Exhibit 1.01
The Manitowoc Company, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2017
Part I.Introduction
This is the Conflict Minerals Report (the “Report”) of The Manitowoc Company, Inc. (the “Company,” “we,” “us” or “our”) for calendar year 2017 in accordance with Rule 13p-1 under the Securities and Exchange Act of 1934 (“the Rule”). This Report discusses the Company’s efforts to determine whether any of the products it manufactures or contracts to be manufactured contain columbite-tantalite (coltan), cassiterite, gold, wolframite or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “3TGs”), that are necessary to the functionality or production of such products that may have originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”) or are from recycled or scrap sources.
Part II.Company and Product Overview
Founded in 1902, The Manitowoc Company, Inc. is a leading global manufacturer of cranes and lifting solutions with manufacturing, distribution, and service facilities in 20 countries. Manitowoc is recognized as one of the premier innovators and providers of crawler cranes, tower cranes, and mobile cranes for the heavy construction industry, which are complemented by a slate of industry-leading aftermarket product support services. In 2017, Manitowoc’s net sales totaled $1.58 billion, with over half generated outside the United States. Additionally, our Manitowoc Crane Care offering leverages Manitowoc’s installed base of approximately 143,000 cranes to provide aftermarket parts and services to enable our customers to manage their fleets more effectively and improve their return on investment. Due to the ongoing and predictable maintenance needed by cranes, as well as the high cost of crane downtime, Crane Care provides us with a consistent stream of recurring aftermarket revenue.
Our Conflict Minerals Steering Committee, which includes members of Strategic Purchasing and Corporate Legal (the “Committee”), conducted an analysis of our manufacturing operations and supply chain (the “applicability assessment”) and identified 3TGs that are necessary to the functionality or production of the Products we manufactured or contracted to be manufactured during calendar year 2017. Our Products generally contain (in varying degrees and amounts) some 3TGs necessary to their functionality or production.
Part III.Reasonable Country of Origin Inquiry (“RCOI”)
We began our scoping process identifying a list of our Products that may contain 3TG and then we extracted a list of our suppliers who provide us with products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the supplier list with contact information and provided the list to our third-party service provider. We also included a list of associated parts for these suppliers to ensure that suppliers have the option of completing their CMRT (as defined below) on the product or company level. This supplier list was then uploaded to our third-party provider’s software platform that allows us to store and manage supplier requests and documentation.
From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and inactive suppliers. This ensures that all suppliers surveyed provided items to the Company that were used in final Products in the year 2017. Through this process, we determined that 381 suppliers were in scope for the 2017 reporting period.
Our service provider then conducted the supplier survey portion of the RCOI. Utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 5.01 or higher, developed by the Responsible Business Alliance (“RBA”) and The Global e-Sustainability Initiative (“GeSI”), the suppliers identified through the procedures
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described above were surveyed on their sourcing of the 3TGs that we identified in our Products. The CMRT includes questions regarding a direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain, such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.
During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in our third-party provider’s software platform. Non-responsive suppliers were contacted a minimum of three times by our service provider’s Supply Chain Team as well as by Manitowoc personnel in one-on-one communications. This included four follow-ups to encourage their response via the CMRT.
To ensure that our suppliers understood our expectations regarding the sourcing of 3TGs, we provided training through webinars, videos, documentation, and one-on-one discussions. We continued to put a strong emphasis on supplier education and training. To accomplish this, we utilized a Learning Management System, Assent University, and provided all in-scope suppliers access to Assent’s Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation was to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms were accepted and classified as valid or invalid so that data was retained. All suppliers who submitted CMRTs that were flagged as “invalid” were contacted at least twice to address items such as incomplete data, missing smelter information, or inconsistent answers. These communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 1, 2018, we had received responses from 77.5% of the suppliers surveyed (there were 11 invalid submissions that were not corrected by suppliers).
Based on the RCOI, we determined that we may have some suppliers who sourced 3TGs from the Covered Countries. Therefore, in an effort to identify mines with the greatest possible specificity, we conducted due diligence on our supplier base, as described below.
Part IV.Due Diligence
In accordance with Securities and Exchange Commission (“SEC”) rules, the Company undertook due diligence efforts to determine whether the 3TGs in the Products it manufactures, or contracts to manufacture, that are necessary to the functionality or production of its Products originated in the Covered Countries or are from recycled or scrap sources. The Company designed its due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework set forth in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and related supplements for each of the Conflict Minerals (the “OECD Guidance”).
Our due diligence process for 2017 included the steps described below:
Step 1: Establish strong Company management systems
We are committed to the responsible sourcing of our Products and we expect the same from our suppliers, including ensuring that the products or components supplied to us do not directly or indirectly finance or benefit armed groups in the Covered Countries. Our suppliers are required to support our efforts to comply with the Rule. We have developed a Conflict Minerals Policy, which is available on our website (www.manitowoc.com) under Investor Relations–Corporate Governance–Governance Highlights–Other Governance Documents (http://ir.manitowoc.com/investor-relations/corporate-governance/governance-documents/default.aspx). In addition, our standard supplier terms and conditions address our expectations related to any 3TGs supplied to us. We also have a Company-level mechanism to enable the reporting of grievances.
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We established a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including with respect to conflict minerals. Suppliers and others outside the Company may contact our conflict minerals team to communicate with us, including to report grievances, via a dedicated email address that is published in our conflict minerals policy and in other communications with our suppliers. In addition, our employees may anonymously report suspected violations using Manitowoc’s Corporate Governance/Whistleblower Hotline, available 24 hours a day, seven days a week. The Company’s Corporate Governance/Whistleblower Hotline is staffed by non-Manitowoc personnel, who share any information reported with our General Counsel and our Audit Committee.
The Committee, which includes multiple internal stakeholder representatives and reports to the Company’s senior leadership, oversees supplier due diligence regarding Conflict Minerals. The Committee is also responsible for educating procurement and supply chain employees, revising supplier terms and conditions to include our Conflict Minerals expectations, and overseeing the preparation of the Form SD and this Report. The Committee also has the authority to engage consultants and advisors to assist with its efforts.
Building on the process the Committee implemented in previous years, in 2017 the Committee analyzed the Company’s manufacturing operations and supply chain to identify the Products that we manufacture or contract to manufacture that might contain 3TGs. Based on that process, the Committee worked with the Company’s engineering, manufacturing, and supply chain management teams as well as our service provider to identify, engage with, and make appropriate inquiries of our suppliers to determine, based on a RCOI, whether the Company may be sourcing 3TGs from the Covered Countries. We also sought to strengthen engagement with suppliers by developing an internal procedure that includes steps for supplier engagement escalations, including direct follow ups from Company personnel and our third-party service provider.
The Company retained information regarding its due diligence efforts for 2017 in accordance with its existing record retention policies and procedures.
Step 2: Identify and assess risk in the supply chain
Our due diligence efforts were based on a survey process in which we requested certain information from selected suppliers who we believed may be providing parts or components containing 3TGs by using the CMRT, as previously discussed. More specifically, the Committee oversaw the following:
| • | A supply chain survey of those direct suppliers identified during the applicability assessment and ROCI who the Company believed represented the highest risk of supplying parts or components that may contain 3TGs from the Covered Countries. |
| • | Automated data validation on all submitted CMRT responses. All invalid responses were flagged and the applicable suppliers were contacted at least twice to correct their CMRT. |
| • | A comparison of the smelters and refiners that were identified by the Company’s suppliers against the list maintained by the Responsible Minerals Initiative (“RMI”) to assist in the supplier risk assessment. |
| • | Periodic reporting to senior management regarding the results of the survey and related risk assessment. |
Certain of the responses to the CMRT included the names of facilities listed by the suppliers as smelters or refiners of 3TGs. As a downstream consumer of 3TGs, we do not have direct relationships with smelters and refiners of 3TGs and do not perform or direct audits of these entities. Our service provider compared the facilities listed by our suppliers to the list of smelters and refiners maintained by the RMI. If a supplier indicated that the facility was identified as “conformant,” our service provider first confirmed that the name of the smelter or refiner was included on the published list as an active facility. As of May 1, 2018, we had validated 321 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs.
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In order to assess the risk that any of these smelters or refiners posed to our supply chain, we determined if the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). In cases where the smelter’s due diligence practices have not been audited against the standard, a potential risk exists. Of the valid facilities identified, 257 have been identified as conformant by the RMAP standard and an additional 11 have committed to or are currently undergoing an audit through the RMAP. Due to the provision of primarily company or divisional level CMRTs by our suppliers, as opposed to product-level CMRTs, we cannot definitively determine the connection of their 3TGs (if any) to our Products.
Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance. Our third-party service provider utilizes the following three scoring criteria to determine the level of risk that each smelter or refiner poses to the supply chain by identifying red flags:
| • | Geographic proximity to the DRC and covered countries; |
| • | RMAP audit status; and |
| • | Credible evidence of unethical or conflict sourcing. |
Additionally, suppliers were evaluated on the strength of their sourcing program, which further assisted in identifying risk in the supply chain and in making key risk mitigation decisions. The following questions from the CMRT were used to evaluate the strength of each supplier’s program:
| • | Have you established a conflict minerals sourcing policy? |
| • | Have you implemented due diligence measures for conflict-free sourcing? |
| • | Do you review due diligence information received from your suppliers against your company’s expectations? |
| • | Does your review process include corrective action management? |
If a supplier answered “yes” to all of the questions above, it was deemed to have a strong 3TGs program. When a supplier did not meet any of those criteria, it was deemed to have a weak 3TGs program. Any supplier who is flagged as having a weak program will be contacted to encourage it to increase the strength of its program.
We believe that the inquiries and investigations described above, which included (1) seeking information about 3TGs smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT; (2) verifying those smelters and refiners with the expanding published lists; (3) conducting the due diligence review; and (4) obtaining additional documentation and verification, as applicable, represent a reasonable effort to determine the mines or locations of origin of the 3TGs in our Products.
Step 3: Design and implement a strategy to respond to identified risks
We completed a management reporting dashboard on a periodic basis summarizing the results of the risk assessment process. Other elements of the Company’s due diligence process designed to respond to identified risks included the following:
| • | Suppliers who did not respond to the Company’s initial survey request were sent at least three escalation communications requesting that they provide the information requested. |
| • | Suppliers who provided incomplete or inconsistent responses were sent follow-up communications, as previously discussed. Based on the type of risk identified during a review of supplier responses, suppliers were sent a corrective action communication. |
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Based on the smelter or refiner risk criteria noted above, the following facilities have been identified with red-flag risks in their supply chain:
| • | Tony Goetz NV - CID002587 |
| • | African Gold Refinery Limited (AGR) – CID003185 |
| • | Kaloti Precious Metals - CID002563 |
| • | Universal Precious Metals Refining Zambia - CID002854 |
| • | Fidelity Printers and Refiners - CID002515 |
| • | Sudan Gold Refinery - CID002567 |
As part of our risk management plan under the OECD Guidance, when these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third-party vendor, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take its own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Manitowoc, and escalating up to removal of these high-risk smelters from their supply chain. As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context.
If a supplier was unable to confirm that 3TGs supplied to us were sourced from a smelter or refiner that has been audited and certified as conflict-free, we requested that the supplier find alternative sources for 3TGs.
In addition, if, through our due diligence process, we became aware that one of our suppliers was sourcing 3TGs from the Covered Countries or was unable to determine the origin of the 3TGs supplied to us, our practice was to take the following steps:
| • | Determine whether the smelter or refiner that processed the 3TGs supplied by that supplier had been audited and certified as conflict-free by a reputable independent third party such as the RMI; |
| • | Notify the supplier of our Conflict Minerals Policy and expectations; and |
| • | Inform the supplier that if the supplier does not begin using conflict-free sources within a reasonable period, we may take appropriate steps including, but not limited to, replacing the supplier. |
Step 4: Third-party audit of smelters’/refiners’ due diligence practices
As a downstream consumer of 3TGs, the Company must rely on its direct suppliers to gather information about smelters and refiners in the supply chain. The Company does not purchase any 3TGs in their raw material form and, to the best of its knowledge, does not directly purchase any products or components directly from any of the Covered Countries. As a result, the Company does not perform or direct audits of smelters and refiners. Instead, we rely on third-party audits of smelters and refiners conducted as part of the RMAP, which uses independent private sector auditors to audit the source, including the mines of origin, and the chain of custody of the minerals used by smelters and refiners that agree to participate in the program.
Step 5: Report annually on supply chain due diligence
This Report and the related Form SD were publicly filed with the SEC and are available on our website (www.manitowoc.com) under Investor Relations–Corporate Governance–Governance Highlights–Other Governance Documents (http://ir.manitowoc.com/investor-relations/corporate-governance/governance-documents/default.aspx).
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Most of the supplier responses we received provided data at a company or divisional level. Therefore, based on our due diligence efforts, we are unable to determine whether the 3TGs reported by the suppliers were contained in the actual components or parts supplied to the Company. Due to this, our list of processing smelters or refiners may contain more facilities than those that actually processed the 3TGs contained in our Products.
The quality of the responses that we received from our surveyed suppliers continues to be varied. Many responses provided by suppliers (via the CMRT) included the names of facilities listed by the suppliers as smelters or refiners. The CMRTs submitted by suppliers that do not list at least one smelter for each 3TGs claimed on the CMRT are considered invalid and our third-party provider continues to follow up with these suppliers. In addition, there are still suppliers unable to provide the smelters or refiners used for 3TGs supplied to us.
For all responses that indicated a smelter, our third-party provider compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was identified as “DRC Conflict-Free,” our provider confirmed that the name was listed by RMI as a conformant smelter. No violations were identified. As of May 1, 2018, we had validated 321 smelters or refiners and we are working to validate the additional smelter or refiner entries from the submitted CMRTs.
Based on the smelter list provided by suppliers via the CMRTs and publicly available information, we have identified 257 smelters and refiners that are deemed RMAP Conformant – this indicates these smelters or refiners follow the RMAP audit protocols. There are 11 more smelters or refiners that have been deemed Active, meaning that they have committed to undergo a RMAP audit or are currently participating in one of the cross-recognized certification programs such as the LBMA Responsible Gold Certification or the Responsible Jewelry Program Chain-of-Custody Certification. The remaining 53 smelters and refiners have not yet been confirmed as conflict-free.
Appendix A to this Report lists the legitimate smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate as a legitimate smelter or refiner of 3TGs. The fact that the smelter or refiner is listed on Appendix A does not definitively indicate that 3TGs processed by such smelter or refiner were included in the Company’s Products. Appendix B to this Report includes an aggregated list of potential countries of origin from which the reported facilities collectively source 3TGs, based on information provided by our suppliers and the RMI; the fact that a country is listed on Appendix B does not definitively indicate that 3TGs in the Company’s Products were sourced from that country.
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Part VI.Steps to Improve Due Diligence
In addition to the measures described above, the Company intends to take the following steps during the next compliance period to improve the due diligence conducted and to further mitigate the risk that the 3TGs necessary to support our operations benefit armed groups, including:
| • | Informing and encouraging suppliers to transition to smelters identified as conflict-free by an independent audit program such as the RMAP; |
| • | Actively participating in and supporting industry trade groups to help improve communication throughout the supply chain; |
| • | Working with certain suppliers to help educate them on our ongoing expectations supporting responsible sourcing decisions; |
| • | Reconsidering our willingness to continue to partner with suppliers who do not comply with our Conflict Minerals Policy and who do not meet our expectations; |
| • | Contacting suppliers that have been flagged for additional follow-up and clarification; and/or |
| • | Increasing education to suppliers regarding the Conflict Minerals Rule, smelters and refiners, and proper use of the CMRT. |
Forward-Looking Statements
The Report contains forward-looking statements, which express a belief, expectation or intention, as well as those that are historical fact, including statements relating to our compliance efforts and expected actions. The words “expects,” “intends,” “plans,” “believes,” and “anticipates” and similar expressions are used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this Report, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.
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List of Potential Smelters/Refiners
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | RMI Audit Status |
Gold | Abington Reldan Metals, LLC | UNITED STATES | CID002708 | Not Enrolled |
Gold | Advanced Chemical Company | UNITED STATES | CID000015 | Conformant |
Gold | African Gold Refinery | UGANDA | CID003185 | Not Enrolled |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Conformant |
Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | CID002560 | Conformant |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Conformant |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Conformant |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 | Conformant |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Conformant |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Conformant |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Conformant |
Gold | Asahi Refining USA Inc. | UNITED STATES | CID000920 | Conformant |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Conformant |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | Not Enrolled |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | Conformant |
Gold | Aurubis AG | GERMANY | CID000113 | Conformant |
Gold | Bangalore Refinery | INDIA | CID002863 | Active |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Conformant |
Gold | Boliden AB | SWEDEN | CID000157 | Conformant |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Conformant |
Gold | Caridad | MEXICO | CID000180 | Not Enrolled |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Conformant |
Gold | Cendres + Métaux S.A. | SWITZERLAND | CID000189 | Conformant |
Gold | Chimet S.p.A. | ITALY | CID000233 | Conformant |
Gold | Chugai Mining | JAPAN | CID000264 | Not Enrolled |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | Conformant |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | Not Enrolled |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | Not Enrolled |
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | Conformant |
Gold | Dowa | JAPAN | CID000401 | Conformant |
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DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 | Active | |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Conformant |
Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 | Conformant |
Gold | Elemetal Refining, LLC | UNITED STATES | CID001322 | Not Enrolled |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Conformant |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | Not Enrolled |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | Not Enrolled |
Gold | Geib Refining Corporation | UNITED STATES | CID002459 | Conformant |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | Conformant |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Not Enrolled |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Not Enrolled |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | Not Enrolled |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | Not Enrolled |
Gold | HeeSung | KOREA, REPUBLIC OF | CID000689 | Conformant |
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Conformant |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | Conformant |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Conformant |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Not Enrolled |
Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 | Not Enrolled |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Conformant |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Conformant |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Conformant |
Gold | Italpreziosi | ITALY | CID002765 | Conformant |
Gold | Japan Mint | JAPAN | CID000823 | Conformant |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Conformant |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | Conformant |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Conformant |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Conformant |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | Not Enrolled |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | Not Enrolled |
Gold | Kazzinc | KAZAKHSTAN | CID000957 | Conformant |
Gold | Kennecott Utah Copper LLC | UNITED STATES | CID000969 | Conformant |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | Active |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Conformant |
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Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Conformant | |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Conformant |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | Not Enrolled |
Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 | Not Enrolled |
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Not Enrolled |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Not Enrolled |
Gold | L'Orfebre S.A. | ANDORRA | CID002762 | Active |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Conformant |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Not Enrolled |
Gold | Marsam Metals | BRAZIL | CID002606 | Conformant |
Gold | Materion | UNITED STATES | CID001113 | Conformant |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Conformant |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Conformant |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Conformant |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | Conformant |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Conformant |
Gold | Metalor USA Refining Corporation | UNITED STATES | CID001157 | Conformant |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | CID001161 | Conformant |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Conformant |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Conformant |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Conformant |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Active |
Gold | Morris and Watson | NEW ZEALAND | CID002282 | Not Enrolled |
Gold | Morris and Watson Gold Coast | AUSTRALIA | CID002866 | Not Enrolled |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Conformant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | CID001220 | Conformant |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Not Enrolled |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | Active |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Conformant |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Conformant |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Conformant |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Conformant |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Conformant |
Gold | PAMP S.A. | SWITZERLAND | CID001352 | Conformant |
Gold | Pease & Curren | UNITED STATES | CID002872 | Not Enrolled |
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Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Not Enrolled | |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | Conformant |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Conformant |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Conformant |
Gold | PX Précinox S.A. | SWITZERLAND | CID001498 | Conformant |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Conformant |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | Not Enrolled |
Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 | Active |
Gold | Republic Metals Corporation | UNITED STATES | CID002510 | Conformant |
Gold | Royal Canadian Mint | CANADA | CID001534 | Conformant |
Gold | SAAMP | FRANCE | CID002761 | Conformant |
Gold | Sabin Metal Corp. | UNITED STATES | CID001546 | Not Enrolled |
Gold | Safimet S.p.A | Italy | CID002973 | Conformant |
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | Active |
Gold | Sai Refinery | INDIA | CID002853 | Not Enrolled |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Conformant |
Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Not Enrolled |
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | Conformant |
Gold | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 | Conformant |
Gold | SEMPSA Joyería Platería S.A. | SPAIN | CID001585 | Conformant |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Not Enrolled |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Conformant |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Conformant |
Gold | Singway Technology Co., Ltd. | TAIWAN | CID002516 | Conformant |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Conformant |
Gold | Solar Applied Materials Technology Corp. | TAIWAN | CID001761 | Conformant |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | Not Enrolled |
Gold | Sudan Gold Refinery | SUDAN | CID002567 | Not Enrolled |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Conformant |
Gold | SungEel HiTech | KOREA, REPUBLIC OF | CID002918 | Conformant |
Gold | T.C.A S.p.A | ITALY | CID002580 | Conformant |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Conformant |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Conformant |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Conformant |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Not Enrolled |
Page 4 of 10
Tony Goetz NV | BELGIUM | CID002587 | Not Enrolled | |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Not Enrolled |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Conformant |
Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Conformant |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Conformant |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Conformant |
Gold | United Precious Metal Refining, Inc. | UNITED STATES | CID001993 | Conformant |
Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 | Not Enrolled |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Conformant |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | Conformant |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | Conformant |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | CID002100 | Conformant |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | Conformant |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Not Enrolled |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Conformant |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 | Conformant |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Conformant |
Tantalum | D Block Metals, LLC | UNITED STATES | CID002504 | Conformant |
Tantalum | Duoluoshan | CHINA | CID000410 | Not Enrolled |
Tantalum | Exotech Inc. | UNITED STATES | CID000456 | Conformant |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Conformant |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Conformant |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Conformant |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | CID002557 | Conformant |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 | Conformant |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Conformant |
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Conformant |
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | Conformant |
Tantalum | H.C. Starck Inc. | UNITED STATES | CID002548 | Conformant |
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | Conformant |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Conformant |
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | Conformant |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Conformant |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Conformant |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Conformant |
Page 5 of 10
Jiujiang Janny New Material Co., Ltd. | CHINA | CID003191 | Conformant | |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Conformant |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Conformant |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Conformant |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Conformant |
Tantalum | KEMET Blue Powder | UNITED STATES | CID002568 | Conformant |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | CID000973 | Conformant |
Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | Conformant |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Conformant |
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | Conformant |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | Conformant |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Conformant |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 | Conformant |
Tantalum | Power Resources Ltd. | MACEDONIA | CID002847 | Conformant |
Tantalum | QuantumClean | UNITED STATES | CID001508 | Conformant |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | Conformant |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | CID001522 | Conformant |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | Conformant |
Tantalum | Taki Chemicals | JAPAN | CID001869 | Conformant |
Tantalum | Telex Metals | UNITED STATES | CID001891 | Conformant |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Conformant |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Conformant |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 | Conformant |
Tin | Alpha | UNITED STATES | CID000292 | Conformant |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | Not Enrolled |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Conformant |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | Active |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Conformant |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 | Not Enrolled |
Tin | CV Ayi Jaya | INDONESIA | CID002570 | Conformant |
Tin | CV Dua Sekawan | INDONESIA | CID002592 | Conformant |
Tin | CV Gita Pesona | INDONESIA | CID000306 | Conformant |
Tin | CV Tiga Sekawan | INDONESIA | CID002593 | Conformant |
Tin | CV United Smelting | INDONESIA | CID000315 | Conformant |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | Conformant |
Page 6 of 10
Dowa | JAPAN | CID000402 | Conformant | |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | Not Enrolled |
Tin | EM Vinto | BOLIVIA | CID000438 | Conformant |
Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 | Not Enrolled |
Tin | Fenix Metals | POLAND | CID000468 | Conformant |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | Conformant |
Tin | Gejiu Jinye Mineral Company | CHINA | CID002859 | Conformant |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | Conformant |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Conformant |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | Conformant |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Not Enrolled |
Tin | Guangdong Hanhe Non-ferrous Metal Limited Company | CHINA | CID003116 | Conformant |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 | Conformant |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | Conformant |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | Conformant |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 | Conformant |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | Conformant |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Conformant |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Conformant |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | Conformant |
Tin | Metallic Resources, Inc. | UNITED STATES | CID001142 | Conformant |
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | Conformant |
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | Conformant |
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | Conformant |
Tin | Minsur | PERU | CID001182 | Conformant |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Conformant |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Active |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | Not Enrolled |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Conformant |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Conformant |
Tin | Operaciones Metalurgical S.A. | BOLIVIA | CID001337 | Conformant |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 | Not Enrolled |
Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | Conformant |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Conformant |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Conformant |
Page 7 of 10
PT Babel Inti Perkasa | INDONESIA | CID001402 | Conformant | |
Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | Conformant |
Tin | PT Bangka Serumpun | INDONESIA | CID003205 | Conformant |
Tin | PT Bangka Tin Industry | INDONESIA | CID001419 | Conformant |
Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 | Conformant |
Tin | PT Bukit Timah | INDONESIA | CID001428 | Conformant |
Tin | PT DS Jaya Abadi | INDONESIA | CID001434 | Conformant |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | CID001438 | Conformant |
Tin | PT Inti Stania Prima | INDONESIA | CID002530 | Conformant |
Tin | PT Karimun Mining | INDONESIA | CID001448 | Conformant |
Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 | Conformant |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 | Conformant |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | Conformant |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Conformant |
Tin | PT O.M. Indonesia | INDONESIA | CID002757 | Conformant |
Tin | PT Panca Mega Persada | INDONESIA | CID001457 | Conformant |
Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 | Conformant |
Tin | PT Prima Timah Utama | INDONESIA | CID001458 | Conformant |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Conformant |
Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 | Conformant |
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | Conformant |
Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | Conformant |
Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 | Conformant |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 | Conformant |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 | Conformant |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | Conformant |
Tin | PT Tommy Utama | INDONESIA | CID001493 | Conformant |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | Conformant |
Tin | Rui Da Hung | TAIWAN | CID001539 | Conformant |
Tin | Soft Metais Ltda. | BRAZIL | CID001758 | Conformant |
Tin | Super Ligas | Brazil | CID002756 | Not Enrolled |
Tin | Thaisarco | THAILAND | CID001898 | Conformant |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | Not Enrolled |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 | Conformant |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | Conformant |
Page 8 of 10
Yunnan Tin Company Limited | CHINA | CID002180 | Conformant | |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 | Conformant |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | Conformant |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Conformant |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | Conformant |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Conformant |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | Conformant |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | Active |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | Conformant |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Conformant |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Conformant |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 | Not Enrolled |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | CID000568 | Conformant |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Conformant |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002542 | Conformant |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | Conformant |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Conformant |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 | Conformant |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | Conformant |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 | Conformant |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | Conformant |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Conformant |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Conformant |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 | Not Enrolled |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Conformant |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Not Enrolled |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Conformant |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Conformant |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 | Conformant |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Conformant |
Tungsten | Kennametal Fallon | UNITED STATES | CID000966 | Conformant |
Tungsten | Kennametal Huntsville | UNITED STATES | CID000105 | Conformant |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Conformant |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | CID002845 | Conformant |
Tungsten | Niagara Refining LLC | UNITED STATES | CID002589 | Conformant |
Page 9 of 10
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 | Conformant | |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Conformant |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 | Conformant |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | Conformant |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | Conformant |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 | Conformant |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 | Conformant |
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | Conformant |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Conformant |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Conformant |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | Conformant |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | Conformant |
Page 10 of 10
Potential Countries of Origin
The list below sets forth the potential countries of origin of 3TGs used in the manufacture of the Products disclosed in the Report. The list is based on publicly available information, our RCOI, and other due diligence efforts. However, for the reasons described in the Report, these possible countries of origin cannot be linked to our Products with reasonable certainty.
Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Cambodia, Canada, Chile, China, Columbia, 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, Zimbabwe, Kenya, Mozambique, South Africa, Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia
