0001094285-16-000231.txt : 20160531 0001094285-16-000231.hdr.sgml : 20160531 20160531132525 ACCESSION NUMBER: 0001094285-16-000231 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20151231 1.02 20151231 FILED AS OF DATE: 20160531 DATE AS OF CHANGE: 20160531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TELEDYNE TECHNOLOGIES INC CENTRAL INDEX KEY: 0001094285 STANDARD INDUSTRIAL CLASSIFICATION: SEARCH, DETECTION, NAVIGATION, GUIDANCE, AERONAUTICAL SYS [3812] IRS NUMBER: 251843385 STATE OF INCORPORATION: DE FISCAL YEAR END: 1228 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 001-15295 FILM NUMBER: 161684919 BUSINESS ADDRESS: STREET 1: 1049 CAMINO DOS RIOS CITY: THOUSAND OAKS STATE: CA ZIP: 91360 BUSINESS PHONE: 805-373-4545 MAIL ADDRESS: STREET 1: 1049 CAMINO DOS RIOS CITY: THOUSAND OAKS STATE: CA ZIP: 91360 SD 1 formsd2016.htm SD Document





UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD
Specialized Disclosure Report


Teledyne Technologies Incorporated
(Exact name of registrant as specified in its charter)


Delaware
(State or other jurisdiction of incorporation)
1-15295
(Commission File Number)
25-1843385
(I.R.S. Employer Identification No.)

1049 Camino Dos Rios
Thousand Oaks, California
(Address of principal executive offices)
91360
(Zip Code)


Melanie S. Cibik, (805) 373-4545
(Name and telephone number 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:

x
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
 
 










Item 1.01. Conflict Minerals Disclosure and Report

Conflict Minerals Disclosure

Teledyne Technologies Incorporated (the “Company”) has determined that columbite-tantalite (tantalum), casserite (tin), gold or wolframite (tungsten) (“conflict minerals”) are necessary to the functionality or production of the products manufactured by Company or contracted by the Company to be manufactured. The Company conducted a reasonable country of origin inquiry to determine whether in the 2015 calendar year the conflict minerals necessary to the functionality or production of a product manufactured by the Company or contracted by the Company to be manufactured originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). After the reasonable country of origin inquiry the Company had reason to believe that its necessary conflict minerals may have originated in the Covered Countries and had reason to believe that they may not be from recycled or scrap sources. As a result, the Company conducted due diligence on the source and chain of custody of those conflict minerals as described in the Conflict Minerals Report filed as Exhibit 1.01 to this Form SD. A copy of the Conflict Minerals Report also can be found on the Company’s website at http://teledyne.com/aboutus/ethics.asp.

Item 1.02. Exhibit

The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.

Item 2.01. Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.


Forward Looking Statements
This Specialized Disclosure Report on Form SD, including the Conflict Minerals Report exhibit, contains forward-looking statements that are based upon management’s expectations and beliefs concerning future events impacting the Company’s conflict minerals compliance and reporting program and use of conflict minerals. Forward-looking statements by their nature address matters that are, to different degrees, uncertain and often contain words such as “may”, “could”, “expect”, “intend”, “plan”, “seek”, “estimate”, “believe”, “predict”, “potential” or “continue”. Certain matters contained herein concerning the future, including risk mitigation steps, constitute forward-looking statements and are based upon management's expectations and beliefs concerning future events. There can be no assurance that these future events will occur as anticipated. Forward-looking statements speak only as of the date they were made, and we undertake no obligation to publicly update them. Readers are urged to read the Company’s periodic reports filed with the Securities and Exchange Commission (“SEC”) for a more complete description of the company, its businesses, its strategies and the various risks that the company faces. Various risks are identified in Teledyne’s 2015 Annual Report on Form 10-K and subsequent Quarterly Reports on Form 10-Q. The company assumes no duty to publicly update or revise any forward-looking statements, whether as a result of new information or otherwise.





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 undersigned hereunto duly authorized.


TELEDYNE TECHNOLOGIES INCORPORATED

By:    /s/ Melanie S. Cibik
Melanie S. Cibik
Senior Vice President, General Counsel and Secretary

Dated May 31, 2016



EX-1.01 2 teledynecmr2016final.htm EXHIBIT 1.01 Exhibit



Teledyne Technologies Incorporated
Conflict Minerals Report
Calendar Year Ending December 31, 2015
May 31, 2016

Introduction
Pursuant to Section 13(p) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and related rules and guidance promulgated by the Securities and Exchange Commission (the “SEC”), including the SEC’s Statement dated April 29, 2014 (the “Conflict Minerals Rule”), if columbite-tantalite (tantalum), casserite (tin), gold or wolframite (tungsten) (“conflict minerals” or “3TG”) are necessary to the functionality or production of a product manufactured by a registrant or contracted by the registrant to be manufactured, the registrant must conduct in good faith a reasonable country of origin inquiry regarding those conflict minerals that is reasonably designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”).
This Conflict Minerals Report (this “Report”) (1) describes the reasonable country of origin inquiry (“RCOI”) and subsequent due diligence efforts undertaken by Teledyne Technologies Incorporated (the “Company”) to determine whether in the 2015 calendar year the conflict minerals necessary to the functionality or production of a product manufactured by the Company or contracted by the Company to be manufactured originated in the Covered Countries and (2) provides additional disclosure required by the Conflict Minerals Rule.
Company Overview
The Company provides enabling technologies for industrial growth markets. The Company has evolved from a company that was primarily focused on aerospace and defense to one that serves multiple markets that require advanced technology and high reliability. These markets include deepwater oil and gas exploration and production, oceanographic research, air and water quality environmental monitoring, electronics design and development, factory automation and medical imaging. The Company’s products include monitoring and control instrumentation for marine and environmental applications, harsh environment interconnects, electronic test and





measurement equipment, digital imaging sensors and cameras, aircraft information management systems, and defense electronics and satellite communication subsystems. The Company also supplies engineered systems for defense, space, environmental and energy applications.
Conflict Minerals Policy
As part of the Company’s due diligence efforts, the Company has adopted a statement on Conflict Minerals which is available at: http://www.teledyne.com/aboutus/ethics.asp
Reasonable Country of Origin Inquiry (RCOI)
After the reasonable country of origin inquiry the Company had reason to believe that its necessary conflict minerals may have originated in the Covered Countries and had reason to believe that they may not be from recycled or scrap sources. In accordance with the Conflict Minerals Rule, the Company conducted due diligence on the source and chain of custody of those conflict minerals. The due diligence approach followed by the Company is intended to meet the criteria set forth in 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, an internationally recognized due diligence framework, and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”).

Description of the RCOI
Due to the wide variety and high mix of products manufactured and sold by the Company, the Company conducted its due diligence with its direct suppliers. In determining which suppliers to survey in 2015, the Company focused on suppliers of materials, parts and components. The Company identified 4,137 suppliers that in the aggregate were responsible for the top 80% of the total annual spending on materials, parts and components at each of the Company’s business units in the fiscal year ended December 28, 2014 (each such supplier an “In-Scope Supplier”).  In-Scope Suppliers also included those suppliers that did not fall within the top 80% of a business unit’s annual spend, but which were known by the business unit with reasonably certainty to provide materials, parts or components that contain Conflict Minerals.

The Company, with the assistance of Assent Compliance (“Assent”), attempted to contact all of the In-Scope Suppliers and provide each with a copy of the Company’s Statement on Conflict Minerals, a Conflict





Minerals Reporting Template version 4.01 (“CMRT”) and instructions on how to complete the CMRT. The CMRT is a standardized reporting template developed by the Conflict-Free Sourcing Initiative (“CFSI”) that facilitates the transfer of information through the supply chain regarding mineral country of origin and smelters and refiners (“SORs”) being utilized. In-Scope Suppliers were instructed to return a completed CMRT to the Company within a certain time period after receipt.

Assent contacted non-responsive suppliers by email a minimum of three times and then by phone a minimum of two to three times. Communications include training and education on the completion of the CMRT form as well as access to a Supplier Resource Center designed to alleviate any remaining confusion with suppliers. All communications were monitored and tracked in Assent's system for future reporting and transparency.

Teledyne’s Conflict Minerals program includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted CMRT forms are accepted and classified as valid or invalid so that data is still retained. Suppliers are contacted in regards to invalid forms and are encouraged to resubmit a valid form.

On the basis of the responses to the Company’s RCOI, the Company is unable to determine that 3TGs necessary to the functionality or production of the Company’s products did not originate in the DRC or any of the Covered Countries. Accordingly, the Company undertook the measures described below to assess the due diligence practices of the SORs listed on its unique smelter list that were known or reasonably believed to have sourced from the DRC or that had unknown sourcing.

Design of Due Diligence Measures
Due Diligence Process
The Company established a Conflict Minerals compliance program that is designed to conform, in all material respects, to the framework in the OECD Guidance.
1    Establish Strong Company Management System Internal Team
1.1    Adopt and commit to a supply chain plan for minerals originating from conflict-affected and high-risk areas





In 2013, the Company adopted an internal Conflict Minerals Assessment Plan (the “Assessment Plan”) incorporating many of the standards set forth in the then current version of the OECD Guidance.
1.2     Structure internal management systems to support supply chain due diligence
The Company has established a management system with respect to the Rule and the obligations thereof. The Company’s management system includes a cross-functional team, the Conflict Minerals Team, which is sponsored by a Conflict Minerals Governance Committee consisting of the Company’s Senior Vice President and General Counsel, the Company’s Chief Operating Officer, and the Company’s Senior Vice President and Chief Financial Officer.. The Conflict Minerals Team is responsible for implementing the Company’s conflict minerals compliance program and is led by the Associate General Counsel who acts as the conflict minerals coordinator. The Conflict Minerals Governance Committee is briefed about the results of the Conflict Minerals Team’s progress and due diligence efforts on a periodic basis.
1.3     Establish a system of controls and transparency over the mineral supply chain
While a portion of the Company’s direct suppliers are also Exchange Act reporting companies which are subject to and knowledgeable about the Conflict Minerals Rule, the Company also has many other suppliers and distributors that are not Exchange Act reporting companies that require additional training to understand the requirements of the Conflict Minerals Rule.
Internal controls include the Company’s on-going initiative of integrating conflict minerals related requirements in its supply agreements that require disclosure of 3TGsconflict minerals.
The Company developed a record retention requirement for information relating to the management of its conflict minerals compliance process. All relevant records will be retained for a period of 5 years. In addition, Assent retains all information gathered during the supply survey portion of the Company’s conflict minerals program for the same 5 year period.
1.4    Strengthen company engagement with suppliers
With respect to the OECD requirement to strengthen engagement with suppliers, the Company has utilized the CMRT version 4.01 and the Assent Compliance Manager web-based reporting tool for collecting conflict minerals declarations from the Company’s supplier base. The use of these tools has allowed the Company to assist





its suppliers in understanding the Company’s expectations and requirements and increase the rate of responses the Company has received from its suppliers to the Company’s survey requests.
Additionally, as identified earlier, the Company’s procurement organization continues to integrate contract provisions related to conflict minerals disclosure requirements language into new supply agreements or renewals of existing supply agreements during the course of negotiations. Accordingly, the Company is continuing its attempts to confirm suppliers have implemented processes to identify the origin of 3TGs.
1.5    Establish a company level grievance mechanism
The Company has established a confidential Corporate Ethics/Help Line, with the theme, "Take The Right Action." The Ethics/Help line is available to all Company employees, as well as concerned individuals outside the company. Violations of Company policies, including those related to conflict minerals, may be reported via this Ethics/Help Line. The toll free help line number is 1-877-666-6968.
2    Identify and assess risk in the supply chain
In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as DRC-Conflict Free by third party sources such as the CFSI or the London Bullion Market Association (“LBMA”) Responsible Gold Programme, pose a significant risk. Assent rates the risk of SORs as High, Medium or Low. This rating is based on various factors, including whether the SOR has been certified conflict free, has committed to a third-party audit, and the smelter’s geographic location, including proximity to the Covered Countries.
Assent verified, to the best of its knowledge, whether the metals processors identified by each supplier on its CMRT are actually SORs or recyclers of 3TGs by comparing facilities reported by suppliers to the CFSI Standard Smelter List and conducting its own independent research. If an SOR was not certified by an internationally-recognized scheme, Assent attempted to contact the SOR to gather more information about its sourcing practices. In addition, internet research was performed to determine whether there was any publicly available sources of information regarding the SOR’s sourcing.
Assent calculates supplier risk based on the chances that a supplier provides 3TGs that may originate from Non-Conflict Free sources. The value of this risk is calculated based on the risk ratings of the smelters declared by that Supplier on their CMRT.





Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
•    Does the supplier have a policy in place that includes DRC conflict-free sourcing?
•    Has the supplier implemented due diligence measures for conflict-free sourcing?
•    Does the supplier verify due diligence information received from its suppliers?
•    Does the supplier verification process include corrective action management?
Based on a supplier’s answers to these criteria, the supplier’s program is deemed to be either strong or weak.
As part of the Company’s Assessment Plan and to ensure suppliers understand the Company’s expectations, Assent provides video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.
Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in the Company’s supply chain. The Company determined that seeking information about 3TG smelters and refiners in its supply chain represents the most reasonable effort the Company can make to determine the mines or locations of origin of the 3TGs in its supply chain. This was done by adopting methodology outlined by the EICC and programs and outreach initiatives and requiring the Company’s suppliers to report to the Company using the CMRT. Through this industry joint effort, the Company made reasonable determination of the mines or locations of origin of the 3TGs in its supply chain.
3.    Design and implement a strategy to respond to identified risks
The Company has developed and continues to use a risk management approach to implement due diligence activities concerning 3TGs and the potential presence of conflict minerals.
The Company’s current strategy to respond to supply chain risks, as described in the Company’s Assessment Plan, is that if the Company become aware of a supplier whose supply chain includes 3TGs that are not conflict free, the Company will take appropriate steps to address the situation in a timely manner, including supplier education and/or reassessment of the supplier relationship. To date, the Company has found no instances where it was necessary to terminate a contract or find a replacement material or supplier.





If suppliers did not provide information as requested, or the data did not appear to be reliable or was conflicting, the Conflict Minerals Team developed a plan to send additional communications, offer additional education, or, if necessary, have the Company’s procurement organization engage with the supplier.
4.    Carry out independent third-party audit of the supply chain due diligence at identified points in the supply chain
As a downstream purchaser of conflict minerals, the Company’s due diligence process is based on the necessity of relying on data obtained from its direct suppliers. The Company also relies on information collected and provided by other external audit programs. As such, the Company has not conducted third- party audits of any smelters or refiners.
5.    Report on Supply Chain Due Diligence
This Conflict Minerals Report is on file with the SEC and is publicly available on the Company’s website at http://teledyne.com/aboutus/ethics.asp.

Results of Due Diligence
The Company, through Assent’s software platform, surveyed a total of 4,137 suppliers. Of the 2,177 responses, 219 were determined to be out of scope, 157 were deemed invalid and marked for follow-up, and 1,801 were accepted as complete. This is an overall response rate of 53%.

Smelters or Refiners
The large majority of the responses received from the supplier survey provided data at a company or divisional level or were unable to specify the smelters or refiners used for components supplied to the Company. The Company was therefore unable to determine whether the 3TGs reported by the suppliers were contained in components or parts supplied to the Company. Furthermore, suppliers did not always provide smelter lists nor were the smelter lists consistently completed with smelter identification numbers, and therefore the Company was unable to validate that any of these smelters or refiners are actually in its supply chain.






The current efforts focus on gathering smelter information via the CMRT and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of 3TGs to their location of origin. Seeking information about 3TG smelters and refiners in the Company’s supply chain represents the most reasonable effort the Company can make to determine the mines or locations of origin of 3TGs in its supply chain.

Certain of the responses provided by suppliers to the CMRT did include the names of facilities listed by the suppliers as smelters or refiners. The Company does not typically have a direct relationship with 3TG smelters and refiners and does not perform or direct audits of these entities within its supply chain. Assent compared facilities listed in the supplier responses to the list of smelters maintained by the CFSI and the LBMA and, if a supplier indicated that the facility was certified as conflict-free, confirmed that the name was listed by CFSI. Based on the smelter lists provided by suppliers via the CMRTs, the Company is aware that 214 smelters are certified conflict-free, and a number of other smelters are active in the CFSP third-party audit process.

As of May 2, 2016, the Company has validated 320 smelters or refiners and is working to validate the additional smelter and refiner entries from the submitted CMRTs. The table set forth on Annex 1 to this Report lists the valid smelters identified by suppliers the Company surveyed. The table set forth on Annex 2 lists the countries from which the minerals processed by the SORs in Annex 1 are believed to have originated. As noted above, since the Company’s suppliers generally provided facility information via the CMRT at the company or divisional level, and generally did not limit their CMRT responses to facility information for 3TGs in products they supply to the Company specifically, 3TGs contained in the Company’s products did not necessarily originate in the facilities listed in Annex 1 or the countries listed in Annex 2.
Many suppliers are still unable to provide the smelters or refiners used for materials supplied to the Company. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs.

Risk Mitigation Steps
Year four of the Company’s conflict minerals program will continue to focus on vetting smelter data, which may include the following actions:
Working with suppliers to move to version 4.10 of the CMRT where new smelter identification numbers have been assigned;





Requiring the use of smelter identification numbers;
Requesting that suppliers connect any identified smelters with the products and parts the suppliers supply to the Company; and
Comparing smelters reported by suppliers on the CMRT to the Conflict-Free Sourcing Initiative’s list of smelters.    
The Company intends to take additional steps to improve its due diligence process and to further mitigate any risk that the necessary conflict minerals in its products could benefit armed groups in the Covered Countries, which may include the following:
•     Include a conflict minerals flow-down clause in new or renewed supplier contracts;
•     Refine the number of suppliers requested to supply information;
•     Engage with suppliers and direct them to training resources to increase the response rate and improve the content of the supplier survey responses; and
•     Engage any suppliers found to be providing the Company with conflict minerals from sources that support conflict in the Covered Countries to establish an alternative source of conflict minerals that does not support such conflict.

In accordance with the Conflict Minerals Rule, a copy of this Report will be posted on the Company’s website at http://teledyne.com/aboutus/ethics.asp.







Annex 1
The following is a list of verified SORs that the suppliers surveyed by the Company reported as being in their supply chains. An affirmative answer in the ‘Conflict-Free?’ column indicates completion of the CFSI’s Conflict-Free Smelter Program third-party audit certifying conflict-free sourcing.
Metal
Standard Smelter Name
Facility Location
Conflict- Free?
Gold
Advanced Chemical Company
UNITED STATES
 
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Yes
Gold
Aktyubinsk Copper Company TOO
KAZAKHSTAN
 
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
 
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Yes
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
 
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Yes
Gold
Argor-Heraeus SA
SWITZERLAND
Yes
Gold
Asahi Pretec Corporation
JAPAN
Yes
Gold
Asahi Refining Canada Limited
CANADA
Yes
Gold
Asahi Refining USA Inc.
UNITED STATES
Yes
Gold
Asaka Riken Co., Ltd.
JAPAN
Yes
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
 
Gold
Aurubis AG
GERMANY
Yes
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Yes
Gold
Bauer Walser AG
GERMANY
 
Gold
Boliden AB
SWEDEN
Yes
Gold
C. Hafner GmbH + Co. KG
GERMANY
Yes
Gold
Caridad
MEXICO
 
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Yes
Gold
Cendres + Métaux SA
SWITZERLAND
 
Gold
Chimet S.p.A.
ITALY
Yes
Gold
Chugai Mining
JAPAN
 
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
 
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
 
Gold
Do Sung Corporation
KOREA, REPUBLIC OF
 
Gold
DODUCO GmbH
GERMANY
Yes
Gold
Dowa
JAPAN
Yes
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Yes
Gold
Elemetal Refining, LLC
UNITED STATES
Yes
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Yes
Gold
Faggi Enrico S.p.A.
ITALY
 
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
 
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
 
Gold
Geib Refining Corporation
UNITED STATES
 





Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
 
Gold
Guangdong Jinding Gold Limited
CHINA
 
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
 
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
 
Gold
Heimerle + Meule GmbH
GERMANY
Yes
Gold
Heraeus Ltd. Hong Kong
CHINA
Yes
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Yes
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
 
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
 
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
CHINA
Yes
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Yes
Gold
Istanbul Gold Refinery
TURKEY
Yes
Gold
Japan Mint
JAPAN
Yes
Gold
Jiangxi Copper Company Limited
CHINA
Yes
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Yes
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Yes
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Yes
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
 
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
 
Gold
Kazzinc
KAZAKHSTAN
Yes
Gold
Kennecott Utah Copper LLC
UNITED STATES
Yes
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
 
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Yes
Gold
Korea Metal Co., Ltd.
KOREA, REPUBLIC OF
 
Gold
Korea Zinc Co. Ltd.
KOREA, REPUBLIC OF
 
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
 
Gold
L' azurde Company For Jewelry
SAUDI ARABIA
 
Gold
Lingbao Gold Company Limited
CHINA
 
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
 
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Yes
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
 
Gold
Materion
UNITED STATES
Yes
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Yes
Gold
Metahub Industries Sdn. Bhd.
MALAYSIA
 
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Yes
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Yes
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
 
Gold
Metalor Technologies SA
SWITZERLAND
Yes
Gold
Metalor USA Refining Corporation
UNITED STATES
Yes





Gold
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V
MEXICO
Yes
Gold
Mitsubishi Materials Corporation
JAPAN
Yes
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Yes
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Yes
Gold
Morris and Watson
NEW ZEALAND
 
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Yes
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Yes
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
 
Gold
Nihon Material Co., Ltd.
JAPAN
Yes
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Yes
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Yes
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Yes
Gold
OJSC Kolyma Refinery
RUSSIAN FEDERATION
 
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Yes
Gold
PAMP SA
SWITZERLAND
Yes
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
 
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Yes
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Yes
Gold
PX Précinox SA
SWITZERLAND
Yes
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Yes
Gold
Republic Metals Corporation
UNITED STATES
Yes
Gold
Royal Canadian Mint
CANADA
Yes
Gold
SAAMP
FRANCE
 
Gold
Sabin Metal Corp.
UNITED STATES
 
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
 
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
 
Gold
SAXONIA Edelmetalle GmbH
GERMANY
 
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Yes
Gold
SEMPSA Joyería Platería SA
SPAIN
Yes
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
 
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Yes
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Yes
Gold
Singway Technology Co., Ltd.
TAIWAN
Yes
Gold
So Accurate Group, Inc.
UNITED STATES
 
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Yes
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Yes
Gold
Sudan Gold Refinery
SUDAN
 
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Yes





Gold
T.C.A S.p.A
ITALY
Yes
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Yes
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Yes
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Yes
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
 
Gold
Tony Goetz NV
BELGIUM
 
Gold
Torecom
KOREA, REPUBLIC OF
 
Gold
Umicore Brasil Ltda.
BRAZIL
Yes
Gold
Umicore Precious Metals Thailand
THAILAND
Yes
Gold
Umicore SA Business Unit Precious Metals Refining
BELGIUM
Yes
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Yes
Gold
Valcambi SA
SWITZERLAND
Yes
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Yes
Gold
WIELAND Edelmetalle GmbH
GERMANY
 
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Yes
Gold
Yokohama Metal Co., Ltd.
JAPAN
Yes
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
 
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Yes
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Yes
Tantalum
Avon Specialty Metals Ltd
UNITED KINGDOM
 
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Yes
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Yes
Tantalum
D Block Metals, LLC
UNITED STATES
Yes
Tantalum
Duoluoshan
CHINA
Yes
Tantalum
E.S.R. Electronics
UNITED STATES
 
Tantalum
Exotech Inc.
UNITED STATES
Yes
Tantalum
F&X Electro-Materials Ltd.
CHINA
Yes
Tantalum
FIR Metals & Resource Ltd.
CHINA
Yes
Tantalum
Global Advanced Metals Aizu
JAPAN
Yes
Tantalum
Global Advanced Metals Boyertown
UNITED STATES
Yes
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Yes
Tantalum
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch
CHINA
 
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Yes
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Yes
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Yes
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Yes
Tantalum
H.C. Starck Inc.
UNITED STATES
Yes
Tantalum
H.C. Starck Ltd.
JAPAN
Yes
Tantalum
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Yes
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Yes
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Yes
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Yes





Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Yes
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Yes
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Yes
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Yes
Tantalum
KEMET Blue Metals
MEXICO
Yes
Tantalum
KEMET Blue Powder
UNITED STATES
Yes
Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Yes
Tantalum
LSM Brasil S.A.
BRAZIL
Yes
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Yes
Tantalum
Mineração Taboca S.A.
BRAZIL
Yes
Tantalum
Mitsui Mining & Smelting
JAPAN
Yes
Tantalum
Molycorp Silmet A.S.
ESTONIA
Yes
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Yes
Tantalum
Plansee SE Liezen
AUSTRIA
Yes
Tantalum
Plansee SE Reutte
AUSTRIA
Yes
Tantalum
QuantumClean
UNITED STATES
Yes
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Yes
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Yes
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Yes
Tantalum
Taki Chemicals
JAPAN
Yes
Tantalum
Telex Metals
UNITED STATES
Yes
Tantalum
Tranzact, Inc.
UNITED STATES
Yes
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Yes
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Yes
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Yes
Tantalum
Zhuzhou Cemented Carbide
CHINA
Yes
Tin
Alpha
UNITED STATES
Yes
Tin
An Thai Minerals Company Limited
VIET NAM
 
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
 
Tin
Chenzhou Yun Xiang mining limited liability company
CHINA
 
Tin
China Tin Group Co., Ltd.
CHINA
Yes
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
 
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Yes
Tin
CV Ayi Jaya
INDONESIA
Yes
Tin
CV Dua Sekawan
INDONESIA
 
Tin
CV Gita Pesona
INDONESIA
Yes
Tin
CV Serumpun Sebalai
INDONESIA
Yes
Tin
CV Tiga Sekawan
INDONESIA
 
Tin
CV United Smelting
INDONESIA
Yes
Tin
CV Venus Inti Perkasa
INDONESIA
Yes
Tin
Dowa
JAPAN
Yes
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
 
Tin
Elmet S.L.U. (Metallo Group)
SPAIN
Yes
Tin
EM Vinto
BOLIVIA
Yes





Tin
Estanho de Rondônia S.A.
BRAZIL
 
Tin
Feinhütte Halsbrücke GmbH
GERMANY
 
Tin
Fenix Metals
POLAND
Yes
Tin
Gejiu Fengming Metalurgy Chemical Plant
CHINA
 
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
 
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Yes
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
 
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
 
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
 
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
 
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
 
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Yes
Tin
Linwu Xianggui Ore Smelting Co., Ltd.
CHINA
 
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Yes
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Yes
Tin
Melt Metais e Ligas S/A
BRAZIL
Yes
Tin
Metahub Industries Sdn. Bhd.
MALAYSIA
 
Tin
Metallic Resources, Inc.
UNITED STATES
Yes
Tin
Metallo-Chimique N.V.
BELGIUM
Yes
Tin
Mineração Taboca S.A.
BRAZIL
Yes
Tin
Minsur
PERU
Yes
Tin
Mitsubishi Materials Corporation
JAPAN
Yes
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
 
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
 
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Yes
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Yes
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Yes
Tin
Phoenix Metal Ltd.
RWANDA
 
Tin
PT Alam Lestari Kencana
INDONESIA
 
Tin
PT Aries Kencana Sejahtera
INDONESIA
Yes
Tin
PT Artha Cipta Langgeng
INDONESIA
Yes
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Yes
Tin
PT Babel Inti Perkasa
INDONESIA
Yes
Tin
PT Bangka Kudai Tin
INDONESIA
 
Tin
PT Bangka Prima Tin
INDONESIA
Yes
Tin
PT Bangka Timah Utama Sejahtera
INDONESIA
 
Tin
PT Bangka Tin Industry
INDONESIA
Yes
Tin
PT Belitung Industri Sejahtera
INDONESIA
Yes
Tin
PT BilliTin Makmur Lestari
INDONESIA
Yes
Tin
PT Bukit Timah
INDONESIA
Yes
Tin
PT Cipta Persada Mulia
INDONESIA
Yes
Tin
PT DS Jaya Abadi
INDONESIA
Yes
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Yes
Tin
PT Fang Di MulTindo
INDONESIA
 
Tin
PT Inti Stania Prima
INDONESIA
Yes
Tin
PT Justindo
INDONESIA
Yes





Tin
PT Karimun Mining
INDONESIA
 
Tin
PT Kijang Jaya Mandiri
INDONESIA
 
Tin
PT Mitra Stania Prima
INDONESIA
Yes
Tin
PT Panca Mega Persada
INDONESIA
Yes
Tin
PT Pelat Timah Nusantara Tbk
INDONESIA
 
Tin
PT Prima Timah Utama
INDONESIA
Yes
Tin
PT Refined Bangka Tin
INDONESIA
Yes
Tin
PT Sariwiguna Binasentosa
INDONESIA
Yes
Tin
PT Seirama Tin Investment
INDONESIA
 
Tin
PT Stanindo Inti Perkasa
INDONESIA
Yes
Tin
PT Sukses Inti Makmur
INDONESIA
Yes
Tin
PT Sumber Jaya Indah
INDONESIA
Yes
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Yes
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Yes
Tin
PT Tinindo Inter Nusa
INDONESIA
Yes
Tin
PT Tirus Putra Mandiri
INDONESIA
 
Tin
PT Tommy Utama
INDONESIA
Yes
Tin
PT Wahana Perkit Jaya
INDONESIA
Yes
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Yes
Tin
Rui Da Hung
TAIWAN
Yes
Tin
Soft Metais Ltda.
BRAZIL
Yes
Tin
Thaisarco
THAILAND
Yes
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
 
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Yes
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Yes
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
 
Tin
Yunnan Tin Group (Holding) Company Limited
CHINA
Yes
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Yes
Tungsten
ACL Metais Eireli
BRAZIL
 
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Yes
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Yes
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Dayu Jincheng Tungsten Industry Co., Ltd.
CHINA
 
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
 
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Ganxian Shirui New Material Co., Ltd.
CHINA
 
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
CHINA
 
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Yes
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Yes
Tungsten
H.C. Starck GmbH
GERMANY
Yes
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Yes
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Yes





Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
 
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin
CHINA
 
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Yes
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Yes
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Yes
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
 
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
 
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
 
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
 
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
 
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
 
Tungsten
Kennametal Fallon
UNITED STATES
 
Tungsten
Kennametal Huntsville
UNITED STATES
Yes
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
 
Tungsten
Niagara Refining LLC
UNITED STATES
Yes
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Yes
Tungsten
Philippine Chuangin Industrial Co., Inc.
PHILIPPINES
Yes
Tungsten
Pobedit, JSC
RUSSIAN FEDERATION
 
Tungsten
Sanher Tungsten Vietnam Co., Ltd.
VIET NAM
 
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Yes
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Yes
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Yes
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
 
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Yes
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
 
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Yes







Annex 2
    Publicly available information on countries of origin for the smelters listed in Annex 1 are included here.
 
Angola
Laos
Argentina
Luxembourg
Australia
Madagascar
Austria
Malaysia
Belgium
Mongolia
Bolivia
Mozambique
Brazil
Myanmar
Burundi
Namibia
Cambodia
Netherlands
Canada
Nigeria
Central African Republic
Peru
Chile
Portugal
China
Republic of Congo
Colombia
Russia
Cote D'Ivoire
Rwanda
Czech Republic
Sierra Leone
Democratic Republic of Congo
Singapore
Djibouti
Slovakia
Ecuador
South Africa
Egypt
South Korea
Estonia
South Sudan
Ethiopia
Spain
France
Suriname
Germany
Switzerland
Guyana
Taiwan
Hungary
Tanzania
India
Thailand
Indonesia
Uganda
Ireland
United Kingdom
Israel
United States
Japan
Vietnam
Kazakhstan
Zambia
Kenya
Zimbabwe