Exhibit 1.01
Wabash National Corporation
Conflict Minerals Report
For The Year Ended December 31, 2015
This report for the year ending December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “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 (the “Dodd-Frank Act”). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals that 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”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
As described in detail below, following reasonable due diligence conducted with our supply base into the source and chain of custody of Conflict Minerals in our products, we are unable with absolute assurance to determine the origin of the Conflict Minerals in our products and therefore cannot exclude the possibility that some may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or from recycled and scrap sources. For that reason, we are required under the Rule to submit to the SEC this Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the Organization for Economic Cooperation and Development (the “OECD”) Guidance and the Rule, this report is available on our website at www.wabashnational.com. This CMR is not subject to an independent private sector audit in accordance to guidance issued by the SEC in April of 2014.
1. Company Overview
This report has been prepared by management of Wabash National Corporation (herein referred to as “Wabash,” the “Company,” “we,” “us,” or “our”). The information includes the activities of all majority-owned subsidiaries that are required to be consolidated. Headquartered in Lafayette, Indiana, Wabash National Corporation (NYSE: WNC) is a diversified industrial manufacturer and North America’s leading producer of semi-trailers and liquid transportation systems. Established in 1985, the Company manufactures a diverse range of products including: dry freight and refrigerated trailers, platform trailers, bulk tank trailers, dry and refrigerated truck bodies, truck mounted tanks, intermodal equipment, aircraft refueling equipment, structural composite panels and products, trailer aerodynamic solutions, and specialty food grade and pharmaceutical equipment. Its innovative products, which could possibly contain 3TGs, are sold under the following brand names: Wabash National®, Transcraft®, Benson®, DuraPlate®, Walker Transport, Walker Engineered Products, Brenner® Tank, Beall®, Garsite, Progress Tank, Bulk Tank International and Extract Technology®. To learn more, visit www.wabashnational.com
Supply chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify entities upstream from our suppliers who provide us with products and/or raw materials necessary to the functionality or production of our products (“Direct Suppliers”). As such, we rely heavily on our Direct Suppliers to provide information on the origin of the Conflict Minerals contained in components and materials supplied to us – including sources of Conflict Minerals that are supplied to them from lower tier suppliers. Current contracts with most of our key Direct Suppliers, which account for the majority of our sourced materials, are in effect for multiple year terms, thus we cannot unilaterally impose new contract terms and flow-down requirements at this time. As we execute new contracts and/or renew contracts, we are requiring affected Direct Suppliers to provide us with geographic origin information concerning Conflict Minerals and smelters. Additionally, all new Direct Suppliers receive Conflict Minerals reporting requirements as a part of our new supplier information packet. It will take several years to ensure that all of our Direct Suppliers are contractually obligated to report this information to us as part of their normal business interactions with us. In the meantime, as described below, we have established a process to contact affected Direct Suppliers to collect necessary Conflict Minerals sourcing information. We have used and will continue to use the data collected through the process described below, and through our contractually obligated disclosures from our Direct Suppliers, to evaluate our supply chain to ensure compliance with the SEC’s Conflict Minerals rules.
Presently, our supply chain consists of over 12,000 suppliers, including many suppliers providing us with services and/or products that are not necessary to the functionality or production of our products and/or products that do not contain Conflict Minerals. As such, it was not practicable to conduct a survey of our entire supply base. Instead, we targeted only those Direct Suppliers that we believed, based upon an evaluation of the composition of the product and/or raw material they supplied, could possibly supply us with products containing Conflict Minerals. Upon removal of intracompany-supplied products and retail purchases the population of Direct Suppliers surveyed was set at approximately 1,200. The Company contacted these approximately 1,200 Direct Suppliers, requesting each to provide Conflict Minerals geographic origin data in the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”). Surveys conducted with other manufacturing companies confirmed that our risk-based approach to developing our list of our surveyed Direct Suppliers, as described above, is consistent with how many peer companies are approaching the Rule.
At this time, having conducted this due diligence process, our products that are subject to the reporting obligations of the Rule are “DRC conflict undeterminable,” as we are unable to determine all of the following with regard to all Conflict Minerals present in our supply chain that are necessary to the functionality or production of our products: (1) the origin of the Conflict Minerals and/or the 3TG they contain (or to determine whether they come from recycled or scrap sources) or (2) the location of the facilities used to process them and/or origin mines.
Conflict Minerals Policy
Wabash is committed to working with our global supply chain to ensure compliance with the SEC’s Rule. We have established a Conflict Minerals compliance program, as outlined above, that is designed to follow the framework established by the OECD. Our enterprise is fully engaged in implementing that program.
For additional information about our commitment to responsible sourcing and other human rights, see our Conflict Minerals Policy and Code of Business Conduct and Ethics, which are both publicly available on our website at www.wabashnational.com.
2. Due Diligence Process
2.1 Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for Conflict Minerals.
2.2 Establish Strong Company Management Systems
Internal Team
Our Senior Vice President – General Counsel and our Vice President of Global Strategic Sourcing established a cross-functional team of subject matter experts from relevant functions of finance, legal, and supply chain to create our Conflict Minerals compliance program and due diligence efforts necessary to comply with the Rule. As part of this team, our Global Director of Strategic Sourcing, a Strategic Commodity Manager and a Global Strategic Sourcing Assistant lead our ongoing due diligence efforts with our Direct Suppliers. Senior management and members of our Audit Committee are briefed about the results of our due diligence efforts on a regular basis.
Control systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in the transportation industry and other relevant sectors, as well as our own Direct Suppliers to encourage the disclosure of all the conflict mineral status of the upstream entities held in common by our various supply chains. Our due diligence process includes utilization of industry-wide initiatives to disclose upstream entities in the supply chain, such as the CMRT and the CFSI certified smelter list.
Our controls include, but are not limited to, our Code of Conduct which outlines expected behaviors for all Wabash National employees and suppliers. Going forward, as discussed above, our controls will also include contractual disclosure requirements in our Direct Supplier contracts.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have invested in tools and developed internal processes and procedures to query and track supplier activity. In addition, we have included Conflict Minerals reporting requirements in our new supplier packets and we will continue to request Conflict Minerals reporting data annually from all of our Direct Suppliers. We will also utilize key opportunities such as annual Executive Management Reviews with our suppliers to reinforce and review compliance.
Grievance Mechanism
We have multiple mechanisms and processes for employees and suppliers to use to report violations of Wabash’s policies. These are described in our Code of Business Conduct and Ethics policy, which is publicly available on our website at www.wabashnational.com
Maintain records
We have adopted a policy to retain relevant documentation requested from and disclosed by our suppliers.
2.3 Identify and assess risk in the supply chain
As outlined previously, since we do not typically have a direct relationship with 3TG smelters and refiners, our due diligence efforts undertaken to comply with the Rule rely heavily on our Direct Suppliers providing us with information about the source of Conflict Minerals contained in the products and raw materials supplied to us. Our Direct Suppliers are similarly reliant upon information provided by their suppliers. Many of our largest suppliers are also SEC registrants and subject to the Rule. However, our ability to comply with the Rule is dependent upon receipt of complete and accurate information from our Direct Suppliers.
2.4 Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, Wabash has an approved risk management plan, through which the Conflict Minerals program is implemented, managed and monitored. As part of the risk management efforts undertaken as part of the Conflict Minerals program, our Global Director of Strategic Sourcing, a Strategic Commodity Manager and a Global Strategic Sourcing Assistant regularly review Conflict Minerals data provided by our Direct Suppliers. Direct Suppliers who provide incomplete or inconsistent Conflict Minerals data are contacted to update and confirm the data provided until Wabash can conclude with a reasonable degree of certainty that the provided data is likely accurate. Updates regarding our due diligence process and this risk assessment are provided regularly to senior management and the Audit Committee.
As described above, we also utilize and participate in several industry-wide initiatives to disclose the conflict mineral status of upstream entities in the supply chain. We will continue to pursue training and participate in seminars to increase our awareness and further enhance our compliance. As part of our risk management plan, and to ensure suppliers understand our ongoing expectations to provide accurate and complete Conflict Minerals data, we will continue to engage suppliers in various ways such as training sessions, Executive Management Reviews and our annual supplier conference.
2.5 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Since we do not have a direct relationship with 3TG smelters and refiners, we do not perform or direct audits of these upstream entities within our supply chain. We will support audits by our supply base, as necessary, and have augmented our own Direct Supplier audit process with questions and procedures to address compliance by our Direct Suppliers with the Rule.
2.6 Report on supply chain due diligence
Wabash has filed a Form SD which includes this report and made such information available on our website, demonstrating our progress in implementing our Conflict Minerals Policy.
3. Due Diligence Results
Request Information
As described above, we conducted a survey of certain Direct Suppliers using the CMRT, which 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 supplier’s conflict-free policies, engagement with its direct suppliers, and a listing of the smelters the suppliers (and its suppliers) utilize in their own supply chain. In addition, the CMRT contains questions about the origin of Conflict Minerals included in suppliers’ products, as well as suppliers’ due diligence efforts. Written instructions and recorded training illustrating the use of the tool is available on CFSI’s website. The CMRT is being used by many of our peer companies in their due diligence processes related to Conflict Minerals.
Survey Responses
To date, we’ve received responses from 70% of the approximately 1,200 Direct Suppliers surveyed, which represents approximately 99% of Wabash’s direct material spend surveyed in 2015. We reviewed the responses provided against criteria developed to determine whether further engagement with our Direct Suppliers was necessary. These criteria included: (1) untimely or incomplete responses, (2) inconsistencies within the data reported in the CMRT or in other provided documentation, or (3) uncertainty in the accuracy of the data reported in light of the product supplied by the Direct Supplier. We have worked directly with these Direct Suppliers until we received data sufficient to allow Wabash to conclude with a reasonable degree of certainty that the provided data is likely accurate.
Approximately 85% of our responding Direct Suppliers reported using no 3TG in products sold to Wabash; 10% provided insufficient detail rendering their responses undeterminable; 3% reported using 3TG in their products but could not certify the smelters being utilized or their country of origin; and the remaining 2% reported using 3TG from within the Covered Countries from non-certified smelters. In all cases where 3TG was reported being used, it cannot be determined if Conflict Minerals were in the products sold to Wabash. Of the thousands of lines of smelter data reported to us, there were only 318 unique smelter identification numbers reported, of which only 246 smelters were identified, based on the CFSI Conflict-Free Smelter Program Assessment protocol. Of these, 207 were validated as compliant, 35 are active, indicating they have committed to the audit process and 4 tungsten smelters are progressing toward validation. As we do not typically have a direct relationship with 3TG smelters and refiners, and thus are unable to directly audit or request documentation from these facilities, Wabash supports the refinement and expansion of the list of participating smelters through the CFSI program.
Additionally, a large majority of our responding Direct Suppliers provided Conflict Minerals data to us at a company or divisional level – and did not specify whether the particular products, parts or raw materials specifically supplied to Wabash: (1) contained Conflict Minerals or (2) originated from a supply chain that included mines, smelters, or refiners containing/using Conflict Minerals. These “blanket responses” covering the totality of what these Direct Suppliers sell in aggregate to their customers, do not allow us to determine whether any of the Conflict Minerals reported by these Direct Suppliers are actually contained in the particular products, parts or raw materials the Direct Supplier sells specifically to Wabash. Therefore, we are also unable to validate whether any of the smelters or refiners (described above) who were disclosed by our Direct Suppliers as being part of the Direct Supplier’s overall supply chain, are actually part of Wabash’s supply chain.
Efforts to determine mine or location of origin
Through our utilization of CFSI tools, the OECD implementation guidelines, and requesting our Direct Suppliers to complete the CMRT, we have determined that seeking information about 3TG smelters and refiners through our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
Smelters or Refiners
Based on Direct Supplier responses received to date:
| · | 85% of respondents reported using no 3TG in their products and, therefore, utilize no smelters or refiners of concern. |
| · | The remaining 15% of respondents reported either: (1) no smelter information available or (2) a list of smelters utilized in their respective supply chains. |
| · | When smelter and refiner lists included smelter identification numbers in a response, Wabash was able to verify the following about those smelters: |
| · | 65% are conflict –free |
| · | 11% are active |
| · | 1% are progressing toward validation |
| · | 23% are unrecognizable smelter identification numbers |
| · | The majority of our responding Direct Suppliers who do utilize 3TG in some or all of the products they sell to their entire customer base: (1) could not represent to us that any smelter or refiner entities they listed as using Conflict Minerals had actually been included in the supply chain for the products, parts and/or raw materials they supplied to Wabash; and/or (2) reported that it was “not known” or “undetermined” if Conflict Minerals had been utilized by smelters or refiners included in the supply chain for the products, parts and/or raw materials they supplied to Wabash. |
The statements above are based on the Reasonable Country of Origin Inquiry process and due diligence performed in good faith by Wabash. As noted previously, these statements are based solely on the information received from our Direct Suppliers through this process. For a listing of smelters or refiners and their country of origin, reported to Wabash by its suppliers and determined as either compliant, active, or progressing toward validation when compared to the CFSI list, reference Table 1 at the end of this CMR.
4. Steps to be taken to mitigate risk
We intend to take the following steps to improve the due diligence we conduct, in an effort to further mitigate risk that the Conflict Minerals necessary to the functionality or production of our products could benefit armed groups in the Covered Countries:
| a) | Inclusion of Conflict Minerals flow-down requirements in Wabash’s new or renewed Direct Supplier contracts. |
| b) | Revisit annually the scope of Direct Suppliers requested to supply information as part of our due diligence process. |
| c) | Engage with Direct Suppliers, as deemed necessary, directing them to training resources in an attempt to increase the due diligence response rate and improve the content of the Direct Supplier survey responses. |
| d) | Work with the OECD and relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. |
TABLE 1
The facilities verified by the CFSI as “smelters” or “refiners”, which have been reported by Wabash suppliers as processing conflict minerals, are listed below
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Gold | Advanced Chemical Company | CID000015 | Active | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | Compliant | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | Compliant | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | Active | UZBEKISTAN |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | Compliant | BRAZIL |
| Gold | Argor-Heraeus S.A. | CID000077 | Compliant | SWITZERLAND |
| Gold | Asahi Pretec Corp. | CID000082 | Compliant | JAPAN |
| Gold | Asaka Riken Co., Ltd. | CID000090 | Compliant | JAPAN |
| Gold | Aurubis AG | CID000113 | Compliant | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | Compliant | PHILIPPINES |
| Gold | Boliden AB | CID000157 | Compliant | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | Compliant | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | Compliant | CANADA |
| Gold | Cendres + Métaux S.A. | CID000189 | Active | SWITZERLAND |
| Gold | Chimet S.p.A. | CID000233 | Compliant | ITALY |
| Gold | Daejin Indus Co., Ltd. | CID000328 | Active | KOREA, REPUBLIC OF |
| Gold | DSC (Do Sung Corporation) | CID000359 | Active | KOREA, REPUBLIC OF |
| Gold | DODUCO GmbH | CID000362 | Compliant | GERMANY |
| Gold | Dowa | CID000401 | Compliant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | CID000425 | Compliant | JAPAN |
| Gold | OJSC Novosibirsk Refinery | CID000493 | Compliant | RUSSIAN FEDERATION |
| Gold | Heimerle + Meule GmbH | CID000694 | Compliant | GERMANY |
| Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | Compliant | GERMANY |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | Compliant | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | Compliant | JAPAN |
| Gold | Istanbul Gold Refinery | CID000814 | Compliant | TURKEY |
| Gold | Japan Mint | CID000823 | Compliant | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | Compliant | CHINA |
| Gold | Asahi Refining USA Inc. | CID000920 | Compliant | UNITED STATES |
| Gold | Asahi Refining Canada Ltd. | CID000924 | Compliant | CANADA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | Compliant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | CID000929 | Compliant | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | Compliant | JAPAN |
| Gold | Kazzinc | CID000957 | Compliant | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | CID000969 | Compliant | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | Compliant | JAPAN |
| Gold | LS-NIKKO Copper Inc. | CID001078 | Compliant | KOREA, REPUBLIC OF |
| Gold | Materion | CID001113 | Compliant | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | Compliant | JAPAN |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | Active | CHINA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | Compliant | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | Compliant | SINGAPORE |
| Gold | Metalor Technologies S.A. | CID001153 | Compliant | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | CID001157 | Compliant | UNITED STATES |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | CID001161 | Compliant | MEXICO |
| Gold | Mitsubishi Materials Corporation | CID001188 | Compliant | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | Compliant | JAPAN |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | Compliant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | Compliant | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | Active | UZBEKISTAN |
| Gold | Nihon Material Co., Ltd. | CID001259 | Compliant | JAPAN |
| Gold | Elemetal Refining, LLC | CID001322 | Compliant | UNITED STATES |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | Compliant | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | Compliant | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | CID001352 | Compliant | SWITZERLAND |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | Compliant | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | Compliant | INDONESIA |
| Gold | PX Précinox S.A. | CID001498 | Compliant | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | Compliant | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CID001534 | Compliant | CANADA |
| Gold | Samduck Precious Metals | CID001555 | Active | KOREA, REPUBLIC OF |
| Gold | Schone Edelmetaal B.V. | CID001573 | Compliant | NETHERLANDS |
| Gold | SEMPSA Joyería Platería S.A. | CID001585 | Compliant | SPAIN |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | Compliant | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | Compliant | CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | Compliant | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | Compliant | TAIWAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | Compliant | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | Compliant | JAPAN |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | Compliant | CHINA |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | Compliant | JAPAN |
| Gold | Torecom | CID001955 | Active | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | CID001977 | Compliant | BRAZIL |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | Compliant | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | CID001993 | Compliant | UNITED STATES |
| Gold | Valcambi S.A. | CID002003 | Compliant | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | CID002030 | Compliant | AUSTRALIA |
| Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 | Compliant | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | Compliant | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | Compliant | CHINA |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 | Compliant | CHINA |
| Gold | Umicore Precious Metals Thailand | CID002314 | Compliant | THAILAND |
| Gold | Faggi Enrico S.p.A. | CID002355 | Active | ITALY |
| Gold | Geib Refining Corporation | CID002459 | Active | UNITED STATES |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | Compliant | INDIA |
| Gold | Republic Metals Corporation | CID002510 | Compliant | UNITED STATES |
| Gold | KGHM Polska Miedź Spółka Akcyjna | CID002511 | Active | POLAND |
| Gold | Singway Technology Co., Ltd. | CID002516 | Compliant | TAIWAN |
| Gold | Emirates Gold DMCC | CID002561 | Compliant | UNITED ARAB EMIRATES |
| Gold | T.C.A S.p.A | CID002580 | Compliant | ITALY |
| Gold | Korea Zinc Co., Ltd. | CID002605 | Active | KOREA, REPUBLIC OF |
| Gold | SAXONIA Edelmetalle GmbH | CID002777 | Active | GERMANY |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | Active | GERMANY |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | Compliant | AUSTRIA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | Compliant | CHINA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 | Compliant | CHINA |
| Tantalum | Duoluoshan | CID000410 | Compliant | CHINA |
| Tantalum | Exotech Inc. | CID000456 | Compliant | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | Compliant | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | Compliant | CHINA |
| Tantalum | Hi-Temp Specialty Metals, Inc. | CID000731 | Compliant | UNITED STATES |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | Compliant | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | Compliant | CHINA |
| Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 | Compliant | CHINA |
| Tantalum | LSM Brasil S.A. | CID001076 | Compliant | BRAZIL |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | Compliant | INDIA |
| Tantalum | Mineração Taboca S.A. | CID001175 | Compliant | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | CID001192 | Compliant | JAPAN |
| Tantalum | Molycorp Silmet A.S. | CID001200 | Compliant | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | Compliant | CHINA |
| Tantalum | QuantumClean | CID001508 | Compliant | UNITED STATES |
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 | Compliant | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | Compliant | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | CID001869 | Compliant | JAPAN |
| Tantalum | Telex Metals | CID001891 | Compliant | UNITED STATES |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | Compliant | KAZAKHSTAN |
| Tantalum | Zhuzhou Cemented Carbide | CID002232 | Compliant | CHINA |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 | Compliant | CHINA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | Compliant | CHINA |
| Tantalum | D Block Metals, LLC | CID002504 | Compliant | UNITED STATES |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | Compliant | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | Compliant | CHINA |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | Compliant | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | Compliant | CHINA |
| Tantalum | KEMET Blue Metals | CID002539 | Compliant | MEXICO |
| Tantalum | Plansee SE Liezen | CID002540 | Compliant | AUSTRIA |
| Tantalum | H.C. Starck Co., Ltd. | CID002544 | Compliant | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | CID002545 | Compliant | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | CID002546 | Compliant | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | Compliant | GERMANY |
| Tantalum | H.C. Starck Inc. | CID002548 | Compliant | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | CID002549 | Compliant | JAPAN |
| Tantalum | Plansee SE Reutte | CID002556 | Compliant | AUSTRIA |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | Compliant | UNITED STATES |
| Tantalum | Global Advanced Metals Aizu | CID002558 | Compliant | JAPAN |
| Tantalum | KEMET Blue Powder | CID002568 | Compliant | UNITED STATES |
| Tantalum | Tranzact, Inc. | CID002571 | Compliant | UNITED STATES |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | Compliant | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | Active | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | Compliant | CHINA |
| Tin | Alpha | CID000292 | Compliant | UNITED STATES |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | CID000295 | Compliant | BRAZIL |
| Tin | CV Gita Pesona | CID000306 | Compliant | INDONESIA |
| Tin | PT Justindo | CID000307 | Compliant | INDONESIA |
| Tin | PT Aries Kencana Sejahtera | CID000309 | Compliant | INDONESIA |
| Tin | CV Serumpun Sebalai | CID000313 | Compliant | INDONESIA |
| Tin | CV United Smelting | CID000315 | Compliant | INDONESIA |
| Tin | EM Vinto | CID000438 | Compliant | BOLIVIA |
| Tin | Fenix Metals | CID000468 | Compliant | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | Compliant | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | Active | CHINA |
| Tin | China Tin Group Co., Ltd. | CID001070 | Compliant | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | Compliant | MALAYSIA |
| Tin | Metallic Resources, Inc. | CID001142 | Compliant | UNITED STATES |
| Tin | Mineração Taboca S.A. | CID001173 | Compliant | BRAZIL |
| Tin | Minsur | CID001182 | Compliant | PERU |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | Compliant | THAILAND |
| Tin | Operaciones Metalurgical S.A. | CID001337 | Compliant | BOLIVIA |
| Tin | PT Artha Cipta Langgeng | CID001399 | Compliant | INDONESIA |
| Tin | PT Babel Inti Perkasa | CID001402 | Compliant | INDONESIA |
| Tin | PT Bangka Tin Industry | CID001419 | Compliant | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | CID001421 | Compliant | INDONESIA |
| Tin | PT Bukit Timah | CID001428 | Compliant | INDONESIA |
| Tin | PT DS Jaya Abadi | CID001434 | Compliant | INDONESIA |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Tin | PT Eunindo Usaha Mandiri | CID001438 | Compliant | INDONESIA |
| Tin | PT Karimun Mining | CID001448 | Active | INDONESIA |
| Tin | PT Mitra Stania Prima | CID001453 | Compliant | INDONESIA |
| Tin | PT Panca Mega Persada | CID001457 | Compliant | INDONESIA |
| Tin | PT Prima Timah Utama | CID001458 | Compliant | INDONESIA |
| Tin | PT Refined Bangka Tin | CID001460 | Compliant | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | CID001463 | Compliant | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | CID001468 | Compliant | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | CID001477 | Compliant | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | CID001482 | Compliant | INDONESIA |
| Tin | PT Tinindo Inter Nusa | CID001490 | Compliant | INDONESIA |
| Tin | PT Tommy Utama | CID001493 | Compliant | INDONESIA |
| Tin | Rui Da Hung | CID001539 | Compliant | TAIWAN |
| Tin | Soft Metais Ltda. | CID001758 | Compliant | BRAZIL |
| Tin | Thaisarco | CID001898 | Compliant | THAILAND |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | Active | CHINA |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | Compliant | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | Compliant | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | Active | CHINA |
| Tin | Yunnan Tin Company Limited | CID002180 | Compliant | CHINA |
| Tin | CV Venus Inti Perkasa | CID002455 | Compliant | INDONESIA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | Compliant | BRAZIL |
| Tin | PT Wahana Perkit Jaya | CID002479 | Compliant | INDONESIA |
| Tin | Melt Metais e Ligas S.A. | CID002500 | Compliant | BRAZIL |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | Compliant | INDONESIA |
| Tin | Phoenix Metal Ltd. | CID002507 | Active | RWANDA |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | Compliant | PHILIPPINES |
| Tin | PT Inti Stania Prima | CID002530 | Compliant | INDONESIA |
| Tin | CV Ayi Jaya | CID002570 | Compliant | INDONESIA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | Active | VIET NAM |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | Active | VIET NAM |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | Active | VIET NAM |
| Tin | CV Dua Sekawan | CID002592 | Active | INDONESIA |
| Tin | PT Cipta Persada Mulia | CID002696 | Compliant | INDONESIA |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | Active | VIET NAM |
| Tin | Resind Indústria e Comércio Ltda. | CID002706 | Compliant | BRAZIL |
| Tin | Metallo-Chimique N.V. | CID002773 | Compliant | BELGIUM |
| Tin | Elmet S.L.U. | CID002774 | Compliant | SPAIN |
| Tin | PT Bangka Prima Tin | CID002776 | Compliant | INDONESIA |
| Tin | PT Sukses Inti Makmur | CID002816 | Compliant | INDONESIA |
| Tin | An Thai Minerals Co., Ltd. | CID002825 | Active | VIET NAM |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | Active | CHINA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 | Compliant | JAPAN |
| Tungsten | Kennametal Huntsville | CID000105 | Compliant | UNITED STATES |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | Compliant | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | Compliant | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CID000345 | Progressing toward validation | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 | Compliant | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | CID000568 | Compliant | UNITED STATES |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | Compliant | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | Compliant | JAPAN |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 | Progressing toward validation | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | Compliant | CHINA |
| Tungsten | Kennametal Fallon | CID000966 | Active | UNITED STATES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | Compliant | VIET NAM |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 | Compliant | VIET NAM |
| Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | Compliant | AUSTRIA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | Compliant | CHINA |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | Compliant | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | Compliant | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | Active | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | Active | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | Active | CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | Compliant | CHINA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | Compliant | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | Compliant | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | Compliant | CHINA |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | Compliant | VIET NAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | Compliant | CHINA |
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CID002518 | Progressing toward validation | CHINA |
| Tungsten | Pobedit, JSC | CID002532 | Progressing toward validation | RUSSIAN FEDERATION |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CID002535 | Compliant | CHINA |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CID002536 | Compliant | CHINA |
| Tungsten | H.C. Starck GmbH | CID002541 | Compliant | GERMANY |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 | Compliant | GERMANY |
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 | Compliant | VIET NAM |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | Active | CHINA |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CID002578 | Active | CHINA |
| Mineral | Smelter Name | Smelter ID | Status | Country of origin |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CID002579 | Compliant | CHINA |
| Tungsten | Niagara Refining LLC | CID002589 | Compliant | UNITED STATES |
| Tungsten | Hydrometallurg, JSC | CID002649 | Compliant | RUSSIAN FEDERATION |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CID002830 | Active | CHINA |
