UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
BRP Inc.
(Exact name of registrant as specified in its charter)
| Canada | 001-38648 | 98-0520087 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) | (I.R.S. Employer Identification No.) |
| 726 Saint-Joseph Street Valcourt, Quebec |
J0E 2L0 | |
| (Address of principal executive offices) | (Zip Code) |
| Martin Langelier (450)-532-6154 |
| (Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.
=============================================================================================================
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
BRP Inc. (herein referred to as the “Company”, “BRP”, “we”, “us”, or “our”) has filed a Conflict Minerals Report for the reporting period from January 1, 2020 to December 31, 2020 (the “2020 Conflict Minerals Report”), which is referenced in Item 1.02 below, as an exhibit to this Form SD and has made the 2020 Conflict Minerals Report publicly available on the Investor Relations page of our website at https://news.brp.com/financial-information. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein.
Item 1.02 Exhibits
A copy of BRP’s 2020 Conflict Minerals Report is included as Exhibit 1.01 attached to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
| Exhibit No. |
Exhibit | |||
| 1.01 |
Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| BRP Inc. (Registrant) |
June 1, 2021 |
| /S/ Martin Langelier |
| Martin Langelier Senior Vice President, General Counsel & Public Affairs |
Exhibit 1.01
BRP Inc. has included this Conflict Minerals Report as an exhibit to its Form SD for the period from January 1, 2020 to December 31, 2020 as provided for in Rule 13p-1 under the Securities Exchange Act of 1934, as amended, and Form SD (collectively, the “Conflict Minerals Rule”). The date of filing of this Conflict Minerals Report is June 1, 2021.
Unless the context indicates otherwise, the terms “Company”, “BRP”, “we”, “us”, or “our” refer to BRP Inc. and its
consolidated subsidiaries. As used herein, “Conflict Minerals” or “3TG” is defined as, consistent with the Conflict Minerals Rule, cassiterite, columbite-tantalite (coltan), gold, wolframite and the derivatives tin, tantalum and tungsten.
COMPANY OVERVIEW
BRP is a global leader in the design, development, manufacturing, distribution and marketing of powersports vehicles and marine products. BRP’s diversified portfolio of brands and products includes, under the Powersports segment, Year-Round Products such as Can-Am ATVs, SSVs and 3WVs, Seasonal Products such as Ski-Doo and Lynx snowmobiles and Sea-Doo PWCs and Rotax engines for karts, motorcycles and recreational aircraft, and under the Marine segment, Alumacraft, Manitou, Quintrex, Stacer and Savage boats, and Rotax engines for jet boats.
We do not source 3TG from smelters or refiners and have no direct relationships with mines, and we believe that we are in at least most cases many levels removed from all of these market participants. However, through the efforts described in this Conflict Minerals Report, we seek to ensure that the 3TG in our products is responsibly sourced.
REASONABLE COUNTRY OF ORIGIN INQUIRY
For 2020, BRP determined that 3TG were necessary to the functionality or production of products that it manufactured or contracted to be manufactured. Therefore, BRP conducted a reasonable country of origin inquiry (“RCOI”) within the meaning of the Conflict Minerals Rule to determine whether any of the 3TGs in its in-scope products originated in the Democratic Republic of the Congo (“DRC”) or an adjoining country (collectively referred to as the “Covered Countries”), and were not from recycled or scrap sources.
For our RCOI, to the extent applicable, we utilized the same processes and procedures as for our due diligence, in particular Steps 1 and 2 of the Organisation for Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”). The OECD Guidance is discussed further below.
Based on our RCOI, in-scope BRP products may contain 3TGs that originated in the Covered Countries and may not be from recycled or scrap sources. In accordance with the Conflict Minerals Rule, we exercised due diligence.
DUE DILIGENCE PROGRAM
Due Diligence Framework
BRP designed its due diligence measures to conform, in all material respects, with the applicable portions of the OECD Guidance. The OECD Guidance has established a five-step framework for due diligence as a basis for responsible global supply chain management of minerals from conflict-affected and high-risk areas. Selected elements of our due diligence program are discussed below. The headings below conform to the headings used in the OECD Guidance for each of the five steps.
Selected Elements of Due Diligence Program
| 1) | Establish Strong Company Management Systems |
Conflict Minerals Policy [and Supplier Code of Conduct]
BRP adopted a conflict minerals policy articulating its 3TG minerals supply chain due diligence process and BRP’s commitments to reporting obligations regarding conflict minerals. The policy is available online and can be found here: https://www.brp.com/en/about-brp/ethics---compliance.html. Information found on or accessed through this website is not considered part of this report and is not incorporated by reference herein.
Internal Compliance Team
BRP has a cross-functional 3TG compliance team led by its Director Intellectual Property & Product Compliance. The 3TG compliance team is responsible for implementing BRP’s 3TG compliance strategy and briefing senior management about the results of our 3TG due diligence.
BRP also uses a third-party service provider (the “Service Provider”) to assist with supplier outreach and validating and evaluating information relating to 3TG usage and sourcing received from suppliers. Some of the activities described in this report have been undertaken by the Service Provider on our behalf. We also utilized specialist outside counsel in connection with selected aspects of our program.
Control Systems and Supplier Engagement
We utilize the Conflict Minerals Reporting Template (the “CMRT”) developed by the Responsible Minerals Initiative (the “RMI”) to identify smelters and refiners in our supply chain. The CMRT requests suppliers to provide information concerning the usage and source of 3TG in their products, as well as information concerning their related compliance efforts. As earlier noted, we utilize the Service Provider to conduct our supplier outreach and follow-up, as well as for the validation and evaluation of supplier responses. BRP also engages with suppliers directly to request CMRTs. BRP has developed an internal procedure that provides for supplier engagement escalation and corrective action if a supplier is not responsive to our CMRT requests.
The Service Provider provides training and educational materials to suppliers to enhance the quality of responses.
We also include in supplier contracts a clause requiring suppliers to provide information about the source of 3TG in the products they sell to us.
Grievance Mechanisms
BRP has multiple grievance mechanisms whereby employees and suppliers can report violations of BRP’s policies, including relating to sourcing of 3TG. Employees and suppliers may anonymously report suspected violations using our Whistleblower Hotline. https://www.brp.com/en/about-brp/ethics---compliance.html
Records Maintenance
We maintain business records relating to 3TG due diligence, including records of due diligence processes, findings and resulting decisions, for at least five years.
| 2) | Identify and Assess Risk in the Supply Chain |
BRP provided a list of suppliers and parts associated with its in-scope products to the Service Provider. Our outreach for 2020 included 1188 suppliers. We requested in writing, through the Service Provider, that these suppliers provide us with a completed CMRT. The Service Provider followed up by email or phone on our behalf with suppliers that did not respond to the request within the specified time frame. The Service Provider followed up multiple times with non-responsive suppliers. BRP directly contacted some suppliers that were unresponsive to the Service Provider’s communications, requesting that these suppliers complete the CMRT and submit it to the Service Provider.
The Service Provider, on our behalf, reviewed supplier responses against its written review criteria to identify incomplete responses, potential errors and inaccuracies in the CMRTs. The Service Provider followed up by email with suppliers that submitted a response that triggered specific quality issues relating to completeness and accuracy. In addition, smelter and refiner information provided by suppliers was reviewed by the Service Provider against the RMI’s list of known smelters and refiners. To the extent that a smelter or refiner identified by a supplier is not on that list, the Service Provider may take additional steps to attempt to determine whether the listed entity is a smelter or refiner. Smelter and refiner information also was reviewed against the lists of Conformant and Active (as later defined) smelters and refiners published by the RMI.
To the extent that a smelter or refiner identified by a supplier was not listed as Conformant by the RMI, the Service Provider undertook an additional review to attempt to determine whether that smelter or refiner obtained 3TG from sources that directly or indirectly financed or benefitted armed groups in the Covered Countries. The Service Provider attempted to reach out to the smelter or refiner directly and conducted research to gain more information about the smelter’s or refiner’s sourcing practices, including the countries of origin of the minerals that it processes, the transit and transfer of the minerals that it processes and whether it has in place internal due diligence procedures or other processes to track the chain-of-custody of its 3TG.
Suppliers that identified specific smelters or refiners of concern on their CMRT were contacted by the Service Provider to inform them of the potential for risk, and to evaluate whether or not these smelters and refiners could be connected to BRP’s products. The suppliers were asked to complete a user-defined or product-level CMRT specific to the materials, products or piece parts purchased by BRP, rather than a company-level CMRT, to better identify the connection to products that they supply to BRP. Other suppliers were evaluated internally to determine if they were still active suppliers. If not, they were removed from the scope of data collection.
