Exhibit 1.01
SolarEdge Technologies, Inc.
Conflict Minerals Report
For the calendar year ended December 31, 2015
1. Introduction
SolarEdge Technologies, Inc., together with its wholly-owned subsidiaries (“SolarEdge” or the “Company,” “we,” “our” or “us”), has prepared this Conflict Minerals Report pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and the requirements of Form SD (collectively, the “Rule”).
We have invented an intelligent inverter solution that has changed the way power is harvested and managed in a solar PV system. Our direct current (“DC”) optimized inverter system maximizes power generation at the individual PV module level while lowering the cost of energy produced by the solar PV system and providing comprehensive and advanced safety features. Our system consists of our power optimizers, inverters and cloud based monitoring platform and addresses a broad range of solar market segments, from residential solar installations to commercial and small utility scale solar installations. Since we began commercial shipments in 2010, we have shipped approximately 2.9 gigawatts (“GW”) of our DC optimized inverter systems and our products have been installed in solar PV systems in 91countries, as of March 31, 2016.
Our systems allow for superior power harvesting and module management relative to traditional inverter systems by deploying power optimizers at each PV module while maintaining a competitive system cost by keeping the AC inversion and grid interaction centralized using a simplified DC AC inverter. The entire system is monitored through our cloud based monitoring platform that enables reduced system operation and maintenance (“O&M”) costs. Our system enables each PV module to operate at its own maximum power point (“MPP”), rather than a system wide average, enabling dynamic response to real world conditions, such as atmospheric conditions, PV module aging, soiling and shading and offering improved energy yield relative to traditional inverter systems. In addition to higher efficiency, our system’s installed cost per watt is competitive with traditional inverter systems of leading manufacturers and generally lower than comparable microinverter systems of leading manufacturers. Furthermore, our architecture allows for complex rooftop system designs and enhanced safety and reliability. Our technology and system architecture were protected by 69 awarded patents and 107 patent applications filed worldwide as of March 31, 2016.
We were founded in 2006 and began commercial shipments in 2010. As of March 31, 2016, we have shipped approximately 11 million power optimizers and 450,000 inverters. We estimate that more than 231,000 installations, many of which may include multiple inverters, are currently connected to, and monitored through, our cloud based monitoring platform.
2. Overview; Applicability of Conflict Minerals Rule to SolarEdge
SolarEdge has performed an internal assessment and determined that certain Conflict Minerals are necessary to the functionality or production of our products. Accordingly, for the purposes of this assessment, all of the products that were in production in the calendar year 2015 were considered (the “Covered Products”).
SolarEdge is several levels removed from the mining of minerals (Conflict Minerals or otherwise). We also do not make purchases of raw ore or unrefined minerals and make no purchases in the Democratic Republic of Congo (“DRC”) or an adjoining country (together, the “covered countries”). SolarEdge therefore has limited influence over the sourcing of the necessary Conflict Minerals in the products that it manufactures or contracts to manufacture (we sometimes refer herein to these products that contain necessary Conflict Minerals as “in-scope products”). In addition, due to its position in the supply chain, SolarEdge depends upon its suppliers for information concerning the origin of the Conflict Minerals contained in its in-scope products. However, through the efforts described in this Conflict Minerals Report, SolarEdge seeks to ensure that its suppliers source responsibly. Minerals including tantalum, tin, tungsten and gold (“3TG”) are classified as “Conflict Minerals” and are necessary to the functionality or production of certain products that we manufacture or contract to manufacture. As such, we are subject to the Rule with respect to those necessary Conflict Minerals. The Rule requires us to conduct in good faith a reasonable country of origin inquiry (“RCOI”) into those necessary Conflict Minerals to determine whether they originated in the covered countries or are from recycled or scrap sources. If, as a result of our RCOI procedures, we know that any of our necessary Conflict Minerals originated in a covered country and are not from recycled or scrap materials, or if we have reason to believe that our necessary Conflict Minerals may have originated in a covered country and have reason to believe that they may not be from recycled or scrap sources, then we are required to exercise due diligence to determine the source and chain of custody of such Conflict Minerals to conclude if they are DRC conflict free or not.
3. Description of Product Identification and RCOI Processes
We have concluded that, during the 2015 calendar year, we have manufactured and contracted to manufacture products containing certain Conflict Minerals. As such, we conducted an RCOI process to determine whether any of the Conflict Minerals originated, or may have originated, in the covered countries and whether such Conflict Minerals originated from recycled or scrap sources.
We conducted an assessment to determine which of our direct suppliers may be providing components of our products that are likely to contain Conflict Minerals. We employed a collaborative process to identify the applicable list of components and suppliers to focus our efforts, consulting with members of our supply chain department including suppliers, senior management and other individuals familiar with the manufacturing and component sourcing processes. We verified with such personnel that the population of components and suppliers was complete and comprehensive for our 2015 products. We then identified the list of suppliers that we directly procured materials from (“tier one” or “direct” suppliers) to survey. This list includes suppliers that supplied components to our third-party equipment manufacturers on our behalf and those suppliers from whom we purchased components directly, all between January 1, 2015 and December 31, 2015.
We used a Conflict Minerals Reporting Template (the “CMRT” or the “Template”), which was developed by Conflict-Free Sourcing Initiative’s (CFSI) to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. Our RCOI consisted of surveying tier one suppliers confirmed to have supplied products or components to us that contain Conflict Minerals that are used to manufacture our products.
SolarEdge identified 290 suppliers (the “Suppliers”) that provided components for products manufactured during the calendar year 2015. Of those Suppliers, SolarEdge’s outreach was to 266 Suppliers that provided components, parts or products that SolarEdge determined contained or potentially contained necessary Conflict Minerals. In connection with its scoping determination, SolarEdge reviewed product specifications, supply chain records and bills of material, made internal engineering and supplier inquiries, commissioned an independent third-party consultant and made use of other information known to it regarding the materials composition of its products.
4. Reasonable Country of Origin Inquiry (RCOI)
As required by the Rule, SolarEdge conducted a “reasonable country of origin inquiry” with respect to calendar year 2015. Our outreach included 266 suppliers (the “Suppliers”) that provided components, parts or products that SolarEdge determined contained or potentially contained necessary Conflict Minerals incorporated into products manufactured by us. In connection with this examination, SolarEdge reviewed product specifications, supply chain records and bills of material, made internal engineering and supplier inquiries and utilized other information known to us regarding the materials composition of our products.
In order to identify the source of those components, parts and products, SolarEdge sent letters to its suppliers, informing them of the Rule and SolarEdge's policy on Conflict Minerals, asking them to comply with the Rule. We also requested suppliers to use the last CMRT revision for their compliance declaration (version 4.01) as a method to query and transmit sourcing information along the supply chain. The CMRT includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. The total number of Suppliers who delivered satisfactory CMRT was 129.
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We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a conflict free designation by the Conflict-Free Smelter Program (“CFSP”), a program of CFSI, or other independent third-party audit program. We rely on the CFSP as an independent third-party audit solution through which mineral sources are identified and independently evaluated.
When Suppliers provided us with chain surveys containing incomplete or potentially inaccurate information, we followed up with such Suppliers to seek additional clarifying information. Unresponsive suppliers were contacted on a regular basis both by email and manual outreach.
For 2015, SolarEdge identified 516 smelters and refiners that processed or may have processed the necessary Conflict Minerals contained in our in-scope products, as described in the Smelter and Refiner list attached as Annex A, as well as in the Country of Origin Information attached as Annex B.
Pursuant to the Conflict Minerals Rule, based on the results of its reasonable country of origin inquiry, SolarEdge was required to conduct due diligence for 2015. Because we were unable to identify the source of all products in our supply chain, our reasonable country of origin inquiry utilized the same processes and procedures as our due diligence. These processes and procedures are described below.
Due Diligence
Design of Due Diligence
SolarEdge utilizes due diligence measures relating to Conflict Minerals that are intended to conform with, in all material respects, the criteria set forth in 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, including the Supplement on Tin, Tantalum and Tungsten and the Supplement on Gold (Second Edition 2013) (the “OECD Guidance”). The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Our Conflict Minerals due diligence process includes: the development of a Conflict Minerals Policy, establishment of a governance charter with cross-functional team members and senior executives, communication to, and engagement of, suppliers, due diligence compliance process and measurement, record-keeping and escalation procedures. We report to the Audit Committee and the Board of Directors with respect to our due diligence process and compliance obligations. Selected elements of our program design are discussed below.
Due Diligence Performed
Step 1: Establish Strong Company Management Systems
SolarEdge's Code of Conduct defines the company's overall principles and commitment towards legal compliance, ethical conduct, human rights, anti-corruption work and environmental protection. These high expectations extend to SolarEdge's partners, subcontractors and suppliers, whom we encourage to strive beyond merely fulfilling legal compliance. SolarEdge has adopted a conflict mineral policy which provides further clarification to the principles of the Code of Conduct and SolarEdge's human rights approach regarding illegal trade of natural resources.
As part of our policy, SolarEdge is committed to respect human rights and the environment in accordance with accepted international conventions and practices, and we strive to ensure that all materials used in our products come from socially and environmentally responsible sources.
We communicate our policy to our suppliers and it is available at: http://media.corporate-ir.net/media_files/IROL/25/253935/SolarEdge_CM%20Policy_comments_%20v7%20clean.pdf (the “Conflict Mineral Policy”). In addition, in support of our compliance efforts, we have established a steering committee for enforcement of this Conflict Mineral Policy. The steering committee team consists of senior staff under SolarEdge’s legal department, supply chain management group and core technologies. The team members have been made aware of the Conflict Minerals Rule, the OECD Guidance, SolarEdge’s Conflict Minerals Policy and governance charter and have established SolarEdge’s procedures for reviewing and validating supplier responses to its inquiries.
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The SolarEdge Conflict Minerals policy includes a grievance mechanism whereby employees and suppliers can report suspected violations of the policy.
SolarEdge also utilizes an outside consultant to advise it on certain aspects of its compliance, as well as a third-party software provider to enhanced supplier data collection process and help minimize responsible sourcing risks.
The following steps have also been adopted:
1. Implementing a system of controls and transparency over the mineral supply chain through the use of the CFSI reporting template.
2. Maintaining records relating to our Conflict Minerals program for 5 years.
3. Implementing standard contract language requiring suppliers to agree to timely respond to answer, and conduct an appropriate due diligence inquiry following, any request by SolarEdge for information on any goods delivered containing Conflict Minerals, as defined under the Rule.
Step 2. Identify and Assess Risks in the Supply Chain
To assist us with our supply chain due diligence, we engaged a third-party consultant for conducing outreach to our Suppliers and archiving responses from Suppliers. We conducted a supply chain survey requesting direct suppliers to identify smelters and refiners and country of origin, through use of the Template.
We, in conjunction with our third-party consultant, reviewed our entire known component and outsourced manufacturing supply chain for the calendar year 2015, which consisted of approximately 290 suppliers. Our outreach included 266 Suppliers that provided components, parts or products that were determined by SolarEdge to contain or potentially contain necessary Conflict Minerals and that were incorporated into products manufactured by us. The responses were reviewed against criteria developed internally and, where necessary, we reached out for further engagement and to receive additional information from our suppliers. These criteria included untimely or incomplete responses, as well as inconsistencies within the data reported in the Template. We worked directly with these suppliers to receive revised responses.
