0001020710-18-000013.txt : 20180531 0001020710-18-000013.hdr.sgml : 20180531 20180531101531 ACCESSION NUMBER: 0001020710-18-000013 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20171231 FILED AS OF DATE: 20180531 DATE AS OF CHANGE: 20180531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DXP ENTERPRISES INC CENTRAL INDEX KEY: 0001020710 STANDARD INDUSTRIAL CLASSIFICATION: WHOLESALE-INDUSTRIAL MACHINERY & EQUIPMENT [5084] IRS NUMBER: 760509661 STATE OF INCORPORATION: TX FISCAL YEAR END: 0727 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-21513 FILM NUMBER: 18870318 BUSINESS ADDRESS: STREET 1: 7272 PINEMONT DRIVE CITY: HOUSTON STATE: TX ZIP: 77040 BUSINESS PHONE: 7139964700 MAIL ADDRESS: STREET 1: 7272 PINEMONT DRIVE CITY: HOUSTON STATE: TX ZIP: 77040 FORMER COMPANY: FORMER CONFORMED NAME: INDEX INC DATE OF NAME CHANGE: 19960808 SD 1 formsd.htm FORM SD
 UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D. C. 20549


FORM SD
Specialized Disclosure Report



DXP ENTERPRISES INC.
(Exact name of registrant as specified in its charter)

Texas
000-21513
76-0509661
(State or other jurisdiction
(Commission File Number)
(IRS Employer Identification No.)
of incorporation or organization)
   
     
     
7272 Pinemont Dr., Houston, Texas
 
77040
     
 (Address of principal executive officers)
 
(Zip Code)
 
Kent Yee
Senior Vice President & CFO
713-996-4700
(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:

[P] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017.
1

SECTION 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report.

DXP Enterprises, Inc. has included its Conflict Minerals Report ("Report") as an exhibit to its Form SD for the period from January 1, 2017 to December 31, 2017. Unless the context otherwise indicates, "DXP," "we," "us" and "our" refer to DXP Enterprises, Inc. and its consolidated subsidiaries.

During 2017, certain of our operations manufactured, or contracted to manufacture, products for which 3TGs, as defined below, are necessary to their functionality or production ("Covered Products"). Conflict minerals are defined in Section 13(p) under the Securities Exchange Act of 1934, as amended, as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (together with 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. Accordingly, we have conducted a reasonable country of origin inquiry ("RCOI") that was designed to determine whether any of the 3TGs in our Covered Products originated in the Democratic Republic of the Congo or an adjoining country (Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda or Zambia), or were from recycled or scrap sources.

A summary of our RCOI and steps of due diligence on the source and chain of custody of any 3TGs in our Covered Products, is included in our Report, which is filed as Exhibit 1.01 to this Form SD. In addition to this, our Report and Form SD is publicly available on our website at: www.dxpe.com within the "Investor Relations" section under "Financial Information" > "SEC Filings".


Forward-Looking Statements

The Report contains forward-looking statements which express a belief, expectation or intention, as well as those that are historical fact, are forward-looking statements, including statements relating to our compliance efforts and expected actions.  The words "expects," "intends," "plans," "believes," and "anticipates" and similar expressions are 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, and the Company undertakes no obligation to publicly update or revise any forward-looking statement.

Item 1.02 Exhibit.

We have filed our Conflict Minerals Report as Exhibit 1.01 to this Form SD.

Item 2.01  Exhibits.

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01. and 1.02 of Form SD.


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SIGNATURES

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.

   
DXP Enterprises, Inc.
     
     
May 31, 2018
By:
   /s/ Kent Yee
Kent Yee
   
Senior Vice President & CFO

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EXHIBIT INDEX

Exhibit
Number
Description
 
1.01
Conflict Minerals Report for the year ended December 31, 2017 as required by Items 1.01 and 1.02 of this Form.
   

4
EX-1.01 2 ex101.htm EX 1.01
EXHIBIT 1.01

DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2017

Introduction

This Report has been prepared by management of DXP for the period from January 1, 2017 to December 31, 2017 (the "Reporting Period"). Unless the context otherwise indicates, "DXP," "we," "us," the "Company" and "our" mean DXP Enterprises, Inc. and its consolidated and combined subsidiaries.

This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the "Rule"). This Rule imposes certain reporting obligations on public companies that manufacture or contract to manufacture products containing conflict minerals that are necessary to the functionality or production of their products. Form SD defines "conflict minerals" as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are currently limited to tin, tantalum and tungsten. We identified tin, tantalum, tungsten and gold ("3TGs") that are necessary to the functionality or production of certain products that we manufactured or contracted to manufacture during the Reporting Period.

As described in this report, DXP has reason to believe that some of the 3TGs present in its supply chain may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country (the "Covered Countries"). Therefore, we performed a reasonable country of origin inquiry ("RCOI") to determine whether any of the 3TGs in our products originated from the Covered Countries and were not from recycled or scrap sources.  Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the DRC Region and proceeded to conduct due diligence on our supplier base. The results of this are covered below.

Company Overview

Our business

DXP is engaged in the business of distributing maintenance, repair, and operating products, equipment and services to energy and industrial customers. DXP is organized into three business segments: Service Centers, Innovative Pumping Solutions and Supply Chain Services. The Service Centers segment is engaged in providing maintenance, MRO products and equipment, including logistics capabilities, to industrial customers. The Service Centers segment provides a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, fastener, industrial supply, safety products and safety services categories. The Innovative Pumping Solutions segment fabricates and assembles custom-made pump packages, remanufactures pumps and manufactures branded private label pumps. The Supply Chain Services segment manages all or part of a customer's MRO products supply chain, including warehouse and inventory management.

We have become customer driven experts in five key product categories. As such, our three business segments are supported by the following five key product categories: rotating equipment, bearings & power transmission, industrial supplies, metal working and safety products & services. Each business segment tailors its inventory and leverages product experts to meet the needs of its local customers.

Key product categories that we offer include:

·
Rotating Equipment. Our rotating equipment products include a full line of centrifugal pumps for transfer and process service applications, such as petrochemicals, refining and crude oil production; rotary gear pumps for low- to- medium pressure service applications, such as pumping lubricating oils and other viscous liquids; plunger and piston pumps for high-pressure service applications such as disposal of produced water and crude oil pipeline service; and air-operated diaphragm pumps. We also provide a large variety of pump accessories.
1



·
Bearings & Power Transmission. Our bearing products include several types of mounted and un-mounted bearings for a variety of applications. The power transmission products we distribute include speed reducers, flexible-coupling drives, chain drives, sprockets, gears, conveyors, clutches, brakes and hoses.

·
Industrial Supplies. We offer a broad range of industrial supplies, such as abrasives, tapes and adhesive products, coatings and lubricants, fasteners, hand tools, janitorial products, pneumatic tools, welding supplies and welding equipment.

·
Metal Working. Our metal working products include a broad range of cutting tools, abrasives, coolants, gauges, industrial tools and machine shop supplies.

·
Safety Products & Services. We sell a broad range of safety products including eye and face protection, first aid, hand protection, hazardous material handling, instrumentation and respiratory protection products. Additionally, we provide safety services including hydrogen sulfide (H2S) gas protection and safety, specialized and standby fire protection, safety supervision, training, monitoring, equipment rental and consulting. Our safety services include safety supervision, medic services, safety audits, instrument repair and calibration, training, monitoring, equipment rental and consulting.


Our Covered Products

We conducted an analysis of our products to determine which of our products were likely to contain 3TG.We have identified tungsten in certain of our rotating equipment products within our segments that are necessary to the functionality or production of products that we manufactured or contracted to manufacture during the Reporting Period.  DXP was unsure of the presence of 3TGs in their products however, through the RCOI, via supplier responses using the CMRT, the presence of all 3TGs were claimed by suppliers. Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to definitively conclude which 3TGs are present in the parts or products that they supplied to us however we did continue with the RCOI and due diligence, as applicable, based on the information supplied.


Description of RCOI

DXP began our scoping process by extracting a list of our suppliers that provide us with Covered Products that may contain one or more of the 3TGs. Once the filtering was completed, we populated the list with contact information and provided the list to our third-party vendor, Assent Compliance. This supplier list was then uploaded to our third-party vendor's software platform that allows us to store and manage supplier requests and documentation.

From there, we defined our scoping process even further by removing service providers, indirect materials suppliers, and suppliers who are inactive. This ensures that all suppliers surveyed provided items to DXP that were used in final products in the year 2017. Through this process we removed 3 suppliers from the scope for the 2017 reporting period.

Our third-party vendor then conducted the supplier survey portion of the RCOI. Utilizing the CFSI Conflict Minerals Reporting Template (the "CMRT"), version 5.0 or higher, the suppliers identified through the procedures above were surveyed on their sourcing of the 3TGs that we identified in our products. The CMRT was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company's supply chain. It includes questions regarding a direct supplier's conflict minerals policy, its due diligence process, and information about its supply chain such as the names and locations of smelters and refiners as well as the origin of 3TGs used by those facilities.

During the supplier survey, suppliers were contacted and asked to complete the CMRT. All communications were tracked and monitored in the software platform. Non-responsive suppliers were contacted a minimum of three times and then were also managed by our third-party vendor's Supply Chain Team in one on one communications. This
2


included at least two follow ups in order to encourage their response via CMRTs. To ensure that our suppliers
understand our expectations regarding the sourcing of 3TGs, we and our third-party vendor have provided training to suppliers though webinars, videos, documentation, and one-on-one discussions.

The RCOI also included automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. All suppliers who submitted CMRTs that were flagged as "invalid" were contacted to address items such as incomplete data, missing smelter information, or inconsistent answers. All of these communications were monitored and tracked in our third-party vendor's system for future reporting and transparency. As of May 20th 2018 there were 21 invalid submissions that were not corrected by suppliers.

Based on the RCOI, we determined that we may have some suppliers that sourced 3TGs from the Covered Countries; therefore, in an effort to locate mines with the greatest possible specificity, we proceeded to conduct due diligence on our supplier base.

Due Diligence

Design of due diligence

We have designed our due diligence procedures to conform, in all material respects, with the due diligence framework presented by the Organization for Economic Co-operation and Development ("OECD") in the publication OECD (2013) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Second Edition, OECD Publishing and the related Supplements for gold and for tin, tantalum and tungsten ("Guidance").

DXP's conflict minerals due diligence process includes the five steps as defined by the Guidance: 1) establishing strong company management systems, 2) identifying and assessing risks in our supply chain, 3) designing and implementing a strategy to respond to identified risks, 4) utilizing independent third-party audits, and 5) publicly reporting on our supply chain due diligence. A summary of the due diligence measures undertaken by the Company is outlined below.

Due diligence performed

Establish Strong Company Management Systems

Internal team

We have organized a Conflict Minerals Committee comprised of individuals in management positions across multiple departments such as legal, finance, and procurement. The Conflict Minerals Committee leads our conflict minerals compliance effort and is responsible for implementing our conflict minerals compliance strategy and overseeing the program.

We have also taken on other management systems that include the use of our third-party vendor, Assent Compliance. Through our third-party vendor's tool we are able to collect and store supplier data and CMRTs, communicate with suppliers, and monitor risks in our supply chain. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.

Control systems

Controls include, but are not limited to, our Code of Conduct, which outlines expected behaviors for all DXP employees and third parties doing business with DXP, and regarding our Conflict Minerals Policy. We established a conflict minerals policy related to our sourcing of 3TGs as described in full in our "Conflict Minerals Policy" posted on our website at www.dxpe.com within the "Investor Relations" section under "Corporate Governance" > "Governance Documents".
3


Supplier engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT version 5.0 or higher and our third-party vendor's software reporting tool for collecting Conflict Minerals declarations from our supply base. The use of these tools has allowed us to assist our suppliers in understanding our expectations and requirements and increase the rate of responses we have received from our suppliers to our survey requests.

We have also communicated with suppliers potentially affected by our Conflict Minerals Policy and compliance efforts, as identified through our RCOI process, our expectation that they assist us in complying with our efforts related to our conflict minerals program. This includes obtaining information to support chain of custody of the 3TGs identified in our products.

Grievance Mechanism

For concerns regarding potential violations, the "Conflict Minerals Policy" includes contact information for DXP's third party conduct helpline and means to make a report using dxpe.ethicspoint.com.

Maintain records

We have maintained company-wide document retention policies. These policies extend to the documentation accumulated in performing our due diligence procedures and requires that documentation will be retained for a period of not less than three years.

Identify and Assess Risks in the Supply Chain

It is important to note that DXP has relied on supplier responses to provide us with the information about the source of 3TGs contained in the parts and components they supply to us. Similarly, our direct suppliers also rely on information provided by their suppliers. This chain of information creates a level of uncertainty and risk related to the accuracy of the information. We will continue to monitor, adapt, and modify our due diligence practices to conform to the recognized industry best practices.

In accordance with OECD Guidance, it is important to understand risk levels associated with conflict minerals in the supply chain. Each facility that meets the Responsible Minerals Initiative (RMI) definition of a smelter or refiner of a 3TGs mineral is assigned a risk of high, medium or low based on 3 scoring criteria:
1.
Geographic proximity to the DRC and Covered Countries;
2.
Responsible Minerals Assurance Process ("RMAP") audit status;
3.
Known or plausible evidence of unethical or conflict sourcing.

Based on this criteria the following facilities have been identified as being of highest concern to the supply chain:
·
Tony Goetz NV - CID002587
·
Kaloti Precious Metals - CID002563
·
Universal Precious Metals Refining Zambia - CID002854
·
Fidelity Printers and Refiners - CID002515
·
Sudan Gold Refinery - CID002567
·
African Gold Refinery Limited (AGR) - CID003185

When these facilities are reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through our third-party vendor, Assent Compliance, 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 DXP, and escalating 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 ultimate goal of progressive elimination of these risks from the supply chain.  
4


In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

We also calculate supplier risk based on the chances that the supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Many suppliers continue to be in the middle of the process and still have "unknown" as some of the answers. It has been decided that penalizing or failing them for working through the process is likely not the best approach for the initial years of compliance, it does not meet the goals or spirit of the Rule, however evaluating and tracking the strength of the program does meet the OECD Guidance and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are:

A. Do you have a policy in place that includes DRC conflict-free sourcing?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company's expectations?
H. Do you verify due diligence information received from your suppliers?

When suppliers meet or exceed the above criteria, by answering yes to all four questions, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. We store all of this information and will continue to assess our suppliers' program strength and monitor any improvements or changes.


Design and Implement a Strategy to Respond to Identified Risks

DXP has established a Conflict Minerals Policy that outlines our expectations for suppliers. If these expectations are not met, the business relationship with that supplier will be evaluated. For example, if we find that we source 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries, DXP will assess the supplier relationship and encourage that supplier to establish an alternative source of the minerals that does not support such conflict. If an alternative source cannot be found or the supplier chooses not to respond to this risk, we will assess whether or not that supplier can be replaced.

Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct relationship with smelters and refiners of Conflict Minerals and therefore do not perform or direct audits of these entities.  In connection with our due diligence, we utilized information made available by the RMI concerning independent third-party audits of smelters and refiners.

Report on Supply Chain Due Diligence
This Report, which constitutes our annual report on our due diligence efforts, is available on our website at www.dxpe.com within the "Investor Relations" section under "Financial Information > SEC Filings" and is filed with the SEC.

Results of Due Diligence
Survey results

As of May 20th 2018, we received responses from 387, we received valid CMRTs from 366 and invalid CMRTs from 21 of our surveyed suppliers for the 2017 year.

As described above, DXP surveys our supply chain and reviews all responses against set criteria that has been developed to determine whether further communication is needed. These criteria include: nonresponsiveness, incomplete responses and overall inconsistencies. Those that provided us with a CMRT were also asked to submit SOR information. The results of this are discussed in the Smelters and Refiners section below.
5


Smelters and Refiners

Of the suppliers surveyed, many completed their CMRTs at the company, business unit or entity level. Due to this we are unable to conclude which 3TGs from which of the processing facilities they listed have actually been included in parts or products that they supplied to us.  Many of the responses provided by a supplier via the CMRT included the names of facilities listed by the suppliers as smelters or refiners ("SOR"). The CMRTs submitted by suppliers that do not list at least one smelter for each 3TGs claimed on the CMRT are considered invalid and our third-party vendor follows up on these, urging suppliers to resubmit the form and include smelter information. That being said, there are still suppliers that are unable to provide SOR used for the materials supplied to us.

For all responses that indicated a smelter, our third-party vender compared the facilities listed to the list of smelters maintained by the RMI If a supplier indicated that the facility was certified as "Conflict-Free," our third-party vendor, Assent Compliance, confirmed that the name was listed by RMI as a certified smelter. No violations were identified. As of May 20th 2018, we have validated 321 smelters or refiners and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Appendix A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by suppliers and RMI.

As our suppliers are largely unable to provide us with the information necessary to determine country of origin at the product level, we are unable to provide additional smelter and refiner names and country of origin of the necessary 3TG in this Report at this time. We will continue to work with our suppliers to obtain smelter information at the product level.

Future Steps to be Taken

We are committed to complying with the provisions of the Rule and Form SD and expect to continue our efforts to improve our conflict minerals program and related due diligence. As we further develop our program and procedures, we intend to take the following steps to mitigate the risk that any of the 3TGs contained in our products could benefit armed groups in the Covered Countries. These may include, but are not limited to the following:

·
Engage with suppliers and direct them to training resources to attempt to increase our response rate and improve the content of responses to assist in our RCOI process and our efforts to determine the processing facilities for and country of origin of our 3TGs with the greatest specificity possible;
·
Engage suppliers and encourage them to provide responses at the product level
·
Continue to invest in Conflict Minerals due diligence tools
·
Continue to respond to industry trends and legal requirements to further improve the traceability of 3TGs in our supply chain.

6


Appendix A:

The table below lists, as of May 20th 2018 the smelters or refiners identified by our responsive direct suppliers that may have been used to process the conflict minerals necessary to the functionality or production of our Covered Products during 2017. As described above, this list may contain more facilities than are actually linked to the Company's Covered Products. Alternatively, this list may not include all applicable facilities as not all of our suppliers were able to provide SOR information at this time. Those that have been validated as compliant under RMAP by the RMI, have been noted as such in the final column on the right.

Metal
 Standard Smelter Name
 Smelter Facility Location
 Smelter ID
 RMI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Not Enrolled
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Conformant
Gold
African Gold Refinery
UGANDA
CID003185
Not Enrolled
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Conformant
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002560
Conformant
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Conformant
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Conformant
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Conformant
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Conformant
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Conformant
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Conformant
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Conformant
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Conformant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Conformant
Gold
Aurubis AG
GERMANY
CID000113
Conformant
Gold
Bangalore Refinery
INDIA
CID002863
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Conformant
Gold
Boliden AB
SWEDEN
CID000157
Conformant
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Conformant
Gold
Caridad
MEXICO
CID000180
Not Enrolled
7


Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Conformant
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Conformant
Gold
Chimet S.p.A.
ITALY
CID000233
Conformant
Gold
Chugai Mining
JAPAN
CID000264
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Conformant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Not Enrolled
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Conformant
Gold
Dowa
JAPAN
CID000401
Conformant
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Active
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Conformant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Conformant
Gold
Elemetal Refining, LLC
UNITED STATES
CID001322
Not Enrolled
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Conformant
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Not Enrolled
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Conformant
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Conformant
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
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
HeeSung
KOREA, REPUBLIC OF
CID000689
Conformant
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Conformant
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Conformant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Conformant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Not Enrolled
8


Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Conformant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Conformant
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Conformant
Gold
Italpreziosi
ITALY
CID002765
Conformant
Gold
Japan Mint
JAPAN
CID000823
Conformant
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Conformant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Conformant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Conformant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Conformant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
CID000957
Conformant
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Conformant
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Conformant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Conformant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Conformant
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Not Enrolled
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
Active
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Conformant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Not Enrolled
Gold
Marsam Metals
BRAZIL
CID002606
Conformant
Gold
Materion
UNITED STATES
CID001113
Conformant
9


Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Conformant
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Conformant
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Conformant
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Conformant
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Conformant
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Conformant
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Conformant
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Conformant
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Conformant
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Conformant
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Active
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
Conformant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Conformant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Not Enrolled
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Active
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Conformant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Conformant
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Conformant
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Conformant
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Conformant
Gold
PAMP S.A.
SWITZERLAND
CID001352
Conformant
Gold
Pease & Curren
UNITED STATES
CID002872
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Not Enrolled
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Conformant
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Conformant
10


Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Conformant
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Conformant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Conformant
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Not Enrolled
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Active
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Conformant
Gold
Royal Canadian Mint
CANADA
CID001534
Conformant
Gold
SAAMP
FRANCE
CID002761
Conformant
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Not Enrolled
Gold
Safimet S.p.A
Italy
CID002973
Conformant
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Active
Gold
Sai Refinery
INDIA
CID002853
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Conformant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Conformant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Conformant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Conformant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Not Enrolled
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Conformant
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Conformant
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516
Conformant
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Conformant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Conformant
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Not Enrolled
Gold
Sudan Gold Refinery
SUDAN
CID002567
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Conformant
Gold
SungEel HiTech
KOREA, REPUBLIC OF
CID002918
Conformant
Gold
T.C.A S.p.A
ITALY
CID002580
Conformant
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Conformant
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Conformant
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Conformant
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Not Enrolled
Gold
Tony Goetz NV
BELGIUM
CID002587
Not Enrolled
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Not Enrolled
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Conformant
11


Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Conformant
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Conformant
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Conformant
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Conformant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Conformant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Conformant
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Conformant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Conformant
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Conformant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Conformant
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Conformant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Conformant
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Conformant
Tantalum
Duoluoshan
CHINA
CID000410
Not Enrolled
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Conformant
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Conformant
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Conformant
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Conformant
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Conformant
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Conformant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Conformant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Conformant
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Conformant
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Conformant
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Conformant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Conformant
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Conformant
12


Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Conformant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Conformant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Conformant
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID003191
Conformant
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Conformant
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Conformant
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Conformant
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Conformant
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Conformant
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
CID000973
Conformant
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Conformant
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Conformant
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Conformant
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Conformant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Conformant
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Conformant
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Conformant
Tantalum
QuantumClean
UNITED STATES
CID001508
Conformant
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Conformant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Conformant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Conformant
Tantalum
Taki Chemicals
JAPAN
CID001869
Conformant
Tantalum
Telex Metals
UNITED STATES
CID001891
Conformant
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Conformant
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Conformant
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
CID002307
Conformant
Tin
Alpha
UNITED STATES
CID000292
Conformant
13


Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Conformant
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Active
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Conformant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000278
Not Enrolled
Tin
CV Ayi Jaya
INDONESIA
CID002570
Conformant
Tin
CV Dua Sekawan
INDONESIA
CID002592
Conformant
Tin
CV Gita Pesona
INDONESIA
CID000306
Conformant
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Conformant
Tin
CV United Smelting
INDONESIA
CID000315
Conformant
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Conformant
Tin
Dowa
JAPAN
CID000402
Conformant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Not Enrolled
Tin
EM Vinto
BOLIVIA
CID000438
Conformant
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Not Enrolled
Tin
Fenix Metals
POLAND
CID000468
Conformant
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Conformant
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Conformant
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Conformant
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Conformant
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Conformant
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Not Enrolled
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
CID003116
Conformant
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Conformant
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Conformant
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Conformant
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244
Conformant
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Conformant
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Conformant
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Conformant
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Conformant
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Conformant
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Conformant
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Conformant
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Conformant
Tin
Minsur
PERU
CID001182
Conformant
14


Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Conformant
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Conformant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Conformant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Conformant
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Not Enrolled
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Conformant
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Conformant
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Conformant
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Conformant
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Conformant
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Conformant
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Conformant
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Conformant
Tin
PT Bukit Timah
INDONESIA
CID001428
Conformant
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Conformant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Conformant
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Conformant
Tin
PT Karimun Mining
INDONESIA
CID001448
Conformant
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Conformant
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Conformant
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Conformant
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Conformant
Tin
PT O.M. Indonesia
INDONESIA
CID002757
Conformant
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Conformant
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Conformant
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Conformant
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Conformant
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Conformant
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Conformant
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Conformant
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Conformant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Conformant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Conformant
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Conformant
Tin
PT Tommy Utama
INDONESIA
CID001493
Conformant
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Conformant
15


Tin
Rui Da Hung
TAIWAN
CID001539
Conformant
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Conformant
Tin
Super Ligas
Brazil
CID002756
Not Enrolled
Tin
Thaisarco
THAILAND
CID001898
Conformant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Not Enrolled
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Conformant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Conformant
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Conformant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Conformant
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Conformant
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Conformant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Conformant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Conformant
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Conformant
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Active
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Conformant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Conformant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Conformant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Conformant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Conformant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Conformant
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Conformant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Conformant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Conformant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Conformant
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Conformant
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Conformant
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Conformant
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Conformant
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Not Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Conformant
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
Conformant
16


Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Conformant
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
CID002535
Conformant
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Conformant
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Conformant
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Conformant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Conformant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Conformant
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Conformant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Conformant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Conformant
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Conformant
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Conformant
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Conformant
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Conformant
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Conformant
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Conformant
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Conformant
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Conformant
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Conformant
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
Conformant

17


Country of Origin List:
This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of Bolivia), Brazil,  Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Viet Nam, Zimbabwe
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