EX-1.01 2 exhibit101.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01

John Bean Technologies Corporation

Conflict Minerals Report

For The Calendar Year Ended December 31, 2016

This report for the calendar year ended December 31, 2016 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). Unless otherwise specified or indicated by the context, JBT Corporation, JBT, we, us, our and the Company refer to John Bean Technologies Corporation and its subsidiaries. In accordance with the Rule, the information presented in this report does not include products manufactured by businesses acquired after May 1, 2015.

JBT has reason to believe that some of the 3TGs1 present in its supply chain may have originated in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”). We are unable to determine the origin of the 3TGs in our products and therefore cannot exclude the possibility that some may have originated in the Covered Countries. For that reason, we are required under the Rule to submit to the Securities and Exchange Commission a Conflict Minerals Report (“CMR”) as an Exhibit to Form SD. In accordance with the instructions to Form SD, this CMR has not been audited by an independent private sector auditor.


Forward-Looking Statement

This report and other materials filed by JBT, as well as information in oral statements or other written statements made or to be made by us, contain statements that are, or may be considered to be, forward-looking statements. All statements that are not historical facts, including statements about our beliefs or expectations, are forward-looking statements. You can identify these forward-looking statements by the use of “seeks”, “approximately”, “predicts”, “intends”, “outlook”, “believes”, “expects”, “potential”, “continues”, “may”, “will”, “should”, “plans”, “estimates”, “anticipates”, “foresees” or the negative version of those words or other comparable words or phrases. Any forward-looking statements contained in this report are based upon our historical performance and on current plans, estimates and expectations. The inclusion of this forward-looking information should not be regarded as a representation by us or any other person that the future plans, estimates or expectations contemplated by us will be achieved.

We believe that the factors that could cause our actual results to differ materially from expectations include but are not limited to the factors we described in our Form 10-K under “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” If one or more of those or other risks or uncertainties materialize, or if our underlying assumptions prove to be incorrect, actual results may vary materially from what we projected. Consequently, actual events and results may vary significantly from those included in or contemplated or implied by our forward-looking statements. The forward-looking statements included in this report are made only as of the date hereof, and we undertake no obligation to publicly update or revise any forward-looking statement made by us or on our behalf, whether as a result of new information, future developments, subsequent events or changes in circumstances or otherwise.


1. Company Overview

We are a leading global technology solutions provider to high-value segments of the food and beverage industry with focus on proteins, liquid foods and automated system solutions. JBT designs, produces and services sophisticated products and systems for multi-national and regional customers through its FoodTech segment. JBT also sells critical equipment and services to domestic and international air transportation customers through its AeroTech segment.


________________________________
1The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country. Gold, columbite-tantalite (coltan), cassiterite and wolframite, and their derivatives, tin, tungsten and tantalum are hereinafter referred to collectively as “3TGs.”






The product offerings of our FoodTech businesses include:

Protein. JBT FoodTech provides comprehensive solutions to our Protein customers that include chilling, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, frying, freezing and weighing for poultry, beef, pork and seafood, as well as ready-to-eat meals, fruits, vegetables, dairy, and bakery products.

Liquid Foods. Our Liquid Foods portfolio includes fruit and juice solutions that extract, concentrate and aseptically process citrus, tomato and other fruits, vegetables, and juices. It also includes in-container solutions for the filling, closing and preservation of fruits, vegetables, soups, sauces, dairy, and pet food products as well as ready-to-eat meals in a wide variety of modern packages. Strategic acquisitions completed in 2015 added to our product portfolio significant capabilities in the dairy and juice preservation and filling segments, as well as in customized skidded systems, mixing, batching and blending systems and tank and vessel manufacturing capabilities for a broad array of market segments.

Automated Systems. JBT FoodTech provides stand-alone and fully-integrated robotic automated guided vehicle systems for repetitive material movement requirements, for example in manufacturing and warehouse facilities.

JBT AeroTech markets its solutions and services to domestic and international airport authorities, passenger airlines, airfreight and ground handling companies, military forces and defense contractors. The product offerings of our AeroTech businesses include:

Mobile Equipment. JBT AeroTech’s portfolio of mobile air transportation equipment includes commercial and military cargo loading, aircraft deicing, aircraft towing, and aircraft ground power and cooling systems.

Fixed Equipment. JBT AeroTech provides gate equipment for passenger boarding.

Airport Services. JBT AeroTech includes the maintenance of airport equipment, systems, and facilities.

Our products may contain conflict minerals within the following components:

Tantalum, used in capacitors

Tin, used in soldered components

Tungsten, used in coatings, alloys, heating elements and electrodes

Gold, used in circuit boards, electrodes and electronic components


Our policy regarding Conflicts Minerals is posted on our website under “Investor Relations” “Corporate Governance” and may be accessed via the following link: http://ir.jbtcorporation.com/governance.cfm.


2. Description of Reasonable County of Origin Inquiry and Conclusion

We engaged Assent Compliance Inc. (“Assent”) to assist in developing our approach to conduct in good faith a reasonable country of origin inquiry (“RCOI”). Assent is a recognized software and consulting provider supporting companies’ regulatory compliance.

JBT’s RCOI employed a combination of measures to determine whether the necessary 3TGs in JBT products originated from the Covered Countries. JBT’s primary means of determining country of origin of necessary 3TGs was by conducting a supply chain survey through Assent with direct JBT suppliers using the EICC-GeSI Conflict Minerals Reporting Template (“CMRT”).

JBT began its scoping process by compiling a list of direct suppliers of materials for JBT’s businesses that were likely to source materials that might contain 3TGs. This list was then filtered to remove suppliers of direct materials for all business units sourced prior to January 1, 2017.






The first two questions in the CMRT used for JBT’s supply chain survey allowed for further scoping as they ask suppliers whether any of the 3TGs are intentionally added and if they are necessary to the functionality or production of their products. Assent conducted additional analysis of the supply chain and, in combination with supplier feedback, discovered that 90.17% of the suppliers surveyed remained in scope.

JBT surveyed its suppliers via the Assent Compliance Manager, a software platform licensed by JBT to log and track supplier communications. This platform also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. In their responses, suppliers specified whether information was being provided at the company level or the product level. Non-responsive suppliers were contacted a minimum of three times by the Assent Compliance Manager and then were also managed by the Assent Compliance supply chain team in one-on-one communications. This included two follow ups from the supply chain team. For the 2016 reporting period, JBT received responses from 64.5%, of its in-scope suppliers. Of the 616 suppliers that provided a response, approximately 24% reported that their products contained 3TGs necessary to the functionality or production of their products.

Assent communications included training and education on the completion of the CMRT to assist suppliers in accurately completing the survey questions in the CMRT.

All of these communications were monitored and tracked in Assent's system for future reporting and transparency.

JBT’s survey process with Assent includes automated data validation on all submitted CMRTs. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. This data validation is based on the construction and relationship of the questions submitted to the suppliers in the CMRT. Suppliers must provide the minimum responses to the CMRT in order to determine the scope of applicability of the remaining CMRT questions - this aligns with the design of the CMRT itself. The remainder of the questions are then automatically assessed for consistency. All submitted forms are accepted and classified as valid or invalid, preserving all of the data submitted through Assent Compliance for record keeping purposes. Suppliers are contacted in regards to invalid forms and are strongly encouraged to resubmit a valid form. As of April 17, 2017, there were 557 valid supplier submissions.

As a result of its assessment, JBT has concluded in good faith that during calendar year 2016:

a)
JBT has manufactured or contracted to manufacture products as to which 3TGs are necessary to the functionality or production of such products.

b)
Based on its RCOI, JBT knows or has reason to believe that a portion of its necessary 3TGs originated or may have originated in the Covered Countries and knows or has reason to believe that those necessary 3TGs may not be from recycle or scrap sources.


3. Due Diligence Process and Results

Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten. The 5 steps of due diligence are:

Establish Strong Company Management Systems

Identify and Assess Risk in the Supply Chain

Design and Implement a Strategy to Respond to Identified Risks

Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

Report on Supply Chain Due Diligence






3.1. Management Systems

Internal Team

JBT has established a management system for conflict minerals. Our management system includes a Conflict Minerals team sponsored by JBT’s executive management, as well as engineering and sourcing resources within JBT’s business segments. The Conflict Minerals Team includes subject matter experts from relevant corporate functions such as:

Controller

General Counsel

Manager, Corporate Sourcing and Logistics

The team is responsible for implementing our conflict minerals compliance strategy and is led by the Company’s Executive Vice President and Chief Financial Officer. Senior management is briefed about the results of our due diligence efforts periodically.

Control Systems

As described above, we have has adopted a Conflict Minerals policy which is posted on our website at http://ir.jbtcorporation.com/governance.cfm.

JBT’s standard purchase order form terms and conditions include a requirement that suppliers comply with all local laws including those pertaining to business integrity.

As we do not typically have a direct relationship with 3TG smelters and refiners, and due to our position in the supply chain and limited insight into deeper levels of the supply chain, we seek to be engaged and actively cooperate with other major manufacturers in the industry regarding 3TG sourcing matters.

Supplier Engagement

With respect to the OECD requirement to strengthen engagement with suppliers, we have, through Assent, provided education with respect to conflict minerals regulations as well as our expectations for a continued business relationship, and leveraged the existing communications with our supplier base as is available. This year, we put a stronger emphasis on supplier education and training. To accomplish this, we utilized Assent’s learning management system, Assent University, and provided all in-scope suppliers access to their Conflict Minerals training course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

Grievance Mechanism

We have a hotline whereby employees can report violations of JBT’s policies. Employees are encouraged to reports concerns about compliance with policies to their managers, their human resources representative or company counsel unless they prefer to remain anonymous and utilize the hotline.

Maintain Records

We have adopted a policy to retain relevant documentation through Assent Compliance. Documentation will be retained for a minimum period of five years based on OECD guidance.

3.2 Identify and Assess Risk in the Supply Chain

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters not being certified DRC conflict-free pose a risk to the supply chain. Each facility that meets the Conflict-Free Sourcing Initiative (CFSI) definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on 3 scoring criteria:

1.
Geographic proximity to the DRC and covered countries;
2.
Conflict-Free Smelter Program (CFSP) audit status;





3.
Known or plausible evidence of unethical or conflict sourcing.

Based on these criteria the following facilities disclosed in CRMT surveys have been identified as high risk in the Company’s supply chain:

Tony Goetz NV - CID002587
Kaloti Precious Metals - CID002563
Phoenix Metals - CID002507
Universal Precious Metals Refining Zambia - CID002854
Fidelity Printers and Refiners - CID002515
Sudan Gold Refinery - CID002567

When these facilities were reported on a CMRT by one of the Company’s suppliers, risk mitigation activities were initiated. Through our third-party vendor, Assent Compliance, submissions that include any of the above facilities immediately produce a receipt instructing the supplier to take their own risk mitigation actions, including submission of a product specific CMRT to better identify the connection to products that they supply to JBT, and escalating up to removal of these high risk smelters from their supply chain.

Consistent with the OECD Due Diligence Guidance, risk mitigation will depend on the supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with the ultimate goal of progressive elimination of these risks from the supply chain.  

In addition, suppliers are guided to the Assent University learning platform to engage in educational materials on mitigating the risk of smelters or refiners on the supply chain.

If any smelter or refiner is not recognized by the CFSI, Assent conducts outreach and research to gain more information about whether they are a smelter or a refiner, sourcing practices, location, and country of origin. Additionally, if any smelter is not certified conflict-free, Assent conducts outreach providing education on the Conflict-Free Smelter Program and encouraging them to join this program.