The Service Provider also evaluated suppliers’ due diligence processes and policies based on the suppliers’ responses to certain of the questions in the CMRT. These questions ask suppliers about their internal processes regarding 3TG.
| 3) | Design and Implement a Strategy to Respond to Identified Risks |
The results of our supplier outreach campaign and risk assessment are reviewed by our 3TG compliance team and shared with BRP’s leadership team.
BRP has developed processes to assess and respond to risks identified in the supply chain. BRP has a risk management plan, through which the 3TG compliance program is implemented, managed and monitored. Escalations are sent to non-responsive suppliers to indicate the importance of a CMRT response and BRP’s compliance expectations.
Feedback on supplier submissions is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. The Service Provider also communicates directly with smelters and refiners that are not yet Conformant to request sourcing information and encourage their involvement with the RMAP program.
In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, BRP may reassess the business relationship.
| 4) | Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
BRP does not have a direct relationship with any 3TG smelters or refiners and does not perform or direct audits of these entities within the supply chain. Instead, BRP utilizes third-party audits of smelters and refiners conducted as part of the RMAP.
| 5) | Report on Supply Chain Due Diligence |
This report is available on the Investor Relations section of BRP’s website at https://news.brp.com/financial-information. BRP has also publicly filed a Form SD and this report with the U.S. Securities and Exchange Commission.
Identified Smelters and Refiners; Country of Origin Information
The suppliers listed 334 smelters and refiners in completed CMRTs. Of these, 237 were Conformant and 23 were Active.
“Conformant” means that a smelter or refiner has successfully completed an assessment against the applicable Responsible Minerals Assurance Process (“RMAP”) standard or an equivalent cross-recognized assessment. Included smelters and refiners were not necessarily Conformant for all or part of 2020 and may not continue to be Conformant for any future period. “Active” means that the smelter or refiner has committed to undergo an RMAP assessment, completed the relevant documents, and scheduled the on-site assessment. These may be in the pre-assessment, assessment, or corrective action phases of the assessment. All compliance status information in the tables is as of May 14, 2021. Compliance status is based on information published by the RMI, without independent verification by us.
The smelters and refiners listed by suppliers are included on Appendix A. Not all of the included smelters and refiners may have processed the necessary 3TG contained in our in-scope products, since most suppliers reported to us at a “company level” the 3TG contained in all of their products, not just those in the products they sold to us. Smelter and refiner country location is based on information published by the RMI, without independent verification by us.
Appendix B includes an aggregated list of countries of origin from which the reported facilities collectively source 3TGs, based on information provided through the CMRT data collection process, from direct smelter outreach and the RMAP. The 3TG in our in-scope products may not originate from all of the countries listed on Appendix B, and they may have sourced from other countries as well. Alternatively, or in addition, some of the smelters and refiners may have sourced from recycled or scrap sources.
Future Risk Mitigation Efforts
For 2021, BRP has taken, or intends to take, the following steps to mitigate the risk that the necessary 3TG in our in-scope products benefit armed groups in the Covered Countries:
| ● | Use the Service Provider to evaluate upstream sources of 3TG through its risk evaluation tools. |
| ● | Provide 3TG compliance information and training resources to suppliers. |
| ● | Encourage relevant suppliers to implement additional procedures to improve the completeness of their responses. |
| ● | Continue to include a 3TG compliance clause in new or renewed supplier contracts, as well as in the terms and conditions of each purchase order issued. |
These steps are in addition to the steps that we took in respect of 2020 described elsewhere in this report, which we intend to continue to take in respect of 2021 to the extent applicable.
APPENDIX A: SMELTER LIST
|
Metal
|
Smelter or Refiner
|
Smelter or Refiner Location
| ||
| Gold |
8853 S.p.A. | ITALY | ||
| Gold |
Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | ||
| Gold |
Advanced Chemical Company | UNITED STATES OF AMERICA | ||
| Gold |
African Gold Refinery | UGANDA | ||
| Gold |
Aida Chemical Industries Co., Ltd. | JAPAN | ||
| Gold |
Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | ||
| Gold |
Alexy Metals | UNITED STATES OF AMERICA | ||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | ||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | ||
| Gold |
AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | ||
| Gold |
Argor-Heraeus S.A. | SWITZERLAND | ||
| Gold |
Asahi Pretec Corp. | JAPAN | ||
| Gold |
Asahi Refining Canada Ltd. | CANADA | ||
| Gold |
Asahi Refining USA Inc. | UNITED STATES OF AMERICA | ||
| Gold |
Asaka Riken Co., Ltd. | JAPAN | ||
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | ||
| Gold |
AU Traders and Refiners | SOUTH AFRICA | ||
| Gold |
Augmont Enterprises Private Limited | INDIA | ||
| Gold |
Aurubis AG | GERMANY | ||
| Gold |
Bangalore Refinery | INDIA | ||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | ||
| Gold |
Boliden AB | SWEDEN | ||
| Gold |
C. Hafner GmbH + Co. KG | GERMANY | ||
| Gold |
C.I Metales Procesados Industriales SAS | COLOMBIA | ||
| Gold |
Caridad | MEXICO | ||
| Gold |
CCR Refinery - Glencore Canada Corporation | CANADA | ||
| Gold |
Cendres + Metaux S.A. | SWITZERLAND | ||
| Gold |
CGR Metalloys Pvt Ltd. | INDIA | ||
| Gold |
Chimet S.p.A. | ITALY | ||
| Gold |
Chugai Mining | JAPAN | ||
| Gold |
Daye Non-Ferrous Metals Mining Ltd. | CHINA | ||
| Gold |
Degussa Sonne / Mond Goldhandel GmbH | GERMANY | ||
| Gold |
Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES | ||
| Gold |
DODUCO Contacts and Refining GmbH | GERMANY | ||
| Gold |
Dowa | JAPAN | ||
| Gold |
DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold |
DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | ||
| Gold |
Eco-System Recycling Co., Ltd. East Plant | JAPAN | ||
| Gold |
Eco-System Recycling Co., Ltd. North Plant | JAPAN | ||
| Gold |
Eco-System Recycling Co., Ltd. West Plant | JAPAN | ||
| Gold |
Emerald Jewel Industry India Limited (Unit 1) | INDIA | ||
| Gold |
Emerald Jewel Industry India Limited (Unit 2) | INDIA | ||
| Gold |
Emerald Jewel Industry India Limited (Unit 3) | INDIA | ||
| Gold |
Emerald Jewel Industry India Limited (Unit 4) | INDIA | ||
| Gold |
Emirates Gold DMCC | UNITED ARAB EMIRATES | ||
| Gold |
Fidelity Printers and Refiners Ltd. | ZIMBABWE | ||
| Gold |
Fujairah Gold FZC | UNITED ARAB EMIRATES | ||
| Gold |
GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | ||
| Gold |
Geib Refining Corporation | UNITED STATES OF AMERICA | ||
| Gold |
Gold Coast Refinery | GHANA | ||
| Gold |
Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | ||
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | ||
| Gold |
Guangdong Jinding Gold Limited | CHINA | ||
| Gold |
Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | ||
| Gold |
Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | ||
| Gold |
Heimerle + Meule GmbH | GERMANY | ||
| Gold |
Heraeus Metals Hong Kong Ltd. | CHINA | ||
| Gold |
Heraeus Precious Metals GmbH & Co. KG | GERMANY | ||
| Gold |
Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
| Gold |
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | ||
| Gold |
HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | ||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | ||
| Gold |
International Precious Metal Refiners | UNITED ARAB EMIRATES | ||
| Gold |
Ishifuku Metal Industry Co., Ltd. | JAPAN | ||
| Gold |
Istanbul Gold Refinery | TURKEY | ||
| Gold |
Italpreziosi | ITALY | ||
| Gold |
JALAN & Company | INDIA | ||
| Gold |
Japan Mint | JAPAN | ||
| Gold |
Jiangxi Copper Co., Ltd. | CHINA | ||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | ||
| Gold |
JSC Uralelectromed | RUSSIAN FEDERATION | ||
| Gold |
JX Nippon Mining & Metals Co., Ltd. | JAPAN | ||
| Gold |
K.A. Rasmussen | NORWAY | ||
| Gold |
Kaloti Precious Metals | UNITED ARAB EMIRATES | ||
| Gold |
Kazakhmys Smelting LLC | KAZAKHSTAN | ||
| Gold |
Kazzinc | KAZAKHSTAN | ||
| Gold |
Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | ||
| Gold |
KGHM Polska Miedz Spolka Akcyjna | POLAND | ||
| Gold |
Kojima Chemicals Co., Ltd. | JAPAN | ||
| Gold |
Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold |
Kundan Care Products Ltd. | INDIA | ||
| Gold |
Kyrgyzaltyn JSC | KYRGYZSTAN | ||
| Gold |
Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | ||
| Gold |
L’azurde Company For Jewelry | SAUDI ARABIA | ||
| Gold |
Lingbao Gold Co., Ltd. | CHINA | ||
| Gold |
Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | ||
| Gold |
L’Orfebre S.A. | ANDORRA | ||
| Gold |
LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | ||
| Gold |
LT Metal Ltd. | KOREA, REPUBLIC OF | ||
| Gold |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | ||
| Gold |
Marsam Metals | BRAZIL | ||
| Gold |
Materion | UNITED STATES OF AMERICA | ||
| Gold |
Matsuda Sangyo Co., Ltd. | JAPAN | ||
| Gold |
MD Overseas | INDIA | ||
| Gold |
Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA | ||
| Gold |
Metallix Refining Inc. | UNITED STATES OF AMERICA | ||
| Gold |
Metalor Technologies (Hong Kong) Ltd. | CHINA | ||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | ||
| Gold |
Metalor Technologies (Suzhou) Ltd. | CHINA | ||
| Gold |
Metalor Technologies S.A. | SWITZERLAND | ||
| Gold |
Metalor USA Refining Corporation | UNITED STATES OF AMERICA | ||
| Gold |
Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | ||
| Gold |
Mitsubishi Materials Corporation | JAPAN | ||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
| Gold |
MMTC-PAMP India Pvt., Ltd. | INDIA | ||
| Gold |
Modeltech Sdn Bhd | MALAYSIA | ||
| Gold |
Morris and Watson | NEW ZEALAND | ||
| Gold |
Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | ||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | ||
| Gold |
Navoi Mining and Metallurgical Combinat | UZBEKISTAN | ||
| Gold |
NH Recytech Company | KOREA, REPUBLIC OF | ||
| Gold |
Nihon Material Co., Ltd. | JAPAN | ||
| Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | ||
| Gold |
Ohura Precious Metal Industry Co., Ltd. | JAPAN | ||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | ||
| Gold |
OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | ||
| Gold |
PAMP S.A. | SWITZERLAND | ||
| Gold |
Pease & Curren | UNITED STATES OF AMERICA | ||
| Gold |
Penglai Penggang Gold Industry Co., Ltd. | CHINA | ||
| Gold |
Planta Recuperadora de Metales SpA | CHILE | ||
| Gold |
Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | ||
| Gold |
PT Aneka Tambang (Persero) Tbk | INDONESIA | ||
| Gold |
PX Precinox S.A. | SWITZERLAND | ||
| Gold |
QG Refining, LLC | UNITED STATES OF AMERICA | ||
| Gold |
Rand Refinery (Pty) Ltd. | SOUTH AFRICA | ||
| Gold |
Refinery of Seemine Gold Co., Ltd. | CHINA | ||
| Gold |
REMONDIS PMR B.V. | NETHERLANDS | ||
| Gold |
Royal Canadian Mint | CANADA | ||
| Gold |
SAAMP | FRANCE | ||
| Gold |
Sabin Metal Corp. | UNITED STATES OF AMERICA | ||
| Gold |
Safimet S.p.A | ITALY | ||
| Gold |
SAFINA A.S. | CZECH REPUBLIC | ||
| Gold |
Sai Refinery | INDIA | ||
| Gold |
Samduck Precious Metals | KOREA, REPUBLIC OF | ||
| Gold |
Samwon Metals Corp. | KOREA, REPUBLIC OF | ||
| Gold |
Sancus ZFS (L’Orfebre, SA) | COLOMBIA | ||
| Gold |
SAXONIA Edelmetalle GmbH | GERMANY | ||
| Gold |
Sellem Industries Ltd. | MAURITANIA | ||
| Gold |
SEMPSA Joyeria Plateria S.A. | SPAIN | ||
| Gold |
Shandong Humon Smelting Co., Ltd. | CHINA | ||
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | ||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | ||
| Gold |
Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA | ||
| Gold |
Shirpur Gold Refinery Ltd. | INDIA | ||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. | CHINA | ||
| Gold |
Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | ||
| Gold |
Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | ||
| Gold |
Sovereign Metals | INDIA | ||
| Gold |
State Research Institute Center for Physical Sciences and Technology | LITHUANIA | ||
| Gold |
Sudan Gold Refinery | SUDAN | ||
| Gold |
Sumitomo Metal Mining Co., Ltd. | JAPAN | ||
| Gold |
SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | ||
| Gold |
Super Dragon Technology Co., Ltd | TAIWAN, PROVINCE OF CHINA | ||
| Gold |
T.C.A S.p.A | ITALY | ||
| Gold |
Tanaka Kikinzoku Kogyo K.K. | JAPAN | ||
| Gold |
The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | ||
| Gold |
Tokuriki Honten Co., Ltd. | JAPAN | ||
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. | CHINA | ||
| Gold |
Tony Goetz NV | BELGIUM | ||
| Gold |
TOO Tau-Ken-Altyn | KAZAKHSTAN | ||
| Gold |
Torecom | KOREA, REPUBLIC OF | ||
| Gold |
Umicore Precious Metals Thailand | THAILAND | ||
| Gold |
Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | ||
| Gold |
United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | ||
| Gold |
Valcambi S.A. | SWITZERLAND | ||
| Gold |
Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | ||
| Gold |
WIELAND Edelmetalle GmbH | GERMANY | ||
| Gold |
Yamakin Co., Ltd. | JAPAN | ||
| Gold |
Yokohama Metal Co., Ltd. | JAPAN | ||
| Gold |
Yunnan Copper Industry Co., Ltd. | CHINA | ||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | ||
| Tantalum |
Asaka Riken Co., Ltd. | JAPAN | ||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | CHINA | ||
| Tantalum |
D Block Metals, LLC | UNITED STATES OF AMERICA | ||
| Tantalum |
Exotech Inc. | UNITED STATES OF AMERICA | ||
| Tantalum |
F&X Electro-Materials Ltd. | CHINA | ||
| Tantalum |
FIR Metals & Resource Ltd. | CHINA | ||
| Tantalum |
Global Advanced Metals Aizu | JAPAN | ||
| Tantalum |
Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | ||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. | CHINA | ||
| Tantalum |
H.C. Starck Co., Ltd. | THAILAND | ||
| Tantalum |
H.C. Starck Hermsdorf GmbH | GERMANY | ||
| Tantalum |
H.C. Starck Inc. | UNITED STATES OF AMERICA | ||
| Tantalum |
H.C. Starck Ltd. | JAPAN | ||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
| Tantalum |
H.C. Starck Tantalum and Niobium GmbH | GERMANY | ||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | ||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum |
Jiangxi Tuohong New Raw Material | CHINA | ||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | ||
| Tantalum |
Jiujiang Tanbre Co., Ltd. | CHINA | ||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tantalum |
KEMET Blue Metals | MEXICO | ||
| Tantalum |
LSM Brasil S.A. | BRAZIL | ||
| Tantalum |
Metallurgical Products India Pvt., Ltd. | INDIA | ||
| Tantalum |
Mineracao Taboca S.A. | BRAZIL | ||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | ||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | ||
| Tantalum |
NPM Silmet AS | ESTONIA | ||
| Tantalum |
PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | ||
| Tantalum |
QuantumClean | UNITED STATES OF AMERICA | ||
| Tantalum |
Resind Industria e Comercio Ltda. | BRAZIL | ||
| Tantalum |
Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | ||
| Tantalum |
Taki Chemical Co., Ltd. | JAPAN | ||
| Tantalum |
Telex Metals | UNITED STATES OF AMERICA | ||
| Tantalum |
Ulba Metallurgical Plant JSC | KAZAKHSTAN | ||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. | CHINA | ||
| Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | ||
| Tin |
Alpha | UNITED STATES OF AMERICA | ||
| Tin |
An Vinh Joint Stock Mineral Processing Company | VIET NAM | ||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | ||
| Tin |
Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | ||
| Tin |
China Tin Group Co., Ltd. | CHINA | ||
| Tin |
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL | ||
| Tin |
CRM Synergies | SPAIN | ||
| Tin |
CV Ayi Jaya | INDONESIA | ||
| Tin |
CV Venus Inti Perkasa | INDONESIA | ||
| Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
| Tin |
Dowa | JAPAN | ||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | ||
| Tin |
EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin |
Estanho de Rondonia S.A. | BRAZIL | ||
| Tin |
Fenix Metals | POLAND | ||
| Tin |
Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA | ||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant | CHINA | ||
| Tin |
Gejiu Kai Meng Industry and Trade LLC | CHINA | ||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | ||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | ||
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | ||
| Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | ||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. | CHINA | ||
| Tin |
Jiangxi New Nanshan Technology Ltd. | CHINA | ||
| Tin |
Luna Smelter, Ltd. | RWANDA | ||
| Tin |
Ma’anshan Weitai Tin Co., Ltd. | CHINA | ||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | ||
| Tin |
Malaysia Smelting Corporation (MSC) | MALAYSIA | ||
| Tin |
Melt Metais e Ligas S.A. | BRAZIL | ||
| Tin |
Metallic Resources, Inc. | UNITED STATES OF AMERICA | ||
| Tin |
Metallo Belgium N.V. | BELGIUM | ||
| Tin |
Metallo Spain S.L.U. | SPAIN | ||
| Tin |
Mineracao Taboca S.A. | BRAZIL | ||
| Tin |
Minsur | PERU | ||
| Tin |
Mitsubishi Materials Corporation | JAPAN | ||
| Tin |
Modeltech Sdn Bhd | MALAYSIA | ||
| Tin |
Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin |
Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION | ||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | ||
| Tin |
O.M. Manufacturing Philippines, Inc. | PHILIPPINES | ||
| Tin |
Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | ||
| Tin |
Pongpipat Company Limited | MYANMAR | ||
| Tin |
Precious Minerals and Smelting Limited | INDIA | ||
| Tin |
PT Aries Kencana Sejahtera | INDONESIA | ||
| Tin |
PT Artha Cipta Langgeng | INDONESIA | ||
| Tin |
PT ATD Makmur Mandiri Jaya | INDONESIA | ||
| Tin |
PT Babel Inti Perkasa | INDONESIA | ||
| Tin |
PT Babel Surya Alam Lestari | INDONESIA | ||
| Tin |
PT Bangka Serumpun | INDONESIA | ||
| Tin |
PT Bukit Timah | INDONESIA | ||
| Tin |
PT Cipta Persada Mulia | INDONESIA | ||
| Tin |
PT Lautan Harmonis Sejahtera | INDONESIA | ||
| Tin |
PT Masbro Alam Stania | INDONESIA | ||
| Tin |
PT Menara Cipta Mulia | INDONESIA | ||
| Tin |
PT Mitra Stania Prima | INDONESIA | ||
| Tin |
PT Mitra Sukses Globalindo | INDONESIA | ||
| Tin |
PT Prima Timah Utama | INDONESIA | ||
| Tin |
PT Rajawali Rimba Perkasa | INDONESIA | ||
| Tin |
PT Rajehan Ariq | INDONESIA | ||
| Tin |
PT Refined Bangka Tin | INDONESIA | ||
| Tin |
PT Stanindo Inti Perkasa | INDONESIA | ||
| Tin |
PT Sukses Inti Makmur | INDONESIA | ||
| Tin |
PT Timah Nusantara | INDONESIA | ||
| Tin |
PT Timah Tbk Kundur | INDONESIA | ||
| Tin |
PT Timah Tbk Mentok | INDONESIA | ||
| Tin |
PT Tinindo Inter Nusa | INDONESIA | ||
| Tin |
Resind Industria e Comercio Ltda. | BRAZIL | ||
| Tin |
Rui Da Hung | TAIWAN, PROVINCE OF CHINA | ||
| Tin |
Soft Metais Ltda. | BRAZIL | ||
| Tin |
Super Ligas | BRAZIL | ||
| Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd. | VIET NAM | ||
| Tin |
Thaisarco | THAILAND | ||
| Tin |
Tin Technology & Refining | UNITED STATES OF AMERICA | ||
| Tin |
Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | ||
| Tin |
VQB Mineral and Trading Group JSC | VIET NAM | ||
| Tin |
White Solder Metalurgia e Mineracao Ltda. | BRAZIL | ||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tin |
