UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
VARIAN MEDICAL SYSTEMS, INC.
(Exact name of the registrant as specified in its charter)
Delaware | 1-7598 | 94-2359345 | ||
(State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) | ||
3100 HANSEN WAY, PALO ALTO, CA | 94304-1030 | |||
(Address of principal executive offices) | (Zip code) |
John W. Kuo | (650) 493-4000 |
(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:
x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2018. |
Introduction:
Varian Medical Systems, Inc. is a Delaware corporation originally incorporated in 1948 as Varian Associates, Inc. Varian Medical Systems, Inc. and subsidiaries are referred to herein as the “Company.”
The Company is the world’s leading manufacturer of medical devices and software for treating cancer and other medical conditions with radiotherapy, stereotactic radiosurgery, stereotactic body radiotherapy, brachytherapy and proton therapy. Our mission is to combine the ingenuity of people with the power of data and technology to achieve new victories against cancer. To meet this challenge, we offer comprehensive solutions for fighting cancer.
Item 1.01. | Conflict Minerals Disclosure and Report |
The Company has concluded in good faith that during 2018,
a) | The Company has manufactured and contracted to manufacture products as to which “conflict minerals” (as defined in Section 1, Item1.01 (d) (3) of Form SD) are necessary to the functionality or production of such products. |
b) | Based on a “reasonable country of origin inquiry”, the Company knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Democratic Republic of the Congo or an adjoining country (collectively, sometimes referred to as the “Covered Countries”). Further the Company has determined that smelters and refiners identified as sourcing from the Covered Countries have been audited by the Responsible Minerals Initiative (RMI) and validated as “conformant to Responsible Minerals Assurance Process (RMAP).” |
The Company’s reasonable country of origin inquiry employed a combination of measures to determine whether the necessary conflict minerals in any of the Company’s products originated from the Covered Countries. The Company’s primary means of determining country of origin of necessary conflict minerals was by conducting a supply-chain survey with direct vendors using the Responsible Business Alliance/Global e-Sustainability Initiative (RBA/GeSI) Conflict Minerals Reporting Template (CMRT). The Company surveyed its direct vendors that were determined to have or had a high likelihood of containing tin, tantalum, tungsten or gold in their products. Additionally, the Company used the RMI website (http://www.responsiblemineralsinitiative.org/), smelter company websites, and other online tools to provide additional country of origin information.
Below is a summary of the information collected from all supply-chain survey respondents.
Metal | Countries of Origin | |
Australia, Austria, Bolivia, Brazil, China, Colombia, Ethiopia, Guinea, India, Madagascar, | ||
Tantalum | Malaysia, Nigeria, Russian Federation, Sierra Leone, Thailand, Mozambique, Burundi, | |
Rwanda, DRC* | ||
Australia, Bolivia, Brazil, China, Colombia, Guinea, Indonesia, Laos, Malaysia, Mongolia, | ||
Tin | Myanmar, Nigeria, Peru, Portugal, Russian Federation, Taiwan, Thailand, United Kingdom | |
of Great Britain and Northern Ireland, Venezuela, Burundi, Rwanda, Uganda, DRC* | ||
Australia, Bolivia, Brazil, China, Colombia, Guinea, Indonesia, Laos, Malaysia, Mongolia, | ||
Tungsten | Myanmar, Nigeria, Peru, United Kingdom of Great Britain and Northern Ireland, Russian | |
Federation, Taiwan, Thailand, United States of America, Burundi, Rwanda, DRC* | ||
Gold | Benin, Bolivia, Brazil, Chile, Colombia, Ecuador, Eritrea, Ghana, Guinea, Guyana, Mali, | |
Mauritania, Nicaragua, Niger, Peru, Swaziland, Togo, South Africa | ||
*The reported tantalum from the DRC came from 20 smelters, reported tin from DRC came from 6 smelters, and reported tungsten from DRC came from 4 smelters all of which have been audited and validated as “conformant” to the RMI RMAP protocol, which is internationally recognized for conflict free validation audits.
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, the Company has filed this Specialized Disclosure Form (Form SD) with the Securities and Exchange Commission and the associated Conflict Minerals Report and both documents are posted to a publicly available Internet site at https://www.varian.com/about-varian/citizenship.
Item 1.02. | Exhibits |
Conflict Minerals Report required by Item 1.01 is attached at Exhibit 1.01.
Item 2.01. | Exhibits |
1.01. | Conflict Minerals Report as required by Items 1.01 and 1.02. |
* * * * *
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.
VARIAN MEDICAL SYSTEMS, INC. | |
(Registrant) | |
/s/ John W. Kuo | |
By: John W. Kuo, Senior Vice President, | |
General Counsel and Corporate Secretary | May 30, 2019 |
Exhibit 1.01
Varian Medical Systems, Inc.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2018
This report for the year ended December 31, 2018 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”).
I. | Overview |
a. | Company Overview |
Varian Medical Systems Inc. (the “Company”) is a Delaware corporation originally incorporated in 1948 as Varian Associates, Inc. We are the world’s leading manufacturer of medical devices and software for treating cancer and other medical conditions with radiotherapy, stereotactic radiosurgery, stereotactic body radiotherapy, brachytherapy and proton therapy. Our mission is to combine the ingenuity of people with the power of data and technology to achieve new victories against cancer. To meet this challenge, we offer comprehensive solutions for fighting cancer.
b. | Product Overview |
We have two reportable operating segments: Oncology Systems and Proton Solutions (formerly known as Varian Particle Therapy).
Oncology Systems
Our Oncology Systems business designs, manufactures, sells and services hardware and software products for treating cancer with conventional radiotherapy, and advanced treatments such as fixed field intensity-modulated radiation therapy (“IMRT”), image-guided radiation therapy (“IGRT”), volumetric modulated arc therapy (“VMAT”), stereotactic radiosurgery (“SRS”), stereotactic body radiotherapy (“SBRT”) and brachytherapy as well as associated quality assurance equipment. Our software solutions also include informatics software for information management, clinical knowledge exchange, patient care management, practice management and decision-making support for comprehensive cancer clinics, radiotherapy centers and medical oncology practices.
Our hardware products include linear accelerators, brachytherapy afterloaders, treatment accessories, and quality assurance software; and our software products include information management, treatment planning, image processing, clinical knowledge exchange, patient care management, decision-making support and practice management software. Our products enable radiation oncology departments in hospitals and clinics to perform conventional radiotherapy treatments and advanced treatments such as IMRT, IGRT, VMAT, SRS and SBRT, as well as the treatment of patients using brachytherapy techniques, which involves the implementation or temporary insertion of radioactive sources. Our products are also used by surgeons and radiation oncologists to perform stereotactic radiosurgery. Our software products are also used in medical oncology departments to manage chemotherapy treatments.
Our software products help improve physician engagement and clinical knowledge-sharing, patient care management and clinical practice management. Our worldwide customers include university research and community hospitals, private and government institutions, healthcare agencies, physicians’ offices, medical oncology practices, radiotherapy centers and cancer care clinics.
Proton Solutions
Our Proton Solutions business develops, designs, manufactures, sells and services products and systems for delivering proton therapy, another form of external beam therapy using proton beams, for the treatment of cancer. Although proton therapy has been in clinical use for more than four decades, it has not been widely deployed due to high capital cost. Our current focus is bringing our expertise in X-ray beam radiation therapy to proton therapy to improve its clinical utility and to reduce its cost of treatment per patient, so that it is more widely accepted and deployed.
c. | Supply Chain Overview |
The Company’s supply chain is complex, and there are multiple tiers between the Company and the mines. The Company relies on the Company’s vendors to provide information on the origin of the conflict minerals (tantalum, tin, tungsten and gold, jointly referred to as “3TG”) contained in components that are included in the Company’s products. The Company validates vendor’s information as complete and reasonable using a check sheet, and any concerns are sent back to the vendor to address. Cumulatively the vendors reported the presence of all 3TG in the parts or products that make up the Company’s products. The Company does not collect data on the product level, and so cannot conclude which of the Company’s products contain which 3TG.
II. | Reasonable Country of Origin Inquiry (RCOI) and Due Diligence Measures |
For reporting year 2018, to identify and assess risk in the supply chain, the Company engaged those vendors who provide the substantial majority of the Company’s components and products of which the Company believes are likely to contain conflict minerals. The Company conducted a supply chain survey of these vendors, using the Responsible Minerals Initiative’s (RMI) Conflict Minerals Reporting Template (CMRT), to determine whether the necessary conflict minerals in components contained in the Company’s products were sourced responsibly. The survey requested vendors to identify smelters or refiners (SORs) and country of origin of the conflict minerals they provide to the Company. The Company used the RMI SOR Database and the RMI RCOI Database to establish country of origin. The Company found that a few of the smelters identified were sourcing from “conflict countries” but all these smelters were found to be conformant to the RMI Responsible Minerals Assurance Process (RMAP) process.
The Company’s due diligence measures have been designed to conform, in all material respects, to 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 Third Edition (OECD 2016) and related Supplements for tantalum, tin, tungsten and gold. In accordance with the OECD 5 Step Framework, the Company’s due diligence exercise included:
(1) | Establish strong company management systems |
The Company’s Conflict Minerals Team is organized by the Legal Department, includes key members of the Global Supply Chain Management Team and includes buyers in each business unit worldwide. The Global Supply Chain Team is represented by the VP, Global Supply Chain & Procurement and the Director, Global Supply Chain. Individuals from Trade Compliance, Finance, SEC Lawyers, Outside Counsel, and the Senior VP and General Counsel are brought into the Team to review and approve the SEC Filings. The Company’s requirements for vendor conflict minerals management are contained in the Company’s vendor training material and in the Supplier Code of Conduct. The Supplier Code of Conduct is posted on the Company’s external website and is referenced in POs and supplier contractual agreements. In short, the requirements are that suppliers follow the OECD Guidelines, provide a CMRT including smelter listing, follow up on risk concerns identified by the Company and aim toward becoming conflict free. The Conflict Minerals Team planned and executed the due diligence methods necessary to complete a RCOI, determined the risk associated with the use of conflict minerals, established steps to mitigate risks, and reported on supply chain due diligence. To assist in completing these due diligence actions, the Company became a member of the RMI (RMI member ID VARI), which is a consortium of companies who are working together to achieve the objective “to help companies make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas.”. The Company is an active participant in RMI teams, including the MRT, Due Diligence Practices and Plenary.
A key element of the RMI RMAP is the research of known smelters, audits of smelters, and publishing the results of this activity in databases which the Company uses to determine country of origin and assess risk in the supply chain. Specifically, the Company looks up country of origin of SORs using the RMI RCOI Database and uses significant data from the RMI SOR Full Database to assess SOR risk. Risk associated with suppliers are referred directly to each supplier. Risk associated with SORs are referred to the suppliers using those SORs.
To resolve grievances that suppliers or SORs may have, the Company uses the publicly available RMI Grievance Mechanism (GM). Suppliers are informed of this GM in the Company’s Conflict Minerals Vendor Training. This GM may be used for complaints against the Company, the RMI, the RMI RMAP, auditors used by the RMI, or other grievances related to conflict minerals. The grievances including corrective action are tracked and monitored by the RMI. Following is a link to the GM. http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/
(2) | Identify and assess risks in the supply chain |
The Company identified 248 vendors to be in-scope, based on the probability of 3TG in their products, and the Company requested a completed CMRT from all the in-scope vendors. The Company received 211 CMRTs, which represent approximately 85% of in-scope vendors, including the names and locations of SORs which process conflict minerals used in components provided by the Company’s vendors. The SOR information provided by the suppliers allowed the Company to determine the mine or country of origin of the conflict minerals. The Company evaluated the information collected, including subjecting the results to a detailed quality review check sheet. If discrepancies, errors, or omissions were identified, the response for that vendor was deemed incomplete and was returned for correction by the vendor. Approximately 75% of the CMRTs collected were acceptable as received or successfully corrected by the vendor and accepted by the Company. The Company reviewed and compared the responses with other information in the Company’s possession and, where appropriate, made further inquiries of the Company’s vendors.
The Company followed a defined escalation process for vendors that did not respond to the request for CMRT data. All in-scope vendors received a Request email. Those not responding in one week received a Reminder email and those not responding in 2 weeks received a Final Reminder email. Buyers were identified for each vendor. Any vendor not responding to the Final Reminder email were escalated to the buyer for further action. Approximately monthly meetings were held with buyer management to review data collection efforts and determine additional steps to be taken. Possible steps considered, and taken where possible, included negative feedback and consideration of termination of supplier contracts.
The result of this CMRT data collection effort is that the Company received submittals from 85% of in-scope vendors. The resulting list of SORs in the Company’s supply chain are found in Appendix A at the end of this document.
(3) | Design a Strategy to Respond to Identified Risk in the Supply Chain. |
The Company completed a risk assessment after collecting data from the in-scope vendors to identify Supply Chain risks incurred during the current reporting year. The Company has a process for determining risk using a set of standard risk factors. Supply Chain risks include risk associated with each vendor and the risk associated with each SOR identified by the vendors. RMI RCOI Data and RMI Smelter Database data is used extensively to determine appropriate risk mitigation factors.
Each vendor is assessed for risk factors that include whether they have conflict minerals policy’s, whether they have corrective management systems, whether they have overall conflict minerals management systems, and whether they have risky SORs in their supply chain. SOR risk falls primarily in 2 categories; 1) SORs without a valid RMI smelter ID who thus may not be a SOR and 2) SORs who are not conformant and not actively pursuing conformance to RMI RMAP.
For each risk factor a possible course of action is determined, and appropriate risk mitigation actions are provided to vendors. To mitigate risk factors the Company’s Procurement Organization puts pressure on suppliers to make improvements, including the possibility of qualifying an alternate supplier for the material. The result of these efforts has been year-over-year improvement in suppliers identifying actual smelters more accurately and percent of conformant smelters improving. The Company found that 80% of smelters were RMI RMAP conformant in 2018 which is an improvement from 79% in 2017.
A summary of results and identified risks are published in a year-end report for the reporting year which is presented to appropriate Varian management, including the VP, Global Supply Chain & Procurement and the Director, Global Supply Chain. The company’s Conflict Minerals Report (CMR) is reviewed by the Company’s Assistant General Counsel and Head of Global Trade, the Company’s SEC Lawyer and the Company’s Outside Counsel. The CMR is signed by the Company’s Senior VP and General Counsel. The risk factors identified during this process are subsequently managed by the Varian Risk Management System, and appropriately acted upon.
(4) | Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain. |
The RMI has a documented process called the RMAP which manages an independent, third-party audit to determine which SORs can be verified as having systems in place to responsibly source minerals in line with current global standards. The Company makes financial contributions (membership dues) to the RMI who manages an independent third-party audit program for 3TG SORs. The results of these audits are reviewed by the RMI and made publicly available for companies to reference. The Company uses the results of these independent third-party audits to determine the country of origin of SORs and identify which SORs have been audited and are conformant to RMI RMAP. In RY2018 the Company found that 80% of SORs were conformant The Company also cooperates with other members of the RMI to identify SORs that require additional investigation to determine whether they are an eligible SOR for the audit program, to supplement RCOI data to determine the country of origin of conflict minerals processed by the SOR, and whether the SOR is RMI RMAP conformant. The Company contributes thought leadership by participating in the activities of several RMI sub-committees including MRT, Due Diligence Processes and Plenary.
(5) | Report on supply chain due diligence. |
This Conflict Minerals Report constitutes the Company’s annual report on the Company’s 3TG due diligence, is filed with the SEC, and is available on the Company’s website at https://www.varian.com/about-varian/citizenship.
III. | Improvements Planned |
(1) | Continuously communicate the Company’s expectation on conflict minerals to vendors based on identified risks. In 2018, the Company posted a Supplier Code of Conduct that described Company’s policy and requirements relating to conflict minerals. This Supplier Code of Conduct will be communicated through purchase orders and supplier agreements in the coming year. |
(2) | Work with vendors who distribute other company’s products to obtain a list of manufacturers and CMRTs and improve the quality of RCOI data coming from these sources. During this reporting year (RY2018) many of these manufacturers were identified. It is expected that this action will result in improved results next reporting year. |
(3) | Work with vendors from countries outside the US SEC jurisdiction to improve the quality of data. The Company prepared a specific training document aimed at EU suppliers and the Company buyers that support them, explaining the Company needs the supplier’s support even though they are not directly obligated by US Regulations. |
(4) | Continue to improve the response rate of vendors |
IV. | Determination |
The Company relies on its vendors to obtain complete and accurate conflict minerals information and cannot guarantee the complete accuracy of all data. However, the Company worked in good faith to achieve a reasonable level of accuracy and completeness.
The Company’s due diligence identified 315 SORs which have been identified as SORs per the RMAP definitions by the RMI (see Appendix A). The RMAP is a set of protocols maintained and used by the RMI and member companies cooperating on due diligence and country of origin inquiry. The RMI has performed independent third-party audits on many of these SORs (80% are RMI RMAP Conformant) and is pursuing audits for the remaining SORs. The Company is working in coordination with other members of the RMI by providing the RMI the SORs used in the Company’s supply chain which require additional investigation or audit to confirm eligible SORs, country of origin, and conformance status.
Facilities Used to Process Necessary Conflict Minerals Used in In-Scope Products: While Company has conducted a thorough due diligence and worked closely with its vendors to survey the conflict minerals supply chain (as described above), Company is not able to identify with reasonable certainty all facilities used to process necessary conflict minerals used in in-scope products. However, based on the information acquired through the due diligence process, Company believes that the facilities that may have been used to process the 3TG necessary to the functionality of production of in-scope products include the SORs listed in Appendix A.
Information About Country of Origin of Necessary Conflict Minerals Used in In-Scope Products: While Company has conducted a thorough due diligence and worked closely with its vendors to survey the supply chain (as described above), Company is not able to determine with reasonable certainty the countries of origin of 3TGs used in all in-scope products or whether the 3TG in all in-scope products are from recycled or scrap sources.
However, Company has so far identified the countries of origin shown in the following table:
*The reported tantalum from the DRC came from 20 smelters, reported tin from DRC came from 6 smelters, and reported tungsten from DRC came from 4 smelters all of which have been audited and validated as “conformant” to the RMI RMAP protocol, which is internationally recognized for conflict free validation audits.
Information about Efforts to Determine Mine or Location of Origin: The description of Company’s due diligence exercise set forth above under the heading “Reasonable Country of Origin and Due Diligence Measures” covers Company’s efforts to determine the mine or location of origin with the greatest possible specificity.
Appendix A: Smelter and Refiner List
Metal | Smelter Name | Country | Smelter Id |
Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
Tantalum | Duoluoshan | CHINA | CID000410 |
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 Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
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 Janny New Material Co., Ltd. | CHINA | CID003191 |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited | CHINA | CID000917 |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | CID000973 |
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 | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
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 | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | CID002307 |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | CID000004 |
Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
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 | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | CID002536 |
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 Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
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 Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | CID002535 |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | CID002543 |
Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 |
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 |
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 LLC | 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 | Caridad | MEXICO | CID000180 |
Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
Gold | Chimet S.p.A. | ITALY | CID000233 |
Gold | Chugai Mining | JAPAN | CID000264 |
Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
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. | JAPAN | CID000425 |
Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | CID001322 |
Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
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 | HwaSeong CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
Gold | Italpreziosi | ITALY | CID002765 |
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 | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
Gold | LinBao Gold Mining | 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 | 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 (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 | Morris and Watson Gold Coast | AUSTRALIA | CID002866 |
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 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
Gold | Remondis Argentia B.V. | NETHERLANDS | CID002582 |
Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | CID002510 |
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 | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
Gold | Shandong Tarzan Bio-Gold Industry Co., Ltd. | CHINA | CID001619 |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
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 | 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 | 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 | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 |
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 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
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 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 |
Tin | CV Ayi Jaya | INDONESIA | CID002570 |
Tin | CV Dua Sekawan | INDONESIA | CID002592 |
Tin | CV Gita Pesona | INDONESIA | CID000306 |
Tin | CV United Smelting | INDONESIA | CID000315 |
Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
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 Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
Tin | Gejiu Jinye Mineral Company | CHINA | CID002859 |
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 | 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 Ketai Advanced Material Co., Ltd. | CHINA | CID000244 |
Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
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 Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 |
Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
Tin | PT Bangka Tin Industry | INDONESIA | CID001419 |
Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
Tin | PT Bukit Timah | INDONESIA | CID001428 |
Tin | PT DS Jaya Abadi | INDONESIA | CID001434 |
Tin | PT Eunindo Usaha Mandiri | INDONESIA | CID001438 |
Tin | PT Inti Stania Prima | INDONESIA | CID002530 |
Tin | PT Karimun Mining | INDONESIA | CID001448 |
Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
Tin | PT Lautan Harmonis Sejahtera | INDONESIA | CID002870 |
Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
Tin | PT O.M. Indonesia | INDONESIA | CID002757 |
Tin | PT Panca Mega Persada | INDONESIA | CID001457 |
Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 |
Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 |
Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | CID001477 |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | CID001482 |
Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
Tin | PT Tommy Utama | INDONESIA | CID001493 |
Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
Tin | Super Ligas | BRAZIL | CID002756 |
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 |
1 Since January 2017 nearly all Sudan-related transactions and activities that previously were prohibited by the Sudanese Sanctions Regulations (SSR) have been authorized under a general license. See 31 C.F.R. § 538.540. Even prior to that general authorization, the SSR did not prohibit imports into the United States of products containing Sudanese-origin raw materials that were incorporated into manufactured products or that otherwise were substantially transformed in a third country. See 31 C.F.R. § 538.410.
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