BioTelemetry, Inc.
Conflict Minerals Report for the year ended December 31, 2017
This Conflict Minerals Report of BioTelemetry, Inc. for the year ended December 31, 2017, 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 monitoring services and digital population health management for healthcare providers, medical device manufacturing and centralized core laboratory services for clinical research. Since we became focused on cardiac monitoring in 1999, we have developed a proprietary integrated patient management platform that incorporates a wireless data transmission network, U.S. Food and Drug Administration (“FDA”) cleared algorithms, medical devices and 24-hour monitoring service centers. On December 1, 2016, BioTelemetry completed the acquisition of Telcare Medical Supply, Inc., and in accordance with the Rule, the business acquired will be part of our 2018 reporting and compliance included on the Form SD to be filed next year. On July 12, 2017, BioTelemetry completed the acquisition of LifeWatch AG, and in accordance with the Rule, the business acquired will be part of our 2019 reporting and compliance included on the Form SD to be filed in 2020.
This report has been prepared by the management of BioTelemetry.
In accordance with the Rule, this report is available on our website: www.gobio.com/investors/corporate-governance/.
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 (collectively, 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. We have a program team and utilize 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 2018, 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 Organisation for Economic Co-operation and Development (“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.
We have identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by our consolidated legal entity, 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.
We have identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by our consolidated legal entity, Braemar Manufacturing, LLC: 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 2017, 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 2017 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: www.gobio.com/investors/corporate-governance/.
In accordance with the Rule, we make our Conflict Minerals Policy available on our website: www.gobio.com/investors/corporate-governance/.
4. Due diligence results - 2017
For the calendar year 2017, 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 2017 was 74%. 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 340 unique smelters as potential sources of 3TG that were reported to be in the supply chain at some point during the 2017 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.
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| | | | |
| Metal | | Identified smelters verified as CFSP conflict-free, or the smelter pledged or committed to CFSI validation | | Number of identified smelters for each metal |
| Tantalum | | 80.0% | | 50 |
| Tungsten | | 95.0% | | 56 |
| Tin | | 78.7% | | 89 |
| Gold | | 78.0% | | 150 |
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 I.”
During 2018, 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 I
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | Abington Reldan Metals, LLC | | UNITED STATES OF AMERICA |
| Gold | | Advanced Chemical Company | | UNITED STATES OF AMERICA |
| Gold | | AGR Mathey | | AUSTRALIA |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN |
| Gold | | Al Etihad Gold LLC | | UNITED ARAB EMIRATES |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN |
| Gold | | AngloGold Ashanti Brazil | | BRAZIL |
| Gold | | Argor-Heraeus S.A. | | SWITZERLAND |
| Gold | | Asahi Pretec Corp. | | JAPAN |
| Gold | | Asahi Refining Canada Ltd. | | CANADA |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN |
| Gold | | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | | TURKEY |
| Gold | | AU Traders and Refiners | | SOUTH AFRICA |
| Gold | | AURA-II | | UNITED STATES OF AMERICA |
| Gold | | Aurubis AG | | GERMANY |
| Gold | | Bangalore Refinery | | INDIA |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| Gold | | Boliden AB | | SWEDEN |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| Gold | | Caridad | | MEXICO |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA |
| Gold | | Cendres + Metaux S.A. | | SWITZERLAND |
| Gold | | Chimet S.p.A. | | ITALY |
| Gold | | China's Shandong Gold Mining Co., Ltd | | CHINA |
| Gold | | Chugai Mining | | JAPAN |
| Gold | | Daejin Indus Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | Daye Non-Ferrous Metals Mining Ltd. | | CHINA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY |
| Gold | | Do Sung Corporation | | REPUBLIC OF KOREA |
| Gold | | Doduco | | GERMANY |
| Gold | | Dowa | | JAPAN |
| Gold | | Eco-System Recycling Co., Ltd. | | JAPAN |
| Gold | | Elemetal Refining, LLC | | UNITED STATES OF AMERICA |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES |
| Gold | | Fidelity Printers and Refiners Ltd. | | ZIMBABWE |
| Gold | | FSE Novosibirsk Refinery | | RUSSIAN FEDERATION |
| Gold | | Gansu Seemine Material Hi-Tech Co., Ltd. | | CHINA |
| Gold | | GCC Gujrat Gold Centre Pvt. Ltd. | | INDIA |
| Gold | | Geib Refining Corporation | | UNITED STATES OF AMERICA |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA |
| 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 |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | HeeSung Metal Ltd. | | REPUBLIC OF KOREA |
| Gold | | Heimerle + Meule GmbH | | GERMANY |
| Gold | | Heraeus Ltd. Hong Kong | | CHINA |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY |
| Gold | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Gold | | HwaSeong CJ CO., LTD. | | REPUBLIC OF KOREA |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN |
| Gold | | Istanbul Gold Refinery | | TURKEY |
| Gold | | Italpreziosi | | ITALY |
| Gold | | Japan Mint | | JAPAN |
| Gold | | Jiangxi Copper Co., Ltd. | | CHINA |
| Gold | | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | | RUSSIAN FEDERATION |
| Gold | | JSC Uralelectromed | | RUSSIAN FEDERATION |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN |
| Gold | | Kaloti Precious Metals | | UNITED ARAB EMIRATES |
| Gold | | Kazakhmys Smelting LLC | | KAZAKHSTAN |
| Gold | | Kazzinc | | KAZAKHSTAN |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES OF AMERICA |
| Gold | | KGHM Polska Miedz Spolka Akcyjna | | POLAND |
| Gold | | Kojima Chemicals Co., Ltd | | JAPAN |
| Gold | | Korea Zinc Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN |
| Gold | | Kyshtym Copper-Electrolytic Plant ZAO | | RUSSIAN FEDERATION |
| Gold | | L'azurde Company For Jewelry | | SAUDI ARABIA |
| Gold | | Lingbao Gold Co., Ltd. | | CHINA |
| Gold | | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | | CHINA |
| Gold | | L'Orfebre S.A. | | ANDORRA |
| Gold | | LS-NIKKO Copper Inc. | | REPUBLIC OF KOREA |
| Gold | | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | | CHINA |
| Gold | | Marsam Metals | | BRAZIL |
| Gold | | Materion | | UNITED STATES OF AMERICA |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| Gold | | Metalor Switzerland | | SWITZERLAND |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES OF AMERICA |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO |
| Gold | | Mitsubishi Materials Corporation | | JAPAN |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | INDIA |
| Gold | | Modeltech Sdn Bhd | | MALAYSIA |
| Gold | | Morris and Watson | | NEW ZEALAND |
| Gold | | Morris and Watson Gold Coast | | AUSTRALIA |
| Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN |
| Gold | | Nihon Material Co. LTD | | JAPAN |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN |
| Gold | | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | | RUSSIAN FEDERATION |
| Gold | | PAMP S.A. | | SWITZERLAND |
| Gold | | Pease & Curren | | UNITED STATES OF AMERICA |
| Gold | | Penglai Penggang Gold Industry Co., Ltd. | | CHINA |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA |
| Gold | | PX Precinox S.A. | | SWITZERLAND |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA |
| Gold | | Remondis Argentia B.V. | | NETHERLANDS |
| Gold | | Republic Metals Corporation | | UNITED STATES OF AMERICA |
| Gold | | Royal Canadian Mint | | CANADA |
| Gold | | SAAMP | | FRANCE |
| Gold | | Sabin Metal Corp. | | UNITED STATES OF AMERICA |
| Gold | | Safimet S.p.A | | ITALY |
| Gold | | SAFINA A.S. | | CZECH REPUBLIC |
| Gold | | Sai Refinery | | INDIA |
| Gold | | Samduck Precious Metals | | REPUBLIC OF KOREA |
| Gold | | Samwon Metals Corp. | | REPUBLIC OF KOREA |
| Gold | | SAXONIA Edelmetalle GmbH | | GERMANY |
| Gold | | Schone Edelmetaal B.V. | | NETHERLANDS |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN |
| Gold | | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | | CHINA |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | | CHINA |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA |
| Gold | | Singway Technology Co., Ltd. | | TAIWAN |
| Gold | | Smelter not listed | | ITALY |
| Gold | | SMM | | JAPAN |
| Gold | | So Accurate Group, Inc. | | UNITED STATES OF AMERICA |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN |
| Gold | | State Research Institute Center for Physical Sciences and Technology | | LITHUANIA |
| Gold | | Sudan Gold Refinery | | SUDAN |
| Gold | | SungEel HiMetal Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | T.C.A S.p.A | | ITALY |
| Gold | | Tanaka Denshi Kogyo K.K | | JAPAN |
| Gold | | Tokuriki Honten Co., Ltd | | JAPAN |
| Gold | | Tongling Nonferrous Metals Group Co., Ltd. | | CHINA |
| Gold | | Tony Goetz NV | | BELGIUM |
| Gold | | TOO Tau-Ken-Altyn | | KAZAKHSTAN |
| Gold | | Torecom | | REPUBLIC OF KOREA |
| Gold | | Umicore Brasil Ltda. | | BRAZIL |
| Gold | | Umicore Precious Metals Thailand | | THAILAND |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM |
| Gold | | United Precious Metal Refining, Inc. | | UNITED STATES OF AMERICA |
| Gold | | Universal Precious Metals Refining Zambia | | ZAMBIA |
| Gold | | Valcambi S.A. | | SWITZERLAND |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY |
| Gold | | Yamakin Co., Ltd. | | JAPAN |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN |
| Gold | | Yunnan Copper Industry Co., Ltd. | | CHINA |
| Gold | | Zhongjin Gold Corporation Limited | | CHINA |
| Tantalum | | Asaka Riken Co., Ltd. | | JAPAN |
| 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 | | E.S.R. Electronics | | UNITED STATES OF AMERICA |
| Tantalum | | Exotech Inc. | | UNITED STATES OF AMERICA |
| Tantalum | | F&X Electro-Materials Limited. | | CHINA |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES OF AMERICA |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck GmbH Goslar | | GERMANY |
| Tantalum | | H.C. Starck GmbH Laufenburg | | GERMANY |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | 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 | | 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 | | Jiangxi Tuohong New Raw Material | | CHINA |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Nonferrous Metals Smelting Company Limited | | 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 | | Mineracao Taboca S.A. | | BRAZIL |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Tantalum | | Molycorp Silmet A.S. | | ESTONIA |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
| Tantalum | | Plansee SE Liezen | | AUSTRIA |
| Tantalum | | Plansee SE Reutte | | AUSTRIA |
| Tantalum | | Power Resources Ltd. | | MACEDONIA |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tantalum | | QuantumClean | | UNITED STATES OF AMERICA |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tantalum | | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium 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 | | ULBA | | KAZAKHSTAN |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| Tantalum | | Yichun Jin Yang Rare Metal Co., Ltd. | | CHINA |
| Tin | | Alpha | | UNITED STATES OF AMERICA |
| Tin | | An Thai Minerals Co., Ltd. | | VIETNAM |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIETNAM |
| Tin | | Brand IMLI | | INDONESIA |
| Tin | | Brand RBT | | INDONESIA |
| Tin | | Chengfeng Metals Co Pte Ltd | | CHINA |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA |
| Tin | | China Rare Metal Material Co., Ltd. | | CHINA |
| Tin | | China Tin (Hechi) | | CHINA |
| Tin | | China Yunnan Tin Co Ltd. | | CHINA |
| Tin | | CNMC (Guangxi) PGMA Co., Ltd. | | CHINA |
| Tin | | Cooperativa Metalurgica de Rondônia Ltda. | | BRAZIL |
| Tin | | CV Ayi Jaya | | INDONESIA |
| Tin | | CV Dua Sekawan | | INDONESIA |
| Tin | | CV Gita Pesona | | INDONESIA |
| Tin | | CV Nurjanah | | INDONESIA |
| Tin | | CV Serumpun Sebalai | | INDONESIA |
| Tin | | CV Tiga Sekawan | | INDONESIA |
| Tin | | CV United Smelting | | INDONESIA |
| Tin | | CV Venus Inti Perkasa | | INDONESIA |
| Tin | | Dowa | | JAPAN |
| Tin | | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | | VIETNAM |
| Tin | | Elmet S.L.U. | | SPAIN |
| Tin | | EM Vinto | | BOLIVIA |
| Tin | | Estanho de Rondonia S.A. | | BRAZIL |
| Tin | | Fenix Metals | | POLAND |
| Tin | | Funsur Smelter | | PERU |
| Tin | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA |
| Tin | | Gejiu Jinye Mineral Company | | CHINA |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA |
| Tin | | Gejiu Non-Ferrous Metal Processing Co. Ltd. | | CHINA |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA |
| Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA |
| Tin | | Kundur Smelter | | INDONESIA |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA |
| Tin | | Melt Metais e Ligas S.A. | | BRAZIL |
| Tin | | Mentok Smelter | | INDONESIA |
| Tin | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Mineracao Taboca S.A. | | BRAZIL |
| Tin | | Mitsubishi Materials Corporation | | JAPAN |
| Tin | | Modeltech Sdn Bhd | | MALAYSIA |
| Tin | | Nghe Tinh Non-Ferrous Metals Joint Stock Company | | VIETNAM |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES |
| Tin | | OMSA | | BOLIVIA |
| Tin | | Phoenix Metal Ltd. | | RWANDA |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA |
| Tin | | PT Babel Inti Perkasa | | INDONESIA |
| Tin | | PT Bangka Prima Tin | | INDONESIA |
| Tin | | PT Bangka Tin Industry | | INDONESIA |
| Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| Tin | | PT Cipta Persada Mulia | | INDONESIA |
| Tin | | PT DS Jaya Abadi | | INDONESIA |
| Tin | | PT Eunindo Usaha Mandiri | | INDONESIA |
| Tin | | PT Inti Stania Prima | | INDONESIA |
| Tin | | PT Justindo | | INDONESIA |
| Tin | | PT Karimun Mining | | INDONESIA |
| Tin | | PT Kijang Jaya Mandiri | | INDONESIA |
| Tin | | PT Lautan Harmonis Sejahtera | | INDONESIA |
| Tin | | PT Menara Cipta Mulia | | INDONESIA |
| Tin | | PT Mitra Stania Prima | | INDONESIA |
| Tin | | PT O.M. Indonesia | | INDONESIA |
| Tin | | PT Panca Mega Persada | | INDONESIA |
| Tin | | PT Prima Timah Utama | | INDONESIA |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| Tin | | PT Sukses Inti Makmur | | INDONESIA |
| Tin | | PT Sumber Jaya Indah | | INDONESIA |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA |
| Tin | | PT Tirus Putra Mandiri | | INDONESIA |
| Tin | | PT Tommy Utama | | INDONESIA |
| Tin | | PT Wahana Perkit Jaya | | INDONESIA |
| Tin | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tin | | Rui Da Hung | | TAIWAN |
| Tin | | Soft Metais Ltda. | | BRAZIL |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tin | | Super Ligas | | BRAZIL |
| Tin | | Thailand Smelting & Refining Co Ltd | | THAILAND |
| Tin | | Tuyen Quang Non-Ferrous Metals Joint Stock Company | | VIETNAM |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL |
| Tungsten | | A.L.M.T. TUNGSTEN Corp. | | JAPAN |
| Tungsten | | ACL Metais Eireli | | BRAZIL |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIETNAM |
| Tungsten | | ATI Metalworking Products | | UNITED STATES OF AMERICA |
| Tungsten | | Chaozhou Xianglu Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Chongyi Zhangyuan Tungsten Co Ltd | | CHINA |
| Tungsten | | Dayu Jincheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Dayu Weiliang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Yatai Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA |
| Tungsten | | H.C. Starck GmbH | | GERMANY |
| Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Hunan Litian Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Kennametal Fallon | | UNITED STATES OF AMERICA |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Moliren Ltd | | RUSSIAN FEDERATION |
| Tungsten | | Niagara Refining LLC | | UNITED STATES OF AMERICA |
| Tungsten | | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | | VIETNAM |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES |
| Tungsten | | South-East Nonferrous Metal Company Limited of Hengyang City | | CHINA |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIETNAM |
| Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION |
| Tungsten | | Vietnam Youngsun Tungsten Industry Co., Ltd. | | VIETNAM |
| Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tungsten | | Woltech Korea Co., Ltd. | | REPUBLIC OF KOREA |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| Tungsten | | Xiamen Tungsten Co., Ltd | | CHINA |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA |
