Exhibit 1.01
SolarEdge Technologies, Inc.
Conflict Minerals Report
For the calendar year ended December 31, 2020
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 are a leading provider of an optimized inverter solution that changed the way power is harvested and managed in photovoltaic (also known as PV) systems. Our direct current or DC, optimized inverter system maximizes power generation while lowering the cost of energy produced by the PV system, for improved return on investment, or RoI. Additional benefits of the DC optimized inverter system include comprehensive and advanced safety features, improved design flexibility, and improved operating and maintenance, or O&M, with module-level and remote monitoring. The typical SolarEdge optimized inverter system consists of inverters, power optimizers, a communication device which enables access to a cloud based monitoring platform and in many cases, additional smart energy management solutions. Our solutions address 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 22.4 gigawatts of our DC optimized inverter systems and our products have been installed in solar PV systems in 133 countries.
Since introducing the optimized inverter solution in 2010, SolarEdge has expanded its activity to other areas of smart energy technology, both through organic growth and through acquisitions. By leveraging world-class engineering capabilities and with a relentless focus on innovation, SolarEdge now offers energy solutions which include not only residential, commercial, and large scale PV systems but also product offerings in the areas of energy storage systems, or ESS, and backup, electric vehicle, or EV components and charging capabilities, home energy management, grid services and virtual power plants, lithium-ion batteries and uninterrupted power supply, known as UPS solutions.
We were founded in 2006 and began commercial shipments in 2010. As of March 31, 2021, we have shipped approximately 69.1 million power optimizers and 2.9 million inverters. Over 2 million 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 2020 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 2020 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 2020 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, 2020 and December 31, 2020.
We used a Conflict Minerals Reporting Template (the “CMRT” or the “Template”), which was developed by the Responsible Minerals Initiative (RMI) (formerly the Conflict-Free Sourcing Initiative) 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 807 suppliers (the “Suppliers”) that provided components for products manufactured during the calendar year 2020. Of those Suppliers, SolarEdge’s outreach was to all 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 Assent Compliance (“Assent”), 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 2020. Our outreach included 807 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 that suppliers upload completed CMRTs versions 6.01 and 6.1 directly to ACM, a software-as-a-service (SaaS) platform provided by Assent that enables users to complete and track supplier communications, for validation, assessment and management. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. The results of data validation contribute to the program’s health assessment and are shared with the suppliers to ensure they understand areas that require further clarifications or improvement. Training and education to guide suppliers on best practices and use of the CMRT template was included. Since some suppliers may remain unresponsive to feedback, we track program gaps to account for future improvement opportunities. We also enabled suppliers to contact SolarEdge directly and provide a CMRT report using versions 6.01 and 6.1. We used these methods 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 318.
2
We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a conflict free designation by the Responsible Minerals Assurance Process (“RMAP”), a program of RMI, or other independent third-party audit program. We rely on the RMAP as an independent third-party audit solution through which mineral sources are identified and independently evaluated. We do not have direct relationship with smelters and refiners , and do not perform direct audits of these entities within the supply chain.
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 automatic emails, manual outreach, and in certain nonresponsive cases, through telephone.
For 2020, SolarEdge identified 334 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 2020. 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 Organization 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 (Third Edition 2016) (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: a Conflict Minerals Policy, 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.
3
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 Minerals Policy”). In addition, in support of our compliance efforts, we have established a steering committee for enforcement of this Conflict Minerals 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.
The SolarEdge Conflict Minerals Policy includes a grievance mechanism whereby employees and suppliers can report suspected violations of the policy.
SolarEdge also utilizes an independent third-party consultant to advise it on certain aspects of its compliance, as well as a third-party software provider as a basis for to enhance the 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 CMRT. |
| 2. | Maintaining records relating to our Conflict Minerals program for 5 years. We store all of the information and findings in a database that can be audited by internal or external parties. |
| 3. | Implementing standard contract language requiring suppliers to agree to timely respond 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 an independent third-party consultant for conducting 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 independent third-party consultant, reviewed our entire known component and outsourced manufacturing supply chain for the calendar year 2020, which consisted of approximately 807 suppliers. Our outreach included 807 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 RMI 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.
Risk mitigation activities are initiated whenever a supplier’s CMRT reports a facility of concern. Suppliers with submissions that included any smelters of concern were immediately provided with feedback instructing the supplier to take their own independent risk mitigation activities. Examples include a submission of a product level CMRT to better identify the connection to products that they supply to SolarEdge. Suppliers are given clear performance objectives and within reasonable timeframes with the ultimate goal of elimination of smelters of concern from the supply chain. In addition, suppliers are guided to the educational resources on mitigating the risk identified through the CMRT collection process.
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, 99 of our Suppliers that replied, which represent 28.61% (99 out of 346 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, the following are some of the steps that SolarEdge takes in this process: 1) verifying smelters according to RMI smelters list; 2) validating questions in the CMRT file and ensuring that the answers are logical and reasonable, and 3) verifying and cross checking between the smelter location and the RMI smelter approved list. Any smelter’s location in the DRC which is not RMI approved is flagged for further review.
4
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 RMI. 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 RMI, 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.
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 Responsible Minerals Assurance Process (“RMAP”). Our independent third-party service provider, Assent, also directly contacted smelters and refiners that are not currently enrolled in the RMAP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners. SolarEdge is a signatory of this communication in accordance with the requirements of downstream companies detailed in the OECD Guidance..
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 RMI’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 joint industry 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 807 suppliers. Out of these: |
| Number of suppliers who replied (response rate): 346(43%). - Out of these: |
| Number of suppliers who provided data at a company level: 246 (71%) |
Number of suppliers who provided data at a product level: 73 (21%) Number of suppliers which provided data according to a custom made description: 27 (8%) |
Number of suppliers which were classified as “Free no 3TG”: 148 ( 42.8%) Number of suppliers which were classified as “Non-DRC 3TGs”: 82 (26.6%) |
| Number of suppliers which were classified as "DRC conflict free" (from DRC, all SORs are certified): 55 ( 15.9%) |
| Number of suppliers which were classified as “DRC Conflict Undeterminable”": 51 ( 14.7%) |
Smelter and Refiner list attached as Annex A as well as in the Country of Origin Information attached as Annex B.
5
Smelters and refiners verified as conflict-free or in the audit process (237):
| Comply & Active | Total | |
| Tin | 54 (69.2%) | 78 |
| Tantalum | 37 (97.3%) | 38 |
| Tungsten | 38 (82.6%) | 46 |
| Gold | 108 (62.7%) | 172 |
| Total | 237 | 334 |
Status of identified smelters and refiners:
| Comply - Verified Conflict Free | 237 (71%) |
| Active - Participating in an audit process | 25 (7.5%) |
| Communication Suspended – Not Interested | 4 (1.2%) |
| In Communication | 12 (3.6%) |
| Outreach required | 44 (13.2%) |
| Non Conformant | 8 (2.4%) |
| Total | 334 |
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, 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.
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, 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.
6
Annex A
| Smelter IDD | Standard Smelter Name | Metal | Smelter Facility Location | RMI Audit Status |
| CID002763 | 8853 S.p.A. | Gold | ITALY | Conformant |
| CID002708 | Abington Reldan Metals, LLC | Gold | UNITED STATES OF AMERICA | Non Conformant |
| CID000015 | Advanced Chemical Company | Gold | UNITED STATES OF AMERICA | Conformant |
| CID003185 | African Gold Refinery | Gold | UGANDA | Outreach Required |
| CID000019 | Aida Chemical Industries Co., Ltd. | Gold | JAPAN | Conformant |
| CID002560 | Al Etihad Gold Refinery DMCC | Gold | UNITED ARAB EMIRATES | Conformant |
| CID003500 | Alexy Metals | Gold | UNITED STATES OF AMERICA | Active |
| CID000035 | Allgemeine Gold-und Silberscheideanstalt A.G. | Gold | GERMANY | Conformant |
| CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Gold | UZBEKISTAN | Conformant |
| CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | Gold | BRAZIL | Conformant |
| CID000077 | Argor-Heraeus S.A. | Gold | SWITZERLAND | Conformant |
| CID000082 | Asahi Pretec Corp. | Gold | JAPAN | Conformant |
| CID000924 | Asahi Refining Canada Ltd. | Gold | CANADA | Conformant |
| CID000920 | Asahi Refining USA Inc. | Gold | UNITED STATES OF AMERICA | Conformant |
| CID000090 | Asaka Riken Co., Ltd. | Gold | JAPAN | Conformant |
7
| CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Gold | TURKEY | Outreach Required |
| CID002850 | AU Traders and Refiners | Gold | SOUTH AFRICA | Conformant |
| CID003461 | Augmont Enterprises Private Limited | Gold | INDIA | Active |
| CID000113 | Aurubis AG | Gold | GERMANY | Conformant |
| CID002863 | Bangalore Refinery | Gold | INDIA | Conformant |
| CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Gold | PHILIPPINES | Conformant |
| CID000157 | Boliden AB | Gold | SWEDEN | Conformant |
| CID000176 | C. Hafner GmbH + Co. KG | Gold | GERMANY | Conformant |
| CID003421 | C.I Metales Procesados Industriales SAS | Gold | COLOMBIA | Active |
| CID000180 | Caridad | Gold | MEXICO | Outreach Required |
| CID000185 | CCR Refinery - Glencore Canada Corporation | Gold | CANADA | Conformant |
| CID000189 | Cendres + Metaux S.A. | Gold | SWITZERLAND | Conformant |
| CID003382 | CGR Metalloys Pvt Ltd. | Gold | INDIA | Outreach Required |
| CID000233 | Chimet S.p.A. | Gold | ITALY | Conformant |
| CID000264 | Chugai Mining | Gold | JAPAN | Conformant |
| CID000343 | Daye Non-Ferrous Metals Mining Ltd. | Gold | CHINA | In Communication |
| CID002867 | Degussa Sonne / Mond Goldhandel GmbH | Gold | GERMANY | Outreach Required |
| CID003348 | Dijllah Gold Refinery FZC | Gold | UNITED ARAB EMIRATES | Outreach Required |
| CID000362 | DODUCO Contacts and Refining GmbH | Gold | GERMANY | Conformant |
| CID000401 | Dowa | Gold | JAPAN | Conformant |
| CID003195 | DS PRETECH Co., Ltd. | Gold | KOREA, REPUBLIC OF | Conformant |
8
| CID000359 | DSC (Do Sung Corporation) | Gold | KOREA, REPUBLIC OF | Conformant |
| CID000425 | Eco-System Recycling Co., Ltd. East Plant | Gold | JAPAN | Conformant |
| CID003424 | Eco-System Recycling Co., Ltd. North Plant | Gold | JAPAN | Conformant |
| CID003425 | Eco-System Recycling Co., Ltd. West Plant | Gold | JAPAN | Conformant |
| CID003487 | Emerald Jewel Industry India Limited (Unit 1) | Gold | INDIA | In Communication |
| CID003488 | Emerald Jewel Industry India Limited (Unit 2) | Gold | INDIA | In Communication |
| CID003489 | Emerald Jewel Industry India Limited (Unit 3) | Gold | INDIA | In Communication |
| CID003490 | Emerald Jewel Industry India Limited (Unit 4) | Gold | INDIA | In Communication |
| CID002561 | Emirates Gold DMCC | Gold | UNITED ARAB EMIRATES | Conformant |
| CID002515 | Fidelity Printers and Refiners Ltd. | Gold | ZIMBABWE | RMI Due Diligence Review - Unable to Proceed |
| CID002584 | Fujairah Gold FZC | Gold | UNITED ARAB EMIRATES | Outreach Required |
| CID002852 | GCC Gujrat Gold Centre Pvt. Ltd. | Gold | INDIA | In Communication |
| CID002459 | Geib Refining Corporation | Gold | UNITED STATES OF AMERICA | Conformant |
| CID003186 | Gold Coast Refinery | Gold | GHANA | Outreach Required |
| CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | Gold | CHINA | Conformant |
9
| CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | Gold | CHINA | Outreach Required |
| CID002312 | Guangdong Jinding Gold Limited | Gold | CHINA | Outreach Required |
| CID000651 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | Gold | CHINA | Outreach Required |
| CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | Gold | CHINA | Outreach Required |
| CID000694 | Heimerle + Meule GmbH | Gold | GERMANY | Conformant |
| CID000707 | Heraeus Metals Hong Kong Ltd. | Gold | CHINA | Conformant |
| CID000711 | Heraeus Precious Metals GmbH & Co. KG | Gold | GERMANY | Active |
| CID000767 | Hunan Chenzhou Mining Co., Ltd. | Gold | CHINA | Outreach Required |
| CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | Gold | CHINA | Outreach Required |
| CID000778 | HwaSeong CJ CO., LTD. | Gold | KOREA, REPUBLIC OF | Communication Suspended - Not Interested |
| CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | Gold | CHINA | Conformant |
| CID002562 | International Precious Metal Refiners | Gold | UNITED ARAB EMIRATES | Active |
| CID000807 | Ishifuku Metal Industry Co., Ltd. | Gold | JAPAN | Conformant |
| CID000814 | Istanbul Gold Refinery | Gold | TURKEY | Conformant |
| CID002765 | Italpreziosi | Gold | ITALY | Conformant |
| CID002893 | JALAN & Company | Gold | INDIA | Outreach Required |
| CID000823 | Japan Mint | Gold | JAPAN | Conformant |
| CID000855 | Jiangxi Copper Co., Ltd. | Gold | CHINA | Conformant |
10
| CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Gold | RUSSIAN FEDERATION | RMI Due Diligence Review - Unable to Proceed |
| CID000929 | JSC Uralelectromed | Gold | RUSSIAN FEDERATION | Conformant |
| CID000937 | JX Nippon Mining & Metals Co., Ltd. | Gold | JAPAN | Conformant |
| CID003497 | K.A. Rasmussen | Gold | NORWAY | Outreach Required |
| CID002563 | Kaloti Precious Metals | Gold | UNITED ARAB EMIRATES | RMI Due Diligence Review - Unable to Proceed |
| CID000956 | Kazakhmys Smelting LLC | Gold | KAZAKHSTAN | In Communication |
| CID000957 | Kazzinc | Gold | KAZAKHSTAN | Conformant |
| CID000969 | Kennecott Utah Copper LLC | Gold | UNITED STATES OF AMERICA | Conformant |
| CID002511 | KGHM Polska Miedz Spolka Akcyjna | Gold | POLAND | Conformant |
| CID000981 | Kojima Chemicals Co., Ltd. | Gold | JAPAN | Conformant |
| CID002605 | Korea Zinc Co., Ltd. | Gold | KOREA, REPUBLIC OF | Conformant |
| CID003463 | Kundan Care Products Ltd. | Gold | INDIA | In Communication |
| CID001029 | Kyrgyzaltyn JSC | Gold | KYRGYZSTAN | Conformant |
| CID002865 | Kyshtym Copper-Electrolytic Plant ZAO | Gold | RUSSIAN FEDERATION | Outreach Required |
| CID001032 | L'azurde Company For Jewelry | Gold | SAUDI ARABIA | RMI Due Diligence Review - Unable to Proceed |
| CID001056 | Lingbao Gold Co., Ltd. | Gold | CHINA | Outreach Required |
| CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002762 | L'Orfebre S.A. | Gold | ANDORRA | Conformant |
| CID001078 | LS-NIKKO Copper Inc. | Gold | KOREA, REPUBLIC OF | Conformant |
11
| CID000689 | LT Metal Ltd. | Gold | KOREA, REPUBLIC OF | Conformant |
| CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002606 | Marsam Metals | Gold | BRAZIL | Conformant |
| CID001113 | Materion | Gold | UNITED STATES OF AMERICA | Conformant |
| CID001119 | Matsuda Sangyo Co., Ltd. | Gold | JAPAN | Conformant |
| CID003548 | MD Overseas | Gold | INDIA | In Communication |
| CID003575 | Metal Concentrators SA (Pty) Ltd. | Gold | SOUTH AFRICA | Conformant |
| CID003557 | Metallix Refining Inc. | Gold | UNITED STATES OF AMERICA | Active |
| CID001149 | Metalor Technologies (Hong Kong) Ltd. | Gold | CHINA | Conformant |
| CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | Gold | SINGAPORE | Conformant |
| CID001147 | Metalor Technologies (Suzhou) Ltd. | Gold | CHINA | Conformant |
| CID001153 | Metalor Technologies S.A. | Gold | SWITZERLAND | Conformant |
| CID001157 | Metalor USA Refining Corporation | Gold | UNITED STATES OF AMERICA | Conformant |
| CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | Gold | MEXICO | Conformant |
| CID001188 | Mitsubishi Materials Corporation | Gold | JAPAN | Conformant |
| CID001193 | Mitsui Mining and Smelting Co., Ltd. | Gold | JAPAN | Conformant |
| CID002509 | MMTC-PAMP India Pvt., Ltd. | Gold | INDIA | Conformant |
| CID002857 | Modeltech Sdn Bhd | Gold | MALAYSIA | Non Conformant |
| CID002282 | Morris and Watson | Gold | NEW ZEALAND | Communication Suspended - Not Interested |
12
| CID001204 | Moscow Special Alloys Processing Plant | Gold | RUSSIAN FEDERATION | Conformant |
| CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | Gold | TURKEY | Conformant |
| CID001236 | Navoi Mining and Metallurgical Combinat | Gold | UZBEKISTAN | Conformant |
| CID003189 | NH Recytech Company | Gold | KOREA, REPUBLIC OF | Non Conformant |
| CID001259 | Nihon Material Co., Ltd. | Gold | JAPAN | Conformant |
| CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Gold | AUSTRIA | Conformant |
| CID001325 | Ohura Precious Metal Industry Co., Ltd. | Gold | JAPAN | Conformant |
| CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Gold | RUSSIAN FEDERATION | Conformant |
| CID000493 | OJSC Novosibirsk Refinery | Gold | RUSSIAN FEDERATION | Conformant |
| CID001352 | PAMP S.A. | Gold | SWITZERLAND | Conformant |
| CID002872 | Pease & Curren | Gold | UNITED STATES OF AMERICA | Outreach Required |
| CID001362 | Penglai Penggang Gold Industry Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002919 | Planta Recuperadora de Metales SpA | Gold | CHILE | Conformant |
| CID001386 | Prioksky Plant of Non-Ferrous Metals | Gold | RUSSIAN FEDERATION | Conformant |
| CID001397 | PT Aneka Tambang (Persero) Tbk | Gold | INDONESIA | Conformant |
| CID001498 | PX Precinox S.A. | Gold | SWITZERLAND | Conformant |
| CID003324 | QG Refining, LLC | Gold | UNITED STATES OF AMERICA | Outreach Required |
| CID001512 | Rand Refinery (Pty) Ltd. | Gold | SOUTH AFRICA | Conformant |
| CID000522 | Refinery of Seemine Gold Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002582 | REMONDIS PMR B.V. | Gold | NETHERLANDS | Conformant |
13
| CID001534 | Royal Canadian Mint | Gold | CANADA | Conformant |
| CID002761 | SAAMP | Gold | FRANCE | Conformant |
| CID001546 | Sabin Metal Corp. | Gold | UNITED STATES OF AMERICA | Outreach Required |
| CID002973 | Safimet S.p.A | Gold | ITALY | Conformant |
| CID002290 | SAFINA A.S. | Gold | CZECH REPUBLIC | Conformant |
| CID002853 | Sai Refinery | Gold | INDIA | Outreach Required |
| CID001555 | Samduck Precious Metals | Gold | KOREA, REPUBLIC OF | Conformant |
| CID001562 | Samwon Metals Corp. | Gold | KOREA, REPUBLIC OF | Communication Suspended - Not Interested |
| CID003529 | Sancus ZFS (L’Orfebre, SA) | Gold | COLOMBIA | In Communication |
| CID002777 | SAXONIA Edelmetalle GmbH | Gold | GERMANY | Conformant |
| CID003540 | Sellem Industries Ltd. | Gold | MAURITANIA | Outreach Required |
| CID001585 | SEMPSA Joyeria Plateria S.A. | Gold | SPAIN | Conformant |
| CID002525 | Shandong Humon Smelting Co., Ltd. | Gold | CHINA | Outreach Required |
| CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Gold | CHINA | Outreach Required |
| CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | Gold | CHINA | Conformant |
| CID002527 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002588 | Shirpur Gold Refinery Ltd. | Gold | INDIA | Outreach Required |
| CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | Gold | CHINA | Conformant |
| CID002516 | Singway Technology Co., Ltd. | Gold | TAIWAN, PROVINCE OF CHINA | Conformant |
14
| CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | Gold | RUSSIAN FEDERATION | Conformant |
| CID001761 | Solar Applied Materials Technology Corp. | Gold | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID003383 | Sovereign Metals | Gold | INDIA | Outreach Required |
| CID003153 | State Research Institute Center for Physical Sciences and Technology | Gold | LITHUANIA | Outreach Required |
| CID002567 | Sudan Gold Refinery | Gold | SUDAN | Outreach Required |
| CID001798 | Sumitomo Metal Mining Co., Ltd. | Gold | JAPAN | Conformant |
| CID002918 | SungEel HiMetal Co., Ltd. | Gold | KOREA, REPUBLIC OF | Conformant |
| CID001810 | Super Dragon Technology Co., Ltd | Gold | TAIWAN, PROVINCE OF CHINA | Outreach Required |
| CID002580 | T.C.A S.p.A | Gold | ITALY | Conformant |
| CID001875 | Tanaka Kikinzoku Kogyo K.K. | Gold | JAPAN | Conformant |
| CID001916 | The Refinery of Shandong Gold Mining Co., Ltd. | Gold | CHINA | Conformant |
| CID001938 | Tokuriki Honten Co., Ltd. | Gold | JAPAN | Conformant |
| CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002587 | Tony Goetz NV | Gold | BELGIUM | Non Conformant |
| CID002615 | TOO Tau-Ken-Altyn | Gold | KAZAKHSTAN | Conformant |
| CID001955 | Torecom | Gold | KOREA, REPUBLIC OF | Conformant |
| CID002314 | Umicore Precious Metals Thailand | Gold | THAILAND | Conformant |
| CID001980 | Umicore S.A. Business Unit Precious Metals Refining | Gold | BELGIUM | Conformant |
| CID001993 | United Precious Metal Refining, Inc. | Gold | UNITED STATES OF AMERICA | Conformant |
15
| CID002003 | Valcambi S.A. | Gold | SWITZERLAND | Conformant |
| CID002030 | Western Australian Mint (T/a The Perth Mint) | Gold | AUSTRALIA | Conformant |
| CID002778 | WIELAND Edelmetalle GmbH | Gold | GERMANY | Conformant |
| CID002100 | Yamakin Co., Ltd. | Gold | JAPAN | Conformant |
| CID002129 | Yokohama Metal Co., Ltd. | Gold | JAPAN | Conformant |
| CID000197 | Yunnan Copper Industry Co., Ltd. | Gold | CHINA | Outreach Required |
| CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Gold | CHINA | Conformant |
| CID000092 | Asaka Riken Co., Ltd. | Tantalum | JAPAN | Conformant |
| CID000211 | Changsha South Tantalum Niobium Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002504 | D Block Metals, LLC | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID000456 | Exotech Inc. | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID000460 | F&X Electro-Materials Ltd. | Tantalum | CHINA | Conformant |
| CID002505 | FIR Metals & Resource Ltd. | Tantalum | CHINA | Conformant |
| CID002558 | Global Advanced Metals Aizu | Tantalum | JAPAN | Conformant |
| CID002557 | Global Advanced Metals Boyertown | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID000616 | Guangdong Zhiyuan New Material Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002544 | H.C. Starck Co., Ltd. | Tantalum | THAILAND | Conformant |
16
| CID002547 | H.C. Starck Hermsdorf GmbH | Tantalum | GERMANY | Conformant |
| CID002548 | H.C. Starck Inc. | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID002549 | H.C. Starck Ltd. | Tantalum | JAPAN | Conformant |
| CID002550 | H.C. Starck Smelting GmbH & Co. KG | Tantalum | GERMANY | Conformant |
| CID002545 | H.C. Starck Tantalum and Niobium GmbH | Tantalum | GERMANY | Conformant |
| CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002842 | Jiangxi Tuohong New Raw Material | Tantalum | CHINA | Conformant |
| CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | Tantalum | CHINA | Conformant |
| CID000917 | Jiujiang Tanbre Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | Tantalum | CHINA | Conformant |
| CID002539 | KEMET Blue Metals | Tantalum | MEXICO | Conformant |
| CID001076 | LSM Brasil S.A. | Tantalum | BRAZIL | Conformant |
| CID001163 | Metallurgical Products India Pvt., Ltd. | Tantalum | INDIA | Conformant |
| CID001175 | Mineracao Taboca S.A. | Tantalum | BRAZIL | Conformant |
| CID001192 | Mitsui Mining and Smelting Co., Ltd. | Tantalum | JAPAN | Conformant |
| CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | Tantalum | CHINA | Conformant |
| CID001200 | NPM Silmet AS | Tantalum | ESTONIA | Conformant |
| CID002847 | PRG Dooel | Tantalum | NORTH MACEDONIA, REPUBLIC OF | Conformant |
| CID001508 | QuantumClean | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID002707 | Resind Industria e Comercio Ltda. | Tantalum | BRAZIL | Conformant |
17
| CID001769 | Solikamsk Magnesium Works OAO | Tantalum | RUSSIAN FEDERATION | Conformant |
| CID001869 | Taki Chemical Co., Ltd. | Tantalum | JAPAN | Conformant |
| CID001891 | Telex Metals | Tantalum | UNITED STATES OF AMERICA | Conformant |
| CID001969 | Ulba Metallurgical Plant JSC | Tantalum | KAZAKHSTAN | Conformant |
| CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | Tantalum | CHINA | Conformant |
| CID003583 | Yancheng Jinye New Material Technology Co., Ltd. | Tantalum | CHINA | Active |
| CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | Tantalum | CHINA | Conformant |
| CID000292 | Alpha | Tin | UNITED STATES OF AMERICA | Conformant |
| CID002703 | An Vinh Joint Stock Mineral Processing Company | Tin | VIET NAM | Outreach Required |
| CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | Tin | CHINA | Conformant |
| CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | Tin | CHINA | Conformant |
| CID001070 | China Tin Group Co., Ltd. | Tin | CHINA | Conformant |
| CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Tin | BRAZIL | Active |
| CID003524 | CRM Synergies | Tin | SPAIN | Active |
| CID002570 | CV Ayi Jaya | Tin | INDONESIA | Active |
| CID002455 | CV Venus Inti Perkasa | Tin | INDONESIA | Active |
| CID003356 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | Tin | CHINA | Non Conformant |
| CID000402 | Dowa | Tin | JAPAN | Conformant |
18
| CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Tin | VIET NAM | Non Conformant |
| CID000438 | EM Vinto | Tin | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| CID000448 | Estanho de Rondonia S.A. | Tin | BRAZIL | Active |
| CID000468 | Fenix Metals | Tin | POLAND | Conformant |
| CID003410 | Gejiu City Fuxiang Industry and Trade Co., Ltd. | Tin | CHINA | Outreach Required |
| CID002848 | Gejiu Fengming Metallurgy Chemical Plant | Tin | CHINA | Conformant |
| CID000942 | Gejiu Kai Meng Industry and Trade LLC | Tin | CHINA | Conformant |
| CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | Tin | CHINA | Conformant |
| CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Tin | CHINA | Conformant |
| CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | Tin | CHINA | Conformant |
| CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | Tin | CHINA | Conformant |
| CID002844 | HuiChang Hill Tin Industry Co., Ltd. | Tin | CHINA | Conformant |
| CID001231 | Jiangxi New Nanshan Technology Ltd. | Tin | CHINA | Conformant |
| CID003387 | Luna Smelter, Ltd. | Tin | RWANDA | Conformant |
| CID003379 | Ma'anshan Weitai Tin Co., Ltd. | Tin | CHINA | Conformant |
| CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Tin | BRAZIL | Conformant |
| CID001105 | Malaysia Smelting Corporation (MSC) | Tin | MALAYSIA | Conformant |
| CID002500 | Melt Metais e Ligas S.A. | Tin | BRAZIL | Conformant |
19
| CID001142 | Metallic Resources, Inc. | Tin | UNITED STATES OF AMERICA | Conformant |
| CID002773 | Metallo Belgium N.V. | Tin | BELGIUM | Conformant |
| CID002774 | Metallo Spain S.L.U. | Tin | SPAIN | Conformant |
| CID001173 | Mineracao Taboca S.A. | Tin | BRAZIL | Conformant |
| CID001182 | Minsur | Tin | PERU | Conformant |
| CID001191 | Mitsubishi Materials Corporation | Tin | JAPAN | Conformant |
| CID002858 | Modeltech Sdn Bhd | Tin | MALAYSIA | Non Conformant |
| CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Tin | VIET NAM | Outreach Required |
| CID001305 | Novosibirsk Processing Plant Ltd. | Tin | RUSSIAN FEDERATION | Active |
| CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | Tin | THAILAND | Conformant |
| CID002517 | O.M. Manufacturing Philippines, Inc. | Tin | PHILIPPINES | Conformant |
| CID001337 | Operaciones Metalurgicas S.A. | Tin | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| CID003208 | Pongpipat Company Limited | Tin | MYANMAR | Outreach Required |
| CID003409 | Precious Minerals and Smelting Limited | Tin | INDIA | Non Conformant |
| CID000309 | PT Aries Kencana Sejahtera | Tin | INDONESIA | Active |
| CID001399 | PT Artha Cipta Langgeng | Tin | INDONESIA | Conformant |
| CID002503 | PT ATD Makmur Mandiri Jaya | Tin | INDONESIA | Conformant |
| CID001402 | PT Babel Inti Perkasa | Tin | INDONESIA | Conformant |
| CID001406 | PT Babel Surya Alam Lestari | Tin | INDONESIA | Conformant |
| CID003205 | PT Bangka Serumpun | Tin | INDONESIA | Conformant |
| CID001428 | PT Bukit Timah | Tin | INDONESIA | Active |
20
| CID002696 | PT Cipta Persada Mulia | Tin | INDONESIA | In Communication |
| CID002870 | PT Lautan Harmonis Sejahtera | Tin | INDONESIA | Active |
| CID002835 | PT Menara Cipta Mulia | Tin | INDONESIA | Conformant |
| CID001453 | PT Mitra Stania Prima | Tin | INDONESIA | Conformant |
| CID003449 | PT Mitra Sukses Globalindo | Tin | INDONESIA | In Communication |
| CID001458 | PT Prima Timah Utama | Tin | INDONESIA | Conformant |
| CID003381 | PT Rajawali Rimba Perkasa | Tin | INDONESIA | Conformant |
| CID002593 | PT Rajehan Ariq | Tin | INDONESIA | Conformant |
| CID001460 | PT Refined Bangka Tin | Tin | INDONESIA | Conformant |
| CID001468 | PT Stanindo Inti Perkasa | Tin | INDONESIA | Conformant |
| CID002816 | PT Sukses Inti Makmur | Tin | INDONESIA | Active |
| CID001486 | PT Timah Nusantara | Tin | INDONESIA | Active |
| CID001477 | PT Timah Tbk Kundur | Tin | INDONESIA | Conformant |
| CID001482 | PT Timah Tbk Mentok | Tin | INDONESIA | Conformant |
| CID001490 | PT Tinindo Inter Nusa | Tin | INDONESIA | Conformant |
| CID002706 | Resind Industria e Comercio Ltda. | Tin | BRAZIL | Conformant |
| CID001539 | Rui Da Hung | Tin | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID001758 | Soft Metais Ltda. | Tin | BRAZIL | Conformant |
| CID002756 | Super Ligas | Tin | BRAZIL | Active |
| CID002834 | Thai Nguyen Mining and Metallurgy Co., Ltd. | Tin | VIET NAM | Conformant |
| CID001898 | Thaisarco | Tin | THAILAND | Conformant |
| CID003325 | Tin Technology & Refining | Tin | UNITED STATES OF AMERICA | Conformant |
21
| CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Tin | VIET NAM | Outreach Required |
| CID002015 | VQB Mineral and Trading Group JSC | Tin | VIET NAM | Outreach Required |
| CID002036 | White Solder Metalurgia e Mineracao Ltda. | Tin | BRAZIL | Conformant |
| CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | Tin | CHINA | Conformant |
| CID002180 | Yunnan Tin Company Limited | Tin | CHINA | Conformant |
| CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | Tin | CHINA | Conformant |
| CID000004 | A.L.M.T. Corp. | Tungsten | JAPAN | Conformant |
| CID002833 | ACL Metais Eireli | Tungsten | BRAZIL | Conformant |
| CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Tungsten | BRAZIL | Active |
| CID003553 | Artek LLC | Tungsten | RUSSIAN FEDERATION | Active |
| CID002502 | Asia Tungsten Products Vietnam Ltd. | Tungsten | VIET NAM | Conformant |
| CID002513 | Chenzhou Diamond Tungsten Products Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002641 | China Molybdenum Co., Ltd. | Tungsten | CHINA | Conformant |
| CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID000281 | CNMC (Guangxi) PGMA Co., Ltd. | Tungsten | CHINA | Outreach Required |
| CID003468 | Cronimet Brasil Ltda | Tungsten | BRAZIL | Active |
| CID003401 | Fujian Ganmin RareMetal Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002645 | Ganzhou Haichuang Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID000875 | Ganzhou Huaxing Tungsten Products Co., Ltd. | Tungsten | CHINA | Conformant |
22
| CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | Tungsten | CHINA | Conformant |
| CID003417 | GEM Co., Ltd. | Tungsten | CHINA | Active |
| CID000568 | Global Tungsten & Powders Corp. | Tungsten | UNITED STATES OF AMERICA | Conformant |
| CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002542 | H.C. Starck Smelting GmbH & Co. KG | Tungsten | GERMANY | Conformant |
| CID002541 | H.C. Starck Tungsten GmbH | Tungsten | GERMANY | Conformant |
| CID000766 | Hunan Chenzhou Mining Co., Ltd. | Tungsten | CHINA | Conformant |
| CID000769 | Hunan Chunchang Nonferrous Metals Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002649 | Hydrometallurg, JSC | Tungsten | RUSSIAN FEDERATION | Conformant |
| CID000825 | Japan New Metals Co., Ltd. | Tungsten | JAPAN | Conformant |
| CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Tungsten | CHINA | Communication Suspended - Not Interested |
| CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID003408 | JSC "Kirovgrad Hard Alloys Plant" | Tungsten | RUSSIAN FEDERATION | Active |
23
| CID000966 | Kennametal Fallon | Tungsten | UNITED STATES OF AMERICA | Conformant |
| CID000105 | Kennametal Huntsville | Tungsten | UNITED STATES OF AMERICA | Conformant |
| CID003388 | KGETS Co., Ltd. | Tungsten | KOREA, REPUBLIC OF | Conformant |
| CID003407 | Lianyou Metals Co., Ltd. | Tungsten | TAIWAN, PROVINCE OF CHINA | Conformant |
| CID002319 | Malipo Haiyu Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002543 | Masan Tungsten Chemical LLC (MTC) | Tungsten | VIET NAM | Conformant |
| CID002845 | Moliren Ltd. | Tungsten | RUSSIAN FEDERATION | Conformant |
| CID002589 | Niagara Refining LLC | Tungsten | UNITED STATES OF AMERICA | Conformant |
| CID003416 | NPP Tyazhmetprom LLC | Tungsten | RUSSIAN FEDERATION | Active |
| CID002827 | Philippine Chuangxin Industrial Co., Inc. | Tungsten | PHILIPPINES | Conformant |
| CID002724 | Unecha Refractory metals plant | Tungsten | RUSSIAN FEDERATION | Conformant |
| CID002044 | Wolfram Bergbau und Hutten AG | Tungsten | AUSTRIA | Conformant |
| CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002082 | Xiamen Tungsten Co., Ltd. | Tungsten | CHINA | Conformant |
| CID002830 | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | Tungsten | CHINA | Conformant |
24
Annex B
Country of Origin
| Mineral | Mines of Origin |
| Tin | Myanmar, Malaysia, Brazil, USA, Japan, Belgium, China, Peru, Vietnam, Bolivia, Thailand, Spain, Indonesia, Russia, Poland, Rwanda, Philippines, Taiwan Province of China |
| Tantalum | China, USA, Brazil, Kazakhstan, Republic of North Macedonia, Japan, India, Germany, Russia, Thailand, Estonia |
| Tungsten | China, Japan, USA, Brazil, Austria, Republic Of Korea, Germany, Russia, Vietnam, Philippines, Taiwan Province of China |
| Gold | Andorra, China, Japan, USA, Indonesia, Brazil, Chile, Canada, Spain, Australia, Malaysia, Kazakhstan, Austria, Republic Of Korea, Colombia, India, Belgium, Germany, Russia, Singapore, Netherlands, France, Switzerland, Czech Republic, Zimbabwe, Philippines, Mexico, Uzbekistan, South Africa, Sweden, Italy, Saudi Arabia, Poland, Kyrgyzstan, New Zealand, Ghana, Mauritania, Lithuania, Sudan, Norway, Taiwan Province of China |
25