UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
NOVANTA INC.
(Exact name of registrant as specified in its charter)
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New Brunswick, Canada |
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001-35083 |
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98-0110412 |
(State or other jurisdiction of incorporation or organization) |
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(Commission File Number) |
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(IRS Employer Identification No.) |
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125 Middlesex Turnpike Bedford, Massachusetts, USA |
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01730 |
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(Address of principal executive offices) |
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(Zip Code) |
Matthijs Glastra, Chief Executive Officer, (781) 266-5700
(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:
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Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period January 1 to December 31, 2020 |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Novanta Inc. has filed a Conflict Minerals Report herewith as Exhibit 1.01 to this Form SD pursuant to Rule 13p-1 for the period January 1 to December 31, 2020.
A copy of the Company’s Conflict Minerals Report for the period January 1 to December 31, 2020 is also publicly available at www.novanta.com/about-us/corporate-citizenship/.
Item 1.02 Exhibit
The Company has filed, as Exhibit 1.01 to this Form SD, the Conflict Minerals Report as required by Item 1.01 of this Form.
Section 2 - Exhibits
Item 2.01 Exhibits
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.
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Novanta Inc. |
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(Registrant) |
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Date: May 28, 2021 |
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By: |
/s/ Matthijs Glastra |
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Matthijs Glastra |
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Chief Executive Officer |
Exhibit 1.01
NOVANTA INC.
Conflict Minerals Report
For the Period January 1 to December 31, 2020
Introduction
This report has been prepared by Novanta Inc. (“Novanta,” the “Company,” “we,” or “our”) for the period from January 1, 2020 to December 31, 2020 (the “Reporting Period”) in accordance with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, which was adopted by the Securities and Exchange Commission (the “SEC”) to implement the reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”).
The term “conflict minerals” is defined as cassiterite, columbite-tantalite, wolframite, gold, and their derivatives, which are currently limited to tin, tantalum, tungsten, and gold (“the 3TGs”) for the purposes of this report. The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain 3TGs that are necessary to the functionality or production of their products.
The Company conducted an analysis of its products and found that 3TGs are present in many of the electronic parts and components included in the Company’s products. Therefore, the Company is subject to the reporting obligations of Rule 13p-1.
The Company’s supply chain is complex. The Company uses a wide variety of raw materials, key components and parts that are purchased from both domestic and international suppliers. The Company also uses contract manufacturers to make certain key components used in the production of the Company’s finished products. As the Company’s manufacturing process consists mostly of final assembly of components and parts that are purchased from suppliers, there are typically several tiers of companies between Novanta and the mines, smelters or refiners of conflict minerals. The Company does not directly source 3TG minerals as raw materials.
Due to the size and complexity of the Company’s supply chain, Novanta has to rely on its suppliers to provide information on the origin of the conflict minerals contained in the components and materials supplied to Novanta, including sources of conflict minerals present in the raw materials and components supplied to Novanta’s suppliers themselves.
Company Overview and Products Covered by This Report
Novanta is a global supplier of core technology solutions that give medical and advanced industrial Original Equipment Manufacturers (“OEMs”) a competitive advantage. We combine deep proprietary technology expertise and competencies in photonics, vision and precision motion with a proven ability to solve complex technical challenges. This enables Novanta to engineer core components and sub-systems that deliver extreme precision and performance, tailored to our customers’ demanding applications.
The Company is organized into three reportable segments: Photonics, Vision and Precision Motion. The Photonics segment designs, manufactures and markets photonics-based solutions, including CO2 lasers, diode-pumped solid state lasers and ultrafast lasers, galvanometer and polygon-based optical scanning components and scan heads, and optical light engines. The Vision segment designs, manufactures and markets a wide range of medical grade technologies, including insufflators, pumps, light sources and video couplers, gamma probes, and related accessories and consumables for minimally invasive surgery, high definition 4K and 4K-3D visualization solutions, video processing, streaming and capture products and wireless video signal transmission devices for surgical applications, embedded capacitive and resistive touch panel technology, camera-based machine vision products and solutions, RFID technologies, embedded and handheld data collection products for barcode scanning, rugged thermal chart recorders, and light and color measurement devices. The Precision Motion segment designs, manufactures and markets optical and inductive encoders, direct drive motor components, servo drives and control software, integrated motion sub-assemblies, high-speed and precision air bearings and air bearing spindles.
Reasonable Country of Origin Inquiry
The Company conducted a good faith reasonable country of origin inquiry (“RCOI”) regarding the 3TG minerals necessary to the functionality or production of our products. Our RCOI was reasonably designed to determine whether such conflict minerals originated in the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, or Zambia (collectively, the “Covered Countries”) or came from scrap or recycled sources. The Company began the scoping process by compiling a list of all suppliers that provide us with products that may contain any 3TGs. Once this list was compiled, we provided the list and the applicable supplier contact information to our third-party supply chain compliance service provider (the “Service Provider”). This list was then uploaded to the Service Provider’s software platform that allows us to store and manage supplier requests, documentation, and related data.
Utilizing the Conflict-Free Sourcing Initiative’s Conflict Minerals Reporting Template (the “CMRT”), we surveyed the suppliers on their sourcing of the 3TGs that may have been used in the materials that were supplied to the Company. The CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide conflict minerals 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.
The RCOI began with an introductory email from Novanta to suppliers describing the Conflict Minerals Compliance Program (“CMCP”) requirements and identifying the Service Provider as a partner in the process. Following that introductory email, the Service Provider sent a subsequent email to the suppliers containing a registration and survey request link for the on-line data collection platform. Up to five reminder emails were sent by the Service Provider to each non-responsive supplier requesting survey completion. If, after these efforts, a given supplier still did not register with the system or provide the information requested, an escalation process was initiated. The escalation process consisted of direct outreach by Novanta supply chain personnel who contacted these suppliers by email to request their participation in the program.
Suppliers were asked to provide information regarding the sourcing of their conflict minerals with the ultimate goal of identifying the 3TG smelters or refiners (“SORs”) and the associated mine countries of origin. Suppliers who had already performed a RCOI through the use of the CMRT (version 4.0 or above) were asked to upload this document into the Service Provider system or to provide this information in the online survey version. Suppliers had the option of providing information at a level with which they were most comfortable, i.e., company, product or user-defined level, but the declaration scope had to be specified in the CMRT. Suppliers were requested to provide an electronic signature before submitting their data to verify that all answers submitted were accurate to the best of the supplier’s knowledge but the suppliers were not required to provide an electronic signature to submit their data.
Quality Assurance
Supplier responses were evaluated by the Service Provider for plausibility, consistency, and gaps. If any of the following “quality control” (QC) flags were raised, suppliers were automatically contacted by the Service Provider on a bi-weekly basis up to three times:
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One or more SORs were listed for an unused metal; |
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SOR information was not provided for a used metal, or SOR information provided was not a verified metal processor; |
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Supplier answered yes to sourcing from the Covered Countries, but none of the SORs listed are known to source from any of the Covered Countries; |
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Supplier indicated that they have not received conflict minerals data for each metal from all relevant suppliers; |
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Supplier indicated they have not identified all of the SORs used for the products included in the declaration scope; |
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Supplier indicated they have not provided all applicable SOR information received; and |
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Supplier indicated 100% of the 3TG for products covered by the declaration originates from scrap/recycled sources, but one or more SORs listed are not known to be exclusively recyclers. |
Design of Due Diligence
The Company’s due diligence process and efforts have been developed in accordance with the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-risk Areas (the “OECD Guidance”). The Company engaged the Service Provider to conduct due diligence and designed the due diligence process and measures to conform with the OECD Guidance in all material respects.
Due Diligence Performed
1. |
Maintain Strong Company Management System |
1.1. |
Adopting and Committing to a Conflict Minerals Policy |
The Company developed a global Conflict Minerals policy and Supplier Code of Conduct that are communicated widely both internally and externally and are posted on the Company’s external website. The Company clearly states its commitment to comply with laws and regulations surrounding conflict minerals.
The Company requires all of its suppliers to use materials that have been sourced in an ethically responsible manner and to confirm that they have not, and will not, knowingly procure conflict minerals that originate from smelters and refiners that are not certified as conflict free. These expectations are stated in our Conflict Minerals Policy and Supplier Code of Conduct, which can be accessed at: https://www.novanta.com/corporate-citizenship/.
1.2. |
Internal Management Systems to Support Supply Chain Due Diligence Control Systems |
The Company’s conflict minerals compliance program is sponsored by the Chief Executive Officer and is executed by a global task force that comprises of the Executive Vice President of Global Supply Chain, the Senior Director of Supply Chain, the Chief Accounting Officer and Corporate Controller, and a Supply Chain Compliance Lead from each of the product lines. The product line Supply Chain Compliance Lead is typically a manager of the procurement function and is supported by procurement and engineering professionals knowledgeable about the products and materials contained in those products.
The Company developed Conflict Minerals Process procedures that are required to be followed to perform the RCOI by all businesses globally. Supply Chain leaders are responsible for ensuring compliance with Conflict Minerals Process procedures at the local business level.
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Supplier Engagement |
The Company has engaged a Service Provider who specialized in supply chain due diligence to perform supplier engagement. With respect to the OECD requirement to strengthen engagement with suppliers, we have utilized the CMRT and our Service Provider’s web-based reporting tool for collecting conflict minerals declarations from our suppliers.
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 our efforts related to the conflict minerals compliance program. This includes obtaining information to support the chain of custody of the 3TGs identified in our products. We included Conflict Minerals terms and conditions on our purchase orders for raw materials and components used in our production process. (See further details in the section entitled “Reasonable Country of Origin Inquiry” above.)
1.4. |
Grievance Mechanism |
The Company maintains the Novanta Compliance Hotline, a 24x7 confidential web and phone messaging system, which provides means for employees, customers and suppliers to report deviations from the Company’s Code of Ethics and Business Conduct or any other matter of concern.
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Document Retention |
The Company utilizes a structured electronic database maintained by our Service Provider for documentation and record maintenance.
2. |
Identify and Assess Risks in the Supply Chain |
We have relied on supplier responses for information about the source of conflict minerals contained in the parts and components that they supplied to us. Similarly, our direct suppliers also relied on information provided by their suppliers. This chain of information created a level of uncertainty and risk related to the accuracy of the information. Risks were identified by assessing the due diligence practices of SORs identified in the supply chain by upstream suppliers that listed mineral processing facilities on their CMRTs. Our Service Provider compared these facilities listed in the responses to the list of SORs maintained by the Responsible Minerals Initiative (“RMI”) to ensure that the facilities met the RMI definition of a 3TG processing facility that was operational during the 2020 calendar year.
Each facility that meets the RMI definition of a SOR of a 3TG mineral is assessed according to red flag indicators defined in the OECD Guidance. Our Service Provider uses three factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags:
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Geographic proximity to the DRC and covered countries; |
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Responsible Minerals Assurance Process (“RMAP”) audit status; and |
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Credible evidence of unethical or conflict sourcing. |
3. |
Design and Implement a Strategy to Respond to Identified Risks |
For those supply chains with SORs that are known or thought to be sourcing from the Covered Countries, additional investigation was undertaken to determine the source and chain-of-custody of the regulated metals. The Service Provider relied on the following internationally accepted audit standards to determine which SORs are considered DRC Conflict Free: the Responsible Minerals Assurance Process (RMAP), the London Bullion Market Association Good Delivery Program, and the Responsible Jewellery Council Chain-of-Custody Certification. The Service Provider is an official vendor member of RMI that aims to further facilitate the exchange of supply chain data and technical information in the quest for global ethical sourcing of materials. This membership provides the Service Provider access to the following working groups: Engage with the CMRT Development Team, Smelter Engagement Team, Smelter Data Management Team, RMI Stakeholders Call, and RMI Plenary.
If the SOR was not certified by these internationally-recognized schemes, the Service Provider attempted to contact the SOR to gain more information about its sourcing practices, including countries of origin and transfer, and whether there were any internal due diligence procedures in place or other processes the SOR took to track the chain of custody on the source of its mineral ores. Relevant information to review included: whether the SOR had a documented, effective and communicated conflict-free policy, an accounting system to support a mass balance of materials processed, and traceability documentation. Internet research was also performed to determine whether there were any outside sources of information regarding the SOR’s sourcing practices. Up to three contact attempts were made by the Service Provider to gather information on mine country of origin and sourcing practices.
We have developed a risk management plan to ensure that all identified risks are responded to. This includes communicating any identified risks to upper management and escalating suppliers who do not meet our expectations.
If the Company discovers through its RCOI efforts that any conflict minerals directly or indirectly benefit the armed groups in the Covered Countries, the Company will take steps to work with its suppliers to stop using such conflict minerals and, if not possible, stop purchasing such raw materials or components from the supplier in question.
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Carry Out Independent Third-Party Audit |
We do not have any direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities
within our supply chain. Through our CMCP Service Provider, we rely on industry efforts, such as the RMI, to influence smelters and refiners to become certified as part of RMI’s Responsible Minerals Assurance Process.
5. |
Report Annually on Supply Chain Due Diligence |
This Report, which constitutes our annual report on our due diligence efforts, is filed with the SEC and is available on the Company’s website at http://www.novanta.com/corporate-citizenship/.
Results of RCOI and Due Diligence
As of May 14, 2021 the Company had surveyed 955 Tier 1 suppliers that are considered in scope and received responses from approximately 88% of such suppliers. Of these responding suppliers, 41% indicated one or more of the 3TGs as necessary to the functionality or production of the products they supplied to the Company.
Of the suppliers surveyed, many completed the CMRT at their business unit or entity level and were unable to represent that 3TGs from the processing facilities they listed had actually been used in the components that they supplied to us. The quality of the responses received from the surveyed suppliers continued to be varied. Many of the responses included the names and locations of the SORs. The CMRTs submitted by the suppliers that did not list at least one SOR for each 3TG claimed on the CMRT are considered inconsistent and our Service Provider followed up on these inconsistent responses as detailed in the Quality Assurance section. As of May 14, 2021, the Service Provider was able to validate 340 SORs submitted by the responding suppliers but there were still suppliers that were unable to provide SOR information or provided SOR information that could not be verified.
Appendix A lists the SORs that our suppliers have reported as being in their supply chains. Appendix A does not include any SORs that the Service Provider has not been able to validate. Appendix B includes an aggregate list of the countries of origin from which the reported facilities collectively sourced conflict minerals, based on information provided by the suppliers and reported by the RMI.
Additional Steps to Be Taken to Mitigate Risks
The Company will continue to work with those suppliers who have not responded, responded with invalid SOR information, or responded as “DRC Conflict Undeterminable” to identify the source of such minerals using available tools, such as the CMRT and the related Smelter Reference list that is publicly available. Should a supplier conclude, and report to us, that they have conflict minerals sourced from the Covered Countries and benefited the armed groups, the Company will require such suppliers to implement measures to become DRC conflict free or find alternative suppliers to the extent alternative DRC conflict free sources of supply are available.
Safe Harbor and Forward-Looking Statements
Certain statements in this Conflict Minerals Report contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995 and are based on current expectations and assumptions that are subject to risks and uncertainties. All statements contained in this Conflict Minerals Report that do not relate to matters of historical fact should be considered forward-looking statements, and are generally identified by words such as “will,” “expects,” “intends,” “plans,” “believes,” “anticipates,” and other similar expressions. These forward-looking statements include, but are not limited to, statements regarding expectation or intention relating to our compliance efforts and expected actions. These statements are neither promises nor guarantees, but involve risks and uncertainties that may cause future expectations or actions to be different. Undue reliance should not be placed on these statements, which are only effective as of the date of this report. The Company disclaims any obligation to update any forward-looking statements as a result of developments occurring after the date of this document except as required by law.
Appendix A
The following is a list of identified smelters or refiners for the 2020 reporting period:
Metal |
Official Smelter Name |
RMI Smelter ID |
Smelter Country |
Gold |
8853 S.p.A. |
CID002763 |
Italy |
Gold |
Abington Reldan Metals, LLC |
CID002708 |
United States |
Gold |
Advanced Chemical Company |
CID000015 |
United States |
Gold |
African Gold Refinery |
CID003185 |
Uganda |
Gold |
Aida Chemical Industries Co., Ltd. |
CID000019 |
Japan |
Gold |
Al Etihad Gold Refinery DMCC |
CID002560 |
United Arab Emirates |
Gold |
Alexy Metals |
CID003500 |
United States |
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
CID000035 |
Germany |
Gold |
Almalyk Mining and Metallurgical Complex (AMMC) |
CID000041 |
Uzbekistan |
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao |
CID000058 |
Brazil |
Gold |
Argor-Heraeus S.A. |
CID000077 |
Switzerland |
Gold |
Asahi Pretec Corp. |
CID000082 |
Japan |
Gold |
Asahi Refining Canada Ltd. |
CID000924 |
Canada |
Gold |
Asahi Refining USA Inc. |
CID000920 |
United States |
Gold |
Asaka Riken Co., Ltd. |
CID000090 |
Japan |
Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
CID000103 |
Turkey |
Gold |
AU Traders and Refiners |
CID002850 |
South Africa |
Gold |
Augmont Enterprises Private Limited |
CID003461 |
India |
Gold |
Aurubis AG |
CID000113 |
Germany |
Gold |
Bangalore Refinery |
CID002863 |
India |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
CID000128 |
Philippines |
Gold |
Boliden AB |
CID000157 |
Sweden |
Gold |
C. Hafner GmbH + Co. KG |
CID000176 |
Germany |
Gold |
C.I Metales Procesados Industriales SAS |
CID003421 |
Colombia |
Gold |
Caridad |
CID000180 |
Mexico |
Gold |
CCR Refinery - Glencore Canada Corporation |
CID000185 |
Canada |
Gold |
Cendres + Metaux S.A. |
CID000189 |
Switzerland |
Gold |
CGR Metalloys Pvt Ltd. |
CID003382 |
India |
Gold |
Chimet S.p.A. |
CID000233 |
Italy |
Gold |
Chugai Mining |
CID000264 |
Japan |
Gold |
Daye Non-Ferrous Metals Mining Ltd. |
CID000343 |
China |
Gold |
Degussa Sonne / Mond Goldhandel GmbH |
CID002867 |
Germany |
Gold |
Dijllah Gold Refinery FZC |
CID003348 |
United Arab Emirates |
Gold |
DODUCO Contacts and Refining GmbH |
CID000362 |
Germany |
Gold |
Dowa |
CID000401 |
Japan |
Gold |
DS PRETECH Co., Ltd. |
CID003195 |
Korea, Republic of |
Gold |
DSC (Do Sung Corporation) |
CID000359 |
Korea, Republic of |
Gold |
Eco-System Recycling Co., Ltd. East Plant |
CID000425 |
Japan |
Gold |
Eco-System Recycling Co., Ltd. North Plant |
CID003424 |
Japan |
Gold |
Eco-System Recycling Co., Ltd. West Plant |
CID003425 |
Japan |
Gold |
Emerald Jewel Industry India Limited (Unit 1) |
CID003487 |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 2) |
CID003488 |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 3) |
CID003489 |
India |
Gold |
Emerald Jewel Industry India Limited (Unit 4) |
CID003490 |
India |
Gold |
Emirates Gold DMCC |
CID002561 |
United Arab Emirates |
Gold |
Fidelity Printers and Refiners Ltd. |
CID002515 |
Zimbabwe |
Gold |
Fujairah Gold FZC |
CID002584 |
United Arab Emirates |
Gold |
GCC Gujrat Gold Centre Pvt. Ltd. |
CID002852 |
India |
Gold |
Geib Refining Corporation |
CID002459 |
United States |
Gold |
Gold Coast Refinery |
CID003186 |
Ghana |
Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. |
CID002243 |
China |
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM |
CID001909 |
China |
Gold |
Guangdong Jinding Gold Limited |
CID002312 |
China |
Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
CID000651 |
China |
Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. |
CID000671 |
China |
Gold |
Heimerle + Meule GmbH |
CID000694 |
Germany |
Gold |
Heraeus Metals Hong Kong Ltd. |
CID000707 |
China |
Gold |
Heraeus Precious Metals GmbH & Co. KG |
CID000711 |
Germany |
Gold |
Hunan Chenzhou Mining Co., Ltd. |
CID000767 |
China |
Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
CID000773 |
China |
Gold |
HwaSeong CJ CO., LTD. |
CID000778 |
Korea, Republic of |
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CID000801 |
China |
Gold |
International Precious Metal Refiners |
CID002562 |
United Arab Emirates |
Gold |
Ishifuku Metal Industry Co., Ltd. |
CID000807 |
Japan |
Gold |
Istanbul Gold Refinery |
CID000814 |
Turkey |
Gold |
Italpreziosi |
CID002765 |
Italy |
Gold |
JALAN & Company |
CID002893 |
India |
Gold |
Japan Mint |
CID000823 |
Japan |
Gold |
Jiangxi Copper Co., Ltd. |
CID000855 |
China |
Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
CID000927 |
Russian Federation |
Gold |
JSC Uralelectromed |
CID000929 |
Russian Federation |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
CID000937 |
Japan |
Gold |
K.A. Rasmussen |
CID003497 |
Norway |
Gold |
Kaloti Precious Metals |
CID002563 |
United Arab Emirates |
Gold |
Kazakhmys Smelting LLC |
CID000956 |
Kazakhstan |
Gold |
Kazzinc |
CID000957 |
Kazakhstan |
Gold |
Kennecott Utah Copper LLC |
CID000969 |
United States |
Gold |
KGHM Polska Miedz Spolka Akcyjna |
CID002511 |
Poland |
Gold |
Kojima Chemicals Co., Ltd. |
CID000981 |
Japan |
Gold |
Korea Zinc Co., Ltd. |
CID002605 |
Korea, Republic of |
Gold |
Kundan Care Products Ltd. |
CID003463 |
India |
Gold |
Kyrgyzaltyn JSC |
CID001029 |
Kyrgyzstan |
Gold |
Kyshtym Copper-Electrolytic Plant ZAO |
CID002865 |
Russian Federation |
Gold |
L'azurde Company For Jewelry |
CID001032 |
Saudi Arabia |
Gold |
Lingbao Gold Co., Ltd. |
CID001056 |
China |
Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
CID001058 |
China |
Gold |
L'Orfebre S.A. |
CID002762 |
Andorra |
Gold |
LS-NIKKO Copper Inc. |
CID001078 |
Korea, Republic of |
Gold |
LT Metal Ltd. |
CID000689 |
Korea, Republic of |
Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
CID001093 |
China |
Gold |
Marsam Metals |
CID002606 |
Brazil |
Gold |
Materion |
CID001113 |
United States |
Gold |
Matsuda Sangyo Co., Ltd. |
CID001119 |
Japan |
Gold |
MD Overseas |
CID003548 |
India |
Gold |
Metal Concentrators SA (Pty) Ltd. |
CID003575 |
South Africa |
Gold |
Metallix Refining Inc. |
CID003557 |
United States |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
CID001149 |
China |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
CID001152 |
Singapore |
Gold |
Metalor Technologies (Suzhou) Ltd. |
CID001147 |
China |
Gold |
Metalor Technologies S.A. |
CID001153 |
Switzerland |
Gold |
Metalor USA Refining Corporation |
CID001157 |
United States |
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. |
CID001161 |
Mexico |
Gold |
Mitsubishi Materials Corporation |
CID001188 |
Japan |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
CID001193 |
Japan |
Gold |
MMTC-PAMP India Pvt., Ltd. |
CID002509 |
India |
Gold |
Modeltech Sdn Bhd |
CID002857 |
Malaysia |
Gold |
Morris and Watson |
CID002282 |
New Zealand |
Gold |
Moscow Special Alloys Processing Plant |
CID001204 |
Russian Federation |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. |
CID001220 |
Turkey |
Gold |
Navoi Mining and Metallurgical Combinat |
CID001236 |
Uzbekistan |
Gold |
NH Recytech Company |
CID003189 |
Korea, Republic of |
Gold |
Nihon Material Co., Ltd. |
CID001259 |
Japan |
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
CID002779 |
Austria |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
CID001325 |
Japan |
Gold |
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
CID001326 |
Russian Federation |
Gold |
OJSC Novosibirsk Refinery |
CID000493 |
Russian Federation |
Gold |
PAMP S.A. |
CID001352 |
Switzerland |
Gold |
Pease & Curren |
CID002872 |
United States |
Gold |
Penglai Penggang Gold Industry Co., Ltd. |
CID001362 |
China |
Gold |
Planta Recuperadora de Metales SpA |
CID002919 |
Chile |
Gold |
Prioksky Plant of Non-Ferrous Metals |
CID001386 |
Russian Federation |
Gold |
PT Aneka Tambang (Persero) Tbk |
CID001397 |
Indonesia |
Gold |
PX Precinox S.A. |
CID001498 |
Switzerland |
Gold |
QG Refining, LLC |
CID003324 |
United States |
Gold |
Rand Refinery (Pty) Ltd. |
CID001512 |
South Africa |
Gold |
Refinery of Seemine Gold Co., Ltd. |
CID000522 |
China |
Gold |
REMONDIS PMR B.V. |
CID002582 |
Netherlands |
Gold |
Royal Canadian Mint |
CID001534 |
Canada |
Gold |
SAAMP |
CID002761 |
France |
Gold |
Sabin Metal Corp. |
CID001546 |
United States |
Gold |
Safimet S.p.A |
CID002973 |
Italy |
Gold |
SAFINA A.S. |
CID002290 |
Czech Republic |
Gold |
Sai Refinery |
CID002853 |
India |
Gold |
Samduck Precious Metals |
CID001555 |
Korea, Republic of |
Gold |
SAMWON METALS Corp. |
CID001562 |
Korea, Republic of |
Gold |
Sancus ZFS (L’Orfebre, SA) |
CID003529 |
Colombia |
Gold |
SAXONIA Edelmetalle GmbH |
CID002777 |
Germany |
Gold |
Sellem Industries Ltd. |
CID003540 |
Mauritania |
Gold |
SEMPSA Joyeria Plateria S.A. |
CID001585 |
Spain |
Gold |
Shandong Humon Smelting Co., Ltd. |
CID002525 |
China |
Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
CID001619 |
China |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CID001622 |
China |
Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. |
CID002527 |
China |
Gold |
Shirpur Gold Refinery Ltd. |
CID002588 |
India |
Gold |
Sichuan Tianze Precious Metals Co., Ltd. |
CID001736 |
China |
Gold |
Singway Technology Co., Ltd. |
CID002516 |
Taiwan |
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
CID001756 |
Russian Federation |
Gold |
Solar Applied Materials Technology Corp. |
CID001761 |
Taiwan |
Gold |
Sovereign Metals |
CID003383 |
India |
Gold |
State Research Institute Center for Physical Sciences and Technology |
CID003153 |
Lithuania |
Gold |
Sudan Gold Refinery |
CID002567 |
Sudan |
Gold |
Sumitomo Metal Mining Co., Ltd. |
CID001798 |
Japan |
Gold |
SungEel HiMetal Co., Ltd. |
CID002918 |
Korea, Republic of |
Gold |
T.C.A S.p.A |
CID002580 |
Italy |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
CID001875 |
Japan |
Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
CID001916 |
China |
Gold |
Tokuriki Honten Co., Ltd. |
CID001938 |
Japan |
Gold |
Tongling Nonferrous Metals Group Co., Ltd. |
CID001947 |
China |
Gold |
Tony Goetz NV |
CID002587 |
Belgium |
Gold |
TOO Tau-Ken-Altyn |
CID002615 |
Kazakhstan |
Gold |
Torecom |
CID001955 |
Korea, Republic of |
Gold |
Umicore Brasil Ltda. |
CID001977 |
Brazil |
Gold |
Umicore Precious Metals Thailand |
CID002314 |
Thailand |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
CID001980 |
Belgium |
Gold |
United Precious Metal Refining, Inc. |
CID001993 |
United States |
Gold |
Valcambi S.A. |
CID002003 |
Switzerland |
Gold |
Western Australian Mint (T/a The Perth Mint) |
CID002030 |
Australia |
Gold |
WIELAND Edelmetalle GmbH |
CID002778 |
Germany |
Gold |
Yamakin Co., Ltd. |
CID002100 |
Japan |
Gold |
Yokohama Metal Co., Ltd. |
CID002129 |
Japan |
Gold |
Yunnan Copper Industry Co., Ltd. |
CID000197 |
China |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CID002224 |
China |
Tantalum |
Asaka Riken Co., Ltd. |
CID000092 |
Japan |
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
CID000211 |
China |
Tantalum |
D Block Metals, LLC |
CID002504 |
United States |
Tantalum |
Exotech Inc. |
CID000456 |
United States |
Tantalum |
F&X Electro-Materials Ltd. |
CID000460 |
China |
Tantalum |
FIR Metals & Resource Ltd. |
CID002505 |
China |
Tantalum |
Global Advanced Metals Aizu |
CID002558 |
Japan |
Tantalum |
Global Advanced Metals Boyertown |
CID002557 |
United States |
Tantalum |
Guangdong Rising Rare Metals-EO Materials Ltd. |
CID000291 |
China |
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
CID000616 |
China |
Tantalum |
H.C. Starck Hermsdorf GmbH |
CID002547 |
Germany |
Tantalum |
H.C. Starck Inc. |
CID002548 |
United States |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CID002492 |
China |
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CID002512 |
China |
Tantalum |
Jiangxi Tuohong New Raw Material |
CID002842 |
China |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CID000914 |
China |
Tantalum |
Jiujiang Tanbre Co., Ltd. |
CID000917 |
China |
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CID002506 |
China |
Tantalum |
KEMET Blue Metals |
CID002539 |
Mexico |
Tantalum |
LSM Brasil S.A. |
CID001076 |
Brazil |
Tantalum |
Meta Materials |
CID002847 |
Macedonia, The Former Yugoslav Republic Of |
Tantalum |
Metallurgical Products India Pvt., Ltd. |
CID001163 |
India |
Tantalum |
Mineracao Taboca S.A. |
CID001175 |
Brazil |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
CID001192 |
Japan |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
CID001277 |
China |
Tantalum |
NPM Silmet AS |
CID001200 |
Estonia |
Tantalum |
QuantumClean |
CID001508 |
United States |
Tantalum |
Resind Industria e Comercio Ltda. |
CID002707 |
Brazil |
Tantalum |
Solikamsk Magnesium Works OAO |
CID001769 |
Russian Federation |
Tantalum |
Taki Chemical Co., Ltd. |
CID001869 |
Japan |
Tantalum |
TANIOBIS Co., Ltd. |
CID002544 |
Thailand |
Tantalum |
TANIOBIS GmbH |
CID002545 |
Germany |
Tantalum |
TANIOBIS Japan Co., Ltd. |
CID002549 |
Japan |
Tantalum |
TANIOBIS Smelting GmbH & Co. KG |
CID002550 |
Germany |
Tantalum |
Telex Metals |
CID001891 |
United States |
Tantalum |
Ulba Metallurgical Plant JSC |
CID001969 |
Kazakhstan |
Tantalum |
XinXing Haorong Electronic Material Co., Ltd. |
CID002508 |
China |
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CID001522 |
China |
Tin |
Alpha |
CID000292 |
United States |
Tin |
An Vinh Joint Stock Mineral Processing Company |
CID002703 |
Viet Nam |
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CID000228 |
China |
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. |
CID003190 |
China |
Tin |
China Tin Group Co., Ltd. |
CID001070 |
China |
Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
CID003486 |
Brazil |
Tin |
CRM Synergies |
CID003524 |
Spain |
Tin |
CV Ayi Jaya |
CID002570 |
Indonesia |
Tin |
CV Venus Inti Perkasa |
CID002455 |
Indonesia |
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. |
CID003356 |
China |
Tin |
Dowa |
CID000402 |
Japan |
Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
CID002572 |
Viet Nam |
Tin |
EM Vinto |
CID000438 |
Bolivia |
Tin |
Estanho de Rondonia S.A. |
CID000448 |
Brazil |
Tin |
Fenix Metals |
CID000468 |
Poland |
Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. |
CID003410 |
China |
Tin |
Gejiu Fengming Metallurgy Chemical Plant |
CID002848 |
China |
Tin |
Gejiu Kai Meng Industry and Trade LLC |
CID000942 |
China |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CID000538 |
China |
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
CID001908 |
China |
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. |
CID000555 |
China |
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CID003116 |
China |
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant |
CID002849 |
China |
Tin |
HuiChang Hill Tin Industry Co., Ltd. |
CID002844 |
China |
Tin |
Huichang Jinshunda Tin Co., Ltd. |
CID000760 |
China |
Tin |
Jiangxi New Nanshan Technology Ltd. |
CID001231 |
China |
Tin |
Luna Smelter, Ltd. |
CID003387 |
Rwanda |
Tin |
Ma'anshan Weitai Tin Co., Ltd. |
CID003379 |
China |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
CID002468 |
Brazil |
Tin |
Malaysia Smelting Corporation (MSC) |
CID001105 |
Malaysia |
Tin |
Melt Metais e Ligas S.A. |
CID002500 |
Brazil |
Tin |
Metallic Resources, Inc. |
CID001142 |
United States |
Tin |
Metallo Belgium N.V. |
CID002773 |
Belgium |
Tin |
Metallo Spain S.L.U. |
CID002774 |
Spain |
Tin |
Mineracao Taboca S.A. |
CID001173 |
Brazil |
Tin |
Minsur |
CID001182 |
Peru |
Tin |
Mitsubishi Materials Corporation |
CID001191 |
Japan |
Tin |
Modeltech Sdn Bhd |
CID002858 |
Malaysia |
Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
CID002573 |
Viet Nam |
Tin |
Novosibirsk Processing Plant Ltd. |
CID001305 |
Russian Federation |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
CID001314 |
Thailand |
Tin |
O.M. Manufacturing Philippines, Inc. |
CID002517 |
Philippines |
Tin |
Operaciones Metalurgicas S.A. |
CID001337 |
Bolivia |
Tin |
Pongpipat Company Limited |
CID003208 |
Myanmar |
Tin |
Precious Minerals and Smelting Limited |
CID003409 |
India |
Tin |
PT Aries Kencana Sejahtera |
CID000309 |
Indonesia |
Tin |
PT Artha Cipta Langgeng |
CID001399 |
Indonesia |
Tin |
PT ATD Makmur Mandiri Jaya |
CID002503 |
Indonesia |
Tin |
PT Babel Inti Perkasa |
CID001402 |
Indonesia |
Tin |
PT Babel Surya Alam Lestari |
CID001406 |
Indonesia |
Tin |
PT Bangka Serumpun |
CID003205 |
Indonesia |
Tin |
PT Bukit Timah |
CID001428 |
Indonesia |
Tin |
PT Lautan Harmonis Sejahtera |
CID002870 |
Indonesia |
Tin |
PT Menara Cipta Mulia |
CID002835 |
Indonesia |
Tin |
PT Mitra Stania Prima |
CID001453 |
Indonesia |
Tin |
PT Mitra Sukses Globalindo |
CID003449 |
Indonesia |
Tin |
PT Prima Timah Utama |
CID001458 |
Indonesia |
Tin |
PT Rajawali Rimba Perkasa |
CID003381 |
Indonesia |
Tin |
PT Rajehan Ariq |
CID002593 |
Indonesia |
Tin |
PT Refined Bangka Tin |
CID001460 |
Indonesia |
Tin |
PT Stanindo Inti Perkasa |
CID001468 |
Indonesia |
Tin |
PT Timah Nusantara |
CID001486 |
Indonesia |
Tin |
PT Timah Tbk Kundur |
CID001477 |
Indonesia |
Tin |
PT Timah Tbk Mentok |
CID001482 |
Indonesia |
Tin |
PT Tinindo Inter Nusa |
CID001490 |
Indonesia |
Tin |
Resind Industria e Comercio Ltda. |
CID002706 |
Brazil |
Tin |
Rui Da Hung |
CID001539 |
Taiwan |
Tin |
Soft Metais Ltda. |
CID001758 |
Brazil |
Tin |
Super Ligas |
CID002756 |
Brazil |
Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd. |
CID002834 |
Viet Nam |
Tin |
Thaisarco |
CID001898 |
Thailand |
Tin |
Tin Technology & Refining |
CID003325 |
United States |
Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
CID002574 |
Viet Nam |
Tin |
VQB Mineral and Trading Group JSC |
CID002015 |
Viet Nam |
Tin |
White Solder Metalurgia e Mineracao Ltda. |
CID002036 |
Brazil |
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CID002158 |
China |
Tin |
Yunnan Tin Company Limited |
CID002180 |
China |
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
CID003397 |
China |
Tungsten |
A.L.M.T. TUNGSTEN Corp. |
CID000004 |
Japan |
Tungsten |
ACL Metais Eireli |
CID002833 |
Brazil |
Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
CID003427 |
Brazil |
Tungsten |
Artek LLC |
CID003553 |
Russian Federation |
Tungsten |
Asia Tungsten Products Vietnam Ltd. |
CID002502 |
Viet Nam |
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
CID002513 |
China |
Tungsten |
China Molybdenum Co., Ltd. |
CID002641 |
China |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
CID000258 |
China |
Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. |
CID000281 |
China |
Tungsten |
Cronimet Brasil Ltda |
CID003468 |
Brazil |
Tungsten |
Fujian Ganmin RareMetal Co., Ltd. |
CID003401 |
China |
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
CID000499 |
China |
Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. |
CID002645 |
China |
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
CID000875 |
China |
Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
CID002315 |
China |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
CID002494 |
China |
Tungsten |
GEM Co., Ltd. |
CID003417 |
China |
Tungsten |
Global Tungsten & Powders Corp. |
CID000568 |
United States |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
CID000218 |
China |
Tungsten |
H.C. Starck Tungsten GmbH |
CID002541 |
Germany |
Tungsten |
Hunan Chenzhou Mining Co., Ltd. |
CID000766 |
China |
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
CID002579 |
China |
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
CID000769 |
China |
Tungsten |
Hunan Litian Tungsten Industry Co., Ltd. |
CID003182 |
China |
Tungsten |
Hydrometallurg, JSC |
CID002649 |
Russian Federation |
Tungsten |
Japan New Metals Co., Ltd. |
CID000825 |
Japan |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
CID002551 |
China |
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. |
CID002321 |
China |
Tungsten |
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
CID002313 |
China |
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
CID002318 |
China |
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
CID002317 |
China |
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. |
CID002316 |
China |
Tungsten |
JSC "Kirovgrad Hard Alloys Plant" |
CID003408 |
Russian Federation |
Tungsten |
Kennametal Fallon |
CID000966 |
United States |
Tungsten |
Kennametal Huntsville |
CID000105 |
United States |
Tungsten |
KGETS CO., LTD. |
CID003388 |
Korea, Republic of |
Tungsten |
Lianyou Metals Co., Ltd. |
CID003407 |
Taiwan |
Tungsten |
Malipo Haiyu Tungsten Co., Ltd. |
CID002319 |
China |
Tungsten |
Masan Tungsten Chemical LLC (MTC) |
CID002543 |
Viet Nam |
Tungsten |
Moliren Ltd. |
CID002845 |
Russian Federation |
Tungsten |
Niagara Refining LLC |
CID002589 |
United States |
Tungsten |
NPP Tyazhmetprom LLC |
CID003416 |
Russian Federation |
Tungsten |
Philippine Chuangxin Industrial Co., Inc. |
CID002827 |
Philippines |
Tungsten |
TANIOBIS Smelting GmbH & Co. KG |
CID002542 |
Germany |
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
CID001889 |
Viet Nam |
Tungsten |
Unecha Refractory Metals Plant |
CID002724 |
Russian Federation |
Tungsten |
Wolfram Bergbau und Hutten AG |
CID002044 |
Austria |
Tungsten |
Woltech Korea Co., Ltd. |
CID002843 |
Korea, Republic of |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
CID002320 |
China |
Tungsten |
Xiamen Tungsten Co., Ltd. |
CID002082 |
China |
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
CID002830 |
China |
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
CID002095 |
China |
Appendix B
The list below sets out possible countries of origin of 3TGs used in the manufacture of our products containing 3TGs for the 2020 reporting year. The list is based on publicly available information, our reasonable country of origin inquiries, and other due diligence efforts. However, for the reasons described in the Conflict Minerals Report, these possible countries of origin cannot be linked to our products with reasonable certainty.
Andorra, Australia, Austria, Belgium, Bolivia, Brazil, Canada, Chile, China, Colombia, Czech Republic, Estonia, France, Germany, Ghana, India, Indonesia, Italy, Japan, Kazakhstan, Republic of Korea, Kyrgyzstan, Lithuania, The Former Yugoslav Republic Of Macedonia, Malaysia, Mauritania, Mexico, Myanmar, Netherlands, New Zealand, Norway, Peru, Philippines, Poland, Russian Federation, Rwanda, Saudi Arabia, Singapore, South Africa, Spain, Sudan, Sweden, Switzerland, Taiwan, Thailand, Turkey, Uganda, United Arab Emirates, United States, Uzbekistan, Viet Nam, Zimbabwe
***