We also calculate supplier risk based on the risk ratings of the smelters declared by that supplier on their CMRT.

Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). At this stage, evaluating and tracking the strength of the program meets the OECD Due Diligence Guidelines and can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the program are based on the following CMRT questions:

A. Do you have a policy in place that includes DRC conflict-free sourcing?

E. Have you implemented due diligence measures for conflict-free sourcing?

H. Do you verify due diligence information received from your suppliers?

I. Does your verification process include corrective action management?

When suppliers meet or exceed those criteria, they are deemed to have a strong program. When suppliers do not meet those criteria, they are deemed to have a weak program.

3.3 Design and Implement a Strategy to Respond to Identified Risks

In response to this risk assessment, we have a risk management plan, through which the conflict minerals program is implemented, managed and monitored.

As part of our risk management plan, to ensure suppliers understand our expectations we have provided both video, recorded training and documented instructions through Assent’s compliance supply chain staff. As the program progresses, contacts via email and phone by our business segments may be utilized to communicate the importance of a response via CMRTs to Assent and the required cooperation for compliance without conflict minerals policies will be emphasized.






We expect any of our suppliers that we have reason to believe are supplying us with 3TGs from sources that may support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict, as provided in the OECD guidance. During calendar year 2016, we have found no instances where it was necessary to terminate a contract or find a replacement supplier.

3.4 Carry out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct relationship with 3TG smelters and refiners and do not presently perform or direct audits of these entities within our supply chain. JBT depends on audits performed and submitted to the CFSI for conflict-free certifications.

3.5 Report Annually on Supply Chain Due Diligence

We report annually on supply chain due diligence by filing a Form SD and a Conflict Minerals Report with the Securities and Exchange Commission. Our Form SD and Conflict Minerals Report can be found on the Investor Relations page of our website http://ir.jbtcorporation.com/sec.cfm.


4. Due Diligence Results

Certain of the responses provided by the Company’s suppliers to the CMRT included the names of smelters or refiners. See Appendix A - Validated Smelter List. Assent compared these facilities listed in the responses to the list of smelters and refiners maintained by the CFSI, and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent confirmed that the name was listed as such by CFSI. Assent, using the sources above, has validated 319 smelters and refiners (“SORs”) disclosed by the Company’s suppliers on submitted CMRTs. Going forward, Assent is continuing to validate additional SORs from the submitted CMRTs.

The information that we received from a majority of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our suppliers contained in Appendix A below may include smelters or refiners that processed conflict minerals that our suppliers supplied to their other customers, but not to us. As a result, we are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the conflict minerals necessary to the functionality or production of our products during calendar year 2016. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed above were the country of origin of conflict minerals in our products during calendar year 2016, and therefore also unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the third-party audits conducted on smelters as part of the CFSP and the information that we receive from our suppliers may yield inaccurate or incomplete information. For example, the information received from our suppliers may be incomplete because they may not have received accurate and complete conflict minerals information from all of the suppliers in their own supply chain. We also do not have access to audit reports or detailed findings of the third-party audits conducted as part of the CFSP and, as a result, are not responsible for the quality of these audits or the audit findings.

Appendix A to this CMR lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Appendix A any smelters or refiners that we have not been able to validate. Appendix A also includes an aggregated list of the countries of origin from which the reported facilities collectively source conflict minerals, based on information provided by our suppliers and CFSI.

Many of our surveyed suppliers are still unable to provide the smelters or refiners used for materials they supplied to us. Furthermore, many of the responses provided at the company or division level indicated an “unknown” status in terms of determining the origin of 3TGs.

As noted above, the current efforts focus on gathering smelter information via the CMRT and, as the program progresses, requiring full completion of all necessary smelter identification information which will enable the validation and disclosure of the smelters as well as the tracing of the 3TGs to their location of origin.

We believe that the inquiries and assessment processes described above represent a reasonable effort to determine the origin of the 3TGs in our products, including (1) seeking information about 3TG smelters and refiners in our supply chain through requesting that our suppliers complete the CMRT, (2) verifying those smelters and refiners with the expanding CFSI lists, (3) conducting the due diligence review, and (4) obtaining additional documentation and verification, as applicable.






5. Risk Mitigation and Program Improvement Steps

We intend to take the following steps to improve the due diligence conducted to further mitigate any risk that the necessary 3TGs in our products could benefit armed groups in the Covered Countries:

a. Engage with suppliers through Assent and provide training resources to attempt to increase the response rate and improve the content of the supplier survey responses.

b. Engage any of our suppliers found to be supplying us with 3TGs from sources that support conflict in the Covered Countries to establish an alternative source of 3TGs that does not support such conflict.


Appendix A - Validated Smelter List

Metal
Smelter Name
 Smelter Facility Location
 CFSI Audit Status
Gold
Abington Reldan Metals, LLC
UNITED STATES
Active
Gold
Advanced Chemical Company
UNITED STATES
Compliant
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 Córrego do Sítio Mineração
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
Compliant
Gold
Asaka Riken Co., Ltd.
JAPAN
Compliant
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Not Enrolled
Gold
AU Traders and Refiners
SOUTH AFRICA
Compliant
Gold
AURA-II
UNITED STATES
Not Enrolled
Gold
Aurubis AG
GERMANY
Compliant
Gold
Bangalore Refinery
INDIA
Active
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Compliant
Gold
Boliden AB
SWEDEN
Compliant
Gold
C. Hafner GmbH + Co. KG
GERMANY
Compliant
Gold
Caridad
MEXICO
Not Enrolled
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Compliant
Gold
Cendres + Métaux S.A.
SWITZERLAND
Active
Gold
Chimet S.p.A.
ITALY
Compliant
Gold
Chugai Mining
JAPAN
Not Enrolled
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not Enrolled
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not Enrolled
Gold
DODUCO GmbH
GERMANY
Compliant
Gold
Dowa
JAPAN
Compliant
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Compliant
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Compliant
Gold
Elemetal Refining, LLC
UNITED STATES
Compliant
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Compliant





Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Not Enrolled
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Not Enrolled
Gold
Geib Refining Corporation
UNITED STATES
Active
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not Enrolled
Gold
Guangdong Jinding Gold Limited
CHINA
Not Enrolled
Gold
Gujarat Gold Centre
INDIA
Not Enrolled
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not Enrolled
Gold
Heimerle + Meule GmbH
GERMANY
Compliant
Gold
Heraeus Ltd. Hong Kong
CHINA
Compliant
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Compliant
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not Enrolled
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Not Enrolled
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Compliant
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Compliant
Gold
Istanbul Gold Refinery
TURKEY
Compliant
Gold
Japan Mint
JAPAN
Compliant
Gold
Jiangxi Copper Co., Ltd.
CHINA
Compliant
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Compliant
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Compliant
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Not Enrolled
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not Enrolled
Gold
Kazzinc
KAZAKHSTAN
Compliant
Gold
Kennecott Utah Copper LLC
UNITED STATES
Compliant
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Active
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Compliant
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Compliant
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Compliant
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Not Enrolled
Gold
Lingbao Gold Co., Ltd.
CHINA
Not Enrolled
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
L'Orfebre S.A.
ANDORRA
Not Enrolled
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Compliant
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not Enrolled
Gold
Materion
UNITED STATES
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
Compliant
Gold
Metalúrgica Met-Mex Peñoles 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 Enrolled
Gold
Morris and Watson
NEW ZEALAND
Not Enrolled





Gold
Morris and Watson Gold Coast
AUSTRALIA
Not Enrolled
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Compliant
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Compliant
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Active
Gold
Nihon Material Co., Ltd.
JAPAN
Compliant
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Compliant
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 Novosibirsk Refinery
RUSSIAN FEDERATION
Compliant
Gold
PAMP S.A.
SWITZERLAND
Compliant
Gold
Pease & Curren
UNITED STATES
Not Enrolled
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Compliant
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Compliant
Gold
PX Précinox S.A.
SWITZERLAND
Compliant
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Compliant
Gold
Remondis Argentia B.V.
NETHERLANDS
Not Enrolled
Gold
Republic Metals Corporation
UNITED STATES
Compliant
Gold
Royal Canadian Mint
CANADA
Compliant
Gold
SAAMP
FRANCE
Not Enrolled
Gold
Sabin Metal Corp.
UNITED STATES
Not Enrolled
Gold
SAFINA A.S.
CZECH REPUBLIC
Not Enrolled
Gold
Sai Refinery
INDIA
Not Enrolled
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Compliant
Gold
SAMWON Metals Corp.
KOREA, REPUBLIC OF
Not Enrolled
Gold
SAXONIA Edelmetalle GmbH
GERMANY
Compliant
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Compliant
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Compliant
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not Enrolled
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
Compliant
Gold
So Accurate Group, Inc.
UNITED STATES
Not Enrolled
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Compliant
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Compliant
Gold
Sudan Gold Refinery
SUDAN
Not Enrolled
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Compliant
Gold
SungEel HiTech
KOREA, REPUBLIC OF
Active
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 Enrolled
Gold
Tony Goetz NV
BELGIUM
Active
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not Enrolled
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
Compliant
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Not Enrolled
Gold
Valcambi S.A.
SWITZERLAND
Compliant
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Compliant
Gold
WIELAND Edelmetalle GmbH
GERMANY
Compliant
Gold
Yamamoto Precious Metal Co., Ltd.
JAPAN
Compliant
Gold
Yokohama Metal Co., Ltd.
JAPAN
Compliant
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not Enrolled
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Compliant
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Compliant
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Compliant
Tantalum
D Block Metals, LLC
UNITED STATES
Compliant
Tantalum
Duoluoshan
CHINA
Compliant
Tantalum
Exotech Inc.
UNITED STATES
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
Compliant
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Compliant
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Compliant
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Compliant
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Not Enrolled
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Compliant
Tantalum
H.C. Starck Inc.
UNITED STATES
Compliant
Tantalum
H.C. Starck Ltd.
JAPAN
Compliant
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Compliant
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Compliant
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
Compliant
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Compliant
Tantalum
Jiangxi Tuohong New Raw Material
CHINA
Compliant
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
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
Mineração Taboca S.A.
BRAZIL
Compliant
Tantalum
Mitsui Mining & Smelting
JAPAN
Compliant
Tantalum
Molycorp Silmet A.S.
ESTONIA
Compliant
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Compliant
Tantalum
Plansee SE Liezen
AUSTRIA
Not Enrolled
Tantalum
Plansee SE Reutte
AUSTRIA
Compliant
Tantalum
Power Resources Ltd.
MACEDONIA
Compliant





Tantalum
QuantumClean
UNITED STATES
Compliant
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Compliant
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Compliant
Tantalum
Taki Chemicals
JAPAN
Compliant
Tantalum
Telex Metals
UNITED STATES
Compliant
Tantalum
Tranzact, Inc.
UNITED STATES
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 Cemented Carbide Group Co., Ltd.
CHINA
Compliant
Tin
Alpha
UNITED STATES
Compliant
Tin
An Thai Minerals Co., Ltd.
VIET NAM
Not Enrolled
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not Enrolled
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Compliant
Tin
China Tin Group Co., Ltd.
CHINA
Compliant
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not Enrolled
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Compliant
Tin
CV Ayi Jaya
INDONESIA
Compliant
Tin
CV Dua Sekawan
INDONESIA
Compliant
Tin
CV Gita Pesona
INDONESIA
Compliant
Tin
CV Serumpun Sebalai
INDONESIA
Compliant
Tin
CV Tiga Sekawan
INDONESIA
Compliant
Tin
CV United Smelting
INDONESIA
Compliant
Tin
CV Venus Inti Perkasa
INDONESIA
Compliant
Tin
Dowa
JAPAN
Compliant
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Active
Tin
Elmet S.L.U.
SPAIN
Compliant
Tin
EM Vinto
BOLIVIA
Compliant
Tin
Estanho de Rondônia S.A.
BRAZIL
Not Enrolled
Tin
Fenix Metals
POLAND
Compliant
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 Enrolled
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
Not Enrolled
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
Compliant
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
Compliant
Tin
Metallo-Chimique N.V.
BELGIUM
Compliant
Tin
Mineração Taboca S.A.
BRAZIL
Compliant
Tin
Minsur
PERU
Compliant





Tin
Mitsubishi Materials Corporation
JAPAN
Compliant
Tin
Modeltech Sdn Bhd
MALAYSIA
Not Enrolled
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Active
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Compliant
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Compliant
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Compliant
Tin
Phoenix Metal Ltd.
RWANDA
Not Enrolled
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 Bangka Prima Tin
INDONESIA
Compliant
Tin
PT Bangka Tin Industry
INDONESIA
Compliant
Tin
PT Belitung Industri Sejahtera
INDONESIA
Compliant
Tin
PT Bukit Timah
INDONESIA
Compliant
Tin
PT Cipta Persada Mulia
INDONESIA
Compliant
Tin
PT DS Jaya Abadi
INDONESIA
Compliant
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Compliant
Tin
PT Inti Stania Prima
INDONESIA
Compliant
Tin
PT Justindo
INDONESIA
Not Enrolled
Tin
PT Karimun Mining
INDONESIA
Compliant
Tin
PT Kijang Jaya Mandiri
INDONESIA
Compliant
Tin
PT Lautan Harmonis Sejahtera
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 Prima Timah Utama
INDONESIA
Compliant
Tin
PT Refined Bangka Tin
INDONESIA
Compliant
Tin
PT Sariwiguna Binasentosa
INDONESIA
Compliant
Tin
PT Stanindo Inti Perkasa
INDONESIA
Compliant
Tin
PT Sukses Inti Makmur
INDONESIA
Compliant
Tin
PT Sumber Jaya Indah
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Compliant
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Compliant
Tin
PT Tinindo Inter Nusa
INDONESIA
Compliant
Tin
PT Tommy Utama
INDONESIA
Compliant
Tin
PT Wahana Perkit Jaya
INDONESIA
Compliant
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Compliant
Tin
Rui Da Hung
TAIWAN
Compliant
Tin
Soft Metais Ltda.
BRAZIL
Compliant
Tin
Thaisarco
THAILAND
Compliant
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not Enrolled
Tin
VQB Mineral and Trading Group JSC
VIET NAM
Compliant
Tin
White Solder Metalurgia e Mineração Ltda.
BRAZIL
Compliant
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Active
Tin
Yunnan Tin Company Limited
CHINA
Compliant
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Compliant





Tungsten
ACL Metais Eireli
BRAZIL
Not Enrolled
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Compliant
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Compliant
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Not Enrolled
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Compliant
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
H.C. Starck GmbH
GERMANY
Compliant
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Compliant
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Compliant
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Compliant
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Compliant
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 Enrolled
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not Enrolled
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
Kennametal Fallon
UNITED STATES
Compliant
Tungsten
Kennametal Huntsville
UNITED STATES
Compliant
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Compliant
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Compliant
Tungsten
Niagara Refining LLC
UNITED STATES
Compliant
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Compliant
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Compliant
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 Hütten AG
AUSTRIA
Compliant
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







Countries of origin include:

Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Democratic Republic of the Congo,  Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland,  Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe.