compliance. In 2017, we met in person with one of our Direct Suppliers to review the systems and procedures that this supplier used in the Conflict Minerals due diligence process, in order to identify areas of improvement. In 2017, we saw significant improvements in both timeliness and completeness of the information submitted to us by this Direct Supplier. |
• | We have communicated to our Direct Suppliers our expectation that for the manufacture of the Covered Products they should increasingly use SORs certified as “conflict-free” through the available third-party validation mechanisms (“Compliant SORs”). For the 2017 fiscal year, all three Direct Suppliers reported that they used Compliant or Active smelters for the relevant Covered Products during the period covered in this Report.3 Please see Section C for additional information. |
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3 RMI defines an SOR as Active if it participates in the Responsible Minerals Assurance Process and has committed to undergo an audit with RMI or a cross-recognized certification entity. Upon successful completion of the audit, such SORs become Compliant SORs.
• | In 2017, we published Responsible Sourcing Principles that address supply chain sustainability, including Conflict Minerals, and developed Implementation Guidelines for all of our suppliers to source minerals responsibly. In 2017, we began communicating this guidance to our suppliers and plan to complete these efforts in 2018. |
• | In 2017, we added a new Direct Supplier for one of our Covered Products. As we set out in the 2016 Report, Conflict Minerals compliance, commitment and readiness were among our criteria for selecting this supplier. In addition, Conflict Minerals criteria were included in the capability review of this supplier prior to production. |
Grievance Mechanism
We have a grievance mechanism that allows employees to report any suspected violation of PMI´s principles and practices to the senior management or the Compliance Department. Reports can be made through face-to-face discussions or via email if the employee prefers to remain anonymous. We maintain both a dedicated email address: PMI.Compliance@pmi.com, and an independently operated and confidential Compliance Helpline, that operates a phone line and a webline. Concerns can also be reported confidentially or anonymously via our website. Any such reports are to be forwarded to the Conflict Minerals Team that will review them and help design appropriate response measures. In addition, we encourage our suppliers to establish their own grievance mechanisms.
Maintain Records
We have a records retention policy applicable to Conflict Minerals-related documentation that provides for the retention of relevant records for prescribed periods.
2. Identify and Assess Risk in the Supply Chain
We reviewed the answers to the CMRT received from our Direct Suppliers and assessed their completeness, clarity and consistency. We worked with our Direct Suppliers to understand their due diligence process, confirmed that they have established a Conflict Minerals policy and obtained a list of SORs in their respective supply chains for the Covered Products.
Our Direct Suppliers confirmed that some of the SORs in their supply chain may source 3TGs from the Covered Countries and that the 3TGs may not be from recycled or scrap sources. As part of our risk assessment, we checked whether these SORs were Compliant SORs by comparing the facilities identified by our Direct Suppliers against
the list provided by the RMI and its Responsible Minerals Assurance Process (“RMAP”) as well as the list provided by the London Bullion Market Association (“LBMA”). We also followed up with additional information requests to obtain the necessary details to better assess the reliability of the responses and the risks in our supply chain.
Please also see Section B.1 for the discussion of our efforts in 2017 to help identify and assess risk in our supply chain.
3. Design and Implement a Strategy to Respond to Risks in the Supply Chain
We designed a strategy to respond to risks in our supply chain. When the Conflict Minerals Team becomes aware that the due diligence of our direct or indirect suppliers needs improvement, it provides feedback, asks clarifying questions and demands corrective actions where necessary. The Conflict Minerals Team has and will continue to provide information and training to our Direct Suppliers and will determine appropriate follow-up actions, if any, to mitigate any identified risks. Follow-up actions may include, but are not limited to, finding alternate sources of supply or terminating existing supplier relationships, as appropriate. We have encouraged our Direct Suppliers to further implement, and require their suppliers to implement, the due diligence standards that reflect the OECD guidance. Steps to improve the accuracy of the due diligence process are described in Sections B.1 above and D below. For 2017, we found no instances where it was necessary to find replacement sources of supply of Covered Products or terminate a supplier relationship due to a failure to comply with Conflict Minerals requirements. To the extent we expand our supplier base for the relevant products, Conflict Minerals compliance, commitment and readiness are among our criteria for selecting new suppliers.
4. Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We rely on the RMI’s Responsible Minerals Assurance Process for the performance of third-party audits of SORs. To the extent possible, we review whether any 3TGs sourced from the Covered Countries are “DRC conflict-free” based on the information provided by our Direct Suppliers and the information available on the RMI’s website. We encourage our suppliers to support industry organizations’ efforts to ensure that smelters’ due diligence sourcing practices are audited by independent third party auditors.
5. Report on Supply Chain Due Diligence
This Report will be filed with the SEC and is publicly available at https://www.pmi.com/our-business/about-us/standards/transparency.
C. Reasonable Country of Origin Inquiry ("RCOI") and Due Diligence on the Source and Chain of Custody
We asked our Direct Suppliers to provide answers to the CMRT to ascertain whether the 3TGs contained in the Covered Products originated from Covered Countries. Based on the evaluation of our Direct Suppliers’ responses to their CMRT, we had reasons to believe that some of the 3TGs in the Covered Products manufactured in 2017 may have originated in the Covered Countries and were not entirely from recycled or scrap sources.
Through the CMRT, our Direct Suppliers informed us that: (i) 100% of their suppliers provided responses to the CMRT; (ii) 3TGs contained in some Covered Products may have originated from the Covered Countries; (iii) 3TGs contained in Covered Products are not entirely from recycled or scrap sources; (iv) 100% of the SORs supplying 3TGs contained in the Covered Products and their locations were identified and reported; and (v) our Direct Suppliers reported that they used only Compliant or Active smelters for the respective Covered Products. We compared the facilities that the Direct Suppliers identified in their respective CMRTs to the list of SORs that are certified as “conflict-free” with the RMI and the LBMA. While one SOR identified by one of our Direct Suppliers was not on the RMI list of Compliant SORs at the time of our review, we followed up with the relevant Direct Supplier and confirmed that the Direct Supplier only sourced 3TGs from this SOR for the Covered Products prior to its removal from RMI’s Compliant SOR list.4
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4 We were informed that this SOR was removed from RMI’s Compliant SOR list in the second quarter of 2017, due to the fact that the SOR was determined by RMI to be an entity that is downstream from an SOR in the supply chain, and therefore no longer eligible for an SOR certification process.
D. Steps to Further Improve Due Diligence
We plan to concentrate on the following steps in the future:
•Continue to engage with our Direct Suppliers to communicate our expectation that they should increasingly source minerals for our products from Compliant SORs;
•Encourage our Direct Suppliers to further strengthen due diligence efforts consistent with the OECD guidance, thereby improving the quality and completeness of supply chain information available to us;
•Encourage our Direct Suppliers to continue to enforce their respective Conflict Minerals policies;
•Continue to communicate and provide training on our Policy, grievance mechanism requirements, compliance expectations and information to our present and future direct suppliers;
•Continue engagement with our Direct Suppliers to review measures for improvement of the due diligence process;
•Communicate our conflict minerals guidance developed in 2017 to our Suppliers; and
•Continue training our employees, specifically, through our standardized web-based programs, such training to be mandatory for all employees responsible for procurement and those in related supporting roles.
E. Independent Private Sector Audit
Pursuant to Rule 13p-1, an independent private sector audit is not required for this Report.
Appendix A - Conflict Minerals Policy
The United States Securities and Exchange Commission (SEC) requires our company to disclose if our products contain certain minerals (gold, tin, tungsten, and tantalum) that:
•originate in the Democratic Republic of the Congo (DRC) or an adjoining country
•contribute to the financing of armed groups that are committing human rights abuses
These minerals are known as conflict minerals. PMI’s policy and due diligence process on the use of conflict minerals is not to knowingly procure conflict minerals that originate from the DRC or an adjoining country – and we ask our direct suppliers to undertake reasonable due diligence with their supply chains to assure the same – unless those minerals are determined to be “conflict-free.”
Appendix B - List of SORs identified by our Direct Suppliers as part of the supply chain for Covered Products5
Subject Mineral | Smelter or Refiner Name | Country Location of Smelter or Refiner |
Gold | Advanced Chemical Company* | UNITED STATES OF AMERICA |
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 Corrego do Sitio Mineracao* | BRAZIL |
Gold | Argor-Heraeus S.A.* | SWITZERLAND |
Gold | Asahi Pretec Corp.* | JAPAN |
Gold | Asaka Riken Co., Ltd.* | JAPAN |
Gold | Aurubis AG* | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | PHILIPPINES |
Gold | Boliden AB* | SWEDEN |
Gold | C. Hafner GmbH + Co. KG* | GERMANY |
Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
Gold | Cendres + Metaux S.A.* | SWITZERLAND |
Gold | Chimet S.p.A.* | ITALY |
Gold | Daejin Indus Co., Ltd.* | SOUTH KOREA |
Gold | DSC (Do Sung Corporation)* | SOUTH KOREA |
Gold | DODUCO Contacts and Refining GmbH* | GERMANY |
Gold | Dowa* | JAPAN |
Gold | Eco-System Recycling Co., Ltd.* | JAPAN |
Gold | OJSC Novosibirsk Refinery* | RUSSIAN FEDERATION |
Gold | HeeSung Metal Ltd.* | SOUTH KOREA |
Gold | Heimerle + Meule GmbH* | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd.* | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG* | GERMANY |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd.* | JAPAN |
Gold | Istanbul Gold Refinery* | TURKEY |
Gold | Japan Mint* | JAPAN |
Gold | Jiangxi Copper Co., Ltd.* | CHINA |
Gold | Asahi Refining USA Inc.* | UNITED STATES OF AMERICA |
Gold | Asahi Refining Canada Ltd.* | CANADA |
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 OF AMERICA |
Gold | Kojima Chemicals Co., Ltd.* | JAPAN |
Gold | Kyrgyzaltyn JSC* | KYRGYZSTAN |
Gold | LS-NIKKO Copper Inc.* | SOUTH KOREA |
Gold | Materion* | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. * | JAPAN |
Gold | Metalor Technologies (Suzhou) Ltd.* | CHINA |
Gold | Metalor Technologies (Hong Kong) Ltd.* | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE |
Gold | Metalor Technologies S.A.* | SWITZERLAND |
Gold | Metalor USA Refining Corporation* | UNITED STATES OF AMERICA |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V.* | MEXICO |
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.S.* | TURKEY |
Gold | Nihon Material Co., Ltd.* | JAPAN |
Gold | Ohura Precious Metal Industry Co., Ltd.* | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | RUSSIAN FEDERATION |
Gold | PAMP S.A.* | SWITZERLAND |
Gold | Prioksky Plant of Non-Ferrous Metals* | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk* | INDONESIA |
Gold | PX Precinox S.A.* | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. * | SOUTH AFRICA |
Gold | Royal Canadian Mint* | CANADA |
Gold | Samduck Precious Metals* | SOUTH KOREA |
Gold | Schone Edelmetaal B.V. * | NETHERLANDS |
Gold | SEMPSA Joyeria Plateria S.A.* | SPAIN |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd.* | CHINA |
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 | Torecom* | SOUTH KOREA |
Gold | Umicore Brasil Ltda.* | BRAZIL |
Gold | Umicore S.A. Business Unit Precious Metals Refining* | BELGIUM |
Gold | United Precious Metal Refining, Inc.* | UNITED STATES OF AMERICA |
Gold | Valcambi S.A.* | SWITZERLAND |
Gold | Western Australian Mint (T/a The Perth Mint)* | AUSTRALIA |
Gold | Yamakin Co., Ltd.* | JAPAN |
Gold | Yokohama Metal Co., Ltd.* | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CHINA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | CHINA |
Gold | SAFINA A.S.* | CZECH REPUBLIC |
Gold | Umicore Precious Metals Thailand* | THAILAND |
Gold | Geib Refining Corporation* | UNITED STATES OF AMERICA |
Gold | MMTC-PAMP India Pvt., Ltd.* | INDIA |
Gold | Republic Metals Corporation* | UNITED STATES OF AMERICA |
Gold | KGHM Polska Miedz Spolka Akcyjna* | POLAND |
Gold | Singway Technology Co., Ltd.* | TAIWAN |
Gold | Al Etihad Gold LLC* | UNITED ARAB EMIRATES |
Gold | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
Gold | T.C.A S.p.A* | ITALY |
Gold | Remondis Argentia B.V.* | NETHERLANDS |
Gold | Korea Zinc Co., Ltd.* | SOUTH KOREA |
Gold | Marsam Metals* | BRAZIL |
Gold | SAAMP* | FRANCE |
Gold | L'Orfebre* S.A. | ANDORRA |
Gold | Italpreziosi* | ITALY |
Gold | SAXONIA Edelmetalle GmbH* | GERMANY |
Gold | WIELAND Edelmetalle GmbH* | GERMANY |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | AUSTRIA |
Gold | AU Traders and Refiners* | SOUTH AFRICA |
Gold | Modeltech Sdn Bhd* | MALAYSIA |
Gold | Bangalore Refinery* | INDIA |
Gold | SungEel HiMetal Co., Ltd.* | SOUTH KOREA |
Gold | Planta Recuperadora de Metales SpA* | CHILE |
Gold | Safimet S.p.A* | ITALY |
Tantalum | Asaka Riken Co., Ltd. * | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. * | CHINA |
Tantalum | Exotech Inc.* | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd.* | CHINA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited* | CHINA |
Tantalum | LSM Brasil S.A.* | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd.* | INDIA |
Tantalum | Mineracao Taboca S.A.* | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd.* | JAPAN |
Tantalum | NPM Silmet AS* | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA |
Tantalum | QuantumClean* | UNITED STATES OF AMERICA |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | Solikamsk Magnesium Works OAO* | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd.* | JAPAN |
Tantalum | Telex Metals* | UNITED STATES OF AMERICA |
Tantalum | Ulba Metallurgical Plant JSC* | KAZAKHSTAN |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd.* | CHINA |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | CHINA |
Tantalum | D Block Metals, LLC* | UNITED STATES OF AMERICA |
Tantalum | FIR Metals & Resource Ltd.* | CHINA |
Tantalum | Jiujiang Zhongao* Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CHINA |
Tantalum | KEMET Blue Metals* | MEXICO |
Tantalum | H.C. Starck Co., Ltd.* | THAILAND |
Tantalum | H.C. Starck Tantalum and Niobium GmbH* | GERMANY |
Tantalum | Jiujiang Tanbre Co., Ltd.* | CHINA |
Tantalum | King-Tan Tantalum* Industry Ltd.* | CHINA |
Tantalum | H.C. Starck Hermsdorf GmbH* | GERMANY |
Tantalum | H.C. Starck Inc.* | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd.* | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG* | GERMANY |
Tantalum | Global Advanced Metals Boyertown* | UNITED STATES OF AMERICA |
Tantalum | Global Advanced Metals Aizu* | JAPAN |
Tantalum | KEMET Blue Powder* | UNITED STATES OF AMERICA |
Tantalum | Resind Industria e Comercio Ltda.* | BRAZIL |
Tantalum | Jiangxi Tuohong New Raw Material* | CHINA |
Tantalum | Power Resources Ltd.* | REPUBLIC OF MACEDONIA |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd.* | CHINA |
Tin | Alpha* | UNITED STATES OF AMERICA |
Tin | CV Gita Pesona* | INDONESIA |
Tin | PT Aries Kencana Sejahtera* | INDONESIA |
Tin | CV Serumpun Sebalai* | INDONESIA |
Tin | CV United Smelting* | INDONESIA |
Tin | Dowa* | JAPAN |
Tin | EM Vinto* | BOLIVIA |
Tin | Fenix Metals* | POLAND |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd.* | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC* | CHINA |
Tin | China Tin Group Co., Ltd.* | CHINA |
Tin | Malaysia Smelting Corporation (MSC)* | MALAYSIA |
Tin | Metallic Resources, Inc.* | UNITED STATES OF AMERICA |
Tin | Mineracao Taboca S.A.* | BRAZIL |
Tin | Minsur* | PERU |
Tin | Mitsubishi Materials Corporation* | JAPAN |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd.* | CHINA |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND |
Tin | Operaciones Metalurgical S.A.* | BOLIVIA |
Tin | PT Artha Cipta Langgeng* | INDONESIA |
Tin | PT Babel Inti Perkasa* | 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 Karimun Mining* | 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 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 Tommy Utama* | INDONESIA |
Tin | Rui Da Hung* | TAIWAN |
Tin | Soft Metais Ltda.* | BRAZIL |
Tin | Thaisarco* | THAILAND |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CHINA |
Tin | White Solder Metalurgia e Mineracao Ltda.* | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA |
Tin | Yunnan Tin Company Limited* | CHINA |
Tin | CV Venus Inti Perkasa* | INDONESIA |
Tin | Magnu's Minerais Metais e Ligas Ltda.* | BRAZIL |
Tin | Melt Metais e Ligas S.A.* | BRAZIL |
Tin | PT ATD Makmur Mandiri Jaya* | INDONESIA |
Tin | O.M. Manufacturing Philippines, Inc.* | PHILIPPINES |
Tin | PT Inti Stania Prima* | INDONESIA |
Tin | CV Ayi Jaya* | INDONESIA |
Tin | CV Dua Sekawan* | INDONESIA |
Tin | CV Tiga Sekawan* | INDONESIA |
Tin | Resind Industria e Comercio Ltda.* | BRAZIL |
Tin | Metallo Belgium N.V.* | BELGIUM |
Tin | Metallo Spain S.L.U.* | SPAIN |
Tin | PT Bangka Prima Tin* | INDONESIA |
Tin | PT Sukses Inti Makmur* | INDONESIA |
Tin | PT Kijang Jaya Mandiri* | INDONESIA |
Tin | PT Menara Cipta Mulia* | INDONESIA |
Tin | PT Premium Tin Indonesia* | INDONESIA |
Tin | PT O.M. Indonesia* | INDONESIA |
Tin | HuiChang Hill Tin Industry Co., Ltd.* | CHINA |
Tin | Gejiu Fengming Metallurgy Chemical Plant* | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant* | CHINA |
Tin | Modeltech Sdn Bhd* | MALAYSIA |
Tin | Gejiu Jinye Mineral Company* | CHINA |
Tin | PT Lautan Harmonis Sejahtera* | INDONESIA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | CHINA |
Tin | VQB Mineral and Trading Group JSC** | VIETNAM |
Tungsten | A.L.M.T. TUNGSTEN Corp.* | JAPAN |
Tungsten | Kennametal Huntsville* | UNITED STATES OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd.* | CHINA |
Tungsten | Global Tungsten & Powders Corp.* | UNITED STATES OF AMERICA |
Tungsten | Hunan Chenzhou Mining Co., Ltd.* | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | CHINA |
Tungsten | Japan New Metals Co., Ltd.* | JAPAN |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Kennametal Fallon* | UNITED STATES OF AMERICA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | VIETNAM |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd.* | VIETNAM |
Tungsten | Wolfram Bergbau und Hutten AG* | AUSTRIA |
Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | CHINA |
Tungsten | Asia Tungsten Products Vietnam Ltd.* | VIETNAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.* | CHINA |
Tungsten | H.C. Starck Tungsten GmbH* | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co. KG* | GERMANY |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC* | VIETNAM |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | CHINA |
Tungsten | Niagara Refining LLC* | UNITED STATES OF AMERICA |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd.* | CHINA |
Tungsten | Hydrometallurg, JSC* | RUSSIAN FEDERATION |
Tungsten | Unecha Refractory metals plant* | RUSSIAN FEDERATION |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | CHINA |
Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CHINA |
Tungsten | ACL Metais Eireli* | BRAZIL |
Tungsten | Woltech Korea Co., Ltd.* | SOUTH KOREA |
Tungsten | Moliren Ltd.* | RUSSIAN FEDERATION |
_________
5 SORs that were designated, to our knowledge, as Compliant or Active as of December 31, 2017 are marked with an asterisk (unless stated otherwise).
** Until June 2017.