Exhibit 1.01
BioTelemetry, Inc.
Conflict Minerals Report for the year ended December 31, 2016
This Conflict Minerals Report of BioTelemetry, Inc. for the year ended December 31, 2016 is provided pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the U.S. Securities and Exchange Commission (the “SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. As permitted by the Rule and in accordance with guidance issued by the SEC on April 29, 2014, this report has not been subject to an independent private sector audit.
1. Introduction
BioTelemetry, Inc. (hereinafter “BioTelemetry”, the “Company”, “we”, “us”, or “our”) provides cardiac monitoring services, cardiac monitoring device manufacturing, and centralized cardiac core laboratory services. Since the Company became focused on cardiac monitoring in 1999, the Company has developed a proprietary integrated patient management platform that incorporates a wireless data transmission network, Food and Drug Administration (“FDA”) cleared algorithms and medical devices, and 24-hour digital monitoring service centers.
This report has been prepared by the management of BioTelemetry. This report does not include the activities of entities that are not required to be consolidated in our financial statements.
In accordance with the Rule, this report is available on our website: http://investors.gobio.com/wp-content/uploads/2017/05/FORM-SD-Exhibit-1.01.pdf
2. Supply chain description and Reasonable Country of Origin Inquiry
2.1 General information on Biotelemetry’s supply chain
The hardware provided by BioTelemetry largely consists of electronics. Our supply chain is complex with multiple tiers of suppliers and we are a remote downstream participant. For manufacturing, BioTelemetry purchases customized and standardized components from several global providers as well as from local and regional suppliers, either off-the-shelf or in accordance with Biotelemetry’s design or specifications. Certain types of components are produced in-house. The production of printed circuit boards and molded plastic components is mostly outsourced to manufacturing services companies. Final configuration of products is largely done in-house and on-demand. This consists of assembling and testing modules and integrating them into complete units.
2.2 Overview of BioTelemetry’s Conflict Minerals Program and Reasonable Country of Origin Inquiry
BioTelemetry gathers conflict minerals information from our suppliers. Through this we know that many of our products contain tin, tantalum, tungsten and gold (“3TG”) that are necessary to the functionality of those products.
As part of BioTelemetry’s commitment to responsible sourcing, human rights and sustainability, it is our goal that the 3TG in our products should not, directly or indirectly, finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries (the “DRC”). At the same time, we aim to continue supporting responsible mineral sourcing in the region. BioTelemetry’s efforts with respect to 3TG are aligned to the work of the Conflict-Free Sourcing Initiative (“CFSI”) and our aim is to improve the traceability in our supply chain.
BioTelemetry does not ban materials from the DRC or avoid using 3TGs. The Company has a program team and utilizes outside advisors to fulfill compliance with the Rule, perform the Reasonable Country of Origin Inquiry and report on 3TG. This team is responsible for BioTelemetry’s 3TG implementation work and senior management is regularly informed about matters relating to 3TG.
BioTelemetry relies on its first tier suppliers to provide information on the origin of 3TG contained in components and parts included in BioTelemetry’s products. This includes sources of 3TG that are supplied to them from sub-suppliers. Our first tier suppliers are similarly reliant upon information provided by their upstream suppliers. Certain of BioTelemetry’s large hardware suppliers are also SEC registrants and subject to the Rule.
The identification of first tier suppliers of BioTelemetry that are in scope under the Rule involves different regions, business units and production sites that are part of BioTelemetry’s global organization. The sourcing organization has an important role in leading and coordinating the work. Suppliers identified to be in scope are first tier suppliers of BioTelemetry supplying (i) products containing 3TG that BioTelemetry contracts to manufacture, (ii) materials, parts, components and other products, containing 3TG, that are incorporated into or included in a product manufactured by BioTelemetry, or (iii) materials used in the production of BioTelemetry’s products where 3TG becomes part of the final product. Suppliers of products that BioTelemetry does not contract to manufacture (i.e. products purchased “off-the shelf”) and not included in, or incorporated into, a BioTelemetry product have been considered out of scope for purposes of the Rule. In our annual inquiry we survey first tier suppliers identified to be in scope and analyze and follow up upon responses as we deem appropriate. Accordingly, during 2016, BioTelemetry conducted a reasonable country of origin inquiry to determine the origin of the 3TG in BioTelemetry’s products.
BioTelemetry believes that industry cooperation is one of the best ways to address issues related to 3TG in an efficient and transparent way. BioTelemetry is engaged and actively cooperates with supply-chain participants and supports the 3TG industry initiatives such as the CFSI driven by the Global e-Sustainability Initiative (GeSI) and the Electronic Industry Citizenship Coalition (EICC).
In accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”), we support the CFSI’s audit of smelters’ and refiners’ due diligence activities. In our internal processes, we use information obtained using CFSI’s Reasonable Country of Origin Inquiry Data for BioTelemetry.
The Company has identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Universal Medical, Inc.: Pacetrak Plus, Pacetrak ENR, Pacetrak Speaks, Heartrak Smart, Heartrak Smart AF, Heartrak 2, Heartrak ECAT, Heartrak TCAT, Heartrak ECAT2, Heartrak Smart Wireless, and Cardiostation Transtelephonic Module.
The Company has identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Braemar: DL800, DL900, DL1200, DTXT, PORT/DOCK, ER8, ER9, ER920W, LOOPER, PER900, Fusion, C5, PSITECIII, CardioKey, EZPUMP, BTP-1000S and BTP-1000M.
3. Due Diligence
BioTelemetry has processes in place for the purpose of exercising due diligence in the supply chain. The design of the due diligence processes conforms substantially to the OECD Guidance as it relates to “downstream” purchasers of products and components. Our position in the supply chain is remote. We do not have a direct relationship with mining companies or with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain with 3TG. We rely upon industry efforts to influence smelters and refiners to be audited and certified through CFSI’s Conflict Free Smelter Program.
The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
3.1 Maintain strong management systems
The first step relates to strong management systems. As mentioned above, BioTelemetry has established a program team for reporting on 3TG and compliance with the Rule. This team is responsible for the 3TG implementation work and senior management is regularly informed about matters relating to 3TG. Controls include, but are not limited to, supplier requirements relating to 3TG as described above and are integrated in our template supplier agreements.
With respect to 2016, identification of smelters/refiners in our supply chain was made via the use of due diligence tools created by the CFSI, including the EICC/GeSI Conflict Minerals Reporting Template 4.01 (the “Template”). The Template is a supply chain survey designed to identify the smelters and refiners that process the necessary 3TG contained in our supply chain. The information from our suppliers, in combination with information from the CFSI, helps BioTelemetry to obtain information on the origin of minerals processed. Data obtained was reviewed and analyzed by BioTelemetry.
We have grievance mechanisms, notably a whistleblower tool, managed by an external service provider, for the reporting of alleged violations of laws or the Code of Business Ethics that relate to corruption, questionable accounting, or auditing matters that seriously affect vital interests of the Group or Compliance, in general. Violations reported through the whistleblower tool are handled by BioTelemetry’s Group Compliance Forum, consisting of representatives from BioTelemetry’s Group Function Legal Affairs and Group Function Human Resources. Information regarding incidents is reported to the Compliance and Audit Committees. Reports include measures taken, details of the responsible Group function and the status of any investigation.
3.2 Identify and assess risk in the supply chain
In the second step, risks are identified and assessed. Downstream companies should, with help from their first tier suppliers, identify smelters and refiners in the supply chain.
In BioTelemetry’s 2016 survey, first tier suppliers identified to be in scope were requested by BioTelemetry to provide information on 3TG in their supply chain through completing and submitting the Template. Suppliers were provided with support material, including the generally available instructions and training illustrating the use of the tool that is available on CFSI’s website. To ensure sufficient quality, a high response rate and to minimize risks, the responses received were continuously analyzed and followed up as deemed appropriate. The data obtained was saved, reviewed and analyzed by BioTelemetry. Supplier responses were reviewed against criteria developed to determine which responses required further engagement with our suppliers. These criteria were developed to identify whether the responses from suppliers were incomplete and where further inquiries were necessary. Suppliers were contacted via e-mail or telephone to improve the quality of responses and increase the response rate.
We have had a risk based approach focused on suppliers with incomplete data since they are typically deemed to constitute a higher risk. As part of the risk mitigation efforts, additional efforts were mainly targeted at suppliers that are awarded large parts of our business on an ongoing basis.
3.3 Design and implement a strategy to respond to identified risks
Under the third step companies are encouraged to design and implement a strategy to respond to identified risks. Due diligence within BioTelemetry is an on-going process, both proactive and reactive, where suppliers are continuously evaluated against BioTelemetry’s requirements to ensure that these requirements are systematically incorporated in the suppliers’ processes.
We continuously work to improve our due diligence processes with respect to 3TG, mainly focusing on the quality of data received from suppliers surveyed. This includes communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. As described above, we have a risk based approach when reviewing and following up supplier responses and we generally prioritize suppliers that we frequently purchase from.
3.4 Independent third party audit of smelters’/refiners’ due diligence practices
The fourth step focuses on analysis of smelters’/refiners’ due diligence practices. We support the Conflict Free Smelter Program (“CFSP”) as well as the development and implementation of due diligence practices and tools such as the Template. Due to the structure of our supply chain, there can be many tiers of suppliers between BioTelemetry and the smelters and refiners in the supply chain. We analyze the received data on smelters and refiners and compare such information against the list of facilities that have received a “conflict free” designation from the CFSP. Via the CFSI we also can access information on country of origin and due diligence information on the 3TG sourced by such facilities.
3.5 Report annually on supply chain due diligence
The fifth step encourages reporting on supply chain due diligence. We have a public statement on 3TG on our external website and strive to continuously increase 3TG awareness within BioTelemetry and among suppliers. BioTelemetry’s public statement on the sourcing of 3TG is available on our website: http://investors.gobio.com/wp-content/uploads/2017/05/FORM-SD-Exhibit-1.01.pdf
In accordance with the Rule, we make our Conflict Minerals Policy available on our website: http://investors.gobio.com/wp-content/uploads/2015/05/Product-Components-and-Conflict-Minerals-Policy1.pdf
4. 2016 due diligence results
For the calendar year 2016, our inquiries were made on the supplier level. Inquiries also include responses where suppliers were unable to specify the smelters or refiners used for components supplied to us and certain responses included names of smelters or refiners that we believe may have been misidentified as smelters or refiners that we believe are not operational. Such names have not been listed among identified smelters and refiners.
The response rate among suppliers surveyed in 2016 was 82%. A higher response rate was achieved in the group of suppliers that are awarded a larger part of our business. Among the supplier responses, we identified approximately 400 unique smelters as potential sources of 3TG that were reported to be in the supply chain at some point during the 2016 calendar year. The following table presents, by mineral, the percentages of identified smelters or refiners in our supply chain that have been verified as conflict-free or pledged or committed to CFSI validation.
Metal |
| Identified smelters |
| Number of identified smelters |
|
Tantalum |
| 92.0 | % | 49 |
|
Tungsten |
| 87.0 | % | 52 |
|
Tin |
| 83.0 | % | 101 |
|
Gold |
| 74.0 | % | 152 |
|
We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the locations of origin of the 3TG in our supply chain. A list of identified smelters, by mineral, is contained in “Annex 1.”
During 2017, we expect to continue to review and evolve our due diligence processes with respect to 3TG. As part of these efforts, we expect to collaborate with suppliers for purposes of further improving the supplier response rate and the reliability and quality of information provided.
Due to the size, breadth and complexity of our products, and the constant evolution of our supply chain, the process of successfully tracing all of the conflict minerals used in our products back to their country of origin will require additional time and resources. We are committed to implementing processes to improve the quantity and quality of responses from our supply chain and to verifying the accuracy and completeness of the information we receive directly from suppliers or which is otherwise available to us through industry and other initiatives.
Our ability to make determinations about the presence and source of origin of 3TGs in our products depends upon a number of factors including, but not limited to, (i) the respective due diligence efforts of our tier one suppliers and their supply chain, as well as their willingness to disclose such information to us, and (ii) the ability and willingness of our supply chain to adopt the OECD Guidance and other initiatives or guidance that may develop over time with respect to responsible sourcing. The failure to obtain reliable information from any level of our supply chain could have a material impact on our ability to provide meaningful information on the presence and origin of 3TGs in our products’ supply chain with any reasonable degree of certainty. There can be no assurance that our suppliers will continue to cooperate with our diligence inquiries and our requests for certifications or to provide us with the documentation or other evidence that we consider reliable or in a time frame sufficient to allow us to make a reasonable and reliable assessment following appropriate further diligence measures, as may be required.
5. Forward Looking Statements
Certain of the matters discussed in this report, including in particular our due diligence processes with respect to 3TG, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of anticipated events.
The information included on any websites that appear in this report and other materials referenced to is not incorporated by reference in this report.
Annex 1
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Gold |
| Asahi Pretec Corporation |
| JAPAN |
Gold |
| Eco-System Recycling Co., Ltd. |
| JAPAN |
Gold |
| Ishifuku Metal Industry Co., Ltd. |
| JAPAN |
Gold |
| JX Nippon Mining & Metals Co., Ltd. |
| JAPAN |
Gold |
| Matsuda Sangyo Co., Ltd. |
| JAPAN |
Gold |
| Mitsubishi Materials Corporation |
| JAPAN |
Gold |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
Gold |
| Nihon Material Co. LTD |
| JAPAN |
Gold |
| Solar Applied Materials Technology Corp. |
| TAIWAN |
Gold |
| Sumitomo Metal Mining Co., Ltd. |
| JAPAN |
Gold |
| Tanaka Kikinzoku Kogyo K.K. |
| JAPAN |
Gold |
| Tokuriki Honten Co., Ltd |
| JAPAN |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co. Ltd |
| CHINA |
Gold |
| Argor-Heraeus SA |
| SWITZERLAND |
Gold |
| Heraeus Ltd. Hong Kong |
| CHINA |
Gold |
| Dowa |
| JAPAN |
Gold |
| Dowa Metals & Mining. |
| JAPAN |
Gold |
| Kojima Chemicals Co., Ltd |
| JAPAN |
Gold |
| Argor-Heraeus S.A. |
| SWITZERLAND |
Gold |
| Aida Chemical Industries Co., Ltd. |
| JAPAN |
Gold |
| Kojima Chemicals Co., Ltd. |
| JAPAN |
Gold |
| Tokuriki Honten Co., Ltd. |
| JAPAN |
Gold |
| The Refinery of Shandong Gold Mining Co., Ltd. |
| CHINA |
Gold |
| Asahi Refining Canada Ltd. |
| CANADA |
Gold |
| Metalor Technologies S.A. |
| SWITZERLAND |
Gold |
| Western Australian Mint trading as The Perth Mint |
| AUSTRALIA |
Gold |
| Heraeus Precious Metals GmbH & Co. KG |
| GERMANY |
Gold |
| Asahi Refining USA Inc. |
| UNITED STATES OF AMERICA |
Gold |
| Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| CHINA |
Gold |
| Allgemeine Gold-und Silberscheideanstalt A.G. |
| GERMANY |
Gold |
| Metalor Technologies (Hong Kong) Ltd. |
| CHINA |
Gold |
| Metalor Technologies (Singapore) Pte., Ltd. |
| SINGAPORE |
Gold |
| Asahi Pretec Corp. |
| JAPAN |
Gold |
| Nihon Material Co., Ltd. |
| JAPAN |
Gold |
| Asaka Riken Co., Ltd. |
| JAPAN |
Gold |
| Valcambi S.A. |
| SWITZERLAND |
Gold |
| Rand Refinery (Pty) Ltd. |
| SOUTH AFRICA |
Gold |
| LS-NIKKO Copper Inc. |
| KOREA (REPUBLIC OF) |
Gold |
| Aurubis AG |
| GERMANY |
Gold |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| PHILIPPINES |
Gold |
| Kennecott Utah Copper LLC |
| UNITED STATES OF AMERICA |
Gold |
| CCR Refinery - Glencore Canada Corporation |
| CANADA |
Gold |
| Metalor USA Refining Corporation |
| UNITED STATES OF AMERICA |
Gold |
| Republic Metals Corporation |
| UNITED STATES OF AMERICA |
Gold |
| Royal Canadian Mint |
| CANADA |
Gold |
| Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| MEXICO |
Gold |
| Ohura Precious Metal Industry Co., Ltd. |
| JAPAN |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Gold |
| Umicore Precious Metals Thailand |
| THAILAND |
Gold |
| Elemetal Refining, LLC |
| UNITED STATES |
Gold |
| Yokohama Metal Co., Ltd. |
| JAPAN |
Gold |
| SEMPSA Joyería Platería S.A. |
| SPAIN |
Gold |
| Jiangxi Copper Co., Ltd. |
| CHINA |
Gold |
| Boliden AB |
| SWEDEN |
Gold |
| Schone Edelmetaal B.V. |
| NETHERLANDS |
Gold |
| Heimerle + Meule GmbH |
| GERMANY |
Gold |
| Chimet S.p.A. |
| ITALY |
Gold |
| Materion |
| UNITED STATES |
Gold |
| DODUCO GmbH |
| GERMANY |
Gold |
| Umicore S.A. Business Unit Precious Metals Refining |
| BELGIUM |
Gold |
| OJSC Novosibirsk Refinery |
| RUSSIAN FEDERATION |
Gold |
| PX Précinox S.A. |
| SWITZERLAND |
Gold |
| Umicore Brasil Ltda. |
| BRAZIL |
Gold |
| PT Aneka Tambang (Persero) Tbk |
| INDONESIA |
Gold |
| United Precious Metal Refining, Inc. |
| UNITED STATES |
Gold |
| PAMP S.A. |
| SWITZERLAND |
Gold |
| Yamamoto Precious Metal Co., Ltd. |
| JAPAN |
Gold |
| Istanbul Gold Refinery |
| TURKEY |
Gold |
| JSC Uralelectromed |
| RUSSIAN FEDERATION |
Gold |
| Kazzinc |
| KAZAKHSTAN |
Gold |
| Prioksky Plant of Non-Ferrous Metals |
| RUSSIAN FEDERATION |
Gold |
| Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| CHINA |
Gold |
| Moscow Special Alloys Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| Japan Mint |
| JAPAN |
Gold |
| Zijin Mining Group Co., Ltd. Gold Refinery |
| CHINA |
Gold |
| C. Hafner GmbH + Co. KG |
| GERMANY |
Gold |
| JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| RUSSIAN FEDERATION |
Gold |
| AngloGold Ashanti Córrego do Sítio Mineração |
| BRAZIL |
Gold |
| SOE Shyolkovsky Factory of Secondary Precious Metals |
| RUSSIAN FEDERATION |
Gold |
| Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| CHINA |
Gold |
| Metalor Switzerland |
| SWITZERLAND |
Gold |
| Tanaka Kikinzoku Kogyo K.K |
| JAPAN |
Gold |
| Almalyk Mining and Metallurgical Complex (AMMC) |
| UZBEKISTAN |
Gold |
| DSC (Do Sung Corporation) |
| KOREA (REPUBLIC OF) |
Gold |
| Kyrgyzaltyn JSC |
| KYRGYZSTAN |
Gold |
| MMTC-PAMP India Pvt., Ltd. |
| INDIA |
Gold |
| Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| TURKEY |
Gold |
| Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| AUSTRIA |
Gold |
| OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
| RUSSIAN FEDERATION |
Gold |
| Samduck Precious Metals |
| KOREA (REPUBLIC OF) |
Gold |
| Sichuan Tianze Precious Metals Co., Ltd. |
| CHINA |
Gold |
| Singway Technology Co., Ltd. |
| TAIWAN, PROVINCE OF CHINA |
Gold |
| T.C.A S.p.A |
| ITALY |
Gold |
| Torecom |
| KOREA (REPUBLIC OF) |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Gold |
| Advanced Chemical Company |
| UNITED STATES OF AMERICA |
Gold |
| Al Etihad Gold Refinery DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| TURKEY |
Gold |
| Caridad |
| MEXICO |
Gold |
| Cendres + Métaux S.A. |
| SWITZERLAND |
Gold |
| Chugai Mining |
| JAPAN |
Gold |
| Daejin Indus Co., Ltd. |
| KOREA (REPUBLIC OF) |
Gold |
| Daye Non-Ferrous Metals Mining Ltd. |
| CHINA |
Gold |
| Gansu Seemine Material Hi-Tech Co., Ltd. |
| CHINA |
Gold |
| Geib Refining Corporation |
| UNITED STATES OF AMERICA |
Gold |
| Great Wall Precious Metals Co., Ltd. of CBPM |
| CHINA |
Gold |
| Guangdong Jinding Gold Limited |
| CHINA |
Gold |
| Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| CHINA |
Gold |
| Hangzhou Fuchunjiang Smelting Co., Ltd. |
| CHINA |
Gold |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Gold |
| HwaSeong CJ Co., Ltd. |
| KOREA (REPUBLIC OF) |
Gold |
| Kazakhmys Smelting LLC |
| KAZAKHSTAN |
Gold |
| KGHM Polska Miedź Spółka Akcyjna |
| POLAND |
Gold |
| L’azurde Company For Jewelry |
| SAUDI ARABIA |
Gold |
| Lingbao Gold Co., Ltd. |
| CHINA |
Gold |
| Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| CHINA |
Gold |
| Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| CHINA |
Gold |
| Metalor Technologies (Suzhou) Ltd. |
| CHINA |
Gold |
| Navoi Mining and Metallurgical Combinat |
| UZBEKISTAN |
Gold |
| Penglai Penggang Gold Industry Co., Ltd. |
| CHINA |
Gold |
| Sabin Metal Corp. |
| UNITED STATES OF AMERICA |
Gold |
| Samwon Metals Corp. |
| KOREA (REPUBLIC OF) |
Gold |
| SAXONIA Edelmetalle GmbH |
| GERMANY |
Gold |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| CHINA |
Gold |
| So Accurate Group, Inc. |
| UNITED STATES OF AMERICA |
Gold |
| Tongling Nonferrous Metals Group Co., Ltd. |
| CHINA |
Gold |
| WIELAND Edelmetalle GmbH |
| GERMANY |
Gold |
| Yunnan Copper Industry Co., Ltd. |
| CHINA |
Gold |
| AU Traders and Refiners |
| SOUTH AFRICA |
Gold |
| AURA-II |
| UNITED STATES OF AMERICA |
Gold |
| Bangalore Refinery |
| INDIA |
Gold |
| Emirates Gold DMCC |
| UNITED ARAB EMIRATES |
Gold |
| Fidelity Printers and Refiners Ltd. |
| ZIMBABWE |
Gold |
| Gujarat Gold Centre |
| INDIA |
Gold |
| Kaloti Precious Metals |
| UNITED ARAB EMIRATES |
Gold |
| Korea Zinc Co., Ltd. |
| KOREA (REPUBLIC OF) |
Gold |
| Modeltech Sdn Bhd |
| MALAYSIA |
Gold |
| Morris and Watson |
| NEW ZEALAND |
Gold |
| Remondis Argentia B.V. |
| NETHERLANDS |
Gold |
| SAAMP |
| FRANCE |
Gold |
| SAFINA A.S. |
| CZECH REPUBLIC |
Gold |
| Sai Refinery |
| INDIA |
Gold |
| Sudan Gold Refinery |
| SUDAN |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Gold |
| Tony Goetz NV |
| BELGIUM |
Gold |
| TOO Tau-Ken-Altyn |
| KAZAKHSTAN |
Gold |
| Universal Precious Metals Refining Zambia |
| ZAMBIA |
Gold |
| Abington Reldan Metals, LLC |
| UNITED STATES OF AMERICA |
Gold |
| CANADA |
| CANADA |
Gold |
| UNITED STATES |
| UNITED STATES |
Gold |
| BELGIUM |
| BELGIUM |
Gold |
| Bauer Walser AG |
| GERMANY |
Gold |
| Faggi Enrico S.p.A. |
| ITALY |
Gold |
| Korea Metal Co., Ltd. |
| KOREA (REPUBLIC OF) |
Gold |
| OJSC Kolyma Refinery |
| RUSSIAN FEDERATION |
Tantalum |
| F & X |
| CHINA |
Tantalum |
| F&X Electro-Materials Ltd. |
| CHINA |
Tantalum |
| Global Advanced Metals Boyertown |
| UNITED STATES OF AMERICA |
Tantalum |
| H.C. Starck Co., Ltd. |
| THAILAND |
Tantalum |
| H.C. Starck GmbH Goslar |
| GERMANY |
Tantalum |
| H.C. Starck Inc. |
| UNITED STATES OF AMERICA |
Tantalum |
| H.C. Starck Ltd. |
| JAPAN |
Tantalum |
| H.C. Starck Smelting GmbH & Co. KG |
| GERMANY |
Tantalum |
| Ningxia Orient Tantalum Industry Co., Ltd. |
| CHINA |
Tantalum |
| Ulba Metallurgical Plant JSC |
| KAZAKHSTAN |
Tantalum |
| H.C. Starck Hermsdorf GmbH |
| GERMANY |
Tantalum |
| Changsha South Tantalum Niobium Co., Ltd. |
| CHINA |
Tantalum |
| Conghua Tantalum and Niobium Smeltry |
| CHINA |
Tantalum |
| D Block Metals, LLC |
| UNITED STATES OF AMERICA |
Tantalum |
| Duoluoshan |
| CHINA |
Tantalum |
| Exotech Inc. |
| UNITED STATES OF AMERICA |
Tantalum |
| FIR Metals & Resource Ltd. |
| CHINA |
Tantalum |
| Global Advanced Metals Aizu |
| JAPAN |
Tantalum |
| Guangdong Zhiyuan New Material Co., Ltd. |
| CHINA |
Tantalum |
| H.C. Starck GmbH Laufenburg |
| GERMANY |
Tantalum |
| Hengyang King Xing Lifeng New Materials Co., Ltd. |
| CHINA |
Tantalum |
| Hi-Temp Specialty Metals, Inc. |
| UNITED STATES OF AMERICA |
Tantalum |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Tanbre Co., Ltd. |
| CHINA |
Tantalum |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| CHINA |
Tantalum |
| KEMET Blue Metals |
| MEXICO |
Tantalum |
| KEMET Blue Powder |
| UNITED STATES OF AMERICA |
Tantalum |
| King-Tan Tantalum Industry Ltd. |
| CHINA |
Tantalum |
| LSM Brasil S.A. |
| BRAZIL |
Tantalum |
| Metallurgical Products India Pvt., Ltd. |
| INDIA |
Tantalum |
| Mineração Taboca S.A. |
| BRAZIL |
Tantalum |
| Mitsui Mining and Smelting Co., Ltd. |
| JAPAN |
Tantalum |
| Molycorp Silmet A.S. |
| ESTONIA |
Tantalum |
| Plansee SE Liezen |
| AUSTRIA |
Tantalum |
| Plansee SE Reutte |
| AUSTRIA |
Tantalum |
| QuantumClean |
| UNITED STATES OF AMERICA |
Tantalum |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Tantalum |
| RFH Tantalum Smeltry Co., Ltd. |
| CHINA |
Tantalum |
| Solikamsk Magnesium Works OAO |
| RUSSIAN FEDERATION |
Tantalum |
| Taki Chemical Co., Ltd. |
| JAPAN |
Tantalum |
| Telex Metals |
| UNITED STATES OF AMERICA |
Tantalum |
| Tranzact, Inc. |
| UNITED STATES OF AMERICA |
Tantalum |
| XinXing HaoRong Electronic Material Co., Ltd. |
| CHINA |
Tantalum |
| Yichun Jin Yang Rare Metal Co., Ltd. |
| CHINA |
Tantalum |
| Zhuzhou Cemented Carbide Group Co., Ltd. |
| CHINA |
Tantalum |
| Jiangxi Tuohong New Raw Material |
| CHINA |
Tantalum |
| Power Resources Ltd. |
| MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) |
Tantalum |
| E.S.R. Electronics |
| UNITED STATES OF AMERICA |
Tin |
| Malaysia Smelting Corporation (MSC) |
| MALAYSIA |
Tin |
| PT Timah |
| INDONESIA |
Tin |
| CV United Smelting |
| INDONESIA |
Tin |
| EM Vinto |
| BOLIVIA |
Tin |
| Gejiu Non-Ferrous Metal Processing Co. Ltd. |
| CHINA |
Tin |
| Metallo Chimique |
| BELGIUM |
Tin |
| Mineração Taboca S.A. |
| BRAZIL |
Tin |
| Minsur |
| PERU |
Tin |
| Mitsubishi Materials Corporation |
| JAPAN |
Tin |
| OMSA |
| BOLIVIA |
Tin |
| PT Bukit Timah |
| INDONESIA |
Tin |
| PT Mitra Stania Prima |
| INDONESIA |
Tin |
| PT REFINED BANGKA TIN |
| INDONESIA |
Tin |
| PT Stanindo Inti Perkasa |
| INDONESIA |
Tin |
| PT Tambang Timah |
| INDONESIA |
Tin |
| Thailand Smelting & Refining Co., Ltd |
| THAILAND |
Tin |
| Thaisarco |
| THAILAND |
Tin |
| Yunnan Tin Company Limited |
| CHINA |
Tin |
| PT Timah (Persero) Tbk Mentok |
| INDONESIA |
Tin |
| PT Timah (Persero) Tbk Kundur |
| INDONESIA |
Tin |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| CHINA |
Tin |
| Metallo-Chimique N.V. |
| BELGIUM |
Tin |
| Operaciones Metalurgical S.A. |
| BOLIVIA (PLURINATIONAL STATE OF) |
Tin |
| White Solder Metalurgia e Mineração Ltda. |
| BRAZIL |
Tin |
| PT Eunindo Usaha Mandiri |
| INDONESIA |
Tin |
| PT Tinindo Inter Nusa |
| INDONESIA |
Tin |
| PT Sariwiguna Binasentosa |
| INDONESIA |
Tin |
| Metallic Resources, Inc. |
| UNITED STATES OF AMERICA |
Tin |
| PT Belitung Industri Sejahtera |
| INDONESIA |
Tin |
| Dowa |
| JAPAN |
Tin |
| Cooperativa Metalurgica de Rondônia Ltda. |
| BRAZIL |
Tin |
| Alpha |
| UNITED STATES |
Tin |
| PT DS Jaya Abadi |
| INDONESIA |
Tin |
| PT Babel Inti Perkasa |
| INDONESIA |
Tin |
| PT Inti Stania Prima |
| INDONESIA |
Tin |
| PT Bangka Tin Industry |
| INDONESIA |
Tin |
| China Tin Group Co., Ltd. |
| CHINA |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Tin |
| MSC |
| MALAYSIA |
Tin |
| China Yunnan Tin Co Ltd. |
| CHINA |
Tin |
| CV Ayi Jaya |
| INDONESIA |
Tin |
| CV Gita Pesona |
| INDONESIA |
Tin |
| CV Serumpun Sebalai |
| INDONESIA |
Tin |
| CV Venus Inti Perkasa |
| INDONESIA |
Tin |
| Elmet S.L.U. |
| SPAIN |
Tin |
| Fenix Metals |
| POLAND |
Tin |
| Jiangxi Ketai Advanced Material Co., Ltd. |
| CHINA |
Tin |
| Magnu’s Minerais Metais e Ligas Ltda. |
| BRAZIL |
Tin |
| Melt Metais e Ligas S.A. |
| BRAZIL |
Tin |
| O.M. Manufacturing (Thailand) Co., Ltd. |
| THAILAND |
Tin |
| O.M. Manufacturing Philippines, Inc. |
| PHILIPPINES |
Tin |
| PT Aries Kencana Sejahtera |
| INDONESIA |
Tin |
| PT Artha Cipta Langgeng |
| INDONESIA |
Tin |
| PT ATD Makmur Mandiri Jaya |
| INDONESIA |
Tin |
| PT Bangka Prima Tin |
| INDONESIA |
Tin |
| PT Cipta Persada Mulia |
| INDONESIA |
Tin |
| PT Menara Cipta Mulia |
| INDONESIA |
Tin |
| PT Panca Mega Persada |
| INDONESIA |
Tin |
| PT Prima Timah Utama |
| INDONESIA |
Tin |
| PT Sukses Inti Makmur |
| INDONESIA |
Tin |
| PT Sumber Jaya Indah |
| INDONESIA |
Tin |
| PT Tommy Utama |
| INDONESIA |
Tin |
| Resind Indústria e Comércio Ltda. |
| BRAZIL |
Tin |
| Rui Da Hung |
| TAIWAN, PROVINCE OF CHINA |
Tin |
| Soft Metais Ltda. |
| BRAZIL |
Tin |
| VQB Mineral and Trading Group JSC |
| VIET NAM |
Tin |
| An Vinh Joint Stock Mineral Processing Company |
| VIET NAM |
Tin |
| CNMC (Guangxi) PGMA Co., Ltd. |
| CHINA |
Tin |
| Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| VIET NAM |
Tin |
| Estanho de Rondônia S.A. |
| BRAZIL |
Tin |
| Gejiu Kai Meng Industry and Trade LLC |
| CHINA |
Tin |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| CHINA |
Tin |
| Gejiu Zili Mining And Metallurgy Co., Ltd. |
| CHINA |
Tin |
| HuiChang Hill Tin Industry Co., Ltd. |
| CHINA |
Tin |
| Huichang Jinshunda Tin Co., Ltd. |
| CHINA |
Tin |
| Nankang Nanshan Tin Manufactory Co., Ltd. |
| CHINA |
Tin |
| Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| Phoenix Metal Ltd. |
| RWANDA |
Tin |
| PT Justindo |
| INDONESIA |
Tin |
| PT Karimun Mining |
| INDONESIA |
Tin |
| PT Tirus Putra Mandiri |
| INDONESIA |
Tin |
| PT Wahana Perkit Jaya |
| INDONESIA |
Tin |
| Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| VIET NAM |
Tin |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| CHINA |
Tin |
| An Thai Minerals Co., Ltd. |
| VIET NAM |
Tin |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| CHINA |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Tin |
| CV Dua Sekawan |
| INDONESIA |
Tin |
| CV Tiga Sekawan |
| INDONESIA |
Tin |
| Gejiu Fengming Metallurgy Chemical Plant |
| CHINA |
Tin |
| Gejiu Jinye Mineral Company |
| CHINA |
Tin |
| Guanyang Guida Nonferrous Metal Smelting Plant |
| CHINA |
Tin |
| Modeltech Sdn Bhd |
| MALAYSIA |
Tin |
| PT Kijang Jaya Mandiri |
| INDONESIA |
Tin |
| PT O.M. Indonesia |
| INDONESIA |
Tin |
| PERU |
| PERU |
Tin |
| Linwu Xianggui Ore Smelting Co., Ltd. |
| CHINA |
Tin |
| Novosibirsk Processing Plant Ltd. |
| RUSSIAN FEDERATION |
Tin |
| PT Bangka Kudai Tin |
| INDONESIA |
Tin |
| PT Bangka Putra Karya |
| INDONESIA |
Tin |
| PT Bangka Timah Utama Sejahtera |
| INDONESIA |
Tin |
| PT BilliTin Makmur Lestari |
| INDONESIA |
Tin |
| Yunnan Tin Company, Ltd. |
| CHINA |
Tungsten |
| Xiamen Tungsten Co., Ltd |
| CHINA |
Tungsten |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| CHINA |
Tungsten |
| China National Nonferrous Industry Corp. |
| CHINA |
Tungsten |
| Chongyi Zhangyuan Tungsten Co Ltd |
| CHINA |
Tungsten |
| Ganzhou Huaxing Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Seadragon W & Mo Co., Ltd. |
| CHINA |
Tungsten |
| Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. |
| CHINA |
Tungsten |
| Chongyi Zhangyuan Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Xiamen Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Xiamen Tungsten (H.C.) Co., Ltd. |
| CHINA |
Tungsten |
| A.L.M.T. TUNGSTEN Corp. |
| JAPAN |
Tungsten |
| Kennametal Huntsville |
| UNITED STATES OF AMERICA |
Tungsten |
| Guangdong Xianglu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Fujian Jinxin Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Global Tungsten & Powders Corp. |
| UNITED STATES OF AMERICA |
Tungsten |
| Hunan Chunchang Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Japan New Metals Co., Ltd. |
| JAPAN |
Tungsten |
| Wolfram Bergbau und Hütten AG |
| AUSTRIA |
Tungsten |
| Chenzhou Diamond Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| H.C. Starck Smelting GmbH & Co.KG |
| GERMANY |
Tungsten |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| VIET NAM |
Tungsten |
| Hydrometallurg, JSC |
| RUSSIAN FEDERATION |
Tungsten |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| CHINA |
Tungsten |
| H.C. Starck GmbH |
| GERMANY |
Tungsten |
| Hunan Chenzhou Mining Co., Ltd. |
| CHINA |
Tungsten |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| CHINA |
Tungsten |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Gan Bei Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Yaosheng Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Kennametal Fallon |
| UNITED STATES OF AMERICA |
Metal |
| Smelter or Refiner Name |
| Smelter Country |
Tungsten |
| Malipo Haiyu Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Niagara Refining LLC |
| UNITED STATES OF AMERICA |
Tungsten |
| Tejing (Vietnam) Tungsten Co., Ltd. |
| VIET NAM |
Tungsten |
| Vietnam Youngsun Tungsten Industry Co., Ltd. |
| VIET NAM |
Tungsten |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Asia Tungsten Products Vietnam Ltd. |
| VIET NAM |
Tungsten |
| Dayu Jincheng Tungsten Industry Co., Ltd. |
| CHINA |
Tungsten |
| Dayu Weiliang Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Yatai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| CHINA |
Tungsten |
| ACL Metais Eireli |
| BRAZIL |
Tungsten |
| Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| CHINA |
Tungsten |
| Moliren Ltd |
| RUSSIAN FEDERATION |
Tungsten |
| Philippine Chuangxin Industrial Co., Inc. |
| PHILIPPINES |
Tungsten |
| South-East Nonferrous Metal Company Limited of Hengyang City |
| CHINA |
Tungsten |
| Unecha Refractory metals plant |
| RUSSIAN FEDERATION |
Tungsten |
| Woltech Korea Co., Ltd. |
| KOREA (REPUBLIC OF) |
Tungsten |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| CHINA |
Tungsten |
| Ganzhou Non-ferrous Metals Smelting Co., Ltd. |
| CHINA |
Tungsten |
| Nippon Yakin Kogyo Co., Ltd. |
| JAPAN |
