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 83 divisions in 52 countries and has prepared this Conflict Minerals Report for calendar year 2021 as provided for in Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended, and Form SD (together referred to as the “Conflict Minerals Rule”). Unless the context indicates otherwise, the terms “Company,” “ITW,” “we,” “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, wolframite and their derivatives, tin, tantalum and tungsten, and/or gold, without regard to their location of origin.
The Company’s operations are reported as the following segments: Automotive OEM; Food Equipment; Test & Measurement and Electronics; Welding; Polymers & Fluids; Construction Products; and Specialty Products. Each of our segments manufactures certain products that contain 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 collectively contain all four 3TGs.
B.Reasonable Country of Origin Inquiry and Due Diligence Overview
As provided for in 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 2021.
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 (with the DRC, the “Covered Countries”), or we are unable to determine the country of origin of the 3TG, we exercise due diligence on the source and chain of custody of the 3TG. We have included 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 in-scope products may have 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. This report is filed as an exhibit to our Form SD and is available on our website at www.itw.com/suppliers/. 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.
C.ITW’s Position in the Supply Chain
ITW is a “downstream company” as defined by the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition) (the “OECD Guidance”). Most of our businesses are many levels removed from 3TG mining, smelting and processing facilities, and we have no relationships with mines. We source materials and components from suppliers who in turn source their materials and components from sub-tier suppliers and, therefore, we 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. Due to our position in the supply chain, we utilize 3TG source information provided by the Responsible Minerals Initiative (the “RMI”), which provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing of minerals from conflict-affected and high-risk areas (“CAHRAs”). RMI also manages the Responsible Minerals Assurance Process (the “RMAP”), which implements a risk-based audit program for SORs. We are a member of the RMI (member identifier = ITWI) and actively participate in its initiatives, as discussed later in this Conflict Minerals Report.
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 www.itw.com/suppliers/) mandates humane treatment and compliance with all laws, and in
particular prohibits use of child or forced labor, and discrimination, and mandates compliance with safety rules, wage and hour laws, international trade laws and anti-bribery laws.
E.Smelter and Refiner and Country of Origin Information
The Company’s in-scope products that contain 3TG that originated or might have originated from a Covered Country are described in Section IV. Product Information. For 2021, we have not found that any of the 3TG contained in our in-scope products directly or indirectly financed or benefited armed groups in a Covered Country. However, we have not concluded that any of our products are “DRC conflict free.” Information about SORs relating to our in-scope products containing 3TG is described in Section V. Identified Smelters and Refiners and on Annex A.
The terms “adjoining country,” “armed group,” and “DRC conflict free” have the meanings contained in the Conflict Minerals Rule.
F.2021 and 2022 Program Enhancements
1.2021 Program Enhancements
For 2021, we took the following actions to enhance our RCOI and 3TG due diligence and mitigate sourcing risk. In accordance with our practice of continuous improvement, these actions build on our insights and efforts in prior years.
Enhanced Smelter Engagement
•We continued to increase our participation in the RMI’s Mineral Reporting Template (“MRT”) and smelter engagement teams and continued our active participation in the RMI’s due diligence practices, multi-stakeholder and plenary calls, contributing perspective and recommendations we believe to be of benefit to RMI members;
•We led an RMI subteam responsible for researching newly identified potential SORs; and
•We continued our active participation and leadership in the Automotive Industry Action Group’s (“AIAG”) Responsible Materials Working Group as well as on their smelter engagement, industry best practices, and global requirements and minerals sensing sub-teams, contributing Tier 1 perspective and insight.
General Process Enhancements
•We continued to review past data to improve our written communications and to follow up with our businesses regarding supplier red flags to enhance the effectiveness of our 3TG compliance program; in particular, we believe that our enhancements in 2021 contributed to an improvement in our supplier response rate, which increased by 6% from our response rate in 2020.
•We joined the “Drive +” organization, made up of Tier 1 automotive suppliers, in June of 2021. The intention of Drive + is to collaborate with the Drive Sustainability automotive OEM organization to integrate sustainability into overall procurement processes, including with respect to sustainable raw materials.
