Exhibit 1.01
Advanced Photonix, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2013
This report for the year ended December 31, 2013 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), Advanced Photonix continued to receive supply chain responses through May 21, 2014. 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 cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to 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.
The report presented herein is not audited as the Rule provides that if a registrant’s products are “DRC conflict undeterminable” in 2013 or 2014, the CMR is not subject to an independent private sector audit.
1. Company Overview
This report has been prepared by management of Advanced Photonix, Inc. (herein referred to as “Advanced Photonix” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries (Picometrix and Advanced Photonix Canada, Inc.).
We are a leading test and measurement company that packages optoelectronic semiconductors into high-speed optical receivers (“HSOR” products), custom optoelectronic subsystems (“Optosolutions” products) and Terahertz instrumentation (“THz” products), serving a variety of global markets. We have approximately 130 employees worldwide and maintain sales and distribution operations across the United States, Europe, Latin America and Asia. We were incorporated in Delaware in 1988. Our principal executive offices are located at 2925 Boardwalk Drive, Ann Arbor, MI 48104.
2. Products Overview
Advanced Photonix’ product lines fundamentally change a light signal into an electrical signal. Our HSOR transmission products are deployed in the internet infrastructure to enable the high-speed bandwidth necessary to support video and data for your TV, computer, tablet or smart phone anytime and anywhere. Our communication test and measurement products (“Comtest”) are used to develop, manufacture and test optical communication equipment used in the telecom infrastructure. Our Optosolutions products are sold to a number of scientific instrumentation manufacturers for various applications such as metrology, currency validation, flame monitoring, solar panel quality, temperature sensing, particle detection, color sensing, infrared detection and many other applications that can only be done through optical sensing. Our T-Gauge® systems are used to measure and verify physical properties on-line and in real-time to reduce raw materials and rework costs in manufacturing processes as well as conduct quality control monitoring. Our established and growing patented Terahertz technology has allowed us to expand from the laboratory market into the 24/7 industrial process and quality control manufacturing, military/aerospace, and security markets.
Based upon Advanced Photonix’ internal assessment, much of the electronic components, photodiodes, module bodies and printed circuit boards used in our products contain conflict minerals and they are necessary to the functionality of the product.
3. Supply Chain Overview
In order to manage the scope of this task, Advanced Photonix relies upon our 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 sub-tier suppliers. Our suppliers are expected to provide the 3TG sourcing information to us due to our contractual relationship.
4. Reasonable Country of Origin Inquiry (RCOI) and RCOI conclusion:
Advanced Photonix has performed a purchasing and engineering review of the approximately 12,000 components used in the assembly of our products to determine which vendors may have provided us components that are likely to contain 3TG. Therefore, the products that we manufacture are subject to the reporting obligations of Rule 13p-1.
We identified approximately 152 vendors from which we purchased materials that were likely to contain the conflict minerals. We sent surveys to these 152 vendors using the questionnaire developed by the Electronic Industry Citizen Coalition (EICC) global e-sustainability initiative (GeSI). The surveys assist members of the supply chain in identifying the origin of the conflict materials used through a centralized list of conflict free smelters which has been put together by the coalition. We received responses from 51 or 34% of the vendors. None of these vendors indicated they were using conflict minerals. Since the vast majority of component suppliers have not provided us conflict minerals country of origin information, the origin of conflict minerals used in our products is undeterminable for 2013.
Due to the breath and complexity of Advanced Photonix’ products and respective supply chain, it will take time for many of our suppliers to verify the origin of all of the minerals. Using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard EICC program, and continuing our outreach efforts we hope to further develop transparency into our supply chain.
5. Conflict Minerals Status Analysis and Conflict Status conclusion:
Advanced Photonix has concluded that our supply chain remains “DRC conflict undeterminable”. We have reached this conclusion because we have been unable to determine the origin of all of the 3TG used in our products.
6. Due Diligence Program
6.1.Conflict Minerals Policy
Advanced Photonix, Inc.
Conflict Minerals Policy
January 1, 2014
There has been increased awareness regarding the human rights violations in the mining of certain minerals from an area known as the “Conflict Region”; the Democratic Republic of the Congo (DRC) and surrounding countries. Through the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, publically traded companies have been chartered to practice reasonable due diligence with their supply chain to determine if “conflict minerals” used in their products are being sourced from mines controlled by non-government or unlawful military groups within the Conflict Region. The definition of “Conflict Minerals” refers to tin, tantalum, tungsten and gold (3TG).
