EXHIBIT 1.01
BABCOCK & WILCOX ENTERPRISES, INC.
CONFLICT MINERALS REPORT
YEAR ENDED DECEMBER 31, 2015
Introduction
This Conflict Minerals Report (this "Report") has been prepared by management of Babcock & Wilcox Enterprises, Inc. In this Report, unless the context otherwise indicates, "B&W," "we," "us," the "Company" and "our" mean Babcock & Wilcox Enterprises, Inc. and its consolidated and combined subsidiaries. This Report for the year ended December 31, 2015 (the “Reporting Period”) is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (“3TG”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this Report, B&W has reason to believe that some of the 3TG present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TG in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TG from the DRC Region and proceeded to conduct due diligence on our supplier base.
Forward looking statements
Statements we make in this Report, which express a belief, expectation or intention, as well as those that are not historical fact, are forward-looking statements, including statements relating to our compliance efforts and expected actions identified under the “Steps to be taken” section of this Report. These forward-looking statements are subject to various risks, uncertainties and assumptions, including, among other things, our ability to implement improvements in our conflict minerals program and identify and mitigate related risks in our supply chain. If one or more of these or other risks materialize, actual results may vary materially from those expressed. For a more complete discussion of these and other risk factors, see our other filings with the Securities and Exchange Commission (“SEC”), including our Annual Report on Form 10-K for the year ended December 31, 2015. B&W cautions not to place undue reliance on these forward-looking statements, which speak only as of the date of this Report, and we undertake no obligation to update or revise any forward-looking statement, except to the extent required by applicable law.
Overview
Our business
B&W is a leading technology-based provider of advanced fossil and renewable power generation and environmental equipment that includes a broad suite of boiler products and environmental systems, and services for power and industrial uses. We specialize in technology and engineering for power generation and
various other industries, the related procurement, erection and specialty manufacturing of equipment, and the provision of related services, including:
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| • | high-pressure equipment for energy conversion, such as boilers fueled by coal, oil, bitumen, natural gas, and renewables including municipal solid waste and biomass fuels; |
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| • | environmental control systems for both power generation and industrial applications to incinerate, filter, capture, recover and/or purify air, liquid and vapor-phase effluents from a variety of power generation and specialty manufacturing processes; |
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| • | aftermarket support for the global installed base of operating plants with a wide variety of products and technical services including replacement parts, retrofit and upgrade capabilities, field engineering, construction, inspection, operations and maintenance, condition assessment and other technical support; and |
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| • | engineered-to-order services, products and systems for energy conversion worldwide and related auxiliary equipment, such as burners, pulverizers, soot blowers and ash and material handling systems. |
We operate in three reportable segments: Global Power, Global Services and Industrial Environmental. Through our Global Power segment, we engineer, manufacture, procure, construct and commission boilers fueled by fossil fuels and renewables in addition to environmental systems and related auxiliary equipment primarily to steam generating customers globally. Through our Global Services segment, we provide aftermarket products and services to steam generating utilities worldwide and numerous industrial customers globally. We have supplied the boilers for approximately 35% of the coal-fired electric generating capacity in the United States. We also provide aftermarket services for global installed units delivered by other original equipment suppliers. Through our Industrial Environmental segment, we provide a range of environmental technology and services to numerous industrial end markets globally.
Our business segments
Global Power
Our Global Power segment represents our worldwide new build boiler and environmental products businesses that serve large steam generating and industrial customers. The segment provides a full suite of product and service offerings including engineering, procurement, specialty manufacturing, construction and commissioning. Our boilers include utility boilers and industrial boilers fired with coal and natural gas as well as renewables including biomass and municipal solid waste. Our boiler products include advanced supercritical boilers, subcritical boilers, fluidized bed boilers, biomass-fired boilers, waste-to-energy boilers, chemical recovery boilers, industrial power boilers, package boilers, heat recovery steam generators and waste heat boilers.
Our environmental systems offerings include air pollution control products and related equipment for the treatment of nitrogen oxides, sulfur dioxide, fine particulate, mercury, acid gases and other hazardous air emissions, including wet and dry flue gas desulfurization systems, catalytic and non-catalytic nitrogen oxides reduction systems, low nitrogen oxides burners and overfire air systems, fabric filter baghouses, wet and dry electrostatic precipitators, mercury control systems and dry sorbent injection for acid gas mitigation.
Global Services
Our Global Services segment provides a comprehensive mix of aftermarket products and services to support peak efficiency and availability of steam generating and associated environmental and auxiliary equipment, serving large steam generating utility and industrial customers globally. Our products and services include replacement parts, field technical services, retrofit and upgrade projects, fuel switching and repowering
projects, construction and maintenance services, start-up and commissioning, training programs and plant operations and maintenance for our full complement of boiler, environmental and auxiliary equipment. Our auxiliary equipment includes boiler cleaning equipment and material handling equipment.
Industrial Environmental
Our Industrial Environmental segment represents our environmental products and services business serving numerous industrial end markets such as the chemical, pharmaceutical, energy storage, packaging, and automotive markets. The segment designs, engineers and manufactures products including oxidizers, solvent and distillation systems, wet and dry electrostatic precipitators, scrubbers and heat recovery systems. The segment also provides specialized industrial process systems and equipment.
Our products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in products within each of our business segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period.
Conflict minerals policy
We have adopted a conflict minerals policy, as follows, which is also publicly available on our website at http://s2.q4cdn.com/785790092/files/doc_downloads/governance_doc/Conflict-Minerals-Policy-external-(5).pdf The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
We support sourcing components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. We are committed to complying with the SEC disclosure requirements and are working with our suppliers to perform reasonable country of origin inquiries and due diligence in determining the potential for conflict minerals in our supply chain and products.
We expect our suppliers to partner with us in our commitment to compliance and have designed our efforts to align with conflict minerals reporting rules.
Description of RCOI
Our operations use materials, such as carbon and alloy steels in various forms and components and accessories for assembly, which are available from numerous sources. We generally purchase materials and components as needed for individual contracts.
As noted above, we manufacture a variety of products for which materials included in those products may differ from year to year. These products are highly complex, typically containing thousands of parts from many suppliers throughout the world. We may purchase the same materials from multiple different suppliers and distributors. These suppliers and distributors often obtain their materials from lower tier suppliers. Accordingly, our supply chain is deep and identifying the ultimate source of materials supplied to us is difficult. We rely on our direct suppliers to work with their suppliers to provide information on the smelters and origin of the 3TG contained in components and materials supplied to us.
During the Reporting Period, our compliance efforts included both our domestic and our international locations. For each of the products (or subassemblies) that we identified as containing 3TG necessary to their functionality or production, we identified the suppliers that provided the materials comprising each of these
products. We specifically identified each supplier that provided the materials containing the 3TG that we identified, as the 3TG in these products and related supplier base was limited.
Additionally, our scoping process included removing service providers, indirect materials suppliers, and suppliers who are inactive and whom we have not made a purchase within the last year. This ensures that all suppliers surveyed provided items to B&W that were used in final products in the year 2015. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party service provider.
Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 4.01b, developed by the Electronic Industry Citizenship Coalition® and The Global e-Sustainability Initiative, the suppliers identified through the procedures above were surveyed on their sourcing of the 3TG that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TG used by those facilities.
During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked. Non-responsive suppliers were contacted a minimum of three times and then were also managed via our service provider’s Supply Chain Team through one-on-one communications. This included at least two follow ups in order to encourage their response via the CMRT.
The RCOI also included automated data validation on all of the submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and encouraged to resubmit a valid form.
Based on the RCOI, we determined that we may have some suppliers that sourced 3TG from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.
Due diligence
Design of due diligence
We have designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the "OECD Guidelines").
The large majority of the responses received provided data at the supplier company level or a division/segment level relative to the supplier, rather than at a level directly relating to a product that the supplier supplies to us, or were otherwise unable to specify the smelters or refiners used for components supplied to us. We were therefore unable to determine whether the 3TG that these suppliers reported were contained in components or parts that the suppliers supplied to us or to validate that any of these smelters or refiners are actually in our supply chain.
Due diligence performed
Establish strong company management systems
Conflict minerals policy
We established a conflict minerals policy related to our sourcing of 3TG as described in full in the “Conflict Minerals Policy” section above and posted this policy on our website at http://s2.q4cdn.com/785790092/files/doc_downloads/governance_doc/Conflict-Minerals-Policy-external-(5).pdf within the “Investor Relations” section under “Corporate Governance.” The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Internal team
We commissioned a Conflict Minerals Steering Committee comprised of individuals in management positions across the procurement, legal and finance functions. The Conflict Minerals Steering Committee is led by members of our senior management. The Conflict Minerals Steering Committee governs our conflict minerals compliance effort and is responsible for providing guidance and direction for the implementation of our conflict minerals program.
We have also taken on other management systems that include the use of a third-party vendor. Through our vendor’s tool, we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
Control systems and grievance mechanism
We do not typically have a direct relationship with smelters and refiners. However, we have controls in place designed to uphold our core values and ethical standards in all interactions with customers, vendors, suppliers, shareholders, fellow employees and others. These controls include a Code of Business Conduct that outlines expected behaviors for all employees, vendors and independent contractors. This Code of Business Conduct is publicly available on our website within the “Investor Relations” section under “Corporate Governance.” To this end, anyone can utilize our Integrity Line as detailed in our Code of Business Conduct to proactively report a violation of our Code or policies, including our conflict minerals policy and related program efforts.
Maintain records
We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of 10 years.
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 4.01b and a third-party vendor’s web-based reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.
Identify and assess risks in the supply chain
Due to the complexity of our products and the depth, breadth, and constant changes to our supply chain, it is difficult to identify sub-tier suppliers from our direct suppliers. We have relied on supplier responses to provide us with the information about the source of conflict minerals contained in the parts and components they supply to us.
Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the Supply Chain. In the software, risk is classified as High, Medium and Low. This risk rating is generated based on three scoring criteria:
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| • | This assesses whether the smelter is a member and has an associated regulated body number (Smelter CID Number is the primary method). |
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| • | Level 1 Country: Countries with known active ore production for tin or tantalum that are not identified as conflict regions or plausible countries of smuggling or export of tin or tantalum containing materials. Smelter Country is located in North or South America, Australia or Europe. |
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| • | Level 2 Country: Known or plausible countries for smuggling, export out of Level 3 countries, or transit of materials containing tin or tantalum. This currently includes Kenya, Mozambique, and South Africa. |
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| • | Level 3 Country: The Democratic Republic of the Congo ("DRC") and its nine adjoining countries as outlined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Section 1502"). These include Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. These are also commonly referred to as "covered countries" in Section 1502. |
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| • | The smelter is certified conflict-free via the Conflict-Free Sourcing Initiative ("CFSI") or the London Bullion Market Association Responsible Gold Programme. |
We also calculate supplier risk based on the chances that the supplier provides 3TG that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many companies continue to be in the middle of the process and still have “unknown” as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however
evaluating and tracking the strength of the program does meet the OECD Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:
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| 1. | Do you have a policy in place that includes DRC conflict-free sourcing? |
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| 2. | Have you implemented due diligence measures for conflict-free sourcing? |
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| 3. | Do you verify due diligence information received from your suppliers? |
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| 4. | Does your verification process include corrective action management? |
When suppliers meet or exceed the above criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
We believe that the inquiries and investigations described above represent a reasonable effort to determine the mines or locations of origin of the 3TG in our Covered Products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
Design and implement a strategy to respond to identified risks
We report our findings annually to the Conflict Minerals Steering Committee prior to the issuance of Form SD and this Report. We also report any significant due diligence findings to the Conflict Minerals Steering Committee as they arise. For example, if we find that we source 3TG that directly or indirectly finances or benefits armed groups, in the Covered Countries, B&W will assess the supplier relationship and encourage the supplier in question to establish an alternative source of 3TG that does not support such conflict. We have found no instance where it was necessary to implement risk mitigation efforts as a result of a supplier’s response to our information request.
Carry-out independent third party audit of supply chain due diligence at identified points in the supply chain
We do not typically have a direct relationship with smelters and refiners and therefore do not perform or direct audits of these entities. However, we will rely on third party assurances and certifications, for example, through the CFSI's Conflict-Free Smelter Program.
Report on supply chain due diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at http://investors.babcock.com/financial-information/sec-filings/default.aspx within the “Investor Relations” section under “SEC Filings” and is filed with the SEC. The inclusion of our website within this filing is not intended to incorporate by reference any materials other than the Form SD, Conflict Minerals Report and Conflict Minerals Policy included therein.
Results of due diligence
Survey results
As described above, B&W actively surveys our supply chain and reviews the responses against criteria developed to determine whether further engagement is required. These criteria include: untimely responses, incomplete responses and inconsistencies within the data reported in the CMRT.
As of March 31, 2016, we received responses from 43% of our 4,192 surveyed suppliers for the 2015 year.
Efforts to determine mine or location of origin
Given that we do not have established relationships with the ultimate smelters and refiners from which the 3TG in our products is sourced, we have determined that requesting our suppliers to complete the CFSI Template represents our good faith effort to determine the mines or locations of origin of 3TG in our supply chain.
Smelters and refiners
Of the suppliers surveyed, many completed the CFSI template at the company, business unit or entity level and are unable to represent that 3TG from the processing facilities they listed had actually been included in components that they supplied to us. The quality of the responses that we received from our surveyed suppliers continue to be varied. Many of the responses provided by supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners ("SORs"). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TG claimed on the CMRT are considered invalid and our third-party provider follows up on these, urging suppliers to resubmit the form and include smelter information. There are still suppliers that are unable to provide SORs used for the materials supplied to us.
For all responses that indicated a smelter, our third-party consultant compared the facilities listed to the list of smelters maintained by the CFSI. If a supplier indicated that the facility was certified as "Conflict-Free," our vendor confirmed that the name was listed by the CFSI as a certified smelter. As of April 13, 2016, we have identified 319 smelters or refiners that were reported by our suppliers via the CMRT. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix B also includes an aggregate list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and the CFSI.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 212 smelters that are certified Conflict-Free. The remaining 107 smelters listed have not yet been confirmed as Conflict-Free. We have assessed these facilities and determined that most of these are of low risk due to their geographic location. Only one listing, "Phoenix Metal Ltd" may be considered a high risk due to the facility's geographic location being in Rwanda. Phoenix Metals Ltd is currently listed on the CFSI’s "Active" smelter list. Smelters and refiners are identified as Active in the Conflict-Free Smelter Program once they submit signed Agreement for the Exchange of Confidential Information and Auditee Agreement contracts. This is the first step of the audit process. Smelters and refiners on the Active list are at various stages of the audit cycle; anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. At this time, we do not have reason to believe that Phoenix Metals Ltd sources from conflict mines.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to make any determinations regarding the 3TG included in our products during the Reporting Period or to provide additional smelter and refiner names and country of origin of the necessary 3TGs at this time. We will continue to work with our suppliers to obtain smelter information at the product level.
Steps to be taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. Our next steps may include, but are not limited to the following:
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| • | Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of our 3TG with the greatest specificity possible; |
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| • | Engage suppliers and encourage them to provide responses at the product level; |
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| • | Implement a strategy to respond to identified risk, including but not limited to, potential action to be taken against suppliers that do not respond to our requests or do not provide reasonable information to support our due diligence activities; and |
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| • | Engage any of our suppliers found to be supplying us with 3TG from sources that support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict. |
Appendix A:
The following smelters and refiners were reported by our suppliers as being in their supply chains. Facilities that have been certified as conflict-free by an internationally-recognized validation scheme for 3TG smelters and refiners are designated below in the fourth column.