Yunnan Tin Company Limited | CHINA | ||
| Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten |
A.L.M.T. Corp. | JAPAN | ||
| Tungsten |
ACL Metais Eireli | BRAZIL | ||
| Tungsten |
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL | ||
| Tungsten |
Artek LLC | RUSSIAN FEDERATION | ||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. | VIET NAM | ||
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten |
China Molybdenum Co., Ltd. | CHINA | ||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
CNMC (Guangxi) PGMA Co., Ltd. | CHINA | ||
| Tungsten |
Cronimet Brasil Ltda | BRAZIL | ||
| Tungsten |
Fujian Ganmin RareMetal Co., Ltd. | CHINA | ||
| Tungsten |
Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | ||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | ||
| Tungsten |
GEM Co., Ltd. | CHINA | ||
| Tungsten |
Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | ||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | ||
| Tungsten |
H.C. Starck Tungsten GmbH | GERMANY | ||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. | CHINA | ||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | ||
| Tungsten |
Hydrometallurg, JSC | RUSSIAN FEDERATION | ||
| Tungsten |
Japan New Metals Co., Ltd. | JAPAN | ||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | ||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | ||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | ||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | ||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
JSC “Kirovgrad Hard Alloys Plant” | RUSSIAN FEDERATION | ||
| Tungsten |
Kennametal Fallon | UNITED STATES OF AMERICA | ||
| Tungsten |
Kennametal Huntsville | UNITED STATES OF AMERICA | ||
| Tungsten |
KGETS Co., Ltd. | KOREA, REPUBLIC OF | ||
| Tungsten |
Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA | ||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
Masan Tungsten Chemical LLC (MTC) | VIET NAM | ||
| Tungsten |
Moliren Ltd. | RUSSIAN FEDERATION | ||
| Tungsten |
Niagara Refining LLC | UNITED STATES OF AMERICA | ||
| Tungsten |
NPP Tyazhmetprom LLC | RUSSIAN FEDERATION | ||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | ||
| Tungsten |
Unecha Refractory metals plant | RUSSIAN FEDERATION | ||
| Tungsten |
Wolfram Bergbau und Hutten AG | AUSTRIA | ||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | ||
| Tungsten |
Xiamen Tungsten Co., Ltd. | CHINA | ||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | ||
APPENDIX B: COUNTRIES OF ORIGIN
| Afghanistan |
Italy |
Suriname | ||
| Albania |
Ivory Coast |
Sweden | ||
| Angola |
Japan |
Switzerland | ||
| Argentina |
Kazakhstan |
Tanzania | ||
| Armenia |
Kenya |
Thailand | ||
| Australia |
Kyrgyzstan |
Turkey | ||
| Austria |
Laos |
Uganda | ||
| Belarus |
Liberia |
United Arab Emirates | ||
| Belgium |
Lithuania |
United Kingdom | ||
| Bermuda |
Luxembourg |
United States | ||
| Bolivia |
Madagascar |
Uzbekistan | ||
| Brazil |
Malaysia |
Vietnam | ||
| Bulgaria |
Mali |
Zambia | ||
| Burundi |
Mauritania |
Zimbabwe | ||
| Cambodia |
Mexico |
Suriname | ||
| Canada |
Mongolia |
Sweden | ||
| Central African Republic |
Morocco |
Switzerland | ||
| Chile |
Mozambique |
Tanzania | ||
| China |
Myanmar |
Thailand | ||
| Colombia |
Namibia |
|||
| Czech Republic |
Netherlands |
|||
| Djibouti |
New Zealand |
|||
| Dominican Republic |
Niger |
|||
| Democratic Republic of the Congo |
Nigeria |
|||
| Ecuador |
Papua New Guinea |
|||
| Egypt |
Peru |
|||
| England |
Philippines |
|||
| Estonia |
Poland |
|||
| Ethiopia |
Portugal |
|||
| Finland |
Republic of Korea |
|||
| France |
Russia |
|||
| Germany |
Rwanda |
|||
| Ghana |
Saudi Arabia |
|||
| Guinea |
Sierra Leone |
|||
| Guyana |
Singapore |
|||
| Hungary |
Slovakia |
|||
| India |
Slovenia |
|||
| Indonesia |
South Africa |
|||
| Ireland |
Spain |
|||
| Israel |
Sudan |
|||