Delphi Technologies PLC
Conflict Minerals Report
For the Year Ended December 31, 2019
Introduction & Background
This Conflict Minerals Report (“CMR”) for the year ended December 31, 2019 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 whose manufactured products 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 the Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”).
This report has been prepared by management of Delphi Technologies PLC (herein referred to as “Delphi,” the “Company,” “we,” “us” or “our”). The information includes the activities of all consolidated subsidiaries in which Delphi holds a controlling financial or management interest. It does not include the activities of non-controlled affiliates that are not required to be consolidated.
Executive Summary of the 2019 Conflict Minerals Program
In order to determine the sources of 3TG in its supply chain, Delphi performed a Reasonable Country of Origin Inquiry (“RCOI”) by surveying a significant portion of our supply base for 3TG use. As a result of these survey procedures, Delphi identified 300 smelters and refineries (herein collectively referred to as “smelters”). Of these 300 smelters, 42 were identified as sourcing, or we had a reason to believe they may be sourcing, from the Covered Countries. We then exercised due diligence procedures over these 42 smelters, and as a result identified that 34 of these 42 smelters have been audited and recognized as conformant with the Responsible Minerals Assurance Process (“RMAP”). The remaining eight smelters were subject to Delphi’s risk mitigation process according to the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas, and as a result, Delphi found no reason to believe that seven of these eight smelters directly or indirectly financed or benefited armed groups in the Covered Countries. Delphi identified some evidence that the remaining smelter, the African Gold Refinery, may be directly or indirectly financing or benefiting armed groups in the Covered Countries. Delphi has initiated action with our suppliers for the removal of all eight of these smelters from our supply chain
I. Company Overview
Delphi is a leader in the development, design and manufacture of vehicle propulsion systems that optimize engine performance, increase vehicle efficiency, reduce emissions, improve driving performance, and support increasing electrification of vehicles. We are a global supplier to original equipment manufacturers (“OEMs”) of both light vehicles (passenger cars, trucks, vans
and sport-utility vehicles) and commercial vehicles (light-duty, medium-duty and heavy-duty trucks; commercial vans; buses and off-highway vehicles). In addition, we manufacture and sell our products and provide value added services to leading aftermarket companies, including independent retailers and wholesale distributors. As of December 31, 2019, we operated 21 manufacturing facilities and 20 technical centers, with a presence in 24 countries.
Products
As of December 31, 2019, our business operated as four segments, grouped on the basis of similar product, market and operating factors:
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| • | Fuel Injection Systems - This segment includes gasoline and diesel fuel injection components and systems. Our gasoline fuel injection portfolio includes a full suite of fuel injection technologies - including pumps, injectors, fuel rail assemblies and complete systems - that deliver greater efficiency for traditional and hybrid vehicles with gasoline combustion engines. The Company’s Gasoline Direct Injection (“GDi”) technology provides high-precision fuel delivery for optimized combustion, which lowers emissions and improves fuel economy. Our diesel fuel injection systems portfolio provides enhanced engine performance. The Company’s common rail fuel injection system is the core technology for both on and off-highway commercial and light vehicle applications. |
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| • | Powertrain Products - This segment includes an array of highly engineered products for traditional combustion and hybrid electric vehicles, including variable valvetrain, smart remote actuators, powertrain sensors, ignition products, canisters, and fuel handling products. These products complement and enhance the efficiency improvements delivered by our fuel injection systems technologies. |
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| • | Electrification & Electronics - Our electronics portfolio consists of engine and transmission control modules and power electronics. The control modules, containing as much as one million lines of software code, are key components that enable the integration and operation of powertrain products throughout the vehicle. As electrification increases, our proprietary solutions - including supervisory controllers, software, DC/DC converters and inverters - provide better efficiency, reduced weight and lower cost for our OEM customers, while also making these and other components easier to integrate. Manufacturers are also choosing to combine power electronic functionality into one unit, enabling more effective packaging at a lower total cost while increasing Delphi Technologies’ content per vehicle. |
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| • | Aftermarket - Through this segment we sell products and services to independent aftermarket customers and original equipment service customers. Our aftermarket product portfolio includes a wide range of solutions covering the fuel injection, electronics and engine management, maintenance, and test equipment and vehicle diagnostics categories. |
Following completion of our due diligence measures, as described below, it was determined that, like many of our peers in the automotive industry, Delphi’s products contain 3TG materials. Delphi considers these 3TG materials necessary to the functionality or production of a significant portion of our manufactured products in all of our operating segments. Delphi has designed and implemented a Conflict Minerals process, including performance of due diligence measures, to be consistent, in all material respects, 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: Third Edition, including the related supplements on tantalum, tin, tungsten and gold (the “OECD Guidance”).
II. Reasonable Country of Origin Inquiry
We procure our raw materials and components from a variety of suppliers around the world. We rely on our direct suppliers to provide information on the source of the 3TG materials contained in components and materials supplied to us - including sources of 3TG that are supplied to them from upstream suppliers.
In order to understand the sources of 3TG in our supply chain, we performed an RCOI. Delphi’s RCOI process involved two stages: Supplier RCOI, which was designed and performed in accordance with Step 2A of the OECD Guidance, and Smelter RCOI, which was designed and performed in accordance with Steps 2B, C, and D of the OECD Guidance.
Supplier RCOI
Delphi designed its Supplier RCOI process to identify, to the best of its efforts, the smelters of 3TG within Delphi’s supply chain in accordance with Step 2A of the OECD Guidance. Delphi conducted a good faith, risk-based applicability assessment of its supply base to identify those suppliers that were reasonably believed to supply products or components to us that may contain 3TG from one or more of the Covered Countries. Delphi identified the suppliers based on information in its material data system, including the International Material Data System (“IMDS”), assessments by Delphi purchasing and materials personnel and prior year supplier CMRT submissions. Delphi’s supplier RCOI process included surveying the identified relevant suppliers (which represented 393 suppliers and/or original manufacturers that supply parts and materials for products manufactured by Delphi that we believe may contain 3TG). Delphi’s 2019 RCOI process was designed to include substantially all of the parts and materials necessary to the functionality or production of products manufactured by Delphi in 2019. Delphi did not include suppliers of indirect material, such as packaging or office supplies, or providers of services, in its supplier survey.
These relevant suppliers and original manufacturers were contacted, provided with Delphi’s Conflict Minerals policy, and requested to disclose to us the sources of 3TG materials used in the products sold to us, including smelter information, via the Conflict Minerals Reporting Template (“CMRT”) developed by the Responsible Minerals Initiative (“RMI”). We reviewed all supplier responses for completeness and accuracy. For suppliers that did not provide adequate responses, where additional follow-up was needed based on the Company’s internal risk assessment
methodology, or if responses were not provided in a timely manner, we actively solicited clarifications and responses.
Our 2019 RCOI and supplier response results represented approximately 95% of the Company’s total Annual Purchase Value (“APV”) from the relevant suppliers. After review of these responses, Delphi consolidated the supplier responses into a single list of unique smelter names which met the definition of a smelter under one of three industry recognized audit protocols. We then reviewed this listing of smelters and compared it to the RMI list of known smelters as well as industry peers in order to determine if we had identified reasonably all of the smelters in our supply chain. As a result of the supplier RCOI process, 300 smelters of 3TG were identified by our suppliers.
The large majority of the CMRT responses received from our suppliers provided data to us at a total company level, and our suppliers were unable to specify the smelters or refiners used for the specific components supplied to us during the reporting period. We are therefore unable to determine whether the 3TGs reported by our suppliers were contained in components or parts supplied to us during the reporting period. We are also unable to verify that all of the 3TG smelters that our suppliers identified were part of our supply chain. Based on the information provided by our suppliers, we made a reasonable good faith effort to collect and evaluate the information concerning 3TG smelters in our supply chain.
Smelter RCOI
Delphi assessed the country of origin information for the 300 smelters identified by our suppliers, and determined that 42 of these smelters either source, or Delphi had a reason to believe they may source, 3TG from the Covered Countries. Due to the overlap between smelter RCOI and smelter due diligence, our smelter RCOI process is summarized below in the Due Diligence section of this report.
