EX-1.01 2 exhibit1012019jbtformsd.htm EXHIBIT 1.01 Exhibit


Exhibit 1.01

John Bean Technologies Corporation

Conflict Minerals Report

For the Calendar Year Ended December 31, 2019

This report for the calendar year ended December 31, 2019 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, 2018.

JBT has reason to believe that some of the 3TGs (as defined below) 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.

The 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.”


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. These forward-looking statements include, among other things, statements about our compliance efforts and our ability to engage suppliers to obtain information. 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.




The product offerings of our FoodTech businesses include:

•
Protein. Our Protein offerings include primary and secondary poultry processing, mixing/grinding, injecting, marinating, tumbling, portioning, packaging, coating, cooking, frying, freezing, weighing, and X-ray food inspection.

•
Liquid Foods. Our Liquid Foods offerings include processing, preserving, and packaging which support extracting, mixing, blending, pasteurizing, sterilizing, concentrating, high pressure processing, filling, closing, sealing, and final packaging.

•
Automated Guided Vehicle 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. Our 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 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 “About Us” “Environmental, Social & Governance” and may be accessed via the following link:  https://www.jbtc.com/en/north-america/about-us/esg


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. This list was then filtered to remove suppliers of direct materials for all business units sourced prior to January 1, 2019.

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 100% 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 also via one-on-one communications. For the 2019 reporting period, JBT received responses from 30% of its in-scope suppliers. Of the 622 suppliers that provided a response, 38.7% reported that their products contained 3TGs necessary to the functionality or production of their products.

We provided 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 the Assent Compliance Manager 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 for record keeping purposes. Suppliers are contacted in regards to invalid forms and are strongly encouraged to resubmit a valid form. As of April 30th, 2020, there were 7 (0.1%) invalid supplier submissions.

As a result of its assessment, JBT has concluded in good faith that during calendar year 2019:

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 is unable to determine whether a portion of its necessary 3TGs originated or may have originated in the Covered Countries and is unable to determine whether 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 or make purchases from the Covered Countries. 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
•
Global Sourcing

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 adopted a Conflict Minerals policy which is posted on our website at https://www.jbtc.com/en/north-america/about-us/esg

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 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 put a strong 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. 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 report 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. 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 3TGs mineral is assessed according to red flag indicators defined in the OECD Guidance. There are numerous factors to determine the level of risk that each smelter poses to the supply chain by identifying red flags. These factors include:

•
Geographic proximity to the DRC and covered countries;
•
Known mineral source country of origin;
•
Responsible Minerals Assurance Process (RMAP) audit status;
•
Credible evidence of unethical or conflict sourcing; and
•
Peer Assessments conducted by credible third-party sources.

As part of our risk management plan under the OECD Guidance, when facilities with red flags were reported on a CMRT by one of the suppliers surveyed, risk mitigation activities are initiated. CMRT submissions that include any red flag 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 flag smelters from their supply chain.

Consistent with the OECD 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 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. Have you established a conflict minerals sourcing policy?

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

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

H. 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 2019, 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 https://www.jbtc.com/en/north-america/investors/sec-filings


4. Due Diligence Results

Survey Results

For the 2019 reporting year, JBT received a CMRT from 30% of the suppliers surveyed. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or gaps in data were found. 7 suppliers were unable to correct their CMRT and as such, are still listed as invalid submissions. We surveyed a total of 2,079 in scope suppliers and received 622 CMRT submissions by April 30th, 2020.

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 307 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 2019. 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 2019, and we are 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 potential countries of origin from which the reported facilities collectively source conflict minerals, 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 requesting 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 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. Encourage our suppliers to have due diligence procedures in place for their supply chains to improve the content of the responses from such suppliers.
d. Continue to include a conflict minerals flow-down clause in new or renewed supplier contracts and in the terms and conditions of each purchase order issued to direct suppliers of materials for JBT businesses likely to source materials that might contain 3TGs.






Appendix A - Validated Smelter List




Metal
Standard Smelter Name
Smelter Facility Location
Smelter ID
Gold
8853 S.p.A.
ITALY
CID002763
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
CID002708
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID000015
Gold
African Gold Refinery
UGANDA
CID003185
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
CID000103
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangalore Refinery
INDIA
CID002863
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
C.I Metales Procesados Industriales SAS
COLOMBIA
CID003421
Gold
Caridad
MEXICO
CID000180
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Cendres + Metaux S.A.
SWITZERLAND
CID000189
Gold
CGR Metalloys Pvt Ltd.
INDIA
CID003382
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
Chugai Mining
JAPAN
CID000264
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
CID000343
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
CID002867
Gold
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
CID003348
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
CID003195
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd. East Plant
JAPAN
CID000425
Gold
Eco-System Recycling Co., Ltd. North Plant
JAPAN
CID003424
Gold
Eco-System Recycling Co., Ltd. West Plant
JAPAN
CID003425
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
CID002515
Gold
Fujairah Gold FZC
UNITED ARAB EMIRATES
CID002584
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
CID002852
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002459
Gold
Gold Coast Refinery
GHANA
CID003186
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
CID001909
Gold
Guangdong Jinding Gold Limited
CHINA
CID002312
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
CID000651
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
CID000671
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000767


Gold
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
CID000773
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
CID000778
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
International Precious Metal Refiners
UNITED ARAB EMIRATES
CID002562
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Italpreziosi
ITALY
CID002765
Gold
JALAN & Company
INDIA
CID002893
Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
CID002563
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
CID000956
Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
CID002511
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kundan Care Products Ltd.
INDIA
CID003463
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
CID002865
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
CID001032
Gold
Lingbao Gold Co., Ltd.
CHINA
CID001056
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
CID001058
Gold
L'Orfebre S.A.
ANDORRA
CID002762
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
LT Metal Ltd.
KOREA, REPUBLIC OF
CID000689
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
CID001093
Gold
Marsam Metals
BRAZIL
CID002606
Gold
Materion
UNITED STATES OF AMERICA
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001157
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Modeltech Sdn Bhd
MALAYSIA
CID002857
Gold
Morris and Watson
NEW ZEALAND
CID002282
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001220
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
CID001236
Gold
NH Recytech Company
KOREA, REPUBLIC OF
CID003189
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Pease & Curren
UNITED STATES OF AMERICA
CID002872
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
CID001362
Gold
Planta Recuperadora de Metales SpA
CHILE
CID002919
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Precinox S.A.
SWITZERLAND
CID001498
Gold
QG Refining, LLC
UNITED STATES OF AMERICA
CID003324
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512


Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
CID000522
Gold
REMONDIS PMR B.V.
NETHERLANDS
CID002582
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
SAAMP
FRANCE
CID002761
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
CID001546
Gold
Safimet S.p.A
ITALY
CID002973
Gold
SAFINA A.S.
CZECH REPUBLIC
CID002290
Gold
Sai Refinery
INDIA
CID002853
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
CID001562
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001585
Gold
Shandong Humon Smelting Co., Ltd.
CHINA
CID002525
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
CID001619
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Shirpur Gold Refinery Ltd.
INDIA
CID002588
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001761
Gold
Sovereign Metals
INDIA
CID003383
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
CID003153
Gold
Sudan Gold Refinery
SUDAN
CID002567
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
CID002918
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
CID001947
Gold
Tony Goetz NV
BELGIUM
CID002587
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
CID002615
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID001993
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamakin Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
CID000197
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tantalum
Asaka Riken Co., Ltd.
JAPAN
CID000092
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211
Tantalum
CP Metals Inc.
UNITED STATES OF AMERICA
CID003402
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID002504
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000456
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
FIR Metals & Resource Ltd.
CHINA
CID002505
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002557
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
CID000616
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
CID002512


Tantalum
Jiangxi Tuohong New Raw Material
CHINA
CID002842
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
CID002506
Tantalum
KEMET Blue Metals
MEXICO
CID002539
Tantalum
LSM Brasil S.A.
BRAZIL
CID001076
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
CID001163
Tantalum
Mineracao Taboca S.A.
BRAZIL
CID001175
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
NPM Silmet AS
ESTONIA
CID001200
Tantalum
PRG Dooel
NORTH MACEDONIA, REPUBLIC OF
CID002847
Tantalum
QuantumClean
UNITED STATES OF AMERICA
CID001508
Tantalum
Resind Industria e Comercio Ltda.
BRAZIL
CID002707
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
CID001769
Tantalum
Taki Chemical Co., Ltd.
JAPAN
CID001869
Tantalum
Telex Metals
UNITED STATES OF AMERICA
CID001891
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
CID002508
Tantalum
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
CID001522
Tin
Alpha
UNITED STATES OF AMERICA
CID000292
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
CID002703
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
CID003190
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
CID003356
Tin
Dowa
JAPAN
CID000402
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
CID002572
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000438
Tin
Estanho de Rondonia S.A.
BRAZIL
CID000448
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
CID003410
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
CID000555
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
Luna Smelter, Ltd.
RWANDA
CID003387
Tin
Ma'anshan Weitai Tin Co., Ltd.
CHINA
CID003379
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Modeltech Sdn Bhd
MALAYSIA
CID002858
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002573
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID001337
Tin
Pongpipat Company Limited
MYANMAR
CID003208
Tin
Precious Minerals and Smelting Limited
INDIA
CID003409
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399


Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
PT Timah Tbk Kundur
INDONESIA
CID001477
Tin
PT Timah Tbk Mentok
INDONESIA
CID001482
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Super Ligas
BRAZIL
CID002756
Tin
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
CID002834
Tin
Thaisarco
THAILAND
CID001898
Tin
Tin Technology & Refining
UNITED STATES OF AMERICA
CID003325
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
CID002574
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tin
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
CID003397
Tungsten
A.L.M.T. Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
CID003427
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513
Tungsten
China Molybdenum Co., Ltd.
CHINA
CID002641
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
CID000281
Tungsten
CP Metals Inc.
UNITED STATES OF AMERICA
CID003448
Tungsten
Fujian Ganmin RareMetal Co., Ltd.
CHINA
CID003401
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
CID002645
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
GEM Co., Ltd.
CHINA
CID003417
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.
CHINA
CID003182
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
CID002313
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xianglu Tungsten Co., Ltd.
CHINA
CID002647
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
CID003408
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID000105
Tungsten
KGETS Co., Ltd.
KOREA, REPUBLIC OF
CID003388
Tungsten
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID003407
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
CID002543
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002845
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002589
Tungsten
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
CID003416
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827


Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002044
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095




List of Potential Countries of Origin:

Afghanistan, Albania, Angola, Argentina, Armenia, Australia, Austria, Belarus, Belgium, Bermuda, Bolivia, Brazil, Bulgaria, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Czech Republic, Djibouti, Dominican Republic, DRC or an adjoining country (Covered Countries), Ecuador, Egypt, England, Estonia, Ethiopia, Finland, France, Germany, Ghana, Guinea, Guyana, Hungary, India, Indonesia, Ireland, Israel, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Lithuania, Luxembourg, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Niger    , Nigeria, Papua New Guinea, Peru, Philippines, Poland, Portugal, Republic, Republic Of Korea, Russia, Rwanda, Saudi Arabia, Sierra Leone, Singapore, Slovakia, Slovenia, South Africa, Spain, Sudan, Suri, Suriname, Sweden, Switzerland, Tanzania, Thailand, Turkey, Uganda, United Arab, Emirates, United Kingdom, USA, Uzbekistan, Viet Nam, Zambia, Zimbabwe