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, 2017

This report for the calendar year ended December 31, 2017 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, 2016.

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. Providing comprehensive solutions to our customers, our Protein technology offerings include chilling, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, frying, freezing, weighing, X-ray food inspection, and packaging systems 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 2017 added significant capabilities in the powder filling and high pressure processing segments to our product portfolio.
Automated Systems. We also provide stand-alone, fully-integrated, and dual-mode robotic automated guided vehicle systems for material movement requirements with a wide variety of applications including 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 also maintains 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://www.jbtc.com/investors/corporate-governance.

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 RBA-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.

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 94% 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 one follow up from the supply chain team. For the 2017 reporting period, JBT received responses from 39%, of its in-scope suppliers. Of the 695 suppliers that provided a response, approximately 69% 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 23, 2018, there were 17 invalid supplier submissions.

As a result of its assessment, JBT has concluded in good faith that during calendar year 2017:
 
 
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 Organization 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:

1.
Establishing strong company management systems regarding conflict minerals;
2.
Identifying and assessing risks in our supply chain;
3.
Designing and implementing a strategy to respond to identified risks in our supply chain;
4.
Utilizing independent third-party audits of supply chain diligence; and
5.
Publicly reporting on our supply chain due diligence

We are a downstream supplier, many steps removed from the mining of 3TG. A large number of suppliers, through multiple tiers of distribution, supply the components and materials integrated into our products. Furthermore, JBT does not purchase raw ore or unrefined conflict minerals. The origin of the conflict minerals cannot be determined with any certainty once the raw ores are smelted, refined and converted to ingots, bullion or other conflict mineral containing derivatives. The smelters and refiners consolidate raw ore and represent the best actors in the total supply chain to possess knowledge of the origin of the ores they procure.

The OECD Guidance specifies that the requirements for compliance should reflect a company’s position in the supply chain.  In particular, the OECD Guidance states that the implementation of due diligence should be tailored to a company’s activities and relationships and that the nature and extent of due diligence may vary based on a company’s size, products, relationships with suppliers and other factors.  Due to practical difficulties associated with supply chain complexities, the OECD Guidance advises that downstream companies exercise due diligence primarily by establishing controls over their immediate suppliers. Accordingly, we rely primarily on our “tier 1” (direct) suppliers to provide information with respect to the origin of the conflict minerals contained in the components and materials supplied to us.


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
 
 
Senior Strategic Sourcing Lead

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.

Control Systems

As described above, we have has adopted a Conflict Minerals policy which is posted on our website under “Investor Relations” “Corporate Governance” at http://www.jbtc.com/investors/corporate-governance.

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. 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 Responsible Minerals Initiative (RMI) 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.
Responsible Minerals Assurance Process (RMAP) audit status and;
3.
Known or plausible evidence of unethical or conflict sourcing.

Based on these criteria the following facilities disclosed in CMRT surveys have been identified as high risk in the Company’s supply chain:
 
 
 
 
Tony Goetz NV - CID002587
 
 
 
 
Kaloti Precious Metals - CID002563
 
 
 
 
African Gold Refinery Limited (AGR) - CID003185
 
 
 
 
Universal Precious Metals Refining Zambia - CID002854
 
 
 
 
Fidelity Printers and Refiners - CID002515
 
 
 
 
Sudan Gold Refinery - CID002567




When these facilities are reported on a CMRT by any of the Company’s suppliers, risk mitigation activities are 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 red-flagged 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 RMI, 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 RMAP 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:

Have you established a conflict minerals sourcing policy?

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

Do you review due diligence information received from your suppliers against your company’s expectations?

Does your review 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 2017, 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 RMI 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://www.jbtc.com/investors/sec-filings.










4. Due Diligence Results


Survey Results

For the 2017 reporting year, JBT received CMRT forms from 39% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. Seventeen suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 1,803 in scope suppliers and received 695 CMRT submissions by April 23, 2018.

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 RMI, and, if a supplier indicated that the facility was certified as “Conflict-Free”, Assent confirmed that the name was listed as such by RMI. Assent, using the sources above, has validated 321 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 2017. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed in Appendix A were the country of origin of conflict minerals in our products during calendar year 2017, 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 RMAP 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 RMAP 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 3TGs, based on information provided by our suppliers and RMI.

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 RMI 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.
c. Through education, encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.









Appendix A - Validated Smelter List

Metal
Standard Smelter Name
Smelter ID
Gold
Abington Reldan Metals, LLC
CID002708
Gold
Advanced Chemical Company
CID000015
Gold
African Gold Refinery
CID003185
Gold
Aida Chemical Industries Co., Ltd.
CID000019
Gold
Al Etihad Gold LLC
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
Gold
Argor-Heraeus S.A.
CID000077
Gold
Asahi Pretec Corp.
CID000082
Gold
Asahi Refining Canada Ltd.
CID000924
Gold
Asahi Refining USA Inc.
CID000920
Gold
Asaka Riken Co., Ltd.
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
Gold
AU Traders and Refiners
CID002850
Gold
Aurubis AG
CID000113
Gold
Bangalore Refinery
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
Gold
Boliden AB
CID000157
Gold
C. Hafner GmbH + Co. KG
CID000176
Gold
Caridad
CID000180
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
Gold
Cendres + Métaux S.A.
CID000189
Gold
Chimet S.p.A.
CID000233
Gold
Chugai Mining
CID000264
Gold
Daejin Indus Co., Ltd.
CID000328
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
Gold
DODUCO Contacts and Refining GmbH
CID000362
Gold
Dowa
CID000401
Gold
DS PRETECH Co., Ltd.
CID003195
Gold
DSC (Do Sung Corporation)
CID000359
Gold
Eco-System Recycling Co., Ltd.
CID000425
Gold
Elemetal Refining, LLC
CID001322
Gold
Emirates Gold DMCC
CID002561
Gold
Fidelity Printers and Refiners Ltd.
CID002515
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
Gold
Geib Refining Corporation
CID002459
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CID002243
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
Gold
Guangdong Jinding Gold Limited
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
Gold
HeeSung
CID000689
Gold
Heimerle + Meule GmbH
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CID000707



Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
Gold
Hwasung CJ Co., Ltd.
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
Gold
Istanbul Gold Refinery
CID000814
Gold
Italpreziosi
CID002765
Gold
Japan Mint
CID000823
Gold
Jiangxi Copper Co., Ltd.
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
Gold
JSC Uralelectromed
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
Gold
Kaloti Precious Metals
CID002563
Gold
Kazakhmys Smelting LLC
CID000956
Gold
Kazzinc
CID000957
Gold
Kennecott Utah Copper LLC
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
CID002511
Gold
Kojima Chemicals Co., Ltd.
CID000981
Gold
Korea Zinc Co., Ltd.
CID002605
Gold
Kyrgyzaltyn JSC
CID001029
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
Gold
L'azurde Company For Jewelry
CID001032
Gold
Lingbao Gold Co., Ltd.
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
Gold
L'Orfebre S.A.
CID002762
Gold
LS-NIKKO Copper Inc.
CID001078
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
Gold
Marsam Metals
CID002606
Gold
Materion
CID001113
Gold
Matsuda Sangyo Co., Ltd.
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
Gold
Metalor Technologies S.A.
CID001153
Gold
Metalor USA Refining Corporation
CID001157
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
Gold
Mitsubishi Materials Corporation
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
Gold
Modeltech Sdn Bhd
CID002857
Gold
Morris and Watson
CID002282
Gold
Morris and Watson Gold Coast
CID002866
Gold
Moscow Special Alloys Processing Plant
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
CID001220
Gold
Navoi Mining and Metallurgical Combinat
CID001236
Gold
NH Recytech Company
CID003189
Gold
Nihon Material Co., Ltd.
CID001259
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
CID001326



Gold
OJSC Novosibirsk Refinery
CID000493
Gold
PAMP S.A.
CID001352
Gold
Pease & Curren
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
Gold
Planta Recuperadora de Metales SpA
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
Gold
PX Précinox S.A.
CID001498
Gold
Rand Refinery (Pty) Ltd.
CID001512
Gold
Refinery of Seemine Gold Co., Ltd.
CID000522
Gold
Remondis Argentia B.V.
CID002582
Gold
Republic Metals Corporation
CID002510
Gold
Royal Canadian Mint
CID001534
Gold
SAAMP
CID002761
Gold
Sabin Metal Corp.
CID001546
Gold
Safimet S.p.A
CID002973
Gold
SAFINA A.S.
CID002290
Gold
Sai Refinery
CID002853
Gold
Samduck Precious Metals
CID001555
Gold
SAMWON Metals Corp.
CID001562
Gold
SAXONIA Edelmetalle GmbH
CID002777
Gold
Schone Edelmetaal B.V.
CID001573
Gold
SEMPSA Joyería Platería S.A.
CID001585
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
Gold
Singway Technology Co., Ltd.
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
Gold
Solar Applied Materials Technology Corp.
CID001761
Gold
State Research Institute Center for Physical Sciences and Technology
CID003153
Gold
Sudan Gold Refinery
CID002567
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
Gold
SungEel HiTech
CID002918
Gold
T.C.A S.p.A
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
Gold
Tokuriki Honten Co., Ltd.
CID001938
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
Gold
Tony Goetz NV
CID002587
Gold
TOO Tau-Ken-Altyn
CID002615
Gold
Torecom
CID001955
Gold
Umicore Brasil Ltda.
CID001977
Gold
Umicore Precious Metals Thailand
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
Gold
United Precious Metal Refining, Inc.
CID001993
Gold
Universal Precious Metals Refining Zambia
CID002854
Gold
Valcambi S.A.
CID002003
Gold
Western Australian Mint trading as The Perth Mint
CID002030
Gold
WIELAND Edelmetalle GmbH
CID002778
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100



Gold
Yokohama Metal Co., Ltd.
CID002129
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
Tantalum
Asaka Riken Co., Ltd.
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
Tantalum
D Block Metals, LLC
CID002504
Tantalum
Duoluoshan
CID000410
Tantalum
Exotech Inc.
CID000456
Tantalum
F&X Electro-Materials Ltd.
CID000460
Tantalum
FIR Metals & Resource Ltd.
CID002505
Tantalum
Global Advanced Metals Aizu
CID002558
Tantalum
Global Advanced Metals Boyertown
CID002557
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CID000291
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
Tantalum
H.C. Starck Co., Ltd.
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
Tantalum
H.C. Starck Inc.
CID002548
Tantalum
H.C. Starck Ltd.
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
Tantalum
Jiujiang Janny New Material Co., Ltd.
CID003191
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
Tantalum
KEMET Blue Metals
CID002539
Tantalum
KEMET Blue Powder
CID002568
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
Tantalum
LSM Brasil S.A.
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
Tantalum
Mineracao Taboca S.A.
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
Tantalum
NPM Silmet AS
CID001200
Tantalum
Power Resources Ltd.
CID002847
Tantalum
QuantumClean
CID001508
Tantalum
Resind Industria e Comercio Ltda.
CID002707
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CID001522
Tantalum
Solikamsk Magnesium Works OAO
CID001769
Tantalum
Taki Chemicals
CID001869
Tantalum
Telex Metals
CID001891
Tantalum
Ulba Metallurgical Plant JSC
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
Tin
Alpha
CID000292
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CID003190



Tin
China Tin Group Co., Ltd.
CID001070
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
Tin
CV Ayi Jaya
CID002570
Tin
CV Dua Sekawan
CID002592
Tin
CV Gita Pesona
CID000306
Tin
CV Tiga Sekawan
CID002593
Tin
CV United Smelting
CID000315
Tin
CV Venus Inti Perkasa
CID002455
Tin
Dowa
CID000402
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
Tin
EM Vinto
CID000438
Tin
Estanho de Rondônia S.A.
CID000448
Tin
Fenix Metals
CID000468
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
Tin
Gejiu Jinye Mineral Company
CID002859
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
Tin
Guangdong Hanhe Non-ferrous Metal Limited Company
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
Tin
Jiangxi New Nanshan Technology Ltd.
CID001231
Tin
Magnu's Minerais Metais e Ligas Ltda.
CID002468
Tin
Malaysia Smelting Corporation (MSC)
CID001105
Tin
Melt Metais e Ligas S.A.
CID002500
Tin
Metallic Resources, Inc.
CID001142
Tin
Metallo Belgium N.V.
CID002773
Tin
Metallo Spain S.L.U.
CID002774
Tin
Mineracao Taboca S.A.
CID001173
Tin
Minsur
CID001182
Tin
Mitsubishi Materials Corporation
CID001191
Tin
Modeltech Sdn Bhd
CID002858
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
Tin
Operaciones Metalurgical S.A.
CID001337
Tin
Pongpipat Company Limited
CID003208
Tin
PT Aries Kencana Sejahtera
CID000309
Tin
PT Artha Cipta Langgeng
CID001399
Tin
PT ATD Makmur Mandiri Jaya
CID002503
Tin
PT Babel Inti Perkasa
CID001402
Tin
PT Bangka Prima Tin
CID002776
Tin
PT Bangka Serumpun
CID003205
Tin
PT Bangka Tin Industry
CID001419
Tin
PT Belitung Industri Sejahtera
CID001421
Tin
PT Bukit Timah
CID001428
Tin
PT DS Jaya Abadi
CID001434



Tin
PT Eunindo Usaha Mandiri
CID001438
Tin
PT Inti Stania Prima
CID002530
Tin
PT Karimun Mining
CID001448
Tin
PT Kijang Jaya Mandiri
CID002829
Tin
PT Lautan Harmonis Sejahtera
CID002870
Tin
PT Menara Cipta Mulia
CID002835
Tin
PT Mitra Stania Prima
CID001453
Tin
PT O.M. Indonesia
CID002757
Tin
PT Panca Mega Persada
CID001457
Tin
PT Premium Tin Indonesia
CID000313
Tin
PT Prima Timah Utama
CID001458
Tin
PT Refined Bangka Tin
CID001460
Tin
PT Sariwiguna Binasentosa
CID001463
Tin
PT Stanindo Inti Perkasa
CID001468
Tin
PT Sukses Inti Makmur
CID002816
Tin
PT Sumber Jaya Indah
CID001471
Tin
PT Timah (Persero) Tbk Kundur
CID001477
Tin
PT Timah (Persero) Tbk Mentok
CID001482
Tin
PT Tinindo Inter Nusa
CID001490
Tin
PT Tommy Utama
CID001493
Tin
Resind Industria e Comercio Ltda.
CID002706
Tin
Rui Da Hung
CID001539
Tin
Soft Metais Ltda.
CID001758
Tin
Super Ligas
CID002756
Tin
Thaisarco
CID001898
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
Tin
Yunnan Tin Company Limited
CID002180
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
Tungsten
ACL Metais Eireli
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CID002645
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
Tungsten
Global Tungsten & Powders Corp.
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co.KG
CID002542
Tungsten
H.C. Starck Tungsten GmbH
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CID003182
Tungsten
Hydrometallurg, JSC
CID002649
Tungsten
Japan New Metals Co., Ltd.
CID000825



Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CID002313
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
Tungsten
Kennametal Fallon
CID000966
Tungsten
Kennametal Huntsville
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
Tungsten
Moliren Ltd
CID002845
Tungsten
Niagara Refining LLC
CID002589
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
Tungsten
Unecha Refractory metals plant
CID002724
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
Tungsten
Woltech Korea Co., Ltd.
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095

This list of potential countries of origin is populated based on publicly available information, our RCOI and due diligence. It is important to note that this is also based on company level responses and therefore, it is not certain which of these countries of origin can be linked to our products.

Argentina, Australia, Austria, Benin, Bolivia (Plurinational State of), Brazil, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Congo, DRC, Ecuador, Eritrea, Ethiopia, France, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Japan, Kazakhstan, Laos, Madagascar, Malaysia, Mali, Mexico, Mongolia, Mozambique, Myanmar, Namibia, Nicaragua, Nigeria, Panama, Peru, Portugal, Russian Federation, Rwanda, Senegal, Sierra Leone, South Africa, Spain, Thailand, Togo, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zimbabwe