III. Due Diligence Process
Establishment of Strong Company Management Systems (OECD Step 1)
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| • | Company Policies (1A) - Delphi has adopted a Conflict Minerals Policy which is publicly available at https://delphi.portal.covisint.com/documents/107627/21076351/DelphiTechnologiesConflictMineralsPolicy.pdf/b00e7020-bbd2-4bec-8998-f8caf27dbac1. Delphi communicated its policy directly to its suppliers as part of the RCOI process, as further described below. |
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| • | Internal Management Team (1B) - We maintain a cross-functional Conflict Minerals Team to support Delphi’s supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program, including compliance activities associated with the Rule. The Conflict Minerals Team periodically reports the status of Delphi’s Conflict Minerals program to a Conflict Minerals Steering Committee comprised of designated senior management members, including the Senior Vice President, General Counsel, Secretary and Chief Compliance Officer and the Vice President of Global Purchasing. |
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| • | System of Supply Chain Controls and Transparency (1C) - We established a system of controls over the Company’s mineral supply chain, including the implementation of a process to collect information to perform the RCOI and due diligence procedures described below, as well as a risk assessment methodology designed to define, identify, mitigate and manage risks. Should a risk arise, it would be reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee. |
Delphi supports an industry-wide approach to addressing social responsibility matters regarding Conflict Minerals. During the 2019 reporting period, Delphi was an active member in the Automotive Industry Action Group (“AIAG”).
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| • | Supplier Engagement (1D) - Due to our size and the nature of our products, and the corresponding size and depth of our supply chain, it is difficult to identify actors upstream from our direct suppliers. We rely on our suppliers to provide us with information concerning the source and chain of custody of 3TG contained in the products and components they supply. Many of our suppliers are also subject to the Rule, and they rely on information provided by their upstream suppliers. Our standard global contract terms and conditions require suppliers to provide information with respect to the origin of their products supplied to Delphi. We also communicated with suppliers regarding our Conflict Minerals program, as detailed in this Conflict Minerals Report, which included direct engagement with our suppliers to collect required supplier and smelter RCOI and due diligence data, as further described below. This engagement included providing training to our suppliers on our Conflict Minerals program, if such assistance was requested by a supplier. We continue to maintain and communicate to our suppliers a dedicated email address (CM@Delphi.com) to facilitate supplier communication with us regarding Conflict Minerals. |
As a downstream entity, we drive responsible sourcing through our supply chain by exercising due diligence over our suppliers’ sourcing of raw materials in their upstream supply chains. We mitigate risks associated with the sourcing of 3TGs by working with our suppliers to identify 3TG smelters and refiners and encouraging those facilities to become RMAP Conformant. We also support broader industry efforts to promote responsible mining and sourcing, as further described above.
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| • | Grievance Mechanism (1E) - We have grievance mechanisms through which our employees and suppliers can report suspected or potential violations of our policies, laws or general ethics or compliance concerns. We maintain an e-mail address (CM@Delphi.com) for suppliers to ask questions, voice concerns and report violations with respect to our Conflict Minerals program. Delphi also maintains a reporting system that allows employees and others to ask questions, voice concerns and report violations with respect to Delphi policies confidentially and anonymously. |
Identification and Assessment of Risks in the Supply Chain (OECD Step 2)
As described in the Reasonable Country of Origin section above, we surveyed our supply base to identify the smelters in their supply chain, as well as the country of origin, source and chain of custody of 3TGs in order to identify each of the smelters that placed conflict minerals into our supply chain, which we believed would facilitate our ability to identify the source and chain of custody of the conflict minerals contained in our products.
Design and Implement a Strategy to Respond to Risks (OECD Step 3)
In response to the risk assessment described in the foregoing section, Delphi has an approved risk management process through which the conflict minerals program is implemented, managed and monitored. Delphi performs risk mitigation on any high-risk smelter (smelters that are identified as sourcing, or believed to be sourcing, from the Covered Countries) that is not recognized as RMAP Conformant. Delphi’s risk mitigation process was designed in accordance with Step 3B of the OECD Guidance and is reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance. If there is reason to believe the smelters subject to Delphi’s risk mitigation process were directly or indirectly financing or benefiting armed groups in the Covered Countries, Delphi would initiate action with our suppliers for the removal of this smelter from our supply base, which is consistent with Step 3B of the OECD Guidance and helps prevent unnecessary boycotts of the Covered Countries.
Third Party Audit of Supply Chain Due Diligence (OECD Step 4)
Delphi utilizes a third party conflict minerals service which relies on the publicly available list of RMAP conformant smelters published by the RMI.