Tracing materials back to their mine of origin is a complex endeavor but an important aspect of responsible sourcing. Advanced Photonix looks to industry guidelines to help establish its programs such as the joint Electronic Industry Citizen Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) which is taking action to address responsible sourcing through the development of the Conflict-Free Smelter (CFS) program aiming to enable companies to source conflict-free minerals.
We are in the process of developing and implementing a strategy to support the objectives of the U.S. regulations on the supply of “Conflict Minerals”. Our commitment includes:
•Developing policies and processes toward preventing the use of conflict minerals or derivative metals necessary to the functionality or production of our product(s) that finance or benefit armed groups in the Conflict Region.
•Not knowingly procure specified minerals that originate from facilities in the “Conflict Region” that are not certified as conflict free.
•Expecting suppliers whose products contain conflict minerals to establish policies, due diligence frameworks, and management systems consistent with the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High Risk-Areas that are designed to accomplish this goal, and requiring their suppliers to do the same.
Advanced Photonix believes in establishing and maintaining long-term relationships with suppliers whenever possible. However, if we determine that any supplier is, or a reasonable risk exists that it may be, violating this policy, then we will require the supplier to commit to devise and undertake suitable corrective action to move to a conflict free source. If suitable action is not taken, we will look to alternative sources for the product. Advanced Photonix’ efforts are not to ban procurement of minerals from the DRC and adjoining countries, but to assure procurement from responsible sources in the region. If we determine that any of the components of our products contain minerals from a mine or facility that is “non-conflict free”, we will work towards transitioning to products that are “conflict free”.
6.2. Due Diligence Process
6.2.1.Design of Our Due Diligence and Description of the Due Diligence Process
Our due diligence processes and efforts have been developed in conjunction with the 2nd edition of The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related supplements for gold and for tin, tantalum and tungsten. Advanced Photonix designed our due diligence process, management and measures to conform in all material respects with the framework OECD Guidance.
Our conflict minerals due diligence process includes: the development of a Conflict Minerals Policy, establishment of governance structures with cross functional team members and senior executives, communication to, and engagement of, suppliers, due diligence compliance process and measurement, record keeping and escalation procedures.
6.2.2.Management Systems
As described above, Advanced Photonix has adopted a company policy which is posted on our website at: www.Advanced Photonix.com.
6.2.3.Internal Team
Advanced Photonix has established a management system for complying with the applicable rules. Our management system includes the development of a Conflict Minerals Task Force led by the Chief Financial Officer, and a team of subject matter experts from relevant functions such as, purchasing, quality assurance, and engineering. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis.
6.2.4.Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, our procurement and engineering team has been responsible for vendor outreach, training, data collection and archiving the received supplier responses to our RCOI. Feedback from this engagement has allowed us to render the conclusions and statement annotated in this report.
6.2.5.Escalation Procedure
Advanced Photonix has established a Conflict Minerals Policy and a Supplier Code of Conduct, which are posted on our website. The Supplier Code of Conduct publishes a mechanism for escalating any issues and concerns. We also created follow-up processes (including e-mail communication) to identify and escalate any identified issues associated with non-responsive or problematic responses to our RCOI.
6.2.6.Maintain records
Advanced Photonix has established our due diligence compliance process and set forth documentation and record maintenance mechanism to ensure the retaining of relevant documentation in a structured electronic database.
6.3.Steps to be taken to mitigate risk and maturing due diligence program
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:
•Enhance supplier communication, training and escalation process to improve due diligence data accuracy and completion.
•Continue to influence additional smelters to obtain CFS status through our supply chain, where possible.
7. Identify and assess risk in the supply chain
Because of our size, the breath and complexity of our products, and the constant evolution of our supply chain, it is difficult to identify actors downstream from our direct suppliers.
We have identified 152 direct suppliers within the scope of our RCOI. We received 51 responses to our request for information. We have 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.
