EX-1.01 2 teledynecmrry2018-assented.htm EXHIBIT 1.01 CONFLICT MINERALS REPORT 2018 Exhibit



Teledyne Technologies Incorporated
Conflict Minerals Report
Calendar Year Ending December 31, 2018
May 30, 2019

Introduction
This Conflict Minerals Report (this "Report") for the year ended December 31, 2018, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement reporting and disclosure requirements related to conflict minerals as provided for by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Rule imposes certain reporting obligations on SEC registrants that manufacture products containing conflict minerals which are necessary to the functionality or production of their products. The term “conflict minerals” is defined as columbite-tantalite (tantalum), casserite (tin), gold or wolframite (tungsten) or any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or any adjoining country the DRC, including the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola (collectively, the “Covered Countries”). For the purposes of this Report, tin, tungsten, tantalum and gold will collectively be referred to as the 3TGs:
This Report (1) describes the reasonable country of origin inquiry ("RCOI") and subsequent due diligence efforts undertaken by Teledyne Technologies Incorporated (herein referred to as the “Company” “we”, “us”, or “our”) to determine whether in the 2018 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 Rule. This Report includes details with respect to the good-faith reasonable country of origin inquiry undertaken by the Company.
Company Overview.
Teledyne Technologies Incorporated provides enabling technologies for industrial growth markets that require advanced technology and high reliability. These markets include aerospace and defense, factory automation, air and water quality environmental monitoring, electronics design and development, oceanographic research, deepwater oil and gas exploration and production, medical imaging and pharmaceutical research. Our products include digital imaging sensors, cameras and systems within the visible, infrared and X-ray spectra, monitoring and control instrumentation for marine and environmental applications, harsh environment interconnects, electronic test and measurement equipment, aircraft information management systems, and defense electronics and satellite communication subsystems. We also supply engineered systems for defense, space, environmental and energy applications. We differentiate ourselves from many of our direct competitors by having a customer and company-sponsored applied research center that augments our product development expertise.
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/about-us/ethics-and-values.
Reasonable Country of Origin Inquiry (RCOI)
After the RCOI, 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.
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 2018, the Company focused on suppliers of materials, parts and components. The Company identified 4,390 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 2017 fiscal year, which ended on December 31, 2017 (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 its third-party service provider, 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 5.11 or higher (“CMRT”) and instructions on how to complete the CMRT. The CMRT is a standardized reporting template developed by the Responsible Minerals Initiative (“RMI”) that facilitates the transfer of information through the supply chain regarding mineral country of origin and smelters or 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 suppliers by email a minimum of three times and then non-responsive suppliers directly a minimum of two times. Additional communications include training and education on the completion of the CMRT form as well as access to Assent University, a learning management system developed by Assent, designed to alleviate any remaining confusion with suppliers. All communications and courses completed by suppliers were monitored and tracked in Assent's system for future reporting and transparency.
Teledyne’s Conflict Minerals program through Assent 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.
Based on the responses provided by suppliers 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.

Due Diligence
Design of Due Diligence Measures
In accordance with the 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”).
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 Systems
1.1    Internal Team
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, General Counsel, Chief Compliance Officer and Secretary, the Company’s President and Chief Executive 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.
As stated throughout this Report, we also partner with Assent, a SaaS company whose software allows us to collect and store CMRTs and supplier data, communicate with our supply chain and provide training and education.
1.2    Establish a system of controls and transparency over the mineral supply chain
The CMRTs we collected from our suppliers allowed us to obtain information that was relevant to our due diligence efforts, including the names of smelters or refiners in our suppliers’ supply chains. While a portion of the Company’s direct suppliers are also subject to the reporting obligations under the Exchange Act and knowledgeable about the Rule, the Company also has many other suppliers and distributors that do not have the same reporting obligations and as such require additional training to understand the requirements of the Rule.
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. Internal controls include the Company’s on-going initiative of integrating conflict minerals related requirements in its supply agreements that require disclosure of 3TGs.
1.4     Maintain Records
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.
1.5    Strengthen company engagement with suppliers
With respect to the OECD requirement to strengthen engagement with suppliers, the Company has utilized the CMRT version 5.11 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, the Company’s procurement organization continues to integrate 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.
1.6    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 order to assess the risk that any of these smelters posed to our supply chain, Assent determined if the smelter had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). We do not typically have a direct relationship with 3TG smelters and refiners and do not perform or direct audits of these entities within our supply chain. Smelters that have completed an RMAP audit are considered to be DRC-Conflict Free. In cases where the smelter’s due diligence practices have not been audited against the RMAP standard, a potential supply chain risk exists.
Each facility that meets the RMI definition of a smelter or refiner of a 3TG mineral is assigned assessed according to red-flag indicators defined in the OECD Guidance. Assent uses 5 factors to determine the level of risk that each smelter poses to the supply chain by identifying red-flags:
•
Geographic proximity to the DRC and covered countries;
•
Known mineral source country of origin;
•
Responsible Minerals Assurance Process (RMAP) audit status;
•
Credible evidence of unethical or conflict sourcing
Peer Assessments conducted by credible third-party sources.
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:
•    Have you established a conflict minerals sourcing policy?
•    Have you implemented due diligence measures for conflict-free sourcing?
•    Do you review due diligence information received from your suppliers against your company’s expectations?
•    Does your review 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 Responsible Business Alliance 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 becomes 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 together with Assent developed a plan to send additional communications, offer additional education, or, if necessary, have the Company’s procurement organization engage with the supplier.
When red-flag smelters or refiners were reported based on the logic discussed in the previous section, risk mitigation activities are initiated. CMRT submissions that include any red-flag smelters or refiners immediately produced a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to Teledyne and directives to remove these red-flag smelters from their supply chain. Through our smelter and refinery assessments, we also monitor red flags related to risks outside of just sourcing conflict minerals from the Covered Countries.
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://www.teledyne.com/about-us/ethics-and-values
Results of Due Diligence
The Company, through Assent’s software platform, surveyed a total of 4,390 suppliers. Of the 2,636 responses, 151 were determined to be out of scope, 119 were deemed invalid and marked for follow-up, and 2,366 were accepted as complete. This is an overall response rate of 60.05 %.

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 RMI and, if a supplier indicated that the facility was certified as conflict-free, confirmed that the name was listed by RMI. Based on the smelter lists provided by suppliers via the CMRTs, the Company is aware that 255 smelters are certified conflict-free, and a number of other smelters are active in the RMAP third-party audit process.
As of May 15, 2019, the Company has validated 319 legitimate 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 based on information provided by suppliers and the RMI. 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
The Company’s conflict minerals program for the 2019 calendar year will continue to focus on vetting smelter data, which may include the following actions:
•
Working with suppliers to move to version 5.12 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 Responsible Minerals 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 3TGs 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;
•     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.
The Company reserves the right to modify or eliminate these Risk Mitigation Steps, including, without limitation, in response to any changes or proposed changes to the Rule by the SEC.

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 RMI’s Responsible Minerals Assurance Process third-party audit certifying conflict-free sourcing. As noted in the Report, 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.

Metal
Standard Smelter Name
Facility Location
Conflict Free?
Gold
8853 S.p.A.
ITALY
Yes
Gold
Abington Reldan Metals, LLC
UNITED STATES
Unknown
Gold
Advanced Chemical Company
UNITED STATES
Yes
Gold
African Gold Refinery
UGANDA
Unknown
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Yes
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
Yes
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Yes
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Yes
Gold
AngloGold Ashanti Córrego do Sítio Mineração
BRAZIL
Yes
Gold
Argor-Heraeus S.A.
SWITZERLAND
Yes
Gold
Asahi Pretec Corp.
JAPAN
Yes
Gold
Asahi Refining Canada Ltd.
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
Unknown
Gold
AU Traders and Refiners
SOUTH AFRICA
Yes
Gold
Aurubis AG
GERMANY
Yes
Gold
Bangalore Refinery
INDIA
Unknown
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Yes
Gold
Boliden AB
SWEDEN
Yes
Gold
C. Hafner GmbH + Co. KG
GERMANY
Yes
Gold
Caridad
MEXICO
Unknown
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Yes
Gold
Cendres + Métaux S.A.
SWITZERLAND
Yes
Gold
Chimet S.p.A.
ITALY
Yes
Gold
Chugai Mining
JAPAN
Unknown
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Yes
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Unknown
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Unknown
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Unknown
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Yes
Gold
Dowa
JAPAN
Yes
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Yes
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Yes
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Yes
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Yes
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Unknown
Gold
Fujairah Gold FZE
UNITED ARAB EMIRATES
Unknown
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Unknown
Gold
Geib Refining Corporation
UNITED STATES
Yes
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Yes
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Unknown
Gold
Guangdong Jinding Gold Limited
CHINA
Unknown
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Unknown
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Unknown
Gold
HeeSung
KOREA, REPUBLIC OF
Yes
Gold
Heimerle + Meule GmbH
GERMANY
Yes
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Yes
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Yes
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Unknown
Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Unknown
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Unknown
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Yes
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
Unknown
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Yes
Gold
Istanbul Gold Refinery
TURKEY
Yes
Gold
Italpreziosi
ITALY
Yes
Gold
Japan Mint
JAPAN
Yes
Gold
Jiangxi Copper Co., Ltd.
CHINA
Yes
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Unknown
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Yes
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Yes
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Unknown
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Unknown
Gold
Kazzinc
KAZAKHSTAN
Yes
Gold
Kennecott Utah Copper LLC
UNITED STATES
Yes
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
Unknown
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Yes
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Yes
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Yes
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Unknown
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Unknown
Gold
Lingbao Gold Co., Ltd.
CHINA
Unknown
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Unknown
Gold
L'Orfebre S.A.
ANDORRA
Yes
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Yes
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Unknown
Gold
Marsam Metals
BRAZIL
Yes
Gold
Materion
UNITED STATES
Yes
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Yes
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Yes
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Yes
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Yes
Gold
Metalor Technologies S.A.
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
Modeltech Sdn Bhd
MALAYSIA
Unknown
Gold
Morris and Watson
NEW ZEALAND
Unknown
Gold
Morris and Watson Gold Coast
AUSTRALIA
Unknown
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
Unknown
Gold
NH Recytech Company
KOREA, REPUBLIC OF
Unknown
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 Novosibirsk Refinery
RUSSIAN FEDERATION
Yes
Gold
PAMP S.A.
SWITZERLAND
Yes
Gold
Pease & Curren
UNITED STATES
Unknown
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Unknown
Gold
Planta Recuperadora de Metales SpA
CHILE
Yes
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Yes
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Yes
Gold
PX Précinox S.A.
SWITZERLAND
Yes
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
Unknown
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Yes
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Unknown
Gold
Remondis Argentia B.V.
NETHERLANDS
Yes
Gold
Republic Metals Corporation
UNITED STATES
Yes
Gold
Royal Canadian Mint
CANADA
Yes
Gold
SAAMP
FRANCE
Yes
Gold
Sabin Metal Corp.
UNITED STATES
Unknown
Gold
Safimet S.p.A
Italy
Yes
Gold
SAFINA A.S.
CZECH REPUBLIC
Unknown
Gold
Sai Refinery
INDIA
Unknown
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Unknown
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Unknown
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Yes
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Yes
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Unknown
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Yes
Gold
Shangdong Humon Smelting Co., Ltd.
CHINA
Unknown
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Yes
Gold
Singway Technology Co., Ltd.
TAIWAN
Yes
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Yes
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Yes
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Unknown
Gold
Sudan Gold Refinery
SUDAN
Unknown
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Yes
Gold
SungEel HiTech
KOREA, REPUBLIC OF
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
Unknown
Gold
Tony Goetz NV
BELGIUM
Unknown
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Unknown
Gold
Torecom
KOREA, REPUBLIC OF
Yes
Gold
Umicore Brasil Ltda.
BRAZIL
Yes
Gold
Umicore Precious Metals Thailand
THAILAND
Yes
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Yes
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Yes
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Unknown
Gold
Valcambi S.A.
SWITZERLAND
Yes
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Yes
Gold
WIELAND Edelmetalle GmbH
GERMANY
Yes
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Yes
Gold
Yokohama Metal Co., Ltd.
JAPAN
Yes
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Unknown
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Yes
Tantalum
Asaka Riken Co., Ltd.
JAPAN
Yes
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Yes
Tantalum
D Block Metals, LLC
UNITED STATES
Yes
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 Rising Rare Metals-EO Materials Ltd.
CHINA
Yes
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Yes
Tantalum
H.C. Starck Co., Ltd.
THAILAND
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
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Yes
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Yes
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Yes
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Yes
Tantalum
Jiujiang Janny New Material Co., Ltd.
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
LSM Brasil S.A.
BRAZIL
Yes
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Yes
Tantalum
Mineracao Taboca S.A.
BRAZIL
Yes
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Yes
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Yes
Tantalum
NPM Silmet AS
ESTONIA
Yes
Tantalum
Power Resources Ltd.
MACEDONIA
Yes
Tantalum
QuantumClean
UNITED STATES
Yes
Tantalum
Resind Industria e Comercio 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
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Yes
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Yes
Tin
Alpha
UNITED STATES
Yes
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Unknown
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Yes
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Yes
Tin
China Tin Group Co., Ltd.
CHINA
Yes
Tin
CV Ayi Jaya
INDONESIA
Yes
Tin
CV Dua Sekawan
INDONESIA
Yes
Tin
CV Gita Pesona
INDONESIA
Yes
Tin
CV Tiga Sekawan
INDONESIA
Yes
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
Unknown
Tin
EM Vinto
BOLIVIA
Yes
Tin
Estanho de Rondônia S.A.
BRAZIL
Unknown
Tin
Fenix Metals
POLAND
Yes
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Yes
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Yes
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Yes
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Yes
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Yes
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CHINA
Yes
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Yes
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Unknown
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Yes
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
Yes
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
Metallic Resources, Inc.
UNITED STATES
Yes
Tin
Metallo Belgium N.V.
BELGIUM
Yes
Tin
Metallo Spain S.L.U.
SPAIN
Yes
Tin
Mineracao Taboca S.A.
BRAZIL
Yes
Tin
Minsur
PERU
Yes
Tin
Mitsubishi Materials Corporation
JAPAN
Yes
Tin
Modeltech Sdn Bhd
MALAYSIA
Yes
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Unknown
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
Pongpipat Company Limited
MYANMAR
Unknown
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 Babel Surya Alam Lestari
INDONESIA
Yes
Tin
PT Bangka Prima Tin
INDONESIA
Yes
Tin
PT Bangka Serumpun
INDONESIA
Yes
Tin
PT Bangka Tin Industry
INDONESIA
Yes
Tin
PT Belitung Industri Sejahtera
INDONESIA
Yes
Tin
PT Bukit Timah
INDONESIA
Yes
Tin
PT DS Jaya Abadi
INDONESIA
Yes
Tin
PT Inti Stania Prima
INDONESIA
Yes
Tin
PT Karimun Mining
INDONESIA
Yes
Tin
PT Kijang Jaya Mandiri
INDONESIA
Yes
Tin
PT Menara Cipta Mulia
INDONESIA
Yes
Tin
PT Mitra Stania Prima
INDONESIA
Yes
Tin
PT Panca Mega Persada
INDONESIA
Yes
Tin
PT Premium Tin Indonesia
INDONESIA
Yes
Tin
PT Prima Timah Utama
INDONESIA
Yes
Tin
PT Refined Bangka Tin
INDONESIA
Yes
Tin
PT Sariwiguna Binasentosa
INDONESIA
Yes
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
Yes
Tin
PT Tommy Utama
INDONESIA
Yes
Tin
Resind Industria e Comercio Ltda.
BRAZIL
Yes
Tin
Rui Da Hung
TAIWAN
Yes
Tin
Soft Metais Ltda.
BRAZIL
Yes
Tin
Super Ligas
Brazil
Unknown
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Yes
Tin
Thaisarco
THAILAND
Yes
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
Yes
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Unknown
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Yes
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Yes
Tin
Yunnan Tin Company Limited
CHINA
Yes
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Yes
Tungsten
ACL Metais Eireli
BRAZIL
Yes
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
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Yes
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Unknown
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Yes
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Yes
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Yes
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Yes
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Yes
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Yes
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Yes
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
Unknown
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Yes
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Yes
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Unknown
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Unknown
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Yes
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Kennametal Fallon
UNITED STATES
Yes
Tungsten
Kennametal Huntsville
UNITED STATES
Yes
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Yes
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Yes
Tungsten
Niagara Refining LLC
UNITED STATES
Yes
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Yes
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Yes
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Yes
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Yes
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Yes
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Yes
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Yes
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
Yes
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Yes



Annex 2

Potential countries of origin include:
•
Argentina, Australia, Austria, Benin, Bolivia, Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, Democratic Republic of the, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zimbabwe