Annual Reporting on Supply Chain Due Diligence (OECD Step 5)
Delphi’s Form SD and CMR are filed annually with the SEC, and a copy of the CMR is publicly available on the Company’s website in the Financial Information section of the Investors page at http://ir.delphi.com.
IV. Due Diligence Performance and Results
Delphi exercised due diligence on the source and chain of custody of all 3TGs that Delphi identified as sourced, or had reason to believe may have been sourced, from the Covered Countries in accordance with a nationally or internationally recognized due diligence framework.
Delphi designed its smelter RCOI and due diligence processes in accordance with the applicable sections of Steps 2, 3 and 4 of the OECD Guidance. Based on its assessment of the survey responses received from suppliers as part of its RCOI process, Delphi performed smelter RCOI and due diligence measures as described below in a manner consistent with the OECD Guidance on the smelters that were identified by our suppliers as potential sources of 3TG in our products.
For each 3TG smelter that was identified by our suppliers as being in Delphi’s supply chain, Delphi, through its third party conflict minerals service, attempted to directly engage the smelter to determine whether or not the smelter sourced from the Covered Countries. For smelters that did not respond to direct engagement, Delphi reviewed publicly available information to determine if there was any reason to believe that the smelter may have sourced 3TG from the Covered Countries during the reporting period. This information included the most recent report by the United Nations (“U.N.”) Group of Experts on the Democratic Republic of the Congo, publications by non-governmental organizations the Enough Project, Global Witness, Southern Africa Resource Watch and Radio Okapi (the U.N. funded news organization in the conflict region of the DRC) and a search of other publicly available information. For smelters that declared directly (e.g. through correspondence, publicly available conflict minerals policy, or information available on their website), or through their relevant industry association, that they did not source from the Covered Countries, and were not recognized as RMAP Conformant, Delphi reviewed the publicly available information sources listed above to determine if there was any contrary evidence to the smelter’s declaration.
Due Diligence Results
As a result of these procedures, 42 of the 300 smelters identified by our suppliers either source, or Delphi had reason to believe they may source, 3TG from the Covered Countries. The countries of origin of 3TG from these 42 smelters may include the DRC, Rwanda, Burundi, Tanzania, and Uganda.
Of these 42 smelters, 34 smelters were conformant with the RMAP and were accordingly listed on the RMI’s website as RMAP Conformant, meaning that the smelters have been determined to be conformant with the RMAP’s, or an equivalent, independent third-party audit program.
The following table categorizes the smelters identified by our suppliers as being in our supply chain by 3TG mineral, those identified as sourcing from the Covered Countries and RMAP status:
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| | Covered Country Sourced | | Non-Covered Country Sourced | | |
| | RMAP Conformant | | RMAP Active or TI-CMC Member | | Not RMAP Conformant | | Total | | RMAP Conformant | | RMAP Active or TI-CMC Member | | Not RMAP Conformant | | Total | | Total Smelters |
| Gold | 8 | | — | | 8 | | 16 | | 88 | | 1 | | 52 | | 141 | | 157 |
| Tantalum | 19 | | — | | — | | 19 | | 17 | | 1 | | 2 | | 20 | | 39 |
| Tin | 2 | | — | | — | | 2 | | 35 | | — | | 20 | | 55 | | 57 |
| Tungsten | 5 | | — | | — | | 5 | | 25 | | 1 | | 16 | | 42 | | 47 |
| Total | 34 | | — | | 8 | | 42 | | 165 | | 3 | | 90 | | 258 | | 300 |
All compliance status information in the above table is as of March 4, 2020, and is based solely on information made publicly available by the RMI and listed on the RMI website, without independent verification by us. “Conformant” means that the smelter was listed as conformant with the RMAP assessment protocols. “Active” means that the smelter has committed to undergo an RMAP audit or is participating in one of the cross-recognized certification programs, such as members of the Tungsten Industry-Conflict Minerals Council (“TI-CMC”). Smelters not listed as Conformant or Active are classified as “Not RMAP Conformant”. Sourcing status information is based on information received directly from the smelters, information received through the RMAP and/or the other public information sources listed above. Included in “Covered Country Sourced” are smelters which Delphi had reason to believe may source from the Covered Countries and included in “Non-Covered Country Sourced” are smelters which Delphi had no reason to believe source from the Covered Countries.
