Exhibit 1.01
Conflict Minerals Report
I. | Introduction |
A. | Our Business |
Illinois Tool Works Inc. is a global manufacturer of a diversified range of industrial products and equipment with 84 divisions in 57 countries, and has prepared this Conflict Minerals Report for calendar year 2015 in accordance with the requirements of Rule 13p-1 (“Rule 13p-1”) and Form SD (together referred to as the "Conflict Minerals Rule") of the United States Securities and Exchange Commission (“SEC”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “its,” “us” and “our” refer to Illinois Tool Works Inc. and its consolidated subsidiaries. “Conflict minerals” or “3TG” as used in this report, refers to cassiterite, columbite-tantalite, gold, wolframite and their derivatives, tin, tantalum, tungsten and/or gold, without regard to their location of origin.
The Company’s operations are reported to senior management as the following segments: Automotive OEM; Test & Measurement and Electronics; Food Equipment; Polymers & Fluids; Welding; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain some amount of 3TG that are necessary to the functionality or production of the products (which we sometimes refer to herein as "in-scope" products). ITW’s in-scope products taken together as a whole contain all four 3TGs, although each product does not contain all four 3TGs.
B.Reasonable Country of Origin Inquiry and Due Diligence Overview
As required by the Conflict Minerals Rule, we conducted a "reasonable country of origin inquiry" ("RCOI"), designed in good faith to determine the origin of the 3TG that are contained in our in-scope products. See Section II. Reasonable Country of Origin Inquiry for a description of our RCOI process for 2015.
If the Company has reason to believe that any of the 3TG in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we are required to exercise due diligence on the source and chain of custody of the 3TG and include a description of our due diligence measures in this Conflict Minerals Report. On the basis of our RCOI, we have determined that some of the 3TG contained in our products originated from a Covered Country, and we are therefore submitting this Conflict Minerals Report, which describes the due diligence we have performed pursuant to the Conflict Minerals Rule and our related processes and procedures. See Section III. Due Diligence. This report is filed as an exhibit to our Form SD and is available on our website at http://investor.itw.com/investor-information/sec-filings. Information contained on our website or otherwise actively linked to this Conflict Minerals Report is not part of or incorporated by reference into this Conflict Minerals Report or our Form SD.
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C. | ITW’s Position in the Supply Chain |
Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We therefore require the cooperation of our supply chain to provide information on smelters and refiners (“SORs”) as well as the origin of 3TG contained in our products, and we rely on the Conflict Free Sourcing Initiative (“CFSI”) and the Conflict Free Smelter Program managed by the CFSI to conduct and recognize independent, third-party audits of SORs.
D. | Responsible Sourcing Commitment |
Through the efforts described in this Conflict Minerals Report, we seek to ensure that our suppliers responsibly source 3TG. Our responsible sourcing goes beyond compliance with the Conflict Minerals Rule, however, and our Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) mandates compliance with all laws, and in particular prohibits use of child labor, forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, and anti-bribery laws.
E. | Smelter and Refiner and Country of Origin Information |
The Company’s in-scope products that contain 3TG and that are required to be described in this CMR are described in Section IV. Product Information. Information about SORs relating to the Company’s in-scope products is described in Section V. Identified Smelters and Refiners and on Annex A. We have not found for 2015 that any of the necessary 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.” The terms "adjoining country," "armed group," and "DRC conflict free" have the meanings contained in the Conflict Minerals Rule.
F. | 2015 Program Improvements |
For 2015, we continued our participation in the AIAG Conflict Minerals Working Group and in the CFSI’s plenary and due diligence practices team. We also took the following actions to improve our RCOI and conflict minerals due diligence and mitigate sourcing risk:
• | Completed an external readiness assessment of our conflict minerals process with a professional assurance firm to evaluate the alignment of our process with the due diligence guidance of the Organisation for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Second Edition 2013) (“OECD Guidance”); |
• | Completed an internal assessment of our conflict minerals due diligence process to better understand how we can assist our business divisions in the process of inquiring and reporting of information from their suppliers. As a result of this assessment, we took certain actions, including: |
◦ | Offered conflict minerals information and assistance at enterprise-wide strategic sourcing conferences; and |
◦ | Revised our communications with our businesses to be simpler and easier to follow. |
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• | Revised ITW’s Conflict Minerals Policy Statement (which can be found at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/) to clearly encourage our suppliers’ support of verified SORs in the Covered Countries; |
• | Incorporated conflict mineral screening questions into incoming supplier bids; |
• | Created a link to ITW’s Helpline in our Conflict Minerals Policy Statement that is included on our website to enable third parties and shareholders, as well as suppliers, to report grievances; and |
• | Participated in the Caterpillar Cross-Industry Collaboration Group calls. |
II. | Reasonable Country of Origin Inquiry |
Our RCOI utilized management systems recommended by the first step of the OECD Guidance and was conducted in accordance with the second step of the OECD Guidance. Selected elements of our program design and RCOI process are discussed below. However, these are not all of the discrete elements of the program that we have put in place in accordance with these steps of the OECD Guidance to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the first and second steps.
A. Establish Strong Management Systems
1. ITW Policies
ITW has adopted a company-wide Conflict Minerals Policy Statement (the "Policy"), which has been approved by ITW’s Chief Executive Officer and is available on our website at http://www.itw.com/about-itw/suppliers/page/en/conflict-minerals-policy-statement/. Our Policy states that we do not knowingly procure 3TG that originate from the Covered Countries unless they originate from mines or SORs that are certified as having followed established protocols to allow them to be considered “conflict free.” We ask our suppliers to undertake reasonable due diligence with their supply chains to determine whether products containing 3TG used in the manufacture of our products originate from a Covered Country and, if they do originate from a Covered Country, that the SORs be certified as compliant by an independent third party. The Policy encourages our suppliers to continue to support compliant SORs in the Covered Countries and to make similar requests of their sub-suppliers. If we discover that any 3TG procured by us are produced in a Covered Country from facilities that are not certified as compliant, we will request that our supplier ask the facility to become certified or use our best efforts to transition the product to be from compliant sources.
ITW’s Supplier Code of Conduct (which can be found at http://www.itw.com/about-itw/suppliers/page/en/supplier-code-of-conduct/) sets forth expectations for all ITW suppliers to adhere to the highest ethical standards in the conduct of their business. It also requires suppliers to adhere to specific standards and specifically prohibits certain behaviors associated with conflict minerals, including use of child or forced labor, unsafe working conditions and bribery. The Code of Conduct also requires that, upon request, our suppliers determine whether any products provided by them contain 3TG and to take such actions as necessary to provide the information requested by ITW to conduct its RCOI, as described below under B. Identify and Assess Risk in the Supply Chain.
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We do not support a general embargo of sourcing from the Covered Countries, and clarified our Conflict Minerals Policy to encourage our suppliers to continue to source from responsible sources in those countries.
2. Cross Functional Committee
ITW has a cross-functional conflict minerals committee (the “Committee”). The Committee is headed by ITW’s Vice President of Strategic Sourcing, who reports to one of ITW’s Vice Chairmen, and includes dedicated employees and representatives from strategic sourcing, legal, environmental and chemical compliance, sustainability, internal audit, IT, and selected personnel from various operations. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets as needed to discuss the conflict minerals compliance process and developments. Senior management is briefed on the results of our due diligence efforts on a regular basis.
3. Internal Training
We maintain an intranet conflict minerals website which contains resources, instructions and guidance on the RCOI and due diligence processes to be followed by our businesses that have or may have in-scope products. The site also contains step-by-step instructions for making supplier inquiries, including a training video regarding our RCOI and due diligence process, and can be accessed by all ITW businesses for reference.
4. Supplier Engagement and Training
In addition to our Conflict Minerals Policy Statement and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” with its suppliers obligates suppliers to take such actions as requested by ITW to enable us to comply with our conflict minerals disclosure requirements. We also include conflict minerals screening questions into incoming supplier bids.
ITW educates key suppliers through presentations regarding our conflict minerals compliance program during supplier meetings and other interactions. We also post information and guidance for suppliers on our Company website and encourage our businesses to share relevant information with suppliers on the process for responding to our RCOI requests for information.
5. Records Retention
ITW retains its conflict minerals related records for at least five years. These records generally are maintained in an electronic format.
6. Grievance Mechanism
ITW maintains a web- and telephone-based reporting system (“Helpline”), providing employees with a confidential reporting mechanism by which they can communicate issues and concerns associated with violations of ITW’s Principles of Conduct, which requires all employees to comply with all applicable laws and Company policies, including the Policy.
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A link to the Helpline is included in our Conflict Minerals Policy Statement on our website to provide convenient access to external stakeholders, suppliers and other third parties to communicate issues and concerns regarding ITW’s supply chain. The contact information for our Helpline is http://www.itwhelpline.ethicspoint.com.
B. Identify and Assess Risk in the Supply Chain
Our RCOI process was used to survey our potential in-scope suppliers to identify and assess conflict mineral sourcing risk in our supply chain for the 2015 reporting cycle.
Prior to conducting our supplier survey, we made internal inquiries of all of our businesses to identify the in-scope products of each of our segments. All businesses were given information and guidance to assist in determining which products are in-scope.
We then surveyed all potential in-scope suppliers to determine whether 3TG in those products originated or may have originated from a Covered Country and were not from recycled or scrap sources. Businesses with potentially in-scope products were instructed to survey their suppliers regarding the origin of the 3TG contained in those products using the CFSI’s Conflict Minerals Reporting Template (“CMRT”). The CMRT requests information regarding 3TG included in the suppliers’ products, SOR identity and location, the supplier’s RCOI process and other information about the suppliers’ conflict minerals policies and practices. Our outreach included all suppliers that we identified as having provided us with components, parts or products that contain 3TG or that we believed may have contained 3TG (the "Suppliers").
ITW has an established protocol for its Supplier inquiry process and uses a third party software vendor to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and Suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).
We sent 4,280 requests to Suppliers to provide us with a completed CMRT. A number of our businesses source different products from the same supplier, and each business sent inquiries to all suppliers of potentially in-scope products; accordingly, the total number of unique suppliers is less than the number of Suppliers queried. We received 1,636 CMRTs from the Suppliers surveyed.
The CM System issued automatic weekly follow-up reminders to non-responding suppliers, and our businesses were given instructions regarding follow-up actions beyond the automatic reminders and in response to receipt of incomplete or incorrect CMRTs.
Our protocol also includes a follow-up process to investigate any CMRTs received that raise red flags. See Section III. Due Diligence for a description of the follow-up process.
Our Supplier responses identified 215 SORs certified by the CFSI as compliant. We determined that 192 of these compliant SORs sourced exclusively from outside the Covered Countries, including in whole or in part from recycled or scrap sources. Our determination was based on country of origin information made available by the CFSI to its members. Our Supplier responses identified an additional 35 SORs that were listed as active by the CFSI and 65 that were on the CFSI’s Smelter Reference List but were not certified or active. Based on the results of our RCOI, we were required to conduct due diligence, as described below.
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III. | Due Diligence |
A. | Design Framework |
ITW´s conflict minerals due diligence process is designed in conformance with the related third, fourth and fifth steps of the OECD Guidance.
B. | Due Diligence Activities |
Selected elements of our program design and implementation in furtherance of the third, fourth and fifth steps of the OECD Guidance are discussed below. However, these are not all of the discrete elements of the program that we have put in place pursuant to these steps to help ensure that the 3TG contained in our products are responsibly sourced. The headings below conform to the headings used in the OECD Guidance for each of the third, fourth and fifth steps. The actions taken by the Company to address the first and second steps of the OECD Guidance are described in Section II. Reasonable Country of Origin Inquiry. See also our 2015 program improvements discussed in Section I. Introduction.
