EX-1.01 2 eslt2019sdexhibit101.htm EXHIBIT 1.01 Exhibit



Exhibit 1.01

Elbit Systems Ltd.
Conflict Minerals Report
For the Year Ended December 31, 2018
In Accordance with Rule 13p-1 under the Securities Exchange Act of 1934

A. Introduction

This Conflict Minerals Report (this “Report”) of Elbit Systems Ltd. (together with its subsidiaries, “Elbit Systems” or “we”) for the year ended December 31, 2018 is presented to comply with Rule 13p-1 (the “CM Rule”) under the Securities Exchange Act of 1934.
The CM Rule was adopted by the U.S. Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to “conflict minerals” under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Pursuant to Section 1502, publicly traded companies, such as Elbit Systems, must report to the SEC whether “conflict minerals” (tantalum, tin, tungsten and gold) (“3TG”) originating in the Democratic Republic of Congo (“DRC”) or adjoining countries (Angola, Burundi, The Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia) (the “Covered Countries”) are present in the products the company manufactures or contracts to manufacture, if any of the 3TG is necessary to the functionality or production of such products. The CM Rule was adopted because the sale of 3TG mined in the Covered Countries has funded armed conflicts in that region, and those conflicts have led to numerous human rights abuses and atrocities.
Unless otherwise defined herein, the terms used in this Report have the meanings ascribed to them in the CM Rule, Form SD and SEC Release No. 34-67716 issued by the SEC in 2012.
B. Company Overview

Elbit Systems Ltd. is an international high technology company engaged in a wide range of defense, homeland security and commercial programs throughout the world. We operate in the areas of aerospace, land and naval systems, command, control, communications, computers, intelligence surveillance and reconnaissance, unmanned aircraft systems, advanced electro-optics, electro-optic space systems, electronic warfare suites, signal intelligence systems, data links and communications systems, radios, cyber-based systems and munitions. We also focus on the upgrading of existing platforms, developing new technologies for defense, homeland security and commercial applications and providing a range of support services, including training and simulation systems.

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C. Applicability of the CM Rule to Elbit Systems
Elbit Systems designs, develops and manufactures a broad portfolio of sophisticated products and systems in numerous programs for our customers around the world. Such products and systems often include a range of electronic components. We purchase these components from a supply chain consisting of thousands of suppliers and/or manufacturers. We collect 3TG information from our suppliers, primarily first-tier manufacturers (i.e., manufacturers contracting directly with us) of the products or components supplied to us. Through this information and our own material engineering analyses we have determined 3TG are necessary to the functionality or production of a number of our products. Therefore, we are required to make a filing pursuant to the CM Rule because we manufacture certain products for which elements of 3TG are necessary to the product’s functionality or production.

We do not directly source any 3TG from mines, smelters or refiners, and we believe that in most cases we are many levels removed from these supply chain participants and therefore have limited influence over them. Furthermore, because of the depth, geographic diversity and ongoing changes in our supply chain, and due to competitive factors, we often have significant challenges in identifying the full supply chain from information provided by our direct suppliers. However, through the efforts described in this Report, we take measures so that our suppliers meet the expectations of our Conflict Minerals Compliance Policy, which is described below.

D. Conflict Minerals Compliance Policy

Elbit Systems’ policy is to use “conflict free” 3TG in our products, and we support industry actions to increase supply chain transparency to facilitate the ability of companies to source conflict free 3TG. Our Conflict Minerals Compliance Policy is published on our website www.elbitsystems.com under “About Us - Ethics and Conduct - Conflict Minerals Compliance Policy.”

Pursuant to our Conflict Minerals Compliance Policy, and as further described in this Report, we are taking measures to meet the applicable reporting obligations under the CM Rule and to enhance our supply chain due diligence and internal controls relating to 3TG. We are committed to sourcing materials from companies that share our values with respect to human rights, ethics and environmental responsibility. These supply chain values are reflected in our Supplier Code of Conduct, which can be found on our website www.elbitsystems.com under “About Us - Ethics and Conduct - Supplier Code of Conduct.” Our policy relating to conflict minerals is an important part of our overall practices regarding responsible supply chain management and is reflected in our Supplier Code of Conduct.

Elbit Systems periodically publishes additional information about our commitment to responsible sourcing and engagement with our suppliers and other stakeholders in our Social Sustainability Report, which includes an overview of our activities in the areas of ethics,

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corporate governance, environmental compliance, fair employment and support for our local communities. The Social Sustainability Report is published on our website www.elbitsystems.com under “About Us - Social Sustainability.”

E.
Overview of the Company’s Conflict Minerals Program and Reasonable Country of Origin Inquiry (“RCOI”) for 2018

As part of our commitment to responsible sourcing, human rights and sustainability, it is our goal that the 3TG in our products should not, directly or indirectly, finance or benefit armed groups in the Covered Countries. Our efforts with respect to 3TG are aligned to the work of the Responsible Minerals Initiative (“RMI”) (formerly the Conflict Free Sourcing Initiative), and we strive to improve the traceability in our supply chain.
Elbit Systems has a Conflict Minerals Compliance and Management Review Team (the “CM Team”) that supports compliance with the CM Rule, performs the RCOI and reports on conflict minerals. The multi-disciplinary CM Team consists of specially designated personnel from our purchasing, quality assurance, operations, materials engineering, information technology, finance and legal departments. The CM Team is supported by outsourced services from specialists in the conflict minerals compliance and RCOI process.
We rely on our suppliers to provide information on the origin of 3TG contained in components and parts included in our products. The identification of suppliers that are relevant to us under the CM Rule involves different geographic regions, business areas and production sites throughout our organization. The CM Team plays a leading role in coordinating the supplier identification efforts. Suppliers who were identified in 2018 to be relevant for our RCOI process were identified on the basis of criteria such as the level of purchasing activities with such supplier and the likelihood that the items furnished by the supplier contain 3TG. The processes performed and described in this Report cover more than 95% of our worldwide supply chain activities relevant to 3TG.
In our annual RCOI process for 2018, we reviewed suppliers identified to be relevant under the above-mentioned identification criteria in an effort to determine the origin of the 3TG in our products. We analyzed and followed up with inquiries as we deemed appropriate where the analysis of our survey results indicated further information may be desirable. We do not have a direct relationship with 3TG smelters and refiners, and we do not perform or direct audits of these entities within our supply chain.
We utilized reporting templates and databases, such as approved smelter and refiner lists, of 3TG industry initiatives such as the RMI, which is aligned with the Global e-Sustainability Initiative (GeSI) and the Electronic Industry Citizenship Coalition (EICC).

F. Conflict Minerals Program Design
Our RCOI activities and other 3TG-related activities are consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and

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High-Risk Areas and the related Supplements for gold and for tin, tantalum and tungsten (the “OECD Guidance”). The design of our due diligence process, including our RCOI, conforms substantially to the OECD Guidance as it relates to “downstream” purchasers of products and components. These processes are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.

Step 1 - Establish Strong Company Management Systems
As mentioned above, we have a dedicated CM Team. This Team is responsible for implementing our due diligence activities, reporting on 3TG in compliance with the CM Rule and informing senior managers and our board of directors about matters relating to our conflict minerals compliance. Our compliance policies include, but are not limited to, our Code of Business Conduct and Ethics and our Supplier Code of Conduct, which set forth expected behavior for all our employees and suppliers. The Supplier Code of Conduct includes provisions relating to conflict minerals compliance and is integrated as a standard supplement into our supplier agreements.
We have internal Conflict Minerals Compliance Guidelines that set out the activities to be taken in our due diligence process. As a result of our periodic review of our processes, updates to those Guidelines were made in 2018. Moreover, as indicated above, we have a published company-wide Conflict Minerals Compliance Policy, for which an update was also issued in 2018. Such updates reflect enhancements to our processes and ongoing compliance benchmarking activities.
In 2018, identification of smelters and refiners in our supply chain was made through the use of due diligence tools, including those created by the RMI such as the EICC/GeSI Conflict Minerals Reporting Template (the “Template”). The Template is a supply chain survey designed to identify, among other 3TG-related information, the smelters and refiners that process the necessary 3TG contained in our supply chain. The information from our suppliers, in combination with information from the RMI, helps us to obtain information on the origin of the 3TG processed in our supply chain. Data obtained was reviewed and analyzed by us and is retained in our company records for the five-year period required by the CM Rule.
While our principal purchasing activities were conducted through our facilities in Israel and the U.S., during 2018 our activities also included 3TG compliance processes at our subsidiaries located in other countries, including RCOI and training activities. IMI Systems Ltd., an Israeli subsidiary that was acquired in November 2018, was not included in our 2018 RCOI activities.
We have grievance mechanisms under which employees and suppliers can report violations of our policies. This includes a whistleblower process for the reporting of alleged violations of laws or our Code of Business Conduct and Ethics, including issues relating to corruption, involving questionable accounting or auditing matters or which otherwise may seriously affect significant interests of Elbit Systems. This process is overseen by Elbit Systems Chief Compliance Officer and by the Chair of the Audit Committee of Elbit Systems Board of Directors. Our Conflict Minerals Compliance Policy and our Supplier Code of Conduct

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also contain reporting mechanisms for reports to applicable Elbit Systems’ management personnel.

Step 2 - Identification and Assessment of Risks in the Supply Chain
Our CM Team leads a process to identify and assess 3TG-related risks. We attempt to focus this process on the most relevant level in our 3TG supply chain, which is the smelters and refiners. As stated above, we require our suppliers to provide identification information relating to smelters and refiners in our supply chain.
During 2018, suppliers meeting our applicable 3TG criteria were requested by us to provide information on 3TG in their supply chains through completing and submitting the Template. Suppliers were provided with support material, including the generally available RMI instructions and training illustrating the use of the tool that is available on RMI’s website. To support the quality of the response and a high response rate, the responses received were analyzed on an ongoing basis and followed up as deemed appropriate by members of the CM Team. Supplier responses were reviewed against risk level criteria developed or utilized by us to determine: (1) the risk level applicable to the supplier regarding 3TG and (2) which responses require further engagement with our suppliers, such as when the responses from suppliers were incomplete. Suppliers were contacted via e-mail or telephone to improve the quality of responses and increase the response rate.

Step 3 - Design and Implementation of a Strategy to Respond to Identified Risks
Under the third step of the OECD Guidance framework companies are encouraged to design and implement a strategy to respond to identified risks. Our due diligence is an ongoing process, both proactive and reactive, where suppliers are evaluated against our conflict mineral risk categories on a continuous basis to facilitate conflict mineral compliance in the suppliers’ processes.
Our due diligence process categorizes suppliers’ responses regarding 3TG under one of the following six conflict mineral risk categories (“DRC or an adjoining country” has the same meaning in this context as “Covered Countries”):
1.
Free/No 3TG - 3TG is not intentionally added to the product and not necessary to the production of the product.
2.
Free/Not From DRC - The 3TG being used in the product do not originate from the DRC or an adjoining country.
3.
DRC/Conflict Free - The 3TG being used in the product originate from the DRC or an adjoining country; however, the smelters and refiners have been designated as “conformant” (formerly “complaint”) or “active” by the RMI under its Responsible Minerals Assurance Process (“RMAP”).
4.
Undetermined/Not from DRC - The 3TG being used in the product do not originate from the DRC or an adjoining country, but to date the supplier has not provided complete information on all of its sources of supply.
5.
Undetermined/from DRC - The 3TG being used in the product originate from the DRC or an adjoining country; however, the smelters and refiners have been designated

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as conformant or active under the RMAP, and to date the supplier has not provided complete information on all of its sources of supply.
6.
Undefined from DRC - The 3TG being used in the product originate from the DRC or an adjoining country, and the smelters and refiners have not been designated as conformant or active under the RMAP.
During 2018, we used this risk-based approach and followed up with suppliers.
We continuously worked to improve our due diligence processes with respect to 3TG, mainly focusing on the quality of data received from suppliers surveyed. This included communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. It also included follow-up communications with suppliers regarding RCOI issues.

Step 4 - Carry Out Independent Third Party Audit of Supply Chain Due Diligence and Identification Points in the Supply Chain
In the fourth step we focus on review of smelters’ and refiners’ 3TG practices. Since, as mentioned above, there are generally many tiers of suppliers between Elbit Systems and the smelters and refiners in the supply chain, we have not performed our own audits of smelters or refiners.
During 2018, we reviewed the data received from our suppliers with respect to smelters and refiners and compared such information against the lists of facilities that have received either an “active” or “conformant” designation from the RMI or otherwise appeared on the RMI’s Smelter Reference List.
Although we are not currently required to conduct an Independent Private Sector Audit under the CM Rule, during 2018 we continued to take steps, such as enhancing our internal controls, to prepare us for such an audit in the future, if applicable.
 
Step 5 - Report on Supply Chain Due Diligence
In compliance with the fifth step of reporting on supply chain due diligence, and in accordance with the CM Rule, during 2018 we continued to make our Conflict Minerals Report available on our website: www.elbitsystems.com under “Investors Relations - SEC Filings.”

G. 2018 Conflict Minerals Program Results
For the calendar year 2018, our due diligence was conducted at the supplier level, mainly first-tier manufacturers. The response rate among suppliers surveyed in 2018 was above 75%. Among the supplier responses, we identified 311 smelters or refiners as potential sources of 3TG that were reported to be in the supply chain through the end of the 2018 calendar year, that were designated by RMI as active or conformant or otherwise appeared on the RMI’s Smelter Reference List.

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We believe that the facilities that may have been used to process the 3TG in Elbit Systems’ products in 2018 include the smelters and refiners listed in Annex 1 hereto. There were also a few additional potential high risk smelters for which we continued our RCOI review.

H. Future Activities
We are continuing to refine and expand the list of participating smelters and refiners. We believe that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the locations of origin of the 3TG in our supply chain.
During 2019, we plan to continue to review and evolve our due diligence and RCOI processes with respect to 3TG. During 2019 we expect to: (1) evaluate possible further updates of our Conflict Mineral Compliance Policy and Guidelines; (2) continue to follow-up on incomplete or unreceived responses from suppliers including with regard to identified smelters and refiners who do not appear on RMI’s active or conformant smelters and refiners lists; (3) further develop the collaboration with suppliers for purposes of continued improvement of the supplier response rate and the reliability and quality of information provided; (4) further refine the criteria for our due diligence and supplier selection processes; (5) further enhance our internal control processes and activities; (6) expand our awareness and training activities; (7) implement the RCOI process with respect to recently acquired subsidiaries in Israel and the U.S.; and (8) further expand our RCOI activities to parts of our organization that are outside Israel and the U.S.

I. Forward Looking Statements
Certain of the matters discussed in this Report, including in particular our due diligence processes, include forward-looking statements. Readers of this Report are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of anticipated events.
The information included on our website and other materials referenced in this Report is not incorporated by reference in this Report.


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Annex 1

List of Smelters and Refiners

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

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CID002852
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002459
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002243
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID001909
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID002312
Gold
Guangdong Jinding Gold Limited
CHINA
CID000651
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000671
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000689
Gold
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
CID000694
Gold
Heimerle + Meule GmbH
GERMANY
CID000707
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000711
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000767
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000773
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID000778
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000801
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID002562
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
CID000807
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000814
Gold
Istanbul Gold Refinery
TURKEY
CID002765
Gold
Italpreziosi
ITALY
CID000823
Gold
Japan Mint
JAPAN
CID000855
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000927
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000929
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000937
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID002563
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID000956
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000957
Gold
Kazzinc
KAZAKHSTAN
CID000969
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID002511
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID000981
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID002605
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID001029
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID002865
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID001032
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001056
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001058
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID002762
Gold
L'Orfebre S.A.
ANDORRA
CID001078
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001093
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID002606
Gold
Marsam Metals
BRAZIL
CID001113
Gold
Materion
UNITED STATES OF AMERICA

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CID001119
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001149
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001152
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001147
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001153
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001157
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001161
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001188
Gold
Mitsubishi Materials Corporation
JAPAN
CID001193
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID002509
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002857
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002282
Gold
Morris and Watson
NEW ZEALAND
CID002866
Gold
Morris and Watson Gold Coast
AUSTRALIA
CID001204
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001220
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001236
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID003189
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID001259
Gold
Nihon Material Co., Ltd.
JAPAN
CID002779
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID001325
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001326
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID000493
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID001352
Gold
PAMP S.A.
SWITZERLAND
CID002872
Gold
Pease & Curren
UNITED STATES OF AMERICA
CID001362
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID002919
Gold
Planta Recuperadora de Metales SpA
CHILE
CID001386
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001397
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001498
Gold
PX Precinox S.A.
SWITZERLAND
CID003324
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID001512
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID000522
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID002582
Gold
REMONDIS PMR B.V.
NETHERLANDS
CID001534
Gold
Royal Canadian Mint
CANADA
CID002761
Gold
SAAMP
FRANCE
CID001546
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
CID002973
Gold
Safimet S.p.A
ITALY
CID002290
Gold
SAFINA A.S.
CZECHIA
CID002853
Gold
Sai Refinery
INDIA
CID001555
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001562
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF

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CID002777
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID001585
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID002525
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
CID001619
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001622
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001736
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID002516
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID001756
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001761
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID003153
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID001798
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID002918
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002580
Gold
T.C.A S.p.A
ITALY
CID001875
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001916
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001938
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001947
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID002587
Gold
Tony Goetz NV
BELGIUM
CID002615
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID001955
Gold
Torecom
KOREA, REPUBLIC OF
CID001977
Gold
Umicore Brasil Ltda.
BRAZIL
CID002314
Gold
Umicore Precious Metals Thailand
THAILAND
CID001980
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001993
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID002003
Gold
Valcambi S.A.
SWITZERLAND
CID002030
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002778
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002100
Gold
Yamakin Co., Ltd.
JAPAN
CID002129
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID000197
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID002224
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002763
Gold
8853 S.p.A.
ITALY
CID000092
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000211
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID002504
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID000456
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000460
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID002505
Tantalum
FIR Metals & Resource Ltd.
CHINA

11


CID002558
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002557
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID000291
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000616
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID002544
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002547
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002548
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002549
Tantalum
H.C. Starck Ltd.
JAPAN
CID002550
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002545
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002492
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002512
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002842
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID003191
Tantalum
Jiujiang Janny New Material Co., Ltd.
CHINA
CID000914
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID002506
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002539
Tantalum
KEMET Blue Metals
MEXICO
CID002568
Tantalum
KEMET Blue Powder
UNITED STATES OF AMERICA
CID001076
Tantalum
LSM Brasil S.A.
BRAZIL
CID001163
Tantalum
Metallurgical Products India Pvt. Ltd. (MPIL)
INDIA
CID001175
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001192
Tantalum
Mitsui Mining & Smelting
JAPAN
CID001277
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001200
Tantalum
NPM Silmet AS
ESTONIA
CID002847
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
CID001508
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID002707
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID001522
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001769
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001869
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001891
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID001969
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID002508
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID000292
Tin
Alpha
UNITED STATES OF AMERICA
CID002703
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID000228
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID003190
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID001070
Tin
China Tin Group Co., Ltd.
CHINA

12


CID002570
Tin
CV Ayi Jaya
INDONESIA
CID002592
Tin
CV Dua Sekawan
INDONESIA
CID000306
Tin
CV Gita Pesona
INDONESIA
CID000315
Tin
CV United Smelting
INDONESIA
CID002455
Tin
CV Venus Inti Perkasa
INDONESIA
CID000402
Tin
Dowa
JAPAN
CID002572
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID000438
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000448
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000468
Tin
Fenix Metals
POLAND
CID002848
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID000942
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000538
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID001908
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID000555
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID003116
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID002849
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002844
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID000760
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID001482
Tin
INDONESIAN STATE TIN CORPORATION MENTOK SMELTER
INDONESIA
CID001231
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID002468
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID001105
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID002500
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID001142
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID002773
Tin
Metallo Belgium N.V.
BELGIUM
CID002774
Tin
Metallo Spain S.L.U.
SPAIN
CID001173
Tin
Mineracao Taboca S.A.
BRAZIL
CID001182
Tin
Minsur
PERU
CID001191
Tin
Mitsubishi Materials Corporation
JAPAN
CID002858
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002573
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID001314
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID002517
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID001337
Tin
OMSA
BOLIVIA (PLURINATIONAL STATE OF)
CID003208
Tin
Pongpipat Company Limited
MYANMAR
CID000309
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID001399
Tin
PT Artha Cipta Langgeng
INDONESIA
CID002503
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID001402
Tin
PT Babel Inti Perkasa
INDONESIA
CID001406
Tin
PT Babel Surya Alam Lestari
INDONESIA
CID002776
Tin
PT Bangka Prima Tin
INDONESIA

13


CID003205
Tin
PT Bangka Serumpun
INDONESIA
CID001419
Tin
PT Bangka Tin Industry
INDONESIA
CID001421
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001428
Tin
PT Bukit Timah
INDONESIA
CID001434
Tin
PT DS Jaya Abadi
INDONESIA
CID002530
Tin
PT Inti Stania Prima
INDONESIA
CID001448
Tin
PT Karimun Mining
INDONESIA
CID002829
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002835
Tin
PT Menara Cipta Mulia
INDONESIA
CID001453
Tin
PT Mitra Stania Prima
INDONESIA
CID001457
Tin
PT Panca Mega Persada
INDONESIA
CID000313
Tin
PT Premium Tin Indonesia
INDONESIA
CID001458
Tin
PT Prima Timah Utama
INDONESIA
CID002593
Tin
PT Rajehan Ariq
INDONESIA
CID001460
Tin
PT Refined Bangka Tin
INDONESIA
CID001463
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001468
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID002816
Tin
PT Sukses Inti Makmur
INDONESIA
CID001471
Tin
PT Sumber Jaya Indah
INDONESIA
CID001477
Tin
PT Tambang Timah
INDONESIA
CID001490
Tin
PT Tinindo Inter Nusa
INDONESIA
CID002478
Tin
PT Tirus Putra Mandiri
INDONESIA
CID001493
Tin
PT Tommy Utama
INDONESIA
CID002706
Tin
Resind Ind e Com Ltda.
BRAZIL
CID001539
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001758
Tin
Soft Metais Ltda.
BRAZIL
CID002756
Tin
Super Ligas
BRAZIL
CID002834
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID001898
Tin
Thaisarco
THAILAND
CID003325
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID002574
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002036
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002158
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002180
Tin
Yunnan Tin Company Limited
CHINA
CID000004
Tungsten
A.L.M.T. Corp.
JAPAN
CID002833
Tungsten
ACL Metais Eireli
BRAZIL
CID002513
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID000258
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002494
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA

14


CID000568
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000218
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID002542
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002541
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID000766
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID002579
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID000769
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID003182
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID002649
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID000825
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID002551
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002316
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID000966
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000105
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID002319
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002543
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002845
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002589
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002827
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002815
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID001889
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID002724
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002044
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002843
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002320
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002082
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002830
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002095
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA




15