The mines used by these smelters are not publicly available and were not disclosed by these smelters. Through experience gained from participating in the RMI, we have concluded that requiring our suppliers to complete the CMRT and conducting the due diligence process described above represents the most reasonable best effort we can make at this time to identify the mines and countries of origin of 3TGs contained in our products with the greatest possible specificity.
Risk Mitigation
Delphi conducted risk mitigation on the smelters that were identified as sourcing, or believed to be sourcing, from the Covered Countries and that were not recognized as RMAP Conformant. Delphi’s risk mitigation was designed in accordance with Step 3B of the OECD Guidance and was reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance.
Delphi conducted risk mitigation on eight gold smelters that Delphi had reason to believe may source from the Covered Countries. Based on the information provided by our suppliers, the gold provided by these smelters may have been included in products manufactured by the Company in 2019.
Delphi’s risk mitigation process included performing 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. This additional due diligence included further review of the publicly available information sources noted above in order to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries, verifying with internal stakeholders and relevant suppliers whether 3TGs from the smelter were actually in Delphi’s supply chain in the 2019 reporting period and direct engagement with each high risk smelter to verify risk and to encourage the smelter to become RMAP Conformant. As a result of this process, Delphi found no reason to believe seven of eight high risk gold smelters directly or indirectly financed or benefited armed groups in the Covered Countries. Delphi identified some information that the African Gold Refinery may be directly or indirectly financing or benefiting armed groups in the Covered Countries. Delphi has initiated action with our suppliers for the removal of all eight of these smelters from our supply base, which is consistent with Step 3B of the OECD Guidance and helps prevent unnecessary boycotts of the Covered Countries.
Continuous Improvement of Supply Chain Due Diligence
The activities undertaken by Delphi as described in this report have helped to mitigate the risk that the 3TG materials necessary to our products benefited armed groups in the Covered Countries. Going forward, we intend to take the following steps to improve our due diligence process and further mitigate the risk that the 3TG materials necessary to our products benefit armed groups:
1) Continue to strengthen our engagement with our suppliers regarding Conflict Minerals, including requiring CMRT information from key suppliers and any new supplier;
2) Continue to drive our suppliers to obtain current, accurate, and complete information from their supply chain about their smelters and refiners of Conflict Minerals; and
3) Encourage smelters identified as part of our supply chain which are sourcing, or believed to be sourcing, from the Covered Countries to be audited and certified to a protocol recognized by the RMAP, either directly or indirectly through suppliers and/or relevant industry partnerships, including follow-up in 2020 on smelters that required risk mitigation in 2019.
Additional Risk Factors
The statements within this CMR are based on the RCOI process and due diligence performed in good faith by Delphi, and are based on the information available at the time. A number of factors could introduce errors or otherwise affect the statements made within. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions in information provided by suppliers, errors or omissions in information provided by smelters, confusion by suppliers over requirements of the SEC final rule, gaps in supplier education and knowledge, errors or omissions in public information, translation of public data, oversights or errors in conflict-free smelter audits, Covered Country-sourced materials being declared secondary
materials, illegally tagged conflict minerals from Covered Countries being introduced into the supply chain, and smuggling of Conflict Minerals from Covered Countries to countries beyond the Covered Countries.
Appendix to the 2019 Conflict Minerals Report of Delphi Technologies PLC Processing Facilities Identified in Supplier CMRT Responses
The following table lists the name and 3TG of the processing facilities identified in supplier CMRT responses to Delphi as part of its 2019 reasonable country of origin inquiry as described in the CMR. All information in the following table is based on information made publicly available by the RMI and listed on the RMI website as of March 4, 2020.
