EXHIBIT 1.01
UFP Industries, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2023
Introduction
This Conflict Minerals Report (the “Report”) has been prepared by UFP Industries, Inc. for the period from January 1, 2023 to December 31, 2023 (the “Reporting Period”). Unless the context otherwise indicates, “UFP Industries,” “we,” “us,” the “Company” and “our” mean UFP Industries, Inc. and its consolidated subsidiaries.
This Report is presented to comply with Rule 13p-1 promulgated under Section 13(p) of the Securities Exchange Act of 1934, as amended (the “Rule”). This Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines “conflict minerals” as gold, cassiterite, columbite-tantalite, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold (collectively, the “3TGs”) that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.
As described in this Report, we have reason to believe that some of the 3TGs present in our supply chain may have originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively, the “Covered Countries”). Therefore, we performed a reasonable country of origin inquiry (“RCOI”) to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources. Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries and proceeded to conduct due diligence on our supplier base. The results of our RCOI and due diligence are covered below.
Company Overview
Our business
We are a holding company with subsidiaries throughout North America, Europe, Asia, and Australia that supply products primarily manufactured from wood, wood and non-wood composites, and other materials to three markets: retail, packaging, and construction. We are headquartered in Grand Rapids, Michigan.
For additional information, please see Item 1 (captioned “Business”) in our Form 10-K for our fiscal year ending December 30, 2023, filed on February 28, 2024.
Our products
We conducted an analysis of our products to determine which of our products were likely to contain 3TG. We have identified 3TG in certain of our products within our segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period. Our range of products that may contain 3TGs include the following components: non-lumber items sold to retailers (e.g. solar powered post caps) and manufacturing housing and recreational vehicle manufacturers (e.g., electrical and mechanical components) and interior fixtures (e.g. shelving, display cases, and lighting).
Description of RCOI
We began our scoping process by extracting a list of our suppliers that provide us with products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party service provider. This supplier list was then uploaded to our third-party service provider’s software platform that allows us to store and manage supplier requests and documentation.
From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed provided items to UFP Industries that were used in final products in the year 2023.
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Our third-party service provider then conducted the supplier survey portion of the RCOI utilizing the Conflict Minerals Reporting Template (the “CMRT”), version 6.01 or higher, developed by the Responsible Minerals Initiative (“RMI”), and the suppliers identified through the procedures above were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT 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 direct supplier’s conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.
The supplier survey campaign conducted by our third-party service provider began in October 2023 and ended the first week of May 2024. During the campaign, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform. Suppliers were contacted once every three weeks from October through January 2024, then once every week beginning in February 2024 in an escalation format. To ensure that our suppliers understand our expectations regarding the sourcing of 3TGs, we and our third-party service provider provided training to suppliers though webinars, videos, documentation, and one-on-one discussions. Our third-party service provider also sent a “No 3TG” campaign to those suppliers who had reported 3TGs in this campaign.
The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms were accepted and classified as valid or invalid so that data is still retained. Any supplier who submitted a CMRT that was flagged as “invalid” was contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our service provider’s system for future reporting and transparency. As of May 8, 2024, there was one invalid submission.
Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, we proceeded to conduct further due diligence on our supplier base.
Due Diligence
Design of due diligence
We have designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organisation for Economic Co-operation and Development (“OECD”) in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten (collectively, the “Guidance”).
Our conflict minerals due diligence process includes the five steps as set forth in the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by us is outlined below.
Due diligence performed
Establish Strong Company Management Systems
Internal team
We have organized a Conflict Minerals Committee comprised of individuals in the legal department, including a senior attorney. As needed, other management personnel from multiple departments participate and/or assist the Conflict Minerals Committee. The Conflict Minerals Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and overseeing the program.
We have also taken on other management systems that include the use of a third-party vendor. Through our vendor’s tool we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
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Control systems
Controls include, but are not limited to, our Code of Business Conduct and Ethics, our Conflict Minerals Policy, regular monitoring of changes in applicable laws, regulations, and guidance, whistleblower mechanisms, regular training of key employee groups, and on-site visits and audits of our suppliers. Our Conflict Minerals Policy related to our sourcing of 3TGs is posted on our website at http://www.ufpinvestor.com/index.php/corporate-governance/highlights within the “Investor Relations” section under “Corporate Governance”.
Supplier engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 6.01 or higher and a third-party vendor’s software reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.
We have also communicated with suppliers potentially affected by our compliance efforts as identified through our RCOI process our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TG identified in our products. We have provided suppliers access to our Conflict Minerals Policy through the website above or upon request.
Grievance mechanism
We maintain several methods in which employees or third parties may notify us of potential issues with our conflict minerals program, including an anonymous employee hotline, email resources both internally and on our website, direct phone numbers, and our open door policy.
Maintain records
We maintain company-wide document retention policies. These policies extend to the documentation accumulated in performing our 3TG due diligence procedures and requires that documentation will be retained for a period of five (5) years.
Identify and Assess Risks in the Supply Chain
It is important to note that UFP Industries has relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices.
UFP Industries, through its third-party vendor, reviews all responses against set criteria that have been developed to determine whether further communication is needed. These criteria include: non-responsiveness, incomplete responses, company-level CMRT, and overall inconsistencies.
Additionally, many companies continue to report “unknown” or having information from less than 75% of their suppliers, and therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.
Risks were further identified by assessing the due diligence practices and the status of the smelters and refiners identified in the CMRTs provided to UFP Industries. Our third-party vendor compared the facilities listed in the responses to the list of smelters and refiners maintained by RMI to ensure that the facilities met the recognized definition of a 3TG processing facility that was operational during 2023. Our vendor also determined if the smelter or refiner had been audited against a standard in conformance with the OECD Guidance, such as RMI’s Responsible Minerals Assurance Process. Smelters or refiners that completed RMI’s Responsible Minerals Assurance Process are considered to be DRC-conflict free. In cases where the smelter’s or refiner’s due diligence practices have not been audited against RMI’s Responsible Minerals Assurance Process, follow-ups are made to these suppliers. Smelters are then assessed for the potential for sourcing risk.
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Each facility that meets the definition of a smelter or refiner of a 3TG mineral is assessed according to red-flag indicators defined in the OECD Guidance. Several factors are used to determine the level of risk, including:
| 1. | Geographic proximity to the DRC and Covered Countries; |
| 2. | Known mineral source country of origin; |
| 3. | Responsible Minerals Assurance Process status; |
| 4. | Credible evidence of unethical or conflict sourcing; |
| 5. | Peer assessment conducted by credible third-party sources. |
Risk mitigation activities are initiated by our third-party vendor whenever a supplier’s CMRT reported facilities of concern. Our vendor provides feedback to such suppliers instructing that supplier to take their own independent risk mitigation actions. Examples include the submission of a product-specific CMRT to better identify the connection to products that they supply to us. Additional escalation may have been necessary to address any continued sourcing from these smelters of concern.
As per the OECD Guidance, risk mitigation will also depend on the supplier’s specific context. If necessary, suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.
In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.
Finally, suppliers are evaluated on program strength, which assists in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on certain questions in the CMRT related to the supplier’s conflict mineral practices and policies, including:
A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Does your review process include corrective active management?
H. Do you verify due diligence information received from your suppliers?
Design and Implement a Strategy to Respond to Identified Risks
UFP Industries has established a Conflict Minerals Policy that outlines our expectations for suppliers. If these expectations are not met, the business relationship with that supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, UFP Industries will assess the supplier relationship and encourage that supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not that supplier can be replaced.
Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with smelters and refiners of Conflict Minerals and, therefore, do not perform or direct audits of these entities. In connection with our due diligence, we utilized information made available by RMI concerning independent third-party audits of smelters and refiners.
Report on Supply Chain Due Diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at http://www.ufpinvestor.com/index.php/corporate-governance/highlights within the “Investor Relations” section under “Corporate Governance” and is filed with the SEC.
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Results of Due Diligence
Survey Results
For the 2023 year, our third-party service provider surveyed 90 suppliers. As of May 8, 2024, the last day of our supplier survey campaign, 33 of the 90 surveyed suppliers had submitted valid CMRTs, and one had submitted an invalid CMRT.
Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to the scope of these CMRTs, we are unable to conclude which of the 3TGs (if any) have actually been included in parts or products that they supplied to us, nor are we able to determine from which of the processing facilities they listed the 3TGs originated.
Smelters and Refiners
Many of the responses provided by suppliers via the CMRT included the names of facilities listed by the suppliers as smelters or refiners (“SORs”). The CMRTs submitted by suppliers that do not list at least one SOR for each 3TG claimed on the CMRT are considered invalid, and our third-party service provider follows up on these, urging suppliers to resubmit the form and include SOR information. Even with that further request, there are still suppliers that are unable to provide SORs used for the materials supplied to us.
Excluding duplicates, suppliers who submitted valid CMRTs listed a total of 347 legitimate SORs. For all supplier responses that indicated a SOR, our third-party service provider compared the facilities listed to the list of SORs maintained by the Responsible Minerals Initiative (“RMI”). If a supplier indicated that the facility was certified as “conflict-fee” or similar, our third-party service provider confirmed whether the facility was assessed by RMI under its Responsible Minerals Assurance Process (“RMAP”). The RMAP is an audit program that uses an independent third-party assessment of an SOR’s management systems and sourcing practices to validate conformance with RMAP standards. Conformance with these standards means that the SOR is found to have the systems and processes in place to support responsible sourcing of raw materials and can provide evidence to support its sourcing activities. As of May 8, 2024, the last day of our supplier survey campaign, our third-party service provider verified 223 of the 347 listed SORs as conformant with RMAP standards.
Appendix A lists the SORs that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any SORs that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported SORs collectively source conflict minerals, based on information provided by suppliers and RMI.
As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional SOR names and country of origin of the necessary 3TGs in this Report at this time.
Future Steps to be Taken
We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:
| ● | Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of the 3TGs in our products with the greatest specificity possible; |
| ● | Engage suppliers and encourage them to provide responses at the product level; |
| ● | Continue to invest in Conflict Minerals due diligence tools; |
| ● | Continue to respond to legal requirements regarding 3TGs in our supply chain; |
| ● | Continue to refine the identification of suppliers who provide us with 3TGs; |
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| ● | Implement a strategy to respond to identified risk, including but not limited to, potential action to be taken against suppliers that do not respond to our requests or do not provide reasonable information to support our due diligence activities; and |
| ● | Engage any of our suppliers found to be supplying us with 3TGs from sourcing that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict. |
Appendix A:
The table below lists, as of May 8, 2024, the smelters or refiners identified by our responsive suppliers that may have been used to process the conflict minerals necessary to the functionality or production of our products during 2023. As described above, this list may contain more facilities than are actually linked to the Company’s products. In addition, this list may not include all applicable facilities as not all of our suppliers were able to provide SOR information at this time.
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID |
Gold | 8853 S.p.A. | ITALY | CID002763 |
Gold | ABC Refinery Pty Ltd. | AUSTRALIA | CID002920 |
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
Gold | African Gold Refinery | UGANDA | CID003185 |
Gold | Agosi AG | GERMANY | CID000035 |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
Gold | Albino Mountinho Lda. | PORTUGAL | CID002760 |
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
Gold | Alexy Meals | UNITED STATES OF AMERICA | CID003500 |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
Gold | Augmont Enterprises Private Limited | INDIA | CID003461 |
Gold | Aurubis AG | GERMANY | CID000113 |
Gold | Bangalore Refinery | INDIA | CID002863 |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
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Gold | Boliden AB | SWEDEN | CID000157 |
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
Gold | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery – Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Coimpa Industrial LTDA | BRAZIL | CID004010 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 |
Gold | Dongwu Gold Group | CHINA | CID003663 |
Gold | Dowa | JAPAN | CID000401 |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 |
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 |
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 |
Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | CID003487 |
Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | CID003488 |
Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | CID003489 |
Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | CID003490 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 |
Gold | GC Refinery Ltd. | CID004506 | |
Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
Gold | Gold by Gold Columbia | COLUMBIA | CID003641 |
Gold | Gold Coast Refinery | GHANA | CID003186 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
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Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
Gold | Heraeus Germany GmbH & Co. KG | GERMANY | CID000711 |
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 |
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
Gold | Industrial Refining Company | BELGIUM | CID002587 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Italpreziosi | ITALY | CID002765 |
Gold | JALAN & Company | INDIA | CID002893 |
Gold | Japan Mint | JAPAN | CID000823 |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
Gold | K.A. Rasmussen | NORWAY | CID003497 |
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
Gold | Kazzinc | KAZAKHSTAN | CID000957 |
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
Gold | Kundan Care Products Ltd. | INDIA | CID003463 |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
Gold | L’azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
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Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
Gold | L’Orfebre S.A. | ANDORRA | CID002762 |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
Gold | Marsam Metals | BRAZIL | CID002606 |
Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
Gold | MD Overseas | INDIA | CID003548 |
Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | CID003575 |
Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | CID003557 |
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
Gold | MKS PAMP S.A. | SWITZERLAND | CID001352 |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002875 |
Gold | Morris and Watson | NEW ZEALAND | CID002282 |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
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Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
Gold | Royal Canadian Mint | CANADA | CID001534 |
Gold | SAAMP | FRANCE | CID002761 |
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
Gold | Safimet S.p.A | ITALY | CID002973 |
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 |
Gold | Sai Refinery | INDIA | CID002853 |
Gold | Sam Precious Metals | UNITED ARAB EMIRATES | CID003666 |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Gold Smelting Co., Ltd. | CHINA | CID001916 |
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | CID002750 |
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | CID002527 |
Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
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Gold | Sovereign Metals | INDIA | CID003383 |
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
Gold | Sudan Gold Refinery | SUDAN | CID002567 |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
Gold | Super Dragon Technology Co., Ltd. | CHINA | CID001810 |
Gold | T.C.A S.p.A | ITALY | CID002580 |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
Gold | WEEEREFINING | FRANCE | CID003615 |
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
Tantalum | 5D Production OU | ESTONIA | CID003926 |
Tantalum | AMG Brasil | BRAZIL | CID001076 |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
11
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
Tantalum | KEMET de Mexico | MEXICO | CID002539 |
Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | CID002548 |
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
Tantalum | PowerX Ltd. | RWANDA | CID004054 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | CID003583 |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
Tantalum | TANIOBIS Co., Ltd. | THAILAND | CID002544 |
Tantalum | TANIOBIS GmbH | GERMANY | CID002545 |
Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | CID002549 |
Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002550 |
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | CID000616 |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
Tin | Aurubis Beerse | BELGIUM | CID002773 |
12
Tin | Aurubis Berango | SPAIN | CID002774 |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda. | BRAZIL | CID003486 |
Tin | CRM Synergies | SPAIN | CID003524 |
Tin | CV Ai Jaya | INDONESIA | CID002570 |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 |
Tin | Dowa | JAPAN | CID000402 |
Tin | DS Myanmar | MYANMAR | CID003831 |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 |
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | CID003582 |
Tin | Fenix Metals | POLAND | CID000468 |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
Tin | HuiChang Hill Tin Industry Co. Ltd | CHINA | CID002844 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 |
Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | CID003379 |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
Tin | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA | CID004434 |
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
13
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
Tin | Mining Minerals Resources SARL | CID004065 | |
Tin | Minsur | PERU | CID001182 |
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION | CID001305 |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 |
Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 |
Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
Tin | PT Bangka Tin Industry | INDONESIA | CID001419 |
Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
Tin | PT Bukit Timah | INDONESIA | CID001428 |
Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT Mitra Sukses Globalindo | INDONESIA | CID003449 |
Tin | PT Panca Mega Persada | INDONESIA | CID001457 |
Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | CID003868 |
Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 |
Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
14
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
Tin | PT Stanindo Inti Perkasa | INDOENSIA | CID001468 |
Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 |
Tin | PT Timah Nusantara | INDONESIA | CID001486 |
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
Tin | PT Tirus Putra Mandiri | INDONESIA | CID002478 |
Tin | PT Tommy Utama | INDONESIA | CID001493 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Super Ligas | BRAZIL | CID002756 |
Tin | Thaisarco | THAILAND | CID001898 |
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd | CHINA | CID002180 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 |
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 |
Tungsten | Artek LLC | RUSSIAN FEDERATION | CID003553 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | CID002641 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 |
Tungsten | Cronimet Brasil Ltda | BRAZIL | CID003468 |
Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF | CID004060 |
Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | CID003609 |
15
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | CID000568 |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | CID003978 |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | CID003417 |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | CID000769 |
Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | CID002513 |
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION | CID003408 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 |
Tungsten | LLC Vostok | RUSSIAN FEDERATION | CID003643 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Tungsten | Masan High Tech Materials | VIET NAM | CID002543 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM | CID004034 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 |
Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | CID003614 |
16
Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | CID003612 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | CID002542 |
Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | CID003993 |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
Country of Origin:
This list of potential countries of origin is populated based on information provided through the CMRT data collection process, direct SMOR outreach by our third-party service provider, and RMI’s RMAP audit process. It is important to note that this list is based, in part, on company-level responses, and therefore, it is not certain which of these countries of origin can be linked to our products. In addition, it is likely that more countries are listed below than are directly linked to our products.
Country List |
Albania Andorra |
Angola |
Argentina |
Armenia |
Australia |
Austria Azerbaijan |
Belarus |
Belgium Benin |
Bermuda |
Bolivia (Plurinational State of) |
Botswana Brazil |
Bulgaria Burkina Faso |
Burundi |
Cambodia |
Canada |
Central African Republic |
Chile |
China |
Colombia Congo Cyprus Democratic Republic of Congo |
Djibouti Dominica Dominican Republic |
Ecuador |
Egypt El Salvador |
17
Eritrea |
Estonia |
Ethiopia Fiji |
Finland |
France Georgia |
Germany |
Ghana Guam Guatemala |
Guinea |
Guyana Honduras Hong Kong |
Hungary |
India |
Indonesia |
Ireland |
Israel |
Italy Ivory Coast |
Japan Jersey |
Kazakhstan |
Kenya Korea |
Kyrgyzstan |
Liberia Liechtenstein |
Lithuania |
Luxembourg |
Madagascar |
Malaysia |
Mali |
Mauritania |
Mexico |
Mongolia |
Morocco |
Mozambique |
Myanmar |
Namibia |
Netherlands |
New Zealand Nicaragua |
Niger |
Nigeria Norway Oman Panama |
Papua New Guinea |
Peru |
Philippines |
Poland |
Portugal |
Russian Federation |
Rwanda |
18
Saudi Arabia Senegal Serbia |
Sierra Leone |
Singapore |
Slovakia |
Solomon Islands |
South Africa South Sudan |
Spain Sudan |
Suriname |
Sweden |
Switzerland Taiwan Tajikistan |
Tanzania |
Thailand Togo |
Turkey |
Uganda |
United Arab Emirates |
United Kingdom |
United States Uruguay |
Uzbekistan |
Viet Nam |
Zambia |
Albania Andorra |
Angola |
19