We compared the CFSI validated smelter list against those smelters identified by our suppliers and, as described in our Conflict Minerals Policy, SolarEdge does not purchase Conflict Minerals directly from mines, smelters or refiners. Tracing minerals to their sources is a challenge that requires us to rely on our suppliers in our efforts to achieve supply chain transparency, including for obtaining information regarding the origin of the Conflict Minerals.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
We work with a significant number of suppliers and they are diverse in terms of size. Based on our research from publicly available data, sixty-two of our suppliers, which represent 23.3% (62 out of 266 suppliers) are also SEC registrants and subject to the Rule. After SolarEdge receives CMRT responses from Suppliers, it reviews the responses. SolarEdge follows up with Suppliers whose CMRT appears to be incomplete or contain errors or inaccuracies, requesting that the Supplier submit a revised response. For illustration purposes, following some of SolarEdge steps: 1) verifying smelters according to CFSI smelters list; 2) validating questions in the CMRT file and insuring that there is logical in line with the answers, and 3) verifying and cross checking between the smelter location and the CFSI smelter approved list. Any smelter’s location in the DRC which is not CFSI approved is flagged for further review.
If a completed CMRT indicates a smelter or refiner, SolarEdge reviews this information against the Standard Smelter Names tab of the CMRT and the lists of “compliant” and “active” smelters and refiners published by the CFSI. If an indicated smelter or refiner is not listed on the Standard Smelter Names tab or the Commerce Department List or listed as compliant by the CFSI, SolarEdge requests the assistance of the supplier or contacts the listed entity to attempt to determine whether that entity is actually a smelter or refiner, the mine or location of origin of the Conflict Minerals processed by the smelter or refiner and whether it is known to obtain Conflict Minerals from sources that directly or indirectly finance or benefit armed groups in any of the Covered Countries.
SolarEdge reports back to senior management, summarizing our risk mitigation efforts.
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Step 4. Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
SolarEdge does not have a direct relationship with 3TG smelters and refiners. As a result, SolarEdge does not perform direct audits of these entities within its supply chain, but rather relies on due diligence performed by organizations such as the CFSI.
Step 5. Report Annually on Supply Chain Due Diligence
SolarEdge files a Form SD and, to the extent required, a Conflict Minerals Report, with the Securities and Exchange Commission and makes these filings publicly available on the Company’s corporate website at http://investors.solaredge.com/phoenix.zhtml?c=253935&p=irol-govHighlights.
Results of Assessment
Based on the information obtained through the due diligence process described above, we do not have sufficient information to determine the products containing Conflict Minerals and/or the country of origin of the Conflict Minerals in those products and/or the facilities used to process Conflict Minerals in those products.
Tracing minerals back to the mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting methodology outlined by the CFSI’s joint industry programs and outreach initiatives and requiring that our Suppliers conform with standards that meet the OECD guidelines and report to us using the Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or location of origin of the 3TG in our supply chain and responses to such inquiries represent the most reasonable source information available. Through this industry joint effort, we have made reasonable efforts to make a reasonable determination of the mines or locations of origin of the 3TG in our supply chain. We were unable, however, to ascertain the specific country of origin and/or chain of custody of all necessary Conflict Minerals processed by the facilities that contributed to our Covered Products.
SolarEdge approached 266 suppliers. Out of these:
- Number of suppliers who replied (response rate): 129 (48%). Out of these:
- Number of suppliers who provided data at a company level: 94 (72%)
- Number of suppliers who provided data at a product level: 36 (28%)
- Number of suppliers which were classified as “Free no 3TG”: 23 (17%)
- Number of suppliers which were classified as "DRC conflict free" (from DRC, all SORs are certified): 8 (6%)
- Number of suppliers which were classified as DRC, due diligence not yet completed: 39 (30%)
- Number of suppliers which were classified as Not from DRC due diligence not yet completed: 16 (12.5%)
- Number of suppliers which were classified as "Not from DRC not all smelters are certified": 33 (25.5%)
Smelter and Refiner list attached as Annex A as well as in the Country of Origin Information attached as Annex B.
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Smelters and refiners verified as conflict free or in the audit process (230):
| Comply & Active | Total | |
| Tin | 59 (27%) | 216 |
| Tantalum | 46 (70%) | 66 |
| Tungstan | 30 (55%) | 55 |
| Gold | 95 (53%) | 179 |
| Total | 230 | 516 |
Status of identified smelters and refiners:
| Comply - Verified Conflict Free | 215 (42%) |
| Active - Participating in an audit process | 15 (3%) |
| Listed but not active | 103 (20%) |
| Outreach required | 183 (35%) |
| Total | 516 |
Improvement to Mitigate Risks
As we further develop our due diligence program, we intend to enhance supplier communication and escalation processes to improve due diligence data accuracy and completion and continue to influence additional smelters to be designated as “conflict-free”, where possible. To the extent we are not able to determine in the future that we are sourcing from non-conflict free smelters we plan to move toward using Conflict Free smelters within a reasonable time frame. We also intend to request of any of our suppliers that we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries, that they establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance.
We understand that supply chain Due Diligence is a dynamic process and requires on-going risk monitoring. Therefore, after implementing our risk mitigation strategy, SolarEdge intends to go back to Step 2 of the OECD guidelines to ensure effective management of risks.
Cautionary Note on Forward-Looking Statements
This Report contains forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, and other federal securities laws. Investors are cautioned that statements in this Report that are not strictly historical statements, including without limitation, SolarEdge’s intentions and expectations and future results regarding further supplier engagement and risk mitigation efforts and strategy, constitute forward-looking statements that involve risks and uncertainties. Actual results could differ materially from the forward-looking statements. Risks and uncertainties that could cause actual results to differ include, without limitation, risks and uncertainties associated with the progress of industry and other supply chain transparency and smelter or refiner validation programs for Conflict Minerals (including the possibility of inaccurate information, fraud and other irregularities), inadequate supplier education and knowledge, limitations on the ability or willingness of suppliers to provide more accurate, complete and detailed information and limitations on SolarEdge’s ability to verify the accuracy or completeness of any information received from Suppliers or others.
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Annex A
Smelter and Refiner list
| Smelter Identification | Smelter Name | Metal | Status |
| CID000019 | Aida Chemical Industries Co., Ltd. | Gold | Comply |
| CID000035 | Allgemeine Gold-und Silberscheideanstalt A.G. | Gold | Comply |
| CID000058 | AngloGold Ashanti Córrego do Sítio Mineração | Gold | Comply |
| CID000077 | Argor-Heraeus SA | Gold | Comply |
| CID000082 | Asahi Pretec Corporation | Gold | Comply |
| CID000090 | Asaka Riken Co., Ltd. | Gold | Comply |
| CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold | Comply |
| CID000113 | Aurubis AG | Gold | Comply |
| CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold | Comply |
| CID000157 | Boliden AB | Gold | Comply |
| CID000176 | C. Hafner GmbH + Co. KG | Gold | Comply |
| CID000185 | CCR Refinery - Glencore Canada Corporation | Gold | Comply |
| CID000233 | Chimet S.p.A. | Gold | Comply |
| CID000362 | DODUCO GmbH | Gold | Comply |
| CID000401 | Dowa | Gold | Comply |
| CID000425 | Eco-System Recycling Co., Ltd. | Gold | Comply |
| CID000493 | OJSC Novosibirsk Refinery | Gold | Comply |
| CID000694 | Heimerle + Meule GmbH | Gold | Comply |
| CID000707 | Heraeus Ltd. Hong Kong | Gold | Comply |
| CID000711 | Heraeus Precious Metals GmbH & Co. KG | Gold | Comply |
| CID000807 | Ishifuku Metal Industry Co., Ltd. | Gold | Comply |
| CID000814 | Istanbul Gold Refinery | Gold | Comply |
| CID000823 | Japan Mint | Gold | Comply |
| CID000855 | Jiangxi Copper Company Limited | Gold | Comply |
| CID000920 | Asahi Refining USA Inc. | Gold | Comply |
| CID000924 | Asahi Refining Canada Limited | Gold | Comply |
| CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold | Comply |
| CID000929 | JSC Uralelectromed | Gold | Comply |
| CID000937 | JX Nippon Mining & Metals Co., Ltd. | Gold | Comply |
| CID000957 | Kazzinc | Gold | Comply |
| CID000969 | Kennecott Utah Copper LLC | Gold | Comply |
| CID000981 | Kojima Chemicals Co., Ltd. | Gold | Comply |
| CID001032 | L' azurde Company For Jewelry | Gold | Comply |
| CID001078 | LS-NIKKO Copper Inc. | Gold | Comply |
| CID001113 | Materion | Gold | Comply |
| CID001119 | Matsuda Sangyo Co., Ltd. | Gold | Comply |
| CID001149 | Metalor Technologies (Hong Kong) Ltd. | Gold | Comply |
| CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | Gold | Comply |
| CID001153 | Metalor Technologies SA | Gold | Comply |
| CID001157 | Metalor USA Refining Corporation | Gold | Comply |
| CID001161 | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | Gold | Comply |
| CID001188 | Mitsubishi Materials Corporation | Gold | Comply |
| CID001193 | Mitsui Mining and Smelting Co., Ltd. | Gold | Comply |
| CID001204 | Moscow Special Alloys Processing Plant | Gold | Comply |
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| Smelter Identification | Smelter Name | Metal | Status |
| CID001220 | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Gold | Comply |
| CID001259 | Nihon Material Co., Ltd. | Gold | Comply |
| CID001322 | Elemetal Refining, LLC | Gold | Comply |
| CID001325 | Ohura Precious Metal Industry Co., Ltd. | Gold | Comply |
| CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | Comply |
| CID001352 | PAMP SA | Gold | Comply |
| CID001386 | Prioksky Plant of Non-Ferrous Metals | Gold | Comply |
| CID001397 | PT Aneka Tambang (Persero) Tbk | Gold | Comply |
| CID001498 | PX Précinox SA | Gold | Comply |
| CID001512 | Rand Refinery (Pty) Ltd. | Gold | Comply |
| CID001534 | Royal Canadian Mint | Gold | Comply |
| CID001573 | Schone Edelmetaal B.V. | Gold | Comply |
| CID001585 | SEMPSA Joyería Platería SA | Gold | Comply |
| CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold | Comply |
| CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | Gold | Comply |
| CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | Gold | Comply |
| CID001761 | Solar Applied Materials Technology Corp. | Gold | Comply |
| CID001798 | Sumitomo Metal Mining Co., Ltd. | Gold | Comply |
| CID001875 | Tanaka Kikinzoku Kogyo K.K. | Gold | Comply |
| CID001916 | The Refinery of Shandong Gold Mining Co., Ltd. | Gold | Comply |
| CID001938 | Tokuriki Honten Co., Ltd. | Gold | Comply |
| CID001977 | Umicore Brasil Ltda. | Gold | Comply |
| CID001980 | Umicore SA Business Unit Precious Metals Refining | Gold | Comply |
| CID001993 | United Precious Metal Refining, Inc. | Gold | Comply |
| CID002003 | Valcambi SA | Gold | Comply |
| CID002030 | Western Australian Mint trading as The Perth Mint | Gold | Comply |
| CID002100 | Yamamoto Precious Metal Co., Ltd. | Gold | Comply |
| CID002129 | Yokohama Metal Co., Ltd. | Gold | Comply |
| CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Gold | Comply |
| CID002243 | Zijin Mining Group Co., Ltd. Gold Refinery | Gold | Comply |
| CID002314 | Umicore Precious Metals Thailand | Gold | Comply |
| CID002509 | MMTC-PAMP India Pvt., Ltd. | Gold | Comply |
| CID002510 | Republic Metals Corporation | Gold | Comply |
| CID002516 | Singway Technology Co., Ltd. | Gold | Comply |
| CID002580 | T.C.A S.p.A | Gold | Comply |
| CID002779 | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | Gold | Comply |
| CID000211 | Changsha South Tantalum Niobium Co., Ltd. | Tantalum | Comply |
| CID000291 | Conghua Tantalum and Niobium Smeltry | Tantalum | Comply |
| CID000410 | Duoluoshan | Tantalum | Comply |
| CID000456 | Exotech Inc. | Tantalum | Comply |
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| Smelter Identification | Smelter Name | Metal | Status |
| CID000460 | F&X Electro-Materials Ltd. | Tantalum | Comply |
| CID000616 | Guangdong Zhiyuan New Material Co., Ltd. | Tantalum | Comply |
| CID000731 | Hi-Temp Specialty Metals, Inc. | Tantalum | Comply |
| CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | Comply |
| CID000917 | Jiujiang Tanbre Co., Ltd. | Tantalum | Comply |
| CID000973 | King-Tan Tantalum Industry Ltd. | Tantalum | Comply |
| CID001076 | LSM Brasil S.A. | Tantalum | Comply |
| CID001163 | Metallurgical Products India Pvt., Ltd. | Tantalum | Comply |
| CID001175 | Mineração Taboca S.A. | Tantalum | Comply |
| CID001192 | Mitsui Mining & Smelting | Tantalum | Comply |
| CID001200 | Molycorp Silmet A.S. | Tantalum | Comply |
| CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | Comply |
| CID001508 | QuantumClean | Tantalum | Comply |
| CID001522 | RFH Tantalum Smeltry Co., Ltd. | Tantalum | Comply |
| CID001769 | Solikamsk Magnesium Works OAO | Tantalum | Comply |
| CID001869 | Taki Chemicals | Tantalum | Comply |
| CID001891 | Telex Metals | Tantalum | Comply |
| CID001969 | Ulba Metallurgical Plant JSC | Tantalum | Comply |
| CID002232 | Zhuzhou Cemented Carbide | Tantalum | Comply |
| CID002307 | Yichun Jin Yang Rare Metal Co., Ltd. | Tantalum | Comply |
| CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | Comply |
| CID002501 | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | Tantalum | Comply |
| CID002504 | D Block Metals, LLC | Tantalum | Comply |
| CID002505 | FIR Metals & Resource Ltd. | Tantalum | Comply |
| CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | Comply |
| CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | Tantalum | Comply |
| CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | Comply |
| CID002539 | KEMET Blue Metals | Tantalum | Comply |
| CID002540 | Plansee SE Liezen | Tantalum | Comply |
| CID002544 | H.C. Starck Co., Ltd. | Tantalum | Comply |
| CID002545 | H.C. Starck GmbH Goslar | Tantalum | Comply |
| CID002546 | H.C. Starck GmbH Laufenburg | Tantalum | Comply |
| CID002547 | H.C. Starck Hermsdorf GmbH | Tantalum | Comply |
| CID002548 | H.C. Starck Inc. | Tantalum | Comply |
| CID002549 | H.C. Starck Ltd. | Tantalum | Comply |
| CID002550 | H.C. Starck Smelting GmbH & Co.KG | Tantalum | Comply |
| CID002556 | Plansee SE Reutte | Tantalum | Comply |
| CID002557 | Global Advanced Metals Boyertown | Tantalum | Comply |
| CID002558 | Global Advanced Metals Aizu | Tantalum | Comply |
| CID002568 | KEMET Blue Powder | Tantalum | Comply |
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| Smelter Identification | Smelter Name | Metal | Status |
| CID002571 | Tranzact, Inc. | Tantalum | Comply |
| CID002707 | Resind Indústria e Comércio Ltda. | Tantalum | Comply |
| CID000244 | Jiangxi Ketai Advanced Material Co., Ltd. | Tin | Comply |
| CID000292 | Alpha | Tin | Comply |
| CID000295 | Cooperativa Metalurgica de Rondônia Ltda. | Tin | Comply |
| CID000306 | CV Gita Pesona | Tin | Comply |
| CID000307 | PT Justindo | Tin | Comply |
| CID000309 | PT Aries Kencana Sejahtera | Tin | Comply |
| CID000313 | CV Serumpun Sebalai | Tin | Comply |
| CID000315 | CV United Smelting | Tin | Comply |
| CID000402 | Dowa | Tin | Comply |
| CID000438 | EM Vinto | Tin | Comply |
| CID000468 | Fenix Metals | Tin | Comply |
| CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | Tin | Comply |
| CID001070 | China Tin Group Co., Ltd. | Tin | Comply |
| CID001105 | Malaysia Smelting Corporation (MSC) | Tin | Comply |
| CID001142 | Metallic Resources, Inc. | Tin | Comply |
| CID001173 | Mineração Taboca S.A. | Tin | Comply |
