Exhibit 1.01
John Bean Technologies Corporation
Conflict Minerals Report
For The Calendar Year Ended December 31, 2016
This report for the calendar year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Unless otherwise specified or indicated by the context, JBT Corporation, JBT, we, us, our and the Company refer to John Bean Technologies Corporation and its subsidiaries. In accordance with the Rule, the information presented in this report does not include products manufactured by businesses acquired after May 1, 2015.
JBT has reason to believe that some of the 3TGs1 present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”). We are unable to determine the origin of the 3TGs in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we are required under the Rule to submit to the Securities and Exchange Commission a Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the instructions to Form SD, this CMR has not been audited by an independent private sector auditor.
Forward-Looking Statement
This report and other materials filed by JBT, as well as information in oral statements or other written statements made or to be made by us, contain statements that are, or may be considered to be, forward-looking statements. All statements that are not historical facts, including statements about our beliefs or expectations, are forward-looking statements. You can identify these forward-looking statements by the use of “seeks”, “approximately”, “predicts”, “intends”, “outlook”, “believes”, “expects”, “potential”, “continues”, “may”, “will”, “should”, “plans”, “estimates”, “anticipates”, “foresees” or the negative version of those words or other comparable words or phrases. Any forward-looking statements contained in this report are based upon our historical performance and on current plans, estimates and expectations. The inclusion of this forward-looking information should not be regarded as a representation by us or any other person that the future plans, estimates or expectations contemplated by us will be achieved.
We believe that the factors that could cause our actual results to differ materially from expectations include but are not limited to the factors we described in our Form 10-K under “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” If one or more of those or other risks or uncertainties materialize, or if our underlying assumptions prove to be incorrect, actual results may vary materially from what we projected. Consequently, actual events and results may vary significantly from those included in or contemplated or implied by our forward-looking statements. The forward-looking statements included in this report are made only as of the date hereof, and we undertake no obligation to publicly update or revise any forward-looking statement made by us or on our behalf, whether as a result of new information, future developments, subsequent events or changes in circumstances or otherwise.
1. Company Overview
We are a leading global technology solutions provider to high-value segments of the food and beverage industry with focus on proteins, liquid foods and automated system solutions. JBT designs, produces and services sophisticated products and systems for multi-national and regional customers through its FoodTech segment. JBT also sells critical equipment and services to domestic and international air transportation customers through its AeroTech segment.
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1The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. Gold, columbite-tantalite (coltan), cassiterite and wolframite, and their derivatives, tin, tungsten and tantalum are hereinafter referred to collectively as “3TGs.”
The product offerings of our FoodTech businesses include:
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| • | Protein. JBT FoodTech provides comprehensive solutions to our Protein customers that include chilling, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, frying, freezing and weighing for poultry, beef, pork and seafood, as well as ready-to-eat meals, fruits, vegetables, dairy, and bakery products. |
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| • | Liquid Foods. Our Liquid Foods portfolio includes fruit and juice solutions that extract, concentrate and aseptically process citrus, tomato and other fruits, vegetables, and juices. It also includes in-container solutions for the filling, closing and preservation of fruits, vegetables, soups, sauces, dairy, and pet food products as well as ready-to-eat meals in a wide variety of modern packages. Strategic acquisitions completed in 2015 added to our product portfolio significant capabilities in the dairy and juice preservation and filling segments, as well as in customized skidded systems, mixing, batching and blending systems and tank and vessel manufacturing capabilities for a broad array of market segments. |
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| • | Automated Systems. JBT FoodTech provides stand-alone and fully-integrated robotic automated guided vehicle systems for repetitive material movement requirements, for example in manufacturing and warehouse facilities. |
JBT AeroTech markets its solutions and services to domestic and international airport authorities, passenger airlines, airfreight and ground handling companies, military forces and defense contractors. The product offerings of our AeroTech businesses include:
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| • | Mobile Equipment. JBT AeroTech’s portfolio of mobile air transportation equipment includes commercial and military cargo loading, aircraft deicing, aircraft towing, and aircraft ground power and cooling systems. |
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| • | Fixed Equipment. JBT AeroTech provides gate equipment for passenger boarding. |
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| • | Airport Services. JBT AeroTech includes the maintenance of airport equipment, systems, and facilities. |
Our products may contain conflict minerals within the following components:
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| • | Tantalum, used in capacitors |
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| • | Tin, used in soldered components |
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| • | Tungsten, used in coatings, alloys, heating elements and electrodes |
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| • | Gold, used in circuit boards, electrodes and electronic components |
Our policy regarding Conflicts Minerals is posted on our website under “Investor Relations” “Corporate Governance” and may be accessed via the following link: http://ir.jbtcorporation.com/governance.cfm.
2. Description of Reasonable County of Origin Inquiry and Conclusion
We engaged Assent Compliance Inc. (“Assent”) to assist in developing our approach to conduct in good faith a reasonable country of origin inquiry (“RCOI”). Assent is a recognized software and consulting provider supporting companies’ regulatory compliance.
JBT’s RCOI employed a combination of measures to determine whether the necessary 3TGs in JBT products originated from the Covered Countries. JBT’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey through Assent with direct JBT suppliers using the EICC-GeSI Conflict Minerals Reporting Template (“CMRT”).
JBT began its scoping process by compiling a list of direct suppliers of materials for JBT’s businesses that were likely to source materials that might contain 3TGs. This list was then filtered to remove suppliers of direct materials for all business units sourced prior to January 1, 2017.
The first two questions in the CMRT used for JBT’s supply chain survey allowed for further scoping as they ask suppliers whether any of the 3TGs are intentionally added and if they are necessary to the functionality or production of their products. Assent conducted additional analysis of the supply chain and, in combination with supplier feedback, discovered that 90.17% of the suppliers surveyed remained in scope.
JBT surveyed its suppliers via the Assent Compliance Manager, a software platform licensed by JBT to log and track supplier communications. This platform also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by the Assent Compliance Manager and then were also managed by the Assent Compliance supply chain team in one-on-one communications. This included two follow ups from the supply chain team. For the 2016 reporting period, JBT received responses from 64.5%, of its in-scope suppliers. Of the 616 suppliers that provided a response, approximately 24% reported that their products contained 3TGs necessary to the functionality or production of their products.
Assent communications included training and education on the completion of the CMRT to assist suppliers in accurately completing the survey questions in the CMRT.
All of these communications were monitored and tracked in Assent's system for future reporting and transparency.
JBT’s survey process with Assent includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on the construction and relationship of the questions submitted to the suppliers in the CMRT. Suppliers must provide the minimum responses to the CMRT in order to determine the scope of applicability of the remaining CMRT questions - this aligns with the design of the CMRT itself. The remainder of the questions are then automatically assessed for consistency. All submitted forms are accepted and classified as valid or invalid, preserving all of the data submitted through Assent Compliance for record keeping purposes. Suppliers are contacted in regards to invalid forms and are strongly encouraged to resubmit a valid form. As of April 17, 2017, there were 557 valid supplier submissions.
As a result of its assessment, JBT has concluded in good faith that during calendar year 2016:
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| a) | JBT has manufactured or contracted to manufacture products as to which 3TGs are necessary to the functionality or production of such products. |
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| b) | Based on its RCOI, JBT knows or has reason to believe that a portion of its necessary 3TGs originated or may have originated in the Covered Countries and knows or has reason to believe that those necessary 3TGs may not be from recycle or scrap sources. |
3. Due Diligence Process and Results
Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten. The 5 steps of due diligence are:
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| • | Establish Strong Company Management Systems |
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| • | Identify and Assess Risk in the Supply Chain |
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| • | Design and Implement a Strategy to Respond to Identified Risks |
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| • | Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
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| • | Report on Supply Chain Due Diligence |
3.1. Management Systems
Internal Team
JBT has established a management system for conflict minerals. Our management system includes a Conflict Minerals team sponsored by JBT’s executive management, as well as engineering and sourcing resources within JBT’s business segments. The Conflict Minerals Team includes subject matter experts from relevant corporate functions such as:
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| • | Manager, Corporate Sourcing and Logistics |
The team is responsible for implementing our conflict minerals compliance strategy and is led by the Company’s Executive Vice President and Chief Financial Officer. Senior management is briefed about the results of our due diligence efforts periodically.
Control Systems
As described above, we have has adopted a Conflict Minerals policy which is posted on our website at http://ir.jbtcorporation.com/governance.cfm.
JBT’s standard purchase order form terms and conditions include a requirement that suppliers comply with all local laws including those pertaining to business integrity.
As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we seek to be engaged and actively cooperate with other major manufacturers in the industry regarding 3TG sourcing matters.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education with respect to conflict minerals regulations as well as our expectations for a continued business relationship, and leveraged the existing communications with our supplier base as is available. This year, we put a stronger emphasis on supplier education and training. To accomplish this, we utilized Assent’s learning management system, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
Grievance Mechanism
We have a hotline whereby employees can report violations of JBT’s policies. Employees are encouraged to reports concerns about compliance with policies to their managers, their human resources representative or company counsel unless they prefer to remain anonymous and utilize the hotline.
Maintain Records
We have adopted a policy to retain relevant documentation through Assent Compliance. Documentation will be retained for a minimum period of five years based on OECD guidance.
3.2 Identify and Assess Risk in the Supply Chain
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC conflict-free pose a risk to the supply chain. Each facility that meets the Conflict-Free Sourcing Initiative (CFSI) definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
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| 1. | Geographic proximity to the DRC and covered countries; |
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| 2. | Conflict-Free Smelter Program (CFSP) audit status; |
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| 3. | Known or plausible evidence of unethical or conflict sourcing. |
Based on these criteria the following facilities disclosed in CRMT surveys have been identified as high risk in the Company’s supply chain:
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| • | Tony Goetz NV - CID002587 |
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| • | Kaloti Precious Metals - CID002563 |
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| • | Phoenix Metals - CID002507 |
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| • | Universal Precious Metals Refining Zambia - CID002854 |
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| • | Fidelity Printers and Refiners - CID002515 |
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| • | Sudan Gold Refinery - CID002567 |
When these facilities were reported on a CMRT by one of the Company’s suppliers, risk mitigation activities were initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to JBT, and escalating up to removal of these high risk smelters from their supply chain.
Consistent with the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
If any smelter or refiner is not recognized by the CFSI, Assent conducts outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, Assent conducts outreach providing education on the Conflict-Free Smelter Program and encouraging them to join this program.
We also calculate supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage, evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on the following CMRT questions:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
When suppliers meet or exceed those criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
3.3 Design and Implement a Strategy to Respond to Identified Risks
In response to this risk assessment, we have a risk management plan, through which the conflict minerals program is implemented, managed and monitored.
As part of our risk management plan, to ensure suppliers understand our expectations we have provided both video, recorded training and documented instructions through Assent’s compliance supply chain staff. As the program progresses, contacts via email and phone by our business segments may be utilized to communicate the importance of a response via CMRTs to Assent and the required cooperation for compliance without conflict minerals policies will be emphasized.
We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During calendar year 2016, we have found no instances where it was necessary to terminate a contract or find a replacement supplier.
3.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with 3TG smelters and refiners and do not presently perform or direct audits of these entities within our supply chain. JBT depends on audits performed and submitted to the CFSI for conflict-free certifications.
3.5 Report Annually on Supply Chain Due Diligence
We report annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission. Our Form SD and Conflict Minerals Report can be found on the Investor Relations page of our website http://ir.jbtcorporation.com/sec.cfm.
4. Due Diligence Results
Certain of the responses provided by the Company’s suppliers to the CMRT included the names of smelters or refiners. See Appendix A - Validated Smelter List. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the CFSI, and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent confirmed that the name was listed as such by CFSI. Assent, using the sources above, has validated 319 smelters and refiners (“SORs”) disclosed by the Company’s suppliers on submitted CMRTs. Going forward, Assent is continuing to validate additional SORs from the submitted CMRTs.
The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our suppliers contained in Appendix A below may include smelters or refiners that processed conflict minerals that our suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during calendar year 2016. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during calendar year 2016, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted on smelters as part of the CFSP and the information that we receive from our suppliers may yield inaccurate or incomplete information. For example, the information received from our suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSP and, as a result, are not responsible for the quality of these audits or the audit findings.
Appendix A to this CMR lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and CFSI.
Many of our surveyed suppliers are still unable to provide the smelters or refiners used for materials they supplied to us. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs.
As noted above, the current efforts focus on gathering smelter information via the CMRT and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the 3TGs to their location of origin.
We believe that the inquiries and assessment processes described above represent a reasonable effort to determine the origin of the 3TGs in our products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
5. Risk Mitigation and Program Improvement Steps
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the Covered Countries:
a. Engage with suppliers through Assent and provide training resources to attempt to increase the response rate and improve the content of the supplier survey responses.
b. Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict.
Appendix A - Validated Smelter List
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| Metal | Smelter Name | Smelter Facility Location | CFSI Audit Status |
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Active |
| Gold | Advanced Chemical Company | UNITED STATES | Compliant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Compliant |
| Gold | Asahi Pretec Corp. | JAPAN | Compliant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Compliant |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Not Enrolled |
| Gold | AU Traders and Refiners | SOUTH AFRICA | Compliant |
| Gold | AURA-II | UNITED STATES | Not Enrolled |
| Gold | Aurubis AG | GERMANY | Compliant |
| Gold | Bangalore Refinery | INDIA | Active |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant |
| Gold | Boliden AB | SWEDEN | Compliant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant |
| Gold | Caridad | MEXICO | Not Enrolled |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant |
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Active |
| Gold | Chimet S.p.A. | ITALY | Compliant |
| Gold | Chugai Mining | JAPAN | Not Enrolled |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Not Enrolled |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Not Enrolled |
| Gold | DODUCO GmbH | GERMANY | Compliant |
| Gold | Dowa | JAPAN | Compliant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Compliant |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
| Gold | Elemetal Refining, LLC | UNITED STATES | Compliant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant |
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| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Not Enrolled |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Not Enrolled |
| Gold | Geib Refining Corporation | UNITED STATES | Active |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Not Enrolled |
| Gold | Guangdong Jinding Gold Limited | CHINA | Not Enrolled |
| Gold | Gujarat Gold Centre | INDIA | Not Enrolled |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Not Enrolled |
| Gold | Heimerle + Meule GmbH | GERMANY | Compliant |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Not Enrolled |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Not Enrolled |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | Istanbul Gold Refinery | TURKEY | Compliant |
| Gold | Japan Mint | JAPAN | Compliant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Compliant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Not Enrolled |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Not Enrolled |
| Gold | Kazzinc | KAZAKHSTAN | Compliant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | Not Enrolled |
| Gold | Lingbao Gold Co., Ltd. | CHINA | Not Enrolled |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | L'Orfebre S.A. | ANDORRA | Not Enrolled |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Not Enrolled |
| Gold | Materion | UNITED STATES | Compliant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Compliant |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Compliant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant |
| Gold | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled |
| Gold | Morris and Watson | NEW ZEALAND | Not Enrolled |
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| Gold | Morris and Watson Gold Coast | AUSTRALIA | Not Enrolled |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active |
| Gold | Nihon Material Co., Ltd. | JAPAN | Compliant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant |
| Gold | PAMP S.A. | SWITZERLAND | Compliant |
| Gold | Pease & Curren | UNITED STATES | Not Enrolled |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Not Enrolled |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant |
| Gold | PX Précinox S.A. | SWITZERLAND | Compliant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant |
| Gold | Remondis Argentia B.V. | NETHERLANDS | Not Enrolled |
| Gold | Republic Metals Corporation | UNITED STATES | Compliant |
| Gold | Royal Canadian Mint | CANADA | Compliant |
| Gold | SAAMP | FRANCE | Not Enrolled |
| Gold | Sabin Metal Corp. | UNITED STATES | Not Enrolled |
| Gold | SAFINA A.S. | CZECH REPUBLIC | Not Enrolled |
| Gold | Sai Refinery | INDIA | Not Enrolled |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Compliant |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Not Enrolled |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Compliant |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Compliant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Not Enrolled |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant |
| Gold | So Accurate Group, Inc. | UNITED STATES | Not Enrolled |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant |
| Gold | Sudan Gold Refinery | SUDAN | Not Enrolled |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant |
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | Active |
| Gold | T.C.A S.p.A | ITALY | Compliant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Not Enrolled |
| Gold | Tony Goetz NV | BELGIUM | Active |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Not Enrolled |
| Gold | Torecom | KOREA, REPUBLIC OF | Compliant |
| Gold | Umicore Brasil Ltda. | BRAZIL | Compliant |
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| | | |
| Gold | Umicore Precious Metals Thailand | THAILAND | Compliant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Not Enrolled |
| Gold | Valcambi S.A. | SWITZERLAND | Compliant |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Compliant |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Not Enrolled |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant |
| Tantalum | D Block Metals, LLC | UNITED STATES | Compliant |
| Tantalum | Duoluoshan | CHINA | Compliant |
| Tantalum | Exotech Inc. | UNITED STATES | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Not Enrolled |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant |
| Tantalum | H.C. Starck Ltd. | JAPAN | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
| Tantalum | KEMET Blue Metals | MEXICO | Compliant |
| Tantalum | KEMET Blue Powder | UNITED STATES | Compliant |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant |
| Tantalum | LSM Brasil S.A. | BRAZIL | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant |
| Tantalum | Plansee SE Liezen | AUSTRIA | Not Enrolled |
| Tantalum | Plansee SE Reutte | AUSTRIA | Compliant |
| Tantalum | Power Resources Ltd. | MACEDONIA | Compliant |
|
| | | |
| Tantalum | QuantumClean | UNITED STATES | Compliant |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
| Tantalum | Taki Chemicals | JAPAN | Compliant |
| Tantalum | Telex Metals | UNITED STATES | Compliant |
| Tantalum | Tranzact, Inc. | UNITED STATES | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Compliant |
| Tin | Alpha | UNITED STATES | Compliant |
| Tin | An Thai Minerals Co., Ltd. | VIET NAM | Not Enrolled |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Not Enrolled |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant |
| Tin | China Tin Group Co., Ltd. | CHINA | Compliant |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Not Enrolled |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant |
| Tin | CV Ayi Jaya | INDONESIA | Compliant |
| Tin | CV Dua Sekawan | INDONESIA | Compliant |
| Tin | CV Gita Pesona | INDONESIA | Compliant |
| Tin | CV Serumpun Sebalai | INDONESIA | Compliant |
| Tin | CV Tiga Sekawan | INDONESIA | Compliant |
| Tin | CV United Smelting | INDONESIA | Compliant |
| Tin | CV Venus Inti Perkasa | INDONESIA | Compliant |
| Tin | Dowa | JAPAN | Compliant |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active |
| Tin | Elmet S.L.U. | SPAIN | Compliant |
| Tin | EM Vinto | BOLIVIA | Compliant |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Not Enrolled |
| Tin | Fenix Metals | POLAND | Compliant |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Compliant |
| Tin | Gejiu Jinye Mineral Company | CHINA | Compliant |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Not Enrolled |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Not Enrolled |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Compliant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Compliant |
| Tin | Metallic Resources, Inc. | UNITED STATES | Compliant |
| Tin | Metallo-Chimique N.V. | BELGIUM | Compliant |
| Tin | Mineração Taboca S.A. | BRAZIL | Compliant |
| Tin | Minsur | PERU | Compliant |
|
| | | |
| Tin | Mitsubishi Materials Corporation | JAPAN | Compliant |
| Tin | Modeltech Sdn Bhd | MALAYSIA | Not Enrolled |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant |
| Tin | Phoenix Metal Ltd. | RWANDA | Not Enrolled |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Bangka Prima Tin | INDONESIA | Compliant |
| Tin | PT Bangka Tin Industry | INDONESIA | Compliant |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant |
| Tin | PT Bukit Timah | INDONESIA | Compliant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Compliant |
| Tin | PT DS Jaya Abadi | INDONESIA | Compliant |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant |
| Tin | PT Inti Stania Prima | INDONESIA | Compliant |
| Tin | PT Justindo | INDONESIA | Not Enrolled |
| Tin | PT Karimun Mining | INDONESIA | Compliant |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Compliant |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Compliant |
| Tin | PT Mitra Stania Prima | INDONESIA | Compliant |
| Tin | PT O.M. Indonesia | INDONESIA | Compliant |
| Tin | PT Panca Mega Persada | INDONESIA | Compliant |
| Tin | PT Prima Timah Utama | INDONESIA | Compliant |
| Tin | PT Refined Bangka Tin | INDONESIA | Compliant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant |
| Tin | PT Sukses Inti Makmur | INDONESIA | Compliant |
| Tin | PT Sumber Jaya Indah | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant |
| Tin | PT Tommy Utama | INDONESIA | Compliant |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
| Tin | Rui Da Hung | TAIWAN | Compliant |
| Tin | Soft Metais Ltda. | BRAZIL | Compliant |
| Tin | Thaisarco | THAILAND | Compliant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Not Enrolled |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Compliant |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active |
| Tin | Yunnan Tin Company Limited | CHINA | Compliant |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant |
|
| | | |
| Tungsten | ACL Metais Eireli | BRAZIL | Not Enrolled |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | H.C. Starck GmbH | GERMANY | Compliant |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Not Enrolled |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Kennametal Fallon | UNITED STATES | Compliant |
| Tungsten | Kennametal Huntsville | UNITED STATES | Compliant |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Compliant |
| Tungsten | Niagara Refining LLC | UNITED STATES | Compliant |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Compliant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Compliant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
Countries of origin include:
Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Democratic Republic of the Congo, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe.
