EX-1.01 2 ex_188266.htm EXHIBIT 1.01 ex_188266.htm

EX-1.01 (Exhibit 1.01)

 

Conflict Minerals Report of Ormat Technologies, Inc.

For the Year Ended December 31, 2019

 

 

Introduction:

 

We are a Delaware corporation, whose shares of common stock are listed on the New York Stock Exchange and on the Tel Aviv Stock Exchange and are registered with the Securities and Exchange Commission (the "SEC").

 

We are a leading vertically integrated company, that is primarily engaged in the geothermal and recovered energy-based power businesses. We are also expanding into the solar Photovoltaic and energy storage and management services business, with the objective of becoming a leading global provider of renewable energy.

This is the Conflict Minerals Report (this "Report") of Ormat Technologies, Inc. ("Ormat", the "Company" or "we") for the reporting period from January 1, 2019 to December 31, 2019, which has been prepared in accordance with Rule13p-1 (“Rule 13p-1”), promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Rule 13p-1 requires every registrant that files reports with the SEC under Sections 13(a) or 15 (d) of the Exchange Act to disclose certain information when the registrant manufactures or contracts to manufacture products and when the minerals specified in Rule 13p-1 are necessary to the functionality or production of those products. The specified minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (collectively, the “Conflict Minerals” or “3TG”), that originate, or are likely originate, in the Democratic Republic of the Congo (the “DRC”) and certain adjoining countries (collectively with the DRC, the “Covered Countries”).

 

As part of Ormat's sustainability approach, our Code of Conduct outlines the Company‘s overall principles and commitments to legal compliance, ethical conduct, human rights, anti-corruption, labor rights and environmental protection. These high expectations extend to Ormat's partners, subcontractors and suppliers. We have adopted a policy (the “Conflict Minerals Policy”) with respect to our sourcing of Conflict Minerals, which was developed in accordance with the OECD guidance, and we implement a comprehensive Conflict Minerals program aimed to ensure responsible sourcing. Our Conflict Minerals Policy is available at http://www.ormat.com/social-responsibility-and-sustainability.

 

Unless otherwise defined herein, defined terms used in this Report have the meaning ascribed to such terms in Rule 13p-1 and Form SD.

 

 

 

 

1.

Overview

 

Company Overview

 

Ormat and its subsidiaries currently conduct business activities in the following three business segments:

 

 

Electricity Segment: In this segment, we develop, build, own and operate geothermal, solar PV and recovered energy-based power plants in the United States and geothermal power plants in other countries around the world and sell the electricity they generate.

 

Product Segment: In this segment, we design, manufacture and sell equipment for geothermal and recovered energy-based electricity generation and remote power units and provide services relating to the engineering, procurement, construction, of geothermal, and recovered energy-based power plants.

 

Energy Storage and Management Services Segment: In the Energy Storage and Management Services segment, we provide energy storage, demand response and energy management related services, as well as services relating to the engineering, procurement, construction, operation and maintenance of energy storage units mainly through our Viridity business.

 

Our customers for the Product segment are contractors, geothermal power plant owners and geothermal power plant developers and operators.

 

For more information about Ormat, please visit www.ormat.com. The content of any website referred to in this Report is included for general information only and is not incorporated by reference herein

 

Supply Chain

 

In accordance with applicable SEC rules, we conducted due diligence on the source and chain of custody of the Conflict Minerals used in our Product Segment. We concluded that no such examination is necessary with respect to the Electricity Segment or the Energy Storage and Management Services Segment because neither of these segments involves the sale of products by the Company.

 

In connection with our manufacturing activities in the Product Segment, we identified certain Conflict Minerals that are used by us and that are necessary to the functionality and production of our products with regards to the following raw materials or components: steel (low and high grade), electronic cards and electronic cables (including tin plating). These materials are purchased from our network of suppliers. As a downstream company that does not work directly with the smelters or refiners of the necessary Conflict Minerals, we work with our large network of international suppliers to obtain information on the likely source and chain of custody of those necessary Conflict Minerals and often there are multiple tiers between the gold, tin, tantalum and tungsten (“3TG”) mines and our direct suppliers. Therefore, we rely on our direct Tier 1 suppliers to cooperate with us and work with their own upstream suppliers or subcontractors to provide us with information on the origin of the 3TG in the components we purchase from them that are necessary to the functionality or production of our products. In order to overcome certain challenges in receiving accurate information from a complex supply chain, Ormat has communicated its Conflict Minerals Policy to our suppliers, and has adopted the Responsible Minerals Initiative's ("RMI") reporting template for surveying suppliers, i.e. the Conflict Minerals Reporting Template ("CMRT") of at least version 5.10 or above.

 

 

 

 

2.

Reasonable Country of Origin Inquiry (RCOI)

 

Ormat has conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether any of the necessary Conflict Minerals originated, or likely originated, in the DRC or Covered Countries or originated entirely from "recycled or scrap sources" (as such terms are defined in Rule 13p-1). In parallel, we conduct due diligence on our mineral supply chain in order to investigate, to a reasonable degree of accuracy, the likely source and chain of custody of the necessary Conflict Minerals used in our products or product components that is sourced from our global network of suppliers.

 

As part of our RCOI, we employed several methods to assess whether the necessary Conflict Minerals in our products originated, or likely originated, in the DRC or the Covered Countries, including the following:

 

 

Internal assessment and analysis of our products manufactured or contracted to manufacture in 2019 to determine which products contain or may contain Conflict Minerals that are necessary to the functionality or production of those products.

 

Compiled a list of applicable suppliers based on relevant product categories that Ormat purchased from during the calendar year 2019, which list was issued using the Ormat Management System (“OMS”) by information technology developers and according to the criteria defined by the OMS manager and the purchasing manager. The list includes a total of 1,412 suppliers. Each supplier has a "Purchase Types" field, which contains one of the following values: Services, BOM, Office supplier, Goods and Capital Expenditure. Only the suppliers with "BOM" values in the "Purchase Types" field were applicable for the RCOI under Rule 13p-1.

 

In order to identify and assess risks in the supply chain, we undertook a risk-based approach and engaged the suppliers representing approximately 90% of our 2019 expenditures on procurement for the Product Segment. On that basis, Ormat's final direct Tier 1 suppliers list ("relevant suppliers") includes a total of 122 suppliers, from which duplicate suppliers were removed to arrive at a total of 116 relevant suppliers for the RY2019 supply chain inquiry.

 

 

 

 

Contracted a third-party service provider to assist us with the survey of suppliers. Through this third-party service provider, we sent letters to our relevant suppliers to explain Rule 13p-1 and to refer the suppliers to online training materials and instructions.

 

We solicited information from our relevant suppliers of raw materials and components of products using the standard template of the independent third-party audit body, the Responsible Minerals Initiative (“RMI”), known as the Conflict Minerals Reporting Template (“CMRT”). We requested that our suppliers provide at least version 5.10 of the CMRT. The CMRT is designed to facilitate the transfer of information through the supply chain regarding each mineral’s country of origin, or likely country of origin, and the relevant smelters or refiners. The CMRT requires suppliers to make representations regarding: (i) the country of origin, or likely country of origin, for the Conflict Minerals contained in the components or products it provides to the Company; (ii) all of the smelters or refiners in the supplier’s supply chain for such Conflict Minerals; (iii) whether such smelters or refiners have been validated as being in compliance with the RMI’s Responsible Minerals Assurance Process (the “RMAP”); (iv) whether the supplier has its own Conflict Minerals Policy that requires its own direct suppliers to be “DRC conflict-free”; and (v) whether the supplier collects Conflict Minerals information in a standardized format, such as the CMRT, from its own suppliers. Communications from the Company to its suppliers and responses received from the suppliers are stored electronically by the Company, together with copies of internal communications that relate to the Company’s due diligence, for a period of up to five years, as recommended by the relevant OECD Guidance.

 

Reviewed the responses that we received and followed up on inconsistent, incomplete, and inaccurate responses. We sent reminders to suppliers who did not respond to our requests for information or to suppliers whose responses required further clarification, as per the expectations noted above. We compared information received from our direct suppliers on their relevant smelters or refiners against the list of facilities that have been validated by RMAP, receiving a "conformant" or "active" status, as well as the documented country of origin information as provided in the declarations from the suppliers. The complete list of smelters or refiners identified in the scope of our supply chain inquiry is included as Annex 1 hereto and the complete list of counties of origin, or likely countries of origin, to the best of our knowledge, is included in Annex 2 hereto.

 

Currently, we do not have sufficient information from our suppliers to determine the complete list of countries of origin of the Conflict Minerals used in our products or the facilities used to process those Conflict Minerals. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the DRC or Covered Countries or are not entirely from recycled or scrap sources.

 

Based on these results, Ormat conducted due diligence activities and described these activities in this Report.

 

 

 

 

3.

Due Diligence Framework

 

We designed our due diligence measures to be in conformity, in all material respects, with the internationally recognized due diligence framework as set forth in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten.

 

 

4.

Due Diligence Measures

 

Our due diligence efforts for the reporting period from January 1, 2019 to December 31, 2019 included the following steps:

 

4.1

Establish strong Company management systems for Conflict Minerals supply chain due diligence and reporting compliance

 

The Company implemented the following measures:

 

 

Established a cross-functional Conflict Minerals steering committee comprised of representatives from procurement, legal and finance departments to direct the overall efforts of the Conflict Minerals compliance program, with the Senior Vice President of Finance as the process owner.

 

Continued to implement our Conflict Minerals Policy with respect to sourcing of minerals from the DRC and the Covered Countries. Our Conflict Minerals Policy provides further clarification to the principles of the Code of Conduct and Ormat's Human Rights Approach, as outlined in our Human Rights & Labor Policy, regarding illegal trade of natural resources and promotes the procurement of minerals from credible and conflict-free sources. Pursuant to our Conflict Minerals Policy, we strive to ensure that purchased metals originate only from smelters or refiners that have been validated as being “conformant” or “active” by the RMI's RMAP; however the Company does not seek to eliminate sourcing from the DRC or Covered Countries. In addition, we expect our suppliers to comply with the terms of our Conflict Minerals Policy and encourage them to define, implement and communicate to their sub-suppliers their own policies outlining their commitment to responsible sourcing of these materials, legal compliance and measures for implementation. The Company's Conflict Minerals Policy is available at: http://www.ormat.com/social-responsibility-and-sustainability.

 

Maintain a grievance mechanism through which concerns and violations of the Conflict Minerals Policy can be reported to Ormat:

 

online via our website www.ormat.com; or

 

by electronic mail to the following address: ormat@ormat.com.

 

Strengthened its engagement with suppliers by referring suppliers to training materials that included an overview of the applicable SEC rules and instructions on how to respond to the survey.

 

 

 

 

Required our suppliers to provide us the information required to perform our analysis of Conflict Minerals.

  Implemented a requirement to maintain records relating to Conflict Minerals due diligence and responsible mineral sourcing for a minimum of five years.

 

4.2

Identify and assess risks in the supply chain

 

To identify risks in our supply chain, we undertook the following measures:

 

We identified two risks in the supply chain: (i) the risk of not receiving timely and accurate information from the supplier; and (ii) the risk of not being able to replace a supplier, when aiming to move towards the goal of responsible sourcing of Conflict Minerals to ensure that the purchase and sourcing of such minerals does not benefit or fund the armed conflict and human rights abuses on-going in the DRC or Covered Countries, or in other conflict-affected areas. We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers’ characteristics, including the extent to which the Company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to focus our risk mitigation efforts according to the supplier level of risk.

As part of the risk assessment phase, Ormat decided to focus on the top approximately 90% of the purchasing spend in 2019. We have identified that, out of the responses received, 31% of Ormat's relevant suppliers have a policy in place that addresses the sourcing of Conflict Minerals.

Responses received were subject to a "red flag" review. Responses that we identified as incomplete or inconsistent based on the red flag review process were marked for follow up. We identified the smelters or refiners that are likely a part of our mineral supply chain by conducting a supply chain survey using the CMRT (at least version 5.10 or higher), requesting suppliers to identify relevant smelters or refiners and country of origin, or likely country of origin, of the Conflict Minerals in products supplied to Ormat in 2019. In addition, we compared smelters and refiners identified by the supply chain survey against the list of facilities that received RMAP’s “conformant” and “active” designations. The RMAP is a program in which the RMI works with independent third-party auditors or cross-certification programs to audit the source, including mines of origin and chains of custody, of the Conflict Minerals processed by smelters and refiners that agree to undergo an audit or to take part in a cross-certification program.

 

 

A smelter or refiner receives an RMAP “conformant” designation from the RMI if the smelter or refiner (i) completes an independent third-party audit, (ii) adheres to the RMAP’s assessment protocols by disclosing to auditors the identities and locations of the mines from which it sources Conflict Minerals, (iii) has been found by its independent third-party auditor to possess the systems and processes to support responsible sourcing of Conflict Minerals and can provide evidence to support its sourcing activities and (iv) maintains good standing in the program, through a continual validation process. The RMI’s RMAP “conformant” list provides the names, locations and links to Conflict Minerals policies of all smelters and refiners deemed compliant with the RMAP’s assessment protocols. Smelters and refiners with a “re-audit in progress” are still considered to be RMAP “conformant.”

 

 

 

 

Smelters and refiners labeled as RMAP “active” by the RMI have committed to undergo an audit, which may be in progress, or are participating in one of the cross-recognized certification programs, namely, the London Bullion Market Association Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. “Active” smelters and refiners may be at various stages of the audit cycle, anywhere from completion of the necessary documents to scheduling the audit date to enacting corrective actions in the post-audit phase. They may not retain their “active” status if, among other things, they are unresponsive to requests for re-audit or corrective action past a certain time.

 

Companies that have been determined to be downstream of smelters or refiners may not take part in the RMAP. However, they may participate in the RMI’s Downstream Audit Program, an independent validation of companies’ sourcing practices outside of the RMAP audit process.

 

 

4.3

Design and implement a strategy to respond to identified risks

 

To address the risks in our supply chain, Ormat maintains a risk mitigation plan, which includes the following:

 

Ormat expects its suppliers to define, implement and communicate to sub-suppliers their own policy, outlining their commitment to responsible sourcing of these materials, and legal compliance and measures for implementation. We also ask suppliers to work with sub-tier suppliers to ensure traceability of these materials at least to the smelter or refiner level, e.g., by using a recent version of the CMRT.

Ormat's senior management, including the CEO, CFO, EVP Electricity, EVP Products and Operations, EVP Business Development and Marketing, and the Legal Counsel and Chief Compliance Officer, was updated with the risk analysis and risk management actions and outcomes.

Suppliers who provided incomplete or inconsistent responses were sent a corrective action letter for follow up, requesting clarification.

Suppliers that did not respond to our initial survey request were sent follow-up letters requesting that they provide the necessary information.

 

Supply chain due diligence is a dynamic process that requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process and update the risk mitigation strategy accordingly.

 

4.4   Carry out independent third-party audit of smelter/refiner’s due diligence practices

 

We do not typically have direct relationships with 3TG smelters or refiners of Conflict Minerals and therefore do not perform direct audits of these entities. As a result, our due diligence efforts relied on independent third-party audit body and cross- industry initiatives, such as those led by the RMI, to conduct smelter or refiner due diligence.

 

 

 

4.5 Report on supply chain due diligence

 

Our Conflict Minerals Policy was adopted with a view to assuring compliance with Section 1502 of the Dodd Frank Act, which requires the filing of a Form SD and this Report with the SEC and disclosure of them on its publicly available Internet website. The Company's Conflict Minerals Reports can be viewed at: http://www.ormat.com/social-responsibility-and-sustainability.

 

5

The Company’s Due Diligence Findings and Conclusions

 

We conducted a supply-chain survey of the 116 relevant suppliers that we identified as potentially contributing the necessary Conflict Minerals contained in our products in 2019. The overall response rate to this survey was approximately 50%. The responses included the names and locations of smelters or refiners (see Annex 1) and possible countries of origin, according to the information provided in our suppliers' declarations (see Annex 2).

 

Our supply chain is complex and there are multiple tiers between the Company and the mines or facilities that process the necessary Conflict Minerals. Accordingly, we rely on our suppliers to provide information on the origin of the 3TG contained in components that are supplied to us to be included in our products.

 

Despite receiving responses from suppliers listing smelter or refiner names in their supply chain, the suppliers were largely unable to accurately report which specific smelters or refiners were part of the supply chain of the components that were sold to Ormat in 2019.

 

In light of inconclusive information, we are unable to determine and to describe the full list of facilities used to process 3TG or their countries of origin. In addition, the information gathered from our suppliers is not gathered on a continuous real-time basis.

 

Smelters or refiners verified as RMAP Conformant or Active:

 

Tantalum

43 of 51 (84.3%)

Tin

70 of 109 (64.2%)

Tungsten

40 of 58 (68.9%)

Gold

108 of 166 (65.1%) 

Total

261 of 384 (67.9%)

 

 

 

Status of identified smelters or refiners:

 

 

2019

“RMAP Conformant”1

252

“RMAP Active”2

9

“Not RMAP Conformant or Active”3

123

Total

384

 

6. Steps to be taken to mitigate risk

 

The Company has taken, and intends to continue to take, steps to improve its due diligence processes. Due diligence is an ongoing, proactive and reactive process, and the Company is continually working to improve its methods and processes for identifying the source or likely source of the Conflict Minerals contained in its Covered Products. The Company plans to continue to inform suppliers of their role in the Company’s Conflict Minerals compliance program and to engage its suppliers to obtain current, accurate and complete information regarding their mineral supply chains. The Company intends to monitor the performance and efficiency of its due diligence efforts to ensure responsible sourcing in compliance with its Conflict Minerals Policy and increase transparency in its supply chain.

 

Specific steps the Company has taken and continues to take to manage risks include:

 

Continue working with our global supply chain to obtain current, accurate and complete information about the supply chain, ensure responsible sourcing, while also assuring compliance with certain international regulations.

 

Continue to strengthen communications with suppliers in order to improve the number of suppliers that respond to the company's supply chain surveys and requests for information.

 

Continue to improve due diligence efforts to ensure responsible sourcing in compliance with the Conflict Minerals Policy.

 

 

 

Caution Concerning Forward- Looking Statements

 

Information provided in this Report may contain statements relating to current expectations and plans that are "forward- looking statements" as defined in the Private Securities Litigation Reform Act of 1995. These forward- looking statements generally relate to Ormat's plans, objectives and expectations for future plans and events and are based upon its management's current estimates. These statements are subject to risks and uncertainties and may not prove to be accurate. These risks and uncertainties include our ability to achieve our plans and goals, including with respect to our business and Conflict Minerals, and the "Risk Factors" as described in Ormat Technologies, Inc.'s Annual Report on Form 10- K filed with the Securities and Exchange Commission on March 2, 2020 and its other filings. These forward- looking statements are made only as of the date hereof, and, except as required by applicable law, we undertake no obligation to update or revise the forward- looking statements, whether as a result of new information, future events or otherwise.

 

 

 

Annex 1- Smelter or Refiner Names in Supply Chain

 

Metal

Smelter Name

Smelter Country

Smelter Status

Gold

8853 S.p.A.

ITALY

Compliant

Gold

Abington Reldan Metals, LLC

UNITED STATES OF AMERICA

Not certified

Gold

Advanced Chemical Company

UNITED STATES OF AMERICA

Compliant

Gold

African Gold Refinery

UGANDA

Not certified

Gold

Aida Chemical Industries Co., Ltd.

JAPAN

Compliant

Gold

Al Etihad Gold Refinery DMCC

UNITED ARAB EMIRATES

Compliant

Gold

Allgemeine Gold-und Silberscheideanstalt A.G.

GERMANY

Compliant

Gold

Almalyk Mining and Metallurgical Complex (AMMC)

UZBEKISTAN

Compliant

Gold

AngloGold Ashanti Corrego do Sitio Mineracao

BRAZIL

Compliant

Gold

Argor-Heraeus S.A.

SWITZERLAND

Compliant

Gold

Asahi Pretec Corp.

JAPAN

Compliant

Gold

Asahi Refining Canada Ltd.

CANADA

Compliant

Gold

Asahi Refining USA Inc.

UNITED STATES OF AMERICA

Compliant

Gold

Asaka Riken Co., Ltd.

JAPAN

Compliant

Gold

Atasay Kuyumculuk Sanayi Ve Ticaret A.S.

TURKEY

Not certified

Gold

AU Traders and Refiners

SOUTH AFRICA

Compliant

Gold

AURA-II

UNITED STATES

Not certified

Gold

Aurubis AG

GERMANY

Compliant

Gold

Bangalore Refinery

INDIA

Compliant

Gold

Bangko Sentral ng Pilipinas (Central Bank of the Philippines)

PHILIPPINES

Compliant

Gold

Bauer Walser AG

GERMANY

Not certified

Gold

Boliden AB

SWEDEN

Compliant

Gold

C. Hafner GmbH + Co. KG

GERMANY

Compliant

Gold

Caridad

MEXICO

Not certified

Gold

CCR Refinery - Glencore Canada Corporation

CANADA

Compliant

Gold

Cendres + Metaux S.A.

SWITZERLAND

Compliant

Gold

CGR Metalloys Pvt Ltd.

INDIA

Not certified

Gold

Chimet S.p.A.

ITALY

Compliant

Gold

China National Gold Group Corporation

CHINA

Not certified

Gold

Chugai Mining

JAPAN

Compliant

Gold

Colt Refining

UNITED STATES

Not certified

Gold

Daejin Indus Co., Ltd.

KOREA, REPUBLIC OF

Not certified

Gold

Daye Non-Ferrous Metals Mining Ltd.

CHINA

Not certified

Gold

Degussa Sonne / Mond Goldhandel GmbH

GERMANY

Not certified

Gold

Dijllah Gold Refinery FZC

UNITED ARAB EMIRATES

Not certified

 

 

 

Gold

DODUCO Contacts and Refining GmbH

GERMANY

Compliant

Gold

Dowa

JAPAN

Compliant

Gold

DS PRETECH Co., Ltd.

KOREA, REPUBLIC OF

Compliant

Gold

DSC (Do Sung Corporation)

KOREA, REPUBLIC OF

Compliant

Gold

Eco-System Recycling Co., Ltd.

JAPAN

Compliant

Gold

Emirates Gold DMCC

UNITED ARAB EMIRATES

Compliant

Gold

Faggi Enrico S.p.A.

ITALY

Not certified

Gold

Fidelity Printers and Refiners Ltd.

ZIMBABWE

Not certified

Gold

Fujairah Gold FZC

UNITED ARAB EMIRATES

Not certified

Gold

GCC Gujrat Gold Centre Pvt. Ltd.

INDIA

Not certified

Gold

Geib Refining Corporation

UNITED STATES OF AMERICA

Compliant

Gold

Gold Refinery of Zijin Mining Group Co., Ltd.

CHINA

Compliant

Gold

Great Wall Precious Metals Co., Ltd. of CBPM

CHINA

Not certified

Gold

Guangdong Jinding Gold Limited

CHINA

Not certified

Gold

Guoda Safina High-Tech Environmental Refinery Co., Ltd.

CHINA

Not certified

Gold

Hangzhou Fuchunjiang Smelting Co., Ltd.

CHINA

Not certified

Gold

HeeSung Metal Ltd.

KOREA, REPUBLIC OF

Compliant

Gold

Heimerle + Meule GmbH

GERMANY

Compliant

Gold

Heraeus Metals Hong Kong Ltd.

CHINA

Compliant

Gold

Heraeus Precious Metals GmbH & Co. KG

GERMANY

Compliant

Gold

Hunan Chenzhou Mining Co., Ltd.

CHINA

Not certified

Gold

Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.

CHINA

Not certified

Gold

HwaSeong CJ CO., LTD.

KOREA, REPUBLIC OF

Not certified

Gold

Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.

CHINA

Compliant

Gold

International Precious Metal Refiners

UNITED ARAB EMIRATES

Not certified

Gold

Ishifuku Metal Industry Co., Ltd.

JAPAN

Compliant

Gold

Istanbul Gold Refinery

TURKEY

Compliant

Gold

Italpreziosi

ITALY

Compliant

Gold

Japan Mint

JAPAN

Compliant

Gold

Jiangxi Copper Co., Ltd.

CHINA

Compliant

Gold

JSC Ekaterinburg Non-Ferrous Metal Processing Plant

RUSSIAN FEDERATION

Not certified

Gold

JSC Uralelectromed

RUSSIAN FEDERATION

Compliant

Gold

JX Nippon Mining & Metals Co., Ltd.

JAPAN

Compliant

Gold

Kaloti Precious Metals

UNITED ARAB EMIRATES

Not certified

Gold

Kazakhmys Smelting LLC

KAZAKHSTAN

Not certified

Gold

Kazzinc

KAZAKHSTAN

Compliant

Gold

Kennecott Utah Copper LLC

UNITED STATES OF AMERICA

Compliant

 

 

 

Gold

KGHM Polska Miedz Spolka Akcyjna

POLAND

Compliant

Gold

Kojima Chemicals Co., Ltd.

JAPAN

Compliant

Gold

Korea Metal Co. Ltd

KOREA, REPUBLIC OF

Not certified

Gold

Korea Zinc Co., Ltd.

KOREA, REPUBLIC OF

Compliant

Gold

Kyrgyzaltyn JSC

KYRGYZSTAN

Compliant

Gold

Kyshtym Copper-Electrolytic Plant ZAO

RUSSIAN FEDERATION

Not certified

Gold

L'azurde Company For Jewelry

SAUDI ARABIA

Not certified

Gold

Lingbao Gold Co., Ltd.

CHINA

Not certified

Gold

Lingbao Jinyuan Tonghui Refinery Co., Ltd.

CHINA

Not certified

Gold

L'Orfebre S.A.

ANDORRA

Compliant

Gold

LS-NIKKO Copper Inc.

KOREA, REPUBLIC OF

Compliant

Gold

Luoyang Zijin Yinhui Gold Refinery Co., Ltd.

CHINA

Not certified

Gold

Marsam Metals

BRAZIL

Compliant

Gold

Materion

UNITED STATES OF AMERICA

Compliant

Gold

Matsuda Sangyo Co., Ltd.

JAPAN

Compliant

Gold

Metalor Technologies (Hong Kong) Ltd.

CHINA

Compliant

Gold

Metalor Technologies (Singapore) Pte., Ltd.

SINGAPORE

Compliant

Gold

Metalor Technologies (Suzhou) Ltd.

CHINA

Compliant

Gold

Metalor Technologies S.A.

SWITZERLAND

Compliant

Gold

Metalor USA Refining Corporation

UNITED STATES OF AMERICA

Compliant

Gold

Metalurgica Met-Mex Penoles S.A. De C.V.

MEXICO

Compliant

Gold

Mitsubishi Materials Corporation

JAPAN

Compliant

Gold

Mitsui Mining and Smelting Co., Ltd.

JAPAN

Compliant

Gold

MMTC-PAMP India Pvt., Ltd.

INDIA

Compliant

Gold

Modeltech Sdn Bhd

MALAYSIA

Not certified

Gold

Morris and Watson

NEW ZEALAND

Not certified

Gold

Morris and Watson Gold Coast

AUSTRALIA

Not certified

Gold

Moscow Special Alloys Processing Plant

RUSSIAN FEDERATION

Compliant

Gold

Nadir Metal Rafineri San. Ve Tic. A.S.

TURKEY

Compliant

Gold

Navoi Mining and Metallurgical Combinat

UZBEKISTAN

Not certified

Gold

NH Recytech Company

KOREA, REPUBLIC OF

Not certified

Gold

Nihon Material Co., Ltd.

JAPAN

Compliant

Gold

Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH

AUSTRIA

Compliant

Gold

Ohio Precious Metals, LLC

UNITED STATES

Not certified

Gold

Ohura Precious Metal Industry Co., Ltd.

JAPAN

Compliant

Gold

OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)

RUSSIAN FEDERATION

Compliant

Gold

OJSC Kolyma Refinery

RUSSIAN FEDERATION

Not certified

Gold

OJSC Novosibirsk Refinery

RUSSIAN FEDERATION

Compliant

Gold

PAMP S.A.

SWITZERLAND

Compliant

 

 

 

Gold

Pease & Curren

UNITED STATES OF AMERICA

Not certified

Gold

Penglai Penggang Gold Industry Co., Ltd.

CHINA

Not certified

Gold

Planta Recuperadora de Metales SpA

CHILE

Compliant

Gold

Prioksky Plant of Non-Ferrous Metals

RUSSIAN FEDERATION

Compliant

Gold

PT Aneka Tambang (Persero) Tbk

INDONESIA

Compliant

Gold

PX Precinox S.A.

SWITZERLAND

Compliant

Gold

QG Refining, LLC

UNITED STATES OF AMERICA

Not certified

Gold

Rand Refinery (Pty) Ltd.

SOUTH AFRICA

Compliant

Gold

Refinery of Seemine Gold Co., Ltd.

CHINA

Not certified

Gold

REMONDIS PMR B.V.

NETHERLANDS

Compliant

Gold

Republic Metals Corporation

UNITED STATES OF AMERICA

Compliant

Gold

Royal Canadian Mint

CANADA

Compliant

Gold

SAAMP

FRANCE

Compliant

Gold

Sabin Metal Corp.

UNITED STATES OF AMERICA

Not certified

Gold

Safimet S.p.A

ITALY

Compliant

Gold

SAFINA A.S.

CZECHIA

Active

Gold

Sai Refinery

INDIA

Not certified

Gold

Samduck Precious Metals

KOREA, REPUBLIC OF

Compliant

Gold

Samwon Metals Corp.

KOREA, REPUBLIC OF

Not certified

Gold

SAXONIA Edelmetalle GmbH

GERMANY

Compliant

Gold

Schone Edelmetaal

NETHERLANDS

Compliant

Gold

SEMPSA Joyeria Plateria S.A.

SPAIN

Compliant

Gold

Shandong Humon Smelting Co., Ltd.

CHINA

Not certified

Gold

Shandong Tiancheng Biological Gold Industrial Co., Ltd.

CHINA

Not certified

Gold

Shandong Zhaojin Gold & Silver Refinery Co., Ltd.

CHINA

Compliant

Gold

Sichuan Tianze Precious Metals Co., Ltd.

CHINA

Compliant

Gold

Singway Technology Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Compliant

Gold

So Accurate Group, Inc.

UNITED STATES

Not certified

Gold

SOE Shyolkovsky Factory of Secondary Precious Metals

RUSSIAN FEDERATION

Compliant

Gold

Solar Applied Materials Technology Corp.

TAIWAN, PROVINCE OF CHINA

Compliant

Gold

Sovereign Metals

INDIA

Not certified

Gold

State Research Institute Center for Physical Sciences and Technology

LITHUANIA

Not certified

Gold

Sudan Gold Refinery

SUDAN

Not certified

Gold

Sumitomo Metal Mining Co., Ltd.

JAPAN

Compliant

Gold

SungEel HiMetal Co., Ltd.

KOREA, REPUBLIC OF

Compliant

 

 

 

Gold

T.C.A S.p.A

ITALY

Compliant

Gold

Tanaka Kikinzoku Kogyo K.K.

JAPAN

Compliant

Gold

The Refinery of Shandong Gold Mining Co., Ltd.

CHINA

Compliant

Gold

Tokuriki Honten Co., Ltd.

JAPAN

Compliant

Gold

Tongling Nonferrous Metals Group Co., Ltd.

CHINA

Not certified

Gold

Tony Goetz NV

BELGIUM

Not certified

Gold

TOO Tau-Ken-Altyn

KAZAKHSTAN

Compliant

Gold

Torecom

KOREA, REPUBLIC OF

Compliant

Gold

Umicore Brasil Ltda.

BRAZIL

Compliant

Gold

Umicore Precious Metals Thailand

THAILAND

Compliant

Gold

Umicore S.A. Business Unit Precious Metals Refining

BELGIUM

Compliant

Gold

United Precious Metal Refining, Inc.

UNITED STATES OF AMERICA

Compliant

Gold

Universal Precious Metals Refining Zambia

ZAMBIA

Not certified

Gold

Valcambi S.A.

SWITZERLAND

Compliant

Gold

Western Australian Mint (T/a The Perth Mint)

AUSTRALIA

Compliant

Gold

WIELAND Edelmetalle GmbH

GERMANY

Compliant

Gold

Yamakin Co., Ltd.

JAPAN

Compliant

Gold

Yokohama Metal Co., Ltd.

JAPAN

Compliant

Gold

Yunnan Copper Industry Co., Ltd.

CHINA

Not certified

Gold

Zhongyuan Gold Smelter of Zhongjin Gold Corporation

CHINA

Compliant

Tantalum

Changsha South Tantalum Niobium Co., Ltd.

CHINA

Compliant

Tantalum

CP Metals Inc.

UNITED STATES OF AMERICA

Not certified

Tantalum

D Block Metals, LLC

UNITED STATES OF AMERICA

Compliant

Tantalum

Duoluoshan

CHINA

Compliant

Tantalum

E.S.R. Electronics

UNITED STATES

Not certified

Tantalum

Exotech Inc.

UNITED STATES OF AMERICA

Compliant

Tantalum

F&X Electro-Materials Ltd.

CHINA

Compliant

Tantalum

FIR Metals & Resource Ltd.

CHINA

Compliant

Tantalum

Global Advanced Metals Aizu

JAPAN

Compliant

Tantalum

Global Advanced Metals Boyertown

UNITED STATES OF AMERICA

Compliant

Tantalum

Guangdong Rising Rare Metals-EO Materials Ltd.

CHINA

Compliant

Tantalum

Guangdong Zhiyuan New Material Co., Ltd.

CHINA

Compliant

Tantalum

Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch

CHINA

Not certified

Tantalum

H.C. Starck Co., Ltd.

THAILAND

Compliant

Tantalum

H.C. Starck GmbH Laufenburg

GERMANY

Not certified

 

 

 

Tantalum

H.C. Starck Hermsdorf GmbH

GERMANY

Compliant

Tantalum

H.C. Starck Inc.

UNITED STATES OF AMERICA

Compliant

Tantalum

H.C. Starck Ltd.

JAPAN

Compliant

Tantalum

H.C. Starck Smelting GmbH & Co. KG

GERMANY

Compliant

Tantalum

H.C. Starck Tantalum and Niobium GmbH

GERMANY

Compliant

Tantalum

Hengyang King Xing Lifeng New Materials Co., Ltd.

CHINA

Compliant

Tantalum

Hi-Temp

UNITED STATES

Compliant

Tantalum

Jiangxi Dinghai Tantalum & Niobium Co., Ltd.

CHINA

Compliant

Tantalum

Jiangxi Tuohong New Raw Material

CHINA

Compliant

Tantalum

Jiujiang Janny New Material Co., Ltd.

CHINA

Not certified

Tantalum

JiuJiang JinXin Nonferrous Metals Co., Ltd.

CHINA

Compliant

Tantalum

Jiujiang Tanbre Co., Ltd.

CHINA

Compliant

Tantalum

Jiujiang Zhongao Tantalum & Niobium Co., Ltd.

CHINA

Compliant

Tantalum

KEMET Blue Metals

MEXICO

Compliant

Tantalum

KEMET Blue Powder

UNITED STATES OF AMERICA

Compliant

Tantalum

King-Tan Tantalum Industry Ltd

CHINA

Compliant

Tantalum

LSM Brasil S.A.

BRAZIL

Compliant

Tantalum

Metallurgical Products India Pvt., Ltd.

INDIA

Compliant

Tantalum

Mineracao Taboca S.A.

BRAZIL

Compliant

Tantalum

Ningxia Orient Tantalum Industry Co., Ltd.

CHINA

Compliant

Tantalum

NPM Silmet AS

ESTONIA

Compliant

Tantalum

Plansee SE Liezen

AUSTRIA

Not certified

Tantalum

Plansee SE Reutte

AUSTRIA

Not certified

Tantalum

Power Resources Ltd.

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

Compliant

Tantalum

QuantumClean

UNITED STATES OF AMERICA

Compliant

Tantalum

Resind Industria e Comercio Ltda.

BRAZIL

Compliant

Tantalum

RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.

CHINA

Compliant

Tantalum

Shanghai Jiangxi Metals Co. Ltd

CHINA

Not certified

Tantalum

Solikamsk Magnesium Works OAO

RUSSIAN FEDERATION

Compliant

Tantalum

Taki Chemical Co., Ltd.

JAPAN

Compliant

Tantalum

Telex Metals

UNITED STATES OF AMERICA

Compliant

Tantalum

Tranzact, Inc.

UNITED STATES OF AMERICA

Compliant

Tantalum

Ulba Metallurgical Plant JSC

KAZAKHSTAN

Compliant

Tantalum

XinXing HaoRong Electronic Material Co., Ltd.

CHINA

Compliant

Tantalum

Yichun Jin Yang Rare Metal Co., Ltd

CHINA

Compliant

 

 

 

Tantalum

Zhuzhou Cement Carbide

CHINA

Compliant

Tin

Alpha

UNITED STATES OF AMERICA

Compliant

Tin

An Thai Minerals Co., Ltd.

VIET NAM

Not certified

Tin

An Vinh Joint Stock Mineral Processing Company

VIET NAM

Not certified

Tin

Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.

CHINA

Compliant

Tin

Chifeng Dajingzi Tin Industry Co., Ltd.

CHINA

Not certified

Tin

China Rare Metal Materials Company

CHINA

Compliant

Tin

China Tin Group Co., Ltd.

CHINA

Compliant

Tin

CNMC (Guangxi) PGMA Co. Ltd.

CHINA

Not certified

Tin

Cooper Santa

BRAZIL

Compliant

Tin

CV Ayi Jaya

INDONESIA

Compliant

Tin

CV Dua Sekawan

INDONESIA

Compliant

Tin

CV Gita Pesona

INDONESIA

Compliant

Tin

CV JusTindo

INDONESIA

Not certified

Tin

CV Makmur Jaya

INDONESIA

Not certified

Tin

CV United Smelting

INDONESIA

Compliant

Tin

CV Venus Inti Perkasa

INDONESIA

Compliant

Tin

Dongguan CiEXPO Environmental Engineering Co., Ltd.

CHINA

Not certified

Tin

Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company

VIET NAM

Active

Tin

EM Vinto

BOLIVIA (PLURINATIONAL STATE OF)

Compliant

Tin

Estanho de Rondonia S.A.

BRAZIL

Not certified

Tin

Fenix Metals

POLAND

Compliant

Tin

Gejiu City Fuxiang Industry and Trade Co., Ltd.

CHINA

Not certified

Tin

Gejiu Fengming Metallurgy Chemical Plant

CHINA

Compliant

Tin

Gejiu Jinye Mineral Company

CHINA

Compliant

Tin

Gejiu Kai Meng Industry and Trade LLC

CHINA

Active

Tin

Gejiu Non-Ferrous Metal Processing Co., Ltd.

CHINA

Compliant

Tin

Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.

CHINA

Active

Tin

Gejiu Zili Mining And Metallurgy Co., Ltd.

CHINA

Not certified

Tin

Guangdong Hanhe Non-Ferrous Metal Co., Ltd.

CHINA

Compliant

Tin

Guanyang Guida Nonferrous Metal Smelting Plant

CHINA

Compliant

Tin

HuiChang Hill Tin Industry Co., Ltd.

CHINA

Compliant

Tin

Huichang Jinshunda Tin Co., Ltd.

CHINA

Active

Tin

Jiangxi Nanshan

CHINA

Not certified

Tin

Jiangxi New Nanshan Technology Ltd.

CHINA

Active

Tin

Linwu Xianggui Smelter Co

CHINA

Not certified

Tin

Ma'anshan Weitai Tin Co., Ltd.

CHINA

Not certified

 

 

 

Tin

Magnu's Minerais Metais e Ligas Ltda.

BRAZIL

Compliant

Tin

Malaysia Smelting Corporation (MSC)

MALAYSIA

Compliant

Tin

Melt Metais e Ligas S.A.

BRAZIL

Compliant

Tin

Metallic Resources, Inc.

UNITED STATES OF AMERICA

Compliant

Tin

Metallo Belgium N.V.

BELGIUM

Compliant

Tin

Metallo Chimique

BELGIUM

Not certified

Tin

Metallo Spain S.L.U.

SPAIN

Compliant

Tin

Minsur

PERU

Compliant

Tin

Nghe Tinh Non-Ferrous Metals Joint Stock Company

VIET NAM

Not certified

Tin

Novosibirsk Integrated Tin Works

RUSSIAN FEDERATION

Not certified

Tin

O.M. Manufacturing (Thailand) Co., Ltd.

THAILAND

Compliant

Tin

O.M. Manufacturing Philippines, Inc.

PHILIPPINES

Compliant

Tin

Operaciones Metalurgicas S.A.

BOLIVIA (PLURINATIONAL STATE OF)

Compliant

Tin

Pongpipat Company Limited

MYANMAR

Not certified

Tin

Precious Minerals and Smelting Limited

INDIA

Not certified

Tin

PT Alam Lestari Kencana

INDONESIA

Not certified

Tin

PT Aries Kencana Sejahtera

INDONESIA

Compliant

Tin

PT Artha Cipta Langgeng

INDONESIA

Compliant

Tin

PT ATD Makmur Mandiri Jaya

INDONESIA

Compliant

Tin

PT Babel Inti Perkasa

INDONESIA

Compliant

Tin

PT Babel Surya Alam Lestari

INDONESIA

Not certified

Tin

PT Bangka Prima Tin

INDONESIA

Compliant

Tin

PT Bangka Putra Karya

INDONESIA

Not certified

Tin

PT Bangka Serumpun

INDONESIA

Not certified

Tin

PT Bangka Tin Industry

INDONESIA

Compliant

Tin

PT Belitung Industri Sejahtera

INDONESIA

Compliant

Tin

PT BilliTin Makmur Lestari

INDONESIA

Not certified

Tin

PT Bukit Timah

INDONESIA

Compliant

Tin

PT Cipta Persada Mulia

INDONESIA

Not certified

Tin

PT Donna Kembara Jaya

INDONESIA

Not certified

Tin

PT DS Jaya Abadi

INDONESIA

Compliant

Tin

PT Eunindo Usaha Mandiri

INDONESIA

Compliant

Tin

PT Fang Di MulTindo

INDONESIA

Not certified

Tin

PT HP Metals Indonesia

INDONESIA

Not certified

Tin

PT Inti Stania Prima

INDONESIA

Compliant

Tin

PT Karimun Mining

INDONESIA

Compliant

Tin

PT Kijang Jaya Mandiri

INDONESIA

Compliant

Tin

PT Koba Tin

INDONESIA

Not certified

Tin

PT Lautan Harmonis Sejahtera

INDONESIA

Compliant

 

 

 

Tin

PT Menara Cipta Mulia

INDONESIA

Compliant

Tin

PT Mitra Stania Prima

INDONESIA

Compliant

Tin

PT O.M. Indonesia

INDONESIA

Compliant

Tin

PT Panca Mega Persada

INDONESIA

Compliant

Tin

PT Pelat Timah Nusantara Tbk

INDONESIA

Not certified

Tin

PT Premium Tin Indonesia

INDONESIA

Compliant

Tin

PT Prima Timah Utama

INDONESIA

Compliant

Tin

PT Rajawali Rimba Perkasa

INDONESIA

Not certified

Tin

PT Rajehan Ariq

INDONESIA

Compliant

Tin

PT Refined Bangka Tin

INDONESIA

Compliant

Tin

PT Sariwiguna Binasentosa

INDONESIA

Compliant

Tin

PT Seirama Tin investment

INDONESIA

Not certified

Tin

PT Stanindo Inti Perkasa

INDONESIA

Compliant

Tin

PT Sukses Inti Makmur

INDONESIA

Compliant

Tin

PT Sumber Jaya Indah

INDONESIA

Compliant

Tin

PT Supra Sukses Trinusa

INDONESIA

Not certified

Tin

PT Timah Tbk Kundur

INDONESIA

Compliant

Tin

PT Timah Tbk Mentok

INDONESIA

Compliant

Tin

PT Tinindo Inter Nusa

INDONESIA

Compliant

Tin

PT Tirus Putra Mandiri

INDONESIA

Not certified

Tin

PT Tommy Utama

INDONESIA

Compliant

Tin

PT Yinchendo Mining Industry

INDONESIA

Not certified

Tin

Rui Da Hung

TAIWAN, PROVINCE OF CHINA

Compliant

Tin

Soft Metais Ltda.

BRAZIL

Compliant

Tin

Super Ligas

BRAZIL

Not certified

Tin

Thai Nguyen Mining and Metallurgy Co., Ltd.

VIET NAM

Not certified

Tin

Thaisarco

THAILAND

Compliant

Tin

Tin Technology & Refining

UNITED STATES OF AMERICA

Not certified

Tin

Tuyen Quang Non-Ferrous Metals Joint Stock Company

VIET NAM

Not certified

Tin

VQB Mineral and Trading Group JSC

VIET NAM

Compliant

Tin

White Solder Metalurgia e Mineracao Ltda.

BRAZIL

Compliant

Tin

Yunnan Chengfeng Non-ferrous Metals Co., Ltd.

CHINA

Compliant

Tin

Yunnan Tin Company Limited

CHINA

Compliant

Tin

Yunnan Yunfan Non-ferrous Metals Co., Ltd.

CHINA

Not certified

Tungsten

A.L.M.T. Corp.

JAPAN

Compliant

Tungsten

ACL Metais Eireli

BRAZIL

Active

Tungsten

Chenzhou Diamond Tungsten Products Co., Ltd.

CHINA

Compliant

Tungsten

China Molybdenum Co., Ltd.

CHINA

Not certified

Tungsten

Chongyi Zhangyuan Tungsten Co., Ltd.

CHINA

Compliant

 

 

 

Tungsten

CNMC (Guangxi) PGMA Co., Ltd.

CHINA

Not certified

Tungsten

Dayu Jincheng Tungsten Industry Co., Ltd.

CHINA

Not certified

Tungsten

Dayu Weiliang Tungsten Co., Ltd.

CHINA

Not certified

Tungsten

Fujian Ganmin RareMetal Co., Ltd.

CHINA

Not certified

Tungsten

Fujian Jinxin Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

Ganxian Shirui New Material Co., Ltd.

CHINA

Not certified

Tungsten

Ganzhou Haichuang Tungsten Co., Ltd.

CHINA

Active

Tungsten

Ganzhou Huaxing Tungsten Products Co., Ltd.

CHINA

Compliant

Tungsten

Ganzhou Jiangwu Ferrotungsten Co., Ltd.

CHINA

Compliant

Tungsten

Ganzhou Non-ferrous Metals Smelting Co., Ltd.

CHINA

Not certified

Tungsten

Ganzhou Seadragon W & Mo Co., Ltd.

CHINA

Compliant

Tungsten

Ganzhou Yatai Tungsten Co., Ltd.

CHINA

Not certified

Tungsten

Global Tungsten & Powders Corp.

UNITED STATES OF AMERICA

Compliant

Tungsten

Guangdong Xianglu Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

H.C. Starck Tungsten GmbH

GERMANY

Compliant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji

CHINA

Compliant

Tungsten

Hunan Chuangda Vanadium Tungsten Co., Ltd. Yanglin

CHINA

Not certified

Tungsten

Hunan Chunchang Nonferrous Metals Co., Ltd.

CHINA

Compliant

Tungsten

Hunan Litian Tungsten Industry Co., Ltd.

CHINA

Active

Tungsten

Hydrometallurg, JSC

RUSSIAN FEDERATION

Compliant

Tungsten

Japan New Metals Co., Ltd.

JAPAN

Compliant

Tungsten

Jiangwu H.C. Starck Tungsten Products Co., Ltd.

CHINA

Compliant

Tungsten

Jiangxi Dayu Longxintai Tungsten Co., Ltd.

CHINA

Not certified

Tungsten

Jiangxi Gan Bei Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.

CHINA

Not certified

Tungsten

Jiangxi Richsea New Materials Co., Ltd.

CHINA

Not certified

Tungsten

Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.

CHINA

Compliant

Tungsten

Jiangxi Xinsheng Tungsten Industry Co., Ltd.

CHINA

Compliant

Tungsten

Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.

CHINA

Compliant

Tungsten

Jiangxi Yaosheng Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

JSC "Kirovgrad Hard Alloys Plant"

RUSSIAN FEDERATION

Not certified

Tungsten

Kennametal Fallon

UNITED STATES OF AMERICA

Compliant

Tungsten

Kennametal Huntsville

UNITED STATES OF AMERICA

Compliant

Tungsten

KGETS Co., Ltd.

KOREA, REPUBLIC OF

Not certified

Tungsten

Lianyou Metals Co., Ltd.

TAIWAN, PROVINCE OF CHINA

Not certified

 

 

 

Tungsten

Malipo Haiyu Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

Masan Tungsten Chemical LLC (MTC)

VIETNAM

Compliant

Tungsten

Moliren Ltd.

RUSSIAN FEDERATION

Compliant

Tungsten

Niagara Refining LLC

UNITED STATES OF AMERICA

Compliant

Tungsten

Philippine Chuangxin Industrial Co., Inc.

PHILIPPINES

Compliant

Tungsten

Pobedit, JSC

RUSSIAN FEDERATION

Not certified

Tungsten

Sanher Tungsten Vietnam Co., Ltd.

VIET NAM

Not certified

Tungsten

South-East Nonferrous Metal Company Limited of Hengyang City

CHINA

Compliant

Tungsten

Tejing (Vietnam) Tungsten Co., Ltd.

VIET NAM

Compliant

Tungsten

Unecha Refractory metals plant

RUSSIAN FEDERATION

Compliant

Tungsten

Vietnam Youngsun Tungsten Industry Co., Ltd

VIET NAM

Compliant

Tungsten

Wolfram Bergbau und Hutten AG

AUSTRIA

Compliant

Tungsten

Wolfram Company CJSC

RUSSIAN FEDERATION

Not certified

Tungsten

Woltech Korea Co., Ltd.

KOREA, REPUBLIC OF

Compliant

Tungsten

Xiamen Tungsten (H.C.) Co., Ltd.

CHINA

Compliant

Tungsten

Xiamen Tungsten Co., Ltd.

CHINA

Compliant

Tungsten

Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.

CHINA

Compliant

Tungsten

Xinhai Rendan Shaoguan Tungsten Co., Ltd.

CHINA

Compliant

 

 

Annex 2- Country of Origin (COO) Inquiry Results*

 

GOLD

TANTALUM

TIN

TUNGSTEN

ANDORRA

AUSTRIA

BELGIUM

AUSTRIA

AUSTRALIA

BRAZIL

BOLIVIA (PLURINATIONAL STATE OF)

BRAZIL

AUSTRIA

CHINA

BRAZIL

CHINA

BELGIUM

ESTONIA

CHINA

GERMANY

BRAZIL

GERMANY

INDIA

JAPAN

CANADA

INDIA

INDONESIA

KOREA, REPUBLIC OF

CHILE

JAPAN

MALAYSIA

PHILIPPINES

CHINA

KAZAKHSTAN

MYANMAR

RUSSIAN FEDERATION

CZECHIA

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

PERU

TAIWAN, PROVINCE OF CHINA

 

 

 

FRANCE

MEXICO

PHILIPPINES

UNITED STATES OF AMERICA

GERMANY

RUSSIAN FEDERATION

POLAND

VIET NAM

INDIA

THAILAND

RUSSIAN FEDERATION

 

INDONESIA

UNITED STATES OF AMERICA

SPAIN

 

ITALY

 

TAIWAN, PROVINCE OF CHINA

 

JAPAN

 

THAILAND

 

KAZAKHSTAN

 

UNITED STATES OF AMERICA

 

KOREA, REPUBLIC OF

 

VIET NAM

 

KYRGYZSTAN

 

 

 

LITHUANIA

 

 

 

MALAYSIA

 

 

 

MEXICO

 

 

 

NETHERLANDS

 

 

 

NEW ZEALAND

 

 

 

PHILIPPINES

 

 

 

POLAND

 

 

 

RUSSIAN FEDERATION

 

 

 

SAUDI ARABIA

 

 

 

SINGAPORE

 

 

 

SOUTH AFRICA

 

 

 

SPAIN

 

 

 

SUDAN

 

 

 

SWEDEN

 

 

 

SWITZERLAND

 

 

 

TAIWAN, PROVINCE OF CHINA

 

 

 

THAILAND

 

 

 

TURKEY

 

 

 

UGANDA

 

 

 

UNITED ARAB EMIRATES

 

 

 

UNITED STATES OF AMERICA

 

 

 

UZBEKISTAN

 

 

 

ZAMBIA

 

 

 

ZIMBABWE

 

 

 

 

* As some SORs did not provide complete information on the Location of Mine in their CMRTs, and the Company was not able to establish with complete certainty, based on the suppliers’ 3TG sourcing information, the exact location for the processing of the minerals. Therefore, we have listed in the COO the closest indication provided as to the source of Conflict Minerals, i.e. the Smelter Country as reported in our relevant suppliers' CMRT declarations, if provided.