Exhibit 1.01
Conflict Minerals Report of FLIR Systems, Inc.
for the Year Ending December 31, 2018
The following should be read in conjunction with the definitions contained in the Securities and Exchange Commission (“SEC”) instructions to Form SD and related rules.
This report for the year ended December 31, 2018 is presented to comply with Rule13p-1 (the “Rule”) under the Securities Exchange Act of 1934 (the “Exchange Act”). The Rule was adopted by the SEC to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The term “conflict minerals” is defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten. For the purposes of this report, tin, tungsten, tantalum and gold will collectively be referred to herein as the 3TGs. The Rule requires each SEC registrant to provide certain disclosures about 3TGs which are necessary to the functionality or production of products manufactured by such registrant.
Description of Company
FLIR Systems, Inc. (“FLIR,” the “Company,” “we,” “us,” or “our”) is a world leader in developing technologies that enhance perception and awareness. We design, develop, market, and distribute solutions that detect people, objects and substances that may not be perceived by human senses and improve the way people interact with the world around them. We bring these innovative technologies—which include thermal imaging systems, visible-light imaging systems, locater systems, measurement and diagnostic systems, and advanced threat-detection solutions—into daily life.
Founded in 1978, FLIR is a pioneer in advanced sensors and integrated sensor systems that enable the gathering, measurement, and analysis of critical information through a wide variety of applications in commercial, industrial, government, and consumer markets worldwide. We offer the broadest range of infrared, also known as thermal, imaging solutions in the world, with products that range fromconsumer-use thermal camera smartphone accessories to highly advanced aircraft-mounted imaging systems for military and search and rescue applications, with products in between serving a multitude of markets, customers, and applications.
Products Overview
We offer a wide array of sensor products, including infrared imaging cameras and systems, detector cores, CBRNE threat detectors, test and measurement instruments, radars, maritime electronics, and related products and solutions. We have evolved our product suite over time, expanding our reach into markets that are adjacent to thermal imaging, with the intent of expanding the adoption and channel development for thermal imaging technology. Examples of this evolution include our entrance into the visible-image security and surveillance market, the maritime electronics market, and the traffic monitoring and signal control market. We intend to continue this evolution as we continue to lower the cost of advanced sensing products. As the cost to own thermal technology continues to decline, the application of these sensors is expanding beyond imaging to areas such as data acquisition where thermal sensors can provide important data that can be used for a wide variety of applications. For further information about our products, please see Item 1 of our Annual Report onForm 10-K for the year ending December 31, 2018.
We conducted an analysis of our products and found that 3TGs can be found in the products described above. Therefore, substantially all the products that we manufacture are subject to the reporting obligations of the Rule.
Due Diligence Process
Reasonable Country of Origin Inquiry
With respect to 3TGs necessary to the functionality or production of products manufactured by us, or contracted by us to be manufactured, and required to be reported on Form SD for 2018, we conducted in good faith a country of origin inquiry that we believe was reasonably designed to determine whether any of the 3TGs originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively the “Covered Countries”) or were from recycled or scrap sources.
First, we identified all component suppliers and analyzed the bills of materials to identify any 3TGs that may be contained in the components provided by these suppliers. To achieve greater control and transparency over our supply chain and help identify the risk that our products contain any 3TGs that may be financing or benefiting armed groups in any Covered Country, we utilized a reporting template, the Conflict Minerals Reporting Template version 5.11 or higher (“CMRT”), and data gathered by
the Responsible Minerals Initiative (“RMI”) of the Responsible Business Alliance (“RBA”) and the GlobalE-Sustainability Initiative (“GeSI”). We identified and compiled a list of our suppliers from whom we needed to request information about their sourcing of 3TGs, and we requested that such identified suppliers provide us with information regarding their supply chain using the CMRT.
To gain insight into the country of origin, chain of custody, and whether they directly or indirectly finance or benefit armed groups in any Covered Country (the “Conflict Status”) of our 3TGs in our products, we relied primarily on the data reported by suppliers via the CMRT and the data from the Responsible Minerals Assurance Process (“RMAP”). RMAP is a voluntary program in which an independent third party evaluates smelter and refiner procurement activities and determines whether the smelter or refiner demonstrated that all the materials it processed originated from conflict-free sources. Pursuant to our Conflict Smelter Policy and our Supplier Code of Conduct, we require all suppliers to complete a CMRT and disclose the smelter and refiner facilities that are linked to the development of their parts and products.
Based on the information we received from our suppliers (as described below), we have reason to believe that some of the 3TGs contained in our products may have come from recycled or scrap sources.
To the extent we determined from our suppliers’ responses that the 3TGs originated (or may have originated) in the Covered Countries and may not have been from recycled or scrap sources, we exercised further due diligence as required by the Rule. In exercising due diligence, we were not able to determine whether the 3TGs that originated (or may have originated) in the Covered Countries directly or indirectly financed or benefitted armed groups.
Despite our good faith effort to determine the countries of origin and chain of custody of the 3TGs contained in our products, we have not been able to determine the exact country of origin of all of the 3TGs used in our in scope products. For the 3TGs whose country of origin has become known to us, we have been unable to determine whether such 3TGs directly or indirectly financed or benefited armed groups in the Covered Countries.
Our ability to determine the origin and chain of custody of 3TGs and the Conflict Status is limited. Our supply chain for 3TGs is complex. In most cases, we are several steps removed from the mining and smelting or refining of 3TGs. Out of necessity, we depend on information from suppliers that may themselves purchase 3TGs from persons other than the miner, smelter or refiner of 3TGs.
Due to the breadth and complexity of our products and respective supply chain, it will take time for many of our suppliers to verify the origin of all the 3TGs they procure. By using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard RMI/RMAP program and continuing our outreach efforts with suppliers, we hope to enhance the transparency within our supply chain regarding 3TGs.
Design of Due Diligence Measures
During 2018, we followed our management systems and due diligence procedures for 3TGs that we established in 2013 (our “CM Process”) with the intent to conform with the Organization for EconomicCo-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition, 2016 (“OECD Guidance”) and the related Supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of these five steps, as outlined below.
OECD Guidance Step 1 – Establish Strong Internal Management Systems
| • | We have adopted a Conflict Minerals Policy and Supplier Code of Conduct, which is available on our web site athttps://www.flir.com/corporate/supplier. |
| • | We have an internal team comprised of those employees who have responsibility for SEC reporting and compliance, and a system to notify the team of information that is relevant to supply-chain due diligence. This team is led by our Legal Department. |
| • | We use a third-party service provider to assist us with supply-chain outreach and CMRT collection as well as with due diligence activities related to same. |
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| • | This year, we continued to put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party service provider’s Learning Management System, to provide allin-scope suppliers access to Conflict Minerals training courses and learning material that includes understanding the CM regulation, filling out the CMRT, and using our third-party service provider’s online portal for submission. |
Our employees may anonymously report suspected violations of our Conflict Minerals Policy and Supplier Code of Conduct using our hotline which is hosted by EthicsPoint, available 24 hours a day, seven days a week.
The Company has adopted a policy to retain relevant documentation for a period of 5 years. Through our third-party service provider we retain all conflict minerals related documents, including supplier responses to CMRTs. All of this information and findings from this process are stored in a database that can be audited by internal or external parties.
OECD Guidance Step 2 – Identify and Assess Risk in the Supply Chain
| • | We require all suppliers that are within scope of providing products that may contain 3TGs to complete a valid and complete CMRT. |
| • | We requested that our suppliers that providein-scope products or parts complete a CMRT to collect information about the smelters of 3TG used in our products. |
| • | We analyzed the suppliers’ template responses for completeness and internal consistency and followed up with suppliers in an effort to resolve any discrepancies or incomplete answers that we identified. |
| • | We relied on representations from suppliers that we considered reasonable. Our third-party service-provider also has automatic validation to flag CMRTs that contain conflicting responses or missing information. If such a CMRT was submitted, the supplier received an automated email response indicating the issues with the CMRT they provided. |
| • | In some instances, we worked with suppliers to contact the manufacturer of products supplied to them. We considered warning signs or other circumstances that, in our view, indicated responses to the CMRT were unreliable or that the 3TGs came from a Covered Country and were not from recycled or scrap sources. |
Based on the smelter lists provided by our suppliers via CMRT, we have identified 321 smelters or refiners that are on the RMI Standard Smelter List that accompanies CMRT version 5.11. Of these, 255 have a been identified as conformant by the RMI through the RMAP.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Our third-party service provider uses 5 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:
| 1. | Geographic proximity to the DRC and covered countries; |
| 2. | RMAP audit status; |
| 3. | Known mineral source country of origin; |
| 4. | Peer assessments conducted by credible third-party sources; and |
| 5. | Credible evidence of unethical or conflict sourcing. |
Based on the above criteria the following facilities have been identified with red flag risks in the supply chain:
| • | Tony Goetz NV—CID002587 |
| • | African Gold Refinery Limited (AGR)—CID003185 |
| • | Kaloti Precious Metals—CID002563 |
| • | Universal Precious Metals Refining Zambia—CID002854 |
| • | Sudan Gold Refinery—CID002567 |
| • | Fidelity Printers and Refiners – CID002515 |
When these facilities were reported on a CMRT by one of our suppliers, risk mitigation activities were initiated. Through our third-party service provider along with the FLIR site supply chain organizations, suppliers that included any of the above facilities were immediately contacted and requested to take their own risk mitigation actions, including reviewing products sold to FLIR, and advise in writing if minerals from any of these smelters were used in FLIR products and, if so, work towards removal of thesered-flag smelter(s) from their supply chain.
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In accordance with OECD Due Diligence Guidance, risk mitigation will depend on each supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with clear expectations to remediate the issue with focus on elimination of these risks from the supply chain.
OECD Guidance Step 3 – Design and Implement a Strategy to Respond to Identified Risks
| • | Supplier terms and conditions require, whenever possible, compliance with FLIR’s Supplier Code of Conduct which requires suppliers to certify as to whether supplied products are or are not free of Conflict Minerals (“CMs”). FLIR’s standard Supplier Terms and Conditions includes language which states Suppliers are required to adhere to our conflict minerals policy. |
| • | We notify our direct suppliers of CMs and each third-party manufacturer of our products that contain CMs of our policy on CMs. |
| • | We are in the process of cross-referencing the smelter and refiner information provided by suppliers this year with the data made available by RMAP concerning the country of origin of the CMs processed by those facilities and their Conflict Status. |
OECD Guidance Step 4 – Carry Out Independent Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain
| • | We rely on the RMAP initiative described above to identify smelters or refiners who are conformant with their assessment protocols, in satisfaction of the OECD framework requirements. Any smelters or refiners that were reported by our suppliers on their CMRTs who were not part of the RMAP were contacted directly by our third-party service provider to encourage them to participate in the RMAP. |
OECD Guidance Step 5 – Report on Supply Chain Due Diligence
| • | We publicly report the results of our due diligence by publishing a CMR annually. Our reports are accessible on our website athttps://www.flir.com/corporate/supplier. |
Due Diligence Results
Survey Results
We received information from approximately 75% of our suppliers, including information on materials supplied directly to us and contained in products that we contracted to have manufactured by third parties. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or inconsistencies were found. 68 suppliers did not submit a new CMRT when advised of such inaccuracies or inconsistencies and as such are still listed as invalid submissions as of April 29, 2019.
Smelters and Refiners
A majority of the responses we received from our suppliers provided aggregate data for their global supplier list on entity company-wide basis. However, some of the responses we received were incomplete or stated that the supplier had no knowledge regarding the source of the 3TGs in their products supplied to FLIR because they had merely purchased such products from a source further down the supply chain. Some suppliers who responded were able to identify smelters or refiners used by sub tier suppliers in their supply chains but not at a component level. However, their responses indicated that their own supply chain due diligence was less than complete. A minority of our suppliers provided product level CMRTs but were unable to tie individual smelters or refiners to the specific components that were delivered to us and are contained in our end products. We are therefore unable to definitively (i) determine whether any of the 3TGs reported by our suppliers were contained in our end products or (ii) validate which of the smelters and refineries included in the CMRTs of our suppliers actually supplied 3TGs for specific components used in our end products. Due to this, our list of smelters or refiners may contain more facilities than those that processed the 3TGs contained in our products.
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We are continuing our review of all responses to correlate, identify and resolve the inconsistencies and missing information related to each supplier’s responses. Our continuing efforts to determine the mine or location of origin of the 3TGs follow the steps outlined in the OECD Guidance described above.
Risk Mitigation and Future Due Diligence Measures
We have taken, or will take, the following steps since the period covered by this Report to mitigate the risk that our 3TGs financed or benefitted armed groups in the Covered Countries:
| • | Increased the response rate of suppliers to our information requests by continuing to refine our data collection process. |
| • | Implemented a new conflict minerals procedure to clarify our processes. |
| • | Carry out requirements outlined in FLIR’s Conflict Mineral Policy Statement to identifynon-compliant suppliers and take action to require suppliers remediate the issue or risk corrective action up to and including FLIR establishing alternative sources from conflict free suppliers and may include escalation to senior management to advise of suppliers using high risk practices. |
| • | Encourage suppliers to increase the participation rate of smelters and refiners in the RMAP. |
| • | Require new suppliers to commit to comply with our Conflict Minerals Policy and Supplier Code of Conduct before placing any orders with the supplier. |
| • | Improve our supply chain due diligence by increasing awareness internally and externally regarding our Conflict Minerals Policy. |
We will also continue to engage with the RBA and other key industry groups as part of a wider industry collaboration to develop best practices for the global supply chain and address the ongoing issue of conflict minerals.
In accordance with the Rule, a copy of this Report will be posted on the Company’s website at www.flir.com/corporate/supplier
Appendix A
Metal | Standard Smelter Name | Smelter Facility Location | ||
| Gold | 8853 S.p.A. | ITALY | ||
| Gold | Abington Reldan Metals, LLC | UNITED STATES | ||
| Gold | Advanced Chemical Company | UNITED STATES | ||
| Gold | African Gold Refinery | UGANDA | ||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | ||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | ||
| Gold | AllgemeineGold-und Silberscheideanstalt A.G. | GERMANY | ||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | ||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | ||
| Gold | Asahi Pretec Corp. | JAPAN | ||
| Gold | Asahi Refining Canada Ltd. | CANADA | ||
| Gold | Asahi Refining USA Inc. | UNITED STATES | ||
| Gold | Asaka Riken Co., Ltd. | JAPAN | ||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
| Gold | AU Traders and Refiners | SOUTH AFRICA | ||
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| Gold | Aurubis AG | GERMANY | ||
| Gold | Bangalore Refinery | INDIA | ||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
| Gold | Boliden AB | SWEDEN | ||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | ||
| Gold | Caridad | MEXICO | ||
| Gold | CCR Refinery—Glencore Canada Corporation | CANADA | ||
| Gold | Cendres + Métaux S.A. | SWITZERLAND | ||
| Gold | Chimet S.p.A. | ITALY | ||
| Gold | Chugai Mining | JAPAN | ||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | DayeNon-Ferrous Metals Mining Ltd. | CHINA | ||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | ||
| Gold | Dowa | JAPAN | ||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | ||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
| Gold | Fujairah Gold FZE | UNITED ARAB EMIRATES | ||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
| Gold | Geib Refining Corporation | UNITED STATES | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||
| Gold | HeeSung | KOREA, REPUBLIC OF | ||
| Gold | Heimerle + Meule GmbH | GERMANY | ||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | ||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | ||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
| Gold | Istanbul Gold Refinery | TURKEY | ||
| Gold | Italpreziosi | ITALY | ||
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| Gold | Japan Mint | JAPAN | ||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | ||
| Gold | JSC EkaterinburgNon-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | ||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||
| Gold | Kazzinc | KAZAKHSTAN | ||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | ||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | ||
| Gold | Lingbao Gold Co., Ltd. | CHINA | ||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
| Gold | L’Orfebre S.A. | ANDORRA | ||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
| Gold | Marsam Metals | BRAZIL | ||
| Gold | Materion | UNITED STATES | ||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | ||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||
| Gold | Metalor Technologies S.A. | SWITZERLAND | ||
| Gold | Metalor USA Refining Corporation | UNITED STATES | ||
| Gold | MetalúrgicaMet-Mex Peñoles S.A. De C.V. | MEXICO | ||
| Gold | Mitsubishi Materials Corporation | JAPAN | ||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | ||
| Gold | Modeltech Sdn Bhd | MALAYSIA | ||
| Gold | Morris and Watson | NEW ZEALAND | ||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | ||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | ||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | ||
| Gold | Nihon Material Co., Ltd. | JAPAN | ||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
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| Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
| Gold | PAMP S.A. | SWITZERLAND | ||
| Gold | Pease & Curren | UNITED STATES | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
| Gold | Planta Recuperadora de Metales SpA | CHILE | ||
| Gold | Prioksky Plant ofNon-Ferrous Metals | RUSSIAN FEDERATION | ||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
| Gold | PX Précinox S.A. | SWITZERLAND | ||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | ||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | ||
| Gold | Remondis Argentia B.V. | NETHERLANDS | ||
| Gold | Republic Metals Corporation | UNITED STATES | ||
| Gold | Royal Canadian Mint | CANADA | ||
| Gold | SAAMP | FRANCE | ||
| Gold | Sabin Metal Corp. | UNITED STATES | ||
| Gold | Safimet S.p.A | Italy | ||
| Gold | SAFINA A.S. | CZECH REPUBLIC | ||
| Gold | Sai Refinery | INDIA | ||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | ||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | ||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
| Gold | Shangdong Humon Smelting Co., Ltd. | CHINA | ||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
| Gold | Singway Technology Co., Ltd. | TAIWAN | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | ||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
| Gold | Sudan Gold Refinery | SUDAN | ||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | ||
| Gold | T.C.A S.p.A | ITALY | ||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | ||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||
| Gold | Tony Goetz NV | BELGIUM | ||
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| Gold | TOOTau-Ken-Altyn | KAZAKHSTAN | ||
| Gold | Torecom | KOREA, REPUBLIC OF | ||
| Gold | Umicore Brasil Ltda. | BRAZIL | ||
| Gold | Umicore Precious Metals Thailand | THAILAND | ||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | ||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | ||
| Gold | Valcambi S.A. | SWITZERLAND | ||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | ||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | ||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | ||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
| Tantalum | D Block Metals, LLC | UNITED STATES | ||
| Tantalum | Exotech Inc. | UNITED STATES | ||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | ||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | ||
| Tantalum | Global Advanced Metals Aizu | JAPAN | ||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | ||
| Tantalum | Guangdong Rising RareMetals-EO Materials Ltd. | CHINA | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | ||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | ||
| Tantalum | H.C. Starck Inc. | UNITED STATES | ||
| Tantalum | H.C. Starck Ltd. | JAPAN | ||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | ||
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | ||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | ||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum | KEMET Blue Metals | MEXICO | ||
| Tantalum | KEMET Blue Powder | UNITED STATES | ||
| Tantalum | LSM Brasil S.A. | BRAZIL | ||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | ||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | ||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
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| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
| Tantalum | NPM Silmet AS | ESTONIA | ||
| Tantalum | Power Resources Ltd. | MACEDONIA | ||
| Tantalum | QuantumClean | UNITED STATES | ||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | ||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | ||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
| Tantalum | Taki Chemicals | JAPAN | ||
| Tantalum | Telex Metals | UNITED STATES | ||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
| Tin | Alpha | UNITED STATES | ||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||
| Tin | China Tin Group Co., Ltd. | CHINA | ||
| Tin | CV Ayi Jaya | INDONESIA | ||
| Tin | CV Dua Sekawan | INDONESIA | ||
| Tin | CV Gita Pesona | INDONESIA | ||
| Tin | CV Tiga Sekawan | INDONESIA | ||
| Tin | CV United Smelting | INDONESIA | ||
| Tin | CV Venus Inti Perkasa | INDONESIA | ||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
| Tin | Dowa | JAPAN | ||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||
| Tin | EM Vinto | BOLIVIA | ||
| Tin | Estanho de Rondônia S.A. | BRAZIL | ||
| Tin | Fenix Metals | POLAND | ||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
| Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | CHINA | ||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
| Tin | Guangdong HanheNon-ferrous Metal Limited Company | CHINA | ||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | ||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | ||
| Tin | Metallic Resources, Inc. | UNITED STATES | ||
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| Tin | Metallo Belgium N.V. | BELGIUM | ||
| Tin | Metallo Spain S.L.U. | SPAIN | ||
| Tin | Mineracao Taboca S.A. | BRAZIL | ||
| Tin | Minsur | PERU | ||
| Tin | Mitsubishi Materials Corporation | JAPAN | ||
| Tin | Modeltech Sdn Bhd | MALAYSIA | ||
| Tin | Nghe TinhNon-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | ||
| Tin | Pongpipat Company Limited | MYANMAR | ||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | ||
| Tin | PT Artha Cipta Langgeng | INDONESIA | ||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | ||
| Tin | PT Babel Inti Perkasa | INDONESIA | ||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | ||
| Tin | PT Bangka Prima Tin | INDONESIA | ||
| Tin | PT Bangka Serumpun | INDONESIA | ||
| Tin | PT Bangka Tin Industry | INDONESIA | ||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | ||
| Tin | PT Bukit Timah | INDONESIA | ||
| Tin | PT DS Jaya Abadi | INDONESIA | ||
| Tin | PT Inti Stania Prima | INDONESIA | ||
| Tin | PT Karimun Mining | INDONESIA | ||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | ||
| Tin | PT Menara Cipta Mulia | INDONESIA | ||
| Tin | PT Mitra Stania Prima | INDONESIA | ||
| Tin | PT Panca Mega Persada | INDONESIA | ||
| Tin | PT Premium Tin Indonesia | INDONESIA | ||
| Tin | PT Prima Timah Utama | INDONESIA | ||
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | ||
| Tin | PT Refined Bangka Tin | INDONESIA | ||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | ||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | ||
| Tin | PT Sukses Inti Makmur | INDONESIA | ||
| Tin | PT Sumber Jaya Indah | INDONESIA | ||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | ||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | ||
| Tin | PT Tinindo Inter Nusa | INDONESIA | ||
| Tin | PT Tirus Putra Mandiri | INDONESIA | ||
| Tin | PT Tommy Utama | INDONESIA | ||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | ||
| Tin | Rui Da Hung | TAIWAN | ||
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| Tin | Soft Metais Ltda. | BRAZIL | ||
| Tin | Super Ligas | Brazil | ||
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||
| Tin | Thaisarco | THAILAND | ||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | ||
| Tin | Tuyen QuangNon-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | ||
| Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | CHINA | ||
| Tin | Yunnan Tin Company Limited | CHINA | ||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | ||
| Tungsten | ACL Metais Eireli | BRAZIL | ||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | ||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | ||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Minmetals Gao’anNon-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Kennametal Fallon | UNITED STATES | ||
| Tungsten | Kennametal Huntsville | UNITED STATES | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | ||
| Tungsten | Niagara Refining LLC | UNITED STATES | ||
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| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | ||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | ||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | ||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | ||
Appendix B
This list of potential countries of origin is populated based on publicly available information, our Reasonable Country of Origin Inquiry (RCOI) and due diligence. It is important to note that this is also based on company level responses and, therefore, it is not certain which of these countries of origin can be linked to our products.
Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo (Democratic Republic of the), Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe
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