Design and implement a strategy to respond to identified risks
The SOR information provided by suppliers in response to the Company’s supplier survey described in Section II.B. was reviewed against the Smelter Reference List in the CMRT. SOR information also was reviewed against the lists of "compliant" and "active" SORs and country-of-origin information published by the CFSI and contained in the CM System. Active SORs are those that are taking action to become certified as conflict free.
CMRTs that indicated 3TG from a source within a Covered Country, or that contained inconsistent smelter information, triggered a red flag in the CM System. If an individual business received a response from a supplier indicating the presence of 3TG from a Covered Country that is sourced from an SOR that is not compliant or that did not identify an SOR, communications with that Supplier were escalated. These Suppliers were asked to complete a series of additional questions, and our businesses were given written guidance and instructions for these communications. These escalated Supplier situations were reviewed on a case-by-case basis, and the communications took place outside of the CM System.
Our red flag process did not result in the need to require corrective action on the part of our Suppliers.
In 2015, we continued to revise and simplify our written communications and instructions to our businesses regarding Supplier red flag follow-up to enhance program effectiveness.
Our conflict minerals compliance team reported the findings from its RCOI and due diligence process to our Vice President of Strategic Sourcing, and these results were in turn discussed with senior management.
Carry out independent third party audit of supply chain diligence at identified points in the supply chain
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The Company continued its membership in the CFSI for 2015. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the CFSI’s Conflict-Free Smelter Program to perform third-party audits of SORs.
Report annually on supply chain due diligence
We describe our supply chain due diligence efforts in our Conflict Minerals Report. We are required to prepare this report annually, post it on our website and file it with the SEC as an exhibit to our annual Form SD. Once filed, the Form SD and Conflict Minerals Report become available on our website. We also include a discussion of our efforts in the area of conflict minerals in our annual Corporate Social Responsibility Report, which is also available on our website (see http://workingtogether.itw-csr.com/our-world/conflict-minerals).
IV. | Product Information |
For 2015, our in-scope products required to be described in this Conflict Minerals Report included products in each of the categories below:
Arc welding and cutting equipment and consumables | Industrial ovens |
Automotive components | Industrial warewashers |
Catalysts | Inspection equipment |
Commercial cooking equipment | LEDs, LCDs |
Commercial refrigerators | Marking and coding equipment |
Cutting Equipment | Mixers |
Electrical devices | Printers and dispensers |
Electronic equipment | Sealing equipment |
Fastening tools | Switches, capacitors and electronics |
Flow control meters | Testing equipment |
Hot stamp machines | Warehouse equipment |
Industrial equipment |
V. Identified Smelters and Refiners
Our Supplier responses identified 215 SORs that were on the CFSI compliant list, 35 that were listed as active and 65 that were on the Smelter Reference List but not compliant or active. These facilities are listed on Annex A. The information in Annex A includes only the information and entities identified by our Suppliers as SORs that were on the Smelter Reference List contained in the CM System as of May 11, 2016, which are those entities identified to us that we were able to determine were SORs. Entities identified by our Suppliers that are not on Annex A have been submitted to the CFSI to support their ongoing effort to identify and audit all 3TG SORs.
Due to our position in the supply chain, which is discussed earlier in this Conflict Minerals Report, we rely on our Suppliers for accurate SOR information, and our RCOI and due diligence measures do not provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope
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products. The information that we received from most of our Suppliers was made at a company or user defined level, rather than at a product level, meaning that such Suppliers provided information on all of their products that contained 3TG, not just the products that were sold to us. Therefore, our list of SORs disclosed in Annex A may contain facilities that did not process the 3TG contained in our products. In addition, the identified SORs may not include all SORs present in our in-scope product supply chain, since some Suppliers were unable to identify all of the SORs in their supply chain.
Annex A also includes information concerning the identified countries of origin of the SORs listed. We have not found for 2015 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country. However, we have not declared that any of our products are “DRC conflict free.” An "armed group" under the Conflict Minerals Rule is an armed group that is identified as a perpetrator of serious human rights abuses in annual Country Reports on Human Rights Practices under sections 116(d) and 502B(b) of the Foreign Assistance Act of 1961 relating to a Covered Country.
We endeavored to determine the mine or location of origin of the 3TG contained in our in-scope products by requesting that the Suppliers provide us with a completed CMRT and through the other actions described in this Conflict Minerals Report.
VI. | Additional Risk Mitigation |
In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take the following steps in respect of our 2016 compliance to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups:
● | Continue to analyze and review our current processes to improve their effectiveness and efficiency. |
● | Analyze spend data against supplier response data to identify inconsistencies and areas of potential enhanced focus for supplier outreach efforts. |
● | Engage with suppliers that provided incomplete responses or that did not provide responses for 2015 to help ensure that they will provide requested information for 2016. |
● | Continue to enhance supplier communication and training to improve RCOI and due diligence data accuracy and completion. |
● | Through our direct suppliers, continue to seek to influence uncertified SORs in our supply chain to obtain a compliant certification by engaging with suppliers who identified uncertified SORs that are not actively pursuing certification to encourage them to pursue certification. |
● | Continue our membership in the CFSI and support the CFSI’s certification of SORs. |
● | Continue to submit to the CFSI facilities identified by our Suppliers that are not on the Smelter Reference List, to support the CFSI's ongoing effort to identify and audit all 3TG SORs. |
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VII. | Forward Looking Statements |
This report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements include expectations concerning the Company’s future actions to identify improvements to our due diligence processes, to engage with our suppliers, and to take other actions regarding our product sourcing. These statements are subject to certain risks, uncertainties and other factors, including but not limited to, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.
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Annex A to Exhibit 1.01 CFSI Smelters or Refiners | |||
Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner Status |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Compliant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant |
Gold | Argor-Heraeus SA | SWITZERLAND | Compliant |
Gold | Asahi Pretec Corporation | JAPAN | Compliant |
Gold | Asahi Refining Canada Limited | CANADA | Compliant |
Gold | Asahi Refining USA Inc. | UNITED STATES | Compliant |
Gold | Asaka Riken Co., Ltd. | JAPAN | Compliant |
Gold | Aurubis AG | GERMANY | Compliant |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant |
Gold | Boliden AB | SWEDEN | Compliant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Compliant |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Compliant |
Gold | Chimet S.p.A. | ITALY | Compliant |
Gold | DODUCO GmbH | GERMANY | Compliant |
Gold | Dowa | JAPAN | Compliant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
Gold | Elemetal Refining, LLC | UNITED STATES | Compliant |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant |
Gold | Heimerle + Meule GmbH | GERMANY | Compliant |
Gold | Heraeus Ltd. Hong Kong | CHINA | Compliant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Compliant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant |
Gold | Istanbul Gold Refinery | TURKEY | Compliant |
Gold | Japan Mint | JAPAN | Compliant |
Gold | Jiangxi Copper Company Limited | CHINA | Compliant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Compliant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant |
Gold | Kazzinc | KAZAKHSTAN | Compliant |
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Gold | Kennecott Utah Copper LLC | UNITED STATES | Compliant |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | Compliant |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Compliant |
Gold | Materion | UNITED STATES | Compliant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Compliant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant |
Gold | Metalor Technologies SA | SWITZERLAND | Compliant |
Gold | Metalor USA Refining Corporation | UNITED STATES | Compliant |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Compliant |
Gold | Mitsubishi Materials Corporation | JAPAN | Compliant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant |
Gold | Nihon Material Co., Ltd. | JAPAN | Compliant |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant |
Gold | PAMP SA | SWITZERLAND | Compliant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant |
Gold | PX Précinox SA | SWITZERLAND | Compliant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant |
Gold | Republic Metals Corporation | UNITED STATES | Compliant |
Gold | Royal Canadian Mint | CANADA | Compliant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | Compliant |
Gold | SEMPSA Joyería Platería SA | SPAIN | Compliant |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant |
Gold | Singway Technology Co., Ltd. | TAIWAN | Compliant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant |
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Gold | Solar Applied Materials Technology Corp. | TAIWAN | Compliant |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant |
Gold | T.C.A S.p.A | ITALY | Compliant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | Compliant |
Gold | Umicore Brasil Ltda. | BRAZIL | Compliant |
Gold | Umicore Precious Metals Thailand | THAILAND | Compliant |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Compliant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | Compliant |
Gold | Valcambi SA | SWITZERLAND | Compliant |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | Compliant |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant |
Gold | Advanced Chemical Company | UNITED STATES | Active |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Active |
Gold | Cendres + Métaux SA | SWITZERLAND | Active |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Active |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | Active |
Gold | Faggi Enrico S.p.A. | ITALY | Active |
Gold | Geib Refining Corporation | UNITED STATES | Active |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active |
Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | Active |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Active |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Active |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | Active |
Gold | Torecom | KOREA, REPUBLIC OF | Active |
Gold | WIELAND Edelmetalle GmbH | GERMANY | Active |
Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | On Smelter Reference List |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | On Smelter Reference List |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Smelter Reference List |
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Gold | Bauer Walser AG | GERMANY | On Smelter Reference List |
Gold | Caridad | MEXICO | On Smelter Reference List |
Gold | Chugai Mining | JAPAN | On Smelter Reference List |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Smelter Reference List |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Smelter Reference List |
Gold | Guangdong Jinding Gold Limited | CHINA | On Smelter Reference List |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Reference List |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Smelter Reference List |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Smelter Reference List |
Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Reference List |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | On Smelter Reference List |
Gold | Lingbao Gold Company Limited | CHINA | On Smelter Reference List |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | On Smelter Reference List |
Gold | Morris and Watson | NEW ZEALAND | On Smelter Reference List |
Gold | OJSC Kolyma Refinery | KOREA, REPUBLIC OF | On Smelter Reference List |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Sabin Metal Corp. | UNITED STATES | On Smelter Reference List |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | On Smelter Reference List |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Smelter Reference List |
Gold | So Accurate Group, Inc. | UNITED STATES | On Smelter Reference List |
Gold | The Great Wall Gold and Silver Refinery of China | China | On Smelter Reference List |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Smelter Reference List |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Smelter Reference List |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Compliant |
Tantalum | D Block Metals, LLC | UNITED STATES | Compliant |
Tantalum | Duoluoshan | CHINA | Compliant |
Tantalum | Exotech Inc. | UNITED STATES | Compliant |
13
Tantalum | F&X Electro-Materials Ltd. | CHINA | Compliant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | Compliant |
Tantalum | Global Advanced Metals Aizu | JAPAN | Compliant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Compliant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | Compliant |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Compliant |
Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Compliant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Compliant |
Tantalum | H.C. Starck Inc. | UNITED STATES | Compliant |
Tantalum | H.C. Starck Ltd. | JAPAN | Compliant |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Compliant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Compliant |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Compliant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant |
Tantalum | KEMET Blue Metals | MEXICO | Compliant |
Tantalum | KEMET Blue Powder | UNITED STATES | Compliant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Compliant |
Tantalum | LSM Brasil S.A. | BRAZIL | Compliant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Compliant |
Tantalum | Mineração Taboca S.A. | BRAZIL | Compliant |
Tantalum | Mitsui Mining & Smelting | JAPAN | Compliant |
Tantalum | Molycorp Silmet A.S. | ESTONIA | Compliant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant |
Tantalum | Plansee SE Liezen | AUSTRIA | Compliant |
Tantalum | Plansee SE Reutte | AUSTRIA | Compliant |
Tantalum | QuantumClean | UNITED STATES | Compliant |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant |
Tantalum | Taki Chemicals | JAPAN | Compliant |
Tantalum | Telex Metals | UNITED STATES | Compliant |
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Tantalum | Tranzact, Inc. | UNITED STATES | Compliant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant |
Tantalum | Zhuzhou Cemented Carbide | CHINA | Compliant |
Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | On Smelter Reference List |
Tin | Alpha | UNITED STATES | Compliant |
Tin | China Tin Group Co., Ltd. | CHINA | Compliant |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant |
Tin | CV Ayi Jaya | INDONESIA | Compliant |
Tin | CV Gita Pesona | INDONESIA | Compliant |
Tin | CV Serumpun Sebalai | INDONESIA | Compliant |
Tin | CV United Smelting | INDONESIA | Compliant |
Tin | CV Venus Inti Perkasa | INDONESIA | Compliant |
Tin | Dowa | JAPAN | Compliant |
Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Compliant |
Tin | EM Vinto | BOLIVIA | Compliant |
Tin | Fenix Metals | POLAND | Compliant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Compliant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant |
Tin | Melt Metais e Ligas S/A | BRAZIL | Compliant |
Tin | Metallic Resources, Inc. | UNITED STATES | Compliant |
Tin | Metallo-Chimique N.V. | BELGIUM | Compliant |
Tin | Mineração Taboca S.A. | BRAZIL | Compliant |
Tin | Minsur | PERU | Compliant |
Tin | Mitsubishi Materials Corporation | JAPAN | Compliant |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | Compliant |
Tin | PT Aries Kencana Sejahtera | INDONESIA | Compliant |
Tin | PT Artha Cipta Langgeng | INDONESIA | Compliant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant |
Tin | PT Babel Inti Perkasa | INDONESIA | Compliant |
Tin | PT Bangka Prima Tin | INDONESIA | Compliant |
Tin | PT Bangka Tin Industry | INDONESIA | Compliant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | Compliant |
Tin | PT BilliTin Makmur Lestari | INDONESIA | Compliant |
Tin | PT Bukit Timah | INDONESIA | Compliant |
15
Tin | PT Cipta Persada Mulia | INDONESIA | Compliant |
Tin | PT DS Jaya Abadi | INDONESIA | Compliant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | Compliant |
Tin | PT Inti Stania Prima | INDONESIA | Compliant |
Tin | PT Justindo | INDONESIA | Compliant |
Tin | PT Mitra Stania Prima | INDONESIA | Compliant |
Tin | PT Panca Mega Persada | INDONESIA | Compliant |
Tin | PT Prima Timah Utama | INDONESIA | Compliant |
Tin | PT Refined Bangka Tin | INDONESIA | Compliant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | Compliant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | Compliant |
Tin | PT Sukses Inti Makmur | INDONESIA | Compliant |
Tin | PT Sumber Jaya Indah | INDONESIA | Compliant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant |
Tin | PT Tinindo Inter Nusa | INDONESIA | Compliant |
Tin | PT Tommy Utama | INDONESIA | Compliant |
Tin | PT Wahana Perkit Jaya | INDONESIA | Compliant |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Compliant |
Tin | Rui Da Hung | TAIWAN | Compliant |
Tin | Soft Metais Ltda. | BRAZIL | Compliant |
Tin | Thaisarco | THAILAND | Compliant |
Tin | VQB Mineral and Trading Group JSC | VIETNAM | Compliant |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant |
Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Compliant |
Tin | An Thai Minerals Company Limited | VIETNAM | Active |
Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM | Active |
Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA | Active |
Tin | CV Dua Sekawan | INDONESIA | Active |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM | Active |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Active |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM | Active |
Tin | Phoenix Metal Ltd. | RWANDA | Active |
Tin | PT Karimun Mining | INDONESIA | Active |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM | Active |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Reference List |
Tin | CV Makmur Jaya | INDONESIA | On Smelter Reference List |
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Tin | Estanho de Rondônia S.A. | BRAZIL | On Smelter Reference List |
Tin | Feinhütte Halsbrücke GmbH | GERMANY | On Smelter Reference List |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | On Smelter Reference List |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Smelter Reference List |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | On Smelter Reference List |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | On Smelter Reference List |
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | On Smelter Reference List |
Tin | PT Alam Lestari Kencana | INDONESIA | On Smelter Reference List |
Tin | PT Babel Surya Alam Lestari | INDONESIA | On Smelter Reference List |
Tin | PT Bangka Kudai Tin | INDONESIA | On Smelter Reference List |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | On Smelter Reference List |
Tin | PT Donna Kembara Jaya | INDONESIA | On Smelter Reference List |
Tin | PT Fang Di MulTindo | INDONESIA | On Smelter Reference List |
Tin | PT Koba Tin | INDONESIA | On Smelter Reference List |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | On Smelter Reference List |
Tin | PT Rajwa International | INDONESIA | On Smelter Reference List |
Tin | PT Seirama Tin Investment | INDONESIA | On Smelter Reference List |
Tin | PT Singkep Times Utama | INDONESIA | On Smelter Reference List |
Tin | PT Supra Sukses Trinusa | INDONESIA | On Smelter Reference List |
Tin | PT Tirus Putra Mandiri | INDONESIA | On Smelter Reference List |
Tin | PT Yinchendo Mining Industry | INDONESIA | On Smelter Reference List |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | Compliant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Compliant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | H.C. Starck GmbH | GERMANY | Compliant |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | Compliant |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant |
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Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant |
Tungsten | Kennametal Huntsville | UNITED STATES | Compliant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Niagara Refining LLC | UNITED STATES | Compliant |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | Compliant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | Compliant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | Compliant |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Active |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Active |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Active |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Active |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Active |
Tungsten | Kennametal Fallon | UNITED STATES | Active |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Active |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | On Smelter Reference List |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA | On Smelter Reference List |
Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | On Smelter Reference List |
Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIETNAM | On Smelter Reference List |
Country of Origin Information
The countries of origin of the 3TG processed by the Compliant SORs listed above may have included the countries listed below. The listed countries of origin are derived from information made available by the CFSI to its members. Except for the DRC, the CFSI does not indicate individual countries of origin of the 3TG processed by Compliant SORs. Instead, the CFSI indicates country of origin by category. Compliant SORs listed above were in each of the categories below:
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L1 – Countries that are not identified as conflict regions or plausible areas of smuggling or export of 3TG from the DRC and its nine adjoining countries: Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Colombia, Cote d’Ivoire, Czech Republic, Djibouti, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Sierra Leone, Singapore, Slovakia, South Korea, Spain, Suriname, Switzerland, Taiwan, Thailand, United Kingdom, United States, Vietnam and Zimbabwe.
L2 – Countries that are known or plausible countries for smuggling, export out of region or transit of materials containing 3TG: Kenya, Mozambique and South Africa.
L3 – The DRC and its nine adjoining countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Uganda, United Republic of Tanzania and Zambia.
DRC – The Democratic Republic of the Congo.
In addition, according to information made available by the CFSI to its members, some of the listed SORs processed 3TG originating solely from recycled or scrap sources and others processed both recycled and scrap content and newly mined content from one or more of the regions indicated above.
Because the CFSI generally does not indicate individual countries of origin of the 3TG processed by Compliant SORs, we were not able to determine the countries of origin of the 3TG processed by the listed Compliant SORs with greater specificity. In addition, for some of the listed Compliant SORs, origin information is not disclosed. We did not determine the countries of origin of the 3TG processed by other SORs listed on this Annex A.
19