Exhibit 1.01
TAT Technologies Ltd.
Conflict Minerals Report
For The Year Ended December 31, 2016
This report for the year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). For the purpose of the required Reasonable Country of Origin Inquiry (RCOI), TAT Technologies Ltd. continued to receive supply chain responses through May 25, 2017. 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). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as tin, tantalum, tungsten, and gold (3TG) for the purposes of this assessment. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry completed.
If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals' source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report (CMR), to the SEC that includes a description of those due diligence measures.
1. Company Overview
This report has been prepared by the management of TAT Technologies Ltd. (herein referred to as "TAT" the "Company," "we," "us," or "our"). The information includes the activities of all relevant subsidiaries that are required to be consolidated.
TAT Technologies Ltd. is a leading provider of services and products to the commercial and military aerospace and ground defense industries. TAT operates under four segments: (i) Original Equipment Manufacturing or "OEM" of Heat Management Solutions (ii) Heat Transfer Services and Products (iii) Maintenance, Repair and Overhaul or "MRO" services of Aviation Components; and (iv) overhaul and coating of jet engine components.
TAT's activities in the area of OEM Heat Management Solutions are focused on the design, development, manufacture, and sale of the following: (i) a broad range of heat transfer components including heat exchangers, pre-coolers and oil/fuel hydraulic coolers used in mechanical and electronic systems on-board commercial, military and business aircraft; (ii) environmental control and cooling systems on board aircraft and for ground applications; and (iii) a variety of other electronic and mechanical aircraft accessories and systems such as pumps, valves, power systems and turbines.
TAT's activities in the area of Heat Transfer Services and Products include the maintenance, repair and overhaul of heat transfer equipment and to a lesser extent, the manufacture of certain heat transfer product parts. TAT's Limco subsidiary operates an FAA certified repair station, which provides heat transfer MRO services and products for airlines, air cargo carriers, maintenance service centers and the military.
TAT's activities in the area of MRO services for Aviation Components include the maintenance, repair and overhaul of APUs, Landing Gears and other aircraft components. TAT's Piedmont subsidiary operates an FAA certified repair station, which provides aircraft component MRO services for airlines, air cargo carriers, maintenance service centers and the military.
TAT's activities in the area of jet engine overhaul includes the overhaul and coating of jet engine components such as turbine vanes and blades, fan blades, variable inlet guide vanes, afterburner flaps and other components.
2. Products Overview
TAT is principally engaged in the following activities:
· | Design, development, manufacture and sale of a broad range of heat transfer equipment and solutions; |
· | Remanufacture, overhaul and repair of heat transfer equipment; |
· | Maintenance, repair and overhaul of auxiliary power units, landing gears and related components; |
· | Design, development and manufacture of aviation and flow control accessories including fuel components, secondary power systems, and various instrumentation and electronic assemblies; and |
· | Design, development and manufacture of environmental control and cooling systems. |
· | Overhaul and coating of jet engine components |
The products developed, repaired, and maintained by TAT are primarily used for airborne systems on commercial and military aircrafts as well as for defense ground systems. The principal markets of TAT are in Israel, Europe and the United States.
Based upon TAT's internal assessment that included review of all company products in order to identify the products that may include the relevant minerals, the Company uses all 3TG through its OEM manufacturing processes and as such may be included in Heat Exchangers Cores, Air Conditioners manufactured by us and Overhaul and coating of jet engine components. Other TAT's activities have been excluded from the process since these activities involve repair and maintenance services, which are excluded from the rule requirements.
3. Reasonable Country of Origin Inquiry (RCOI)
Based on our products analysis, TAT has concluded in good faith that during the calendar year 2016, out of the above SEC defined "Conflict Minerals", Gold, Tantalum, Tungsten and tin can be found in our products. Therefore, the products that we manufacture are subject to the reporting obligations of Rule 13p-1. A suppliers list, which TAT Technologies purchased from during calendar year 2016, was issued using TAT's IT systems by the purchasing department manager. The total number of the suppliers in the list was approximately 700 suppliers. The list was segmented according to the type of material or component the supplier provides such as: papers, rubber, plastic, metal, electronics, etc. All of the suppliers' categories were excluded (a total of 688 suppliers) except for the electronics category, since these suppliers provided other components than "Electronics", which did not contain Conflict Minerals or that the suppliers provide components which are not necessary to the functionality or production of the products. TAT's finalized level 1 suppliers list includes 14 suppliers (2 of our identified suppliers sent 2 questionnaires) one of the suppliers did not send any questionnaire. The cumulative number of questionnaires received was 13.
The methods we used in order to determine the origin of Conflict Minerals in our products included:
● | Sending letters to our direct suppliers, explaining the rule and referring the suppliers to online training materials and instructions; | |
● | Soliciting survey responses from relevant suppliers of components of our products, using the most updated version of the standard Conflict Minerals Reporting Template (CMRT) designed by the CFSI; | |
● | Reviewing responses that we received from our suppliers and following up on inconsistent, incomplete, and inaccurate responses; and | |
● | Sending reminders to suppliers who did not respond to our requests for information. |
Our supply chain is complex. There are multiple tiers between our company and the relevant smelters and refineries. Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components which are included in our products. Using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard CFSI/CFS program, and continuing our outreach efforts we hope to further develop transparency into our supply chain.
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Despite having conducted a good faith reasonable country of origin inquiry, we have been unable to determine the origin of all of the 3TG used in our products. Therefore we have performed the due diligence activities and detailed these efforts in this Conflict Minerals Report.
4. Design of Due Diligence
Our due diligence processes and efforts have been developed and adjusted in conjunction with the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing and the related supplements for gold, tin, tantalum and tungsten.
5. Due Diligence Performed
The due diligence measures we performed are presented below according to the five-step framework established by the OECD:
Step 1. Establish Strong Company Management Systems
Conflict Minerals Policy
Our policy is published on our company's website. As mentioned in our policy, TAT strives to only use 3TG minerals from smelters that have been audited and verified as conflict free by the Conflict Free Smelter Program ("CFSP") or equivalent programs as they become available. Our policy with respect to the sourcing of Conflict Minerals can be found at http://www.tat-technologies.com/Corporate-Governance-Documents.html .
Internal Team
The Company established a management system for complying with the applicable rules. Our management system includes the development of a Conflict Minerals Task Force led by our Chief Financial Officer and a team of subject matter personnel from relevant functions in the Company such as, purchasing, quality assurance, engineering and manufacturing.
Supplier Engagement
As part of our efforts to strengthen engagement with suppliers, we direct and provide our suppliers with training and electronic instruction related to Conflict Minerals, including the CMRT, our Conflict Minerals policy, and FAQs from the U.S. Securities and Exchange Commission. In addition, suppliers that handle 3TG are expected to have their own programs for implementing their own policies.
Procurement processes
TAT is maintaining its standard Terms and Conditions with suitable Conflict Minerals contractual language which requires our suppliers to comply with the rule's reporting requirements.
Maintain records
TAT is maintaining a due diligence compliance process and set forth documentation and record maintenance mechanism to ensure the retaining of relevant documentation in a structured electronic database.
Grievance Mechanism
TAT is maintaining a grievance mechanism which is published on our policy. Whereby concerns and violations of the Conflict Minerals Policy can be reported to its non-executive members or its subcommittees through our official grievance channels (at: ayehuda@turbochrome.com).
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Step 2. Identify and Assess Risks in the Supply Chain
In order to identify risks in our supply chain we assessed two primary risks:
1. | The risk of not receiving on time and accurate information from the supplier; and |
2. | The risk of not being able to replace a supplier while trying to move towards the goal of being a conflict free company. |
We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers characteristics, such as: the geographical location of the supplier or manufacturer, whether or not the supplier is a SEC registrant, volume of spending during 2016 and the extent to which the company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to invest our risk mitigation efforts according to the supplier level of risk.
As part of the risk assessment phase, we have identified that out of the responses received, 92.3% of TAT's in scope suppliers and manufacturers list have policy in place, which addresses the Conflict Minerals sourcing in the products provided to TAT.
We relied on these supplier's responses to provide us with information about the source of Conflict Minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.
We have identified, to the best of our efforts, the smelters/refiners in the supply chain by conducting a supply chain survey using the CMRT in order to facilitate disclosure and communication of information regarding smelters that provide materials to our supply chain. In addition, TAT compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "Conflict Free" designation from the CFSP.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
TAT continues to work with suppliers who are sourcing from non-conflict free smelters to move towards using Conflict Free smelters within a reasonable time frame. Our management strategy includes: Follow-up processes (including e-mail communication and manual outreach) to escalate any identified issues associated with non-responsive or problematic responses and reviewed in scope suppliers' responses to track smelters and refiners in our supply chain that supply us with Conflict Minerals and have not received a conflict-free designation based on the CFSP or other independent third party validation program..
The supply chain Due Diligence is a dynamic process which requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process occasionally and update the risk mitigation strategy accordingly. Senior management is briefed about the results of our due diligence efforts on a regular basis. We are periodically reporting to the Audit Committee with respect to our due diligence process and compliance obligations.
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices
The Company does not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain the 3TG. However, we do rely upon the industry (for example, CFSI) efforts to influence smelters and refineries to get audited and certified through CFSI's CFS program.
Step 5. Report Annually on Supply Chain Due Diligence
In addition to this report, for further information about our supply chain Conflict Minerals policy, including our approach for supply chain due diligence and supplier expectation, please see it at: http://www.tat-technologies.com/Press-Releases.html.
6. Results of Assessment
We conducted a supply-chain survey of the 14 suppliers we identified as potential providers of necessary Conflict Minerals to our products.
The overall response rate to this survey was approximately 92.8% containing the presumed names and locations of smelters and refiners (see Annex 1) and country of origin see (Annex 2) which process Conflict Minerals. We received 13 questionnaires Of this response rate, 2 suppliers reported that their products do not contain Conflict Minerals and 8 suppliers reported that they are conflict free (both from DRC and not from DRC).
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By adopting a methodology based on the OECD guidelines and the CFSI template, TAT concludes that the information gathered from the smelters and refiners in its supply chain represents the most reasonable known mine of origin information available as the OECD Due Diligence Guidance is currently the best known efforts to obtain mine and country of origin information.
TAT has encountered difficulty in identifying entities downstream from TAT's products. Therefore, TAT relies on its direct suppliers to provide information about the source of Conflict Minerals contained in the components supplied to TAT.
In addition, information gathered from TAT's suppliers is not on a continuous, real-time basis. Therefore, TAT can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals, since the information comes from direct and secondary suppliers and independent third party audit programs
Smelters and refiners verified as conflict free or in the audit process:
Tin | 70 of 97 (72%) |
Tantalum | 43 of 54 (80%) |
Tungsten | 38 of 51 (74.5%) |
Gold | 96 of 130 (74%) |
Total | 247 of 332 (74.5%) |
Status of identified smelters and refiners:
2016 | ||||
Verified Conflict Free | 236 | |||
Participating in an audit process | 11 | |||
Total | 247 |
7. Continuous improvement efforts to mitigate risk
As we move towards developing our due diligence program, we intend to take the following steps to continue to mitigate any possible risk that the necessary Conflict Minerals in our products could benefit armed groups in the DRC or adjoining countries:
· | TAT will continue working with its global supply chain to ensure responsible sourcing and assure compliance with international regulations |
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Safe Harbor for Forward-Looking Statements
This press release contains forward-looking statements which include, without limitation, statements regarding possible or assumed future operation results. These statements are hereby identified as "forward-looking statements" for purposes of the safe harbor provided by the Private Securities Litigation Reform Act of 1995. These forward-looking statements involve risks and uncertainties that could cause our results to differ materially from management's current expectations. Actual results and performance can also be influenced by other risks that we face in running our operations including, but are not limited to, general business conditions in the airline industry, changes in demand for our services and products, the timing and amount or cancellation of orders, the price and continuity of supply of component parts used in our operations, the change of control that will occur on the sale by the receiver of the Company's shares held by our previously controlling stockholders, and other risks detailed from time to time in the Company's filings with the Securities Exchange Commission, including, its annual report on form 20-F and its periodic reports on form 6-K. These documents contain and identify other important factors that could cause actual results to differ materially from those contained in our projections or forward-looking statements. Stockholders and other readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date on which they are made. We undertake no obligation to update publicly or revise any forward-looking statement.
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Annex 1- listing smelter or refiner names in supply chain
Metal | Smelter Name | Smelter Country |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL |
Gold | Argor-Heraeus S.A. | SWITZERLAND |
Gold | Asahi Pretec Corp. | JAPAN |
Gold | Asahi Refining Canada Ltd. | CANADA |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
Gold | Aurubis AG | GERMANY |
Gold | Bangalore Refinery | INDIA |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
Gold | Smelter not listed | GERMANY |
Gold | Boliden AB | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | GERMANY |
Gold | Caridad | MEXICO |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
Gold | Cendres + Métaux S.A. | SWITZERLAND |
Gold | Chimet S.p.A. | ITALY |
Gold | Chugai Mining | JAPAN |
Gold | Daejin Indus Co., Ltd. | KOREA (REPUBLIC OF) |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
Gold | DSC (Do Sung Corporation) | KOREA (REPUBLIC OF) |
Gold | DODUCO GmbH | GERMANY |
Gold | Dowa | JAPAN |
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Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
Gold | Smelter not listed | ITALY |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
Gold | Guangdong Jinding Gold Limited | CHINA |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Ltd. Hong Kong | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Gold | HwaSeong CJ Co., Ltd. | KOREA (REPUBLIC OF) |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
Gold | Kazzinc | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND |
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Gold | Kojima Chemicals Co., Ltd. | JAPAN |
Gold | Smelter not listed | 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 Co., Ltd. | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
Gold | LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
Gold | Materion | UNITED STATES OF AMERICA |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
Gold | Metalor Technologies S.A. | SWITZERLAND |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
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 | Morris and Watson | NEW ZEALAND |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
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Gold | Smelter not listed | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Précinox S.A. | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA |
Gold | Royal Canadian Mint | CANADA |
Gold | SAAMP | FRANCE |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
Gold | SAFINA A.S. | CZECH REPUBLIC |
Gold | Samduck Precious Metals | KOREA (REPUBLIC OF) |
Gold | Samwon Metals Corp. | KOREA (REPUBLIC OF) |
Gold | SAXONIA Edelmetalle GmbH | GERMANY |
Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyería Platería S.A. | SPAIN |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
Gold | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
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Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
Gold | Tony Goetz NV | BELGIUM |
Gold | Torecom | KOREA (REPUBLIC OF) |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
Gold | Valcambi S.A. | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH | GERMANY |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN |
Gold | Yokohama Metal Co., Ltd. | JAPAN |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA |
Tantalum | Duoluoshan | CHINA |
Tantalum | E.S.R. Electronics | UNITED STATES OF AMERICA |
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | Smelter not listed | CHINA |
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 |
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Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd. | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA |
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 and Smelting Co., Ltd. | JAPAN |
Tantalum | Molycorp Silmet A.S. | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
Tantalum | Smelter not listed | AUSTRIA |
Tantalum | Plansee SE Liezen | AUSTRIA |
Tantalum | Plansee SE Reutte | AUSTRIA |
Tantalum | QuantumClean | UNITED STATES OF AMERICA |
Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES OF AMERICA |
Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA |
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Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES OF AMERICA |
Tin | An Thai Minerals Co., Ltd. | VIET NAM |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Dua Sekawan | INDONESIA |
Tin | CV Gita Pesona | INDONESIA |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | CV Tiga Sekawan | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Dowa | JAPAN |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
Tin | Elmet S.L.U. | SPAIN |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Estanho de Rondônia S.A. | BRAZIL |
Tin | Smelter not listed | GERMANY |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
Tin | Gejiu Jinye Mineral Company | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
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Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
Tin | Smelter not listed | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
Tin | Smelter not listed | MALAYSIA |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
Tin | Metallo-Chimique N.V. | BELGIUM |
Tin | Mineração Taboca S.A. | BRAZIL |
Tin | Minsur | PERU |
Tin | Mitsubishi Materials Corporation | JAPAN |
Tin | Modeltech Sdn Bhd | MALAYSIA |
Tin | Smelter not listed | CHINA |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | Smelter not listed | RUSSIAN FEDERATION |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Smelter not listed | INDONESIA |
Tin | PT Aries Kencana Sejahtera | INDONESIA |
Tin | PT Artha Cipta Langgeng | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
Tin | PT Babel Inti Perkasa | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Bangka Prima Tin | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
14
Tin | PT Belitung Industri Sejahtera | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Bukit Timah | INDONESIA |
Tin | PT Cipta Persada Mulia | INDONESIA |
Tin | PT DS Jaya Abadi | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Inti Stania Prima | INDONESIA |
Tin | PT Justindo | INDONESIA |
Tin | PT Karimun Mining | INDONESIA |
Tin | PT Kijang Jaya Mandiri | INDONESIA |
Tin | PT Mitra Stania Prima | INDONESIA |
Tin | PT Panca Mega Persada | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Prima Timah Utama | INDONESIA |
Tin | PT Refined Bangka Tin | INDONESIA |
Tin | PT Sariwiguna Binasentosa | INDONESIA |
Tin | Smelter not listed | INDONESIA |
Tin | PT Stanindo Inti Perkasa | INDONESIA |
Tin | PT Sukses Inti Makmur | 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 Tirus Putra Mandiri | INDONESIA |
Tin | PT Tommy Utama | INDONESIA |
Tin | PT Wahana Perkit Jaya | INDONESIA |
Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
Tin | VQB Mineral and Trading Group JSC | VIET NAM |
Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | ACL Metais Eireli | BRAZIL |
15
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Smelter not listed | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Smelter not listed | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck GmbH | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
Tungsten | Smelter not listed | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd. | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
16
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Moliren Ltd | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
Tungsten | Smelter not listed | RUSSIAN FEDERATION |
Tungsten | Smelter not listed | VIET NAM |
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 | Woltech Korea Co., Ltd. | KOREA (REPUBLIC OF) |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
Gold | Colt Refining | UNITED STATES |
Tantalum | Global Advanced Metals | UNITED STATES |
Tantalum | H.C. Starck Group | GERMANY |
Tantalum | Kemet Blue Powder | UNITED STATES |
Tantalum | Shanghai Jiangxi Metals Co. Ltd | CHINA |
Tantalum | Tantalite Resources | SOUTH AFRICA |
Tin | Metallo Chimique | BELGIUM |
Tin | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
Tungsten | HC Starck GmbH | GERMANY |
Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION |
Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | CHINA |
17
Annex 2- country of origin
Gold | Tantalum | Tin | Tungsten |
AUSTRALIA | AUSTRIA | BELGIUM | AUSTRIA |
AUSTRIA | BRAZIL | BOLIVIA | BRAZIL |
BELGIUM | CHINA | BRAZIL | CHINA |
BRAZIL | ESTONIA | CHINA | GERMANY |
CANADA | GERMANY | GERMANY | JAPAN |
CHINA | INDIA | INDONESIA | KOREA (REPUBLIC OF) |
CZECH REPUBLIC | JAPAN | JAPAN | PHILIPPINES |
FRANCE | KAZAKHSTAN | MALAYSIA | RUSSIAN FEDERATION |
GERMANY | MEXICO | NEW ZEALAND | UNITED STATES OF AMERICA |
HONG KONG | RUSSIAN FEDERATION | PERU | VIET NAM |
INDIA | SOUTH AFRICA | PHILIPPINES | |
INDONESIA | THAILAND | POLAND | |
ITALY | UNITED STATES OF AMERICA | RUSSIAN FEDERATION | |
JAPAN | SPAIN | ||
KAZAKHSTAN | TAIWAN, PROVINCE OF CHINA | ||
KOREA (REPUBLIC OF) | THAILAND | ||
KYRGYZSTAN | UNITED STATES OF AMERICA | ||
MEXICO | VIET NAM | ||
NETHERLANDS | |||
NEW ZEALAND | |||
NORWAY | |||
PERU | |||
PHILIPPINES | |||
POLAND | |||
RUSSIAN FEDERATION | |||
SAUDI ARABIA | |||
SINGAPORE | |||
SOUTH AFRICA | |||
SPAIN | |||
SWEDEN | |||
SWITZERLAND | |||
TAIWAN, PROVINCE OF CHINA | |||
THAILAND | |||
TURKEY | |||
UNITED ARAB EMIRATES | |||
UNITED STATES OF AMERICA | |||
UZBEKISTAN | |||
ZIMBABWE |
18