UNITED STATES
SECURITIES
AND EXCHANGE COMMISSION
Washington,
D.C. 20549
FORM SD
Specialized
Disclosure Report
|
MERITOR, INC. |
|
(Exact name of the registrant as specified in its charter) |
| Indiana | 1-15983 | 38-3354643 |
| (State or other jurisdiction of | (Commission File Number) | (IRS Employer Identification No.) |
| incorporation) |
| 2135 West Maple Road, Troy, Michigan | 48084-7186 | |
| (Address of principal executive offices) | (Zip code) |
| Mark R. Schaitkin | (248) 435-1000 | |
| (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:
✓ Rule13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016
SECTION 1 - CONFLICT MINERALS DISCLOSURE
Item 1.01 Conflict Minerals Disclosure and Report
For the year ended December 31, 2016, based upon the results of its due diligence, Meritor, Inc. (“Meritor”) is unable to exclude the presence of “conflict minerals” (as defined in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”)) in certain of its products or to determine the origin of any conflict minerals in its manufactured products. Accordingly, Meritor cannot exclude the possibility that some of its products contain conflict minerals which may have originated in the Democratic Republic of the Congo or an “adjoining country” (as defined in Section 1502 of the Dodd-Frank Act). As a result, Meritor is filing a Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Conflict Minerals Disclosure
A copy of the Meritor’s Conflict Minerals Report is filed as Exhibit 1.01 to this Form SD and is publicly available at www.meritor.com.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
SECTION 2 – EXHIBITS
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report 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.
MERITOR,
INC.
(Registrant)
| By: | /s/ April Miller Boise | May 10, 2017 | ||
| April Miller Boise | (Date) | |||
| Senior Vice President, General | ||||
| Counsel & Corporate Secretary | ||||
MERITOR, INC.
Conflict Minerals Report
For The Year Ended December 31, 2016
This report, for the year ended December 31, 2016, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Conflict Minerals Rule”). The Conflict Minerals Rule was adopted by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”). The Conflict Minerals Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict Minerals” are defined as cassiterite, columbite-tantalite, gold, wolframite and their derivatives, which are limited to tin, tantalum, tungsten and gold (“3TG”). These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
Each registrant must submit a Form SD which describes the reasonable country of origin inquiry completed by the registrant and, if the registrant is unable to establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or certain adjoining countries (the “Covered Countries”) or from recycled or scrap sources or elects not to disclose the source of its Conflict Minerals, then the registrant must also submit a Conflict Minerals Report to the SEC that includes a description of its due diligence efforts on the Conflict Minerals source and chain of custody.
1. Company Overview
This report has been approved by management of Meritor, Inc. (herein referred to as “Meritor”, “we”, “us” or “our”). The information includes the activities of all majority-owned subsidiaries and any less than majority-owned subsidiaries that are consolidated in Meritor’s financial results. It does not include the activities of any entities that are not required to be consolidated in Meritor’s financial results, except to the extent that those entities supply products to Meritor which may contain any of the Conflict Minerals.
Meritor is a premier global supplier of a broad range of integrated systems and components to original equipment manufacturers (“OEMs”) and the aftermarket for the commercial vehicle, transportation and industrial sectors. Meritor serves commercial truck, trailer, off-highway, military, bus and coach and other industrial OEMs and certain aftermarkets. Our principal products are axles, undercarriages, drivelines, brakes and braking systems.
Supply Chain
Due to the complexity of our products and the number of direct suppliers supplying products to Meritor, we rely on our direct suppliers to provide information on the origin of the 3TG contained in the products they supply to us—including sources of 3TG that are supplied to them from their lower tier suppliers. Accordingly, in 2014, Meritor published a new version of our Supplier Quality System Requirements (“SQSR”) manual which is incorporated by reference into our purchase orders and other agreements and which obligates our suppliers to exercise due diligence on the source and chain of custody of any Conflict Minerals incorporated in their products sold to Meritor and to report those findings to Meritor. To ensure that these findings are, in fact, reported to Meritor, we worked directly with a large group of selected suppliers, as described below.
The suppliers selected by Meritor for inquiry were those direct suppliers who supplied any production parts to Meritor in 2016, where the parts in question, by their nature, could potentially contain 3TG.
Reasonable Country of Origin Inquiry
Based upon the results of our due diligence, we are unable to rule out the presence of 3TG in certain of our products or to determine the origin of all 3TG which may be contained in any of our products. Accordingly, we cannot exclude the possibility that some of our products may contain 3TG which may have originated in one or more of the Covered Countries. For that reason, we are required, under the Conflict Minerals Rule, to submit a Conflict Minerals Report to the SEC as an exhibit to Form SD.
Because of our size, our global presence, the complexity of our products and the depth, breadth and constant changes within our supply base, it is difficult to identify those potential sources of 3TG upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives to determine those possible suppliers of 3TG as described in Section 2.2 below.
In accordance with the Organization for Economic Cooperation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the Conflict Minerals Rule, this report is available on our website at http://meritor.com/policy/conflict-minerals-information.aspx.
Conflict Minerals
Policy
Meritor is committed to
working with our global supply chain to ensure compliance with the SEC’s
conflict minerals rules. Meritor intends to source responsibly in support of its
intent not to manufacture products that contain Conflict Minerals that support
armed conflict in any of the Covered Countries. To that end, we have established
a conflict minerals compliance program that is designed to follow the framework
established by the OECD. As part of that program, Meritor requires that relevant
suppliers conduct conflict minerals due diligence and report their results to
us.
To help ensure that we source responsibly, we have also adopted an internal Conflict Minerals Policy to guide the conduct of our employees.
In addition, Meritor has published a Conflict Minerals Statement on our website at http://meritor.com/policy/conflict-minerals-information.aspx.
2. Due Diligence Process
2.1. Design of Due Diligence
Our due diligence measures have been designed to conform, in all material respects, with the framework in the OECD Guidance and the related supplements for gold and for tin, tantalum and tungsten.
2.2. Management Systems
As described above, Meritor has adopted an internal Conflict Minerals Policy, for its employees, and a publicly available Conflict Minerals Statement which is posted at www.meritor.com.
Internal Team
Meritor has established a Conflict Minerals Team reporting to Meritor’s VP & Chief Procurement Officer. The core team includes representatives from our procurement, sales and legal groups, with support, as needed, from our IS and engineering groups. Senior management, including Meritor’s CEO and CFO, are periodically briefed about the results of our due diligence efforts.
Control Systems
Because we do not have any direct relationships with 3TG smelters and refiners, we are engaged, and actively participate, with other major manufacturers in the automotive industry and other sectors, in the following industry-wide initiatives to disclose upstream actors in the supply chain: the National Association of Manufacturers and the Automotive Industry Action Group (“AIAG”) Conflict Minerals Work Group.
In addition to adopting a Conflict Minerals Policy which outlines expected behaviors for all Meritor employees, our expectations for our suppliers are set forth in our SQSR manual.
Supplier Engagement
With respect to the OECD requirement to strengthen engagement with suppliers, we have contacted all relevant suppliers and asked them to complete, on the i-Point Conflict Minerals Platform, a CMRT Template (described in Section 3 below) and have followed up with all suppliers who failed to respond or who have provided inadequate or questionable responses.
Meritor Helpline Reporting
Through our internal Conflict Minerals Policy and the Conflict Minerals Statement on our website, we have encouraged our employees and suppliers to contact the Meritor Helpline to report instances in which Meritor’s products may contain Conflict Minerals from a Covered Country (other than from a scrap or recycled source) which have not already been discovered by, or reported to, Meritor or which Meritor may not have previously disclosed in its Form SD or its Conflict Minerals Report.
Records Maintenance
We intend to retain relevant documentation in accordance with Meritor’s standard records retention policies.
2.3. Identify and Assess Risk in the Supply Chain
Because of our size, our global presence, the complexity of our products and the depth, breadth and constant changes within our supply base, it is difficult to identify those potential sources of 3TG upstream from our direct suppliers. Accordingly, we participate in a number of industry-wide initiatives to determine those possible suppliers of 3TG as described in Section 2.2 above.
Through tools and other available processes, we identified 366 direct suppliers whose products could potentially contain 3TG. We rely on those direct suppliers to provide us with information about the source of Conflict Minerals, if any, contained in the products they supply to us. In turn, those direct suppliers are similarly reliant upon information provided by their suppliers. Many of our largest direct suppliers are also SEC registrants and, therefore, are also subject to the Conflict Minerals Rule.
2.4. Design and Implement a Strategy to Identify and Respond to Risks
Meritor has an approved risk management plan, through which our conflict minerals program is implemented, managed and monitored.
As described above, we participate in the following industry-wide initiatives to determine potential upstream suppliers of 3TG: the National Association of Manufacturers and the AIAG Conflict Minerals Work Group.
As part of our risk management plan, to ensure that our suppliers understand our expectations, we have described our intention to source responsibly in the Conflict Minerals Statement available on our website at http://meritor.com/policy/conflict-minerals-information.aspx, have referenced those expectations in our SQSR manual, have sent each of the suppliers whose products may contain 3TG information on the Conflict Mineral regulations, have encouraged our suppliers to join i-Point and to participate in i-Point’s educational seminars, and have encouraged our suppliers to contact members of our Conflict Minerals Team to address any questions they may have.
In addition, in an effort to assist other companies to comply with the Conflict Mineral regulations and to raise awareness of the initiatives in our industry, a member of the Meritor Conflict Minerals Work Team has participated in a number of seminars on the topic and has spoken, as a subject matter expert, at the Annual Conflict Minerals Compliance and Supply Chain Transparency Conference hosted by the Marcus Evans Group.
As described in our Conflict Minerals Policy, Meritor intends to source responsibly in support of its intent not to manufacture products that contain Conflict Minerals that support armed conflict in any of the Covered Countries.
2.5. 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 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain. We support audits through our active participation in the AIAG Conflict Minerals Work Group. Through this group Meritor is helping to fund travel for members to attend supplier education sessions and on-site smelter visits.
2.6. Report on Supply Chain Due Diligence
In addition to this report, see our website at http://meritor.com/policy/conflict-minerals-information.aspx for further information about our supply chain due diligence.
3. Due Diligence Results
Requests for Information
We conducted a survey of those direct suppliers described above using the template developed by the Electronic Industry Citizenship Coalition® (“EICC”) and the Global e-Sustainability Initiative (“GeSI”), known as the Conflict Mineral Reporting Template (the “CMRT Template”). The CMRT Template was developed to facilitate disclosure and communication of information regarding smelters that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters used by the company and its suppliers. In addition, the template contains questions about the origin of conflict minerals used in the supplier’s products, as well as the supplier’s own due diligence efforts. Written instructions and recorded training illustrating the use of the tool is available on EICC’s website. The CMRT Template is being used by many companies in their due diligence processes related to Conflict Minerals.
Survey Responses
Using the information gathered from our direct suppliers over the past several years as well as our internal business systems which track production shipments, Meritor contacted all of its suppliers whose products could potentially contain 3TG, including those suppliers who responded “no” to the presence of 3TG in their products in previous reporting years. As in 2015, Meritor again received acceptable responses from 100% of those identified suppliers.
Since 2013, one of Meritor’s stated Conflict Mineral goals has been to increase the “Product Level” responses received from its suppliers who indicated the possible presence of 3TG in their products (a “Product Level” response meaning a response indicating whether the actual product supplied to Meritor by such supplier contained 3TG as opposed to a “Company Level” response meaning that the supplier sells products which contain 3TG, but cannot identify whether any 3TG is in the actual products sold to Meritor). Meritor assumed that, at a Product Level, fewer supplier responses would indicate the use of 3TG in the products being sold to Meritor and those responses would also show a smaller number of smelters as being involved in the production of those products. As in all previous reporting years, these assumptions were proven to have been correct.
In 2016, of the 366 suppliers surveyed, 48 (13%) reported some level of 3TG in their products. Of these 48 suppliers, 22 provided a Product Level response, while the remaining 26 suppliers provided a Company Level response. Of the 22 Product Level responses, 18 (82%) reported that tin was the only 3TG present in the products sold to Meritor, confirming Meritor’s belief that tantalum, tungsten and gold are present in few Meritor products.
As to the smelter information contained in these supplier responses, Meritor reported a total of 405 smelter names in 2015, of which 63% had case identification numbers (“CID Numbers”) assigned to them by the Conflict Free Sourcing Initiative (“CFSI”). The presence of a CID Number indicates that the CFSI is aware of the company being reported as an alleged smelter and is actively working to verify its status and potential compliance as a Conflict Free smelter. In 2016, Meritor’s final smelter list contained a total of 173 company names, 100% of which had CID Numbers assigned to them, satisfying Meritor’s stated 2015 goal of obtaining more accurate smelter information from its suppliers. At the time of this report, only 20 of the 173 smelter names were not on either the CFSI “Compliant” list or the CFSI “active” list. Meritor continues to monitor the CFSI status of those companies as part of its on-going due diligence.
Relevant information about the smelters disclosed in Meritor’s supplier responses is set forth on Exhibit 1 to this Conflict Minerals Report. Meritor continues to support the further refinement and expansion of the list of participating smelters who are conflict free through our active participation in the AIAG Conflict Mineral Work Group and our subscription to i-Point.
While some of these smelters or refiners have been verified as being on the conflict free smelter list, many of the remaining mines or locations of origin of the 3TG in our products remain unknown. As to the companies responding “yes” to the presence of 3TG products in a Company Level declaration, Meritor is unable to determine whether any of the Conflict Minerals reported by these suppliers were in fact contained in products they supplied to Meritor, and is therefore unable to validate that any of the smelters or refiners identified by those suppliers are actually in our supply chain.
To ensure that we have received reliable responses from our suppliers, we reviewed all of our supplier responses against criteria we developed to determine which responses merited further inquiry with our suppliers. These criteria call for follow-up of untimely or incomplete responses as well as those containing inconsistencies within the data reported in the CMRT Template. In addition, we applied a higher level of scrutiny to responses from direct suppliers who are foundries and those who supply electronic components to Meritor. We have worked directly with these suppliers in order to obtain acceptable revised responses.
4. Efforts to Determine Mine or Location of Origin
Through our participation in AIAG Conflict Minerals Work Group, the OECD implementation programs, and requesting our suppliers to complete the CMRT Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG, if any, in our supply chain.
Smelters or Refiners
Of the 48 suppliers whose responses indicated that their products may contain 3TG, 26 of those suppliers responded at a Company Level, meaning that 3TG may or may not actually be present in the components or materials actually provided to Meritor. Meritor’s experience indicates that many of those smelters identified in a Company Level declaration by Meritor’s suppliers may not actually be involved in the products supplied to Meritor. Moreover, based on what Meritor’s core team has learned through its association with the AIAG Conflict Minerals Work Group, it is clear that a great deal of work remains to be done in order to identify which smelters are or are not conflict free.
5. Steps to be Taken to Mitigate Risks
For 2017, we intend to take the following steps to improve the due diligence we conduct in order to identify and mitigate any risk that the Conflict Minerals in our products could benefit armed groups in the Covered Countries:
| a. | Continue to work with our suppliers who have indicated the presence of 3TG at a Company Level to obtain Product Level declarations in an effort to more accurately determine which of their products actually contain 3TG, thereby allowing Meritor to refine its smelter list to include only actual verified smelters within the Meritor supply chain. | ||
| b. | Take appropriate actions with regard to any “red flag” smelters found to be in our supply base. | ||
| c. | Assist Meritor’s Tier 1 suppliers to attain a higher response rate from their lower tier suppliers as a result of their supply chain due diligence. | ||
| d. | Continue to educate our suppliers on Meritor’s higher expectations relating to product level responses and accurate smelter lists. | ||
| e. | Work with any suppliers found to be supplying Meritor with 3TG from sources that support armed conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict. | ||
| f. | Work with the AIAG to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance. | ||
| g. | Work with the AIAG to help expand the list of conflict free smelters and refiners. | ||
| h. | Monitor legislative changes to the Conflict Mineral rules to ensure compliance. |
| Smelter Name (*) | Country | Smelter Identification |
| Sabin Metal Corp. | UNITED STATES | CID001546 |
| Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
| Caridad | MEXICO | CID000180 |
| An Thai Minerals Co., Ltd. | VIETNAM | CID002825 |
| Estanho de Rondônia S.A. | BRAZIL | CID000448 |
| Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 |
| Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Phoenix Metal Ltd. | RWANDA | CID002507 |
| Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
| Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Elemetal Refining, LLC | UNITED STATES | CID001322 |
| Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Metalor USA Refining Corporation | UNITED STATES | CID001157 |
| Royal Canadian Mint | CANADA | CID001534 |
| Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 |
| Duoluoshan | CHINA | CID000410 |
| D Block Metals, LLC | UNITED STATES | CID002504 |
| F&X Electro-Materials Ltd. | CHINA | CID000460 |
| FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Global Advanced Metals Aizu | JAPAN | CID002558 |
| Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| H.C. Starck GmbH Goslar | GERMANY | CID002545 |
| H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| Exotech Inc. | UNITED STATES | CID000456 |
| H.C. Starck Ltd. | JAPAN | CID002549 |
| H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| KEMET Blue Metals | MEXICO | CID002539 |
| Global Advanced Metals Boyertown | UNITED STATES | CID002557 |
| H.C. Starck Inc. | UNITED STATES | CID002548 |
| King-Tan Tantalum Industry Ltd. | CHINA | CID000973 |
| LSM Brasil S.A. | BRAZIL | CID001076 |
| Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Hi-Temp Specialty Metals, Inc. | UNITED STATES | CID000731 |
| Mitsui Mining & Smelting | JAPAN | CID001192 |
| Molycorp Silmet A.S. | ESTONIA | CID001200 |
| KEMET Blue Powder | UNITED STATES | CID002568 |
| Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Resind Indústria e Comércio Ltda. | BRAZIL | CID002707 |
| QuantumClean | UNITED STATES | CID001508 |
| RFH Tantalum Smeltry Co., Ltd. | CHINA | CID001522 |
| Telex Metals | UNITED STATES | CID001891 |
| Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Tranzact, Inc. | UNITED STATES | CID002571 |
| Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
| Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 |
| Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Mineração Taboca S.A. | BRAZIL | CID001175 |
| An Vinh Joint Stock Mineral Processing Company | VIETNAM | CID002703 |
| Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Electro-Mechanical Facility of the Cao Bang Minerals Co | VIETNAM | CID002572 |
| Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| PT Karimun Mining | INDONESIA | CID001448 |
| Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Alpha | UNITED STATES | CID000292 |
| China Tin Group Co., Ltd. | CHINA | CID001070 |
| CV Ayi Jaya | INDONESIA | CID002570 |
| CV Gita Pesona | INDONESIA | CID000306 |
| CV Serumpun Sebalai | INDONESIA | CID000313 |
| CV United Smelting | INDONESIA | CID000315 |
| CV Venus Inti Perkasa | INDONESIA | CID002455 |
| Dowa | JAPAN | CID000402 |
| Elmet S.L.U. | SPAIN | CID002774 |
| EM Vinto | BOLIVIA | CID000438 |
| Fenix Metals | POLAND | CID000468 |
| Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | CID000244 |
| Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Metallic Resources, Inc. | UNITED STATES | CID001142 |
| Metallo-Chimique N.V. | BELGIUM | CID002773 |
| Mitsubishi Materials Corporation | JAPAN | CID001191 |
| O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Operaciones Metalurgical S.A. | BOLIVIA | CID001337 |
| PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| PT Babel Inti Perkasa | INDONESIA | CID001402 |
| PT Bangka Prima Tin | INDONESIA | CID002776 |
| PT Bangka Tin Industry | INDONESIA | CID001419 |
| PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| PT Bukit Timah | INDONESIA | CID001428 |
| PT Cipta Persada Mulia | INDONESIA | CID002696 |
| PT DS Jaya Abadi | INDONESIA | CID001434 |
| PT Eunindo Usaha Mandiri | INDONESIA | CID001438 |
| PT Panca Mega Persada | INDONESIA | CID001457 |
| PT Sukses Inti Makmur | INDONESIA | CID002816 |
| PT Sumber Jaya Indah | INDONESIA | CID001471 |
| PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 |
| PT Tommy Utama | INDONESIA | CID001493 |
| PT Wahana Perkit Jaya | INDONESIA | CID002479 |
| Resind Indústria e Comércio Ltda. | BRAZIL | CID002706 |
| Rui Da Hung | TAIWAN | CID001539 |
| Soft Metais Ltda. | BRAZIL | CID001758 |
| VQB Mineral and Trading Group JSC | VIETNAM | CID002015 |
| Yunnan Tin Company Limited | CHINA | CID002180 |
| Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 |
| PT Tirus Putra Mandiri | INDONESIA | CID002478 |
| PT Inti Stania Prima | INDONESIA | CID002530 |
| PT Mitra Stania Prima | INDONESIA | CID001453 |
| PT Prima Timah Utama | INDONESIA | CID001458 |
| PT Refined Bangka Tin | INDONESIA | CID001460 |
| PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | CID000295 |
| CV Dua Sekawan | INDONESIA | CID002592 |
| CV Tiga Sekawan | INDONESIA | CID002593 |
| Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
| Gejiu Jinye Mineral Company | CHINA | CID002859 |
| Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
| Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
| Mineração Taboca S.A. | BRAZIL | CID001173 |
| Minsur | PERU | CID001182 |
| Modeltech Sdn Bhd | MALAYSIA | CID002858 |
| PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
| PT O.M. Indonesia | INDONESIA | CID002757 |
| PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 |
| Thaisarco | THAILAND | CID001898 |
| White Solder Metalurgia e Mineração Ltda. | BRAZIL | CID002036 |
| Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
| A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
| Asia Tungsten Products Vietnam Ltd. | VIETNAM | CID002502 |
| Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 |
| Global Tungsten & Powders Corp. | UNITED STATES | CID000568 |
| Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM | CID002543 |
| Kennametal Huntsville | UNITED STATES | CID000105 |
| Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM | CID001889 |
| Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM | CID002011 |
| Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 |
| Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
| Dayu Jincheng Tungsten Industry Co., Ltd. | CHINA | CID002518 |
| Dayu Weiliang Tungsten Co., Ltd. | CHINA | CID000345 |
| Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Kennametal Fallon | UNITED STATES | CID000966 |
| H.C. Starck GmbH | GERMANY | CID002541 |
| H.C. Starck Smelting GmbH & Co.KG | GERMANY | CID002542 |
| Moliren Ltd | RUSSIAN FEDERATION | CID002845 |
| Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 |
| Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
| Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |