Exhibit 1.01
John Bean Technologies Corporation
Conflict Minerals Report
For The Calendar Year Ended December 31, 2017
This report for the calendar year ended December 31, 2017 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, 2016.
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. Providing comprehensive solutions to our customers, our Protein technology offerings include chilling, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, frying, freezing, weighing, X-ray food inspection, and packaging systems 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 2017 added significant capabilities in the powder filling and high pressure processing segments to our product portfolio. |
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| • | Automated Systems. We also provide stand-alone, fully-integrated, and dual-mode robotic automated guided vehicle systems for material movement requirements with a wide variety of applications including 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 also maintains 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://www.jbtc.com/investors/corporate-governance.
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 RBA-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.
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 94% 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 one follow up from the supply chain team. For the 2017 reporting period, JBT received responses from 39%, of its in-scope suppliers. Of the 695 suppliers that provided a response, approximately 69% 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 23, 2018, there were 17 invalid supplier submissions.
As a result of its assessment, JBT has concluded in good faith that during calendar year 2017:
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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 Organization 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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| 1. | Establishing strong company management systems regarding conflict minerals; |
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| 2. | Identifying and assessing risks in our supply chain; |
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| 3. | Designing and implementing a strategy to respond to identified risks in our supply chain; |
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| 4. | Utilizing independent third-party audits of supply chain diligence; and |
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| 5. | Publicly reporting on our supply chain due diligence |
We are a downstream supplier, many steps removed from the mining of 3TG. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, JBT does not purchase raw ore or unrefined conflict minerals. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.
The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.
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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| • | Senior Strategic Sourcing Lead |
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.
Control Systems
As described above, we have has adopted a Conflict Minerals policy which is posted on our website under “Investor Relations” “Corporate Governance” at http://www.jbtc.com/investors/corporate-governance.
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. 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 Responsible Minerals Initiative (RMI) 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; |
| 2. | Responsible Minerals Assurance Process (RMAP) audit status and; |
| 3. | Known or plausible evidence of unethical or conflict sourcing. |
Based on these criteria the following facilities disclosed in CMRT 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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| • | | African Gold Refinery Limited (AGR) - CID003185 |
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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 are reported on a CMRT by any of the Company’s suppliers, risk mitigation activities are 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 red-flagged 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 RMI, 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 RMAP 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:
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| • | Have you established a conflict minerals sourcing policy? |
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| • | Have you implemented due diligence measures for conflict-free sourcing? |
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| • | Do you review due diligence information received from your suppliers against your company’s expectations? |
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| • | Does your review 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 2017, 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 RMI 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://www.jbtc.com/investors/sec-filings.
4. Due Diligence Results
Survey Results
For the 2017 reporting year, JBT received CMRT forms from 39% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. Seventeen suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 1,803 in scope suppliers and received 695 CMRT submissions by April 23, 2018.
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 RMI, and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent confirmed that the name was listed as such by RMI. Assent, using the sources above, has validated 321 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 2017. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix A were the country of origin of conflict minerals in our products during calendar year 2017, 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 RMAP 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 RMAP 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 3TGs, based on information provided by our suppliers and RMI.
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 RMI 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.
c. Through education, encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
Appendix A - Validated Smelter List
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| Metal | Standard Smelter Name | Smelter ID |
| Gold | Abington Reldan Metals, LLC | CID002708 |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | African Gold Refinery | CID003185 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Al Etihad Gold LLC | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 |
| Gold | Argor-Heraeus S.A. | CID000077 |
| Gold | Asahi Pretec Corp. | CID000082 |
| Gold | Asahi Refining Canada Ltd. | CID000924 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
| Gold | AU Traders and Refiners | CID002850 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangalore Refinery | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Boliden AB | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Métaux S.A. | CID000189 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daejin Indus Co., Ltd. | CID000328 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
| Gold | DODUCO Contacts and Refining GmbH | CID000362 |
| Gold | Dowa | CID000401 |
| Gold | DS PRETECH Co., Ltd. | CID003195 |
| Gold | DSC (Do Sung Corporation) | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. | CID000425 |
| Gold | Elemetal Refining, LLC | CID001322 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | CID002852 |
| Gold | Geib Refining Corporation | CID002459 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | HeeSung | CID000689 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
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| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hwasung CJ Co., Ltd. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Italpreziosi | CID002765 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kaloti Precious Metals | CID002563 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
| Gold | Korea Zinc Co., Ltd. | CID002605 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
| Gold | L'azurde Company For Jewelry | CID001032 |
| Gold | Lingbao Gold Co., Ltd. | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
| Gold | L'Orfebre S.A. | CID002762 |
| Gold | LS-NIKKO Copper Inc. | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Marsam Metals | CID002606 |
| Gold | Materion | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies S.A. | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | Modeltech Sdn Bhd | CID002857 |
| Gold | Morris and Watson | CID002282 |
| Gold | Morris and Watson Gold Coast | CID002866 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | NH Recytech Company | CID003189 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 |
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| Gold | OJSC Novosibirsk Refinery | CID000493 |
| Gold | PAMP S.A. | CID001352 |
| Gold | Pease & Curren | CID002872 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Planta Recuperadora de Metales SpA | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Précinox S.A. | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 |
| Gold | Remondis Argentia B.V. | CID002582 |
| Gold | Republic Metals Corporation | CID002510 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | SAAMP | CID002761 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Safimet S.p.A | CID002973 |
| Gold | SAFINA A.S. | CID002290 |
| Gold | Sai Refinery | CID002853 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | SAMWON Metals Corp. | CID001562 |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 |
| Gold | Schone Edelmetaal B.V. | CID001573 |
| Gold | SEMPSA Joyería Platería S.A. | CID001585 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
| Gold | Sudan Gold Refinery | CID002567 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | SungEel HiTech | CID002918 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Tony Goetz NV | CID002587 |
| Gold | TOO Tau-Ken-Altyn | CID002615 |
| Gold | Torecom | CID001955 |
| Gold | Umicore Brasil Ltda. | CID001977 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
| Gold | Universal Precious Metals Refining Zambia | CID002854 |
| Gold | Valcambi S.A. | CID002003 |
| Gold | Western Australian Mint trading as The Perth Mint | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 |
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| | |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Tantalum | Asaka Riken Co., Ltd. | CID000092 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | Duoluoshan | CID000410 |
| Tantalum | Exotech Inc. | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
| Tantalum | H.C. Starck Inc. | CID002548 |
| Tantalum | H.C. Starck Ltd. | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CID003191 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | KEMET Blue Metals | CID002539 |
| Tantalum | KEMET Blue Powder | CID002568 |
| Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 |
| Tantalum | LSM Brasil S.A. | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineracao Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | NPM Silmet AS | CID001200 |
| Tantalum | Power Resources Ltd. | CID002847 |
| Tantalum | QuantumClean | CID001508 |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemicals | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 |
| Tin | Alpha | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
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| | |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 |
| Tin | CV Ayi Jaya | CID002570 |
| Tin | CV Dua Sekawan | CID002592 |
| Tin | CV Gita Pesona | CID000306 |
| Tin | CV Tiga Sekawan | CID002593 |
| Tin | CV United Smelting | CID000315 |
| Tin | CV Venus Inti Perkasa | CID002455 |
| Tin | Dowa | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondônia S.A. | CID000448 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CID002848 |
| Tin | Gejiu Jinye Mineral Company | CID002859 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CID003116 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
| Tin | Melt Metais e Ligas S.A. | CID002500 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Metallo Belgium N.V. | CID002773 |
| Tin | Metallo Spain S.L.U. | CID002774 |
| Tin | Mineracao Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Modeltech Sdn Bhd | CID002858 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Operaciones Metalurgical S.A. | CID001337 |
| Tin | Pongpipat Company Limited | CID003208 |
| Tin | PT Aries Kencana Sejahtera | CID000309 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | PT Babel Inti Perkasa | CID001402 |
| Tin | PT Bangka Prima Tin | CID002776 |
| Tin | PT Bangka Serumpun | CID003205 |
| Tin | PT Bangka Tin Industry | CID001419 |
| Tin | PT Belitung Industri Sejahtera | CID001421 |
| Tin | PT Bukit Timah | CID001428 |
| Tin | PT DS Jaya Abadi | CID001434 |
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| | |
| Tin | PT Eunindo Usaha Mandiri | CID001438 |
| Tin | PT Inti Stania Prima | CID002530 |
| Tin | PT Karimun Mining | CID001448 |
| Tin | PT Kijang Jaya Mandiri | CID002829 |
| Tin | PT Lautan Harmonis Sejahtera | CID002870 |
| Tin | PT Menara Cipta Mulia | CID002835 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT O.M. Indonesia | CID002757 |
| Tin | PT Panca Mega Persada | CID001457 |
| Tin | PT Premium Tin Indonesia | CID000313 |
| Tin | PT Prima Timah Utama | CID001458 |
| Tin | PT Refined Bangka Tin | CID001460 |
| Tin | PT Sariwiguna Binasentosa | CID001463 |
| Tin | PT Stanindo Inti Perkasa | CID001468 |
| Tin | PT Sukses Inti Makmur | CID002816 |
| Tin | PT Sumber Jaya Indah | CID001471 |
| Tin | PT Timah (Persero) Tbk Kundur | CID001477 |
| Tin | PT Timah (Persero) Tbk Mentok | CID001482 |
| Tin | PT Tinindo Inter Nusa | CID001490 |
| Tin | PT Tommy Utama | CID001493 |
| Tin | Resind Industria e Comercio Ltda. | CID002706 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Soft Metais Ltda. | CID001758 |
| Tin | Super Ligas | CID002756 |
| Tin | Thaisarco | CID001898 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Yunnan Tin Company Limited | CID002180 |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 |
| Tungsten | ACL Metais Eireli | CID002833 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
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| | |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Moliren Ltd | CID002845 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CID002815 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 |
| Tungsten | Unecha Refractory metals plant | CID002724 |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 |
| Tungsten | Woltech Korea Co., Ltd. | CID002843 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 |
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.
Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, DRC, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zimbabwe