2.2022 Program Enhancements
In 2022, we updated our Conflict Minerals Policy (which is now referred to as our Responsible Materials Policy), as further discussed below.
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 the 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 policy (formerly the “Conflict Minerals Policy,” most recently updated in the second quarter of 2022 and now known as our “Responsible Materials Policy”), which has been approved by ITW’s Chairman and Chief Executive Officer and is available in seven languages on our website at www.itw.com/suppliers/. We also provide a copy of ITW’s Responsible Materials Policy to potential suppliers participating in our online bid portal process whose products contain or may contain 3TG.
Our Responsible Materials Policy states that:
•We do not knowingly procure 3TG that originates from a CAHRA unless processed by SORs that are verified or in the process of becoming verified as “conflict free.”
•Our due diligence processes and efforts conform to the relevant portions of the OECD Guidance.
•Our due diligence requests to our suppliers are supported by our Supplier Code of Conduct, which is described below, and our Terms and Conditions of Purchase.
•If we discover that products procured by us contain 3TG from CAHRAs that are processed by facilities that are not conflict free or in the process of becoming conflict free, we will take steps to transition the products to conflict free sources.
•We do not seek to embargo responsibly sourced 3TG from CAHRAs as doing so could be detrimental to the legitimate economies and communities of those areas, and our suppliers are encouraged to continue support of conflict free SORs in CAHRAs and to take similar measures with their supply chains.
•The information provided by our suppliers is used to conduct our due diligence and to inform our risk assessments and risk mitigation activities and in the development of our Conflict Minerals Report and Form SD.
ITW’s Supplier Code of Conduct (which can be found at www.itw.com/suppliers/) 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, including responsible sourcing of materials and an expectation of the same commitment from their suppliers, and specifically prohibits certain behaviors and conditions associated with 3TG mining and processing, including use of child or forced labor, unsafe working conditions, corruption and bribery. The Supplier 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.
2. Cross Functional Committee
ITW has a cross-functional responsible sourcing committee (the “Committee”). The Committee is headed by ITW’s Vice President of Global Strategic Sourcing & Environmental Health and Safety, who reports to ITW’s Vice Chairman, and includes dedicated strategic sourcing, environmental, legal, internal audit, IT, trade compliance and corporate communications. Our compliance efforts are supplemented by specialist outside counsel. The Committee meets quarterly to discuss the 3TG compliance process, minerals beyond the 3TG compliance process, modern slavery, restricted party screening and other responsible supply chain developments. Senior management is briefed on the results of our RCOI and due diligence efforts on a regular basis.
3. Internal Training
We maintain an internal responsible sourcing webpage, 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 training videos regarding our RCOI and due diligence process, and
is accessible by all ITW businesses at any time. We continually encourage our businesses to review the training videos prior to sending RCOI requests to suppliers.
4. Supplier Engagement and Training
In addition to our Responsible Materials Policy and Supplier Code of Conduct, ITW’s standard “Terms and Conditions” obligate our 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 has an established protocol for its supplier inquiry process and uses a third-party software vendor whose role is to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool (the “CM System”).
Our supplier invitation letters are translated into eight languages. We encourage our businesses’ use of RMI’s eLearning Academy for supplier training, 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
All ITW colleagues are encouraged to share any ethics or compliance concerns through multiple channels, including to their local management teams, the Legal department, Internal Audit or our confidential Helpline. ITW partners with EthicsPoint, an external third-party supplier, to provide a web- and telephone-based confidential reporting system in 43 countries. Web-based reporting is offered in 16 languages, and telephone-based reporting is offered in more than 200 languages. The EthicsPoint reporting system is also available to suppliers and other external stakeholders through a public domain website. ITW has a no retaliation policy for good faith reporting.
All reports are investigated promptly and appropriately and regular updates are provided to the Audit Committee of the Board of Directors.
ITW’s Responsible Materials Policy, Supplier Code of Conduct, and Modern Slavery and Human Trafficking Statement each contain links to the ITW Confidential Helpline (which is available at itwhelpline.ethicspoint.com) so that external stakeholders, suppliers, and other third parties have a channel for reporting any concerns they may have, including with respect to ITW’s supply chain.
As an RMI member, we also support the use of the RMI’s grievance mechanism for reporting grievances relating to SORs and
the RMAP.
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 3TG sourcing risk in our supply chain for the 2021 reporting cycle.
For 2021, our 3TG working team, together with various members of our sourcing department, compiled a list of the Company’s “80” suppliers by segment (i.e., the most significant suppliers) that have or are likely to have 3TG in their products, and distributed the list to our businesses with products containing or likely to contain 3TG. Those businesses were asked to further refine the list by identifying their own “80” suppliers and were instructed to survey those suppliers (we refer to the surveyed suppliers for 2021 as the “Suppliers”). We asked our businesses to concentrate their outreach on their “80” suppliers because these suppliers are the most likely to be recurring suppliers and responsible for a significant portion of the 3TG in our products.
The purpose of the Supplier survey was to determine whether 3TG in the components, parts or products from the Suppliers originated or may have originated from the Covered Countries and were not from recycled or scrap sources. Businesses were
instructed to survey the Suppliers using the then latest version of the CMRT. The CMRT requests information regarding 3TG included in suppliers’ products, SOR identity and location, suppliers’ RCOI processes and other information about the suppliers’ 3TG policies and practices.
ITW has an established protocol for its supplier inquiry process and uses the CM System, a third-party software vendor whose role is to support our process for coordinating and tracking RCOI and due diligence interactions between ITW businesses, their customers and in-scope suppliers through use of a cloud-based 3TG tracking tool.
We sent 1,674 requests in eight languages to the Suppliers to provide us with a completed CMRT, as compared to 1,872 requests sent for 2020. The number of queried Suppliers decreased year-over-year due to further enhanced internal scoping. A number of our businesses source different products from the same Supplier, which means the total number of unique Suppliers is less than the number of Suppliers queried. We received 1,295 completed CMRTs from the Suppliers surveyed, compared to 1,334 received for 2020. Since our earliest report in 2014, our supplier response rate has improved steadily year-over-year, and increased from 71% for 2020 to 77% for 2021.
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 raised “red flags.” See Section III. Due Diligence for a description of the follow-up process.
Our Supplier responses identified 237 SORs verified by the RMI as Conformant. We determined that 43 of these Conformant SORs sourced in whole or in part from within the Covered Countries. Our determination was based on country-of-origin information the RMI has obtained through the RMAP that is made available to RMI members.
Our Supplier responses also identified an additional 19 SORs that were listed as “Active” (as later defined in Section III.B.) by the RMI and 128 that were listed on the Smelter Look-up tab of the CMRT but were not Conformant or Active.
Based on the results of our RCOI, we were required to conduct due diligence, as described below.
III.Due Diligence
A.Design Framework
ITW’s conflict minerals due diligence process is designed in conformance with the 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 2021 and 2022 program enhancements 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 list in the CMRT. SOR information also was reviewed against the lists of Conformant, Active, and other SORs not listed as Conformant or Active and country-of-origin information provided by the RMI and contained in the CM System. “Conformant” SORs have been audited and are conformant with the RMAP assessment protocols, including those listed as “re-audit in progress.” “Active” SORs are those that have committed to undergo an RMAP assessment, completed the relevant documents and scheduled the on-site assessment. These may be in the pre-assessment, assessment or corrective-action phases of the assessment.
CMRTs received from our Suppliers that indicated 3TG from a source within a Covered Country triggered a “red flag” in the CM System, and communications with the flagged Suppliers were escalated. Businesses and their respective flagged Suppliers indicating 3TG from a source within a Covered Country were asked to provide additional information, and our businesses were given written guidance and instructions for these Supplier communications. The escalated Supplier responses were evaluated on a case-by-case basis. For our 2021 compliance, we continued to review past data to improve our written communications and to follow up with our businesses regarding supplier red flags.
