Exhibit 1.01
Modine Manufacturing Company
Conflict Minerals Report
For The Year Ended December 31, 2015
This report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).
This report has been prepared by management of Modine Manufacturing Company (herein referred to as “Modine,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries and consolidated joint ventures. It does not include the activities of variable interest entities that are not required to be consolidated.
Modine specializes in thermal management systems and components, bringing highly engineered heating and cooling technology and solutions to diversified global markets. Modine’s products are used in light-, medium-, and heavy-duty vehicles, heating, ventilation and air conditioning equipment and systems, off-highway and industrial equipment and refrigeration systems. Modine is a global company headquartered in Racine, Wisconsin (USA) with operations in North America, South America, Europe, Asia and Africa. Our principal products include radiators and radiator cores, condensers, oil coolers, charge air coolers, exhaust gas recirculation coolers, heat-transfer packages and modules, and building heating, ventilating and air conditioning (HVAC) equipment.
We conducted an analysis of our products and concluded that small amounts of tin, tantalum, tungsten and/or gold (3TG) are present in a portion of our products. In particular, we concluded that 3TG are present in the following Modine products: vehicular heat exchangers and modules containing tin-plated materials or tin-based solder, and building HVAC products or systems containing some or all of the 3TG materials, in electronic devices in particular.
Conflict Minerals Policy
We have adopted a Conflict Minerals Policy. This policy is publicly available on our website at www.modine.com/web/en/policies.htm.
Supply Chain
Modine manufactures and assembles its products using both raw materials and purchased parts acquired through our competitive global supply process. Modine has over 1,500 direct material suppliers across the globe, and there are generally multiple tiers between the 3TG mines and our direct suppliers. Therefore, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers. Contracts with our suppliers are frequently in force for multiple years and we cannot always unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts we are requiring suppliers to provide information about the presence of conflict minerals in the products supplied and about the smelter sources of the conflict minerals. Our conflict mineral policy is published on www.modine.com/web/en/policies.htm, and our Modine Global Supplier Manual (available at http://www.modine.com/web/en/reference-documents.htm) outlines our expectations for conflict free supply. We have implemented a survey process for assessing our current products and the supply chain associated with these components and materials that go into these products.
As further described in Section 2.3 of this Report, our survey process started with those suppliers who provided parts or components we believed were reasonably likely to contain 3TG. We then modified the list to remove suppliers with whom Modine spent less than approximately $5,000 in 2015, based upon spend data through September 30, 2015 and our conclusion that the data did not materially change between then and December 31, 2015, unless non-spend factors weighed in favor of inclusion for a particular supplier. As a result of these processes, we surveyed direct suppliers representing in excess of 11% of our 2015 expenditures for direct components. We assessed our industry as well as others and confirmed that this risk-based approach is consistent with how many peer companies are approaching The Rule. The number of surveyed suppliers decreased versus last year due to our ability in this second year to narrow our data in a more reliable manner based upon information learned to date.
We requested that all identified suppliers provide information to us regarding 3TG and smelters, using the template provided by the Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), known as the Conflict Minerals Reporting Template (CMRT). The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide material to a manufacturer’s supply chain. It includes questions about a direct supplier’s conflict-free 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 3TG used by those facilities.
Efforts to Determine Mine or Location of Origin
Because of our size, the complexity of our products, and the depth, breadth and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. We have determined that requesting our suppliers to complete the CMRT represents our reasonable best efforts to determine the mine or locations of origin of 3TG in our supply chain. We have reached this conclusion in part as a result of our active participation in various industry initiatives and groups. As a member of the Conflict Free Sourcing Initiative (CFSI), we have had access to updated smelter due diligence to improve our Reasonable Country of Origin Investigation (RCOI). This membership has been valuable in our smelter classification and supply chain due diligence processes.
Smelters or Refiners and Country of Origin of 3TG
The supplier CMRT declarations we received mentioned approximately 1592 potential smelters or supply chain participants. Of these 1592 entities, 320 have been identified and are being monitored by the CFSI. The remaining 1272 entities have not been classified and will be the subject of future due diligence.
The 320 identified entities being monitored by the CFSI can be categorized in the following manner:
| Smelter CFSI Analysis Metrics | |
| | | |
| Status Code | Status | Entity Count | Status Description |
| 1 | Compliant | 216 | Legitimate smelter and CFSI compliant |
| 2 | On CFSI Active List | 43 | Legitimate smelter engaged in CFSI but not yet compliant |
| 3 | In Communication | 16 | Legitimate smelter and has been contacted regarding the CFSI Audit Program |
| 3 | TI-CMC member company | 4 | Legitimate Tungsten smelter. Has been contacted regarding the CFSI Audit Program |
| | | | |
| 4 | Outreach Required | 24 | Legitimate smelter. Outreach required to request CFSI participation and to initiate certification |
| 5 | Compliant | 17 | Legitimate smelter; audit status not applicable |
| | Subtotal – CFSI Assessed | 320 | |
| 6 | UNIDENTIFIED | 1272 | Alleged smelters submitted to Modine on Supplier CMRT’s. Entity not identified on CFSI smelter list. Outreach required to validate smelter status |
| Grand Total | | 1592 | |
| | | Smelter Count |
| Status Code | 1 | 2 | 3 | 3 | 4 | 5 | | 6 | |
| Status | Compliant | On CFSI Active List | In Communication | TI-CMC member company | Outreach Required | Compliant (Audit N/A) | CFSI Identified Entities | UNIDENTIFIED | Grand Total |
| Gold | 80 | 15 | 11 | | 20 | 5 | 131 | 266 | 397 |
| Tantalum | 46 | 1 | | | | 2 | 49 | 56 | 105 |
| Tin | 59 | 17 | 3 | | 4 | 8 | 91 | 820 | 911 |
| Tungsten | 31 | 10 | 2 | 4 | | 2 | 49 | 130 | 179 |
| Grand Total | 216 | 43 | 16 | 4 | 24 | 17 | 320 | 1272 | 1592 |
We were unable to validate whether the 1272 entities classified as Unidentified are smelters, refiners or intermediate supply chain companies. We will continue our due diligence in 2016 to improve this unidentified classification.
Modine’s Conflict Mineral program has resulted in improved supply chain transparency to Conflict Mineral Content and smelter sources. The number of CFSI-listed entities submitted on supplier CMRT certifications increased by a factor of about 2.5 times (320 vs. 131 in 2013).
The number of certified Conflict Free smelters increased by more than a factor of three (216 vs. 65 in 2013).
The vast majority of suppliers from which we requested information indicated in their responses that the information provided was at a company or divisional level as opposed to a product level. We requested that the surveyed suppliers report at an aggregate company level, specifically with respect to any products sold to Modine. We will continue to move towards unique part number-level reporting in future years.
The Appendix to this report includes a list of countries of origin for 3TG reported to Modine. The list is derived from the CFSI analysis of potential countries of origin based on the information obtained through our due diligence.
Conclusion
We are unable with assurance to determine the origin of the 3TG in all of our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, under the Rule we are required to submit to the SEC this Conflict Minerals Report (CMR) as an Exhibit to Form SD.
This report is available on our website at www.modine.com/web/en/conflict-minerals.htm.
| 2.1 | Design of Due Diligence |
Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (OECD) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing (OECD Guidance) and the related Supplements for gold and for tin, tantalum and tungsten.
As described above, Modine has adopted a company policy relating to our sourcing of 3TG, which is posted on our website at www.modine.com/web/en/policies.htm.
Internal Team
Modine’s management system for conflict minerals covering calendar year 2015 was sponsored by our Vice President, Legal and Corporate Communications, General Counsel and Secretary, and Vice President, Asia and Global Purchasing and was supported by a team of subject matter experts from relevant functions such as Operations, Purchasing, Engineering Systems and Services, Sales, Legal and Internal Audit. The team of subject matter experts was responsible for implementing our conflict minerals compliance strategy for calendar year 2015, and was led by the Vice President, Global Purchasing, who acted as the executive conflict minerals program manager. Senior management is briefed about the results of our due diligence efforts on a regular basis.
Control Systems
Since we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in our business sector and other sectors, through our own efforts and those organized by trade associations. We also participate in or actively monitor the following industry-wide initiatives to disclose upstream actors in the supply chain: The Electronics Industry Citizenship Coalition-Global e-Sustainability Initiative’s (EICC-GeSI) Conflict Free Sourcing Initiative (CFSI), as well as several other manufacturing industry consortiums including the National Association of Manufacturers (NAM), the Automotive Industry Action Group (AIAG) and the Manufacturers Alliance for Productivity and Innovation (MAPI).
Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all Modine employees and third parties doing business with Modine, our Global Supplier Manual, our Policy regarding Conflict Minerals, and our internal standard practices that govern our new product development processes. We incorporate these controls into our standard supplier contract, the Modine Approved Supplier Agreement (“MAS”). We utilize comprehensive agreements with suppliers of products that are not “off-the-shelf” items. These “off-the-shelf” items include, for example, standard fittings and fasteners, personal protective equipment, and general business supplies. For suppliers with whom we utilize comprehensive agreements, we use the MAS in the majority of cases.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT versions 4.01(a) and 4.01(b) and the Assent Compliance Manager web-based reporting tool for collecting conflict minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests. In this third year of conflict mineral reporting, we engaged Assent Compliance to assist with the training of suppliers and the collection of supplier CMRTs. Assent Compliance has followed up with suppliers to ensure completion of CMRTs, and all communications with suppliers has been documented to reflect the degree of success of these efforts.
Grievance Mechanism
We have multiple, longstanding grievance mechanisms whereby employees and third parties, can report violations of Modine’s policies. We have established a Global Policy regarding Reporting and Investigation, which is publicly available at www.modine.com/web/en/policies.htm. This policy establishes worldwide, consistent methods for employees and others to report any matters they believe may violate our Code or legal obligations, and for the investigation and resolution of all such reports. Communication channels range from an employee’s immediate supervisor to a third-party-hosted Ethics Helpline to direct contact with Modine’s Business Ethics Committee.
Modine has included clear links to the Helpline and Code on our website, www.modine.com. Through these mechanisms, third parties within our supply chain, or others related to or with knowledge of those third parties, can report any activities that could violate our Conflict Minerals Policy or the spirit of maintaining a conflict-free supply chain.
Maintain Records
We have adopted a policy to retain relevant documentation for a period of 5 years, consistent with the OECD requirement. Relevant documentation is collected and stored using a variety of methods, including, without limitation, an e-mail address designated for this purpose (conflictminerals@na.modine.com), a database maintained by Assent Compliance containing information provided by Modine’s supply chain, and an internal drive maintained by Modine for purposes of storing materials related to our conflict minerals due diligence and compliance.
| 2.3 | Identify and Assess Risk in the Supply Chain |
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Accordingly we participate in a number of industry-wide initiatives as described above.
In order to assess the risk of the presence of 3TG in the parts and materials Modine purchases, we first considered where, logically, 3TG necessary to functionality or production of our products might reside. To accomplish this, we implemented a multilevel analysis that included the following:
| 1. | We reviewed material specifications (M-Specs) to identify those where 3TG is specifically called out as a necessary ingredient in the material. |
| 2. | We queried the International Material Data System (IMDS), the automotive industry's material data system, which has become a global standard used by almost all of the global original equipment manufacturers for the tracking of material content in parts supplied to automotive industry. IMDS provided another level of detail that might not be captured in our internal M-Specs. |
| 3. | Using the information from steps 1 and 2, we queried our company enterprise resource planning (ERP) systems to identify suppliers who provided the materials containing 3TG in the 2015 calendar year. |
| 4. | We utilized our purchasing global material group code spend analytics data to identify suppliers who provided electronic devices (e.g. wiring, motors, controls, sensors) that we considered to be at risk for containing 3TG. We built on our learning from the first two years of conflict minerals due diligence and included suppliers determined to be at-risk for supplying product that may contain any conflict minerals. Due to the nature of our supply chain, which includes distributors of electronic components, we engaged with several Tier 2 sub-suppliers to improve the reporting to our direct supplier distributors. |
The multi-level analysis above yielded a list of 147 direct material suppliers that are supplying parts or materials to Modine that reasonably may contain 3TG. We rely on these suppliers to provide us with information about the existence and source of conflict minerals contained in the parts or materials supplied to us. Our direct suppliers similarly rely upon information provided by their suppliers.
| 2.4 | Design and Implement a Strategy to Respond to Risks |
In response to this risk assessment, Modine continues to update and utilize a risk management plan, through which the conflict minerals program is implemented, managed and monitored.
Updates to this risk assessment are provided regularly to senior management
As described above, we participate in the following industry-wide initiatives to disclose upstream actors in the supply chain: The Conflict Free Sourcing Initiative (CFSI), as well as several other manufacturing industry consortiums including the National Association of Manufacturers (NAM) the Automotive Industry Action Group (AIAG), and the Manufacturers Alliance for Productivity and Innovation (MAPI).
As part of our risk management plan, to ensure suppliers understand our expectations, we have posted pertinent materials on our website, communicated directly with suppliers (orally and in writing), and included relevant information in our Global Supplier Manual.
As described in our conflict minerals policy, we would engage any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that may support conflict in the DRC or any adjoining country, and assist them to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. We have found no instances where it was necessary to terminate a contract or find a replacement supplier due to possible violation of our Conflict Minerals Policy or the spirit of a conflict-free supply chain.
| 2.5 | Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We do not have a direct relationship with 3TG smelters and refiners nor do we perform direct audits of these entities. However, we do rely upon various industry efforts to influence smelters and refineries to undergo audits and become certified, as appropriate.
| 2.6 | Report on Supply Chain Due Diligence |
In addition to this report, see our website at http://www.modine.com/web/en/supplier-policies.htm for further information about our supply chain due diligence and policies and practices.
Utilizing the process outlined above, we received responses from 80% of the 147 suppliers surveyed. We reviewed the responses to determine where further engagement with our suppliers was warranted. We considered untimely or incomplete responses as well as inconsistencies within the data reported in the template in making this determination. We have worked directly with these suppliers to provide revised responses.
Responses included the names of 1592 entities listed by our suppliers as smelters or refiners. 320 or 20% of these entities have been identified and categorized by the CFSI. Of these 320 entities, 216 or 68% are certified as Conflict Free, 43 or 13% are engaged in the audit process to become certified as Conflict Free, 20 or 6% are being pursued by the CFSI to begin the certification process, 24 or 8% need to be contacted to start the audit process, and 17 or 5% are legitimate smelters not needing an audit. Our supplier CMRTs included 1272 entities that have not been identified by the CFSI and may be smelters or intermediate supply chain participants. Fifty-nine (59) of the surveyed suppliers indicated that they sourced 3TG from one or more of twenty-two smelters linked to the DRC, and that such smelters may have been used for tin, tungsten or tantalum supply in products supplied to us. Five of these 59 suppliers indicated they were reporting to us at a broad product level, while the remainder indicated their reports were at a company level. None reported at a level specific enough to identify products supplied to Modine. Each of the twenty-two smelters so identified have been determined by the CFSI to be Conflict Free. In the Appendix, we have included information about these twenty-two entities, as well as a full list of the 320 CFSI-monitored suppliers reported to us through our due diligence process. We will continue to work with our suppliers and the CFSI to determine their validity and encourage CFSI certification where appropriate for the 1272 unknown entities.
| 4. | Steps To Be Taken To Mitigate Risk |
We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary conflict minerals in our products could benefit armed groups in the DRC or adjoining countries:
| a) | In addition to binding our suppliers to our conflict minerals procedures through the use of the Global Supplier Manual and other documents incorporated by referenced into our supply agreements, include a specific conflict minerals flow-down clause in new or renewed supplier contracts. |
| b) | Continue to direct suppliers to training resources provided by Assent Compliance to attempt to increase the response rate and improve the content of the supplier survey responses. |
| c) | Engage any of our suppliers who declared “unknown” sources of 3TG in their declarations to pursue the identification of supply chain smelting sources. |
| d) | Engage with suppliers who provided smelter names that could not be found on the CFSI Conflict Free Smelter List to pursue the identification and confirmation of smelter sources. |
| e) | Work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. |
| f) | Continue to encourage suppliers to provide part-level information. |
| g) | In the event that any of our suppliers are found to be providing Modine with products containing 3TG from sources that support conflict in the Covered Countries, work with them to establish alternative sources of 3TG. |
| h) | Continue to invest in Conflict Minerals due diligence tools, such as Assent Compliance and the resources it provides. |
Appendix to Modine Manufacturing Company
Conflict Minerals Report
For The Year Ended December 31, 2015
DRC-Related Smelters Reported to Modine
| Metal | Standard Smelter Name | Smelter Facility Location | Conflict Free? |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes |
| Tantalum | Duoluoshan | CHINA | Yes |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes |
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
| Tantalum | Taki Chemicals | JAPAN | Yes |
| Tin | Thaisarco | THAILAND | Yes |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes |
Country of Origin List:
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.
CFSI-Monitored Smelters Reported To Modine
| Metal | Standard Smelter Name | Smelter Facility Location | Conflict Free? |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes |
| Tungsten | ACL Metais Eireli | BRAZIL | |
| Gold | Advanced Chemical Company | UNITED STATES | |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | |
| Tin | Alpha | UNITED STATES | Yes |
| Tin | An Thai Minerals Company Limited | VIET NAM | |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes |
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes |
| Gold | Asahi Pretec Corporation | JAPAN | Yes |
| Gold | Asahi Refining Canada Limited | CANADA | Yes |
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes |
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | |
| Gold | Aurubis AG | GERMANY | Yes |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes |
| Gold | Bauer Walser AG | GERMANY | |
| Gold | Boliden AB | SWEDEN | Yes |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes |
| Gold | Caridad | MEXICO | |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes |
| Gold | Cendres + Métaux SA | SWITZERLAND | |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | |
| Gold | Chimet S.p.A. | ITALY | Yes |
| Tin | China Tin Group Co., Ltd. | CHINA | Yes |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes |
| Gold | Chugai Mining | JAPAN | |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes |
| Tin | CV Ayi Jaya | INDONESIA | Yes |
| Tin | CV Dua Sekawan | INDONESIA | |
| Tin | CV Gita Pesona | INDONESIA | Yes |
| Tin | CV Serumpun Sebalai | INDONESIA | Yes |
| Tin | CV Tiga Sekawan | INDONESIA | |
| Tin | CV United Smelting | INDONESIA | Yes |
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes |
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | |
| Gold | DODUCO GmbH | GERMANY | Yes |
| Gold | Dowa | JAPAN | Yes |
| Tin | Dowa | JAPAN | Yes |
| Tantalum | Duoluoshan | CHINA | Yes |
| Tantalum | E.S.R. Electronics | UNITED STATES | |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | |
| Gold | Elemetal Refining, LLC | UNITED STATES | Yes |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes |
| Tin | EM Vinto | BOLIVIA | Yes |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes |
| Tin | Estanho de Rondônia S.A. | BRAZIL | |
| Tantalum | Exotech Inc. | UNITED STATES | Yes |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes |
| Gold | Faggi Enrico S.p.A. | ITALY | |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | |
| Tin | Fenix Metals | POLAND | Yes |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes |
| Gold | Geib Refining Corporation | UNITED STATES | |
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | |
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | |
| Gold | Guangdong Jinding Gold Limited | CHINA | |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes |
| Tungsten | H.C. Starck GmbH | GERMANY | Yes |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes |
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes |
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | |
| Gold | Heimerle + Meule GmbH | GERMANY | Yes |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes |
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Yes |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes |
| Gold | Istanbul Gold Refinery | TURKEY | Yes |
| Gold | Japan Mint | JAPAN | Yes |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | |
| Gold | Jiangxi Copper Company Limited | CHINA | Yes |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | |
| Gold | Kazzinc | KAZAKHSTAN | Yes |
| Tantalum | KEMET Blue Metals | MEXICO | Yes |
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes |
| Tungsten | Kennametal Fallon | UNITED STATES | |
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA | |
| Gold | Lingbao Gold Company Limited | CHINA | |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | |
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | Yes |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes |
| Gold | Materion | UNITED STATES | Yes |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes |
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | |
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes |
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | |
| Gold | Metalor Technologies SA | SWITZERLAND | Yes |
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes |
| Tin | Mineração Taboca S.A. | BRAZIL | Yes |
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes |
| Tin | Minsur | PERU | Yes |
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes |
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes |
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | |
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes |
| Gold | Morris and Watson | NEW ZEALAND | |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | |
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes |
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes |
| Gold | PAMP SA | SWITZERLAND | Yes |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | |
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Yes |
| Tin | Phoenix Metal Ltd. | RWANDA | |
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes |
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes |
| Tin | PT Alam Lestari Kencana | INDONESIA | |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes |
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes |
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes |
| Tin | PT Bangka Kudai Tin | INDONESIA | |
| Tin | PT Bangka Prima Tin | INDONESIA | Yes |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | |
| Tin | PT Bangka Tin Industry | INDONESIA | Yes |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes |
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes |
| Tin | PT Bukit Timah | INDONESIA | Yes |
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes |
| Tin | PT DS Jaya Abadi | INDONESIA | Yes |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes |
| Tin | PT Fang Di MulTindo | INDONESIA | |
| Tin | PT Inti Stania Prima | INDONESIA | Yes |
| Tin | PT Justindo | INDONESIA | Yes |
| Tin | PT Karimun Mining | INDONESIA | |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | |
| Tin | PT Mitra Stania Prima | INDONESIA | Yes |
| Tin | PT Panca Mega Persada | INDONESIA | Yes |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | |
| Tin | PT Prima Timah Utama | INDONESIA | Yes |
| Tin | PT Refined Bangka Tin | INDONESIA | Yes |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes |
| Tin | PT Seirama Tin Investment | INDONESIA | |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes |
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes |
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes |
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes |
| Tin | PT Tirus Putra Mandiri | INDONESIA | |
| Tin | PT Tommy Utama | INDONESIA | Yes |
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes |
| Gold | PX Précinox SA | SWITZERLAND | Yes |
| Tantalum | QuantumClean | UNITED STATES | Yes |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes |
| Gold | Republic Metals Corporation | UNITED STATES | Yes |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes |
| Gold | Royal Canadian Mint | CANADA | Yes |
| Tin | Rui Da Hung | TAIWAN | Yes |
| Gold | SAAMP | FRANCE | |
| Gold | Sabin Metal Corp. | UNITED STATES | |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes |
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes |
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes |
| Gold | So Accurate Group, Inc. | UNITED STATES | |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes |
| Tin | Soft Metais Ltda. | BRAZIL | Yes |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes |
| Gold | Sudan Gold Refinery | SUDAN | |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes |
| Gold | T.C.A S.p.A | ITALY | Yes |
| Tantalum | Taki Chemicals | JAPAN | Yes |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes |
| Tantalum | Telex Metals | UNITED STATES | Yes |
| Tin | Thaisarco | THAILAND | Yes |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | |
| Gold | Tony Goetz NV | BELGIUM | |
| Gold | Torecom | KOREA, REPUBLIC OF | |
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes |
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes |
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes |
| Gold | Valcambi SA | SWITZERLAND | Yes |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | |
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes |
