EX-1.01 2 ex-1012019conflictminerals.htm EX-1.01 Document
Exhibit 1.01
L.B. FOSTER COMPANY

Conflict Minerals Report
For the reporting period from January 1, 2019 to December 31, 2019
1. Introduction
This Conflict Minerals Report (the “Report”) of L.B. Foster Company (the “Company” or “we”) has been prepared pursuant to Rule 13p-1 and Form SD (collectively, the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2019 to December 31, 2019.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products for which the minerals specified in the Rule are necessary to the functionality or production of those products. The term “conflict minerals” is defined in Section 13(p) as (A) cassiterite, columbite-tantalite (coltan), wolframite, and their derivatives, as limited by the Rule, tin, tantalum, tungsten, and gold (collectively “3TG”); 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 (the “DRC”) or any adjoining country that shares an internationally recognized border with the DRC (collectively the “Covered Countries”).

As further described in this Report, the Company has determined that certain of its operations manufacture or contract to manufacture products that may contain 3TGs that are necessary to the functionality or production of such products.

L.B. Foster Company’s policy relating to 3TGs (the “Conflict Minerals Policy”) can be viewed on the Company’s website at https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.

1.1 Company Overview
L.B. Foster Company is a leading manufacturer and distributor of products and provider of services for transportation and energy infrastructure with locations in North America and Europe. The Company’s Rail Products and Services segment provides a full line of new and used rail, trackwork, and accessories to railroads, mines, and other customers in the rail industry. The Rail Products and Services segment also designs and produces insulated rail joints, power rail, track fasteners, concrete railroad ties, coverboards, and special accessories for mass transit and other rail systems. In addition, the Rail Products and Services segment engineers, manufactures, and assembles friction management products and railway wayside data collection, application systems, railroad condition monitoring systems and equipment, wheel impact load detection, fire protection systems, and management systems. The Company’s Construction Products segment sells and rents steel sheet piling, H-bearing pile, and other piling products for foundation and earth retention requirements. The Construction Products segment also sells bridge decking, bridge railing, structural steel fabrications, expansion joints, bridge forms, and other products for highway construction and repair. Lastly, the Construction Products segment produces precast concrete buildings and a variety of specialty precast concrete products. The Company’s Tubular and Energy Services segment provides pipe coatings for natural gas pipelines and utilities, upstream test and inspection services, precision measurement systems for the oil and gas market, and produces threaded pipe products for the oil and gas markets as well as industrial water well and irrigation markets.

1.2 Product Overview
This Report relates to the Company’s products (i) for which 3TGs are necessary to the functionality or production of that product; (ii) that were manufactured or contracted to be manufactured by the Company; and (iii) for which the manufacture was completed during calendar year 2019.

The Company does not directly purchase 3TGs, but it purchases components that it uses in the products it manufactures. The Company identified certain products it sells as possibly containing 3TGs that are necessary to the functionality or production of the products. These products include, but are not limited to, power rail, coverboards, mass transit and rail system accessories, certain friction management products, railway wayside data collection and management systems, expansion joints, precast concrete buildings, and precision measurement systems.

2. Reasonable Country of Origin Inquiry (“RCOI”)
The Company conducted a good faith RCOI regarding the 3TG in materials, components, and finished goods supplied to the Company, including the following steps (collectively, the “Program”):

Utilizing version 5.0 or higher of the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”), the Company engaged its 745 potential 3TG suppliers to collect information regarding the presence and sourcing of 3TG in its products.

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The Company retained a third party vendor (“Vendor”) to conduct supplier surveying via its platform that enables users to complete and track supplier communications. It also allows suppliers to upload completed CMRTs directly to the platform for assessment and management. Non-responsive suppliers were contacted a minimum of three times and were also subject to one on one communications by the Vendor, including offering assistance and further information to suppliers about the requirements of the Rule and the Program.

The Program continues to include automated data validation on all submitted CMRTs via the Vendor’s software. The goal of data validation is to increase the accuracy of submissions and identify any contradictory answers in the CMRT. All submitted forms are accepted and classified as valid or invalid so that data is still retained. Suppliers were contacted with regard to invalid forms and were encouraged to resubmit a valid form. As of May 14, 2020, six invalid supplier submissions were not yet corrected.

Of the suppliers who responded that they provide 3TG to the Company, many did not include the name of any verified Smelters or Refiners (together, “SOR” or “Smelters”). Based on the responses received from the Company’s RCOI, which included thousands of alleged SOR names, a list was compiled of 307 verified, unique SORs, including information regarding associated countries of origin (the “Unique Smelter List”). The Company performed due diligence on the SORs which appeared on the Unique Smelter List that were known or reasonably believed to have sourced from the Covered Countries or that had unknown sourcing.

Based on the responses to our RCOI, the Company is unable to determine that 3TGs necessary to the functionality or production of our products did not originate in the Covered Countries. Accordingly, the Company undertook the below due diligence measures to assess the practices of the SORs listed on its Unique Smelter List that were known or reasonably believed to have been sourced from the Covered Countries or that had unknown sourcing.

3. Due Diligence
3.1 Design of Due Diligence
The Company designed its due diligence process to be in conformity, in all material respects, with the due diligence framework in the Organization of Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition and related Supplements on tin, tantalum, and tungsten and on gold (collectively, the “OECD Guidance”). The OECD Guidance identifies five steps for due diligence that should be implemented and provides guidance as to how to achieve each step. We have developed our due diligence process to address each of these five steps.

3.1.1 Establish Strong Company Management Systems
Conflict Minerals Policy
As described above, we maintain a Conflict Minerals Policy, which is posted on our website at https://www.lbfoster.com/en/about/corporate-responsibility/conflict-mineral.

Internal Team and Training
The Company has established a management team responsible for the oversight of its conflict mineral assessment. The management team is overseen by the Chief Accounting Officer and a team of subject matter experts from relevant functions such as quality, supply chain, operations, finance, and legal. Senior management is briefed about the results of our due diligence efforts.

We, in cooperation with our Vendor, have developed internal training programs to educate persons within the Company who may potentially have contact with suppliers or other external parties regarding the Company’s conflict minerals compliance efforts. We review our training programs at least annually to make sure they are continuously aligned with current regulations, our initiatives, and the tools we use.

Control Systems
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other manufacturers in our industry and other sectors.

Our controls include our Legal and Ethical Conduct Policy, which outlines expected behaviors for all our employees.

Supplier Engagement
We rely on our direct suppliers to provide information on the origin of the 3TG contained in components and materials supplied to us, including sources of 3TG that are supplied to them from lower tier suppliers.
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In accordance with the OECD requirement to strengthen engagement with suppliers, we have, in cooperation with our Vendor, provided education to suppliers on the conflict minerals regulations as well as the expectations of the law. We continue to utilize our Vendor’s Learning Management System to provide all in-scope suppliers access to their Conflict Minerals Training Course. This training is tracked and evaluated based on completion. All suppliers are encouraged to complete all modules within this course.

In addition, we have leveraged the existing communications within the Company, specifically through our procurement personnel, to encourage supplier interactions with our Vendor as well for them to understand the need to complete the surveys. Feedback from this process has allowed us to enhance the training, to focus and adapt it to each user’s needs, and refine and clarify our supplier communications to ensure that our expectations are clear.

Grievance Mechanism
We have longstanding grievance mechanisms whereby employees and suppliers can report violations of the Company’s policies, including our Conflict Minerals Policy.

Records Maintenance
We have retained all relevant documentation from our RCOI and due diligence. Our existing policy related to relevant documentation of our conflict mineral compliance process requires that documentation be retained for a period of at least five years.

3.1.2 Identify and Assess Risk in Our Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and constant evolution of our supply chain, it is difficult for us to identify all vendors upstream from our direct suppliers.

We have identified 745 direct suppliers related to our in-scope products. We rely on suppliers whose materials or components contain 3TG to provide us with information about the source of 3TG contained in those materials or components. Our direct suppliers similarly rely upon information provided by their suppliers. Many of the largest suppliers either are Securities and Exchange Commission (“SEC”) registrants and subject to the Rule or are suppliers to other SEC registrants who are subject to the Rule.

Risks are identified automatically in the reporting system based on criteria established for supplier responses. The primary risk we identified with respect to the reporting period for the year ended December 31, 2019 related to the nature of the responses received. Many of the responses received provided data at a company or divisional level or were unable to specify the smelters or refiners used for 3TG in the components supplied to the Company. Additionally, many suppliers indicated that they received information regarding their supply chains from fewer than 75% of their suppliers and, therefore, they could not provide a comprehensive list of all smelters or refiners in their supply chains.

In accordance with OECD Guidelines, it is important to understand risk levels associated with conflict minerals in the supply chain. Smelters that are not certified as “conflict-free” by third party sources such as the Responsible Minerals Assurance Process (“RMAP”) pose a significant risk. Where a smelter is not identified as “conflict-free” by such sources, we rate the risk as high, medium, or low. This rating is based on various factors, including whether the SOR has been identified as a valid SOR and has an associated Smelter Identification Number (under the RMI, this is known as a Country Identification Number, or “CID”), whether there is known or plausible evidence of unethical or conflict sourcing, and the smelter’s geographic location, including proximity to the Covered Countries.

Based on these criteria the following facilities have been identified as being of highest concern to the Company’s supply chain:
African Gold Refinery - CID003185
Fidelity Printers and Refiners Ltd. - CID002515
Kaloti Precious Metals - CID002563
Sudan Gold Refinery - CID002567
Tony Goetz NV - CID002587

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

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Additionally, suppliers are evaluated on program strength (further assisting in identifying risk in the supply chain). Evaluating and tracking the strength of the program can assist in making key risk mitigation decisions as the program progresses. The criteria used to evaluate the strength of the supplier’s program are:
Existence of a policy in place that includes “conflict-free” sourcing;
Implementation of due diligence measures for “conflict-free” sourcing;
Whether the supplier reviews due diligence information received from their suppliers against your company’s expectations;
Whether the verification process includes corrective action management.

Based on how each supplier’s program meets these criteria, its program strength is identified as either strong or weak.

As part of our risk management plan and to ensure suppliers understand our expectations, we have, through our Vendor, provided video and written training on conflict minerals and the CMRT. This includes instructions on completing the form, and one-on-one email and phone discussions with supplier personnel.

In accordance with our Conflict Minerals Policy, we engage suppliers to establish an alternative source of 3TGs that do not support conflict in the Covered Countries, as provided in the OECD guidance, when we have reason to believe those suppliers may be supplying us with 3TGs from sources that may support conflict in the Covered Countries. If we are not satisfied with the results, we may then take steps to terminate a contract and find replacement suppliers.

Tracing materials back to their mine of origin is a complex aspect of responsible sourcing in our supply chain. We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TGs in our supply chain. This was done by adopting the methodology outlined by the RMI’s joint industry programs and outreach initiatives and requiring our suppliers to conform with the same standards to meet the OECD Guidelines, and report to us using the CMRT. Through this industry joint effort, we made a reasonable determination of the mines or locations of origin of the 3TGs in our supply chain. We also requested that all our suppliers support the initiative by following the sourcing initiative and working to align their declared sources with the “Known” and “Conflict-Free” lists of sourced metals.

3.1.3 Design and Implement a Strategy to Respond to Risks
In response to this risk assessment, the Company has an approved risk management plan through which the conflict minerals program is implemented, managed, and monitored. Updates to this risk assessment are provided to senior management.

As part of our risk management plan, to ensure suppliers understand our expectations, we have provided both video, recorded training, and documented instructions through our Vendor and responded to questions of suppliers requiring further clarification. We then provided each supplier a copy of the Responsible Business Alliance (“RBA”) reporting CMRT to complete for purposes of conflict minerals tracking. Furthermore, we reviewed responses to the reporting CMRT with suppliers where we needed clarification. As described in our Conflict Minerals Policy, we intend to engage any of our suppliers that we have reason to believe are supplying us with 3TG from sources that may support conflict in the Covered Countries to establish an alternative source of 3TG that does not support such conflict, as provided in the OECD guidance. We do not seek to embargo responsible sourcing of 3TGs from the DRC region or condone a general embargo on sourcing from the region.

3.1.4 Carry Out Independent Third Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chains
The Company does not have a direct relationship with conflict minerals smelters or refiners and thus, the Company does not perform direct audits of these entities in its supply chain. The Company relies on the efforts of the industry associations that administer independent third-party smelter and refinery audit programs and encourages suppliers with more direct relationships with smelters to participate in comparable due diligence validation activities.

3.1.5 Report on Supply Chain Due Diligence
This conflict minerals report is being filed with the SEC as an exhibit to our specialized disclosure report on Form SD and is available on our website at https://www.lbfoster.com.

4. Due Diligence Results
For the 2019 reporting year, the Company received complete and valid CMRTs from approximately 55% of its 745 suppliers surveyed. Most supplier responses received provided information at a company-wide level. We reviewed the responses against criteria we developed to determine which responses might require further engagement with our suppliers. Such criteria included
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untimely or incomplete responses as well as inconsistencies with the data reported. We have sent and continue to send additional requests to seek clarifications from suppliers to validate such data and obtain more complete and accurate responses.

4.1 Efforts to Determine Mine or Location of Origin
Due to our position in the supply chain, it is difficult for us to identify suppliers upstream from our direct suppliers and it is increasingly difficult to track 3TGs down to the mine or smelter level. Through continual follow-up, the Company requests additional status reports from direct suppliers. We work to validate the data obtained from suppliers by utilizing claims made by referenced refiners or smelters on their websites. For our position in the supply chain, we have determined to use this risk based approach to determine the origin of 3TGs in purchased products/materials.

4.2 Country of Origin
Based on the nature of information we received from our suppliers, we are unable to determine the country of origin of 3TG’s in our products.

4.3 Smelters or Refiners
For all responses that indicated a smelter, our Vendor compared the facilities listed to the list of smelters maintained by the RMI. If a supplier indicated that the facility was certified as “conflict-free,” our Vendor confirmed that the name was listed by RMI as a certified smelter. As of May 14, 2020, we have determined that 307 smelters or refiners are listed as certified smelters/refiners by RMI and we are working to validate the additional smelter/refiner entries from the submitted CMRTs. Schedule A lists the smelters and refiners that the suppliers we surveyed reported as being in their supply chains. We have not listed in Schedule A any smelters or refiners that we have not been able to validate.

Based on the smelter lists provided by suppliers via the CMRTs and publicly available information, we have identified 235 smelters that are certified “conflict-free.” In addition, 7 smelters are active in the Responsible Minerals Assurance Process and are or have committed to undergoing an audit.

From the responses that we received, we identified 65 smelters that potentially posed a risk. These concerns stem from the location of the facilities and claims that fall outside of the scope of the conflict minerals law. For suppliers that identified these smelters of concern on their CMRT, we created an escalation plan. These suppliers were contacted by our Vendor and the Company to evaluate whether these smelters could be connected to the Company’s products. The suppliers were asked to complete a product-level CMRT, rather than a company-level CMRT, to better identify the connection to products that they supply to the Company. Other suppliers were evaluated internally to determine if they were in fact still active suppliers. If not, they were taken out of scope.

5. Steps Taken to Mitigate Risk
In 2020, we have taken, or plan to take, the following steps to mitigate the risk that our necessary 3TGs benefit armed groups:
Continue to deploy our supply chain policy in accordance with OECD recommendations;
Further augment our reasonable country of origin and due diligence process with our vendors;
Increase our supplier response rate while increasing the validation of Smelter information by substituting suppliers that do not use 3TGs from suppliers that use 3TGs from the Covered Countries; and
Raise the awareness of suppliers to their use of “conflict-free” minerals.
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Cautionary Statement on Forward-Looking Statements
This Report contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and such forward-looking statements involve risks and uncertainties. These forward-looking statements are subject to various risks, uncertainties and other factors, including, among other matters, the Company’s suppliers’ responsiveness and cooperation with the Company’s due diligence efforts, the Company’s ability to identify and mitigate risks in its supply chain, whether smelters and refiners and other market participants responsibly source conflict minerals, and political and regulatory developments, whether in the Covered Countries, the United States, or elsewhere. The Company’s forward-looking statements in this Report are based on management’s current views, beliefs, and assumptions regarding future events. The Company undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise, except as required by the federal securities laws.
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Schedule A
The following lists the smelters/refiners identified by our suppliers as sources for their products that are certified by the “Responsible Minerals Assurance Process.”

The information that we received from much of our direct suppliers was at their company-wide level. Thus, the smelters or refiners identified by our direct suppliers contained in the tables below may include smelters or refiners that processed minerals that our direct suppliers supplied to their other customers, but not to us. We are unable to conclusively determine whether the smelters or refiners included in the tables below were used to process the 3TGs necessary to the functionality or production of our products during 2019. Because of this uncertainty, we are also unable to conclusively determine whether each of the countries of origin listed below were the country of origin of minerals in our products during 2019, and therefore we are unable to conclusively determine the source and chain of custody of those conflict minerals. In addition, the information that we received from our direct suppliers may yield inaccurate or incomplete information. For example, the information we received from our direct 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 RMI Responsible Minerals Assurance Process – RMAP and, thus, are not responsible for the quality of these audits or the audit findings.
MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
Gold8853 S.p.A.ITALYCID002763
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAfrican Gold RefineryUGANDACID003185
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsahi Refining USA Inc.UNITED STATES OF AMERICACID000920
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldC.I Metales Procesados Industriales SASCOLOMBIACID003421
GoldCaridadMEXICOCID000180
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDowaJAPANCID000401
GoldDS PRETECH Co., Ltd.KOREA, REPUBLIC OFCID003195
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424
GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldEmirates Gold DMCCUNITED ARAB EMIRATESCID002561
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldFujairah Gold FZCUNITED ARAB EMIRATESCID002584
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Coast RefineryGHANACID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldHwaSeong CJ CO., LTD.KOREA, REPUBLIC OFCID000778
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldItalpreziosiITALYCID002765
GoldJALAN & CompanyINDIACID002893
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldJSC UralelectromedRUSSIAN FEDERATIONCID000929
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKazzincKAZAKHSTANCID000957
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
GoldKGHM Polska Miedz Spolka AkcyjnaPOLANDCID002511
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKundan Care Products Ltd.INDIACID003463
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldL'Orfebre S.A.ANDORRACID002762
GoldLS-NIKKO Copper Inc.KOREA, REPUBLIC OFCID001078
GoldLT Metal Ltd.KOREA, REPUBLIC OFCID000689
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldMarsam MetalsBRAZILCID002606
GoldMaterionUNITED STATES OF AMERICACID001113
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236
GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPAMP S.A.SWITZERLANDCID001352
GoldPease & CurrenUNITED STATES OF AMERICACID002872
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldQG Refining, LLCUNITED STATES OF AMERICACID003324
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldREMONDIS PMR B.V.NETHERLANDSCID002582
GoldRoyal Canadian MintCANADACID001534
GoldSAAMPFRANCECID002761
GoldSabin Metal Corp.UNITED STATES OF AMERICACID001546
GoldSafimet S.p.AITALYCID002973
GoldSAFINA A.S.CZECH REPUBLICCID002290
GoldSai RefineryINDIACID002853
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldShirpur Gold Refinery Ltd.INDIACID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldTorecomKOREA, REPUBLIC OFCID001955
GoldUmicore Brasil Ltda.BRAZILCID001977
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211
TantalumCP Metals Inc.UNITED STATES OF AMERICACID003402
TantalumD Block Metals, LLCUNITED STATES OF AMERICACID002504
TantalumExotech Inc.UNITED STATES OF AMERICACID000456
TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Inc.UNITED STATES OF AMERICACID002548
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumPRG DooelNORTH MACEDONIA, REPUBLIC OFCID002847
TantalumQuantumCleanUNITED STATES OF AMERICACID001508
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumTelex MetalsUNITED STATES OF AMERICACID001891
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinAlphaUNITED STATES OF AMERICACID000292
TinAn Vinh Joint Stock Mineral Processing CompanyVIET NAMCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinDowaJAPANCID000402
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyVIET NAMCID002572
TinEM VintoBOLIVIA (PLURINATIONAL STATE OF)CID000438
TinEstanho de Rondonia S.A.BRAZILCID000448
TinFenix MetalsPOLANDCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINACID002849
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinHuichang Jinshunda Tin Co., Ltd.CHINACID000760
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinLuna Smelter, Ltd.RWANDACID003387
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMinsurPERUCID001182
TinMitsubishi Materials CorporationJAPANCID001191
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002573
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
TinPT Refined Bangka TinINDONESIACID001460
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinResind Industria e Comercio Ltda.BRAZILCID002706
TinRui Da HungTAIWAN, PROVINCE OF CHINACID001539
TinSoft Metais Ltda.BRAZILCID001758
TinSuper LigasBRAZILCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIET NAMCID002834
TinThaisarcoTHAILANDCID001898
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIET NAMCID002574
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.BRAZILCID003427
TungstenAsia Tungsten Products Vietnam Ltd.VIET NAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChina Molybdenum Co., Ltd.CHINACID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TungstenCP Metals Inc.UNITED STATES OF AMERICACID003448
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenFujian Jinxin Tungsten Co., Ltd.CHINACID000499
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGEM Co., Ltd.CHINACID003417
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINACID002579
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINACID003182
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xianglu Tungsten Co., Ltd.CHINACID002647
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenKGETS Co., Ltd.KOREA, REPUBLIC OFCID003388
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan Tungsten Chemical LLC (MTC)VIET NAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589
TungstenNPP Tyazhmetprom LLCRUSSIAN FEDERATIONCID003416
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIET NAMCID001889



MetalStandard Smelter NameSmelter Facility LocationRMI Audit Status
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044
TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFCID002843
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINACID002095