| CID001182 | Minsur | Tin | Comply |
| CID001191 | Mitsubishi Materials Corporation | Tin | Comply |
| CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | Tin | Comply |
| CID001337 | Operaciones Metalurgical S.A. | Tin | Comply |
| CID001399 | PT Artha Cipta Langgeng | Tin | Comply |
| CID001402 | PT Babel Inti Perkasa | Tin | Comply |
| CID001419 | PT Bangka Tin Industry | Tin | Comply |
| CID001421 | PT Belitung Industri Sejahtera | Tin | Comply |
| CID001424 | PT BilliTin Makmur Lestari | Tin | Comply |
| CID001428 | PT Bukit Timah | Tin | Comply |
| CID001434 | PT DS Jaya Abadi | Tin | Comply |
| CID001438 | PT Eunindo Usaha Mandiri | Tin | Comply |
| CID001453 | PT Mitra Stania Prima | Tin | Comply |
| CID001457 | PT Panca Mega Persada | Tin | Comply |
| CID001458 | PT Prima Timah Utama | Tin | Comply |
| CID001460 | PT Refined Bangka Tin | Tin | Comply |
| CID001463 | PT Sariwiguna Binasentosa | Tin | Comply |
| CID001468 | PT Stanindo Inti Perkasa | Tin | Comply |
| CID001471 | PT Sumber Jaya Indah | Tin | Comply |
| CID001477 | PT Timah (Persero) Tbk Kundur | Tin | Comply |
| CID001482 | PT Timah (Persero) Tbk Mentok | Tin | Comply |
| CID001490 | PT Tinindo Inter Nusa | Tin | Comply |
10
| Smelter Identification | Smelter Name | Metal | Status |
| CID001493 | PT Tommy Utama | Tin | Comply |
| CID001539 | Rui Da Hung | Tin | Comply |
| CID001758 | Soft Metais Ltda. | Tin | Comply |
| CID001898 | Thaisarco | Tin | Comply |
| CID002015 | VQB Mineral and Trading Group JSC | Tin | Comply |
| CID002036 | White Solder Metalurgia e Mineração Ltda. | Tin | Comply |
| CID002180 | Yunnan Tin Group (Holding) Company Limited | Tin | Comply |
| CID002455 | CV Venus Inti Perkasa | Tin | Comply |
| CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Tin | Comply |
| CID002479 | PT Wahana Perkit Jaya | Tin | Comply |
| CID002500 | Melt Metais e Ligas S/A | Tin | Comply |
| CID002503 | PT ATD Makmur Mandiri Jaya | Tin | Comply |
| CID002517 | O.M. Manufacturing Philippines, Inc. | Tin | Comply |
| CID002530 | PT Inti Stania Prima | Tin | Comply |
| CID002570 | CV Ayi Jaya | Tin | Comply |
| CID002696 | PT Cipta Persada Mulia | Tin | Comply |
| CID002706 | Resind Indústria e Comércio Ltda. | Tin | Comply |
| CID002773 | Metallo-Chimique N.V. | Tin | Comply |
| CID002774 | Elmet S.L.U. (Metallo Group) | Tin | Comply |
| CID002776 | PT Bangka Prima Tin | Tin | Comply |
| CID002816 | PT Sukses Inti Makmur | Tin | Comply |
| CID000004 | A.L.M.T. TUNGSTEN Corp. | Tungsten | Comply |
| CID000105 | Kennametal Huntsville | Tungsten | Comply |
| CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | Comply |
| CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | Tungsten | Comply |
| CID000499 | Fujian Jinxin Tungsten Co., Ltd. | Tungsten | Comply |
| CID000568 | Global Tungsten & Powders Corp. | Tungsten | Comply |
| CID000766 | Hunan Chenzhou Mining Co., Ltd. | Tungsten | Comply |
| CID000769 | Hunan Chunchang Nonferrous Metals Co., Ltd. | Tungsten | Comply |
| CID000825 | Japan New Metals Co., Ltd. | Tungsten | Comply |
| CID000875 | Ganzhou Huaxing Tungsten Products Co., Ltd. | Tungsten | Comply |
| CID001889 | Tejing (Vietnam) Tungsten Co., Ltd. | Tungsten | Comply |
| CID002011 | Vietnam Youngsun Tungsten Industry Co., Ltd. | Tungsten | Comply |
| CID002044 | Wolfram Bergbau und Hütten AG | Tungsten | Comply |
| CID002082 | Xiamen Tungsten Co., Ltd. | Tungsten | Comply |
| CID002095 | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Tungsten | Comply |
| CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Tungsten | Comply |
| CID002319 | Malipo Haiyu Tungsten Co., Ltd. | Tungsten | Comply |
| CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | Tungsten | Comply |
| CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | Comply |
11
| Smelter Identification | Smelter Name | Metal | Status |
| CID002494 | Ganzhou Grand Sea W & Mo Group Co Ltd | Tungsten | Comply |
| CID002502 | Asia Tungsten Products Vietnam Ltd. | Tungsten | Comply |
| CID002513 | Chenzhou Diamond Tungsten Products Co., Ltd. | Tungsten | Comply |
| CID002535 | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | Tungsten | Comply |
| CID002536 | Ganzhou Yatai Tungsten Co., Ltd. | Tungsten | Comply |
| CID002541 | H.C. Starck GmbH | Tungsten | Comply |
| CID002542 | H.C. Starck Smelting GmbH & Co.KG | Tungsten | Comply |
| CID002543 | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Tungsten | Comply |
| CID002578 | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | Tungsten | Comply |
| CID002589 | Niagara Refining LLC | Tungsten | Comply |
| CID002649 | Hydrometallurg, JSC | Tungsten | Comply |
| CID000015 | Advanced Chemical Company | Gold | Active |
| CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Gold | Active |
| CID000189 | Cendres + Métaux SA | Gold | Active |
| CID000328 | Daejin Indus Co., Ltd. | Gold | Active |
| CID000359 | DSC (Do Sung Corporation) | Gold | Active |
| CID001147 | Metalor Technologies (Suzhou) Ltd. | Gold | Active |
| CID001236 | Navoi Mining and Metallurgical Combinat | Gold | Active |
| CID001555 | Samduck Precious Metals | Gold | Active |
| CID001955 | Torecom | Gold | Active |
| CID002355 | Faggi Enrico S.p.A. | Gold | Active |
| CID002459 | Geib Refining Corporation | Gold | Active |
| CID002511 | KGHM Polska Miedź Spółka Akcyjna | Gold | Active |
| CID002605 | Korea Zinc Co. Ltd. | Gold | Active |
| CID002777 | SAXONIA Edelmetalle GmbH | Gold | Active |
| CID002778 | WIELAND Edelmetalle GmbH | Gold | Active |
| CID000028 | Aktyubinsk Copper Company TOO | Gold | Listed but not active |
| CID000141 | Bauer Walser AG | Gold | Listed but not active |
| CID000180 | Caridad | Gold | Listed but not active |
| CID000197 | Yunnan Copper Industry Co., Ltd. | Gold | Listed but not active |
| CID000236 | China Golddeal | Gold | Listed but not active |
| CID000242 | China National Gold Group Corporation | Gold | Listed but not active |
| CID000264 | Chugai Mining | Gold | Listed but not active |
| CID000282 | Colt refining | Gold | Listed but not active |
| CID000284 | Codelco | Gold | Listed but not active |
12
| Smelter Identification | Smelter Name | Metal | Status |
| CID000288 | Colt Refining | Gold | Listed but not active |
| CID000333 | DaeryongENC | Gold | Listed but not active |
| CID000343 | Daye Non-Ferrous Metals Mining Ltd. | Gold | Listed but not active |
| CID000465 | Feinhütte Halsbrücke GmbH | Gold | Listed but not active |
| CID000522 | Gansu Seemine Material Hi-Tech Co., Ltd. | Gold | Listed but not active |
| CID000651 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Gold | Listed but not active |
| CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | Gold | Listed but not active |
| CID000767 | Hunan Chenzhou Mining Co., Ltd. | Gold | Listed but not active |
| CID000778 | Hwasung CJ Co., Ltd. | Gold | Listed but not active |
| CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Gold | Listed but not active |
| CID000956 | Kazakhmys Smelting LLC | Gold | Listed but not active |
| CID000988 | Korea Metal Co., Ltd. | Gold | Listed but not active |
| CID001029 | Kyrgyzaltyn JSC | Gold | Listed but not active |
| CID001056 | Lingbao Gold Company Limited | Gold | Listed but not active |
| CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Gold | Listed but not active |
| CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Gold | Listed but not active |
| CID001328 | OJSC Kolyma Refinery | Gold | Listed but not active |
| CID001362 | Penglai Penggang Gold Industry Co., Ltd. | Gold | Listed but not active |
| CID001546 | Sabin Metal Corp. | Gold | Listed but not active |
| CID001562 | SAMWON Metals Corp. | Gold | Listed but not active |
| CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Gold | Listed but not active |
| CID001754 | So Accurate Group, Inc. | Gold | Listed but not active |
| CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | Gold | Listed but not active |
| CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | Gold | Listed but not active |
13
| Smelter Identification | Smelter Name | Metal | Status |
| CID002282 | Morris and Watson | Gold | Listed but not active |
| CID002312 | Guangdong Jinding Gold Limited | Gold | Listed but not active |
| CID002515 | Fidelity Printers and Refiners Ltd. | Gold | Listed but not active |
| CID002559 | Yantai Zhaojinlufu | Gold | Listed but not active |
| CID002560 | Al Etihad Gold Refinery DMCC | Gold | Listed but not active |
| CID002821 | Metahub Industries Sdn. Bhd. | Gold | Listed but not active |
| CID001634 | Shanghai Jiangxi Metals Co. Ltd | Tantalum | Listed but not active |
| CID001879 | Tantalite Resources | Tantalum | Listed but not active |
| CID000169 | Brinkmann Chemie AG | Tin | Listed but not active |
| CID000196 | CFC Cooperativa dos Fundidores de Cassiterita da Amazônia Ltda. | Tin | Listed but not active |
| CID000278 | CNMC (Guangxi) PGMA Co., Ltd. | Tin | Listed but not active |
| CID000304 | CV Duta Putra Bangka | Tin | Listed but not active |
| CID000308 | CV Makmur Jaya | Tin | Listed but not active |
| CID000448 | Estanho de Rondônia S.A. | Tin | Listed but not active |
| CID000466 | Feinhütte Halsbrücke GmbH | Tin | Listed but not active |
| CID000553 | Gejiu YunXin Colored Electrolysis Ltd | Tin | Listed but not active |
| CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | Tin | Listed but not active |
| CID000572 | Gold Bell Group | Tin | Listed but not active |
| CID000760 | Huichang Jinshunda Tin Co., Ltd. | Tin | Listed but not active |
| CID000864 | Jiangxi Nanshan | Tin | Listed but not active |
| CID000942 | Gejiu Kai Meng Industry and Trade LLC | Tin | Listed but not active |
| CID001063 | Linwu Xianggui Ore Smelting Co., Ltd. | Tin | Listed but not active |
| CID001136 | Metahub Industries Sdn. Bhd. | Tin | Listed but not active |
| CID001143 | Metallo Chimique | Tin | Listed but not active |
14
| Smelter Identification | Smelter Name | Metal | Status |
| CID001179 | Tin Co. Ltd, Minmetals Ganzhou | Tin | Listed but not active |
| CID001231 | Nankang Nanshan Tin Manufactory Co., Ltd. | Tin | Listed but not active |
| CID001305 | Novosibirsk Processing Plant Ltd. | Tin | Listed but not active |
| CID001343 | Operaciones Metalugicas SA. | Tin | Listed but not active |
| CID001393 | PT Alam Lestari Kencana | Tin | Listed but not active |
| CID001406 | PT Babel Surya Alam Lestari | Tin | Listed but not active |
| CID001409 | PT Bangka Kudai Tin | Tin | Listed but not active |
| CID001412 | PT Bangka Putra Karya | Tin | Listed but not active |
| CID001416 | PT Bangka Timah Utama Sejahtera | Tin | Listed but not active |
| CID001442 | PT Fang Di MulTindo | Tin | Listed but not active |
| CID001445 | PT HP Metals Indonesia | Tin | Listed but not active |
| CID001448 | PT Karimun Mining | Tin | Listed but not active |
| CID001449 | PT Koba Tin | Tin | Listed but not active |
| CID001466 | PT Seirama Tin Investment | Tin | Listed but not active |
| CID001476 | PT Supra Sukses Trinusa | Tin | Listed but not active |
| CID001486 | PT Pelat Timah Nusantara Tbk | Tin | Listed but not active |
| CID001494 | PT Yinchendo Mining Industry | Tin | Listed but not active |
| CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Tin | Listed but not active |
| CID002042 | Westmetall GmbH & Co.KG | Tin | Listed but not active |
| CID002121 | Yifeng Tin Industry (Chenzhou) Co Ltd | Tin | Listed but not active |
| CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Tin | Listed but not active |
| CID002287 | PT HANJAYA PERKASA METALS | Tin | Listed but not active |
| CID002476 | PT Singkep Times Utama | Tin | listed but not Active |
| CID002478 | PT Tirus Putra Mandiri | Tin | Listed but not active |
15
| Smelter Identification | Smelter Name | Metal | Status |
| CID002507 | Phoenix Metal Ltd. | Tin | Listed but not active |
| CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Tin | Listed but not active |
| CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Tin | Listed but not active |
| CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Tin | Listed but not active |
| CID002592 | CV Dua Sekawan | Tin | Listed but not active |
| CID002703 | An Vinh Joint Stock Mineral Processing Company | Tin | Listed but not active |
| CID002825 | An Thai Minerals Company Limited | Tin | Listed but not active |
| CID000345 | Dayu Weiliang Tungsten Co., Ltd. | Tungsten | Listed but not active |
| CID000868 | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | Tungsten | Listed but not active |
| CID000966 | Kennametal Fallon | Tungsten | Listed but not active |
| CID002047 | Wolfram Company CJSC | Tungsten | Listed but not active |
| CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Tungsten | Listed but not active |
| CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | Tungsten | Listed but not active |
| CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Tungsten | Listed but not active |
| CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Tungsten | Listed but not active |
| CID002493 | Jiangxi Richsea New Materials Co., Ltd. | Tungsten | Listed but not active |
| CID002518 | Dayu Jincheng Tungsten Industry Co., Ltd. | Tungsten | Listed but not active |
| CID002531 | Ganxian Shirui New Material Co., Ltd. | Tungsten | Listed but not active |
| CID002532 | Pobedit, JSC | Tungsten | Listed but not active |
| CID002538 | Sanher Tungsten Vietnam Co., Ltd. | Tungsten | Listed but not active |
| CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Tungsten | Listed but not active |
| CID002579 | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | Tungsten | Listed but not active |
| 0 | Alpha Metals Korea | Gold | Outreach required |
| 0 | Atotech | Gold | Outreach required |
16
| Smelter Identification | Smelter Name | Metal | Status |
| 0 | AURA-II | Gold | Outreach required |
| 0 | BALORE REFINERSGA | Gold | Outreach required |
| 0 | Bangalore Refinary | Gold | Outreach required |
| 0 | BANGALORE REFINERY P | Gold | Outreach required |
| 0 | Bangalore Refinery Pvt Ltd | Gold | Outreach required |
| 0 | China Golddeal | Gold | Outreach required |
| 0 | China National Gold Group Corp. | Gold | Outreach required |
| 0 | Codelco | Gold | Outreach required |
| 0 | Colt Refining | Gold | Outreach required |
| 0 | DaeryongENC | Gold | Outreach required |
| 0 | electro metals | Gold | Outreach required |
| 0 | ENTHONE OMI | Gold | Outreach required |
| 0 | ERCEI | Gold | Outreach required |
| 0 | Feinhütte Halsbrücke GmbH | Gold | Outreach required |
| 0 | Hawkins Inc | Gold | Outreach required |
| 0 | Heesung Catalysts | Gold | Outreach required |
| 0 | Heimerdinger | Gold | Outreach required |
| 0 | HON HAI PRECISION IN | Gold | Outreach required |
| 0 | Hutti Gold Mines Co. | Gold | Outreach required |
| 0 | inovan gmbh | Gold | Outreach required |
| 0 | K.A Rasmussen as | Gold | Outreach required |
| 0 | Mead Metals | Gold | Outreach required |
| 0 | Metalor Technologies | Gold | Outreach required |
| 0 | MPF | Gold | Outreach required |
| 0 | Remondis Argentia B.V. | Gold | Outreach required |
17
Annex B
| Mineral | Countries of origin |
| Tin | Philippines, Poland, Brazil, China, Indonesia, Bangka Island |
| Tantalum | Australia, Bolivia, Brazil, Ethiopia, India, Mozambique, Namibia, Rwanda, Sierra Leone, Zimbabwe, Russia |
| Tungsten | China |
| Gold | Australia, Belgium, Canada, , Chile, Brazil, China, Germany, Hong Kong, Japan, South Africa, Switzerland, U.S.A. |
18