DocumentExhibit 1.01
Conflict Minerals Report
For The Year Ended December 31, 2022
This Conflict Minerals Report for the reporting period from January 1, 2022 to December 31, 2022 is presented to comply with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended. Rule 13p-1 imposes certain reporting obligations on reporting companies whose manufactured or contracted to be manufactured products contain conflict minerals which are necessary to the functionality or production of their products. “Conflict minerals” are defined as gold, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG”) for the purposes of this assessment. Please refer to Rule 13p-1, Form SD and the 1934 Act Release No. 34-67716 for definitions to the terms used in this Report, unless otherwise defined herein.
1. Company Overview
Compass Group Diversified Holdings LLC and Compass Diversified Holdings (collectively, “CODI” or the “Company”) were formed to acquire and manage a group of small to middle market businesses and the Company was a controlling owner of eleven businesses, or operating subsidiaries, at December 31, 2022. The subsidiaries are as follows: 5.11 ABR Corp. ("5.11"), Boa Holdings Inc. ("BOA"), EBP Lifestyle Brands Holdings, Inc.. (“Ergobaby”), Lugano Holdings, Inc. ("Lugano Diamonds" or "Lugano"), Wheelhouse Holdings, Inc. ("Marucci Sports" or "Marucci"), Relentless Topco, Inc., Inc. ("PrimaLoft"), CBCP Products, LLC ("Velocity Outdoor" or "Velocity"), Compass AC Holdings, Inc. (“ACI” or “Advanced Circuits”), AMTAC Holdings, LLC (“Arnold”), FFI Compass, Inc. ("Altor Solutions" or "Altor") and SternoCandleLamp Holdings, Inc. (“Sterno”). During the first quarter of 2023, The Company completed the sale of Advanced Circuits.
The Company’s subsidiaries are engaged in the following lines of business:
•5.11 is a leading provider of purpose-built technical apparel and gear for law enforcement, firefighters, EMS, and military special operations as well as outdoor and adventure enthusiasts. 5.11 is a brand known for innovation and authenticity, and works directly with end users to create purpose-built apparel and gear designed to enhance the safety, accuracy, speed and performance of tactical professionals and enthusiasts worldwide. Headquartered in Costa Mesa, California, 5.11 operates sales offices and distribution centers globally, and 5.11 products are widely distributed in uniform stores, military exchanges, outdoor retail stores, its own retail stores and on 511tactical.com.
•BOA, creator of the revolutionary, award-winning, patented BOA Fit System, partners with market-leading brands to make the best gear even better. Delivering fit solutions purpose-built for performance, the BOA Fit System is featured in footwear across snow sports, cycling, outdoor, athletic, workwear as well as performance headwear and medical bracing. The system consists of three integral parts: a micro-adjustable dial, high-tensile lightweight laces, and low friction lace guides creating a superior alternative to laces, buckles, Velcro, and other traditional closure mechanisms. Each unique BOA configuration is designed with brand partners to deliver superior fit and performance for athletes, is engineered to perform in the toughest conditions and is backed by The BOA Lifetime Guarantee. BOA is headquartered in Denver, Colorado and has offices in Austria, Greater China, South Korea, and Japan.
•Ergobaby, headquartered in Torrance, California, is a designer, marketer and distributor of wearable baby carriers and accessories, blankets and swaddlers, nursing pillows, strollers, bouncers and related products. Ergobaby primarily sells its Ergobaby and Baby Tula branded products through brick-and-mortar retailers, national chain stores, online retailers, its own websites and distributors and derives more than 50% of its sales from outside of the United States.
•Lugano Diamonds is a leading designer, manufacturer and marketer of high-end, one-of-a-kind jewelry sought after by some of the world’s most discerning clientele. Lugano conducts sales via its own retail salons as well as pop-up showrooms at Lugano-hosted or sponsored events in partnership with influential organizations in the equestrian, art and philanthropic community. Lugano is headquartered in Newport Beach, California.
•Marucci Sports is a leading designer, manufacturer, and marketer of premium wood and metal baseball bats, fielding gloves, batting gloves, bags, protective gear, sunglasses, on and off-field apparel, and other baseball and softball equipment used by professional and amateur athletes. Marucci also develops
corporate-owned and franchised sports training facilities. Marucci is headquartered in Baton Rouge, Louisiana.
•PrimaLoft is a leading provider of branded, high-performance synthetic insulation and materials used primarily in consumer outerwear, and accessories. The portfolio of PrimaLoft synthetic insulations offers products that can both mimic natural down aesthetics and provide the freedom to design garments ranging from stylish puffers to lightweight performance apparel. PrimaLoft insulations also offer superior economics to the brand partner and enable better sustainability characteristics through the use of recycled, low-carbon inputs. PrimaLoft is headquartered in Latham, New York.
•Velocity Outdoor is a leading designer, manufacturer, and marketer of airguns, archery products, laser aiming devices, hunting apparel and related accessories. Velocity Outdoor offers its products under the highly recognizable Crosman, Benjamin, LaserMax, Ravin, CenterPoint and King's Camo brands that are available through national retail chains, mass merchants, dealer and distributor networks. The airgun product category consists of air rifles, air pistols and a range of accessories including targets, holsters and cases. Velocity Outdoor's other primary product categories are archery, with products including CenterPoint and Ravin crossbows, consumables, which includes steel and plastic BBs, lead pellets and CO2 cartridges, lasers for firearms, and airsoft products. The apparel category offers high-performance, feature rich hunting and casual apparel of uncompromised quality utilizing King’s own proprietary camo patterns. Velocity Outdoor is headquartered in Bloomfield, New York.
•Advanced Circuits is a provider of small-run, quick-turn and volume production (including assembly) PCBs to customers throughout the United States. ACI manufactures and delivers custom printed circuit boards to customers primarily in North America. ACI is headquartered in Aurora, Colorado.
•Altor Solutions is a designer and manufacturer of custom molded protective foam solutions and original equipment manufacturer components made from expanded polystyrene and expanded polypropylene. Altor provides products to a variety of end markets, including appliances and electronics, pharmaceuticals, health and wellness, automotive, building and other products. Altor is headquartered in Scottsdale, Arizona and operates 18 molding and fabricating facilities across North America.
•Arnold is a global solutions provider and manufacturer of engineered solutions for a wide range of specialty applications and end-markets, including aerospace and defense, general industrial, motorsport/transportation, oil and gas, medical, energy, reprographics and advertising specialties. Arnold engineers solutions for and produces high performance permanent magnets (PMAG), stators, rotors and full electric motors ("Ramco"), precision foil products (Precision Thin Metals or "PTM"), and flexible magnets (Flexmag™) that are mission critical in motors, generators, sensors and other systems and components. Based on its long-term relationships, Arnold has built a diverse and blue-chip customer base totaling more than 2,000 customers and leading systems-integrators worldwide with a focus on North America, Europe, and Asia. Arnold has built a preferred rare earth supply chain and has leading rare earth and other permanent magnet production capabilities. Arnold is headquartered in Rochester, New York.
•Sterno is a leading manufacturer and marketer of portable food warming systems, creative indoor and outdoor lighting, and home fragrance solutions for the consumer markets. Sterno offers a broad range of wick and gel chafing systems, butane stoves and accessories, liquid and traditional wax candles, catering equipment and lamps through Sterno Products, scented wax cubes, warmer products, outdoor lighting and essential oils used for home decor and fragrance systems through Rimports. Sterno is headquartered in Corona, California.
2. Description of the Company's Products Covered by this Report
This Report relates to products: (i) for which 3TG are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2022. The Company determined that component products at seven (7) of its subsidiaries contain or may contain 3TG which are necessary to the functionality or production of their products. The seven subsidiaries and the applicable 3TG are Advanced Circuits (gold and tin), Arnold (gold, tantalum, tin and tungsten), Ergobaby (tin), Lugano (gold), Sterno (tin and gold), 5.11 (tin and gold), and Velocity Outdoor (tin).
The Company acquired PrimaLoft during the year ended December 31, 2022. As permitted by the instructions to the Form SD, the Company has not included PrimaLoft in our reporting for Form SD and the Conflict Mineral report for
the year ended December 31, 2022.
3. Reasonable Country of Origin Inquiry
The Company conducted an analysis of its subsidiaries’ products and found that small quantities of necessary 3TG are contained in some of its subsidiaries’ products. Therefore, for the reporting period from January 1, 2022 to December 31, 2022, the Company conducted a good faith reasonable country of origin inquiry (“RCOI”) which was designed to determine whether any of the necessary 3TG contained in its subsidiaries’ products originated in the Democratic Republic of the Congo or an adjoining country (collectively, the "Covered Countries") or came from recycled or scrap sources. “Necessary 3TG” are 3TG that are necessary to the functionality or production of products that the Company’s subsidiaries manufacture or that the Company’s subsidiaries contract with others to manufacture for us.
The Company used the Conflict Minerals Reporting Template (“CMRT”) developed by the Conflict-Free Sourcing Initiative to request information from its subsidiaries’ suppliers about their supply chain and to gather information about the country of origin of its necessary 3TG. The Company identified approximately 93 direct suppliers that potentially supplied the Company necessary 3TG and requested each of them to complete a CMRT. The Company received responses (by either a letter or completed CMRT) from approximately 94% of these suppliers and reviewed the responses for completeness and accuracy. When the Company determined that its suppliers’ CMRT responses contained information the Company believed to be incomplete or inaccurate, the Company followed up with those suppliers to seek additional information or clarification about those responses.
Based on the Company’s supplier responses, the Company does not have sufficient information to determine whether the products it manufactured or contracted for manufacture during the reporting period contain necessary 3TG that originated, or may have originated, in the Covered Countries and are not or may not be from recycled or scrap sources. Accordingly, and out of an abundance of caution, the Company performed due diligence in an effort to determine the source and chain of custody of these necessary 3TG.
4. Due Diligence
Due Diligence Design
With respect to the period covered, the design of the due diligence process conforms in all material respects with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas, Third Edition, 2016, as further set out in the specific guidance for downstream companies contained in the Supplement on Tin, Tantalum, and Tungsten and the Supplement for Gold (hereinafter, collectively, the “OECD Guidance”).
Due Diligence Measures Performed
The Company undertook due diligence at each of its subsidiaries that have component products that contain or may contain necessary 3TG to determine the source and chain of custody of the necessary 3TG contained in the products manufactured by or contracted for manufacture by the Company’s subsidiaries. Summarized below are the components of the 3TG due diligence program the Company undertook as they relate to the five-step framework set forth in the OECD Guidance:
1. OECD Step #1: Establish and maintain strong company management systems
Our operations are reported in multiple business segments, therefore, we established a single point of contact to assist in implementing a 3TG program. Each segment that manufactures or distributes products that contain necessary 3TG had its own designated specific personnel to coordinate the 3TG diligence, oversee the implementation and execution of a program and coordinate directly with its affected suppliers, if applicable. The affected segments used the CMRT developed by the Conflict-Free Sourcing Initiative as a mechanism to request that suppliers provide information about the source and chain of custody of the necessary 3TG contained in products supplied to each of the affected segments. For suppliers that did not respond to the Company's source and chain of custody inquiry (or provided limited response) for calendar year 2022, the Company submitted that supplier name to the executive management of the applicable subsidiary for review. The Company maintains a conflict minerals policy regarding the sourcing of conflict minerals, which is publicly available on the Company’s website at: http://ir.compassequity.com/corporate-governance.cfm. The content of any website referred to in this Report is not incorporated by reference in this Report.
2. OECD Step #2: Identifying and assessing risk in the supply chain
To identify risks related to necessary 3TG in its products, the Company took the following actions:
•worked with suppliers to obtain more complete information;
•followed up with suppliers that did not respond or provided inconsistent or incomplete responses;
•sought information regarding the smelters or refiners or smelters that processed the conflict minerals in the suppliers’ products; and
•analyzed the supplier’s responses against the Company's conflict minerals policy and against the list of smelters and refiners on the CFSI website to determine whether the smelters received a "compliant" or "active" designations from the Conflict Free Smelter Program ("CFSP").
3. OECD Step #3: Design and implement a strategy to respond to identified risks
Results of the Company’s supplier responses were reported to the senior management of the Company, specifically our Chief Financial Officer. The Company continued a risk management plan of attempting to disengage with a supplier where the Company deems risk mitigation unfeasible or unacceptable, and where, in the Company’s opinion, such disengagement would not likely harm the supply chain for a particular product.
4. OECD Step #4: Carry out an independent third party audit of smelter's/ refiner’s due diligence practices
As an owner of downstream companies, the Company relies on audits by independent third parties, including audits of smelters and refiners reported by the CFSP. The Company also relies on the certification processes of the London Bullion Market Association, The Responsible Jewellery Council, and the Tungsten Industry - Conflict Minerals Council.
5. OECD Step #5: Report annually on supply chain due diligence
The Company reports on our conflict minerals due diligence annually by making our Form SD and this Report publicly available on our Company website at: http://ir.compassequity.com/sec.cfm and filing the Form SD (with this Report) with the Securities and Exchange Commission ("SEC").
5. Results of Review
As an owner of downstream companies, the Company can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG contained in its subsidiaries’ products. The Company relies on the information collected and provided by its subsidiaries’ direct suppliers and publicly available information regarding independent third party audit programs.
Facilities Used to Process the Necessary 3TG
The Company requested smelter information from the suppliers of each of its subsidiaries that were determined to have component products that contain or may contain 3TG which are necessary to the functionality or production of their products. Based on the responses from our direct suppliers, two (2) suppliers identified only one (1) tin smelter, resulting in a total of two (2) tin smelters being identified. Based on the responses from the two (2) suppliers with only one (1) smelter disclosed for tin, we determined that the following smelter processed the tin that is contained in certain of our products.
| | | | | | | | | | | |
| Metal | Official Smelter Name | CESI Smelter ID | Smelter Country |
| | | |
| Tin | China BaoWu Steel Group Corporation Ltd. | Unknown | CHINA |
| Tin | Yunnan Tin Company, Ltd. | CID002180 | CHINA |
In the other responses received from our direct suppliers, each supplier named more than one (1) smelter or refiner in their response for each metal. This lack of detail from the rest of our suppliers prevented the Company from being able to determine whether a particular smelter or refiner named in their responses processed the necessary 3TG in the Company's products. Accordingly, the Company is unable to disclose any other facilities used to produce the necessary 3TG in its products. However, Table 1 attached to this Report lists the smelters and refiners provided to the Company by its other direct suppliers that may have processed necessary 3TG in its subsidiaries’ product lines.
Country of Origin
Based on the responses provided by the Company’s suppliers described directly above, the responses did not provide sufficiently detailed information for us to identify the country of origin of the necessary 3TG in the Company’s products. Accordingly, the Company is unable to disclose the country of origin of the necessary 3TG in its products.
Efforts to determine mine or location
The Company has determined that the most reasonable effort it can make to determine the mines or locations of origin of its necessary 3TG to the greatest possible specificity is to seek information from its direct suppliers about the smelters and refiners and the countries of origin of the necessary 3TG in its products and urge that its suppliers do the same with their direct suppliers. The Company must rely on its direct and indirect suppliers to provide the information about the mine or location of origin of the necessary 3TG in its products. As a result of the lack of information obtained from the Company’s subsidiaries’ suppliers, the Company was unable to determine the mine or location of the necessary conflict minerals in its subsidiaries’ product lines.
6. Risk Mitigation / Steps to Improve Due Diligence Measures
The Company currently intends to take steps to improve its due diligence and mitigate the risk that the Company’s necessary 3TG benefit or finance armed groups, including:
•Evaluating current direct suppliers based on their responsiveness to the 2022 calendar year's data collection effort. We expect to submit the names of those suppliers who provide products with risk of possible 3TG content that required responses and whose responses were limited or non-existent for calendar year 2022 to the executive management of the applicable subsidiary for review.
•Reaching out to suppliers earlier in the process and asking them to complete the CMRT.
•Improving, to the extent possible, the percentage of supplier provided responses to the request to complete the CMRT.
7. Independent Private Sector Audit
Based on the existing guidance from the SEC, this report has not been audited, nor is an Independent Private Sector Audit required for this Report.
8. Forward-Looking Statements
This Report may contain certain forward-looking statements, including those made under the “Risk Mitigation / Steps to Improve Due Diligence Measures” section. Words such as “believes,” “expects,” “projects,” and “future” or similar expressions, are intended to identify forward-looking statements. These forward-looking statements are subject to the inherent uncertainties in predicting future results and conditions. These statements are subject to a variety of uncertainties, unknown risks and other factors concerning the Company’s operations and business environment, which are difficult to predict and are beyond the control of the Company. Factors that could adversely affect our future performance include (1) those described under the heading “Risk Factors” in Item 1A of Part I of our Annual Report on Form 10-K for the year ended December 31, 2022, (2) the responsible sourcing of 3TG in our supply chain by our direct and indirect suppliers and (3) the effectiveness of traceability systems used by our direct and indirect suppliers to determine the source and chain of custody of 3TG contained in our supply chain. Except as required by law, CODI undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise.
Table 1 - List of smelters and refiners that may have processed necessary 3TG of the Company’s subsidiaries
| | | | | | | | | | | | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| | | | |
| Gold | | Agosi AG | | GERMANY |
| Gold | | Aida Chemical Industries Co. Ltd. | | JAPAN |
| Gold | | AngloGold Ashanti Córrego do Sítio Mineração | | BRAZIL |
| Gold | | Argor-Heraeus SA | | SWITZERLAND |
| Gold | | Asahi Pretec Corp. | | JAPAN |
| Gold | | Asahi Refining Canada Limited | | CANADA |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN |
| Gold | | Aurubis AG | | GERMANY |
| Gold | | Boliden AB | | SWEDEN |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA |
| Gold | | Chimet S.p.A. | | ITALY |
| Gold | | Coimpa Industrial | | BRAZIL |
| Gold | | Chugai Mining | | JAPAN |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY |
| Gold | | Dowa | | JAPAN |
| Gold | | Eco-System Recycling Co., Ltd. East Plant | | JAPAN |
| Gold | | Geib Refining Corporation | | UNITED STATES |
| Gold | | Heimerle + Meule GmbH | | GERMANY |
| Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA |
| Gold | | Heraeus Germany GmbH Co. KG | | GERMANY |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN |
| Gold | | Istanbul Gold Refinery | | TURKEY |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN |
| Gold | | LAIZHOU SHANDONG | | CHINA |
| Gold | | LS-NIKKO Copper Inc. | | KOREA, REPUBLIC OF |
| Gold | | Materion | | UNITED STATES |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA |
| Gold | | Metalor Technologies SA | | SWITZERLAND |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES |
| Gold | | Mitsubishi Materials Corporation | | JAPAN |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Gold | | Nihon Material Co., Ltd. | | JAPAN |
| | | | | | | | | | | | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN |
| Gold | | PAMP S.A. | | SWITZERLAND |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA |
| Gold | | Royal Canadian Mint | | CANADA |
| Gold | | SAFINA A.S | | CZECHIA |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA |
| Gold | | Shandong Gold Smelting Co., Ltd | | CHINA |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN |
| Gold | | Tokuriki Honten Co., Ltd. | | JAPAN |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM |
| Gold | | United Precious Metal Refining, Inc. | | UNITED STATES |
| Gold | | Valcambi SA | | SWITZERLAND |
| Gold | | Western Australian Mint trading as The Perth Mint | | AUSTRALIA |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY |
| Gold | | YMAD | | ARGENTINA |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| Tantalum | | D Block Metals, LLC | | UNITED STATES |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES |
| Tantalum | | H.C. Starck Ltd. | | JAPAN |
| Tantalum | | H.C. Starck Smelting GmbH & Co.KG | | GERMANY |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | KEMET de Mexico | | MEXICO |
| Tantalum | | LSM Brasil S.A. | | BRAZIL |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | INDIA |
| Tantalum | | Mineração Taboca S.A. | | BRAZIL |
| Tantalum | | Mitsui Mining & Smelting | | JAPAN |
| Tantalum | | NPM Silmet AS | | ESTONIA |
| | | | | | | | | | | | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tantalum | | Telex Metals | | UNITED STATES |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA |
| Tin | | Alpha | | UNITED STATES |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA |
| Tin | | China BaoWu Steel Group Corporation Ltd. | | CHINA |
| Tin | | China Tin Group Co., Ltd. | | CHINA |
| Tin | | China Yunnan Tin Co Ltd. | | CHINA |
| Tin | | CRM Synergies | | SPAIN |
| Tin | | CV Venus Inti Perkasa | | INDONESIA |
| Tin | | Dowa | | JAPAN |
| Tin | | Dragon Silver Holdings Limited | | CHINA |
| Tin | | EM Vinto | | BOLIVIA |
| Tin | | Fabrica Auricchio Industria e Comercio Ltda. | | BRAZIL |
| Tin | | Fenix Metals | | POLAND |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd | | CHINA |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd | | CHINA |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA |
| Tin | | GuangXi China Tin | | CHINA |
| Tin | | Jiangxi New Nanshan Technology, Ltd. | | CHINA |
| Tin | | Luna Smelter, Ltd | | RWANDA |
| Tin | | Ma'anshan Weitai Tin Co., Ltd. | | CHINA |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA |
| Tin | | Metallic Resources, Inc. | | UNITED STATES |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Metallo Spain S.L.U. | | SPAIN |
| Tin | | Mineração Taboca S.A. | | BRAZIL |
| Tin | | Minsur | | PERU |
| Tin | | Mitsubishi Materials Corporation | | JAPAN |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| Tin | | O.M Manufacturing Philippines, Inc. | | PHILIPPINES |
| Tin | | Operaciones Metalurgical S.A. | | BOLIVIA |
| Tin | | PT Aries Kencana Sejahtera | | INDONESIA |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA |
| Tin | | PT Babel Surya Alam Lestari | | INDONESIA |
| Tin | | PT Babel Inti Perkasa | | INDONESIA |
| Tin | | PT Bangka Serumpun | | INDONESIA |
| Tin | | PT Bukit Timah | | INDONESIA |
| | | | | | | | | | | | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tin | | PT Cipta Persada Mulia | | INDONESIA |
| Tin | | PT Menara Cipta Mulia | | INDONESIA |
| Tin | | PT Mitra Stania Prima | | INDONESIA |
| Tin | | PT Prima Timah Utama | | INDONESIA |
| Tin | | PT Rajehan Ariq | | INDONESIA |
| Tin | | PT Rajawali Rimba Perkasa | | INDONESIA |
| Tin | | PT Refined Bangka Tin | | INDONESIA |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| Tin | | PT Timah (Persero) Tbk Kundur | | INDONESIA |
| Tin | | PT Timah (Persero) Tbk Mentok | | INDONESIA |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA |
| Tin | | Rui Da Hung | | TAIWAN |
| Tin | | Tin Smelting Branch of Yunnan Tin Co., Ltd. | | CHINA |
| Tin | | Tin Technology & Refining | | UNITED STATES |
| Tin | | Thai Nguyen Mining and Metallurgy Co., Ltd. | | VIETNAM |
| Tin | | Thaisarco | | THAILAND |
| Tin | | White Solder Metalurgia e Mineração Ltda. | | BRAZIL |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA |
| Tin | | Yunnan Tin Company Limited | | CHINA |
| Tin | | YunNan Gejiu Yunxin Electrolyze Limited | | CHINA |
| Tin | | Zhejiang QLG Holding Co., ltd | | CHINA |
| Tungsten | | A.L.M.T. Corp. | | JAPAN |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | China Molybdenum Co., Ltd. | | CHINA |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Fujian Ganmin RareMetal Co., Ltd. | | CHINA |
| Tungsten | | Fujian Xinlu Tungsten | | CHINA |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | HC Starck Tungsten GmBH | | GERMANY |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Kennametal Fallon | | UNITED STATES |
| Tungsten | | Kennametal Huntsville | | UNITED STATES |
| | | | | | | | | | | | | | |
| Metal | | Smelter Reference List | | Smelter Facility Location: Country |
| Tungsten | | Lianyou Metals Co., Ltd. | | TAIWAN, PROVINCE OF CHINA |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIETNAM |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILLIPINES |
| Tungsten | | TANIOBIS Smelting GmbH & Co. KG | | GERMANY |
| Tungsten | | Wolfram Bergbau und Hütten AG | | AUSTRIA |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |