Malibu Boats, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2017
Introduction
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2017 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers if they manufacture or contract to manufacture products that contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If an issuer has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries and are not from recycled or scrap sources, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and file a CMR as an exhibit to the Form SD with the SEC that includes a description of those due diligence measures.
Company Overview
Malibu Boats, Inc., also referred to as “Malibu Boats”, “we”, “our”, and “us” is a leading designer, manufacturer and marketer of a diverse range of recreational powerboats, including performance sport boats, sterndrive and outboard boats. Our boats are used for water sports, including water skiing, wakeboarding and wake surfing, as well as general recreational boating. Our high performance boats are sold under three brands: Malibu; Axis; and Cobalt. We manufacture our own Malibu, Axis and Cobalt performance boats and components such as trailers, towers and tower accessories. In addition, we contract with other third-party vendors to manufacture other components for installation on our boats, such as engines and electronic controls and pursuant to our engine integration strategy, beginning as early as with our model year 2019 boats we will purchase engines from General Motors LLC and prepare them for marine use. We determined that Conflict Minerals were necessary to the functionality and/or production of such products during calendar year 2017.
Executive Summary
Malibu Boats does not directly source any Conflict Minerals that may be used in the products we manufacture or contract to manufacture. Therefore we relied upon our suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to them from sub-tier suppliers. Malibu Boats performed a Reasonable Country of Origin Inquiry (“RCOI”) on suppliers believed to provide Malibu Boats with materials or components containing necessary 3TGs.
Malibu Boats’ suppliers identified 306 valid smelters and refineries (“smelters”). Of these 306 smelters, Malibu Boats identified 41 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Malibu Boats’ due diligence review indicated that 36 of these smelters have been audited and recognized as conflict free by the Responsible Minerals Assurance Process (“RMAP,” previously known as the Conflict Free Smelter Program or CFSP) and designated as RMAP Conformant by the Responsible Minerals Initiative (previously known as the Conflict Free Sourcing Initiative). The remaining five smelters sourcing from the Covered Countries were subjected to Malibu Boats’ risk mitigation process in accordance with the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (“OECD Due Diligence Guidance”), as described below.
Although we requested information at a product level, many suppliers returned information at a company or division level, not at a product level. Such suppliers were unable to specify the smelters used for components supplied to Malibu Boats. Therefore the information provided was not necessarily limited to smelters contained in components supplied to us and confirmed to be in the Company’s supply chain.
Company Management Systems
Malibu Boats established strong management systems according to Step 1 of the OECD Due Diligence Guidance. Malibu Boats implemented the following:
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| • | Step 1A - Adopted, and clearly communicated to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. Malibu Boats: |
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| ◦ | implemented a conflict minerals policy, which is publicly available at http://investors.malibuboats.com/investors/corporate-governance/governance-documents; and |
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| ◦ | communicated the policy directly to suppliers as part of the RCOI process. |
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| • | Step 1B - Structured internal management to support supply chain due diligence. Malibu Boats: |
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| ◦ | maintained an internal cross functional team to support supply chain due diligence; |
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| ◦ | appointed a member of the senior staff with the necessary competence, knowledge, and experience to oversee supply chain due diligence; and |
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| ◦ | applied the resources necessary to support the operation and monitoring of these processes including internal resources and external consulting support. |
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| • | Step 1C - Established a system of transparency, information collection and control over the supply chain. Malibu Boats: |
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| ◦ | implemented a process to collect required supplier and smelter RCOI and due diligence data. |
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| • | Step 1D - Strengthened company engagement with suppliers. Malibu Boats: |
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| ◦ | engaged directly with suppliers during the RCOI process; |
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| ◦ | reviewed supplier responses as part of the RCOI process; |
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| ◦ | added conflict minerals compliance to new supplier contracts and Malibu Boats’ supplier code of conduct; and |
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| ◦ | implemented a plan to improve the quantity and quality of supplier and smelter responses year over year. |
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| • | Step 1E - Established a company and/or mine level grievance mechanism. Malibu Boats: |
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| ◦ | recognized the RMAP’s three audit protocols for gold, tin/tantalum, and tungsten as valid sources of smelter or mine level grievances; and |
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| ◦ | reviewed Malibu Boats’ ethics violations reporting system to ensure that it allows employees to voice confidentially without any fear of retribution, any concerns with the violations of the Malibu Boats’ conflict minerals policy. |
Reasonable Country of Origin Inquiry
Malibu Boats designed its RCOI process in accordance with Steps 2A and 2B of the OECD Due Diligence Guidance. Malibu Boats’ RCOI process involved two stages:
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| • | Stage 1 - Supplier RCOI (Step 2A of the OECD Due Diligence Guidance) |
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| • | Stage 2 - Smelter RCOI (Step 2B of the OECD Due Diligence Guidance) |
Supplier RCOI
Malibu Boats designed its supplier RCOI process to identify, to the best of Malibu Boats’ efforts, the smelters in Malibu Boats’ supply chain in accordance with Step 2A of the OECD Due Diligence Guidance. Malibu Boats’ supplier RCOI process for the 2017 reporting period included the following:
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| • | developed a list of suppliers providing components containing 3TG to Malibu Boats; |
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| • | contacted each supplier and requested the industry standard Conflict Minerals Reporting Template including smelter information; |
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| • | reviewed supplier responses for accuracy and completeness; |
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| • | amalgamated supplier provided smelters into a single list of smelters meeting the definition of a smelter under one of three industry recognized audit protocols; and |
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| • | reviewed the final smelter list (and compared it to industry peers) to determine if Malibu Boats identified reasonably all of the smelters in their supply chain. |
Malibu Boats’ suppliers identified 306 smelters in their supply chain. The specific list of smelters is included in “List of Smelter and Refineries” at the end of this report.
Smelter RCOI
Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.
Due Diligence
Malibu Boats’ due diligence process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Due Diligence Guidance.
Smelter RCOI and Due Diligence
Malibu Boats’ smelter RCOI and due diligence process were designed to:
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| • | identify the scope of the risk assessment of the mineral supply chain (OECD Due Diligence Guide Step 2B); |
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| • | assess whether the smelters have carried out all elements of due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas (OECD Due Diligence Guide Step 2C); and |
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| • | carry out, where necessary, including through participation in industry-driven programs, joint spot checks at the mineral smelter’s own facilities (OECD Due Diligence Guide Step 2D). |
Malibu Boats’ smelter RCOI and due diligence process included the following:
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| • | For each smelter identified in Malibu Boats’ supply chain, Malibu Boats: |
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| ◦ | attempted to engage directly with the smelter to determine whether or not the smelter sources from the Covered Countries; |
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| ◦ | reviewed publicly available information to determine if there was any contrary evidence to the smelter’s declaration for smelters that declared directly or through their relevant industry association that they did not source from the Covered Countries, and were not recognized as conflict free by the RMAP; and |
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| ◦ | reviewed publicly available sources to determine if there was any reason to believe that the smelter may have sourced from the Covered Countries during the reporting period for smelters that did not respond to our direct engagement. |
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| • | For high risk smelters (smelters that are sourcing from or there is reason to believe they may be sourcing from the Covered Countries), Malibu Boats determined if the smelter was audited and recognized as conflict free by the RMAP. |
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| ◦ | For high risk smelters that have not been audited and recognized as conflict free by the RMAP, Malibu Boats communicated the risk to a designated member of senior management (OECD Due Diligence Guide Step 3A) and conducted risk mitigation on the smelter according to OECD Due Diligence Guide Step 3B. |
For the 2017 reporting period, Malibu Boats’ RCOI and due diligence process was executed by Claigan Environmental Inc.
Malibu Boats’ suppliers identified 306 smelters. Malibu Boats identified 41 smelters that source, or there is a reason to believe they source, from the Covered Countries.
Malibu Boats determined that 36 of these 41 smelters have been audited and recognized as conflict free by the RMAP or RMAP Conformant. Malibu Boats conducted risk mitigation on the remaining five smelters as discussed below.
Risk Mitigation
Malibu Boats conducted risk mitigation on five smelters that were not recognized as conflict free by the RMAP and were sourcing from the Covered Countries. Malibu Boats’ risk mitigation was designed in accordance with Step 3B of the OECD Due Diligence Guidance and was reported to our Chief Financial Officer in accordance with Step 3A of the OECD Due Diligence Guidance. Malibu Boats’ risk mitigation process included the following:
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| • | conducted additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries; |
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| • | attempted to verify with internal stakeholders and relevant suppliers whether 3TGs from the specific smelter were actually in Malibu Boats’ supply chain in the 2017 reporting period; and |
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| • | engaged directly with each high risk smelter to verify risk and to encourage the smelter to become conflict free. |
As discussed above, as many suppliers return information at a company or division level, and not at a product level, we are not able to determine if the five remaining smelters are confirmed to be in Malibu Boats’ supply chain. We will continue to work with our suppliers to determine if these five smelters can be directly linked to the actual parts or products sold to Malibu Boats.
In addition, as part of our risk mitigation process we have engaged with each of them to verify risk and to encourage the smelter to become conflict free. We are continuing to work with the suppliers who currently have these five smelters in their supply chain to evaluate the removal of these smelters from their supply chain.
Improvement Plan
Malibu Boats is taking and will continue to take the following steps to improve the due diligence conducted to further mitigate any risk that the Conflict Minerals contained in the products manufactured or contracted for manufacture by Malibu Boats could directly or indirectly benefit or finance armed groups in the Covered Countries:
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| • | including a conflict minerals clause in all new and renewing supplier contracts; |
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| • | continuing to drive our suppliers to obtain current, accurate, and complete information about the smelters in their supply chain; |
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| • | continuing to work with our suppliers to encourage the removal of any high risk smelters; |
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| • | evaluating ongoing supplier relationships with those suppliers that do not comply with our conflict minerals policy; |
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| • | engaging smelters sourcing from the Covered Countries to become audited and certified to a protocol recognized by the RMAP; and |
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| • | following up in 2018 on the smelter requiring risk mitigation, but not removal from Malibu Boats’ supply chain. |
List of Smelters and Refineries
Below are the smelters reported to Malibu Boats as likely to be in Malibu Boats’ supply chain in the 2017 reporting period. 41 of the smelters below are declared to be sourcing or there was reason to believe they may be sourcing from the Covered Countries. Under the SEC Final Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries; there is no requirement to identify the specific covered country by smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Countries are The Democratic Republic of the Congo, Rwanda, Burundi, and Tanzania. As noted above, Malibu Boats has determined that of these 41 smelters, 36 have been audited and recognized as conflict free by the RMAP and Malibu Boats conducted risk mitigation on the remaining five smelters.
Metal Smelter Name
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| Gold | Abington Reldan Metals, LLC |
| Gold | Advanced Chemical Company |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração |
| Gold | Argor-Heraeus S.A. |
| Gold | Asahi Pretec Corp. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | AU Traders and Refiners |
| Gold | Aurubis AG |
| Gold | Bangalore Refinery |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden AB |
| Gold | C. Hafner GmbH + Co. KG |
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| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Métaux S.A. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Daejin Indus Co., Ltd. |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | DODUCO Contacts and Refining GmbH |
| Gold | Dowa |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. |
| Gold | Emirates Gold DMCC |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Geib Refining Corporation |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Gujarat Gold Centre |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | HeeSung Metal Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Precious Metals GmbH & Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | HwaSeong CJ Co., Ltd. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold | JSC Uralelectromed |
| Gold | JX Nippon Mining & Metals Co., Ltd. |
| Gold | Kaloti Precious Metals |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedź Spółka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO |
| Gold | L'azurde Company For Jewelry |
| Gold | L'Orfebre S.A. |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | LS-NIKKO Copper Inc. |
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| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold | Marsam Metals |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Morris and Watson Gold Coast |
| Gold | Moscow Special Alloys Processing Plant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
| Gold | OJSC Novosibirsk Refinery |
| Gold | PAMP S.A. |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Précinox S.A. |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | Remondis Argentia B.V. |
| Gold | Republic Metals Corporation |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | SAMWON Metals Corp. |
| Gold | SAXONIA Edelmetalle GmbH |
| Gold | SEMPSA Joyería Platería S.A. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
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| Gold | Solar Applied Materials Technology Corp. |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sudan Gold Refinery |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | Tony Goetz NV |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Torecom |
| Gold | Umicore Brasil Ltda. |
| Gold | Umicore Precious Metals Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Universal Precious Metals Refining Zambia |
| Gold | Valcambi S.A. |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | Exotech Inc. |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | FIR Metals & Resource Ltd. |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. |
| Tantalum | H.C. Starck Co., Ltd. |
| Tantalum | H.C. Starck Hermsdorf GmbH |
| Tantalum | H.C. Starck Inc. |
| Tantalum | H.C. Starck Ltd. |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET Blue Metals |
| Tantalum | KEMET Blue Powder |
| Tantalum | LSM Brasil S.A. |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
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| Tantalum | Mineração Taboca S.A. |
| Tantalum | Mitsui Mining & Smelting |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | Power Resources Ltd. |
| Tantalum | QuantumClean |
| Tantalum | Resind Indústria e Comércio Ltda. |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tantalum | Taki Chemicals |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. |
| Tin | Alpha |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CV Ayi Jaya |
| Tin | CV Dua Sekawan |
| Tin | CV Gita Pesona |
| Tin | CV Tiga Sekawan |
| Tin | CV United Smelting |
| Tin | CV Venus Inti Perkasa |
| Tin | Dowa |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | EM Vinto |
| Tin | Estanho de Rondônia S.A. |
| Tin | Fenix Metals |
| Tin | Gejiu Fengming Metallurgy Chemical Plant |
| Tin | Gejiu Jinye Mineral Company |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Huichang Jinshunda Tin Co., Ltd. |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Metallic Resources, Inc. |
| Tin | Metallo Belgium N.V. |
| Tin | Metallo Spain S.L.U. |
| Tin | Mineração Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Modeltech Sdn Bhd |
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| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalurgical S.A. |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Bangka Prima Tin |
| Tin | PT Bangka Tin Industry |
| Tin | PT Belitung Industri Sejahtera |
| Tin | PT Bukit Timah |
| Tin | PT DS Jaya Abadi |
| Tin | PT Eunindo Usaha Mandiri |
| Tin | PT Inti Stania Prima |
| Tin | PT Karimun Mining |
| Tin | PT Kijang Jaya Mandiri |
| Tin | PT Lautan Harmonis Sejahtera |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Panca Mega Persada |
| Tin | PT Premium Tin Indonesia |
| Tin | PT Prima Timah Utama |
| Tin | PT Refined Bangka Tin |
| Tin | PT Sariwiguna Binasentosa |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Sukses Inti Makmur |
| Tin | PT Sumber Jaya Indah |
| Tin | PT Timah (Persero) Tbk Kundur |
| Tin | PT Timah (Persero) Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | PT Tommy Utama |
| Tin | Resind Indústria e Comércio Ltda. |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Super Ligas |
| Tin | Thaisarco |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | White Solder Metalurgia e Mineração Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Tin Company Limited |
| Tungsten | A.L.M.T. TUNGSTEN Corp. |
| Tungsten | ACL Metais Eireli |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
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| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. |
| Tungsten | Global Tungsten & Powders Corp. |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. |
| Tungsten | Hydrometallurg, JSC |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Moliren Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. |
| Tungsten | Unecha Refractory Metals Plant |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. |
| Tungsten | Wolfram Bergbau und Hütten AG |
| Tungsten | Woltech Korea Co., Ltd. |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
