UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Glaukos Corporation
(Exact name of registrant as specified in its charter)
Delaware |
| 001-37463 |
| 33-0945406 |
(State or other jurisdiction |
| (Commission |
| (I.R.S. Employer |
of incorporation) |
| File Number) |
| Identification No.) |
229 Avenida Fabricante | 92672 | |
(Address of principal executive offices) |
| (Zip Code) |
Diana A. Scherer | (949) 367-9600 |
(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 the form applies:
⌧ Rule 13 p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020
Section 1 – Conflict Minerals Disclosure
Item 1.01Conflict Minerals Disclosure and Report
This Specialized Disclosure Report on Form SD of Glaukos Corporation (“Glaukos” or ”we” or “our”) for the reporting period from January 1, 2020 to December 31, 2020 is submitted to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”). Rule 13p-1 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 (together with Rule 13p-1, the “Conflict Minerals Rule”).
The description of the Company’s reasonable country of origin inquiry (“RCOI”) process, the results of our inquiry, and the determination we reached as a result of the RCOI are included in the Company’s Conflict Minerals Report, attached as an exhibit to this Form SD.
This Form SD and our Conflict Minerals Report, filed as an Exhibit to this Form SD, are publicly available on Glaukos’ Internet website under the “Investors” heading, which can be reached through the following link: http://investors.glaukos.com/investors/corporate-governance/Corporate-Responsibility/default.aspx. The content of any website referred to in this Form SD or the related Conflict Minerals Report is included for general information only and is not incorporated by reference in this Form SD or the related Conflict Minerals Report.
Item 1.02Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01Exhibits
The following exhibit is filed as part of this report.
Exhibit No. |
| Description | |
1.01 |
| Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD | |
| | | |
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
| GLAUKOS CORPORATION | |
| (Registrant) | |
| | |
| By: | /s/ Diane W. Biagianti |
| Name: | Diane W. Biagianti |
| Title: | Senior Vice President and General Counsel |
Date: May 28, 2021
Exhibit 1.01
Glaukos
Conflict Minerals Report
for the Year Ended December 31, 2020
Glaukos Corporation (“Glaukos,” “the Company,” “we,” “our,” and “us”) has filed this Conflict Minerals Report (“CMR”) for the year ended December 31, 2020 to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) issuers whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite- tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If any Conflict Minerals contained in an issuer’s manufactured products that are necessary to the functionality or production of such products may have originated in the Covered Countries, or if the issuer is unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals’ source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures.
Forward-Looking Statements and Other Disclaimers
This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, the Company’s risk mitigation and improvement plans may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to conflict minerals; (b) the ability of our suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward- looking statements are made as of the date hereof and we assume no obligation to update such statements.
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Glaukos. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect the accuracy of these statements. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) some suppliers and smelters are unfamiliar with the diligence process and information required to be provided, which could lead to inaccurate or incomplete responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in conflict free smelter audits, (xi) materials sourced from the Covered Countries could be inaccurately declared as sourced from outside the Covered Countries, (xii) illegally tagged Conflict Minerals could be introduced into the supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in
business, and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult.
Introduction
Glaukos is an ophthalmic medical technology and pharmaceutical company focused on developing novel therapies for the treatment of glaucoma, corneal disorders, and retinal disease. We developed Micro-Invasive Glaucoma Surgery (MIGS) to serve as an alternative to the traditional glaucoma treatment paradigm. We have developed a proprietary bio-activated pharmaceutical therapy for the treatment of keratoconus, a corneal disorder. We are also developing a pipeline of surgical devices, sustained pharmaceutical therapies, and implantable biosensors intended to treat glaucoma progression, corneal disorders such as keratoconus, dry eye and refractive vision correction, and retinal diseases such as neovascular age-related macular degeneration, diabetic macular edema, and retinal vein occlusion. Ophthalmic diseases and disorders are a national and global health concern and, as the population ages, the number of individuals with vision impairment and blindness is increasing. Moreover, improving access to cost-effective tools is increasing the diagnosis of sight-threatening ocular diseases globally and driving demand for innovative products, technologies, and therapies that improve clinical outcomes, and provide ease of use and reliability. In response to the significant unmet needs that exist within ophthalmology we have designed commercial and development-stage solutions to provide ophthalmologists with treatment options.
This CMR relates to the process undertaken for Glaukos products that were manufactured, or contracted to be manufactured, during calendar year 2020 and that contain Conflict Minerals.
Executive Summary
We performed a Reasonable Country of Origin Inquiry (“RCOI”) on our suppliers, including those we believe provided materials or components containing 3TGs necessary to the manufacturing of our products during calendar year 2020. We contacted each supplier requesting conflict minerals data using the Conflict Minerals Reporting Template (“CMRT”), and 83% of these suppliers responded to our inquiries. Our suppliers identified 306 valid smelters and refineries (“Smelters”). Of these 306 Smelters, we identified 33 as sourcing (or there was a reason to believe they may be sourcing) from the Covered Countries. Our due diligence review indicated that all 33 of these Smelters have been audited and recognized as conformant to the Responsible Minerals Assurance Process (“RMAP”). This process was in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”).
Company Management Systems
Glaukos established strong management systems based on Step 1 of the OECD Guidance.
● | Step 1A - Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. We adopted a conflict minerals policy as part of our Supplier Code of Conduct that is publicly available on our Investor website under the heading “Corporate Governance” at http://investors.glaukos.com. The Supplier Code of Conduct and Conflict Minerals Policy is communicated directly to our suppliers as part of the RCOI process. |
● | Step 1B - Structure internal management to support supply chain due diligence. We maintain a cross- functional internal team to support our supply chain due diligence efforts. This team reports its findings to a senior member of the supply chain management organization. |
● | Step 1C - Establish a system of transparency, information collection and control over the supply chain. We implemented a detailed process to collect required supplier and smelter RCOI and due diligence data. Full details on the supply chain data gathering are included in the RCOI and due diligence sections of this Report. |
● | Step 1D - Strengthen company engagement with suppliers. We engage directly with suppliers during the RCOI process. Additionally, we are taking steps to update the terms and conditions that apply to suppliers with whom we enter into contracts to require them to work with us to source materials from smelters that, if sourcing from conflict-affected or high-risk areas, are either conformant with the RMI’s Responsible Minerals Assurance Process assessment protocols or are working towards conformance. We have also implemented a plan to improve the quantity and quality of supplier and smelter responses year-over-year. |
● | Step 1E - Establish a company level grievance mechanism. Our employees and suppliers can anonymously report a violation of our policies according to our Code of Business Conduct and Ethics by calling 1-866-910-3108, and online at https://glaukos.ethicaladvocate.com for suppliers and employees to report violations, ask questions and voice concerns. |
Reasonable Country of Origin Inquiry (RCOI)
We designed our RCOI process in accordance with Steps 2A and 2B of the OECD Guidance. Our RCOI process involved two stages:
● | Stage 1 - Supplier RCOI (Step 2A of the OECD Guidance) |
● | Stage 2 - Smelter RCOI (Step 2B of the OECD Guidance) |
For the 2020 reporting period, Glaukos’s RCOI process was executed by Claigan Environmental Inc. (“Claigan”).
Supplier RCOI
We designed our supplier RCOI process to identify the smelters in our supply chain. Our supplier RCOI process for the 2020 reporting period included:
● | developing a list of suppliers providing components that may contain 3TG |
● | contacting each supplier and requesting Conflict Minerals data using the industry-standard CMRT |
● | reviewing supplier responses for accuracy and completeness |
● | aggregating supplier-provided smelters into a single unique list of smelters meeting the definition of a smelter under one of three industry-recognized audit protocols |
● | reviewing the final smelter list (and comparing it to industry peers) to determine if we reasonably identified all the smelters in our supply chain. |
Through the supplier RCOI process, we identified 306 Smelters in our supply chain.
Smelter RCOI
Due to the overlap between smelter RCOI and smelter due diligence, the smelter RCOI process is summarized in the due diligence section of this report.
Due Diligence
Glaukos’s Due Diligence Process was designed in accordance with the applicable sections of Steps 2, 3, and 4 of the OECD Guidance.
For the 2020 reporting period, Glaukos’s smelter RCOI and Due Diligence process were executed by Claigan.
Smelter RCOI and Due Diligence
Glaukos’s smelter RCOI and due diligence processes were designed to meet the criteria of Step 2 of the OECD Guidance.
We engaged with each smelter identified in our supply chain to determine whether or not they sourced from the Covered Countries. For smelters that confirmed, either directly or through industry associations, that they did not source from the Covered Countries but who were not recognized as conformant to the RMAP, we reviewed publicly available information to determine whether there was any evidence that contradicted the smelter’s declaration. In doing so, we reviewed sources such as NGO publications, including the Enough Project, Global Witness, Southern Africa Resource Watch and Radio Okapi. We also consulted the most recent United Nations Group of Experts reports on the DRC and performed public internet searches.
If smelters did not respond to our inquiry, we reviewed the same publicly available sources to determine whether there was reason to believe the smelter may have sourced from the Covered Countries during the reporting period.
We categorize smelters that are sourcing (or that we have reason to believe may be sourcing) from the Covered Countries and not currently RMAP Conformant as high-risk. This year, we did not identify any smelters in our supply chain that met this definition of a high-risk smelter.
Our suppliers identified 306 unique smelters, of which 33 smelters source, or there is a reason to believe they may source, from the Covered Countries. We determined that all 33 of these smelters have been audited and recognized as conformant to the RMAP.
Risk Mitigation
This year, we did not identify any smelters in our supply chain that met the definition of a high-risk smelter. We will continue to monitor our supply chain, and, should the situation arise, we will conduct risk mitigation according to Step 3 of the OECD Guidance.
Risk Mitigation Improvement Plan
Glaukos is committed to continuous improvement in our due diligence process to further mitigate the risk that the 3TG materials in our products could directly or indirectly benefit or finance armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts will require suppliers to provide information that will allow us to evaluate their Conflict Mineral sourcing status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from RMAP conformant smelters when sourcing material from the Covered Countries.
Smelters and Refineries
3TG Metal | Standard Smelter Name |
Gold | 8853 S.p.A. |
Gold | Abington Reldan Metals, LLC |
Gold | Advanced Chemical Company |
Gold | Aida Chemical Industries Co., Ltd. |
Gold | Al Etihad Gold Refinery DMCC |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
Gold | AngloGold Ashanti Córrego do Sítio Mineração |
Gold | Argor-Heraeus S.A. |
Gold | Asahi Pretec Corp. |
Gold | Asahi Refining Canada Ltd. |
Gold | Asahi Refining USA Inc. |
Gold | Asaka Riken Co., Ltd. |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
Gold | AU Traders and Refiners |
Gold | Aurubis AG |
Gold | Bangalore Refinery |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Gold | Boliden AB |
Gold | C. Hafner GmbH + Co. KG |
Gold | Caridad |
Gold | CCR Refinery - Glencore Canada Corporation |
Gold | Cendres + Métaux S.A. |
Gold | CGR Metalloys Pvt Ltd. |
Gold | Chimet S.p.A. |
Gold | Chugai Mining |
Gold | Daye Non-Ferrous Metals Mining Ltd. |
Gold | Degussa Sonne / Mond Goldhandel GmbH |
Gold | DODUCO Contacts and Refining GmbH |
Gold | Dowa |
Gold | DS PRETECH Co., Ltd. |
Gold | DSC (Do Sung Corporation) |
Gold | Eco-System Recycling Co., Ltd. East Plant |
Gold | Eco-System Recycling Co., Ltd. North Plant |
Gold | Eco-System Recycling Co., Ltd. West Plant |
Gold | Emirates Gold DMCC |
Gold | Geib Refining Corporation |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
Gold | Guangdong Jinding Gold Limited |
Gold | Gujarat Gold Centre |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
Gold | Heimerle + Meule GmbH |
Gold | Heraeus Metals Hong Kong Ltd. |
Gold | Heraeus Precious Metals GmbH & Co. KG |
Gold | Hunan Chenzhou Mining Co., Ltd. |
Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
Gold | HwaSeong CJ Co., Ltd. |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
Gold | Ishifuku Metal Industry Co., Ltd. |
Gold | Istanbul Gold Refinery |
Gold | Italpreziosi |
Gold | Japan Mint |
Gold | Jiangxi Copper Co., Ltd. |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
Gold | JSC Uralelectromed |
Gold | JX Nippon Mining & Metals Co., Ltd. |
Gold | Kazakhmys Smelting LLC |
Gold | Kazzinc |
Gold | Kennecott Utah Copper LLC |
Gold | KGHM Polska Miedź Spółka Akcyjna |
Gold | Kojima Chemicals Co., Ltd. |
Gold | Korea Zinc Co., Ltd. |
Gold | Kyrgyzaltyn JSC |
Gold | Kyshtym Copper-Electrolytic Plant ZAO |
Gold | L’azurde Company For Jewelry |
Gold | L’Orfebre S.A. |
Gold | Lingbao Gold Co., Ltd. |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
Gold | LS-NIKKO Copper Inc. |
Gold | LT Metal Ltd. |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
Gold | Marsam Metals |
Gold | Materion |
Gold | Matsuda Sangyo Co., Ltd. |
Gold | Metalor Technologies (Hong Kong) Ltd. |
Gold | Metalor Technologies (Singapore) Pte., Ltd. |
Gold | Metalor Technologies (Suzhou) Ltd. |
Gold | Metalor Technologies S.A. |
Gold | Metalor USA Refining Corporation |
Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. |
Gold | Mitsubishi Materials Corporation |
Gold | Mitsui Mining and Smelting Co., Ltd. |
Gold | MMTC-PAMP India Pvt., Ltd. |
Gold | Modeltech Sdn Bhd |
Gold | Morris and Watson |
Gold | Moscow Special Alloys Processing Plant |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. |
Gold | Navoi Mining and Metallurgical Combinat |
Gold | NH Recytech Company |
Gold | Nihon Material Co., Ltd. |
Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH |
Gold | Ohura Precious Metal Industry Co., Ltd. |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
Gold | OJSC Novosibirsk Refinery |
Gold | PAMP S.A. |
Gold | Pease & Curren |
Gold | Penglai Penggang Gold Industry Co., Ltd. |
Gold | Planta Recuperadora de Metales SpA |
Gold | Prioksky Plant of Non-Ferrous Metals |
Gold | PT Aneka Tambang (Persero) Tbk |
Gold | PX Précinox S.A. |
Gold | QG Refining, LLC |
Gold | Rand Refinery (Pty) Ltd. |
Gold | Refinery of Seemine Gold Co., Ltd. |
Gold | REMONDIS PMR B.V. |
Gold | Royal Canadian Mint |
Gold | SAAMP |
Gold | Sabin Metal Corp. |
Gold | Safimet S.p.A |
Gold | SAFINA A.S. |
Gold | Sai Refinery |
Gold | Samduck Precious Metals |
Gold | SAMWON Metals Corp. |
Gold | SAXONIA Edelmetalle GmbH |
Gold | SEMPSA Joyería Platería S.A. |
Gold | Shandong Humon Smelting Co., Ltd. |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
Gold | Sichuan Tianze Precious Metals Co., Ltd. |
Gold | Singway Technology Co., Ltd. |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
Gold | Solar Applied Materials Technology Corp. |
Gold | Sovereign Metals |
Gold | State Research Institute Center for Physical Sciences and Technology |
Gold | Sumitomo Metal Mining Co., Ltd. |
Gold | SungEel HiMetal Co., Ltd. |
Gold | T.C.A S.p.A |
Gold | Tanaka Kikinzoku Kogyo K.K. |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. |
Gold | Tokuriki Honten Co., Ltd. |
Gold | Tongling Nonferrous Metals Group Co., Ltd. |
Gold | TOO Tau-Ken-Altyn |
Gold | Torecom |
Gold | Umicore Precious Metals Thailand |
Gold | Umicore S.A. Business Unit Precious Metals Refining |
Gold | United Precious Metal Refining, Inc. |
Gold | Valcambi S.A. |
Gold | Western Australian Mint (T/a The Perth Mint) |
Gold | WIELAND Edelmetalle GmbH |
Gold | Yamakin Co., Ltd. |
Gold | Yokohama Metal Co., Ltd. |
Gold | Yunnan Copper Industry Co., Ltd. |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
Tantalum | Asaka Riken Co., Ltd. |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
Tantalum | D Block Metals, LLC |
Tantalum | Exotech Inc. |
Tantalum | F&X Electro-Materials Ltd. |
Tantalum | FIR Metals & Resource Ltd. |
Tantalum | Global Advanced Metals Aizu |
Tantalum | Global Advanced Metals Boyertown |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. |
Tantalum | H.C. Starck Co., Ltd. |
Tantalum | H.C. Starck Hermsdorf GmbH |
Tantalum | H.C. Starck Inc. |
Tantalum | H.C. Starck Ltd. |
Tantalum | H.C. Starck Smelting GmbH & Co. KG |
Tantalum | H.C. Starck Tantalum and Niobium GmbH |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
Tantalum | Jiangxi Tuohong New Raw Material |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
Tantalum | Jiujiang Tanbre Co., Ltd. |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
Tantalum | KEMET Blue Metals |
Tantalum | LSM Brasil S.A. |
Tantalum | Metallurgical Products India Pvt., Ltd. |
Tantalum | Mineração Taboca S.A. |
Tantalum | Mitsui Mining & Smelting |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
Tantalum | NPM Silmet AS |
Tantalum | PRG Dooel |
Tantalum | QuantumClean |
Tantalum | Resind Indústria e Comércio Ltda. |
Tantalum | Solikamsk Magnesium Works OAO |
Tantalum | Taki Chemical Co., Ltd. |
Tantalum | Telex Metals |
Tantalum | Ulba Metallurgical Plant JSC |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
Tin | Alpha |
Tin | An Vinh Joint Stock Mineral Processing Company |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
Tin | China Tin Group Co., Ltd. |
Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
Tin | CRM Synergies |
Tin | CV Ayi Jaya |
Tin | CV Venus Inti Perkasa |
Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
Tin | Dowa |
Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
Tin | EM Vinto |
Tin | Estanho de Rondônia S.A. |
Tin | Fenix Metals |
Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
Tin | Gejiu Fengming Metallurgy Chemical Plant |
Tin | Gejiu Kai Meng Industry and Trade LLC |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
Tin | HuiChang Hill Tin Industry Co., Ltd. |
Tin | Jiangxi New Nanshan Technology Ltd. |
Tin | Luna Smelter, Ltd. |
Tin | Ma’anshan Weitai Tin Co., Ltd. |
Tin | Magnu’s Minerais Metais e Ligas Ltda. |
Tin | Malaysia Smelting Corporation (MSC) |
Tin | Melt Metais e Ligas S.A. |
Tin | Metallic Resources, Inc. |
Tin | Metallo Belgium N.V. |
Tin | Metallo Spain S.L.U. |
Tin | Mineração Taboca S.A. |
Tin | Minsur |
Tin | Mitsubishi Materials Corporation |
Tin | Modeltech Sdn Bhd |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
Tin | Novosibirsk Processing Plant Ltd. |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
Tin | O.M. Manufacturing Philippines, Inc. |
Tin | Operaciones Metalúrgicas S.A. |
Tin | Pongpipat Company Limited |
Tin | Precious Minerals and Smelting Limited |
Tin | PT Aries Kencana Sejahtera |
Tin | PT Artha Cipta Langgeng |
Tin | PT ATD Makmur Mandiri Jaya |
Tin | PT Babel Inti Perkasa |
Tin | PT Babel Surya Alam Lestari |
Tin | PT Bangka Serumpun |
Tin | PT Bukit Timah |
Tin | PT Lautan Harmonis Sejahtera |
Tin | PT Menara Cipta Mulia |
Tin | PT Mitra Stania Prima |
Tin | PT Mitra Sukses Globalindo |
Tin | PT Prima Timah Utama |
Tin | PT Rajawali Rimba Perkasa |
Tin | PT Rajehan Ariq |
Tin | PT Refined Bangka Tin |
Tin | PT Stanindo Inti Perkasa |
Tin | PT Timah Tbk Kundur |
Tin | PT Timah Tbk Mentok |
Tin | PT Tinindo Inter Nusa |
Tin | Resind Indústria e Comércio Ltda. |
Tin | Rui Da Hung |
Tin | Soft Metais Ltda. |
Tin | Super Ligas |
Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. |
Tin | Thaisarco |
Tin | Tin Technology & Refining |
Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
Tin | VQB Mineral and Trading Group JSC |
Tin | White Solder Metalurgia e Mineração Ltda. |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
Tin | Yunnan Tin Company Limited |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
Tungsten | A.L.M.T. Corp. |
Tungsten | ACL Metais Eireli |
Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
Tungsten | Artek LLC |
Tungsten | Asia Tungsten Products Vietnam Ltd. |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. |
Tungsten | China Molybdenum Co., Ltd. |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
Tungsten | CNMC (Guangxi) PGMA Co., Ltd. |
Tungsten | Cronimet Brasil Ltda |
Tungsten | Fujian Ganmin RareMetal Co., Ltd. |
Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
Tungsten | GEM Co., Ltd. |
Tungsten | Global Tungsten & Powders Corp. |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
Tungsten | H.C. Starck Smelting GmbH & Co. KG |
Tungsten | H.C. Starck Tungsten GmbH |
Tungsten | Hunan Chenzhou Mining Co., Ltd. |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. |
Tungsten | Hunan Litian Tungsten Industry Co., Ltd. |
Tungsten | Hydrometallurg, JSC |
Tungsten | Japan New Metals Co., Ltd. |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
Tungsten | JSC "Kirovgrad Hard Alloys Plant" |
Tungsten | Kennametal Fallon |
Tungsten | Kennametal Huntsville |
Tungsten | KGETS Co., Ltd. |
Tungsten | Lianyou Metals Co., Ltd. |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
Tungsten | Masan Tungsten Chemical LLC (MTC) |
Tungsten | Moliren Ltd. |
Tungsten | Niagara Refining LLC |
Tungsten | NPP Tyazhmetprom LLC |
Tungsten | Philippine Chuangxin Industrial Co., Inc. |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. |
Tungsten | Unecha Refractory Metals Plant |
Tungsten | Wolfram Bergbau und Hütten AG |
Tungsten | Woltech Korea Co., Ltd. |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
Tungsten | Xiamen Tungsten Co., Ltd. |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
Thirty-three of the 306 unique Smelters identified during our RCOI either declared that they were sourcing, or there was reason to believe were sourcing, from the Covered Countries. Based on the Smelters’ disclosures and the publicly available information, we have reason to believe these Smelters may be sourcing from the following Covered Countries: The Democratic Republic of the Congo, Rwanda, Burundi, Uganda, and Tanzania. Our due diligence review indicated that all 33 of these Smelters have been audited and recognized as conformant to the RMAP.