Exhibit 1.01
Exhibit 1.01
Conflict Minerals Report
Sparton Corporation
2015 Calendar Year
Introduction
The following Conflict Minerals Report has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 and Form SD (together, the “Rule”) and is a description of the measures taken to exercise due diligence on the source and chain of custody of conflict minerals (as defined in Item 1.01(d)(3) of Form SD, “Conflict Minerals”) contained in our products manufactured during the 2015 calendar year. The U.S. Securities and Exchange Commission defines “Conflict Minerals” as columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten, and gold (collectively referred to as “3TGs”).
Company and Product Overview
Sparton Corporation and its subsidiaries (the “Company”, “Sparton”, “we”, “our” or “us”), headquartered in Schaumburg, Illinois, have been in continuous existence since 1900. The Company is a provider of complex and sophisticated electromechanical devices with capabilities that include concept development, design and manufacturing engineering, production, distribution, and field service. The Company serves the Medical & Biotechnology, Military & Aerospace and Industrial & Commercial markets through two reportable business segments: Manufacturing & Design Services (“MDS”) and Engineered Components & Products (“ECP”).
The Company’s products and services include products for Original Equipment Manufacturers and Emerging Technology customers that are microprocessor-based systems that include transducers, printed circuit boards and assemblies, sensors, and electromechanical components, as well as development and design engineering services relating to these product sales. Sparton also develops and manufactures sonobuoys, anti-submarine warfare devices used by the United States Navy and other free-world countries.
Our broad and complex product range may contain conflict minerals within the following components:
| • | Tantalum, used in capacitors, |
| • | Tin, used in soldered components, |
| • | Tungsten, used in coatings, alloys, heating elements and electrodes, |
| • | Gold, used in circuit boards, electrodes and electronic components. |
Our Conflict Minerals Policy Statement is publicly available on our Internet website under Terms and Conditions, Downloads, Conflict Minerals Policy Statement at: http://sparton.com/terms-and-conditions/.
Reasonable Country of Origin Inquiry (RCOI)
As a first step, Sparton determined that Conflict Minerals are contained in certain products manufactured or contracted to be manufactured by Sparton, and that the Conflict Minerals are necessary to the functionality or production of certain products.
Sparton then, with assistance of a third party, conducted in good faith a reasonable country of origin inquiry (“RCOI”) for calendar year 2015 to determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or are from recycled or scrap sources (as defined in Item 1.01(d)(6) of Form SD, “Recycled/Scrap Sources”).
Following our RCOI, we conducted a due diligence review of the source and chain of custody of the Conflict Minerals in our products as outlined below. Our due diligence measures were designed to conform in all material respects with the framework in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten (“Supplements”).
Sparton engaged a third party conflict minerals consultant to assist with the RCOI, due diligence and the overall effectiveness of Sparton’s Conflict Minerals program.
Due Diligence Framework and Process
Sparton, in cooperation with our third party consultant, designed Sparton’s Conflict Minerals program and due diligence framework to conform, in all material respects, with the OECD five-step framework for risk-based due diligence for responsible supply chains of minerals from conflict-affected and high-risk areas in the OECD Guidance and the Supplements. Sparton’s due diligence framework and compliance efforts are described below.
Since Sparton is not a direct purchaser of ore or unrefined minerals, it is several tiers “downstream” from the smelters or refiners (“SORs”) of such minerals. SORs are at the point in the supply chain where ore, concentrates and/or scrap material are converted to a metal. Sparton, like many downstream companies, does not have direct business relationships with SORs or visibility to the extraction and movement of conflict minerals between SORs and upstream entities. This position increases the difficulty of determining the origin of the conflict minerals in the applicable products and, as a result, Sparton relies on industry processes and information from its suppliers.
Step 1:Establish Strong Sparton Management Systems
In accordance with our due diligence framework and compliance efforts:
| • | We have communicated to all of our applicable suppliers our efforts to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, pursuant to Sparton’s Conflict Minerals Policy Statement and other communications (collectively, the “Compliance Statement”). We request that our applicable suppliers provide a comprehensive Conflict Minerals declaration for all Conflict Minerals in the form of the Electronic Industry Citizenship Coalition, Incorporated and Global e-Sustainability Initiative (“EICC-GeSI”) Conflict Minerals Reporting Template (“CMRT”). We provide our Compliance Statement to all new suppliers and plan to provide annual related compliance statement communications to our entire supply base. |
Our Conflict Minerals Policy Statement is publicly available on our Internet website under Downloads, Conflict Minerals Policy Statement at: http://sparton.com/terms-and-conditions/.
We have also, through our third party consultant, provided education on Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the rules and regulations promulgated thereunder (the “Conflict Minerals Rule”) as well as the expectations for compliance to the Conflict Minerals Rule, in both our organization and with our suppliers. We have leveraged the existing communications within the company, specifically procurement, to encourage supplier interactions with our third party consultant, as well as educating our suppliers to understand the requirement for completion.
| • | We implemented internal compliance efforts, including internal reporting requirements, to support our supply chain due diligence process. |
| • | We implemented an intake process with new suppliers to screen their applicable components. |
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| • | We established a system of controls and supply chain transparency. Controls include, but are not limited to, our Code of Business Conduct and Ethics which outlines expected behaviors for all Sparton employees, our General Provisions for Subcontracts and Purchase Orders, a supplier conflict minerals contract clause which is further described below, and employing due diligence tools created by EICC/GeSI, including supply chain surveys. As a downstream manufacturer, we rely on our suppliers to provide information on the origins of all Conflict Minerals contained in components and materials supplied to us, including sources of Conflict Minerals that are supplied to our direct suppliers from lower tier suppliers, smelter and mine locations, and transit routes. Additionally, our customers often instruct us as to which suppliers we are required to purchase materials from. |
Contracts with our suppliers are frequently in force for three to five years or more and we cannot unilaterally impose new contract terms and flow-down requirements. As we enter into new contracts, or our contracts renew, we are using commercially reasonable efforts to either add a clause to require suppliers to provide information about the source of 3TGs and smelters and refiners or comply with our policies as to Conflict Minerals. It will take a number of years to ensure that all our supplier contracts contain appropriate flow-down clauses. In the meantime, as described below, we are working with selected suppliers to insure they provide the 3TG sourcing information until the contracts can be amended.
| • | We implemented a risk mitigation response plan to address business relationships with suppliers who are unable to definitively determine the source of the 3TGs in the parts supplied to Sparton, which mitigation may include identifying an alternate supply. Our program includes continuous monitoring to adjust our strategies as sourcing data improves and new information is received. |
Sparton has established a management system for Sparton’s Conflict Minerals program and due diligence. Our management system includes the Conflict Minerals Compliance Team sponsored by Gordon Madlock, Senior Vice President – Operations as well as executive-level representatives and a team of subject matter experts from relevant functions such as supply chain and purchasing managers. Senior management is briefed on the results of our due diligence efforts on a regular basis.
| • | We have multiple longstanding whistleblower mechanisms whereby employees and suppliers can report violations of Sparton’s policies. |
| • | We have adopted a policy to retain relevant documentation. Documentation will be retained for the applicable period required by the OECD Guidance but in any event for at least 5 years. |
Step 2:Identify and Assess Risks in Our Supply Chain
We identified risks at the product level by determining first whether the products contained Conflict Minerals necessary to the functionality or production of products that we manufacture or contract to be manufactured.
We then identified the applicable supplier(s) relating to those products. The scoping process began by completing a supplier list extraction from Sparton’s approved vendor list. This list was then filtered to remove: service providers/suppliers, indirect materials suppliers, and inactive suppliers (inactive suppliers are those with no receipt history since January 31, 2014). This ensures that surveys covered all suppliers providing items to Sparton that were used in final products in the year 2015. Once the filtering was completed, Sparton populated the list with contact information and uploaded it to the Company’s compliance management system. It was deemed appropriate to not further filter this list based on the necessity of the presence of Conflict Minerals in the product as Sparton could not definitively determine the presence or absence of Conflict Minerals in all parts supplied to Sparton for its products.
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Sparton, in conjunction with its third-party consultant, then conducted the supplier survey portion of the RCOI. We surveyed our applicable direct suppliers identified as providing components that potentially contain Conflict Minerals during the 2015 calendar year. The supply chain survey was made using the CMRT, version 4.01. The CMRT was developed to facilitate general disclosures and information regarding smelters and refiners that provide materials to the supplier. It includes questions regarding the supplier’s conflict-free minerals policy, the engagement process with its direct suppliers, and identification of the smelters and refiners used by the supplier.
Non-responsive suppliers were contacted by email a minimum of 3 times and then contacted by phone a minimum of 2-3 times. Communications include training and education on the completion of the CMRT form as well as access to a Supplier Resource Center designed to alleviate any remaining confusion with suppliers. All communications were monitored and tracked in our third party consultant’s system for future reporting and transparency.
Sparton’s Conflict Minerals program includes 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 CMRT forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to resubmit a valid form.
Sparton, through our third-party vendor, surveyed a total of 3328 suppliers. Of the 2141 responses, 203 were determined to be out of scope, 179 were deemed invalid and marked for follow-up, and 1759 were accepted as complete. This is an overall response rate of 64%.
The response rate for complete declarations is an 8% increase from the 2014 supplier survey campaign, including a 12% reduction in responses deemed Invalid.
Surveys received from suppliers for calendar year 2015 indicate that there are suppliers that source Conflict Minerals from DRC and Adjoining Countries.
Based on the smelter lists provided by our suppliers via CMRT, we have identified 320 SORs that are on the CFSI Standard Smelter List that accompanies CMRT version 4.01. Of these, 215 have a certified conflict-free status from the Conflict-Free Smelter Program’s (CFSP) third-party audit process. From supplier CMRTs and publicly available information, all SORs known to source from the Covered Countries are compliant to the CFSP’s conflict-free protocols. Annex A lists the SORs that the suppliers we surveyed reported as being in their supply chains. We have not listed in Annex A any SORs that we have not been able to validate.
The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the SORs identified by our direct suppliers may contain SORs that processed Conflict Minerals that our direct suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether these SORs were used to process the conflict minerals necessary to the functionality or production of our products during 2015. Because of this uncertainty, we are also unable to conclusively determine the countries of origin of Conflict Minerals in our products during 2015, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we receive from our direct suppliers may yield inaccurate or incomplete information. For example, the information received from our direct suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSI Conflict-Free Smelter Program or the LBMA Responsible Gold Programme and, as a result, are not responsible for the quality of these audits or the audit findings.
As we progress, we expect that transparency in our supply chain will increase and that will allow for better risk assessment at more detailed levels of our supply chain. We intend to continue communicating with our suppliers regarding Conflict Minerals, in order to help mitigate risks that the necessary Conflict Minerals identified in the products we manufacture or contract to manufacture could benefit armed groups in the Covered Countries.
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Step 3:Design and Implement a Strategy to Respond to Identified Risks
We believe that our RCOI and due diligence was reasonably designed and executed to determine the existence and source of Conflict Minerals in our supply chain, including Recycled/Scrap Sources. We engaged a third party to assist us in the RCOI and due diligence. We utilized the EICC-GeSI CMRT for our RCOI and due diligence. We conducted our effort to send surveys in good faith, utilizing up to three rounds of communications with our suppliers through March 2015. We evaluated survey responses to identify: (i) the use and source of Conflict Minerals; and (ii) any warning signs indicating that Conflict Minerals may have come from the Covered Countries. We made additional inquiries on a case-by-case basis to clarify or obtain more information as necessary. We tracked results of our supply chain diligence process and periodically reported the results to our executive leadership team.
We do not have sufficient information, based on the survey responses received, to determine each of the specific facilities used to process Conflict Minerals or to identify specific countries of origin for the Conflict Minerals used in all of our products (whether manufactured or contracted to be manufactured by us).
In accordance with OECD Guidelines, it is important to understand risk levels associated with Conflict Minerals in the supply chain. Smelters and refiners not being certified DRC conflict free pose a significant risk to the supply chain. In our third party consultant’s system, risk is classified as High, Medium and Low based on 3 scoring criteria:
| • | Regulated Body: This assesses whether the smelter is a member and has an associated regulated body number (Smelter CID Number is the primary method). |
| • | Proximity: |
| • | Level 1 Country: Countries with known active ore production for tin or tantalum that are not identified as conflict regions or plausible countries of smuggling or export of tin or tantalum containing materials. Smelter country is located in North or South America, Australia or Europe. |
| • | Level 2 Country: Known or plausible countries for smuggling, export out of Level 3 countries, or transit of materials containing tin or tantalum. This currently includes Kenya, Mozambique, and South Africa. |
| • | Level 3 Country: The DRC and Adjoining Countries. These include Angola, Burundi, Central African Republic, DRC, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia. These are also commonly referred to as “covered countries” in the Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. |
| • | Certification: If the Smelter is certified conflict-free via the CFSI or the LBMA Responsible Gold Programme. |
We also calculate supplier risk based on the chances that the supplier provides Conflict Minerals that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the smelters and refiners declared by that supplier on their CMRT.
Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage in Conflict Minerals compliance it is well-known that many companies are in the middle of the process and do not have many answers beyond “unknown”. Evaluating and tracking the strength of the program of a supplier can assist us in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:
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?
H. Do you verify due diligence information received from your suppliers?
I. Does your verification process include corrective action management?
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When suppliers meet or exceed those criteria (“Yes” to at least A,E,H,I) , they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.
Risk Mitigation
We have taken or intend to take the following steps to further mitigate the risk that the Conflict Minerals in our products could benefit armed groups in the DRC and Adjoining Countries:
| • | Implement a supplier screening program that requires suppliers within risk-based scope to provide information regarding Conflict Minerals. |
| • | Continue to review the refinement and expansion of the list of participating smelters and refiners through the CFSI website to validate the smelters and refiners provided by suppliers. |
| • | Train and inform suppliers of conflict-free minerals. |
| • | Encourage suppliers to establish procedures to identify the origin of Conflict Minerals. |
| • | Continue and further improve our direct supplier surveys and due diligence process, including engage with suppliers and direct them to training resources to seek to increase the response rate and improve the content of their responses, as well as to continue to gather data regarding the sources of any Conflict Minerals contained in materials supplied to us. |
| • | Implemented a risk mitigation response plan to address business relationships with suppliers that are DRC conflict undeterminable (as defined in Item 1.01(d)(5) of Form SD), which mitigation may include identifying an alternate supply. |
Step 4:Implement Targeted Independent Third-Party Due Diligence
As a downstream supplier, we do not have a direct relationship with Conflict Minerals smelters and refiners and do not perform or direct audits of these entities within our supply chain. We support industry associations that administer independent third-party smelter and refinery audit programs. We encourage targeted suppliers and/or facilities to participate in comparable due diligence validation activities.
Step 5:Report on Supply Chain Due Diligence
We developed a supply chain due diligence policy, communicated this policy to our suppliers and will continue to communicate with our suppliers. We also developed and distributed our Compliance Statement. Further, we have responded to various customer requests for information regarding our Conflict Minerals determination.
Sparton has also prepared this Conflict Minerals Report and made it publicly available on the Sparton’s Internet website at: http://sparton.com.
Due Diligence Process
We believe that the inquiries and investigations described in Step 3 represent a reasonable effort to determine the mines or locations of origin of the Conflict Minerals in our products, including (1) seeking information about Conflict Mineral smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
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While due diligence is ongoing and the information received continues to improve in quantity and quality, the majority of the responses received continue to provide data at a company or divisional level or did not specify the smelters or refiners used for materials supplied to us. We cannot definitively determine whether any of the Conflict Minerals reported by the suppliers were contained in materials supplied to us, nor can we validate that all of the reported smelters or refiners are actually in our supply chain.
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Annex A
The following is a list of verified SORs that the suppliers surveyed by the Company reported as being in their supply chains. An affirmative answer in the ‘Conflict-Free?’ column indicates completion of the CFSI’s Conflict-Free Smelter Program third-party audit certifying conflict-free sourcing.
| Metal | Standard Smelter Name | Facility Location | Conflict- Free? | |||
| Gold | Advanced Chemical Company | UNITED STATES | ||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes | |||
| Gold | Aktyubinsk Copper Company TOO | KAZAKHSTAN | ||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes | |||
| Gold | Argor-Heraeus SA | SWITZERLAND | Yes | |||
| Gold | Asahi Pretec Corporation | JAPAN | Yes | |||
| Gold | Asahi Refining Canada Limited | CANADA | Yes | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES | Yes | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Yes | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||||
| Gold | Aurubis AG | GERMANY | Yes | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes | |||
| Gold | Bauer Walser AG | GERMANY | ||||
| Gold | Boliden AB | SWEDEN | Yes | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes | |||
| Gold | Caridad | MEXICO | ||||
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | Yes | |||
| Gold | Cendres + Métaux SA | SWITZERLAND | ||||
| Gold | Chimet S.p.A. | ITALY | Yes | |||
| Gold | Chugai Mining | JAPAN | ||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||||
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF | ||||
| Gold | DODUCO GmbH | GERMANY | Yes | |||
| Gold | Dowa | JAPAN | Yes | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes |
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| Gold | Elemetal Refining, LLC | UNITED STATES | Yes | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes | |||
| Gold | Faggi Enrico S.p.A. | ITALY | ||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | ||||
| Gold | Geib Refining Corporation | UNITED STATES | ||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||||
| Gold | Guangdong Jinding Gold Limited | CHINA | ||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||||
| Gold | Heimerle + Meule GmbH | GERMANY | Yes | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | ||||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | Yes | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | Istanbul Gold Refinery | TURKEY | Yes | |||
| Gold | Japan Mint | JAPAN | Yes | |||
| Gold | Jiangxi Copper Company Limited | CHINA | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Yes | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Yes | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | ||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | ||||
| Gold | Kazzinc | KAZAKHSTAN | Yes | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | ||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes | |||
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Korea Zinc Co. Ltd. | KOREA, REPUBLIC OF | ||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | ||||
| Gold | L’ azurde Company For Jewelry | SAUDI ARABIA |
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| Gold | Lingbao Gold Company Limited | CHINA | ||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||||
| Gold | Materion | UNITED STATES | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes | |||
| Gold | Metahub Industries Sdn. Bhd. | MALAYSIA | ||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | ||||
| Gold | Metalor Technologies SA | SWITZERLAND | Yes | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes | |||
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Yes | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Yes | |||
| Gold | Morris and Watson | NEW ZEALAND | ||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Yes | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Yes | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||||
| Gold | Nihon Material Co., Ltd. | JAPAN | Yes | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Yes | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes | |||
| Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | ||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes | |||
| Gold | PAMP SA | SWITZERLAND | Yes | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes | |||
| Gold | PX Précinox SA | SWITZERLAND | Yes | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes |
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| Gold | Republic Metals Corporation | UNITED STATES | Yes | |||
| Gold | Royal Canadian Mint | CANADA | Yes | |||
| Gold | SAAMP | FRANCE | ||||
| Gold | Sabin Metal Corp. | UNITED STATES | ||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | ||||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | ||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | ||||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes | |||
| Gold | SEMPSA Joyería Platería SA | SPAIN | Yes | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Yes | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Yes | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN | Yes | |||
| Gold | So Accurate Group, Inc. | UNITED STATES | ||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes | |||
| Gold | Sudan Gold Refinery | SUDAN | ||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes | |||
| Gold | T.C.A S.p.A | ITALY | Yes | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Yes | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Yes | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Yes | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||||
| Gold | Tony Goetz NV | BELGIUM | ||||
| Gold | Torecom | KOREA, REPUBLIC OF | ||||
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Yes | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes | |||
| Gold | Valcambi SA | SWITZERLAND | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | ||||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes |
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| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | ||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Yes | |||
| Tantalum | Avon Specialty Metals Ltd | UNITED KINGDOM | ||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Yes | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes | |||
| Tantalum | Duoluoshan | CHINA | Yes | |||
| Tantalum | E.S.R. Electronics | UNITED STATES | ||||
| Tantalum | Exotech Inc. | UNITED STATES | Yes | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Yes | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Yes | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Yes | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CHINA | ||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Yes | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Yes | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Yes | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Yes | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES | Yes | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Yes | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | Yes | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | KEMET Blue Metals | MEXICO | Yes | |||
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes |
12
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tantalum | Mitsui Mining & Smelting | JAPAN | Yes | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Yes | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Yes | |||
| Tantalum | QuantumClean | UNITED STATES | Yes | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Yes | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Yes | |||
| Tantalum | Taki Chemicals | JAPAN | Yes | |||
| Tantalum | Telex Metals | UNITED STATES | Yes | |||
| Tantalum | Tranzact, Inc. | UNITED STATES | Yes | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Yes | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Yes | |||
| Tantalum | Zhuzhou Cemented Carbide | CHINA | Yes | |||
| Tin | Alpha | UNITED STATES | Yes | |||
| Tin | An Thai Minerals Company Limited | VIET NAM | ||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||||
| Tin | Chenzhou Yun Xiang mining limited liability company | CHINA | ||||
| Tin | China Tin Group Co., Ltd. | CHINA | Yes | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Yes | |||
| Tin | CV Ayi Jaya | INDONESIA | Yes | |||
| Tin | CV Dua Sekawan | INDONESIA | ||||
| Tin | CV Gita Pesona | INDONESIA | Yes | |||
| Tin | CV Serumpun Sebalai | INDONESIA | Yes | |||
| Tin | CV Tiga Sekawan | INDONESIA | ||||
| Tin | CV United Smelting | INDONESIA | Yes | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes | |||
| Tin | Dowa | JAPAN | Yes |
13
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||||
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN | Yes | |||
| Tin | EM Vinto | BOLIVIA | Yes | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | ||||
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | ||||
| Tin | Fenix Metals | POLAND | Yes | |||
| Tin | Gejiu Fengming Metalurgy Chemical Plant | CHINA | ||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | ||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | ||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | ||||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes | |||
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | ||||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes | |||
| Tin | Melt Metais e Ligas S/A | BRAZIL | Yes | |||
| Tin | Metahub Industries Sdn. Bhd. | MALAYSIA | ||||
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Yes | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Yes | |||
| Tin | Minsur | PERU | Yes | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | ||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Yes | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Yes | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | Yes | |||
| Tin | Phoenix Metal Ltd. | RWANDA | ||||
| Tin | PT Alam Lestari Kencana | INDONESIA | ||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes |
14
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Bangka Kudai Tin | INDONESIA | ||||
| Tin | PT Bangka Prima Tin | INDONESIA | Yes | |||
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | ||||
| Tin | PT Bangka Tin Industry | INDONESIA | Yes | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes | |||
| Tin | PT BilliTin Makmur Lestari | INDONESIA | Yes | |||
| Tin | PT Bukit Timah | INDONESIA | Yes | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Yes | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes | |||
| Tin | PT Fang Di MulTindo | INDONESIA | ||||
| Tin | PT Inti Stania Prima | INDONESIA | Yes | |||
| Tin | PT Justindo | INDONESIA | Yes | |||
| Tin | PT Karimun Mining | INDONESIA | ||||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | ||||
| Tin | PT Mitra Stania Prima | INDONESIA | Yes | |||
| Tin | PT Panca Mega Persada | INDONESIA | Yes | |||
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | ||||
| Tin | PT Prima Timah Utama | INDONESIA | Yes | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Yes | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes | |||
| Tin | PT Seirama Tin Investment | INDONESIA | ||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Yes | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Yes | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Yes | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Yes | |||
| Tin | PT Tirus Putra Mandiri | INDONESIA | ||||
| Tin | PT Tommy Utama | INDONESIA | Yes | |||
| Tin | PT Wahana Perkit Jaya | INDONESIA | Yes | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Yes | |||
| Tin | Rui Da Hung | TAIWAN | Yes |
15
| Tin | Soft Metais Ltda. | BRAZIL | Yes | |||
| Tin | Thaisarco | THAILAND | Yes | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Yes | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||||
| Tin | Yunnan Tin Group (Holding) Company Limited | CHINA | Yes | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes | |||
| Tungsten | ACL Metais Eireli | BRAZIL | ||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | ||||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | ||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | ||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Yes | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | ||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin | CHINA | ||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Yes | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Yes | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA |
16
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||||
| Tungsten | Kennametal Fallon | UNITED STATES | ||||
| Tungsten | Kennametal Huntsville | UNITED STATES | Yes | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | ||||
| Tungsten | Niagara Refining LLC | UNITED STATES | Yes | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes | |||
| Tungsten | Philippine Chuangin Industrial Co., Inc. | PHILIPPINES | Yes | |||
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION | ||||
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | ||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Yes | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Yes | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | ||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
17
