UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Woodward, Inc.
(Exact name of registrant as specified in its charter)
Delaware | 0-8408 | 36-1984010 | ||
(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
1081 Woodward Way, Fort Collins, Colorado | 80524 | |||
(Address of principal executive offices) | (Zip Code) |
A. Christopher Fawzy (970) 482-5811
(Name and telephone number, including area code, of the person to contact in connection with this report.)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020. |
Section 1 Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
Woodward, Inc. (the Company, Woodward, we, us or our) is filing this Form SD pursuant to Rule 13p-1 (Rule 13p-1) under the Securities Exchange Act of 1934 for the reporting period from January 1, 2020 to December 31, 2020 (the Reporting Period).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD and as used herein, conflict minerals means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country as defined in Form SD (collectively, the Covered Countries). Our operations, including the operations of our consolidated subsidiaries, may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products. Woodward primarily serves the aerospace market and industrial market. Products we manufacture or contract to manufacture in the aerospace market include fuel pumps, metering units, actuators, air valves, specialty valves, fuel nozzles, and thrust reverser actuation systems for turbine engines and nacelles; as well as flight deck controls (auto throttles, rudder pedal assembles, flight control assemblies), actuators, servocontrols, motors and sensors for aircraft. Products we manufacture or contract to manufacture in the industrial market include power converters, actuators, valves, pumps, injectors, solenoids, ignition systems, governors, electronics and devices that measure, communicate and protect low and medium voltage electrical distribution systems. Woodward has determined that some of these products contain one or more conflict minerals, in particular:
| All of the product families listed, except for valves, nozzles, injectors and some pumps, contain (or physically are) electronics, motors and/or sensors. These product families will contain, at a minimum, tin in the lead/tin solder that fastens electronic components to printed circuit boards and tantalum in certain families of capacitors used in printed circuit board assemblies within those product families. |
| Gold is used in the plating of connectors and contacts in many of the electronics within our product families. |
| Finally, items in all of Woodward product families use a variety of steels, which contain very small amounts of tungsten as part of their material recipe. |
As a result of these determinations, Woodward is required to conduct a reasonable country of origin inquiry (RCOI) in accordance with Rule 13p-1.
In 2018, Woodward extended its fuel injection systems product portfolio with the acquisition of LOrange, a world class fuel injection systems technology company, from Rolls-Royce (Woodward LOrange). The acquisition formally closed on June 4, 2018. This Form SD includes for the first time information regarding Woodward LOranges use of conflict minerals and its due diligence. Unless otherwise noted, all numbers and data are inclusive of Woodward LOrange.
Reasonable Country of Origin Inquiry
As noted above, some of the products Woodward manufactures contain one or more conflict minerals. Woodward does not purchase conflict minerals directly from mines, smelters or refiners. Rather, the Company sources products containing conflict minerals from its suppliers. In accordance with the OECD Guidelines (as defined below), the Company relies on its suppliers to provide information regarding the origin of conflict minerals included in supplied products, including, where possible, the smelters or refiners (SOR) of the conflict minerals. There is significant overlap between our RCOI efforts and the due diligence measures we perform. Our due diligence measures are described in our Conflict Minerals Report, attached hereto as Exhibit 1.01.
General
Woodward developed its initial good faith RCOI process in calendar year 2013 (subsequent references to whole years refer to calendar years) and has continued to improve and refine that process in subsequent years. Our RCOI process conforms to the Organisation for Economic Co-operation and Developments (OECD) framework, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (the OECD Guidelines). We have contracted with Assent to license the Assent Compliance Platform (ACP) and we utilize Assents support services to automate the supplier inquiry, data collection and data validation tasks essential for RCOI. We are members of the Responsible Materials Initiative (RMI), and we leverage RMIs extensive database of SORs, SOR audit records, and country of origin data. We participate in a multi-company written request, facilitated by Assent, to each SOR that was not participating in, or had not completed, an independent audit program. This request is made to determine compliance to conflict-free sourcing protocols, and to encourage such SORs to participate in the audit program at the earliest practical opportunity.
Supplier Categorization
In connection with the preparation of the Form SD and associated Conflict Minerals Report, we create a master supplier list of direct suppliers who provide items or services directly used in items that Woodward manufactures or contracts to manufacture. Such suppliers are classified as either direct non-distribution suppliers, who fabricate custom designed items to either Woodward specification or supplier-engineered specifications, or direct distribution suppliers, who source items from multiple Original Equipment Manufacturers (OEMs), typically in the nature of a commercial item or items manufactured to standard government specifications. Direct distribution suppliers do not manufacture or contract to manufacture, nor do they influence the functionality or content of the items they obtain from OEMs and provide to their customers. Woodward relies on the efforts and activities of professional societies, including IPC Association Connecting Electronics Industries which provides a leading role in the conflict minerals efforts of the electronics and electronics distribution industries, to establish and maintain the principal mechanisms for obtaining OEM distribution component conflict minerals status from our first tier distribution suppliers. Woodward also utilizes Assent to contact OEMs directly for compliance status when Woodward is able to provide the OEMs name and part number.
Suppliers that contribute items or services only for Woodwards internal operations and infrastructure, and are not incorporated into items that Woodward manufactures or contracts to manufacture, are not included in the Companys conflict minerals reporting.
Applicable Supplier Identification
Because we are continuing to fully integrate Woodward LOrange into our reporting systems, we ran two separate conflict minerals campaigns for the Reporting Period. Additionally, we used a different process to identify applicable Woodward LOrange suppliers than we did for other Woodward suppliers.
To identify the applicable Woodward suppliers (exclusive of Woodward LOrange), we generated reports within our WISE and SAP enterprise resource planning (ERP) systems to identify the products that were shipped during 2020, using actual shipments from January through September, and forecasted shipments from October through December. We also included the suppliers of the inventory we had on hand at the beginning of the calendar year, to the degree that our business systems are capable of such delineation. The resulting product identifiers were input to a set of customized scripts that: 1) expanded each product into its constituent subassemblies and parts; and 2) provided the associated supplier identifier and/or Woodward plant identifier from which the subassemblies or parts had been purchased or fabricated for those products. That information was uploaded into ACP to create the applicable composite part and subassembly lists for each applicable supplier, which was then included in a part-level Conflict Minerals Reporting Template (CMRT). Each applicable supplier was sent a part-level CMRT in January 2021.
To identify the applicable Woodward LOrange suppliers (exclusive of other Woodward suppliers), we generated product and supplier data from Woodward LOranges SAP ERP system for the period from June 2019 to December 2020, and determined which components were used in products that were introduced into the stream of commerce during 2020. That information was uploaded to ACP to create the applicable Woodward LOrange supplier list. Woodward LOrange, via ACP, first sent each applicable supplier a CMRT on March 1, 2021. Because the Woodward LOrange campaign was initiated during the end stages of Woodwards overall campaign, we requested company-level CMRTs from Woodward LOrange suppliers rather than part-level CMRTs.
Woodward Conflict Minerals Data Requests and Supplier Responses
See Woodward Calendar Year 2020 Due Diligence Results in our Conflict Minerals Report for a summary of supplier responses and the results of our supplier and country of origin due diligence.
Supplier Response Assessment
The Assent services team and ACP provided to Woodward an extensive and comprehensive supplier CMRT assessment and validation of supplier responses using a due diligence process conforming to the 5-step due diligence process specified in the OECD Guidelines. We discuss this diligence process further in our Conflict Minerals Report. Assent validated the SOR input provided in supplier CMRTs using an extensive database consisting of the RMI, Responsible Jewelry Network, and London Bullion Market Association validated SOR lists and the results of Assents internal independent SOR validation efforts. The CMRTs that passed the assessment process were automatically combined by ACP into a Woodward company level CMRT. Those CMRTs that did not pass were returned to the supplier with discrepancies identified and a corrective action request. Woodward, using its RMI membership and access to the RMI SOR audit records and country of origin data, completed its RCOI down to the mine country of origin level to the degree of accuracy and discrimination available in the RMI database. See Smelter or Refiner Mine Country of Origin Results in our Conflict Minerals Report for a summary of our country of origin findings.
Based on a reasonable country of origin inquiry, Woodward has found that some of its suppliers use smelters whose wolframite, columbite-tantalite, and cassiterite ores were acquired from mines in the Covered Countries. These ores are the sources of tungsten, tantalum and tin, respectively. As a result of our due diligence process and findings to date, the Company has determined to file a Conflicts Minerals Report, a copy of which is filed as Exhibit 1.01 to this Form SD. Our Conflict Minerals Report is also publicly available as a document link at: https://www.woodward.com/en/about/corporate-governance/compliance. The content on any web site referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.
RCOI Continuous Improvement Actions
In pursuit of continuous improvement, we engage in the following activities that enable us to consistently enhance and refine our country of origin inquiry:
| We refine the tools and processes needed to support part-level CMRT requests. To eliminate ambiguity in our requests to suppliers, we provide each applicable supplier a complete list of the specific parts that Woodward purchased from them that was incorporated into our calendar year shipments. |
| We use supplier CMRTs to identify the parent companies of our suppliers (if any), parent company contact data (if applicable), and whether the supplier reported conflict minerals data at a corporate or business group level. The information we gather using this approach enables us to improve the targeting of future campaigns. |
| We use ACP and other Assent services to further automate our RCOI efforts. |
| We review our supplier terms and conditions, our template long-term supply agreement, and our Conflict Minerals Policy to promote Woodwards social responsibility goals and to ensure compliance with all applicable laws and regulations. |
| We participate in Assents outreach to suppliers that report the use of smelters of concern, strongly encouraging them to procure, and to request their supply chains to procure, materials from sources that use conflict-free processes as determined by appropriate independent third-party audit programs, such as RMI. |
| We conduct an annual outreach program directly to SORs on the risk list to strongly encourage their participation in an independent third-party audit program and to achieve conflict-free processes and protocols. We participate in a multi-company program facilitated by Assent that leverages the collective influence we may have on the SORs. |
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this Form SD.
Exhibit 1.01 Conflict Minerals Report of Woodward, Inc., for the year ended December 31, 2020.
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.
Woodward, Inc. |
(Registrant) |
/s/ A. Christopher Fawzy |
May 28, 2021 | |||||||
By: | A. Christopher Fawzy Corporate Vice President, General Counsel, Corporate Secretary and Chief Compliance Officer |
(Date) |
Exhibit 1.01
Conflict Minerals Report of Woodward, Inc.
For the reporting period from January 1, 2020 to December 31, 2020
This Conflict Minerals Report (the Report) of Woodward, Inc. (the Company, Woodward, we, us or our) has been prepared pursuant to Rule 13p-1 (Rule 13p-1) and Form SD (Form SD) promulgated under the Securities Exchange Act of 1934 (the Exchange Act) for the reporting period January 1, 2020 to December 31, 2020 (the Reporting Period).
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain conflict minerals (as defined below) are necessary to the functionality or production of such products. As defined in Form SD, and as used herein, conflict minerals means: (i)(a) columbite-tantalite (or coltan), (b) cassiterite, (c) gold and (d) wolframite, or their derivatives, which are currently limited to tantalum, tin and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country as defined in Form SD (collectively, the Covered Countries).
Woodwards Manufactured and Contracted-to-Manufacture Products
Woodward, including our consolidated subsidiaries, manufactures and sub-contracts for the manufacture of products for which conflict minerals are necessary to the functionality or production of those products. We provide energy control and optimization solutions for the aerospace and industrial markets through the precise and efficient control of fluid and electrical energy, combustion, and motion. Within the aerospace market, we provide systems, components and solutions for both commercial and defense applications. Our key focus areas within this market are propulsion and combustion control solutions for turbine powered aircraft, and fluid and motion control solutions for critical aerospace and defense applications. Our aerospace segment designs, manufactures and services systems and products for the management of fuel, air, combustion and motion control. These products include fuel pumps, metering units, actuators, air valves, specialty valves, fuel nozzles, and thrust reverser actuation systems for turbine engines and nacelles, as well as flight deck controls, actuators, servocontrols, motors and sensors for aircraft. These products are used on commercial and private aircraft and rotorcraft, as well as on military fixed-wing aircraft and rotorcraft, guided weapons, and other defense systems. Within the industrial market, our key focus areas are applications and control solutions for machines that produce electricity, and fluid, motion, and combustion control solutions for complex oil and gas, industrial, power generation, and transportation applications. Our industrial segment designs, produces and services systems and products for the management of fuel, air, fluids, gases, motion, combustion and electricity. These products include actuators, valves, pumps, fuel injection systems, solenoids, ignition systems, speed controls, electronics and software, power converters, sensors and other devices that measure, communicate and protect electrical distribution systems. Our industrial products are used on industrial gas turbines (including heavy frame, aeroderivative and small industrial gas turbines), steam turbines, reciprocating engines (including low speed, medium speed and high speed engines, natural gas vehicles and diesel, heavy fuel oil and dual-fuel engines), electric power generation and power distribution systems, and compressors. The equipment on which our industrial products are found is used to generate and distribute power; to extract and distribute fossil and renewable fuels; in the mining of other commodities; and to convert fuel to work in transportation and freight (both marine and locomotives), mobile, and industrial equipment applications.
In 2018, Woodward extended its fuel injection systems product portfolio with the acquisition of LOrange, a world class fuel injection systems technology company, from Rolls-Royce (Woodward LOrange). The acquisition formally closed on June 4, 2018. This Report includes for the first time information regarding Woodward LOranges use of conflict minerals and its due diligence. Unless otherwise noted, all numbers and data are inclusive of Woodward LOrange.
The Companys Due Diligence Process
The Companys due diligence measures have been designed to conform to the framework in the Organisation for Economic Co-operation and Developments (OECD), OECD Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas, Third Edition, including applicable supplements thereto (the OECD Guidelines).
Woodward has implemented or is addressing each of the steps in the OECD 5-step due diligence framework as discussed or referenced below:
1. | Establish strong company management systems |
a. | Company conflict minerals policy |
Woodward has developed and adopted a conflict minerals policy, Policy 9-14, Conflict Minerals (the Conflict Minerals Policy). The Conflict Minerals Policy affirms that the Company takes our corporate responsibility with respect to responsible sourcing seriously and that it is the Companys goal to only use in our products conflict minerals that are sourced responsibly. The Conflict Minerals Policy provides that Woodward will take appropriate measures to ensure participants in our global supply chain exercise due diligence and comply with reporting and other compliance requirements with respect to the items Woodward procures from them. The policy is publicly available and can be accessed at https://www.woodward.com/en/about/corporate-governance/compliance. The policy is formally reviewed at least annually to determine if any revisions or enhancements are required to maintain compliance with the letter and the intent of the law. No changes were made to Woodwards Conflict Minerals Policy as the result of its review for 2020.
b. | Internal management structure |
The Conflict Minerals Policy designates the Corporate Vice President of Global Supply Chain as responsible for ensuring our compliance with conflict minerals reporting requirements. Woodwards Governance and Securities Counsel serves as an advisor on conflict minerals compliance. When appropriate, conflict minerals are a topic of discussion and review at meetings of our Board of Directors.
We assigned our Global Supply Chain group (GSC) the responsibility for conflict minerals compliance to be overseen by the Corporate Vice President, Global Supply Chain. GSC has established an internal team led by a senior GSC leader to manage conflict minerals engagement with our suppliers (such team, the Core Team). Woodward is subject to numerous product material compliance regulations, including with respect to conflict minerals, which require enterprise-wide system and compliance processes and integrated process teams to achieve regulatory compliance requirements and social responsibility goals.
The Core Team, together with other GSC members and with counsel from the Global Legal & Compliance Department, are the Companys team of subject matter experts and implementers. GSC is responsible for reaching out to the Companys supply base on an ongoing basis to collect information, including Conflict Minerals Reporting Templates (CMRT), regarding the presence and sourcing of conflict minerals in the products supplied to the Company. Others within GSC provide focused support as required. These actions have aligned existing strategic and organizational structures to address the due diligence and reporting requirements of Rule 13p-1.
In addition, Woodwards product material compliance activity, including conflict minerals, was chartered as a formal project in 2015 to provide an established framework for the continuing evolution of an enterprise-wide set of material compliance processes and standard work. Woodwards Corporate Vice President of Global Supply Chain, the Vice President of Information Technology, and the Corporate Vice President, General Counsel, Corporate Secretary and Chief Compliance Officer all provide executive guidance and oversight of our product material compliance activities. The Core Team leader provides status updates and receives executive project guidance at various times throughout the year. Since 2018, product material compliance, including conflict minerals, has been a standard element of Woodwards workflow.
c. | System of controls and transparency over the mineral supply chain |
Our enterprise resource planning (ERP) systems, WISE and SAP, provide controls over our supply chain. The ERP systems currently provide:
| Identification of the end item products we provide to each of our customers; |
| Shipping transaction history to assist in bounding our sales/shipments by calendar year as required by the Rule 13p-1 of the Exchange Act; |
| A bill of material identifying all of the components and materials in each of our end item products; |
| A purchasing history of each of our purchased components and raw materials and the identification of the suppliers used for these purchases; |
| A receiving inspection function that accepts or rejects purchased components and raw materials based upon whether the purchased items meet or do not meet the specification requirements (including specified material requirements) of the associated drawing or other specification documents. This is accomplished by a combination of direct measurements / inspections of the actual parts, or by reviewing the existence and completeness of formal supplier certifications to selected specifications, such as certifying proper use of specified aluminum or steel specifications. |
We continue to use the Assent Compliance Platform (ACP) and other Assent services to automate much of the Companys product materials compliance efforts. In addition, Woodward maintains full membership with the Aerospace Industries Association (AIA), the IPC the Association Connecting Electronics Industries, and the Responsible Materials Initiative (RMI).
d. | Strengthen Company engagement with suppliers |
Woodward is committed to conducting business in a socially responsible manner and is determined to partner with suppliers who are similarly committed. We continue to significantly enhance our engagement with our suppliers regarding conflict minerals requirements. Our purchase order terms and conditions and our standard long-term supplier agreement (collectively, our supplier terms) require our suppliers to support our conflict minerals reporting. Woodward reviews the conflict minerals provisions in our supplier terms on a regular basis. We desire to achieve improved supply chain transparency and responsible sourcing, with the ultimate goal of obtaining full material disclosure (substance, content-by-weight, raw material smelter sources) to increase the traceability of materials from each supplier.
By accepting a Woodward purchase order, a Woodward supplier:
warrants and certifies that it complies with Section 1502 of the Dodd Frank Act and the Final Rule issued by the U.S. Securities and Exchange Commission, and any subsequent rules and regulations related thereto issued by the United States Government and, where identified by Woodward, other governments and/or authorities in regions that Woodward provides its products (Conflict Minerals Regulations), and has implemented compliant processes to ensure its suppliers are in compliance with the Conflict Minerals Regulations.
Where Seller does not have direct and formal reporting requirements under the Conflict Minerals Regulations, and upon request by Buyer, Seller agrees to provide due diligence and Responsible Country of Origin Inquiry (RCOI) information under this Agreement to Buyer in support of Buyers reporting requirements (the RCOI Requirements).
Further, Seller shall promptly comply with all requests by Buyer to provide documentation, and other substantiating data and assurances with respect to its compliance with Conflict Minerals Regulations and the RCOI Requirements as Buyer may deem necessary from time to time. In the event: (a) Buyer deems Seller is not in compliance with the Conflict Minerals Regulations or the RCOI Requirements, (b) Buyer is not satisfied with the outcome of any review of Seller documentation and/or data or otherwise, or (c) Seller does not provide the documentation, other data and/or other further assurances to Buyer as requested by Buyer, Buyer shall have the right to terminate this Order or any portion thereof without penalty or further liability to Buyer.
Woodward conducts one-on-one contact sessions with suppliers to address their inquiries and provide guidance where needed. Through our contract with Assent, our suppliers have access to an extensive suite of training videos, slide decks, how-to manuals and regulation guidance documents. Our suppliers also have access to online chat with an Assent specialist if they have difficulties or questions while preparing their responses. Woodward typically participates in multiple Assent Compliance supplier summits and conferences during the year, often inviting our suppliers.
e. | Establish a company-level, or industry-wide, grievance mechanism as an early warning risk-awareness system |
Woodward has a comprehensive ethics awareness compliance policy, annual training and robust reporting mechanisms for employees concerns or ethics grievances. All Woodward employees have the right and responsibility to promptly report concerns, including but not limited to suspected or known violations of applicable law or regulation. Any person may choose to report any such concerns to their leader or any Company leader, Human Resources, Legal & Compliance, any member of Woodwards
Business Conduct Oversight Committee, any Company Officer, or any member of the Companys Board of Directors. Additionally, Woodward has established an Ethics Help Line, facilitated by a third party, that employees can contact to report concerns, anonymously or with attribution at the employees election. The ethics policy and reporting mechanisms are set forth in the Woodward Code of Business Conduct and Ethics, and the concepts are reinforced in annual employee and leader ethics trainings. Investigations of alleged violations are handled by a Company-level Business Conduct Oversight Committee and overseen by the Audit Committee of the Board of Directors.
Woodward suppliers are encouraged to contact their Woodward point of contact or the Ethics Help Line if they believe elements of Woodward direction may cause them to be noncompliant with Woodwards stated social responsibility goals and compliance requirements. Woodward GSC members are also available to help our direct suppliers with compliance issues they may have with their suppliers regarding our flow down contract requirements. Suppliers conflict minerals representatives may also contact Woodwards product material compliance team, who will facilitate the appropriate guidance or resolution regarding such issues. Further, Woodward has adopted a Supplier Code of Conduct, which can be found at https://www.woodward.com/en/about/supplier-overview/supplier-code-of-conduct.
2. | Identify and assess risks in the supply chain |
Woodward is a downstream manufacturer. As such, Woodward does not control the origin or composition of many of the materials provided by our suppliers. Consequently, we ask our suppliers to inquire, identify, and conduct data collection and due diligence activities, which in turn are fundamental elements of our due diligence activities. Woodward conducts analyses of the data collected from our first-tier suppliers for accuracy and completeness in order to identify and assess risks in the Woodward supply chain. This includes:
| The initial smelter checklist analysis contained in the CMRT |
| Assent validation of smelter or refiner (SOR) lists in the supplier CMRTs, using an extensive database consisting of the RMI, Responsible Jewelry Network, and London Bullion Market Association validated SOR lists, and the results of Assents extensive internal and independent SOR validation efforts |
| The indirect analysis input that Woodward has acquired as a result of submitting interim roll-up CMRTs to our customers and receiving analysis results from the various software applications they use |
In 2015, Woodward started (on a manual basis) to use both the publicly available RMI SOR list, and the RMI compliance and country of origin databases available through our RMI membership. Since then, we have continued that approach and have applied it to the roll-up Woodward CMRT that ACP generates from our valid supplier CMRTs. As it becomes available via RMI or ACP, Woodward intends to utilize the certification results of sources certified to the Fairtrade Standard for Gold and Precious Metals.
For suppliers smelter inputs that are still undetermined (i.e., the source has not been confirmed as a smelter, or its conflict-free sourcing status has not been identified through the above validation programs), ACP automatically provides a corrective action request to suppliers having such inputs. Assent and Woodward jointly work with suppliers needing additional assistance to correct or eliminate these undetermined inputs as appropriate.
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our RCOI process is described in our Form SD.
3. | Design and implement a strategy to respond to identified risks |
a. | Report and implement a strategy to respond to identified risks |
As noted above, the product materials compliance Core Team and/or its leader reports at various times throughout the year to Global Supply Chain leadership and other Woodward executive leadership. In 2020, Woodward continued to work closely with Assent to perform assessments of supplier-provided SOR data as described in the Woodward Calendar Year 2020 Due Diligence Results section of this Report.
| Woodward conducts periodic supplier reviews by commodity grouping with the Corporate Vice President of Global Supply Chain and the commodity directors. |
| The periodic reviews conducted by each business group president include a review of supply chain issues for that business group. |
| Each year, senior Global Supply Chain leadership engage in a strategic planning review and a mid-year review with senior management of the Company, including with the Companys Chief Executive Officer, Chief Financial Officer and Chief Operating Officer, to provide, at the highest level of management, strategic oversight of our supply chain strategies and performance. |
b. | Devise and adopt a risk management plan |
Woodward has several formal procedures and tools that form the foundation of the conflict minerals aspects of our risk management plan. These procedures and tools include but are not limited to our supplier approval process, our purchasing procedures, our purchase order and supplier agreement terms and conditions (described in Due Diligence section 1d above), our supplier registration portal and our Parts Transition Process, as well as the evaluation of other existing and possible future software solutions. In addition, Assent and ACP enable us to perform a risk assessment of, and assign a risk rating to, each supplier CMRT we receive.
c. | Implement a risk mitigation plan |
Woodward is continuing to develop a risk management and mitigation plan providing for actions to be taken should Woodward determine any conflict minerals are sourced from conflict-affected areas of Covered Countries. This started with Woodward co-signing, together with more than 40 other companies, an annual letter coordinated by Assent. Beginning in 2017, this letter was sent to every SOR that has not completed or that was not actively participating in an independent conflict-free sourcing practices audit, and was sent to enable the assessment of the use of conflict-free sourcing practices. We continue to participate in this annual letter and we intend to extend this risk mitigation practice by sending letters directly from Woodward to our supply chain.
In 2020, Woodward continued to engage in additional fact finding and risk assessments to identify risks requiring mitigation or after a change in circumstances. These activities are described above. The enhanced inquiry and assessment activities discussed for RCOI in our Form SD also provide additional and refined findings for risk identification and assessment. These activities are discussed in the RCOI Continuous Improvement Actions section at the end of our Form SD.
4. | Carry out independent third-party audits of supply chain due diligence at identified points in the supply chain |
Woodward is significantly downstream in the supply chain from smelters and refiners. In order to obtain SOR information, Woodward seeks information from our upstream suppliers and from third party data aggregating services. Woodward is an RMI member and leverages the RMI Responsible Minerals Assurance Process and the resulting audit data from that program.
5. | Report annually on supply chain due diligence |
The Form SD is posted as one of our many required SEC filings at https://ir.woodward.com/financials/sec-filings/default.aspx. This Report and Woodwards Conflict Minerals Policy can be found at https://www.woodward.com/en/about/corporate-governance/compliance. The Report will be posted within one business week of the filing of these documents with the SEC. Woodward has published a Sustainability Report, which summarizes our Conflict Minerals Policy and provides the context of conflict minerals compliance and objectives within our overall sustainability goals, initiatives and practices. The Sustainability Report is available at https://www.woodward.com/en/about/social-responsibility.
Woodward Calendar Year 2020 Due Diligence Results
Woodward Conflict Minerals Data Requests and Supplier Responses (the Due Diligence in Acquiring Supplier Data)
Because we are continuing to fully integrate Woodward LOrange into our reporting systems, we ran two separate conflict minerals campaigns for the Reporting Period. See Applicable Supplier Identification in our Form SD for information as to how we identified the suppliers we campaigned for 2020.
Woodward, excluding Woodward LOrange, initiated its 2020 campaign via ACP in January 2021 by sending part-level CMRT requests to our suppliers. If suppliers were unable to provide part-level CMRTs, then we accepted company-level CMRTs. We also requested updated supplier contact data. During the campaign, two follow-up inquiries were sent to non-respondents and, where suppliers did not respond, we followed up with three further escalation inquiries. As part of the escalation, Assent separated those suppliers who reported a no 3TG status in 2019 into a separate simplified campaign, asking them if they could confirm their no 3TG status for 2020. Additionally, Woodward twice followed-up with suppliers that returned incomplete or incorrect CMRTs with corrective action requests.
We initiated the 2020 campaign for Woodward LOrange via ACP by sending company-level CMRT requests to Woodward LOrange suppliers on March 1, 2021. Because the Woodward LOrange campaign was initiated during the end stages of Woodwards overall 2020 campaign, no follow-up inquiries were made to Woodward LOrange suppliers.
Summary results for our 2020 campaign, as of April 16, 2021 and inclusive of Woodward LOrange, are as follows:
| We campaigned 1,720 suppliers (compared to 2,205 suppliers in 2019) |
| We received CMRTs from 1,019 suppliers for a response rate of 59% (in 2019, we received CMRTs from 1,060 suppliers for a 48% response rate) |
| 771 suppliers, or 45% of the suppliers we campaigned, returned valid CMRTs (compared to 875, or 44%, in 2019) |
| 166, or 16%, of our supplier CMRT responses were made at the Woodward-requested part or part-family level (compared to 140, or 13%, of CMRT responses last year) |
While our supplier response rate is lower than desired and it remains slightly below its peak in 2018, it did increase in 2020 as compared to 2019. We believe our 2019 response rate was negatively impacted by the onset of the global COVID-19 pandemic during the performance our campaign, and also that the COVID-19 pandemic continued to exert downward pressure on our supplier response rate in 2020. Further, based on feedback received from suppliers and the nature of certain supplier responses, supplier interest in compliance with customer requests and the general conflict minerals program appears to have waned over the past few years. Additionally, also based on the nature of certain supplier responses, it appears that some upstream suppliers continue to believe they only need to provide information related to sales made during the current Reporting Period. However, Woodward and other downstream customers in many cases use components purchased in prior years within the products they introduce into the stream of commerce during the current Reporting Period. This results in a need from Woodward and other downstream suppliers for CMRT data from prior timeframes that can be challenging to acquire.
Supplier Response Assessment (Smelter Determination Due Diligence)
ACP generated an integrated roll-up CMRT from all valid supplier CMRTs received as of April 16, 2021. This resulted in 313 SORs with RMI identification numbers who provide, through our supply chain, conflict minerals used in Woodwards products. See Exhibit A to this Report for a list of these 313 SORs. Woodward conducts no direct transactions and has no contractual relationship with these SORs or their sources of ore.
We used RMIs SOR compliance status data and the results of our 2020 campaign, in each case as of April 16, 2021, to evaluate the 313 SORs with respect to RMI compliance. The summarized results are as follows:
| 236 SORs were determined by RMI to be conformant, meaning the SOR has been verified as having completed a responsible mineral sourcing validation program |
| 15 SORs are designated by RMI as active, meaning the SOR has begun participating in a responsible mineral sourcing validation program |
| 45 SORs are in communication, in vetting or awaiting outreach with RMI for audits |
| 8 SORs are designated by RMI as non-conformant (compared to 7 in the prior year) |
| 9 SORs had other RMI designations |
We intend to conduct further investigations into the eight SORs found to be non-conformant to identify the suppliers using these SORs to the extent possible and determine if that use relates to any items we procure from those suppliers. We have also identified specific suppliers that source from one or more of 5 other SORs that are categorized as high risk based on the sourcing practices and relationships of the applicable SOR. Woodward will conduct an outreach to these suppliers via Assent to request that they encourage these SORs to participate in a responsible mineral sourcing validation program, and/or to encourage and facilitate these suppliers migration to alternate, acceptable SORs.
Smelter or Refiner Mine Country of Origin Results
Mine country of origin data was available for 234 of the 236 conformant SORs. Of these 234 SORs, the mine country of origin data for 65 were provided on an aggregate basis to RMI by the London Bullion Market Association (LBMA). See Exhibit B to this Report for our country of origin findings as of April 16, 2021.
Concluding Statement
Woodward continues to make year-over-year progress relative to supplier conflict minerals risk analysis, SOR identification and mine country of origin through improvements in our due diligence activity, our greater use of the ACP and other Assent services, and our association memberships. The combined availability of RMI and LBMA audit results provided Woodward the most comprehensive mine country of origin data to date. However, because: (i) Woodward has not yet achieved a 100% supplier response rate; (ii) a significant majority of our supplier responses are still at a company level and not yet focused on Woodward specific parts; and (iii) complete SOR conflict status and mine country of origin data is not yet available from centralized sources specializing in the collection and assessment of such data, Woodward does not have sufficiently complete or discriminating data at this time to confirm the conflict-free or may-not-be-conflict-free status of any of its product families or individual products. We have also found that many supplier respondents have supply chains using SORs that were not conformant to a responsible mineral sourcing validation program, and we will continue to actively address this issue to mitigate and eventually eliminate such usage. Woodward is continuing its efforts and progress on the improvement actions described above.
Exhibit A: Smelter and Refiner List
Metal | Standard Smelter Name | Smelter Facility Location | Smelter ID | Source of Smelter Identification Number | ||||
Gold | 8853 S.p.A. | ITALY | CID002763 | RMI | ||||
Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 | RMI | ||||
Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 | RMI | ||||
Gold | African Gold Refinery | UGANDA | CID003185 | RMI | ||||
Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 | RMI | ||||
Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 | RMI | ||||
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | RMI | ||||
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | RMI | ||||
Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 | RMI | ||||
Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | RMI | ||||
Gold | Asahi Pretec Corp. | JAPAN | CID000082 | RMI | ||||
Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | RMI | ||||
Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 | RMI | ||||
Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 | RMI | ||||
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | RMI | ||||
Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 | RMI | ||||
Gold | Aurubis AG | GERMANY | CID000113 | RMI | ||||
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | RMI | ||||
Gold | Boliden AB | SWEDEN | CID000157 | RMI | ||||
Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | RMI | ||||
Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | CID003421 | RMI | ||||
Gold | Caridad | MEXICO | CID000180 | RMI | ||||
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | RMI | ||||
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 | RMI | ||||
Gold | CGR Metalloys Pvt Ltd. | INDIA | CID003382 | RMI |
Gold | Chimet S.p.A. | ITALY | CID000233 | RMI | ||||
Gold | Chugai Mining | JAPAN | CID000264 | RMI | ||||
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | RMI | ||||
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 | RMI | ||||
Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | CID003348 | RMI | ||||
Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 | RMI | ||||
Gold | Dowa | JAPAN | CID000401 | RMI | ||||
Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 | RMI | ||||
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | RMI | ||||
Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | CID000425 | RMI | ||||
Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | CID003424 | RMI | ||||
Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | CID003425 | RMI | ||||
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 | RMI | ||||
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 | RMI | ||||
Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | CID002584 | RMI | ||||
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 | RMI | ||||
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 | RMI | ||||
Gold | Gold Coast Refinery | GHANA | CID003186 | RMI | ||||
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 | RMI | ||||
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | RMI | ||||
Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | RMI | ||||
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 | RMI | ||||
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 | RMI | ||||
Gold | Heimerle + Meule GmbH | GERMANY | CID000694 | RMI | ||||
Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 | RMI | ||||
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | RMI | ||||
Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | RMI | ||||
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 | RMI | ||||
Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 | RMI | ||||
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | RMI |
Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | CID002562 | RMI | ||||
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | RMI | ||||
Gold | Istanbul Gold Refinery | TURKEY | CID000814 | RMI | ||||
Gold | Italpreziosi | ITALY | CID002765 | RMI | ||||
Gold | JALAN & Company | INDIA | CID002893 | RMI | ||||
Gold | Japan Mint | JAPAN | CID000823 | RMI | ||||
Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | RMI | ||||
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | RMI | ||||
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | RMI | ||||
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | RMI | ||||
Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 | RMI | ||||
Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 | RMI | ||||
Gold | Kazzinc | KAZAKHSTAN | CID000957 | RMI | ||||
Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 | RMI | ||||
Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 | RMI | ||||
Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 | RMI | ||||
Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 | RMI | ||||
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | RMI | ||||
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 | RMI | ||||
Gold | Lazurde Company For Jewelry | SAUDI ARABIA | CID001032 | RMI | ||||
Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | RMI | ||||
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | RMI | ||||
Gold | LOrfebre S.A. | ANDORRA | CID002762 | RMI | ||||
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | RMI | ||||
Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | CID000689 | RMI | ||||
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | RMI | ||||
Gold | Marsam Metals | BRAZIL | CID002606 | RMI | ||||
Gold | Materion | UNITED STATES OF AMERICA | CID001113 | RMI | ||||
Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | RMI | ||||
Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | RMI |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | RMI | ||||
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | RMI | ||||
Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | RMI | ||||
Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 | RMI | ||||
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 | RMI | ||||
Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | RMI | ||||
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | RMI | ||||
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | RMI | ||||
Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 | RMI | ||||
Gold | Morris and Watson | NEW ZEALAND | CID002282 | RMI | ||||
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | RMI | ||||
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 | RMI | ||||
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | RMI | ||||
Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 | RMI | ||||
Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | RMI | ||||
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | RMI | ||||
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 | RMI | ||||
Gold | OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | RMI | ||||
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | RMI | ||||
Gold | PAMP S.A. | SWITZERLAND | CID001352 | RMI | ||||
Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 | RMI | ||||
Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | RMI | ||||
Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 | RMI | ||||
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | RMI | ||||
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | RMI | ||||
Gold | PX Precinox S.A. | SWITZERLAND | CID001498 | RMI | ||||
Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 | RMI | ||||
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | RMI | ||||
Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 | RMI |
Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 | RMI | ||||
Gold | Royal Canadian Mint | CANADA | CID001534 | RMI | ||||
Gold | SAAMP | FRANCE | CID002761 | RMI | ||||
Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 | RMI | ||||
Gold | Safimet S.p.A | ITALY | CID002973 | RMI | ||||
Gold | SAFINA A.S. | CZECH REPUBLIC | CID002290 | RMI | ||||
Gold | Sai Refinery | INDIA | CID002853 | RMI | ||||
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | RMI | ||||
Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 | RMI | ||||
Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | RMI | ||||
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 | RMI | ||||
Gold | Shandong Humon Smelting Co., Ltd. | CHINA | CID002525 | RMI | ||||
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | RMI | ||||
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | RMI | ||||
Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | CID002527 | RMI | ||||
Gold | Shirpur Gold Refinery Ltd. | INDIA | CID002588 | RMI | ||||
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | RMI | ||||
Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 | RMI | ||||
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | RMI | ||||
Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 | RMI | ||||
Gold | Sovereign Metals | INDIA | CID003383 | RMI | ||||
Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 | RMI | ||||
Gold | Sudan Gold Refinery | SUDAN | CID002567 | RMI | ||||
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | RMI | ||||
Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 | RMI | ||||
Gold | T.C.A S.p.A | ITALY | CID002580 | RMI | ||||
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | RMI | ||||
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | RMI | ||||
Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | RMI | ||||
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | RMI |
Gold | Tony Goetz NV | BELGIUM | CID002587 | RMI | ||||
Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 | RMI | ||||
Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | RMI | ||||
Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | RMI | ||||
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | RMI | ||||
Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 | RMI | ||||
Gold | Valcambi S.A. | SWITZERLAND | CID002003 | RMI | ||||
Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 | RMI | ||||
Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | RMI | ||||
Gold | Yamakin Co., Ltd. | JAPAN | CID002100 | RMI | ||||
Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 | RMI | ||||
Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | RMI | ||||
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | RMI | ||||
Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 | RMI | ||||
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 | RMI | ||||
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 | RMI | ||||
Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 | RMI | ||||
Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | RMI | ||||
Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 | RMI | ||||
Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 | RMI | ||||
Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 | RMI | ||||
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 | RMI | ||||
Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | RMI | ||||
Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 | RMI | ||||
Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 | RMI | ||||
Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 | RMI | ||||
Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | RMI | ||||
Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 | RMI | ||||
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 | RMI | ||||
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 | RMI |
Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 | RMI | ||||
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | RMI | ||||
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | RMI | ||||
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 | RMI | ||||
Tantalum | KEMET Blue Metals | MEXICO | CID002539 | RMI | ||||
Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 | RMI | ||||
Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | RMI | ||||
Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 | RMI | ||||
Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 | RMI | ||||
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | RMI | ||||
Tantalum | NPM Silmet AS | ESTONIA | CID001200 | RMI | ||||
Tantalum | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | CID002847 | RMI | ||||
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 | RMI | ||||
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 | RMI | ||||
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 | RMI | ||||
Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 | RMI | ||||
Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 | RMI | ||||
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | RMI | ||||
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 | RMI | ||||
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 | RMI | ||||
Tin | Alpha | UNITED STATES OF AMERICA | CID000292 | RMI | ||||
Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | RMI | ||||
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 | RMI | ||||
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 | RMI | ||||
Tin | China Tin Group Co., Ltd. | CHINA | CID001070 | RMI | ||||
Tin | CV Ayi Jaya | INDONESIA | CID002570 | RMI | ||||
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 | RMI | ||||
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | CID003356 | RMI | ||||
Tin | Dowa | JAPAN | CID000402 | RMI |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | CID002572 | RMI | ||||
Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 | RMI | ||||
Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 | RMI | ||||
Tin | Fenix Metals | POLAND | CID000468 | RMI | ||||
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | CID003410 | RMI | ||||
Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 | RMI | ||||
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | RMI | ||||
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 | RMI | ||||
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 | RMI | ||||
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | RMI | ||||
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 | RMI | ||||
Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 | RMI | ||||
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 | RMI | ||||
Tin | Luna Smelter, Ltd. | RWANDA | CID003387 | RMI | ||||
Tin | Maanshan Weitai Tin Co., Ltd. | CHINA | CID003379 | RMI | ||||
Tin | Magnus Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 | RMI | ||||
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | RMI | ||||
Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 | RMI | ||||
Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 | RMI | ||||
Tin | Metallo Belgium N.V. | BELGIUM | CID002773 | RMI | ||||
Tin | Metallo Spain S.L.U. | SPAIN | CID002774 | RMI | ||||
Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 | RMI | ||||
Tin | Minsur | PERU | CID001182 | RMI | ||||
Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 | RMI | ||||
Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 | RMI | ||||
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | RMI | ||||
Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | CID001305 | RMI | ||||
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 | RMI | ||||
Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 | RMI |
Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 | RMI | ||||
Tin | Pongpipat Company Limited | MYANMAR | CID003208 | RMI | ||||
Tin | Precious Minerals and Smelting Limited | INDIA | CID003409 | RMI | ||||
Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 | RMI | ||||
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 | RMI | ||||
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 | RMI | ||||
Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 | RMI | ||||
Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 | RMI | ||||
Tin | PT Bangka Serumpun | INDONESIA | CID003205 | RMI | ||||
Tin | PT Bukit Timah | INDONESIA | CID001428 | RMI | ||||
Tin | PT Cipta Persada Mulia | INDONESIA | CID002696 | RMI | ||||
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 | RMI | ||||
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 | RMI | ||||
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 | RMI | ||||
Tin | PT Prima Timah Utama | INDONESIA | CID001458 | RMI | ||||
Tin | PT Rajawali Rimba Perkasa | INDONESIA | CID003381 | RMI | ||||
Tin | PT Rajehan Ariq | INDONESIA | CID002593 | RMI | ||||
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 | RMI | ||||
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 | RMI | ||||
Tin | PT Timah Nusantara | INDONESIA | CID001486 | RMI | ||||
Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 | RMI | ||||
Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 | RMI | ||||
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 | RMI | ||||
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 | RMI | ||||
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 | RMI | ||||
Tin | Soft Metais Ltda. | BRAZIL | CID001758 | RMI | ||||
Tin | Super Ligas | BRAZIL | CID002756 | RMI | ||||
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | CID002834 | RMI | ||||
Tin | Thaisarco | THAILAND | CID001898 | RMI | ||||
Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 | RMI |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | RMI | ||||
Tin | VQB Mineral and Trading Group JSC | VIET NAM | CID002015 | RMI | ||||
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 | RMI | ||||
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | RMI | ||||
Tin | Yunnan Tin Company Limited | CHINA | CID002180 | RMI | ||||
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | CID003397 | RMI | ||||
Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 | RMI | ||||
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 | RMI | ||||
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | CID003427 | RMI | ||||
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | RMI | ||||
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 | RMI | ||||
Tungsten | China Molybdenum Co., Ltd. | CHINA | CID002641 | RMI | ||||
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 | RMI | ||||
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000281 | RMI | ||||
Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | CID003401 | RMI | ||||
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 | RMI | ||||
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 | RMI | ||||
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 | RMI | ||||
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 | RMI | ||||
Tungsten | GEM Co., Ltd. | CHINA | CID003417 | RMI | ||||
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 | RMI | ||||
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 | RMI | ||||
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 | RMI | ||||
Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 | RMI | ||||
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 | RMI | ||||
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 | RMI | ||||
Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 | RMI | ||||
Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 | RMI | ||||
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 | RMI |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 | RMI | ||||
Tungsten | Jiangxi Minmetals Gaoan Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | RMI | ||||
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 | RMI | ||||
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 | RMI | ||||
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 | RMI | ||||
Tungsten | JSC Kirovgrad Hard Alloys Plant | RUSSIAN FEDERATION | CID003408 | RMI | ||||
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 | RMI | ||||
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 | RMI | ||||
Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | CID003388 | RMI | ||||
Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID003407 | RMI | ||||
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 | RMI | ||||
Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 | RMI | ||||
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 | RMI | ||||
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 | RMI | ||||
Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | CID003416 | RMI | ||||
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 | RMI | ||||
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 | RMI | ||||
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 | RMI | ||||
Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 | RMI | ||||
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | RMI | ||||
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 | RMI | ||||
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 | RMI |
Exhibit B: Mine Country of Origin Data
Country of Origin - Mined Materials |
Mineral | |||||||
Argentina | Gold | |||||||
Australia | Gold | Tantalum | Tin | Tungsten | ||||
Austria | Tungsten | |||||||
Azerbaijan | Gold | |||||||
Benin | Gold | |||||||
Bolivia (Plurinational State of) | Gold | Tantalum | Tin | Tungsten | ||||
Botswana | Gold | |||||||
Brazil | Gold | Tantalum | Tin | Tungsten | ||||
Burkina Faso | Gold | |||||||
Burundi* | Tantalum | Tin | Tungsten | |||||
Canada | Gold | |||||||
Chile | Gold | |||||||
China | Gold | Tantalum | Tin | Tungsten | ||||
Colombia | Gold | Tantalum | Tin | Tungsten | ||||
Congo, Democratic Republic of the* | Gold | Tantalum | Tin | Tungsten | ||||
Costa Rica | Gold | |||||||
Cote dIvoire | Gold | |||||||
Cuba | Gold | |||||||
Cyprus | Gold | |||||||
Dominican Republic | Gold | |||||||
Ecuador | Gold | |||||||
Egypt | Gold | |||||||
Eritrea | Gold | |||||||
Ethiopia | Gold | Tantalum | ||||||
Fiji | Gold | |||||||
France | Tantalum | |||||||
French Guiana | Gold | |||||||
Georgia | Gold | |||||||
Germany | Tantalum | |||||||
Ghana | Gold | |||||||
Guatemala | Gold | |||||||
Guinea | Gold | |||||||
Guyana | Gold | |||||||
Honduras | Gold | |||||||
India | Tantalum | |||||||
Indonesia | Gold | Tin | ||||||
Iran | Gold | |||||||
Ivory Coast | Gold | |||||||
Japan | Gold | |||||||
Kazakhstan | Gold | Tungsten |
Kenya | Gold | |||||||
Laos | Gold | Tin | ||||||
Liberia | Gold | |||||||
Madagascar | Tantalum | |||||||
Malaysia | Gold | Tantalum | Tin | Tungsten | ||||
Mali | Gold | |||||||
Mauritania | Gold | |||||||
Mexico | Gold | Tungsten | ||||||
Mongolia | Gold | Tin | Tungsten | |||||
Morocco | Gold | |||||||
Mozambique | Gold | Tantalum | ||||||
Myanmar | Tantalum | Tin | Tungsten | |||||
Namibia | Gold | Tantalum | ||||||
Netherlands | Gold | |||||||
New Zealand | Gold | |||||||
Nicaragua | Gold | |||||||
Niger | Gold | |||||||
Nigeria | Tantalum | Tin | Tungsten | |||||
Papua New Guinea | Gold | |||||||
Peru | Gold | Tin | Tungsten | |||||
Philippines | Gold | |||||||
Portugal | Tin | Tungsten | ||||||
Puerto Rico | Gold | |||||||
Russian Federation | Gold | Tantalum | Tin | Tungsten | ||||
Rwanda* | Gold | Tantalum | Tin | |||||
Saudi Arabia | Gold | |||||||
Senegal | Gold | |||||||
Serbia | Gold | |||||||
Sierra Leone | Gold | Tantalum | ||||||
Slovakia | Gold | |||||||
Solomon Islands | Gold | |||||||
South Africa | Gold | |||||||
Spain | Gold | Tantalum | Tin | Tungsten | ||||
Suriname | Gold | |||||||
Swaziland | Gold | |||||||
Sweden | Gold | |||||||
Taiwan | Tin | |||||||
Tajikistan | Gold | |||||||
Tanzania* | Gold | |||||||
Thailand | Tantalum | Tin | Tungsten | |||||
Turkey | Gold | |||||||
Uganda* | Gold | Tantalum | Tin | Tungsten | ||||
United Kingdom | Gold | Tin | Tungsten |
United States of America | Gold | Tin | Tungsten | |||||
Uruguay | Gold | |||||||
Uzbekistan | Tungsten | |||||||
Venezuela | Tin | |||||||
Vietnam | Tin | Tungsten | ||||||
Zambia* | Gold | |||||||
Zimbabwe | Gold | Tantalum | Tungsten |
* | Covered Countries |
Country of Origin - Recycled / Scrap |
Mineral | |||||||
Andorra | Gold | |||||||
Angola* | Tin | |||||||
Argentina | Gold | Tin | ||||||
Armenia | Gold | |||||||
Australia | Gold | Tin | ||||||
Austria | Gold | Tantalum | Tin | Tungsten | ||||
Bahamas | Gold | |||||||
Bangladesh | Tin | |||||||
Belarus | Tin | |||||||
Belgium | Gold | Tin | Tungsten | |||||
Benin | Tin | |||||||
Bolivia | Gold | Tin | ||||||
Botswana | Gold | |||||||
Brazil | Gold | Tin | Tungsten | |||||
Brunei | Gold | |||||||
Bulgaria | Gold | Tin | ||||||
Burkina Faso | Gold | |||||||
Cameroon | Gold | |||||||
Canada | Gold | Tantalum | Tin | Tungsten | ||||
Cayman Islands | Gold | |||||||
Chile | Gold | Tin | ||||||
China | Gold | Tantalum | Tin | Tungsten | ||||
Colombia | Gold | |||||||
Congo, Democratic Republic of the* | Gold | Tin | ||||||
Croatia | Gold | Tin | ||||||
Cyprus | Gold | Tin | ||||||
Czechia | Gold | Tin | Tungsten | |||||
Denmark | Gold | Tin | ||||||
Dominican Republic | Gold | |||||||
Ecuador | Gold |
Egypt | Gold | Tin | ||||||
El Salvador | Gold | Tin | ||||||
Estonia | Gold | Tin | ||||||
Finland | Gold | Tin | ||||||
France | Gold | Tantalum | Tin | Tungsten | ||||
Gabon | Tin | |||||||
Gambia, The | Gold | |||||||
Georgia | Gold | |||||||
Germany | Gold | Tantalum | Tin | Tungsten | ||||
Ghana | Tin | |||||||
Greece | Gold | Tin | ||||||
Guatemala (HR) | Gold | |||||||
Guinea | Tin | |||||||
Honduras (HR) | Gold | |||||||
Hong Kong | Gold | Tin | Tungsten | |||||
Hungary | Gold | Tin | ||||||
Iceland | Gold | |||||||
India | Gold | Tantalum | Tin | |||||
Indonesia | Gold | Tantalum | Tin | |||||
Ireland | Gold | Tantalum | Tin | Tungsten | ||||
Israel | Gold | Tantalum | Tin | Tungsten | ||||
Italy | Gold | Tin | ||||||
Ivory Coast | Gold | |||||||
Japan | Gold | Tantalum | Tin | Tungsten | ||||
Jordan | Gold | Tin | ||||||
Kazakhstan | Gold | Tin | ||||||
Kenya | Gold | |||||||
Korea, Republic of | Gold | |||||||
Kuwait | Gold | |||||||
Kyrgyzstan | Gold | |||||||
Laos | Gold | |||||||
Latvia | Gold | Tin | Tungsten | |||||
Lebanon | Gold | Tin | ||||||
Libya | Tin | |||||||
Liechtenstein | Gold | |||||||
Lithuania | Gold | Tin | ||||||
Luxembourg | Gold | Tin | ||||||
Macau | Gold | |||||||
Madagascar | Gold | |||||||
Malaysia | Gold | Tantalum | Tin | |||||
Malta | Gold | Tin | ||||||
Mauritius | Gold | |||||||
Mexico | Gold |
Monaco | Gold | Tin | ||||||
Morocco | Gold | Tin | ||||||
Netherlands | Gold | Tantalum | Tin | |||||
New Caledonia | Gold | |||||||
New Zealand | Gold | Tin | ||||||
Nigeria | Tin | |||||||
Norway | Gold | Tin | ||||||
Pakistan | Gold | Tin | ||||||
Panama | Gold | |||||||
Panama (HR) | Gold | |||||||
Papua New Guinea | Gold | |||||||
Paraguay | Gold | |||||||
Peru | Gold | Tin | ||||||
Philippines | Gold | Tin | ||||||
Poland | Gold | Tin | ||||||
Portugal | Gold | Tin | ||||||
Puerto Rico | Gold | Tin | ||||||
Qatar | Tin | |||||||
Romania | Gold | Tin | ||||||
Russian Federation | Gold | Tin | Tungsten | |||||
San Marino | Gold | |||||||
Saudi Arabia | Gold | Tin | ||||||
Senegal | Gold | Tin | ||||||
Serbia | Gold | Tin | ||||||
Sierra Leone | Gold | |||||||
Singapore | Gold | Tin | ||||||
Slovakia | Gold | Tin | ||||||
Slovenia | Gold | Tin | ||||||
South Africa | Gold | Tin | ||||||
South Korea | Gold | Tantalum | Tin | Tungsten | ||||
Spain | Gold | Tantalum | Tin | Tungsten | ||||
St Vincent and Grenadines | Gold | |||||||
Sudan | Gold | Tin | ||||||
Sweden | Gold | Tin | ||||||
Switzerland | Gold | Tin | ||||||
Taiwan | Gold | Tantalum | Tin | Tungsten | ||||
Tanzania* | Gold | Tin | ||||||
Thailand | Gold | Tantalum | Tin | Tungsten | ||||
Togo | Gold | Tin | ||||||
Trinidad and Tobago | Gold | |||||||
Tunisia | Gold | Tin | ||||||
Turkey | Gold | Tin | ||||||
Ukraine | Gold | Tin |
United Arab Emirates | Gold | Tin | Tungsten | |||||
United Kingdom | Gold | Tantalum | Tin | |||||
United States of America | Gold | Tantalum | Tin | Tungsten | ||||
Uruguay | Gold | Tin | ||||||
Uzbekistan | Gold | |||||||
Venezuela | Gold | |||||||
Vietnam | Gold | Tungsten | ||||||
Yemen | Tin | |||||||
Zimbabwe | Gold |
* | Covered Countries |