UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
SEALED AIR CORPORATION
(Exact Name of Registrant as Specified in its Charter)
| Delaware | 1-12139 | 65-0654331 | ||
| (State or Other Jurisdiction of Incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
| 2415 Cascade Pointe Boulevard Charlotte, North Carolina |
28208 | |
| (Address of Principal Executive Offices) | (Zip Code) |
Thomas C. Lagaly
Vice President, Acting General Counsel & Secretary
980-221-3235
(Name and telephone number, including area code, of the person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
Section 1 – Conflict Minerals Disclosure
| Item 1.01 | Conflict Minerals Disclosure and Report |
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”), Sealed Air Corporation (“Sealed Air” or the “Company”) is filing this Form SD to disclose information relating to the Company’s use and sourcing of columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”).
The Company has determined that during the reporting period January 1, 2016 to December 31, 2016, certain of the products the Company manufactures or contracts to manufacture contained 3TG that was necessary to the functionality or production of those products. Sealed Air conducted a reasonable country of origin inquiry (“RCOI”) designed to determine whether any of the 3TG originated in the Democratic Republic of the Congo or an adjoining country (together, a “Covered Country”) and whether any of the 3TG originated from recycled or scrap sources. Based on this RCOI, Sealed Air determined that certain of the 3TG likely originated in the Covered Countries and did not originate from recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and has filed a Conflict Minerals Report for calendar year 2016 (the “2016 Conflict Minerals Report”). The Company’s 2016 Conflict Minerals Report is attached hereto as Exhibit 1.01 and is publicly available at www.sealedair.com/investors.
| Item 1.02 | Exhibit |
The Company’s 2016 Conflict Minerals Report, as required by Item 1.02, is attached as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
| Item 2.01 | Exhibits |
Exhibit 1.01 – Conflict Minerals Report for the reporting period January 1, 2016 to December 31, 2016.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Sealed Air Corporation | ||
| By: | /s/ Thomas C. Lagaly | |
| Thomas C. Lagaly | ||
| Vice President, Acting General Counsel & Secretary | ||
Dated: May 26, 2017
Exhibit 1.01
Sealed Air Corporation
Conflict Minerals Report
for the Year Ended December 31, 2016
Introduction
This Conflict Minerals Report has been prepared pursuant to Rule 13p-1 of the Securities Exchange Act of 1934, as amended (the “Rule”), for the reporting period from January 1 to December 31, 2016. This Conflict Minerals Report describes Sealed Air Corporation’s (“Sealed Air,” the “Company,” “we,” “our,” or “us”) reasonable country of origin inquiry (“RCOI”) and due diligence on the source and chain of custody of gold, columbite-tantalite (coltan), cassiterite, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten (“3TG” or “Conflict Minerals”) that are necessary to the production or functionality of products that Sealed Air manufactured or contracted to manufacture during calendar year 2016 (the “2016 Report Year”). We are several steps removed from the mining and processing of the 3TG used in the components for our products. Accordingly, our due diligence process focused on our suppliers, and we rely on them to assist with both our RCOI and due diligence process, including the identification of smelters or refiners (“SORs”) in the supply chain and the countries of origin of 3TG sourced by the identified SORs.
The information in this report covers the activities of Sealed Air and all of its consolidated subsidiaries.
Company Overview
Sealed Air, a corporation organized under the laws of Delaware, is a global leader in food safety and security, facility hygiene and product protection. The Company serves an array of end markets including food and beverage processing, food service, retail, healthcare and industrial, and commercial and consumer applications. Our focus is on achieving quality sales growth through leveraging our geographic footprint, technological know-how and leading market positions to bring measurable, sustainable value to our customers and investors.
Product Description
This Conflict Minerals Report relates to products (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2016. Through a screening process, the Company determined that, to the best of our knowledge, customer equipment and other select products from the Company’s three divisions, Food Care, Product Care and Diversey Care, referred to collectively as the “Covered Products,” contain 3TG or have a high likelihood of containing 3TG, as these products contain electronic components. More specifically, the “Covered Products” may contain necessary Conflict Minerals as follows:
| • | Tantalum, used in capacitors and certain alloys; |
| • | Tin, used in soldered components; |
| • | Tungsten, used in coatings and certain alloys; and |
| • | Gold, used in circuit boards and electronic components. |
Supply Chain
Our supply chain includes 507 different in-scope suppliers. Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging to identify actors upstream from our direct suppliers. There are many tiers of suppliers and sub-suppliers between the Company and the SORs that process the 3TG that is contained in each particular product manufactured or contracted to be manufactured by Sealed Air. Therefore, it is inherently difficult to determine the ultimate source of 3TG in the products we manufacture. As a result, we rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.
We have revised contract terms applicable to the majority of our suppliers with regard to 3TG. Those terms require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.
Reasonable Country of Origin Inquiry
We conducted a RCOI reasonably designed to determine whether the 3TG in our products in the 2016 Report Year originated from the Covered Countries or are from recycled or scrap sources in accordance with the requirements of the Rule. The Covered Countries are the Democratic Republic of the Congo and its adjoining countries (Angola, Burundi, Republic of the Congo, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda and Zambia). As part of its RCOI, and with the assistance of a third-party consultant, Assent Compliance, Inc. (“Assent”), the Company engaged its potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products. Suppliers were asked to complete and submit, within a certain time frame, the joint Electronic Industry Citizen Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”) EICC-GeSI Conflict Minerals Reporting Template v. 4.1 or higher (“CMRT”). The CMRT is a standardized reporting template developed by the Conflict-Free Sourcing Initiative (“CFSI”) that requests, among other things, information regarding country of origin of 3TG supplied to the Company and the SORs in the supply chain. Assent followed up with all unresponsive suppliers through a defined process via both automated emails and one-on-one emails, including offering assistance and further information to suppliers about the requirements of the Rule and the Company’s expectations. Based on the RCOI, Sealed Air determined that certain of our 3TG originated in the Covered Countries and did not originate from recycled or scrap sources. Accordingly, Sealed Air exercised due diligence on the source and chain of custody of such 3TG and is filing this Conflict Minerals Report for the 2016 Report Year.
Due Diligence
Design of Due Diligence
Sealed Air designed its due diligence process to conform with the due diligence framework in the Organization of Economic Co-operation and Development Due Diligence (“OECD”) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively the “OECD Guidance”).
Step One – Establish Strong Company Management Systems
Conflict Minerals Policy
We have adopted a Conflict Minerals policy, which is posted on our website at www.sealedair.com/investors.
Internal Team and Training
The Company has established an internal management team responsible for executing our Conflict Minerals due diligence process and reporting compliance. Our Conflict Minerals team is overseen by the General Counsel and Chief Supply Chain Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance and legal. The team of subject matter experts is responsible for implementing our Conflict Minerals compliance strategy. Senior management is briefed about the results of our due diligence efforts on a regular basis.
We, in cooperation with Assent, have developed internal training programs to educate anyone within the Company that is a potential contact point for suppliers or other external parties regarding the Company’s Conflict Minerals compliance efforts. We intend to review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.
Control Systems
As previously noted, the Company engaged Assent to facilitate supplier engagement and assist the Company in collecting, analyzing, verifying, and storing supplier-provided data and performing due diligence for the Conflict Minerals program. Data regarding the presence and sourcing of 3TG in materials, goods and components supplied to the Company was collected from suppliers utilizing the CMRT, a standardized reporting template developed by the CFSI.
Our controls also include our Code of Business Conduct and Ethics, which outlines expected behaviors for all our employees.
Supplier Engagement
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us – including sources of 3TG that are supplied to them from lower tier suppliers.
In accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with Assent, provided educational materials to suppliers on the Conflict Minerals regulations as well as relevant SEC reporting requirements (as discussed further below). In addition, we have leveraged our existing communications framework, specifically through our procurement personnel, to encourage supplier interactions with Assent and to impress on our suppliers the importance of completing the Conflict Minerals surveys. It has also allowed for our supplier communications to be more focused and to ensure expectations are clear.
Additionally, as noted, the majority of our supplier contracts require suppliers to certify that, unless otherwise specified in writing, the products do not contain any 3TG, and further require that the suppliers respond to reasonable requests from the Company in connection with its compliance with Section 1502 of the Dodd-Frank Act.
This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized Assent’s Learning Management System, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.
Grievance Mechanism
We have in place a grievance mechanism whereby employees and suppliers can report violations of the Company’s policies, including concerns with regard to Conflict Minerals. Employees and suppliers can raise concerns by emailing at contact.us@sealedair.com.
Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence. Our policy related to relevant documentation of our Conflict Minerals compliance process requires that documentation be retained for a period of at least five years.
Step Two – Identify and Assess Risk in Our Supply Chain
Supplier Risk Assessment
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is challenging for us to identify suppliers other than our direct suppliers. After conducting a risk-based assessment of our direct suppliers, we identified over 500 different in-scope direct suppliers. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are SEC registrants and subject to the Rule or are suppliers to other SEC registrants that are subject to the Rule.
We calculate supplier risk based on the chances that a supplier provides 3TG that may originate from non-conflict free sources. The value of this risk is calculated based on the risk ratings of the SORs declared by that supplier on their CMRT. Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
| • | Does the supplier have a policy in place that includes DRC conflict-free sourcing? |
| • | Has the supplier implemented due diligence measures for conflict-free sourcing? |
| • | Does the supplier verify due diligence information received from its suppliers? |
| • | Does the supplier’s verification process include corrective action management? |
When a supplier meets these criteria, the supplier is deemed to have a strong program. When a supplier does not meet these criteria, the supplier is deemed to have a weak program.
As part of our risk management plan and to ensure suppliers understand our expectations, we have, through Assent, provided video and written training on Conflict Minerals and the CMRT. This training includes instructions on completing the form and one-on-one email and phone discussions with supplier personnel.
Supplier Surveys
Tracing materials back to their mine or location of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG SORs in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain.
Our primary means of determining the origin of our 3TG for the 2016 Report Year was by conducting a supply chain survey with direct suppliers using the CMRT. This supply chain survey, and Sealed Air’s Conflict Minerals program as a whole, has been developed and implemented in cooperation with Assent.
Assent provided each supplier a copy of the EICC-GeSI reporting CMRT to complete for purposes of Conflict Minerals tracking. Assent and/or members of the Sealed Air supply chain team made at least three follow-up inquiries to each supplier that did not respond to our initial survey, either by phone or email or both. The Assent software platform automatically reviewed the responses against criteria developed to determine which required further engagement with our suppliers. These criteria included incomplete responses as well as inconsistencies within the data reported in the CMRT. Assent worked directly with those suppliers to provide revised responses.
Once surveys were returned, Assent reviewed and attempted to match each verified SOR identified in the completed surveys to available lists of SORs that have been validated as conflict free under internationally-recognized schemes such as the CFSI Conflict-Free Smelter Program (“CFSP”). If a SOR was not validated by the CFSP, Assent either attempted to contact the SOR to gather more information about its sourcing practices or conducted Internet research to determine whether there are any additional publicly available sources of information regarding the SOR’s sourcing practices.
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC-Conflict Free pose a significant risk to the Supply Chain. Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:
| • | Geographic proximity to the DRC and covered countries; |
| • | CFSP audit status; and |
| • | Known or plausible evidence of unethical or conflict sourcing. |
Per these criteria the following facilities have been identified as being of highest concern to the supply chain:
| • | Tony Goetz NV – CID002587 |
| • | Kaloti Precious Metals – CID002563 |
| • | Phoenix Metals – CID002507 |
| • | Universal Precious Metals Refining Zambia – CID002854 |
| • | Fidelity Printers and Refiners – CID002515 |
| • | Sudan Gold Refinery – CID002567 |
When these facilities are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through, Assent, submissions that include any of the above facilities immediately produce 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 Sealed Air, up to removal of these high risk smelters from their supply chain.
As per the OECD Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the goal of progressive elimination of these risks from the supply chain. In addition, suppliers are guided to the Assent University learning platform to view educational materials on mitigating the risk of smelters or refiners to the supply chain.
Step Three – Design and Implement a Strategy to Respond to Risks
The Company maintains a risk management plan to respond to risks identified in the above-described risk assessment. The Company’s Conflict Minerals program is implemented, managed and monitored in accordance with this risk management plan.
The Company’s Conflict Minerals team provides updates to senior management of the Company in connection with the Conflict Minerals Program, including with regard to risk assessment and results of the annual due diligence process.
As described in our Conflict Minerals policy, we expect our suppliers to fully support our compliance efforts, including in connection with our due diligence efforts to trace the source and chain of custody of our 3TG. As part of our risk management plan, to ensure suppliers understand our expectations, we provided both video recorded training and documented instructions through Assent, and answered all questions that suppliers requiring further clarification presented to us.
Step Four – Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Sealed Air does not have a direct relationship with Conflict Minerals SORs and, accordingly, we do not perform direct audits of these entities in our supply chain. Rather, Sealed Air relies on independent third-parties to audit and validate SORs.
Step Five – Report on Supply Chain Due Diligence
This Conflict Minerals Report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at www.sealedair.com/investors.
Due Diligence Results
As a result of the due diligence efforts described above, we received completed CMRTs from 88% of our in-scope direct suppliers as of April 21, 2017. Appendix A lists the SORs identified by our direct suppliers that may have been used to process Conflict Minerals necessary to the functionality or production of our products during 2016. For all responses that indicated a SOR, Assent compared the facilities listed to the list of SORs maintained by the CFSI. If a supplier indicated that the facility was “Conflict-Free,” Assent confirmed that the name was listed by CFSI as such. We have validated 317 SORs to date and we are working to validate the additional SOR entries from the submitted CMRTs. We have not listed in Appendix A any potential SORs that we have not been able to validate. Based on the SOR lists provided by suppliers via the CMRTs and publicly available information regarding the results of sourcing audits by the CFSI, we have identified 246 Conflict-Free SORs. Appendix B includes an aggregated list of the countries of origin from which the reported facilities collectively source Conflict Minerals, based on information provided by our suppliers.
The information that we received from a majority of our direct suppliers was at a company-wide level. Therefore, the SORs identified by our direct suppliers contained in Appendix A may include SORs that processed 3TGs that our direct suppliers supplied to their other customers rather than to us. As a result, we are unable to conclusively determine whether the SORs included in Appendix A were used to process the 3TGs necessary to the functionality or production of our products during 2016. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix B was a country of origin of 3TGs in our products during 2016, and therefore are unable to conclusively determine the source and chain of custody of those 3TGs. In addition, the third-party audits conducted by the CFSI, and 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 and, as a result, are not responsible for the quality of these audits or the audit findings.
Risk Mitigation Efforts
We have taken, and intend to continue to take, the following steps to mitigate the risk that 3TG contained in products we manufacture or contract to manufacture benefit armed groups:
| • | Track and add new suppliers as they enter Sealed Air’s supply chain to the Company’s Conflict Minerals program; |
| • | Engage with suppliers and direct them to training resources to attempt to increase the response rate and improve the content of the supplier survey responses; |
| • | Begin a targeted engagement plan with suppliers that do not reply or that reply with inaccurate or invalid responses; and |
| • | Encourage suppliers to use conflict-free SORs in the supply chain. |
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements that express certain beliefs, expectations or intentions, including with regard to our compliance efforts and expected actions in this regard. The words “expect,” “intend,” “plan,” “believe,” and “anticipate” and similar expressions may be used to identify these forward-looking statements. These statements are not guarantees of future actions or performance and are subject to various risks, uncertainties and assumptions. Undue reliance should be not be placed on these statements, which are only effective as of the date of this report. Sealed Air undertakes no obligation to publicly update or revise any forward-looking statement, other than as required by law.
Appendix A
Sealed Air Corporation
Conflict Minerals Report
For the Year Ended December 31, 2016
| Metal |
Standard Smelter Name |
Smelter Facility Location |
Smelter ID | CFSI Audit Status | ||||
| Gold | Abington Reldan Metals, LLC | UNITED STATES | CID002708 | Active | ||||
| Gold | Advanced Chemical Company | UNITED STATES | CID000015 | Compliant | ||||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | Compliant | ||||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | Compliant | ||||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Compliant | ||||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | Compliant | ||||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 | Compliant | ||||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Compliant | ||||
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 | Compliant | ||||
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Compliant | ||||
| Gold | Asahi Refining USA Inc. | UNITED STATES | CID000920 | Compliant | ||||
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | Compliant | ||||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | Not Enrolled | ||||
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | Compliant | ||||
| Gold | AURA-II | UNITED STATES | CID002851 | Not Enrolled | ||||
| Gold | Aurubis AG | GERMANY | CID000113 | Compliant | ||||
| Gold | Bangalore Refinery | INDIA | CID002863 | Active | ||||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Compliant | ||||
| Gold | Boliden AB | SWEDEN | CID000157 | Compliant | ||||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Compliant | ||||
| Gold | Caridad | MEXICO | CID000180 | Not Enrolled | ||||
| Gold | CCR Refinery – Glencore Canada Corporation | CANADA | CID000185 | Compliant | ||||
| Gold | Cendres + Métaux S.A. | SWITZERLAND | CID000189 | Active | ||||
| Gold | Chimet S.p.A. | ITALY | CID000233 | Compliant | ||||
| Gold | Chugai Mining | JAPAN | CID000264 | Not Enrolled | ||||
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | Compliant | ||||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | Not Enrolled | ||||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | Not Enrolled | ||||
| Gold | DODUCO GmbH | GERMANY | CID000362 | Compliant | ||||
| Gold | Dowa | JAPAN | CID000401 | Compliant | ||||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | Compliant | ||||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 | Compliant | ||||
| Gold | Elemetal Refining, LLC | UNITED STATES | CID001322 | Compliant | ||||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | Compliant | ||||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | Not Enrolled | ||||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | CID000522 | Not Enrolled | ||||
| Gold | Geib Refining Corporation | UNITED STATES | CID002459 | Active | ||||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Not Enrolled | ||||
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Not Enrolled | ||||
| Gold | Gujarat Gold Centre | INDIA | CID002852 | Not Enrolled | ||||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | Not Enrolled | ||||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | Not Enrolled | ||||
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | Compliant | ||||
| Gold | Heraeus Ltd. Hong Kong | CHINA | CID000707 | Compliant | ||||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Compliant | ||||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Not Enrolled | ||||
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 | Not Enrolled | ||||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Compliant | ||||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Compliant | ||||
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Compliant | ||||
| Gold | Japan Mint | JAPAN | CID000823 | Compliant | ||||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Compliant | ||||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | Compliant | ||||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Compliant | ||||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Compliant | ||||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | Not Enrolled | ||||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | Not Enrolled | ||||
| Gold | Kazzinc | KAZAKHSTAN | CID000957 | Compliant | ||||
| Gold | Kennecott Utah Copper LLC | UNITED STATES | CID000969 | Compliant | ||||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | CID002511 | Active | ||||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | Compliant | ||||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | Compliant | ||||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Compliant | ||||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | CID001032 | Not Enrolled | ||||
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Not Enrolled | ||||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Not Enrolled | ||||
| Gold | L’Orfebre S.A. | ANDORRA | CID002762 | Not Enrolled | ||||
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Compliant | ||||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Not Enrolled | ||||
| Gold | Materion | UNITED STATES | CID001113 | Compliant | ||||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Compliant | ||||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Compliant | ||||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Compliant | ||||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | Compliant | ||||
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Compliant | ||||
| Gold | Metalor USA Refining Corporation | UNITED STATES | CID001157 | Compliant | ||||
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | CID001161 | Compliant | ||||
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Compliant | ||||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Compliant | ||||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Compliant | ||||
| Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | Not Enrolled | ||||
| Gold | Morris and Watson | NEW ZEALAND | CID002282 | Not Enrolled | ||||
| Gold | Morris and Watson Gold Coast | AUSTRALIA | CID002866 | Not Enrolled | ||||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Compliant | ||||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | CID001220 | Compliant | ||||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | Active | ||||
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Compliant | ||||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Compliant | ||||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | Compliant | ||||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Compliant | ||||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Compliant | ||||
| Gold | PAMP S.A. | SWITZERLAND | CID001352 | Compliant | ||||
| Gold | Pease & Curren | UNITED STATES | CID002872 | Not Enrolled | ||||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Not Enrolled | ||||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Compliant | ||||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Compliant | ||||
| Gold | PX Précinox S.A. | SWITZERLAND | CID001498 | Compliant | ||||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Compliant | ||||
| Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 | Not Enrolled | ||||
| Gold | Republic Metals Corporation | UNITED STATES | CID002510 | Compliant | ||||
| Gold | Royal Canadian Mint | CANADA | CID001534 | Compliant | ||||
| Gold | SAAMP | FRANCE | CID002761 | Not Enrolled | ||||
| Gold | Sabin Metal Corp. | UNITED STATES | CID001546 | Not Enrolled | ||||
| Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | Not Enrolled | ||||
| Gold | Sai Refinery | INDIA | CID002853 | Not Enrolled | ||||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | Compliant | ||||
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Not Enrolled | ||||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | Compliant | ||||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 | Compliant | ||||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | CID001585 | Compliant | ||||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Not Enrolled | ||||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Compliant | ||||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Compliant | ||||
| Gold | Singway Technology Co., Ltd. | TAIWAN | CID002516 | Compliant | ||||
| Gold | So Accurate Group, Inc. | UNITED STATES | CID001754 | Not Enrolled | ||||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Compliant | ||||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN | CID001761 | Compliant | ||||
| Gold | Sudan Gold Refinery | SUDAN | CID002567 | Not Enrolled | ||||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Compliant | ||||
| Gold | SungEel HiTech | KOREA, REPUBLIC OF | CID002918 | Active | ||||
| Gold | T.C.A S.p.A | ITALY | CID002580 | Compliant | ||||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Compliant | ||||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Compliant | ||||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Compliant | ||||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Not Enrolled | ||||
| Gold | Tony Goetz NV | BELGIUM | CID002587 | Active | ||||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | Not Enrolled | ||||
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | Compliant | ||||
| Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Compliant | ||||
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Compliant | ||||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Compliant | ||||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES | CID001993 | Compliant | ||||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 | Not Enrolled | ||||
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Compliant | ||||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | Compliant | ||||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | Compliant | ||||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | CID002100 | Compliant | ||||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | Compliant | ||||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Not Enrolled | ||||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Compliant | ||||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | CID002243 | Compliant | ||||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | Compliant | ||||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 | Compliant | ||||
| Tantalum | D Block Metals, LLC | UNITED STATES | CID002504 | Compliant | ||||
| Tantalum | Duoluoshan | CHINA | CID000410 | Compliant | ||||
| Tantalum | Exotech Inc. | UNITED STATES | CID000456 | Compliant | ||||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Compliant | ||||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | Compliant | ||||
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | Compliant | ||||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | CID002557 | Compliant | ||||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | Compliant | ||||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Compliant | ||||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | CID002545 | Compliant | ||||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | CID002546 | Not Enrolled | ||||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | Compliant | ||||
| Tantalum | H.C. Starck Inc. | UNITED STATES | CID002548 | Compliant | ||||
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | Compliant | ||||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Compliant | ||||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | Compliant | ||||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES | CID000731 | Compliant | ||||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | Compliant | ||||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | Compliant | ||||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Compliant | ||||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Compliant | ||||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | Compliant | ||||
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Compliant | ||||
| Tantalum | KEMET Blue Powder | UNITED STATES | CID002568 | Compliant | ||||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | CID000973 | Compliant | ||||
| Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | Compliant | ||||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Compliant | ||||
| Tantalum | Mineração Taboca S.A. | BRAZIL | CID001175 | Compliant | ||||
| Tantalum | Mitsui Mining & Smelting | JAPAN | CID001192 | Compliant | ||||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | CID001200 | Compliant | ||||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Compliant | ||||
| Tantalum | Plansee SE Liezen | AUSTRIA | CID002540 | Not Enrolled | ||||
| Tantalum | Plansee SE Reutte | AUSTRIA | CID002556 | Compliant | ||||
| Tantalum | Power Resources Ltd. | MACEDONIA | CID002847 | Compliant | ||||
| Tantalum | QuantumClean | UNITED STATES | CID001508 | Compliant | ||||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | CID002707 | Compliant | ||||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | CID001522 | Compliant | ||||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | Compliant | ||||
| Tantalum | Taki Chemicals | JAPAN | CID001869 | Compliant | ||||
| Tantalum | Telex Metals | UNITED STATES | CID001891 | Compliant | ||||
| Tantalum | Tranzact, Inc. | UNITED STATES | CID002571 | Compliant | ||||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Compliant | ||||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | Compliant | ||||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 | Compliant | ||||
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | CID002232 | Compliant | ||||
| Tin | Alpha | UNITED STATES | CID000292 | Compliant | ||||
| Tin | An Thai Minerals Co., Ltd. | VIET NAM | CID002825 | Not Enrolled | ||||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | Not Enrolled | ||||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | Compliant | ||||
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | Compliant | ||||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 | Not Enrolled | ||||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | CID000295 | Compliant | ||||
| Tin | CV Ayi Jaya | INDONESIA | CID002570 | Compliant | ||||
| Tin | CV Dua Sekawan | INDONESIA | CID002592 | Compliant | ||||
| Tin | CV Gita Pesona | INDONESIA | CID000306 | Compliant | ||||
| Tin | CV Serumpun Sebalai | INDONESIA | CID000313 | Compliant | ||||
| Tin | CV Tiga Sekawan | INDONESIA | CID002593 | Compliant | ||||
| Tin | CV United Smelting | INDONESIA | CID000315 | Compliant | ||||
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | Compliant | ||||
| Tin | Dowa | JAPAN | CID000402 | Compliant | ||||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | Active | ||||
| Tin | Elmet S.L.U. | SPAIN | CID002774 | Compliant | ||||
| Tin | EM Vinto | BOLIVIA | CID000438 | Compliant | ||||
| Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 | Not Enrolled | ||||
| Tin | Fenix Metals | POLAND | CID000468 | Compliant | ||||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | Compliant | ||||
| Tin | Gejiu Jinye Mineral Company | CHINA | CID002859 | Compliant | ||||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | Active | ||||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | Compliant | ||||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | Active | ||||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Not Enrolled | ||||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 | Compliant | ||||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | Compliant | ||||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | Not Enrolled | ||||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 | Compliant | ||||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | Compliant | ||||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Compliant | ||||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | Compliant | ||||
| Tin | Metallic Resources, Inc. | UNITED STATES | CID001142 | Compliant | ||||
| Tin | Metallo-Chimique N.V. | BELGIUM | CID002773 | Compliant | ||||
| Tin | Mineração Taboca S.A. | BRAZIL | CID001173 | Compliant | ||||
| Tin | Minsur | PERU | CID001182 | Compliant | ||||
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | Compliant | ||||
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | Not Enrolled | ||||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 | Active | ||||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | Not Enrolled | ||||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | Compliant | ||||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | Compliant | ||||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA | CID001337 | Compliant | ||||
| Tin | Phoenix Metal Ltd. | RWANDA | CID002507 | Not Enrolled | ||||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | Compliant | ||||
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | Compliant | ||||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | Compliant | ||||
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | Compliant | ||||
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 | Compliant | ||||
| Tin | PT Bangka Tin Industry | INDONESIA | CID001419 | Compliant | ||||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 | Compliant | ||||
| Tin | PT Bukit Timah | INDONESIA | CID001428 | Compliant | ||||
| Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | Compliant | ||||
| Tin | PT DS Jaya Abadi | INDONESIA | CID001434 | Compliant | ||||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | CID001438 | Compliant | ||||
| Tin | PT Inti Stania Prima | INDONESIA | CID002530 | Compliant | ||||
| Tin | PT Justindo | INDONESIA | CID000307 | Not Enrolled | ||||
| Tin | PT Karimun Mining | INDONESIA | CID001448 | Compliant | ||||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 | Compliant | ||||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 | Compliant | ||||
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | Compliant | ||||
| Tin | PT O.M. Indonesia | INDONESIA | CID002757 | Compliant | ||||
| Tin | PT Panca Mega Persada | INDONESIA | CID001457 | Compliant | ||||
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 | Compliant | ||||
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | Compliant | ||||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 | Compliant | ||||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | Compliant | ||||
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 | Compliant | ||||
| Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 | Compliant | ||||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 | Compliant | ||||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 | Compliant | ||||
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | Compliant | ||||
| Tin | PT Tommy Utama | INDONESIA | CID001493 | Compliant | ||||
| Tin | PT Wahana Perkit Jaya | INDONESIA | CID002479 | Compliant | ||||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | CID002706 | Compliant | ||||
| Tin | Rui Da Hung | TAIWAN | CID001539 | Compliant | ||||
| Tin | Soft Metais Ltda. | BRAZIL | CID001758 | Compliant | ||||
| Tin | Thaisarco | THAILAND | CID001898 | Compliant | ||||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | Not Enrolled | ||||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 | Compliant | ||||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 | Compliant | ||||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | Active | ||||
| Tin | Yunnan Tin Company Limited | CHINA | CID002180 | Compliant | ||||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 | Compliant | ||||
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | Not Enrolled | ||||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Compliant | ||||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | Compliant | ||||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | Compliant | ||||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | CID000345 | Not Enrolled | ||||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 | Compliant | ||||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | Compliant | ||||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | Compliant | ||||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | Compliant | ||||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 | Not Enrolled | ||||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES | CID000568 | Compliant | ||||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | Compliant | ||||
| Tungsten | H.C. Starck GmbH | GERMANY | CID002541 | Compliant | ||||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002542 | Compliant | ||||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | Compliant | ||||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 | Compliant | ||||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | Compliant | ||||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | Compliant | ||||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | Compliant | ||||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | Compliant | ||||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 | Not Enrolled | ||||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | Compliant | ||||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Not Enrolled | ||||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | Compliant | ||||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | Compliant | ||||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 | Compliant | ||||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | Compliant | ||||
| Tungsten | Kennametal Fallon | UNITED STATES | CID000966 | Compliant | ||||
| Tungsten | Kennametal Huntsville | UNITED STATES | CID000105 | Compliant | ||||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | Compliant | ||||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | CID002845 | Compliant | ||||
| Tungsten | Niagara Refining LLC | UNITED STATES | CID002589 | Compliant | ||||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 | Compliant | ||||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | Compliant | ||||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 | Compliant | ||||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 | Compliant | ||||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | Compliant | ||||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 | Compliant | ||||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 | Compliant | ||||
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | Compliant | ||||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Compliant | ||||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | Compliant | ||||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | Compliant | ||||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 | Compliant | ||||
Appendix B
Sealed Air Corporation
Conflict Minerals Report
For the Year Ended December 31, 2016
Angola, Argentina, Australia, Austria, Belgium, Brazil, Burundi, Canada, Central Africa Republic, Chile, China, Columbia, Cote D’Ivoire, Czech Republic, the Democratic Republic of the Congo, Djibouti, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungry, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Lao People’s Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Plurinational State of Bolivia, Portugal, Republic of Korea, Republic of the Congo, Russian Federation, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Sudan, Spain, Suriname, Switzerland, Taiwan, Thailand, Uganda, United Kingdom of Great Britain, United Republic of Tanzania, United States of America, Vietnam, Zambia and Zimbabwe.