UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
QUALYS, INC.
(Exact name of registrant as specified in its charter)
| Delaware | 001-35662 | |
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
919 E. Hillsdale Boulevard, 4th Floor, Foster City, California 94404
(Address of principal executive offices) (Zip Code)
Bruce K. Posey, Chief Legal Officer and Corporate Secretary
(650) 801-6100
(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, 2023. |
| ☐ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended . |
SECTION 1 – CONFLICT MINERALS DISCLOSURE
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 to this Form SD, are publicly available at https://investor.qualys.com/financials-filings/sec-filings.
| Item 1.02 | Exhibit |
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
SECTION 3 – EXHIBITS
| Item 3.01 | Exhibits |
Exhibit 1.01 – 2023 Conflict Minerals Report of Qualys, Inc. as required by Items 1.01 and 1.02 of this Form SD.
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.
| Qualys, Inc. | ||
| By: | /s/ Bruce K. Posey | |
| Name: | Bruce K. Posey | |
| Title: | Chief Legal Officer and Corporate Secretary | |
Date: May 30, 2024
Exhibit 1.01
Qualys, Inc.
Conflict Minerals Report
For the Reporting Period from January 1, 2023 to December 31, 2023
This Conflict Minerals Report (this “Report”) of Qualys, Inc. (“we,” “Qualys” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2023 to December 31, 2023 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are referred to as “Conflict Minerals,” which include gold, columbite-tantalite (coltan), cassiterite, wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Company Overview
We are a pioneer and leading provider of a cloud-based platform delivering information technology (“IT”), security and compliance solutions that enable organizations to identify security risks to their IT infrastructures, help protect their IT systems and applications from ever-evolving cyber-attacks and achieve compliance with internal policies and external regulations.
Our cloud platform addresses the growing IT, security and compliance complexities and risks that are amplified by the dissolving boundaries between IT infrastructures and web environments, the rapid adoption of cloud computing, containers and serverless IT models, and the proliferation of geographically dispersed IT assets. Our integrated suite of IT, security and compliance solutions delivered on Qualys’ Enterprise TruRisk Platform enables our customers to identify and manage their IT and operational technology (“OT”) assets, collect and analyze large amounts of IT security data, discover and prioritize vulnerabilities, quantify cyber risk exposure, recommend and implement remediation actions and verify the implementation of such actions. Organizations use our integrated suite of solutions to cost-effectively obtain a unified view of their internal and external IT and OT asset inventory as well as security and compliance posture across globally-distributed IT infrastructures as our solution offers a single platform for information technology, information security, application security, endpoint, developer security and cloud teams.
Our cloud platform utilizes physical and virtual sensors, and cloud agents that provide our customers with continuous visibility enabling customers to respond to threats immediately. Our cloud platform automatically gathers and analyzes security and compliance data in a scalable, state-of-the-art backend. The technology underlying our cloud infrastructure enables us to ingest, process, analyze and store a high volume of sensor data coming from our agents, scanners and passive analyzers, and correlate information at very high speeds in a distributed manner for millions of devices.
Description of the Company’s Products Covered by this Report
This Report relates to our physical scanner appliances: (1) for which Conflict Minerals are necessary to their functionality or production, (2) that were manufactured, or contracted to be manufactured, by the Company, and (3) for which the manufacture was completed during the Reporting Period. In this Report, we refer to these products collectively as the “Covered Products.”
Description of the Company’s Reasonable Country of Origin Inquiry
We have determined that Conflict Minerals are necessary to the functionality or production of the Covered Products that were manufactured or contracted to be manufactured by us during the Reporting Period. As a result, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources.
Our supply chain is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. We do not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, we must rely on our contract manufacturers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products. In designing our RCOI, we determined to survey all of our first tier contract manufacturers.
As such, our RCOI primarily consisted of requesting the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”) be completed and returned to us from our first tier contract manufacturers. Responses were reviewed for completeness, reasonableness, and consistency, and we followed up with our contract manufacturers for corrections and clarifications as needed.
We requested from our seven contract manufacturers that they complete the CMRT, and we received a 100% response rate. Based on the smelter lists provided by our suppliers via the CMRTs, an aggregate of 352 facilities or smelters were used by our contract manufacturers to fulfill their requirements for Conflict Minerals. Of these 352 facilities and smelters, we have identified 223 facilities or smelters that are deemed to be compliant with the Conflict-Free Smelter Program (“CFSP”). There are four other smelters or refiners that are deemed “active” by the CFSP, which means such smelters or refiners have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 125 facilities or smelters identified by our contract manufacturers are not on the CFSI lists for compliant or active smelters. We have assessed these 125 facilities and determined that most of these are of low risk due to their geographic location. There is one smelter or refiner that may be considered at greater risk because it is geographically located in a Covered Country. Further, there is no guarantee that these 125 facilities or smelters are present in our supply chain as our contract manufacturers were only able to provide company-level CMRTs, rather than product-level CMRTs directly linking smelters or refiners to the Covered Products.
Based on these due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals contained in the Covered Products or whether the Conflict Minerals in the Covered Products are from recycled or scrap sources.
Description of the Company’s Due Diligence Process
Based on the information provided by our contract manufacturers, we performed additional due diligence on the source and chain of custody of these Conflict Minerals which was designed to conform to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the related supplements on gold, tin, tantalum and tungsten (the “Framework”), in order to determine if any Conflict Minerals included in our Covered Products may have originated in the Covered Countries and if so, whether they benefited armed groups in those countries.
After performing the RCOI and due diligence designed to conform with the Framework, we were unable to comprehensively establish the origin of all Conflict Minerals used in our Covered Products, the facilities used to process them, their country of origin, and their mine or location of origin.
In accordance with the five-step Framework, the design of our due diligence includes the following five steps: (1) establishment of strong company management systems, (2) identification and assessment of risks in the supply chain, (3) designing and implementing a strategy to respond to identified risks, (4) carrying out an independent third-party audit of smelter’s/refiner’s due diligence practices, and (5) reporting on supply chain due diligence. A description of certain activities undertaken by us with respect to each of the five steps of the Framework is described below.
1. Establishment of Strong Company Management Systems
We have completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in our Covered Products. These actions include:
| a. | Adopt and Commit to a Supply Chain Policy for Conflict Minerals: We are committed to sourcing minerals for our products in a manner that does not finance or benefit armed groups in the Covered Countries. We have a Code of Business Conduct and Ethics (“Code of Conduct”) available at https://investor.qualys.com/corporate-governance/overview which requires honest and ethical conduct and compliance with all applicable laws. Our Code of Conduct provides that we select suppliers not only on the merits of their products and services, but also on their business practices and that we will not establish business relationships with any suppliers if we know or have reason to believe that their business practices violate any applicable laws. Information contained on, or that can be accessed through, our website, does not constitute part of this Report and inclusion of our website address in this Report is an inactive textual reference only. |
| b. | Internal Management to Support Supply Chain Due Diligence: Our management has established an internal compliance team which includes members from our operations, legal and finance departments, charged with the development and implementation of our Conflict Minerals Program. |
| c. | Controls and Transparency to Support Supply Chain Diligence: As described above, we undertook a RCOI with respect to the Conflict Minerals in our supply chain by requesting the CMRT be completed by each of our contract manufacturers to gather information about their use of Conflict Minerals, the smelters and refiners in their supply chain that are included in our Covered Products, and the countries of origin for such Conflict Minerals. |
| d. | Supplier Engagement: We continue to actively engage with our contract manufacturers to strengthen our relationship with them. We have communicated to our contract manufacturers our commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries. Further, we will continue to engage with our suppliers and encourage them to provide responses at a product level so that we can fully assess our supply chain. |
Lastly, we have communicated to our contract vendors who have listed facilities or smelters which have an indeterminable status, that we are evaluating their responses and may elect to seek alternative arrangements with other contract manufacturers. We expect to continue our efforts to ensure that the minerals in our products do not originate from the Covered Countries and do not directly or indirectly finance armed conflict or benefit armed groups.
| e. | Grievance Mechanism: Our Code of Conduct includes procedures for reporting violations of our Code of Conduct, including how to report such violations anonymously. We believe that this is an appropriate mechanism for our employees to report violations of our Code of Conduct. |
2. Identification and Assessment of Risks in the Supply Chain
Because of our position within our supply chain, it is difficult for us to identify actors upstream from our first tier contract manufacturers. As discussed above, we identified seven first tier contract manufacturers and we have relied upon them to provide us with the necessary information about the source of Conflict Minerals contained in the products that we contract with them to manufacture for us. Our contract manufacturers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.
3. Designing and Implementing a Strategy to Respond to Identified Risks
We address any risks identified through the process described in Step 2 above on a case-by-case basis. During the Reporting Period, when our contract manufacturers did not provide us with complete or reliable responses to the CMRT, such matters were reported to members of our executive management team who considered a variety of responses to such manufacturers, including seeking alternative arrangements, with the further input from our internal compliance team. However, we have not yet identified any circumstances to date where it was necessary to terminate a contract or find a replacement contract manufacturer.
4. Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any smelters or refiners in our supply chain and, therefore, we do not directly conduct audits. Instead, we have supported the development and implementation of independent third party audits of smelters such as the Conflict-Free Smelter Program by encouraging our contract manufacturers to purchase materials from audited, conflict-free smelters and determining whether the smelters that were used to process these minerals were validated as conflict-free as part of the Conflict-Free Smelter Program.
5. Reporting on Supply Chain Due Diligence
In 2023, we publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at https://investor.qualys.com/financials-filings/sec-filings.
This Report includes information about the RCOI we undertook, our due diligence process designed to conform with the OECD Guidelines, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our products that incorporate Conflict Minerals necessary to the functionality or production of such products.
Findings and Conclusions
Based on the information that was provided by our contract manufacturers and otherwise obtained through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed in Annex I below.
This table includes only facilities that are listed in the CMRT as “known smelters or refineries.” An indication of “Full Compliant” in the far right column of the table indicates that the smelter or refinery has received a “conflict free” designation from an independent third party audit program. An indication of “Active” in the far right column of the table indicates that the smelter or refinery has committed to undergo a CFSP audit or is participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. An indication of “Indeterminable” in the far right column of the table indicates that the smelter or refinery was not included in the CFSI compliant or active lists and thus, the facility’s designation is indeterminable.
Because the CFSI lists generally did not indicate individual countries of origin of the Conflict Minerals processed by compliant smelters and refiners, we were not able to determine the countries of origin of the Conflict Minerals processed by the listed compliant smelters and refiners with greater specificity. In addition, for the listed compliant smelters and refiners, origin information is not disclosed by the CFSI. Furthermore, as stated earlier, submission of these smelters by our contract manufacturers does not guarantee that these smelters or refiners are present in the Company’s supply chain as our contract manufacturers were only able to provide company-level CMRTs and not able to provide product-level CMRTs directly linking those smelters or refiners to the Covered Products. Therefore, based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals contained in the Covered Products or whether the Conflict Minerals in the Covered Products are from recycled or scrap sources.
ANNEX I- SMELTER LIST
| Gold | 8853 S.p.A. | ITALY | Indeterminable | |||
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA | Indeterminable | |||
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Active | |||
| Gold | African Gold Refinery* | UGANDA | Indeterminable | |||
| Gold | Agosi AG | GERMANY | Full Compliant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Albino Mountinho Lda. | PORTUGAL | Indeterminable | |||
| Gold | Alexy Metals | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Full Compliant | |||
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | Full Compliant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Full Compliant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Full Compliant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Indeterminable | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Indeterminable | |||
| Gold | Augmont Enterprises Private Limited | INDIA | Indeterminable | |||
| Gold | Aurubis AG | GERMANY | Full Compliant | |||
| Gold | Bangalore Refinery | INDIA | Active | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Full Compliant | |||
| Gold | Boliden Ronnskar | SWEDEN | Full Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Full Compliant | |||
| Gold | C.I Metales Procesados Industriales SAS | COLOMBIA | Indeterminable | |||
| Gold | Caridad | MEXICO | Indeterminable | |||
| Gold | CCR Refinery—Glencore Canada Corporation | CANADA | Full Compliant | |||
| Gold | Cendres + Metaux S.A. | SWITZERLAND | Indeterminable | |||
| Gold | CGR Metalloys Pvt Ltd. | INDIA | Indeterminable | |||
| Gold | Chimet S.p.A. | ITALY | Full Compliant | |||
| Gold | Chugai Mining | JAPAN | Full Compliant | |||
| Gold | Coimpa Industrial LTDA | BRAZIL | Full Compliant | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Indeterminable | |||
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | Indeterminable | |||
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Dongwu Gold Group | CHINA | Indeterminable | |||
| Gold | Dowa | JAPAN | Full Compliant | |||
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | Full Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN | Full Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN | Full Compliant | |||
| Gold | Emerald Jewel Industry India Limited (Unit 1) | INDIA | Indeterminable | |||
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA | Indeterminable | |||
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA | Indeterminable | |||
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA | Indeterminable | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Indeterminable | |||
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA | Indeterminable | |||
| Gold | Gold by Gold Colombia | COLOMBIA | Full Compliant | |||
| Gold | Gold Coast Refinery | GHANA | Indeterminable | |||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Indeterminable | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Indeterminable | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Full Compliant | |||
| Gold | Heraeus Germany GmbH Co. KG | GERMANY | Full Compliant | |||
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | Full Compliant | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | Indeterminable | |||
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | Indeterminable | |||
| Gold | Industrial Refining Company | BELGIUM | Indeterminable | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Full Compliant | |||
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Full Compliant | |||
| Gold | Italpreziosi | ITALY | Full Compliant | |||
| Gold | JALAN & Company | INDIA | Indeterminable | |||
| Gold | Japan Mint | JAPAN | Full Compliant | |||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Full Compliant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | K.A. Rasmussen | NORWAY | Indeterminable | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Indeterminable | |||
| Gold | Kazzinc | KAZAKHSTAN | Full Compliant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | Full Compliant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Kundan Care Products Ltd. | INDIA | Indeterminable | |||
| Gold |
Kyrgyzaltyn JSC |
KYRGYZSTAN |
Indeterminable | |||
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Indeterminable | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | L’Orfebre S.A. | ANDORRA | Full Compliant | |||
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Marsam Metals | BRAZIL | Indeterminable | |||
| Gold | Materion | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | MD Overseas | INDIA | Indeterminable | |||
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | Full Compliant | |||
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Full Compliant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Full Compliant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Full Compliant | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | Full Compliant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Full Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | MKS PAMP SA | SWITZERLAND | Full Compliant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Full Compliant | |||
| Gold | Modeltech Sdn Bhd | MALAYSIA | Indeterminable | |||
| Gold | Morris and Watson | NEW ZEALAND | Indeterminable | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | Full Compliant | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Full Compliant | |||
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Full Compliant | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | Pease & Curren | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Planta Recuperadora de Metales SpA | CHILE | Full Compliant | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Full Compliant | |||
| Gold | PX Precinox S.A. | SWITZERLAND | Full Compliant | |||
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Full Compliant | |||
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | Indeterminable | |||
| Gold | REMONDIS PMR B.V. | NETHERLANDS | Full Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Full Compliant | |||
| Gold | SAAMP | FRANCE | Indeterminable | |||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Safimet S.p.A | ITALY | Indeterminable | |||
| Gold | SAFINA A.S. | CZECHIA | Full Compliant | |||
| Gold | Sai Refinery | INDIA | Indeterminable | |||
| Gold | Sam Precious Metals | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | Indeterminable | |||
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | Indeterminable | |||
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA | Indeterminable | |||
| Gold | Sellem Industries Ltd. | MAURITANIA | Indeterminable | |||
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | Full Compliant | |||
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Shirpur Gold Refinery Ltd. | INDIA | Indeterminable | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Indeterminable | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Indeterminable | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Gold | Sovereign Metals | INDIA | Indeterminable | |||
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | Indeterminable | |||
| Gold | Sudan Gold Refinery | SUDAN | Indeterminable | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Indeterminable | |||
| Gold | T.C.A S.p.A | ITALY | Full Compliant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Full Compliant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Indeterminable | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Full Compliant | |||
| Gold | Torecom | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Indeterminable | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Full Compliant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Valcambi S.A. | SWITZERLAND | Full Compliant | |||
| Gold | WEEEREFINING | FRANCE | Full Compliant | |||
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | Full Compliant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Full Compliant | |||
| Gold | Yamakin Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Full Compliant | |||
| Tantalum | 5D Production OU | ESTONIA | Indeterminable | |||
| Tantalum | AMG Brasil | BRAZIL | Full Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Full Compliant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Full Compliant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Full Compliant | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Full Compliant | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | KEMET de Mexico | MEXICO | Full Compliant | |||
| Tantalum | Materion Newton Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Full Compliant | |||
| Tantalum | Mineracao Taboca S.A. | BRAZIL | Full Compliant | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | NPM Silmet AS | ESTONIA | Full Compliant | |||
| Tantalum | PowerX Ltd. | RWANDA | Full Compliant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | Full Compliant | |||
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Indeterminable | |||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | Full Compliant | |||
| Tantalum | TANIOBIS GmbH | GERMANY | Full Compliant | |||
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Full Compliant | |||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Full Compliant | |||
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | Full Compliant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Alpha | UNITED STATES OF AMERICA | Full Compliant | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Indeterminable | |||
| Tin | Aurubis Beerse | BELGIUM | Full Compliant | |||
| Tin | Aurubis Berango | SPAIN | Full Compliant | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Full Compliant | |||
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | Full Compliant | |||
| Tin | CRM Synergies | SPAIN | Full Compliant | |||
| Tin | CV Ayi Jaya | INDONESIA | Full Compliant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Dowa | JAPAN | Full Compliant | |||
| Tin | DS Myanmar | MYANMAR | Full Compliant | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Full Compliant | |||
| Tin | Estanho de Rondonia S.A. | BRAZIL | Full Compliant | |||
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL | Full Compliant | |||
| Tin | Fenix Metals | POLAND | Full Compliant | |||
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Indeterminable | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Full Compliant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | Full Compliant | |||
| Tin | Luna Smelter, Ltd. | RWANDA | Full Compliant | |||
| Tin | Ma’anshan Weitai Tin Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Full Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Full Compliant | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Indeterminable | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tin | Mineracao Taboca S.A. | BRAZIL | Full Compliant | |||
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE | Full Compliant | |||
| Tin | Minsur | PERU | Full Compliant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Full Compliant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Indeterminable | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION | Indeterminable | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Full Compliant | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Full Compliant | |||
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Full Compliant | |||
| Tin | Pongpipat Company Limited | MYANMAR | Indeterminable | |||
| Tin | Precious Minerals and Smelting Limited | INDIA | Active | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Full Compliant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Full Compliant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Full Compliant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | PT Babel Surya Alam Lestari | INDONESIA | Full Compliant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Full Compliant | |||
| Tin | PT Bangka Serumpun | INDONESIA | Full Compliant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Active | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Full Compliant | |||
| Tin | PT Bukit Timah | INDONESIA | Full Compliant | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Full Compliant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Full Compliant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Full Compliant | |||
| Tin | PT Mitra Sukses Globalindo | INDONESIA | Full Compliant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Indeterminable | |||
| Tin | PT Premium Tin Indonesia | INDONESIA | Full Compliant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Full Compliant | |||
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA | Full Compliant | |||
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | Full Compliant | |||
| Tin | PT Rajehan Ariq | INDONESIA | Full Compliant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Full Compliant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Full Compliant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | PT Sukses Inti Makmur (SIM) | INDONESIA | Full Compliant | |||
| Tin | PT Timah Nusantara | INDONESIA | Full Compliant | |||
| Tin | PT Timah Tbk Kundur | INDONESIA | Full Compliant | |||
| Tin | PT Timah Tbk Mentok | INDONESIA | Full Compliant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Full Compliant | |||
| Tin | PT Tirus Putra Mandiri | INDONESIA | Indeterminable | |||
| Tin | PT Tommy Utama | INDONESIA | Full Compliant | |||
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | Full Compliant | |||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Tin | Super Ligas | BRAZIL | Full Compliant | |||
| Tin | Thaisarco | THAILAND | Full Compliant | |||
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | Full Compliant | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Indeterminable | |||
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | Full Compliant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | A.L.M.T. Corp. | JAPAN | Full Compliant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Indeterminable | |||
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | Indeterminable | |||
| Tungsten | Artek LLC | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Full Compliant | |||
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Cronimet Brasil Ltda | BRAZIL | Full Compliant | |||
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF | Indeterminable | |||
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | Full Compliant | |||
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF | Indeterminable | |||
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA | Full Compliant | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Full Compliant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Tungsten | LLC Vostok | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Masan High-Tech Materials | VIET NAM | Full Compliant | |||
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Nam Viet Cromit Joint Stock Company | VIET NAM | Indeterminable | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Full Compliant | |||
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | Full Compliant | |||
| Tungsten | Tungsten Vietnam Joint Stock Company | VIET NAM | Full Compliant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Indeterminable | |||
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | Full Compliant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA | Indeterminable | |||
| * | The United States Department of Treasury, Office of Foreign Assets Control (“OFAC”) designated African Gold Refinery (“AGR”) as a Specially Designated National (“SDN”) on March 17, 2022. Based on a review conducted by Qualys following AGR’s designation as an SDN, Qualys did not identify any direct transactions or contractual relationships with AGR. However, one of our suppliers reported that they utilized AGR in their supply chain. Qualys subjected this supplier to our escalation process, and as a result, such supplier informed Qualys that it has removed AGR from Qualys’ supply chain. Qualys continues to work with its supply base to ensure compliance with all applicable sanctions laws. |
Future Steps
We have communicated our expectations to our contract manufacturers regarding our commitment to sourcing minerals for our products in a manner that does not finance or benefit armed groups in the Covered Countries. Since the end of 2023, we have continued, and plan to continue, our engagement with our relevant first-tier contract manufacturers in order to build their knowledge and capacity so they are able to provide us with more complete and accurate information on the source and chain of custody of Conflict Minerals in our supply chain.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Qualys. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our Conflict Minerals status. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers, errors or omissions by smelters, the definition of a smelter not being finalized at the end of the 2023 reporting period, all instances of Conflict Minerals necessary to the functionality or manufacturing of our products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversight or errors in conflict free smelter audits, Covered Countries’ sourced materials being declared secondary materials, companies going out of business in 2023, certification programs being not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals from the Covered Countries to other countries.