Exhibit 1.01
Johnson Outdoors Inc.
Conflict Minerals Report for Calendar Year 2015
May 31, 2016
Exhibit 1.01
to Specialized Disclosure Report Accompanying Form SD
Filed with the SEC on: May 31, 2016
| Signed by: | /s/ David W. Johnson | |
| Name, Title: David W. Johnson, Chief Financial Officer |
| Date: May 31, 2016 |
Introduction:
Johnson Outdoors Inc. (“JOI,” “we,” “us,” “our”) is a publicly traded U.S. company that recognizes itself as an issuer as defined under section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, referred to in this report as “Dodd-Frank.” JOI has manufactured or contracted to manufacture products for which conflict minerals are necessary to their functionality. JOI has reason to believe that some of these necessary conflict minerals may have originated from the Democratic Republic of Congo or an adjoining countries and that some of those minerals may not be solely from recycled or scrap sources.
As an issuer under Dodd-Frank, JOI has designed, implemented, executed, and managed its conflict minerals plan for compliance with Dodd-Frank. Elements, efforts, results, and conclusions of this compliance effort are outlined in this Conflict Minerals Report (CMR) as required by the legislation. This Conflict Minerals Report is filed with our Form SD to comply with the requirements of Rule 13p-1 of the Securities and Exchange Act 1934.
All terms and definitions in this conflict minerals report are as defined by the Final Rules Dodd-Frank and the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
JOI’s efforts in compliance with Dodd-Frank support the Conflict-free Smelter Program (CFSP). With the cooperation of its suppliers, JOI has undertaken a risk assessment of smelters and refiners (hereafter referred to collectively as smelters) of tin, tantalum, tungsten, and gold (3TG) and, to the best of its abilities, has attempted to identify the mines of origin of 3TG through a holistically managed supply chain due diligence and compliance program. JOI’s goal is to implement its supply chain transparency program in which its employees, suppliers, smelters, and other actors in its supply chain understand program requirements and identify the applicable risks and responsibilities associated with their role in JOI’s supply chain. This program is designed to reasonably identify all smelters in our supply chain as identified by affected suppliers.
JOI’s supply chain compliance and due diligence programs support a clean minerals trade in the Democratic Republic of Congo (DRC) and adjoining countries (covered countries, or CC’s), while maintaining economic relationships with conflict-free smelters in the countries covered under this legislation. This report may be found on our website at: http://www. http://investor.johnsonoutdoors.com/sec.cfm. This report covers all JOI products at a company level and includes all covered products in all JOI businesses.
JOI’s Conflict Minerals Program:
For Reporting Year 2015 (RY2015), JOI maintained strong management systems and carried out due diligence procedures to evaluate the extraction and trade of mineral ores containing 3TG, also referred to as conflict minerals (CM). JOI implemented a supply chain transparency system and due diligence program to identify and evaluate its 3TG smelters relating to the conflict minerals necessary to the functionality or production of products manufactured by JOI, or contracted to be manufactured by JOI.
This system is designed to identify and minimize the trade in conflict minerals from mines that directly or indirectly finance or benefit armed groups in the DRC region, while enabling legitimate minerals from the DRC and surrounding countries to enter global supply chains.
JOI’s conflict minerals program includes:
| · | Maintenance of a publicly available conflict minerals policy. |
| · | Annual implementation of an organization-wide process that ensures 100% of JOI suppliers are made aware of JOI’s policy and standards regarding conflict minerals and obligations to comply with our conflict minerals policy. |
| · | Maintenance of internal protocols to ensure that conflict minerals supply chain due diligence and obligations are clearly presented and understood by JOI employees who have knowledge of the SEC disclosure requirements regarding conflict minerals. |
| · | Survey and analysis of suppliers and sources of 3TG. |
| · | Annual implementation of a supply chain communication plan that requests use of the most current Conflict-Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT) in order to gather, survey, and evaluate suppliers and sources of 3TG, and identify 3TG smelters in our supply chain. |
| · | Annual internal audit of first tier suppliers regarding their understanding of the conflict minerals rule and their obligations regarding the rule. |
| · | Identification of priority suppliers who supply electrical and electronic parts. |
| · | Escalation of Reasonable Country of Origin Inquiry (RCOI) efforts, including identifying smelters from priority suppliers. |
| · | Collection of conflict minerals information to achieve control and transparency over conflict minerals identified in our supply chain and identify any risk that our products may contain conflict minerals that could finance or benefit armed groups in covered countries. |
| · | Identification of 3TG smelters in order to determine the locations of country of origin and mines of these ores. |
| · | Reliance on the Conflict-Free Smelter Program (CFSP) and other industry approved mechanisms to validate smelter supply chain due diligence. |
| · | Internal research to validate smelters not participating in the CFSP. |
| · | Annual request that suppliers only source from CFSP or validated smelters for 3TG. |
| · | Direct contact efforts with smelters that are not participating in the CFSP and encouraging participation in the CFSP. |
| · | Public disclosure and reporting of the results of our due diligence. |
| · | Maintenance of all records relating to our due diligence efforts for a minimum of five years. |
| · | Multi-tiered assessment and performance of risk mitigation efforts throughout our supply chain including review and evaluation from business group leaders and executives. |
| · | Maintenance of an improvement plan based on previous reporting years and lessons learned. |
| · | Maintenance of a mechanism that allows JOI, its suppliers, and concerned parties to communicate any concerns regarding our conflict minerals program. |
Due Diligence:
Design of due diligence:
Design and implementation of JOI’s conflict minerals program conforms to the “Five Step Framework for Risk-Based Due Diligence in the Mineral Supply Chain” (Annex I) and the “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas” (Annex II) included in the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (second Edition). The due diligence steps performed and a brief description of them are below.
Step 1: Establish strong company management systems.
Step 2: Identify and assess risk in the supply chain.
Step 3: Design and implement a strategy to respond to identified risks.
Step 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
Step 5: Report on supply chain due diligence.
Due diligence performed:
Due diligence measures JOI performed regarding the source and chain of custody of conflict minerals identified in our supply chain and regarding 3TG smelters identified in our supply chain include, but are not limited to, the steps below as mapped to the OECD 5 Step Framework referenced above:
| OECD Steps: | JOI Due Diligence Measures Performed: |
Step 1: Establish strong company management systems. | · Assign and implement multi-disciplinary responsibilities to internal JOI business group leaders, support staff, and its third-party consultant to carry out all elements of JOI’s conflict minerals program. · Maintain a detailed project plan and hold semi-monthly meetings for JOI employees who have knowledge of the SEC disclosure requirements for conflict minerals and publish this project plan on JOI’s intranet. · Maintain records in a secure computerized database repository for a minimum of five years. |
Step 2: Identify and assess risk in the supply chain. | · Evaluate 100% of JOI suppliers across all business groups as being in or out of scope of the conflict minerals program. · Review and verification of supplier commodity class. · Review and update of affected suppliers. · Review and update of priority suppliers. · Review new suppliers and changes in supplier status and commodity class. · Assess risk in our supply chain according to commodity class and supplier status. |
| | · Assess risk in our supply chain according to supplier responses. · Engage suppliers by performing multi-tiered survey of 100% of JOI in-scope conflict minerals suppliers by requesting current, complete, and accurate CMRTs in order to identify 3TG smelters in the supply chain and set expectations for compliance. · Annually redistribute copies of our conflict minerals policy and basic standards to all suppliers, regardless of commodity class. · Analyze smelter information from suppliers with the information available from CFSP, the London Market Bullion Association (LBMA), the Responsible Jewellery Council (RJC), and other accredited industry mechanisms. · Analyze smelter information from suppliers via other sources, including but not limited to information from: the United States Department of Commerce; United Nations publications; iTSCi (ITRI Tin Supply Chain Initiative); extensive internet research including smelter websites and company profiles; non-governmental organization (NGO) websites; in-region sourcing programs; other company CMRTs; news articles and publications. · Identify smelters of 3TG that appear to have facilities, or likelihood of facilities, in covered countries. · Report identified and/or potential supply chain risks to business group leaders and senior management. |
Step 3: Design and implement a strategy to respond to identified risks. | · Audit distribution of our conflict minerals policy to evaluate and ensure supplier understanding, acknowledgment, and adherence to this policy and our basic standards. · Perform internal multi-tiered analysis of our suppliers’ CMRTs including: completeness; reasonable response based on commodity class and scope; consistency with previous reporting year information. · Communicate supplier expectations for return of the CMRT with smelters identified. · Communicate supplier expectation that they source only from CFSP smelters. · Communicate supplier expectation that they notify us of any risks and red flags identified by their own due diligence activities. · Communicate supplier expectation that they notify us immediately of any smelters that may be suspected of supporting armed groups in covered countries. · Perform internal ongoing training of the conflict minerals rules and risks in the supply chain. · Engage JOI business group leaders, support staff, and a third-party consultant in multi-tiered follow ups and escalations with suppliers in an effort to obtain higher quantity and quality of smelter information, particularly from suppliers of electrical and electronic equipment. · Use JOI level of influence to encourage suppliers to source from CFSP audited and compliant smelters. · Encourage identified smelters to participate in the CFSP and obtain CFSP certification if they have not already done so. · Continue to improve on efficiencies and effectiveness of our conflict minerals program to close gaps and mitigate risks for each reporting year. · Perform risk mitigation efforts to ensure suppliers are in conformance with our conflict minerals policy. · Execute a risk mitigation plan that improves supply chain due diligence and mitigates the risk that any conflict minerals identified in our supply chain benefit any armed groups. |
| | · Communicate risks to business group leaders, our conflict minerals executive team, and senior management. · Perform gap analysis and communicate these gaps and issues to our conflict minerals executive team and to senior management. |
Step 4: Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain. | · Identify smelters in covered countries that are conflict-free, or participating in a conflict-free program as defined by CFSP. · Rely on the due diligence performed by CFSP, LBMA and RJC regarding smelter conflict-free status. · Directly contact smelters in the form of an RCOI regarding source and chain of custody of conflict minerals and evidence of due diligence for whom we were unable to confirm conflict-free status via the sources above. |
Step 5: Report on supply chain due diligence. | · In compliance with Dodd-Frank and the SEC Final Rule, on or before May 31, 2016, JOI will file Form SD and Conflict Minerals Report (this report) with the SEC, as well as publish this information on its website. |
Results of Due Diligence:
JOI identified 369 unique smelters in its supply chain in RY2015. These are associated with the following 3TG as follows:
Out of these 369 smelters, JOI has identified 45 unique smelters that we have reason to believe source from the DRC and/or surrounding countries. JOI exercised due diligence on the conflict mineral source and chain of custody for these smelters who appear to have presence in either the DRC or surrounding countries (covered countries, or CCs).
Smelter conflict-free (CF) status and facility location are summarized in the table below. The conflict-free status is based on research concluded by April 19th, 2016 and does not reflect any subsequent changes in this status after such date. Details regarding specific smelter names, countries, and facility locations of 3TG, in and out of covered countries, will be shared upon request for legitimate business purposes.
| 3TG, # of Smelters: | 45 Smelters with Locations in Covered Countries: |
Gold: 5 Smelters | 12 Locations in 7 CCs: · 5 CFSP CF Compliant Smelters - includes presence in the following countries: DRC (4); Burundi (1); Uganda (2); Tanzania (1); Central African Republic (1); Zambia (2); South Sudan (1) |
| | |
Tantalum: 19 Smelters | 63 Locations in 9 CCs: · 18 CFSP CF Compliant Smelters - includes presence in the following countries: DRC (16); Burundi (8); Uganda (8); Tanzania (2); Central African Republic (8); Zambia (2); South Sudan (7); Rwanda (9); Republic of the Congo (2) · 1 CF Unconfirmed Smelter but have reason to believe CF - includes presence in the following country: DRC |
| | |
Tin: 6 Smelters | 11 Locations in 4 CCs: · 4 CFSP CF Compliant Smelters - includes presence in the following countries: DRC (3); Rwanda (3); Burundi (1); Tanzania (1) · 1 CFSP CF Active Smelter from the following country: Rwanda (1) · 1 CF unknown status - may have presence in the following countries: DRC (1); Rwanda (1) |
| | |
Tungsten: 15 Smelters | 41 Locations in 11 CCs: · 10 CFSP CF Compliant Smelters - includes presence in the following surrounding countries: DRC (6); Rwanda (3); Uganda (5); Burundi (7); Tanzania (1); Central African Republic (4); Zambia (1); Angola (1); South Sudan (4); Republic of the Congo (1 ) · 1 CFSP Active Smelter - includes presence in the following country: DRC · 1 CF unconfirmed Smelter but have reason to believe CF includes presence in the following countries: DRC (1) Rwanda (1); Zambia (1) · 3 CF unknown status - includes presence in the following countries: DRC (2); Rwanda (2); Burundi (1) |
| | |
Summary:
The CF status for all smelters that may have facilities located in DRC and surrounding countries:
| · | For gold: smelters appear to be 100% CF |
| · | For tantalum: smelters appear to be 100% CF |
| · | For tin: smelters appears to be 83% CF |
| · | For tungsten: smelters appear to be 80% CF |
| Ø | 91% of all smelters in the DRC and surrounding countries appear to be conflict-free (41 out of 45 smelters) |
Conclusion:
The conflict-free status of the 45 smelters listed as a having a presence in the DRC and surrounding countries is as follows:
| · | 37 (82%) are CFSP CF Certified |
| · | 0 (0%) are Progressing Toward CFSP Certification |
| · | 2 (4%) are believed to be CF due to LBMA accreditation and/or website statement |
| · | 4 (9%) are unknown CF status (U/K), as no information was available from public sources and the smelters did not respond to the RCOIs sent |
| Ø | 87% of smelters in covered countries were participating in a CFSP program |
Improvements:
There was a decrease in total smelters and unique smelters listed in supplier RCOIs from RY2014, indicating that JOI’s suppliers are more educated and knowledgeable regarding identifying smelters in their supply chains by omitting entities that are not valid smelters. This may also indicate that suppliers are possibly performing higher levels of due diligence regarding smelters in their own supply chains.
The increase in total unique smelters in covered countries in RY2015 vs. RY2014 indicates that JOI suppliers are identifying more of the relevant smelters in the supply chain in regards to Dodd-Frank. The net increase in 3TG smelters in covered countries is over 160% since the first reporting year in 2013. These increases are consistent with the number of conflict-free smelters in covered countries from year to year.
Both gold and tantalum in covered countries appear to be 100% conflict-free. The overall conflict-free status increases over 20% in RY2015, which is much smaller compared to the 112% increase in RY2014. This indicates that more of the relevant smelters are being identified in JOI’s supply chain. The lack of material change in the number of conflict status unknown smelters is the same in the last two years, however the smelters with unknown status were different smelters than those identified in RY2014.
The overall increase in conflict-free status in JOI’s supply chain reflects a consistent improvement in our due diligence process and identification of the number of smelters we were able to identify as sourcing 3TG from covered countries.
Details of statistical improvements will be shared upon request for legitimate business purposes.
Determination:
JOI has made a reasonable good faith effort to collect and evaluate all information regarding 3TG smelters in our supply chain as furnished by our in-scope suppliers.
Based on the information provided by JOI in-scope suppliers and the due diligence that JOI performed to identify smelters of 3TG in covered countries, including conducting smelter direct RCOIs, where applicable, JOI has concluded in good faith that certain smelters in its supply chain either do have, or may have, facilities that source 3TG from covered countries.
Based on these due diligence efforts, JOI does not have sufficient information to conclusively confirm that 100% of these smelters are conflict-free at the time of this report or that all of the conflict minerals sourced from them are exclusively from recycled or scrap sources.
Although we have not been able to confirm the identification of and conflict-free status as defined by the CFSP for 100% of the smelters identified in our supply chain, we can confirm that none of the smelters identified by our suppliers are known to us as sourcing 3TG that directly or indirectly finances or benefits armed groups in the DRC or adjoining countries.
Regarding gold and tantalum, JOI can reasonably conclude after its due diligence efforts that 100% of the gold and 100% of tantalum in its supply chain is sourced from smelters that are either conflict-free or that the gold and tantalum are from recycled or scrap sources. 100% of all smelter information is based on identification by JOI suppliers.
Planned Risk Mitigation and Future Due Diligence Measures:
During RY2015 and to present day, JOI has taken certain steps to improve supply chain due diligence and mitigate the risk that any conflict minerals identified in our supply chain benefit any armed groups. The goal of these activities includes supporting a clean and conflict-free minerals trade in the DRC and covered countries and includes the following actions:
| · | Engage internal business group leaders at a deep level for review, analysis, evaluation, and recommendation for risks in each business group. |
| · | Impose direct responsibility for supplier escalations and risk assessment on business group leaders. |
| · | Leverage multi-tiered influence from JOI internal and external resources in order to compel its in-scope suppliers to deliver more current, accurate, timely, and complete information about their smelters of conflict minerals, and increase both response level and quality of responses. |
| · | Leverage multi-tiered influence from JOI internal and external resources to increase response level from in-scope distributors regarding JOI supply chain procedures and increase their participation in supply chain transparency of conflict minerals. |
| · | Increase pressure, specifically on suppliers of electrical and electronic equipment (EEE), to provide current, correct, and more comprehensive smelter information. |
| · | Continue to review commodity classes for veracity and inclusion of EEE. |
| · | Repeat and enhance our annual pro-active supplier communication plan to further assist all suppliers regarding JOI’s need for correct and complete conflict minerals information to satisfy the SEC requirements. |
| · | Use our level of influence to encourage all suppliers to source from smelters validated as compliant to a CFSP assessment protocol using the most recent version of the Conflict-free Sourcing Compliant Smelter List as published by the CFSI or other accredited independent validation scheme or institutional mechanism. |
| · | Use our level of influence to encourage all suppliers to source away from un-validated conflict-free smelters, and to identify the sources of conflict minerals in their supply chains. |
| · | Instruct suppliers to advise JOI if they have reason to believe that any person or entity in their supply chain is directly or indirectly financing or benefiting armed groups in the covered countries and provide a discrete mechanism to do so. |
| · | Through smelter RCOIs and other electronic communication, pressure smelters directly to become verified as having conflict-free sourcing practices and encourage participation in the CFSP audit process. |
Description of Products:
Conflict minerals are found in products that JOI manufactures, or contracts to manufacture. Accessories are included in all groups. The descriptions of product families by business group are as follows:
Marine Electronics Group:
Dive Group:
| · | Dive computers, instruments and gauges |
Outdoor Equipment Group:
| · | Military, party, and event tents |
Watercraft Group:
In Conclusion:
The information presented in this CMR is based on due diligence efforts performed in good faith by JOI and its suppliers. These conclusions and determinations are based on the information available at the time the supplier and smelter RCOIs were made, results analyzed, and metrics recorded. Errors or omissions may be inherent in these results due to errors or omissions in supplier and smelter RCOIs, and the definition of a smelter at the time of the research.
Any information found to be contradictory to this CMR may be communicated to JOI through our early warning risk-awareness conflict minerals grievance mechanism. This open reporting mechanism allows JOI to receive any additional relevant information that may not have been uncovered through our due diligence process in supply chain transparency as it relates to conflict minerals. A link to JOI’s conflict minerals grievance mechanism may be found at the following URL: http://files.shareholder.com/downloads/JOUT/1578683010x0x761719/72FEE43A-0808-4B6D-9DCA-8B25CD3688DE/JOI_CM_Grievance_Mechanism_Final.pdf
Appendix A:
Below is a list of the 3TG smelters with one or more worldwide facilities that JOI suppliers identified to be potentially in our supply chain and that were participating at some level with the Conflict-free Sourcing Initiative (CFSI) as of February 27th, 2016. The presence of a smelter on the list below does not indicate that JOI products necessarily contained conflict minerals processed by that smelter. The location information for each entity was reported by the Conflict-free Smelter Program (CFSP) as of February 27th, 2016.
| 3TG: | Smelter Name: | Location: |
| | | |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Cendres + Métaux SA | SWITZERLAND |
| Gold | Daejin Indus Co., Ltd. | SOUTH KOREA |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Faggi Enrico S.p.A. | ITALY |
| Gold | Geib Refining Corporation | UNITED STATES |
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
| Gold | Argor-Heraeus SA | SWITZERLAND |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | DODUCO GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | CHINA |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Gold | Asahi Refining USA Inc. | UNITED STATES |
| Gold | Asahi Refining Canada Limited | CANADA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Materion | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies SA | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | PAMP SA | SWITZERLAND |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Précinox SA | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | SEMPSA Joyería Platería SA | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Valcambi SA | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | Singway Technology Co., Ltd. | TAIWAN |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Emirates Gold DMCC | Dubai |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN |
| Gold | Bauer Walser AG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | China National Gold Group Corporation | CHINA |
| Gold | Chugai Mining | JAPAN |
| Gold | Colt Refining | UNITED STATES |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | KAZ Minerals | KAZAKHSTAN |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Lingbao Gold Company Limited | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Elemetal Refining, LLC | UNITED STATES |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | So Accurate Group, Inc. | UNITED STATES |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
| Gold | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | CHINA |
| Gold | Morris and Watson | NEW ZEALAND |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF |
| Gold | SAAMP | FRANCE |
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | PT Justindo | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | Operaciones Metalurgical S.A. | BOLIVIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT DS Jaya Abadi | INDONESIA |
| Tin | PT Eunindo Usaha Mandiri | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Rui Da Hung | TAIWAN |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | Yunnan Tin Company, Ltd. | CHINA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | Melt Metais e Ligas S/A | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | PT Inti Stania Prima | INDONESIA |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Sukses Inti Makmur | INDONESIA |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | Estanho de Rondônia S.A. | BRAZIL |
| Tin | Gejiu Zi-Li | CHINA |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
| Tin | Jiangxi Nanshan | CHINA |
| Tin | Linwu Xianggui Smelter Co | CHINA |
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Kudai Tin | INDONESIA |
| Tin | PT Bangka Putra Karya | INDONESIA |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA |
| Tin | PT HP Metals Indonesia | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Seirama Tin investment | INDONESIA |
| Tin | PT Supra Sukses Trinusa | INDONESIA |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | PT HANJAYA PERKASA METALS | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Telex Metals | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | Zhuzhou Cemented Carbide | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | Tranzact, Inc. | UNITED STATES |
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tantalum | E.S.R. Electronics | UNITED STATES |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA |
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
| Tungsten | Niagara Refining LLC | UNITED STATES |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA |
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | Wolfram Bergbau und Hütten AG | RUSSIAN FEDERATION |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | CHINA |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA |
JOI suppliers identified 47 additional entities which are not listed above because they were either not identified by CFSP or the Department of Commerce as valid smelters and/or were not participating in any CFSI program at the time of the report. Consequently, these additional entities are not included in the list above, however, their names may be provided upon request.