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| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Gold | Advanced Chemical Company | UNITED STATES | Unknown |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | Unknown |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Unknown |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Unknown |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes |
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes |
| Gold | Asahi Pretec Corporation | JAPAN | Yes |
| Gold | Asahi Refining Canada Limited | CANADA | Yes |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Yes |
| Gold | Aurubis AG | GERMANY | Yes |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes |
| Gold | Bauer Walser AG | GERMANY | Unknown |
| Gold | Boliden AB | SWEDEN | Yes |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes |
| Gold | Caridad | MEXICO | Unknown |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes |
| Gold | Cendres + Métaux SA | SWITZERLAND | Unknown |
| Gold | Chimet S.p.A. | ITALY | Yes |
| Gold | Chugai Mining | JAPAN | Unknown |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Unknown |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Unknown |
| Gold | DODUCO GmbH | GERMANY | Yes |
| Gold | Dowa | JAPAN | Yes |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes |
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Unknown |
| Gold | Faggi Enrico S.p.A. | ITALY | Unknown |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unknown |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Unknown |
| Gold | Geib Refining Corporation | UNITED STATES | Unknown |
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| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unknown |
| Gold | Guangdong Jinding Gold Limited | CHINA | Unknown |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unknown |
| Gold | Heimerle + Meule GmbH | GERMANY | Yes |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Unknown |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Unknown |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes |
| Gold | Istanbul Gold Refinery | TURKEY | Yes |
| Gold | Japan Mint | JAPAN | Yes |
| Gold | Jiangxi Copper Company Limited | CHINA | Yes |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Unknown |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unknown |
| Gold | Kazzinc | KAZAKHSTAN | Yes |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes |
| Gold | KGHM Polska MiedŸ Spó³ka Akcyjna | POLAND | Unknown |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | Unknown |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Unknown |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Yes |
| Gold | Lingbao Gold Company Limited | CHINA | Unknown |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Unknown |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown |
| Gold | Materion | UNITED STATES | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Unknown |
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| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Gold | Metalor Technologies SA | SWITZERLAND | Yes |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes |
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes |
| Gold | Morris and Watson | NEW ZEALAND | Unknown |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | TURKEY | Yes |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Unknown |
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | Unknown |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes |
| Gold | PAMP SA | SWITZERLAND | Yes |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unknown |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes |
| Gold | PX Précinox SA | SWITZERLAND | Yes |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes |
| Gold | Republic Metals Corporation | UNITED STATES | Yes |
| Gold | Royal Canadian Mint | CANADA | Yes |
| Gold | SAAMP | FRANCE | Unknown |
| Gold | Sabin Metal Corp. | UNITED STATES | Unknown |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Unknown |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unknown |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Unknown |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes |
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes |
| Gold | So Accurate Group, Inc. | UNITED STATES | Unknown |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Unknown |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes |
| Gold | Sudan Gold Refinery | SUDAN | Unknown |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes |
| Gold | T.C.A S.p.A | ITALY | Yes |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Unknown |
| Gold | Tony Goetz NV | BELGIUM | Unknown |
| Gold | Torecom | KOREA, REPUBLIC OF | Unknown |
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes |
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes |
| Gold | Valcambi SA | SWITZERLAND | Yes |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Unknown |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | Unknown |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes |
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes |
| Tantalum | Duoluoshan | CHINA | Yes |
| Tantalum | E.S.R. Electronics | UNITED STATES | Unknown |
| Tantalum | Exotech Inc. | UNITED STATES | Yes |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | Yes |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes |
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Unknown |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes |
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes |
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes |
| Tantalum | QuantumClean | UNITED STATES | Yes |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes |
| Tantalum | Taki Chemicals | JAPAN | Yes |
| Tantalum | Telex Metals | UNITED STATES | Yes |
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes |
| Tin | Alpha | UNITED STATES | Yes |
| Tin | An Thai Minerals Company Limited | VIETNAM | Unknown |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | Unknown |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | Unknown |
| Tin | China Tin Group Co., Ltd. | CHINA | Unknown |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes |
| Tin | CV Ayi Jaya | INDONESIA | Yes |
| Tin | CV Dua Sekawan | INDONESIA | Unknown |
| Tin | CV Gita Pesona | INDONESIA | Yes |
| Tin | CV Serumpun Sebalai | INDONESIA | Yes |
| Tin | CV Tiga Sekawan | INDONESIA | Unknown |
| Tin | CV United Smelting | INDONESIA | Yes |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes |
| Tin | Dowa | JAPAN | Yes |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | Unknown |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes |
| Tin | EM Vinto | BOLIVIA | Yes |
| Tin | Estanho de Rondônia S.A. | BRAZIL | Unknown |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | Unknown |
| Tin | Fenix Metals | POLAND | Yes |
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | Unknown |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Unknown |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Unknown |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Unknown |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Unknown |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Unknown |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | Unknown |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | Unknown |
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes |
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes |
| Tin | Mineração Taboca S.A. | BRAZIL | Yes |
| Tin | Minsur | PERU | Yes |
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Unknown |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | Unknown |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes |
| Tin | Phoenix Metal Ltd. | RWANDA | Unknown |
| Tin | PT Alam Lestari Kencana | INDONESIA | Unknown |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes |
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes |
| Tin | PT Bangka Kudai Tin | INDONESIA | Unknown |
| Tin | PT Bangka Prima Tin | INDONESIA | Yes |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | Unknown |
| Tin | PT Bangka Tin Industry | INDONESIA | Yes |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes |
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes |
| Tin | PT Bukit Timah | INDONESIA | Yes |
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes |
| Tin | PT DS Jaya Abadi | INDONESIA | Yes |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes |
| Tin | PT Fang Di MulTindo | INDONESIA | Unknown |
| Tin | PT Inti Stania Prima | INDONESIA | Yes |
| Tin | PT Justindo | INDONESIA | Yes |
| Tin | PT Karimun Mining | INDONESIA | Unknown |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Unknown |
| Tin | PT Mitra Stania Prima | INDONESIA | Yes |
| Tin | PT Panca Mega Persada | INDONESIA | Yes |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | Unknown |
| Tin | PT Prima Timah Utama | INDONESIA | Yes |
| Tin | PT Refined Bangka Tin | INDONESIA | Yes |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes |
| Tin | PT Seirama Tin Investment | INDONESIA | Unknown |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes |
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes |
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes |
| Tin | PT Tirus Putra Mandiri | INDONESIA | Unknown |
| Tin | PT Tommy Utama | INDONESIA | Yes |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tin | Rui Da Hung | TAIWAN | Yes |
| Tin | Soft Metais Ltda. | BRAZIL | Yes |
| Tin | Thaisarco | THAILAND | Yes |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | Unknown |
| Tin | VQB Mineral and Trading Group JSC | VIETNAM | Yes |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes |
| Tungsten | ACL Metais Eireli | BRAZIL | Unknown |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Unknown |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | Unknown |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Unknown |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | H.C. Starck GmbH | GERMANY | Yes |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Unknown |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | Unknown |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Unknown |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Unknown |
| Tungsten | Kennametal Fallon | UNITED STATES | Unknown |
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Unknown |
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Yes |
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Unknown |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | Unknown |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM | Unknown |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Yes |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Yes |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Unknown |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
|
| | | |
| METAL | SMELTER / REFINER NAME | FACILITY LOCATION | CONFLICT FREE? |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
Appendix B:
Countries of origin include:
|
| | |
| UNITED STATES | PHILIPPINES | NEW ZEALAND |
| JAPAN | SWEDEN | AUSTRIA |
| KAZAKHSTAN | MEXICO | INDONESIA |
| UNITED ARAB EMIRATES | ITALY | SOUTH AFRICA |
| GERMANY | KOREA, REPUBLIC OF | FRANCE |
| UZBEKISTAN | CHINA | NETHERLANDS |
| BRAZIL | ZIMBABWE | SPAIN |
| SWITZERLAND | RUSSIAN FEDERATION | TAIWAN |
| CANADA | POLAND | SUDAN |
| UNITED STATES | KYRGYZSTAN | BELGIUM |
| TURKEY | SAUDI ARABIA | THAILAND |
| VIETNAM | MALAYSIA | AUSTRALIA |
| BOLIVIA | SINGAPORE | UNITED KINGDOM |
| PERU | INDIA | ESTONIA |
| RWANDA | | |
