Exhibit 1.01
Exhibit 1.01
Conflict Minerals Report
Sparton Corporation
2017 Calendar Year
Introduction
The following Conflict Minerals Report has been prepared pursuant to Rule13p-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 2017 calendar year. The U.S. Securities and Exchange Commission defines “Conflict Minerals” as (A) columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to tantalum, tin and tungsten, and gold (collectively referred to as “3TGs”); or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC. The adjoining countries include: the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola (together with the DRC, the “Covered Countries”).
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, and |
| • | 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 Statementat: 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 consultant, conducted in good faith a reasonable country of origin inquiry (“RCOI”) for calendar year 2017 to determine whether any of the Conflict Minerals originated in 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 EconomicCo-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 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 Responsible Business Alliance and Globale-Sustainability Initiative 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 Statementat: 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.
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| • | 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. |
| • | 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 the Responsible Business Alliance, 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 sometimes in force for three to five years or more and we may not able to unilaterally impose new contract terms and flow-down requirements. As we have entered into new contracts, and as contracts renew, we use 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. To the extent we do not have a long term contract in place and we use purchase orders placed with suppliers, we have added a clause to our standard terms and conditions that suppliers comply with our policies as to Conflict Minerals. Additionally, as described below, we are working with selected suppliers to ensure they provide the 3TG sourcing information.
| • | 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, including our Conflict Minerals Policy. |
| • | 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, 2016). This ensures that surveys covered all suppliers providing items to Sparton that were used in final products in the year 2017. Once the filtering was completed, Sparton populated the list with contact information and uploaded it to the Company’s
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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.
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 2017 calendar year. The supply chain was surveyed using the CMRT, version 45.0 or higher. 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. Communications included training and education on the completion of the CMRT form as well as enrollment into Conflict Minerals courses through our third-party consultant’s learning management software. This was 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 3,833 suppliers. Of the 2,402 responses, 318 were determined to be out of scope, 76 were deemed invalid and marked forfollow-up, and 2,008 were accepted as complete. These “complete,” “invalid” and “out of scope” responses from our suppliers this year gives us an overall response rate of 63% which is a 5% improvement over last year when considering those same categories.
This year we also have had a1.5% reduction in responses deemed “Invalid.” Our overall response rates increased even though our supplier list grew by more than 300 this year.
Surveys received from suppliers for calendar year 2017 indicate that there are suppliers that source Conflict Minerals from the Covered Countries.
Based on the smelter lists provided by our suppliers via CMRT, we have identified 321SORs that are on the RMI Standard Smelter List that accompanies CMRT version 5.10. Of these, 257 have a certified conflict-free status from the Responsible Minerals Assurance Process (RMAP) third-party audit process. From supplier CMRTs and publicly available information, all SORs known to source from the Covered Countries are conformant to the RMAP’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 2017. Because of this uncertainty, we are also unable to conclusively determine the countries of origin of Conflict Minerals in our products during 2017, 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 RMI Responsible Minerals Assurance Process and, as a result, are not responsible for the quality of these audits or the audit findings.
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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.
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 Responsible Business Alliance-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 April 10, 2018. 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 acase-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. Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Our third party consultant uses 3 factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags
| • | Credible evidence of unethical or conflict sourcing |
| • | Geographic Proximity to the DRC and Covered Countries |
| • | Responsible Minerals Assurance Process (RMAP) audit status |
Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
| • | Tony Goetz NV—CID002587 |
| • | African Gold Refinery Limited – CID003185 |
| • | Kaloti Precious Metals—CID002563 |
| • | Universal Precious Metals Refining Zambia—CID002854 |
| • | Fidelity Printers and Refiners—CID002515 |
| • | Sudan Gold Refinery—CID002567 |
When these facilities were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities were initiated. Through our third party consultant, submissions that included any of the above facilities immediately received a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to us and escalating up to removal of these red flag smelters from their supply chain.As per the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. 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 our third-party consultant’s learning platform to engage in educational materials on mitigating the risk of smelters or refiners in the supply chain.
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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 continue to work through 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. Have you established a conflict minerals sourcing policy?
E. Have you implemented due diligence measures for conflict free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?
When suppliers meet or exceed those criteria (“Yes” to at least A, E, G, H), 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 Covered 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 RMI 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 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.
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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 RMI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.
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 RMI’s Responsible Minerals Assurance Process third-party audit certifying conflict-free sourcing.
Metal | Standard Smelter Name | Facility Location | Conflict- Free? | |||
| Gold | Abington Reldan Metals, LLC | UNITED STATES | Unknown | |||
| Gold | Advanced Chemical Company | UNITED STATES | Yes | |||
| Gold | African Gold Refinery | UGANDA | Unknown | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Yes | |||
| Gold | Al Etihad Gold LLC | UNITED ARAB EMIRATES | Yes | |||
| Gold | AllgemeineGold-und Silberscheideanstalt A.G. | GERMANY | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Yes | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Yes | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Yes | |||
| Gold | Asahi Pretec Corp. | JAPAN | Yes | |||
| Gold | Asahi Refining Canada Ltd. | 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 | Unknown | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Yes | |||
| Gold | Aurubis AG | GERMANY | Yes | |||
| Gold | Bangalore Refinery | INDIA | Unknown | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Yes | |||
| Gold | Boliden AB | SWEDEN | Yes | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Yes | |||
| Gold | Caridad | MEXICO | Unknown | |||
| Gold | CCR Refinery—Glencore Canada Corporation | CANADA | Yes |
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| Gold | Cendres + Métaux S.A. | SWITZERLAND | Yes | |||
| Gold | Chimet S.p.A. | ITALY | Yes | |||
| Gold | Chugai Mining | JAPAN | Unknown | |||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | Yes | |||
| Gold | DayeNon-Ferrous Metals Mining Ltd. | CHINA | Unknown | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Unknown | |||
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | Yes | |||
| Gold | Dowa | JAPAN | Yes | |||
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Yes | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Yes | |||
| Gold | Elemetal Refining, LLC | UNITED STATES | Unknown | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Yes | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Unknown | |||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | Unknown | |||
| Gold | Geib Refining Corporation | UNITED STATES | Yes | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Yes | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Unknown | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Unknown | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Unknown | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Unknown | |||
| Gold | HeeSung | KOREA, REPUBLIC OF | Yes | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Yes | |||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Yes | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Unknown |
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| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Yes | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Yes | |||
| Gold | Istanbul Gold Refinery | TURKEY | Yes | |||
| Gold | Italpreziosi | ITALY | Yes | |||
| Gold | Japan Mint | JAPAN | Yes | |||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Yes | |||
| Gold | JSC EkaterinburgNon-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 | Unknown | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Unknown | |||
| Gold | Kazzinc | KAZAKHSTAN | Yes | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | Yes | |||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Unknown | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Yes | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Yes | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Yes | |||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Unknown | |||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Unknown | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Unknown | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Unknown | |||
| Gold | L’Orfebre S.A. | ANDORRA | Unknown | |||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Yes | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Unknown | |||
| Gold | Marsam Metals | BRAZIL | Yes |
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| Gold | Materion | UNITED STATES | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Yes | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Yes | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Yes | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Yes | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES | Yes | |||
| Gold | MetalúrgicaMet-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 | Modeltech Sdn Bhd | MALAYSIA | Unknown | |||
| Gold | Morris and Watson | NEW ZEALAND | Unknown | |||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | Unknown | |||
| 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 | Unknown | |||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Unknown | |||
| 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 KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Yes | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Yes | |||
| Gold | PAMP S.A. | SWITZERLAND | Yes |
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| Gold | Pease & Curren | UNITED STATES | Unknown | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Unknown | |||
| Gold | Planta Recuperadora de Metales SpA | CHILE | Yes | |||
| Gold | Prioksky Plant ofNon-Ferrous Metals | RUSSIAN FEDERATION | Yes | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Yes | |||
| Gold | PX Précinox S.A. | SWITZERLAND | Yes | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Yes | |||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Unknown | |||
| Gold | Remondis Argentia B.V. | NETHERLANDS | Unknown | |||
| Gold | Republic Metals Corporation | UNITED STATES | Yes | |||
| Gold | Royal Canadian Mint | CANADA | Yes | |||
| Gold | SAAMP | FRANCE | Yes | |||
| Gold | Sabin Metal Corp. | UNITED STATES | Unknown | |||
| Gold | Safimet S.p.A | Italy | Yes | |||
| Gold | SAFINA A.S. | CZECH REPUBLIC | Unknown | |||
| Gold | Sai Refinery | INDIA | Unknown | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Yes | |||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | Unknown | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Yes | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Yes | |||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Yes | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Unknown | |||
| 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 | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Yes |
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| Gold | Solar Applied Materials Technology Corp. | TAIWAN | Yes | |||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Unknown | |||
| Gold | Sudan Gold Refinery | SUDAN | Unknown | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Yes | |||
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | 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 | Unknown | |||
| Gold | Tony Goetz NV | BELGIUM | Unknown | |||
| Gold | TOOTau-Ken-Altyn | KAZAKHSTAN | Unknown | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Yes | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Yes | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Yes | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Yes | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | Yes | |||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Unknown | |||
| Gold | Valcambi S.A. | SWITZERLAND | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Yes | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Yes | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Yes | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Unknown | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Yes |
13
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Yes | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | D Block Metals, LLC | UNITED STATES | Yes | |||
| Tantalum | Duoluoshan | CHINA | Unknown | |||
| 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 Rising RareMetals-EO Materials Ltd. | CHINA | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Yes | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | 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 | H.C. Starck Tantalum and Niobium GmbH | GERMANY | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Yes | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Yes | |||
| Tantalum | Jiujiang Janny New Material Co., Ltd. | 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 |
14
| Tantalum | KEMET Blue Powder | UNITED STATES | Yes | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Yes | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Yes | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Yes | |||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Yes | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Yes | |||
| Tantalum | NPM Silmet AS | ESTONIA | Yes | |||
| Tantalum | Power Resources Ltd. | MACEDONIA | Yes | |||
| Tantalum | QuantumClean | UNITED STATES | Yes | |||
| Tantalum | Resind Industria e Comercio 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 | 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 | |||
| Tin | Alpha | UNITED STATES | Yes | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Unknown | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Yes | |||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Unknown | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Yes | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Unknown | |||
| Tin | CV Ayi Jaya | INDONESIA | Yes | |||
| Tin | CV Dua Sekawan | INDONESIA | Yes |
15
| Tin | CV Gita Pesona | INDONESIA | Yes | |||
| Tin | CV Tiga Sekawan | INDONESIA | Yes | |||
| Tin | CV United Smelting | INDONESIA | Yes | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Yes | |||
| Tin | Dowa | JAPAN | Yes | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Unknown | |||
| Tin | EM Vinto | BOLIVIA | Yes | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | Unknown | |||
| Tin | Fenix Metals | POLAND | Yes | |||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Yes | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Yes | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Yes | |||
| Tin | GejiuNon-Ferrous Metal Processing Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Yes | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Unknown | |||
| Tin | Guangdong HanheNon-ferrous Metal Limited Company | CHINA | Yes | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Yes | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Yes | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Yes | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Yes | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Yes | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Yes |
16
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Yes | |||
| Tin | Metallic Resources, Inc. | UNITED STATES | Yes | |||
| Tin | Metallo Belgium N.V. | BELGIUM | Yes | |||
| Tin | Metallo Spain S.L.U. | SPAIN | Yes | |||
| Tin | Mineracao Taboca S.A. | BRAZIL | Yes | |||
| Tin | Minsur | PERU | Yes | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Yes | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Unknown | |||
| Tin | Nghe TinhNon-Ferrous Metals Joint Stock Company | VIET NAM | Unknown | |||
| 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 | Pongpipat Company Limited | MYANMAR | Unknown | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Yes | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Yes | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Yes | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Yes | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Yes | |||
| Tin | PT Bangka Serumpun | INDONESIA | Yes | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Yes | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Yes | |||
| Tin | PT Bukit Timah | INDONESIA | Yes | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Yes | |||
| Tin | PT Inti Stania Prima | INDONESIA | Yes | |||
| Tin | PT Karimun Mining | INDONESIA | Yes | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Yes | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Yes | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Yes |
17
| Tin | PT Mitra Stania Prima | INDONESIA | Yes | |||
| Tin | PT O.M. Indonesia | INDONESIA | Yes | |||
| Tin | PT Panca Mega Persada | INDONESIA | Yes | |||
| Tin | PT Premium Tin Indonesia | INDONESIA | Yes | |||
| Tin | PT Prima Timah Utama | INDONESIA | Yes | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Yes | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Yes | |||
| 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 Tommy Utama | INDONESIA | Yes | |||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Yes | |||
| Tin | Rui Da Hung | TAIWAN | Yes | |||
| Tin | Soft Metais Ltda. | BRAZIL | Yes | |||
| Tin | Super Ligas | Brazil | Unknown | |||
| Tin | Thaisarco | THAILAND | Yes | |||
| Tin | Tuyen QuangNon-Ferrous Metals Joint Stock Company | VIET NAM | Unknown | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Yes | |||
| Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tin | Yunnan Tin Company Limited | CHINA | Yes | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Yes | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Yes | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Yes | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Yes |
18
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Yes | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Yes | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Yes | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Yes | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
| Tungsten | Hunan Litian Tungsten Industry 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 | Yes | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Yes | |||
| Tungsten | Jiangxi Minmetals Gao’anNon-ferrous Metals Co., Ltd. | CHINA | Unknown | |||
| Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Yes |
19
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Yes | |||
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Yes | |||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Yes | |||
Tungsten | Kennametal Fallon | UNITED STATES | Yes | |||
Tungsten | Kennametal Huntsville | UNITED STATES | Yes | |||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Yes | |||
Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Yes | |||
Tungsten | Niagara Refining LLC | UNITED STATES | Yes | |||
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Yes | |||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Yes | |||
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Yes | |||
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Yes | |||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | 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 | Yes | |||
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 | Yes | |||
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Yes |
20