In addition, we reached out directly to the SORs that were not listed as Conformant or Active by the RMI and asked them to become Conformant. Entities that the RMI has determined are either not SORs or not in operation were not addressed in our outreach efforts. We seek to exercise leverage over SORs that are neither Conformant nor Active through our participation in and support of the RMI and its Smelter Engagement Team, and we utilize information provided by the RMI to its members to help us monitor SOR improvement. Finally, we screen our smelters with a restricted party screening software to alert us if our SORs are sanctioned or on various government watchlists. As a result of our ongoing due diligence activities for 2021, we have thus far identified a number of SORs that are neither Conformant nor Active or that otherwise fail to meet our supplier requirements and intend to take steps to remove these smelters from our supply chain.
Our 3TG working team reported the findings from its RCOI and due diligence process to our Vice President of Global Strategic Sourcing, and these results were in turn discussed with senior management.
Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
The Company continued its membership in the RMI for 2021. Due to our location in the mineral supply chain, which is discussed earlier in this Conflict Minerals Report, we support and utilize the RMI’s RMAP to perform third-party audits of SORs, as well as the London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”) gold audit standards, which RMI cross-recognizes. Additionally, we continued our voluntary contribution to RMI’s Initial Audit Fund, managed by RMI, meant to encourage RMAP-eligible smelters to undergo an independent third-party assessment and participate in its annual review process by fully paying for the costs of the SOR initial audit.
Report annually on supply chain due diligence
We describe our supply chain due diligence efforts in this annual Conflict Minerals Report. We post this report 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 at www.itw.com/suppliers/. We also refer to our efforts relating to conflict minerals and further efforts to source our minerals responsibly in our annual Sustainability Report, which is available on our website at https://www.itw.com/sustainability/itw-sustainability/.
IV.Product Information
For 2021, our in-scope products that contain 3TG that originated or might have originated from a Covered Country included products in each of the categories below:
| | | | | |
| Air delivery equipment | Industrial equipment |
| Automotive components | Industrial ovens |
| Commercial cooking equipment | Industrial warewashers |
| Commercial food equipment | Inspection equipment |
| Commercial refrigerators | LED lamps & displays |
| Electrical enclosures | Measuring equipment |
| Electronic components & devices | Power sources |
| Electronic equipment | Printers & dispensers |
| Electronic safety product | Production equipment |
| Fastening tools | Sealing equipment |
| Flow control meters | Solder products |
| Foam | Switches |
| | | | | |
| Ground support equipment | Testing equipment |
| Industrial cleaners & cleaning equipment | Welding hardware |
V. Identified Smelters and Refiners
As stated above, our Supplier responses identified 237 SORs that were on the RMI Conformant lists, 19 that were listed as Active with the RMI and 128 that were on the Smelter list of the CMRT but not listed as Conformant or Active by the RMI. Those facilities are listed on Annex A. The information on Annex A includes only information regarding the SORs identified by our Suppliers that were on the Smelter list contained in the CM System as of February 17, 2022. Entities identified by our Suppliers that are not on Annex A have been submitted to the RMI 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 cannot provide absolute certainty regarding the source and chain of custody of the necessary 3TG contained in our in-scope 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 on 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, because we did not obtain a response from all Suppliers surveyed, some Suppliers were unable to identify all of the SORs in their supply chain, and we surveyed only the larger suppliers of products containing or potentially containing 3TG.
Annex A includes information concerning the locations of the SORs listed. We utilized the information made available to RMI members regarding the potential countries of origin of the 3TG processed by these SORs and did not find for 2021 that any of our in-scope products contained necessary 3TG that directly or indirectly financed or benefited an armed group in a Covered Country.
