0001020710-19-000049.txt : 20190531 0001020710-19-000049.hdr.sgml : 20190531 20190531115304 ACCESSION NUMBER: 0001020710-19-000049 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 3 13p-1 1.01 20181231 1.02 20181231 FILED AS OF DATE: 20190531 DATE AS OF CHANGE: 20190531 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: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-21513 FILM NUMBER: 19869318 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 dxp2018formsd.htm SD Document







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)
 
 
 
 
 
 
 
 
5301 Hollister, Houston, Texas
 
77040
 
 
 
 (Address of principal executive officers)
 
(Zip Code)
 
Kent Yee
Senior Vice President & CFO
713-996-4736
(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:

[ ü ] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018.






SECTION 1 - Conflict Minerals Disclosure

Item 1.01    Conflict Minerals Disclosure and Report.

DXP Enterprises, Inc. has included its Conflict Minerals Report (“Report”) as Exhibit 1.01 to its Form SD for the period from January 1, 2018 to December 31, 2018. Unless the context otherwise indicates, “DXP,” “we,” “us” and “our” refer to DXP Enterprises, Inc. and its consolidated subsidiaries.

During 2018, 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
This 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.







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, 2019
By:
   /s/ Kent Yee
Kent Yee
 
 
Senior Vice President & CFO







EXHIBIT INDEX

Exhibit
Number
Description
 
1.01
Conflict Minerals Report for the year ended December 31, 2018 as required by Items 1.01 and 1.02 of this Form.
 
 



EX-1.01 2 dxpenterprisesincconlictmi.htm EXHIBIT 1.01 Exhibit
    EXHIBIT 1.01

DXP Enterprises, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2018

Introduction and Summary

This Conflict Minerals Report (this “Report”) has been prepared by management of DXP Enterprises, Inc. for the period from January 1, 2018 to December 31, 2018 (the “Reporting Period”). Unless the context otherwise indicates, "DXP," "we," "us," the "Company" and "our" mean DXP Enterprises, Inc. and its subsidiaries and directly related entities.

This Report is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). This Rule was adopted by the Securities and Exchange Commission to implement reporting and disclosure requirements pursuant to 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. The Rule defines “Conflict Minerals” as (A) cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are currently limited to tin, tantalum, tungsten and gold (together with gold collectively referred to as “3TGs”); or (B) any other mineral or 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 (“Covered Countries”). The adjoining countries include: the Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola.

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 DRC or in any of the Covered Countries. Therefore, we conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the 3TGs in our products originated from the DRC or any Covered Countries. Based on our RCOI, we believe that our products could contain 3TGs that may have originated in the DRC or the Covered Countries and therefore, in accordance with the Rule, we performed due diligence on the source and chain of custody of the 3TGs in question to determine whether such products are “DRC Conflict Free”, as defined in the Rule. DXP is committed to complying with the requirements of the Rule and upholding responsible sourcing practices.

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 offer a wide range of MRO products, equipment and integrated services, including technical expertise and logistics capabilities, to energy and industrial customers. The Service Centers segment also provides services such as field safety supervision, in-house and field repair and predictive maintenance. The Service Centers provide a wide range of MRO products in the rotating equipment, bearing, power transmission, hose, fluid power, metal working, industrial supply, safety products and safety services categories. The Innovative Pumping Solutions segment provides integrated, custom pump skid packages, pump remanufacturing and manufactures branded private label pumps. The Supply Chain Services segment manages all or part of a customer’s supply chains, including procurement 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

1



and crude oil pipeline service; and air operated diaphragm pumps. We also provide a large variety of pump accessories.

Bearings & Power Transmission. Our bearing products include several types of mounted and unmounted 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 RBA-GeSI Conflict Minerals Reporting Template (“CMRT”), the presence of all 3TGs were claimed by some 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.

Conflict Minerals Program & Policy

DXP has engaged with our customers and suppliers with respect to the use of Conflict Minerals. We adopted a Conflict Minerals Policy articulating our Conflict Minerals supply chain due diligence process.


Description of RCOI

To determine whether necessary 3TGs in our products originated in the DRC or Covered Countries, we retained Assent Compliance (“Assent”), our third party service provider, to assist us in reviewing our supply chain. We provided a list composed of suppliers that could be associated with Covered Products to Assent to upload to the Assent Compliance Manager tool (“ACM”). We determined it impractical to filter the list further to exclude some possibly irrelevant suppliers because we could not determine definitively the presence or absence of Conflict Minerals in all parts supplied to us for our products.

DXP utilized CMRT version 5.11 or higher to conduct a survey of all in scope suppliers. During the supplier survey, we contacted suppliers via the ACM, a SaaS platform provided by Assent that enables users to complete and track supplier communications as well as allow suppliers to upload completed CMRTs directly to the platform for assessment and management. The use of the CMRT allowed for some elimination of irrelevant suppliers.

Assent requested that all suppliers complete a CMRT and included training and education to guide suppliers on best practices and the use of this template. Assent monitored and tracked all communications in the ACM for future reporting and transparency.


2



Our Conflict Minerals program continues to include automated validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify contradictory answers in the CMRT.

All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to submit a valid form. Suppliers are also provided with guidance on how to correct these validations errors. As of May 22, 2019 there were 24 invalid supplier submissions that could not be corrected.

Assent compared the list of smelters and refiners provided in our suppliers’ responses to the list of smelters maintained by the Steering Committee and the Responsible Minerals Initiative (“RMI”) and, if a supplier indicated that a facility was certified as conflict free, confirmed the facility was listed on RMI’s list of validated conflict free smelters and refiners of 3TGs. Our suppliers identified a total 325 smelters and refiners that appear on the lists maintained by RMI. Of those 325 smelters and refiners, 257 are validated as conflict free by RMI or a cross recognized initiative, and, based on information provided by RMI, a further 6 have agreed to undergo or are currently undergoing a third party audit. Most of the CMRTs we received were made on a company or division level basis which did not allow us to identify which smelters or refiners listed by our suppliers actually processed the 3TGs contained in our products.

Based on the RCOI, we have reason to believe that some of the 3TGs may have originated from the DRC or Covered Countries, therefore, in accordance with the Rule, due diligence on the source and chain of custody of the Conflict Minerals in question was performed.

Due Diligence

Design of due diligence

We have designed our due diligence procedures to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflicted-Affected and High-Risk Areas (“the Guidance”) and the related supplements for gold, tin, tantalum and tungsten. The Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We developed our due diligence process to address each of the five steps, namely:

1)
establishing strong company management systems regarding Conflict Minerals;
2)
identifying and assessing risks in our supply chain;
3)
designing and implementing a strategy to respond to identified risks in our supply chain;
4)
utilizing independent third party audits of supply chain diligence; and
5)
publicly reporting on our supply chain due diligence.

We are a downstream supplier, many steps removed from the mining of 3TGs. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. The origin of Conflict Minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted into ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain. In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors. Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the Conflict Minerals contained in the components and materials supplied to us.

 

3




Due Diligence Performed

Establish Strong Company Management Systems

Internal Compliance Team

We have organized a Conflict Minerals committee comprised of individuals in management positions across 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 results of our due diligence.

We also use Assent to assist us with evaluating supply chain information regarding 3TGs, identifying potential risks, and in the development and implementation of additional due diligence steps that we will undertake with suppliers in regards to Conflict Minerals.

Control systems

DXP expects all of its suppliers to have policies and procedures in place to ensure that any 3TGs used in the production of the products sold to us are DRC Conflict Free. This means that the products must not contain 3TGs that directly or indirectly finance or benefit armed groups in the Covered Countries. We rely upon our direct suppliers to provide information on the origin of the 3TGs contained in components and materials supplied to us, including sources of 3TGs that are supplied to us, including sources of 3TGs that are supplied to them from lower tier suppliers.

Our Code of Conduct applies to direct suppliers and outlines expected behaviors and practices. The Code of Conduct is based on industry accepted principles. For third parties doing business with DXP, 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”.

Supplier engagement

DXP engages with suppliers to request that they complete a valid CMRT for the products they supply to us. With respect to the OECD requirement to strengthen engagement with suppliers, we have worked with Assent to develop steps of supplier engagement escalation such as corrective actions. This year we have emphasized supplier education and training. To accomplish this, we have utilized Assent’s online resources and provided suppliers, through Assent, access to Conflict Minerals training and support resources.

We believe that our Conflict Minerals Policy and engagement with suppliers for Conflict Minerals training and other requests constitutes a viable program when it comes to supplier engagement.

Grievance Mechanism

DXP has established grievance mechanisms whereby employees and suppliers can report violations of DXP’s policies, including with respect to Conflict Minerals. Suppliers may contact us anonymously via a dedicated email address that is published in our Conflict Minerals Policy. In addition, our employees may anonymously report suspected violations using the same dedicated email address, dxpe.ethicspoint.com or our anonymous third party conduct help line at (888) 307-4308 as published in our Conflict Minerals Policy.

Maintain records

We have adopted a policy to retain relevant documents with Assent for a period of 5 years. We implemented this policy through Assent to retain Conflict Minerals related documents, including responses to CMRTs. We store all of the information and findings from this process in a database that can be audited by internal and external parties.



4



Identifying and Assessing Risk in the Supply Chain

Due to our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult to identify actors upstream from our direct suppliers. Risks are identified automatically in the ACM tool based on criteria established for supplier responses in the ACM. These risks are addressed by Assent Compliance Supply Chain staff who contact the supplier, gather pertinent data and perform an assessment of the supplier’s Conflict Minerals status.

One risk we identified with respect to the reporting period ended December 31, 2018 related to the nature of the responses received. A large number of the responses received provided data at a company or division level or were unable to specify the smelters or refiners used for the 3TGs in the components supplied to us. Additionally, some suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of smelters or refiners in their supply chain.

In accordance with OECD Guidance, it is important to identify and assess risks associated with Conflict Minerals in the supply chain. Risks were identified by assessing the due diligence practices of smelters and refiners identified in the supply chain by upstream suppliers that listed minerals processing facilities on their CMRT declarations. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the Responsible Minerals Initiative (“RMI”) to ensure that these facilities listed in the response to the list of smelters and refiners maintained by the RMI to ensure that the facilities met the RMI definition of a 3TGs processing facility that was operational during the 2018 calendar year.

In order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard of conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (“RMAP”). We do not typically have a direct relationship with 3TGs smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed a RMAP audit are considered to be DRC Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.

As of May 22, 2019, we have validated 325 smelters or refiners and are working to validate the additional smelter/refiner entries from the submitted CMRTs. Due to the provision of primary supplier level CMRTs, we cannot definitely determine their connection to the Covered Products.

Each facility that meets the RMI definition of a smelter or refiner of a 3TGs mineral is assessed, according to red flag indicators defined in the OECD Guidance. Assent uses numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

1.
Geographic proximity to the DRC and Covered Countries;
2.
Known mineral source country of origin;
3.
RMAP audit status;
4.
Credible evidence of unethical or conflict sourcing; and
5.
Peer assessments conducted by credible third party sources.

As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. Through Assent, submissions that include any red flag facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including the submission of a product specific CMRT to better identify the connection to products that they supply to us and escalating up to removal of these red flag smelters from their supply chain.

As per the OECD 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 the red flags from the supply chain. In addition, the 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.


5



Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on these four questions in the CMRT:

A. Have you established a Conflict Minerals sourcing policy?
E. Have you implemented due diligence measures for conflict-free sourcing?
G. Do you review due diligence information received from your suppliers against your company’s expectations?
H. Does your review process include corrective action management?

When suppliers meet or exceed those criteria (Yes to at least A, E, G and H) they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program. At this time 53 of our responsive suppliers have been identified as having a weak program.


Design and Implement a Strategy to Respond to Risks

Together with Assent, we developed processes to assess and respond to the risks identified in our supply chain. In response to this risk assessment, we have a risk management plan, through which our Conflict Minerals program is implemented, managed and monitored. As the program progresses, escalations are sent to non-responsive suppliers to outline the importance of a response via CMRTs and to outline the required cooperation for compliance to the Conflict Minerals rules.

We will engage any of our suppliers whom we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD Guidance.

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 any 3TGs smelters or refiners and do not perform or direct audits of these entities within our supply chain. Instead, we rely upon third party audits of smelters and refiners conducted as part of RMAP, which uses independent private sector auditors to audit the source, including mines of origin, and the chain of custody of the Conflict Minerals used by smelters and refiners that agree to participate in the program.

Assent also directly contacts smelters and refiners that are not currently enrolled in RAMP to encourage their participation and gather information regarding each facilities’ sourcing practices on behalf of its compliance partners.

Public Reporting on Supply Chain Due Diligence

We have published our Form SD for the year ended December 31, 2018 and this Report 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. Information found on or accessed through our website is not considered part of this Report and is not incorporated herein by reference. We have also publicly filed our Form SD and this Report with the Securities and Exchange Commission.

Due Diligence Results

Survey results

For the 2018 reporting year, DXP received CMRT forms from 455 suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. Twenty-four suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions.


6



Smelters and Refiners

Attached as Appendix A is a list of all of the smelters and refiners listed by our suppliers in their completed CMRTs that appear on the lists of smelters maintained by the RMI. Since many of the CMRTs we received from our suppliers were made on a company or division level basis, rather than on a product level basis, we are not able to identify which smelters or refiners listed on Appendix A actually processed the 3TGs contained in our products. Therefore, our list of processing smelters and refiners disclosed in Appendix A may contain more facilities than those that actually processed the Conflict Minerals contain in our products.

From the responses that we received, we identified 6 smelters that potentially posed a risk due to the presence of some red flag indicators. For suppliers that identified these specific smelters of concern on their CMRT, we created a new escalation plan. These suppliers were contacted by Assent to evaluate whether or not these smelters could be connected to DXP’s products. The suppliers were asked to complete a product level CMRT, rather than a company level CMRT, to better identify the connection to products that they supply to us.

Countries of Origin

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 suppliers and the RMI. As mentioned in the above section, many responses were provided at the company level, therefore, Appendix B may contain more countries than those that our products are being sourced from.

Steps to be Taken to Mitigate Risk

From the filing date of this Report with the Securities and Exchange Commission, we will take or intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the DRC and the Covered Countries.

We are committed to complying with the provisions of the Rule and Form SD and we 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 that could benefit armed groups in the DRC or Covered Countries. These may include, but are not limited to the following:

Work more closely with Assent to obtain CMRTs on a product specific basis to enable us to determine which smelters and refiners actually process 3TGs contain in our Covered Products;
Engage with our suppliers more closely and provide suppliers with Assent’s assistance to obtain more information and training resources regarding responsible sourcing of 3TGs;
Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers; and
With Assent’s assistance increase the emphasis on clean and validated smelter and refiner information from our supply chain as the list of DRC Conflict Free smelters and refiners grows and more smelters and refiners declare their intent to enroll in the program.

7

EX-1.01 3 appendixaandb5-29x2019.htm EXHIBIT 1.01 Exhibit



Appendix A:


Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
8853 S.p.A.
ITALY
CID002763
Gold
Abington Reldan Metals, LLC
UNITED STATES
CID002708
Gold
Advanced Chemical Company
UNITED STATES
CID000015
Gold
African Gold Refinery
UGANDA
CID003185
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangalore Refinery
INDIA
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
Caridad
MEXICO
CID000180
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Cendres + Métaux S.A.
SWITZERLAND
CID000189
Gold
CGR Metalloys Pvt Ltd.
INDIA
CID003382
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
Chugai Mining
JAPAN
CID000264
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
CID003348
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Gold
Fujairah Gold FZE
UNITED ARAB EMIRATES
CID002584
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852

1




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
Geib Refining Corporation
UNITED STATES
CID002459
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
HeeSung
KOREA, REPUBLIC OF
CID000689
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID000773
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
CID002562
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Italpreziosi
ITALY
CID002765
Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Gold
Marsam Metals
BRAZIL
CID002606
Gold
Materion
UNITED STATES
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149

2




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation
UNITED STATES
CID001157
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Gold
Morris and Watson
NEW ZEALAND
CID002282
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID002866
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
CID001220
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Pease & Curren
UNITED STATES
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Précinox S.A.
SWITZERLAND
CID001498
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID003324
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Gold
Remondis Argentia B.V.
NETHERLANDS
CID002582
Gold
Republic Metals Corporation
UNITED STATES
CID002510
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
SAAMP
FRANCE
CID002761
Gold
Sabin Metal Corp.
UNITED STATES
CID001546
Gold
Safimet S.p.A
Italy
CID002973
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Gold
Sai Refinery
INDIA
CID002853
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
SEMPSA Joyería Platería S.A.
SPAIN
CID001585
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619

3




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Shangdong Humon Smelting Co., Ltd.
CHINA
CID002525
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.
TAIWAN
CID001761
Gold
Sovereign Metals
INDIA
CID003383
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Gold
Sudan Gold Refinery
SUDAN
CID002567
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
SungEel HiTech
KOREA, REPUBLIC OF
CID002918
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Gold
Tony Goetz NV
BELGIUM
CID002587
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
United Precious Metal Refining, Inc.
UNITED STATES
CID001993
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
CID002854
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
CID003402
Tantalum
D Block Metals, LLC
UNITED STATES
CID002504
Tantalum
Exotech Inc.
UNITED STATES
CID000456
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
CID002557
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291

4




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID003191
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Tantalum
KEMET Blue Powder
UNITED STATES
CID002568
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Tantalum
Power Resources Ltd.
MACEDONIA
CID002847
Tantalum
QuantumClean
UNITED STATES
CID001508
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
CID001522
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemicals
JAPAN
CID001869
Tantalum
Telex Metals
UNITED STATES
CID001891
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Tin
Alpha
UNITED STATES
CID000292
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
CV Ayi Jaya
INDONESIA
CID002570
Tin
CV Dua Sekawan
INDONESIA
CID002592
Tin
CV Gita Pesona
INDONESIA
CID000306
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Tin
CV United Smelting
INDONESIA
CID000315
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
CID003356

5




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Tin
Dowa
JAPAN
CID000402
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Tin
EM Vinto
BOLIVIA
CID000438
Tin
Estanho de Rondônia S.A.
BRAZIL
CID000448
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
CID003410
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgical S.A.
BOLIVIA
CID001337
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Tin
PT Babel Surya Alam Lestari
INDONESIA
CID001406
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Tin
PT Bangka Serumpun
INDONESIA
CID003205
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Tin
PT Bukit Timah
INDONESIA
CID001428
Tin
PT DS Jaya Abadi
INDONESIA
CID001434

6




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Tin
PT Rajawali Rimba Perkasa
INDONESIA
CID003381
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Tin
PT Tirus Putra Mandiri
INDONESIA
CID002478
Tin
PT Tommy Utama
INDONESIA
CID001493
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Super Ligas
Brazil
CID002756
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID002834
Tin
Thaisarco
THAILAND
CID001898
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID003325
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000281
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
CID002536
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541

7




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
Kennametal Fallon
UNITED STATES
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
CID002845
Tungsten
Niagara Refining LLC
UNITED STATES
CID002589
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
CID002044
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095


Appendix B:

Argentina
Eritrea
Mauritania
Slovakia
Botswana
Honduras
Nicaragua
Tanzania
Brazil
India
Niger
Thailand
Burkina Faso
Indonesia
Nigeria
Togo
Canada
Ivory Coast
Peru
Uganda
Colombia
Kyrgyzstan
Puerto Rico
United States of America
Congo, Democratic Republic of the
Laos
Russian Federation
Uruguay
Cyprus
Lebanon
Rwanda
Uzbekistan
Dominican Republic
Madagascar
Saudi Arabia
Venezuela

8