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| 3TG Metal | Standard Smelter Name | Smelter ID |
| Gold | 8853 S.p.A. | CID002763 |
| Gold | Abington Reldan Metals, LLC | CID002708 |
| Gold | Advanced Chemical Company | CID000015 |
| Gold | African Gold Refinery | CID003185 |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 |
| Gold | Argor-Heraeus S.A. | CID000077 |
| Gold | Asahi Pretec Corp. | CID000082 |
| Gold | Asahi Refining Canada Ltd. | CID000924 |
| Gold | Asahi Refining USA Inc. | CID000920 |
| Gold | Asaka Riken Co., Ltd. | CID000090 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 |
| Gold | AU Traders and Refiners | CID002850 |
| Gold | Aurubis AG | CID000113 |
| Gold | Bangalore Refinery | CID002863 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 |
| Gold | Boliden AB | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | CID000176 |
| Gold | Caridad | CID000180 |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 |
| Gold | Cendres + Métaux S.A. | CID000189 |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 |
| Gold | Chimet S.p.A. | CID000233 |
| Gold | Chugai Mining | CID000264 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 |
| Gold | Dijllah Gold Refinery FZC | CID003348 |
| Gold | DODUCO Contacts and Refining GmbH | CID000362 |
| Gold | Dowa | CID000401 |
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| Gold | DS PRETECH Co., Ltd. | CID003195 |
| Gold | DSC (Do Sung Corporation) | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 |
| Gold | Emirates Gold DMCC | CID002561 |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 |
| Gold | Fujairah Gold FZC | CID002584 |
| Gold | Geib Refining Corporation | CID002459 |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CID002312 |
| Gold | Gujarat Gold Centre | CID002852 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 |
| Gold | HeeSung Metal Ltd. | CID000689 |
| Gold | Heimerle + Meule GmbH | CID000694 |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | CID002519 |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 |
| Gold | HwaSeong CJ Co., Ltd. | CID000778 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 |
| Gold | International Precious Metal Refiners | CID002562 |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 |
| Gold | Istanbul Gold Refinery | CID000814 |
| Gold | Italpreziosi | CID002765 |
| Gold | Japan Mint | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 |
| Gold | JSC Novosibirsk Refinery | CID000493 |
| Gold | JSC Uralelectromed | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 |
| Gold | Kaloti Precious Metals | CID002563 |
| Gold | Kazakhmys Smelting LLC | CID000956 |
| Gold | Kazzinc | CID000957 |
| Gold | Kennecott Utah Copper LLC | CID000969 |
| Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 |
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| Gold | Korea Zinc Co., Ltd. | CID002605 |
| Gold | Kyrgyzaltyn JSC | CID001029 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 |
| Gold | L’azurde Company For Jewelry | CID001032 |
| Gold | L’Orfebre S.A. | CID002762 |
| Gold | Lingbao Gold Co., Ltd. | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 |
| Gold | LS-NIKKO Copper Inc. | CID001078 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 |
| Gold | Marsam Metals | CID002606 |
| Gold | Materion | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 |
| Gold | Metalor Technologies S.A. | CID001153 |
| Gold | Metalor USA Refining Corporation | CID001157 |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 |
| Gold | Mitsubishi Materials Corporation | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 |
| Gold | Modeltech Sdn Bhd | CID002857 |
| Gold | Morris and Watson | CID002282 |
| Gold | Moscow Special Alloys Processing Plant | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 |
| Gold | NH Recytech Company | CID003189 |
| Gold | Nihon Material Co., Ltd. | CID001259 |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | CID001326 |
| Gold | PAMP S.A. | CID001352 |
| Gold | Pease & Curren | CID002872 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 |
| Gold | Planta Recuperadora de Metales SpA | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 |
| Gold | PX Précinox S.A. | CID001498 |
| Gold | QG Refining, LLC | CID003324 |
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| Gold | Rand Refinery (Pty) Ltd. | CID001512 |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 |
| Gold | REMONDIS PMR B.V. | CID002582 |
| Gold | Royal Canadian Mint | CID001534 |
| Gold | SAAMP | CID002761 |
| Gold | Sabin Metal Corp. | CID001546 |
| Gold | Safimet S.p.A | CID002973 |
| Gold | SAFINA A.S. | CID002290 |
| Gold | Sai Refinery | CID002853 |
| Gold | Samduck Precious Metals | CID001555 |
| Gold | SAMWON Metals Corp. | CID001562 |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 |
| Gold | SEMPSA Joyería Platería S.A. | CID001585 |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 |
| Gold | Singway Technology Co., Ltd. | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | CID001761 |
| Gold | Sovereign Metals | CID003383 |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 |
| Gold | Sudan Gold Refinery | CID002567 |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 |
| Gold | T.C.A S.p.A | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 |
| Gold | Tony Goetz NV | CID002587 |
| Gold | TOO Tau-Ken-Altyn | CID002615 |
| Gold | Torecom | CID001955 |
| Gold | Umicore Brasil Ltda. | CID001977 |
| Gold | Umicore Precious Metals Thailand | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 |
| Gold | United Precious Metal Refining, Inc. | CID001993 |
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| | |
| Gold | Valcambi S.A. | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | CID002778 |
| Gold | Yamakin Co., Ltd. | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | CID002129 |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 |
| Gold | Zhongkuang Gold Industry Co., Ltd. | CID002214 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 |
| Tantalum | Asaka Riken Co., Ltd. | CID000092 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 |
| Tantalum | CP Metals Inc. | CID003402 |
| Tantalum | D Block Metals, LLC | CID002504 |
| Tantalum | Exotech Inc. | CID000456 |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 |
| Tantalum | Global Advanced Metals Aizu | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | CID002557 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 |
| Tantalum | H.C. Starck Inc. | CID002548 |
| Tantalum | H.C. Starck Ltd. | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 |
| Tantalum | KEMET Blue Metals | CID002539 |
| Tantalum | KEMET Blue Powder | CID002568 |
| Tantalum | LSM Brasil S.A. | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 |
| Tantalum | Mineração Taboca S.A. | CID001175 |
| Tantalum | Mitsui Mining & Smelting | CID001192 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 |
| Tantalum | NPM Silmet AS | CID001200 |
| Tantalum | Power Resources Ltd. | CID002847 |
| Tantalum | QuantumClean | CID001508 |
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| | |
| Tantalum | Resind Indústria e Comércio Ltda. | CID002707 |
| Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 |
| Tantalum | Telex Metals | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 |
| Tin | Alpha | CID000292 |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 |
| Tin | China Tin Group Co., Ltd. | CID001070 |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 |
| Tin | Dowa | CID000402 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 |
| Tin | EM Vinto | CID000438 |
| Tin | Estanho de Rondônia S.A. | CID000448 |
| Tin | Fenix Metals | CID000468 |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CID002848 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CID002849 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 |
| Tin | Ma’anshan Weitai Tin Co., Ltd. | CID003379 |
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 |
| Tin | Melt Metais e Ligas S.A. | CID002500 |
| Tin | Metallic Resources, Inc. | CID001142 |
| Tin | Metallo Belgium N.V. | CID002773 |
| Tin | Metallo Spain S.L.U. | CID002774 |
| Tin | Mineração Taboca S.A. | CID001173 |
| Tin | Minsur | CID001182 |
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| | |
| Tin | Mitsubishi Materials Corporation | CID001191 |
| Tin | Modeltech Sdn Bhd | CID002858 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 |
| Tin | Operaciones Metalúrgicas S.A. | CID001337 |
| Tin | Pongpipat Company Limited | CID003208 |
| Tin | Precious Minerals and Smelting Limited | CID003409 |
| Tin | PT Artha Cipta Langgeng | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 |
| Tin | PT Mitra Stania Prima | CID001453 |
| Tin | PT Refined Bangka Tin | CID001460 |
| Tin | PT Timah Tbk Kundur | CID001477 |
| Tin | PT Timah Tbk Mentok | CID001482 |
| Tin | Resind Indústria e Comércio Ltda. | CID002706 |
| Tin | Rui Da Hung | CID001539 |
| Tin | Soft Metais Ltda. | CID001758 |
| Tin | Super Ligas | CID002756 |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | CID002834 |
| Tin | Thaisarco | CID001898 |
| Tin | Tin Technology & Refining | CID003325 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 |
| Tin | Yunnan Tin Company Limited | CID002180 |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 |
| Tungsten | ACL Metais Eireli | CID002833 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CID003401 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CID002645 |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 |
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| | |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CID003182 |
| Tungsten | Hydrometallurg, JSC | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CID002647 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 |
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CID002313 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | CID003408 |
| Tungsten | Kennametal Fallon | CID000966 |
| Tungsten | Kennametal Huntsville | CID000105 |
| Tungsten | KGETS Co., Ltd. | CID003388 |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | CID002543 |
| Tungsten | Moliren Ltd. | CID002845 |
| Tungsten | Niagara Refining LLC | CID002589 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 |
| Tungsten | Unecha Refractory Metals Plant | CID002724 |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 |
| Tungsten | Woltech Korea Co., Ltd. | CID002843 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 |