VI.Additional Risk Mitigation
In addition to the actions described elsewhere in this Conflict Minerals Report, we intend to take or continue the following steps in respect of our 2022 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;
•Continue to enhance supplier and internal communications and training to improve RCOI and due diligence data accuracy and completeness;
•Continue to seek to influence non-Conformant SORs in our supply chain to obtain a Conformant designation;
•Continue our membership in the RMI and active participation in its Plenary, Multi-Stakeholder, Due Diligence, Smelter Engagement and MRT Teams and support the RMAP;
•Continue our membership and active participation in the AIAG Responsible Materials Working Group and its global requirements and minerals sensing, industry best practices and smelter engagement subteams;
•Continue our membership in Drive+ and participation in various subteams;
•Continue to submit to the RMI facilities identified by our suppliers that have not yet been identified by the RMI as SORs, to support the RMI’s ongoing effort to identify and audit all 3TG SORs;
•Continue to send tailored communications to SORs believed to be in our supply chain who are either scheduled to undergo RMI re-audit or are not fulfilling RMI audit requirements, encouraging them to go through the re-audit process or to continue fulfilling their audit requirements; and
•Continuous evaluation of supplier CMRT response failures to assist our businesses in the collection of their supplier assessments.
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, incomplete information from industry or other third-party sources, continuing guidance regarding the Conflict Minerals Rule and the enactment of laws and rules in other jurisdictions, decisions to make changes to our continual improvement efforts and delays or difficulties in engaging suppliers and/or transitioning sources of product containing 3TG.
| | |
| Annex A to Exhibit 1.01 |
| RMI Smelters and Refiners |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Gold | 8853 S.p.A. | ITALY | Conformant |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Conformant |
| Gold | Agosi AG | GERMANY | Conformant |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Conformant |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Conformant |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Conformant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Conformant |
| Gold | Asahi Pretec Corp. | JAPAN | Conformant |
| Gold | Asahi Refining Canada Ltd. | CANADA | Conformant |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Gold | Aurubis AG | GERMANY | Conformant |
| Gold | Bangalore Refinery | INDIA | Conformant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Conformant |
| Gold | Boliden AB | SWEDEN | Conformant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Conformant |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Conformant |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Conformant |
| Gold | Chimet S.p.A. | ITALY | Conformant |
| Gold | Chugai Mining | JAPAN | Conformant |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Conformant |
| Gold | Dowa | JAPAN | Conformant |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Conformant |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Conformant |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Conformant |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Conformant |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Conformant |
| Gold | Heimerle + Meule GmbH | GERMANY | Conformant |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | Conformant |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Conformant |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Conformant |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | Istanbul Gold Refinery | TURKEY | Conformant |
| Gold | Italpreziosi | ITALY | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Gold | Japan Mint | JAPAN | Conformant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Conformant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Conformant |
| Gold | Kazzinc | KAZAKHSTAN | Conformant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Conformant |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Conformant |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Conformant |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | L'Orfebre S.A. | ANDORRA | Conformant |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Conformant |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | Marsam Metals | BRAZIL | Conformant |
| Gold | Materion | UNITED STATES OF AMERICA | Conformant |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Conformant |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Conformant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Conformant |
| Gold | Metalor Technologies S.A. | SWITZERLAND | Conformant |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Conformant |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Conformant |
| Gold | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Conformant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Conformant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Conformant |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Conformant |
| Gold | Nihon Material Co., Ltd. | JAPAN | Conformant |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Conformant |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Conformant |
| Gold | PAMP S.A. | SWITZERLAND | Conformant |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Conformant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Conformant |
| Gold | PX Precinox S.A. | SWITZERLAND | Conformant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Conformant |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | Conformant |
| Gold | Royal Canadian Mint | CANADA | Conformant |
| Gold | SAAMP | FRANCE | Conformant |
| Gold | Safimet S.p.A | ITALY | Conformant |
| Gold | SAFINA A.S. | CZECHIA | Conformant |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Conformant |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | Conformant |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Conformant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Conformant |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Conformant |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Conformant |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Gold | T.C.A S.p.A | ITALY | Conformant |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Conformant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Conformant |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Conformant |
| Gold | Torecom | KOREA, REPUBLIC OF | Conformant |
| Gold | Umicore Precious Metals Thailand | THAILAND | Conformant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Conformant |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Conformant |
| Gold | Valcambi S.A. | SWITZERLAND | Conformant |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Conformant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Conformant |
| Gold | Yamakin Co., Ltd. | JAPAN | Conformant |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Conformant |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Conformant |
| Gold | Alexy Metals | UNITED STATES OF AMERICA | Active |
| Gold | Augmont Enterprises Private Limited | INDIA | Active |
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | Active |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | Active |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | Active |
| Gold | WEEEREFINING | FRANCE | Active |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA | On Smelter Look-up List |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | African Gold Refinery | UGANDA | On Smelter Look-up List |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | On Smelter Look-up List |
| Gold | AU Traders and Refiners | SOUTH AFRICA | On Smelter Look-up List |
| Gold | Caridad | MEXICO | On Smelter Look-Up List |
| Gold | CGR Metalloys Pvt Ltd. | INDIA | On Smelter Look-up List |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | On Smelter Look-up List |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | On Smelter Look-up List |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | On Smelter Look-up List |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | On Smelter Look-up List |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | On Smelter Look-up List |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Gold Coast Refinery | GHANA | On Smelter Look-up List |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | On Smelter Look-up List |
| Gold | Guangdong Jinding Gold Limited | CHINA | On Smelter Look-up List |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Industrial Refining Company | BELGIUM | On Smelter Look-up List |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | JALAN & Company | INDIA | On Smelter Look-up List |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Refiners | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | K.A. Rasmussen | NORWAY | On Smelter Look-up List |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | On Smelter Look-up List |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | On Smelter Look-up List |
| Gold | Kundan Care Products Ltd. | INDIA | On Smelter Look-up List |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | On Smelter Look-up List |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | On Smelter Look-up List |
| Gold | Lingbao Gold Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | MD Overseas | INDIA | On Smelter Look-up List |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Modeltech Sdn Bhd | MALAYSIA | On Smelter Look-up List |
| Gold | Morris and Watson | NEW ZEALAND | On Smelter Look-up List |
| Gold | Morris and Watson Gold Coast | AUSTRALIA | On Smelter Look-up List |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Gold | Sai Refinery | INDIA | On Smelter Look-up List |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | On Smelter Look-up List |
| Gold | Sellem Industries Ltd. | MAURITANIA | On Smelter Look-up List |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | Shirpur Gold Refinery Ltd. | INDIA | On Smelter Look-up List |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | On Smelter Look-up List |
| Gold | Sovereign Metals | INDIA | On Smelter Look-up List |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | On Smelter Look-up List |
| Gold | Sudan Gold Refinery | SUDAN | On Smelter Look-up List |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | On Smelter Look-up List |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | On Smelter Look-up List |
| Gold | TSK Pretech | KOREA, REPUBLIC OF | On Smelter Look-up List |
| Gold | Umicore Brasil Ltda. | BRAZIL | On Smelter Look-up List |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | On Smelter Look-up List |
| Gold | Value Trading | BELGIUM | On Smelter Look-up List |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Tantalum | AMG Brasil | BRAZIL | Conformant |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Conformant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Conformant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Conformant |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Conformant |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Conformant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | Conformant |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Conformant |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Conformant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | KEMET de Mexico | MEXICO | Conformant |
| Tantalum | Meta Materials | NORTH MACEDONIA, REPUBLIC OF | Conformant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Conformant |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Conformant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Conformant |
| Tantalum | NPM Silmet AS | ESTONIA | Conformant |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Conformant |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Conformant |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | Conformant |
| Tantalum | TANIOBIS GmbH | GERMANY | Conformant |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | Conformant |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Conformant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Conformant |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Conformant |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Conformant |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Conformant |
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | On Smelter Look-up List |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tin | Alpha | UNITED STATES OF AMERICA | Conformant |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | China Tin Group Co., Ltd. | CHINA | Conformant |
| Tin | CRM Synergies | SPAIN | Conformant |
| Tin | Dowa | JAPAN | Conformant |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | Estanho de Rondonia S.A. | BRAZIL | Conformant |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Fenix Metals | POLAND | Conformant |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Conformant |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Conformant |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Conformant |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Conformant |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Conformant |
| Tin | Luna Smelter, Ltd. | RWANDA | Conformant |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | Conformant |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Conformant |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Conformant |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Conformant |
| Tin | Metallo Belgium N.V. | BELGIUM | Conformant |
| Tin | Metallo Spain S.L.U. | SPAIN | Conformant |
| Tin | Mineracao Taboca S.A. | BRAZIL | Conformant |
| Tin | Minsur | PERU | Conformant |
| Tin | Mitsubishi Materials Corporation | JAPAN | Conformant |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | Conformant |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Conformant |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Conformant |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Conformant |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Conformant |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Conformant |
| Tin | PT Babel Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Conformant |
| Tin | PT Bangka Serumpun | INDONESIA | Conformant |
| Tin | PT Cipta Persada Mulia | INDONESIA | Conformant |
| Tin | PT Menara Cipta Mulia | INDONESIA | Conformant |
| Tin | PT Mitra Stania Prima | INDONESIA | Conformant |
| Tin | PT Prima Timah Utama | INDONESIA | Conformant |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | Conformant |
| Tin | PT Rajehan Ariq | INDONESIA | Conformant |
| Tin | PT Refined Bangka Tin | INDONESIA | Conformant |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Conformant |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Conformant |
| Tin | PT Timah Tbk Kundur | INDONESIA | Conformant |
| Tin | PT Timah Tbk Mentok | INDONESIA | Conformant |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Conformant |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Conformant |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Conformant |
| Tin | Soft Metais Ltda. | BRAZIL | Conformant |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | Conformant |
| Tin | Thaisarco | THAILAND | Conformant |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Conformant |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Conformant |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Conformant |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Active |
| Tin | CV Venus Inti Perkasa | INDONESIA | Active |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Active |
| Tin | PT Bukit Timah | INDONESIA | Active |
| Tin | PT Masbro Alam Stania | INDONESIA | Active |
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Active |
| Tin | PT Sukses Inti Makmur | INDONESIA | Active |
| Tin | PT Timah Nusantara | INDONESIA | Active |
| Tin | Super Ligas | BRAZIL | Active |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | On Smelter Look-up List |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | CV Ayi Jaya | INDONESIA | On Smelter Look-up List |
| Tin | CV Dua Sekawan | INDONESIA | On Smelter Look-up List |
| Tin | CV Gita Pesona | INDONESIA | On Smelter Look-up List |
| Tin | CV United Smelting | INDONESIA | On Smelter Look-up List |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | On Smelter Look-up List |
| Tin | Gejiu Jinye Mineral Company | CHINA | On Smelter Look-up List |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | On Smelter Look-up List |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | On Smelter Look-up List |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | On Smelter Look-up List |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | On Smelter Look-up List |
| Tin | Modeltech Sdn Bhd | MALAYSIA | On Smelter Look-up List |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | Pongpipat Company Limited | MYANMAR | On Smelter Look-up List |
| Tin | Precious Minerals and Smelting Limited | INDIA | On Smelter Look-up List |
| Tin | PT Bangka Prima Tin | INDONESIA | On Smelter Look-up List |
| Tin | PT Bangka Tin Industry | INDONESIA | On Smelter Look-up List |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | On Smelter Look-up List |
| Tin | PT DS Jaya Abadi | INDONESIA | On Smelter Look-up List |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | On Smelter Look-up List |
| Tin | PT Inti Stania Prima | INDONESIA | On Smelter Look-up List |