8. Design and Implement a Strategy to Respond to Risks
Advanced Photonix will work with suppliers who are sourcing from non-Conflict Free smelters to move towards using Conflict Free smelters within a reasonable time frame. The time frame will be dependent on the criticality of the specific part and the availability of alternative suppliers.
| 9. Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
Advanced Photonix 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, EICC and CFSI) efforts to influence smelters and refineries to get audited and certified.
10. Report on supply chain due diligence and Results
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: www.Advanced Photonix.com.
10.1.Due Diligence Process
We conducted a survey of Advanced Photonix of the active suppliers described above using the template developed jointly by the companies of Electronic Industry Citizenship Coalition® (EICC®) and The Global e-Sustainability Initiative (GeSI), (the "Template"). The Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. The Template is being widely adopted by many companies in their due diligence processes related to conflict minerals.
10.2.Survey Responses
We received 51 responses to our request for information. We have relied on these supplier’s responses to provide us with information about the source of conflict minerals contained in the components supplied to us.
10.3.Efforts to determine country of origin of mine or 3TG
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. By adopting methodology outlined by the EEIC’s joint industry programs and outreach initiatives and requirement that our suppliers conform with the same standards that meets the OECD guidelines, and report to us using the Template, we have determined that the smelters and refiners we gathered from our supply chain shall represent the most reasonable known mine of origin information available. Through this industry joint effort, we made reasonable determination of the mines or locations of origin of the 3TG in our supply chain. Advanced Photonix also requested that all of our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict Free” lists of sourced metals.
10.4.Smelters or Refiners Identified
At Advanced Photonix, we adopted the EEIC’s industry approach and traced back the origin of 3TG by identifying smelters, refineries or recyclers and scrap supplier sources. Advanced Photonix leveraged EEIC and its program to trace the mine of origin of the 3TG to its ore level. The CFS program audits smelters and refineries to ensure that all certified smelters and refineries only use the ores that are conflict free from the DRC and covered countries.
As the result of our due diligence survey, we have gathered 2,118 smelters and refineries names from our supply chain. Of those, 1,416 smelters and refineries are identified as EEIC’s known smelters and refineries, and 702 smelters and refineries are not validated or verified. The 1,416 smelters and refineries provided to us consolidated down to 317 conflict free smelters as provided by the EEIC. Set forth below is the list of EEIC certified conflict free smelters identified by our supply chain so far and their country of origin.
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tin | CV United Smelting | INDONESIA |
| Gold | Shanghai Gold Exchange | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Gold | AGR Matthey | AUSTRALIA |
| Gold | Aida Chemical Industries Co. Ltd. | JAPAN |
| Tin | AIM | CANADA |
| Gold (Au) | AKK,Asahi Pretec Corp koube koujyo | JAPAN |
| Tungsten | Alldyne Powder Technologies (ATI Firth Sterling) | UNITED STATES |
| Gold | Allgemeine Gold- und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Tungsten | ALMT | JAPAN |
| Tin | Alpha | UNITED STATES |
| Tin (Sn) | Alpha Metals Taiwan | UNITED STATES |
| Gold (Au) | AngloGold Ashanti | BRAZIL |
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL |
| Gold | AngloGold Ashanti Mineração Ltda | BRAZIL |
| Gold | Argor Heraeus | SWITZERLAND |
| Gold | Argor-Heraeus SA | SWITZERLAND |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Asaka Riken Co Ltd | JAPAN |
| Gold (Au) | ATAkulche | TURKEY |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Tungsten | ATI Metalworking Products | UNITED STATES |
| Tungsten | ATI Tungsten Materials | UNITED STATES |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold (Au) | Boliden Mineral AB | SWEDEN |
| Tantalum (Ta) | Cabot | UNITED STATES |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA |
| Gold (Au) | Cendres & Metaux SA | SWITZERLAND |
| Gold (Au) | Central Bank of the DPR of Korea | KOREA, REPUBLIC OF |
| Gold (Au) | Central Bank of the Philippines Gold Refinery & Mint | PHILIPPINES |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tungsten | Chaozhou Xianglu Tungsten Industry Co Ltd | CHINA |
| Tungsten (W) | Chenzhou,Chenzhou Mining Group | CHINA |
| Gold | Chimet S.p.A. | ITALY |
| Tungsten | China Minmetals Corp. | CHINA |
| Tungsten | China Minmetals Nonferrous Metals Co Ltd | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co Ltd | CHINA |
| Gold | Chugai Mining | JAPAN |
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA |
| Gold | Codelco | CHILE |
| Tin | Complejo Metalurgico Vinto S.A. | Bolivia |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Gold | Cookson Group | SPAIN |
| Gold | Cookson Sempsa | SPAIN |
| Tin | Cooper Santa | BRAZIL |
| Tin | CV DS Jaya Abadi | INDONESIA |
| Tin | CV Duta Putra Bangka | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Makmur Jaya | INDONESIA |
| Tin | CV Nurjanah | INDONESIA |
| Tin | CV Prima Timah Utama | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF |
| Gold | DaeryongENC | KOREA, REPUBLIC OF |
| Tin | Daewoo International | KOREA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | Dowa | JAPAN |
| Tantalum (Ta) | Duoluoshan Sapphire Rare Metal Co. Ltd | CHINA |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold (Au) | Ekaterinburg | RUSSIAN FEDERATION |
| Tin | EM Vinto | BOLIVIA |
| Tantalum | Exotech Inc. | UNITED STATES |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tantalum (Ta) | F&X Electro-Materials Limited | CHINA |
| Tin | Fenix Metals | POLAND |
| Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tantalum | Gannon & Scott | UNITED STATES |
| Tungsten | Ganzhou Grand Sea W & Mo Group Co Ltd | CHINA |
| Tungsten | Ganzhou Huaxin Tungsten Products Ltd | CHINA |
| Tungsten | Ganzhou Nonferrous Metals Smelting Co Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W&Mo Co., Ltd. | CHINA |
| Tin | Geiju Non-Ferrous Metal Processing Co. Ltd. | CHINA |
| Tin | Gejiu Zili Metallurgy Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining and Smelting co LTD | CHINA |
| Tantalum | Global Advanced Metals | UNITED STATES |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tin | Gold Bell Group | CHINA |
| Gold (Au) | Great Wall Gold & Silver Refinery | CHINA |
| Tungsten | Guangdong Xianglu Tungsten Industry Co., Ltd. | CHINA |
| Tin | Guangxi Pinggui PGMA Co., Ltd | China |
| Tin (Sn) | Guangxi Zhongshan Gold Bell Smelting Corp.Ltd | CHINA |
| Tantalum | H.C. Starck GmbH | GERMANY |
| Tantalum | H.C. Starck Group | GERMANY |
| Gold | Harmony Gold Refinery | SOUTH AFRICA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus (zhaoyuan)Precious Metal Materials Co.,Ltd. | CHINA |
| Gold | Heraeus GmbH | GERMANY |
| Gold | Heraeus Ltd. Hong Kong | HONG KONG |
| Gold | Heraeus Precious Metals | UNITED STATES |
| Tantalum | Hi-Temp | UNITED STATES |
| Tin | Huichang Jinshunda Tin Co. Ltd | CHINA |
| Tungsten | Hunan Chenzhou Mining Group Co | CHINA |
| Tungsten | Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | CHINA |
| Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold (Au) | Ishifuku Tokyo Melters | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Japan Mint | JAPAN |
| Tungsten | Japan New Metals Co Ltd | JAPAN |
| Gold (Au) | Japanese Mint Osaka | JAPAN |
| Gold (Au) | JCC | CHINA |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Tin | Jiangxi Nanshan | CHINA |
| Tungsten | Jiangxi Rare Earth & Rare Metals Tungsten Group Corp | CHINA |
| Tungsten (W) | Jiangxi Tungsten Industry Co Ltd | CHINA |
| Tungsten | Jiangxi Tungsten Industry Group Co Ltd | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Gold | JM USA | UNITED STATES |
| Tungsten (W) | JNM,Mitsubishi Materials Corporation,Mitsubishi | Japan |
| Gold | Johnson Matthey Canada | CANADA |
| Gold | Johnson Matthey Inc | UNITED STATES |
| Gold | Johnson Matthey Limited | CANADA |
| Gold | Johnson Matthey USA | United States |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Tin | Kai Unita Trade Limited Liability Company | CHINA |
| Gold | Kazzinc Ltd | KAZAKHSTAN |
| Tantalum | Kemet Blue Powder | UNITED STATES |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Kennametal Inc. | UNITED STATES |
| Tin | Ketabang | United Kingdom |
| Tantalum | King-Tan Tantalum Industry Ltd | CHINA |
| Gold | Kojima Chemicals Co., Ltd | JAPAN |
| Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Gold (Au) | L' azurde | SAUDI ARABIA |
| Gold | L' azurde Company For Jewelry | SAUDI ARABIA |
| Tin | Lingbao Jinyuan tonghu | CHINA |
| Tin | Linwu Xianggui Smelter Co | CHINA |
| Tin | Liuzhou China Tin | CHINA |
| Gold (Au) | LS Nikko | KOREA, REPUBLIC OF |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Gold | Materion | UNITED STATES |
| Gold (Au) | Materion Advanced Metals | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Tin (Sn) | Mentok | INDONESIA |
| Tin | METALLIC MATERIALS BRANCHL OF GUANGXI CHINA TIN GROUP CO.,LTD | CHINA |
| Tin | Metallo Chimique | BELGIUM |
| Gold | Metalor Switzerland | SWITZERLAND |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
| Gold | Metalor Technologies SA | SWITZERLAND |
| Gold (Au) | Metalor USA | UNITED STATES |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Met-Mex Peñoles, S.A. | MEXICO |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Minmetals Ganzhou Tin Co. Ltd. | CHINA |
| Tin | Minsur | PERU |
| Tin | Minsur S.A. Tin Metal (&Mineração Taboca S.A.) | UNITED STATES |
| Gold | Mistubishi 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 |
| Tin | Nancang Metal Material Co.,Ltd | CHINA |
| Tin | NANSHAN TINNING | CHINA |
| Gold | Navoi | UZBEKISTAN |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Nihon Material Co. LTD | JAPAN |
| Gold | Ningbo Kangqiang | CHINA |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tantalum (Ta) | Ningxia | CHINA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum (Ta) | Niotan | UNITED STATES |
| Tantalum | Nippon Mining & Metals Co.,Ltd. | JAPAN |
| Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION |
| Gold | Ohio Precious Metals | UNITED STATES |
| Gold | Ohio Precious Metals LLC. | UNITED STATES |
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION |
| Tin | OMSA | BOLIVIA |
| Tin | P.T. Tambang Timah | INDONESIA |
| Gold | PAMP SA | SWITZERLAND |
| Gold (Au) | PAMP SA SWITZERLAND | SWITZERLAND |
| Gold | Pan Pacific Copper Co. LTD | JAPAN |
| Gold | Perth Mint | Australia |
| Tantalum (Ta) | Plansee Group,Plansee Holding AG | AUSTRIA |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Tin | PT Alam Lestari Kencana | INDONESIA |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT Babel Inti Perkasa | 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 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 Fang Di MulTindo | INDONESIA |
| Tin | PT HP Metals Indonesia | INDONESIA |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Koba Tin | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT REFINED BANGKA TIN | INDONESIA |
| Tin | PT Refined Banka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Seirama Tin investment | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tin | PT Tambang Timah | INDONESIA |
| Tin | PT Timah | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tinindo Internusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | PT Yinchendo Mining Industry | INDONESIA |
| Gold (Au) | PX Precinox | SWITZERLAND |
| Gold | PX Précinox SA | SWITZERLAND |
| Gold (Au) | Qiankun Gold and Silver | CHINA |
| Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA |
| Gold (Au) | Rand Refinery Limited | SOUTH AFRICA |
| Tantalum | RFH | CHINA |
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | Sabin | UNITED STATES |
| Gold | Sabin Metal Corp. | UNITED STATES |
| Gold | Samwon Metal | KOREA, REPUBLIC OF |
| Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF |
| Tungsten | Sandvik Material Technology | SWEDEN |
| Gold | Schone Edelmetaal | NETHERLANDS |
| Gold | SD(Samdok) Metal | KOREA |
| Gold | SEMPSA Joyería Platería SA | SPAIN |
| Gold (Au) | Shandong Gold Mining (Laizhou),China's Shangdong Gold Mining Co.,Ltd | CHINA |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Gold | ShanDong Gold Mining Co;Ltd | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd | China |
| Gold | Shanghai Gold Exchange | China |
| Gold (Au) | Shyolkovsky | RUSSIAN FEDERATION |
| Tungsten | Sichuan Metals & Materials Imp & Exp Co | CHINA |
| Tin | Smelting Branch of Yunnan Tin Company Limited | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar | Taiwan |
| Gold (Au) | Solar Applied Materials Taiwan | TAIWAN |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Tantalum (Ta) | Solikamsk | RUSSIAN FEDERATION |
| Tantalum | Solikamsk Metal Works | RUSSIAN FEDERATION |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold (Au) | Sumitomo,Toyo Smelter & Refinery,SMM | JAPAN |
| Gold | Suzhou Xingrui Noble | CHINA |
| Tin (Sn) | Taboca,Paranapanema | BRAZIL |
| Tantalum | Taki Chemicals | JAPAN |
| Gold | Tanaka Denshi Kogyo K.K. | Japan |
| Gold | Tanaka Kikinzoku | Japan |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Tantalum | Tantalite Resources | SOUTH AFRICA |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten (W) | Tejing Tungsten | VIETNAM |
| Tantalum | Telex | UNITED STATES |
| Tin (Sn) | Thailand Smelting and Refining Co. Ltd. | THAILAND |
| Tin | Thaisarco | THAILAND |
| Gold | The Great Wall Gold and Silver Refinery of China | CHINA |
| Gold | The Hutti Gold Company | INDIA |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd | China |
| Gold | Tokuriki Honten Co., Ltd | JAPAN |
| Gold (Au) | Tokuriki Tokyo Melters Assayers | JAPAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Toyo Smelter & Refinery, Japan | Japan |
| Tantalum | Ulba | KAZAKHSTAN |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Tantalum | Ulba Metallurgical Plant, jsc | KAZAKHSTAN |
| Gold | Umicore | BELGIUM |
| Gold | Umicore Brasil Ltda | BRAZIL |
| Gold (Au) | Umicore Feingold | NETHERLANDS |
| Gold | Umicore Precious Metal Refining | UNITED STATES |
| Gold | Umicore SA | BELGIUM |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Tin | UNITED SMELTER | INDONESIA |
| Gold | Valcambi SA | SWITZERLAND |
| Gold | W.C. Heraeus GmbH | GERMANY |
| Tungsten (W) | WBH | AUSTRIA |
| Tin | White Solder Metalurgia | BRAZIL |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Wolfram Company CJSC | RUSSIAN FEDERATION |
| Tungsten | Wolfram JSC | RUSSIAN FEDERATION |
| Tungsten | Xiamen Golden Egret Special Alloy Co. Ltd., | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd | CHINA |
| Tungsten (W) | Xianglu Tungsten Industry Co. Ltd. | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
| Gold | Xstrata Canada Corporation | CANADA |
| Tungsten (W) | XTC,XTC Haicang,XTC H.C. | CHINA |
| Gold | Yokohama Metal Co Ltd | JAPAN |
| Tin | YTCL | CHINA |
| Tin | YUNNAN | CHINA |
| Tin | YUNNAN CHENGEFENG NONFERROUS METALS CO.,LTD | CHINA |
| Tin | Yunnan Chengfeng | CHINA |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tungsten (W) | Zhangyuan Tungsten Co Ltd | CHINA |
| Advanced Photonix Conflict Free Smelter Listing |
| Metal | Smelter | Country |
| Gold | zhaojin,zhaoyuan,Shandong | CHINA |
| Gold | Zhongjin Gold CO.,LTD. | CHINA |
| Gold (Au) | Zhongjin Gold Corporation Limited | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Tantalum | Zhuzhou Cement Carbide | CHINA |
| Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | CHINA |
| Tantalum (Ta) | Zhuzhou,Zhuzhou Cemented Carbide Works Import and Export Co. | CHINA |
| Gold (Au) | Zijin Mining | CHINA |
| Gold | Zijin Mining Group Co. Ltd | CHINA |
| Tin | 云南锡业 | CHINA |
| Tin | 云南锡业股份有限公司 | CHINA |
| Tin | 云南锡业股份有限公司冶煉分公司 (Yunnan Tin Co., Ltd. smelting branch) | CHINA |
| Gold | 山东招金金银精炼有限公司 | CHINA |
| Gold | 山东黄金 | CHINA |
| Gold | 河南中原黄金冶炼厂有限责任公司 | CHINA |