| Tin | PT Karimun Mining | INDONESIA | On Smelter Look-up List |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | On Smelter Look-up List |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | On Smelter Look-up List |
| Tin | PT Panca Mega Persada | INDONESIA | On Smelter Look-up List |
| Tin | PT Premium Tin Indonesia | INDONESIA | On Smelter Look-up List |
| Tin | PT Sumber Jaya Indah | INDONESIA | On Smelter Look-up List |
| Tin | PT Tirus Putra Mandiri | INDONESIA | On Smelter Look-up List |
| Tin | PT Tommy Utama | INDONESIA | On Smelter Look-up List |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | On Smelter Look-up List |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | On Smelter Look-up List |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | A.L.M.T. Corp. | JAPAN | Conformant |
| Tungsten | ACL Metais Eireli | BRAZIL | Conformant |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Conformant |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Conformant |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Conformant |
| Tungsten | Fujian Xinlu Tungsten | CHINA | Conformant |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Conformant |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Conformant |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Conformant |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Conformant |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Conformant |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Conformant |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Conformant |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd. | CHINA | Conformant |
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | Conformant |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Conformant |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Conformant |
| | | | | | | | | | | |
| Mineral | Smelter or Refiner Name | Smelter or Refiner Country | Smelter or Refiner
Status |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Masan High-Tech Materials | VIET NAM | Conformant |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Conformant |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Conformant |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Conformant |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Conformant |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Conformant |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Conformant |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | Conformant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Conformant |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Conformant |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Conformant |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | Active |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | Active |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | Active |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | Active |
| Tungsten | Artek LLC | RUSSIAN FEDERATION | On Smelter Look-up List |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | CP Metals Inc. | UNITED STATES OF AMERICA | On Smelter Look-up List |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | On Smelter Look-up List |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | On Smelter Look-up List |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | On Smelter Look-up List |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | On Smelter Look-up List |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | On Smelter Look-up List |
Country of Origin Information
The countries of origin of the newly-mined 3TG processed by the Conformant SORs listed above may have included the countries listed below, as well as possibly other countries. We did not determine the possible countries of origin of the 3TG processed by any other SORs listed on this Annex A. The listed countries of origin are derived from information made available by the RMI to its members, which includes LBMA Good Delivery List and RJC Chain of Custody Certification information. Because the RMI generally does not indicate individual countries of origin of the 3TG processed by Conformant SORs, we were not able to determine the countries of origin of the newly-mined 3TG processed by the listed Conformant SORs with greater specificity. According to information made available by the RMI 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 countries indicated below.
| | | | | | | | |
| Argentina | Hungary | Paraguay |
| Armenia | Iceland | Peru |
| Australia | India | Philippines |
| Austria | Indonesia | Poland |
| Azerbaijan | Ireland | Portugal |
| Belgium | Israel | Romania |
| Benin | Italy | Russian Federation |
| Bolivia (Plurinational State of) | Ivory Coast | Rwanda* |
| Botswana | Japan | San Marino |
| Brazil | Jordan | Saudi Arabia |
| Brunei | Republic of Korea | Senegal |
| Bulgaria | Kazakhstan | Serbia |
| Burkina Faso | Kenya | Sierra Leone |
| Burundi* | Kuwait | Singapore |
| Cambodia | Kyrgyzstan | Slovakia |
| Cameroon | Laos | Slovenia |
| Canada | Latvia | Solomon Islands |
| Chile | Lebanon | Somaliland |
| China | Liberia | South Africa |
| Colombia | Liechtenstein | Spain |
| Croatia | Lithuania | Sudan |
| Cuba | Luxembourg | Suriname |
| Cyprus | Macau | Swaziland |
| Czech Republic | Madagascar | Sweden |
| Democratic Republic of the Congo* | Malaysia | Switzerland |
| Denmark | Mali | Taiwan |
| Dominican Republic | Malta | Tanzania* |
| Ecuador | Mauritania | Tajikistan |
| Egypt | Mauritius | Thailand |
| El Salvador | Mexico | Togo |
| Eritrea | Mongolia | Trinidad and Tobago |
| Estonia | Morocco | Tunisia |
| Ethiopia | Mozambique | Turkey |
| Fiji | Myanmar | Ukraine |
| Finland | Namibia | United Arab Emirates |
| | | | | | | | |
| France | Netherlands | United Kingdom of Great Britain and Northern Ireland |
| Gambia | New Caledonia | Uganda* |
| Georgia | New Zealand | United States of America |
* Covered Country.
