0000354908-17-000039.txt : 20170531 0000354908-17-000039.hdr.sgml : 20170531 20170531121205 ACCESSION NUMBER: 0000354908-17-000039 CONFORMED SUBMISSION TYPE: SD PUBLIC DOCUMENT COUNT: 2 13p-1 1.01 20161231 1.02 20161231 FILED AS OF DATE: 20170531 DATE AS OF CHANGE: 20170531 FILER: COMPANY DATA: COMPANY CONFORMED NAME: FLIR SYSTEMS INC CENTRAL INDEX KEY: 0000354908 STANDARD INDUSTRIAL CLASSIFICATION: SEARCH, DETECTION, NAVIGATION, GUIDANCE, AERONAUTICAL SYS [3812] IRS NUMBER: 930708501 STATE OF INCORPORATION: OR FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: SD SEC ACT: 1934 Act SEC FILE NUMBER: 000-21918 FILM NUMBER: 17880167 BUSINESS ADDRESS: STREET 1: 27700 SW PARKWAY AVENUE CITY: WILSONVILLE STATE: OR ZIP: 97070 BUSINESS PHONE: 5034983547 MAIL ADDRESS: STREET 1: 27700 SW PARKWAY AVENUE CITY: WILSONVILLE STATE: OR ZIP: 97070 SD 1 flir-formsd2016.htm SD Document



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM SD
SPECIALIZED DISCLOSURE REPORT


FLIR Systems Inc.
(Exact Name of Registrant as Specified in Its Charter)

Oregon
0-21918
93-0708501
(State or other jurisdiction of
incorporation or organization)
(Commission File Number)
(I.R.S. Employer
Identification No.)
 
 
 
27700 SW Parkway Avenue
Wilsonville, Oregon
(Address of principal executive offices)
 
97070
(Zip Code)


Todd M. DuChene, (503) 498-3318
(Name and telephone, 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, 2016.



Section 1 - Conflict Minerals Disclosure

ITEM 1.01 Conflict Minerals Disclosure and Report

The registrant’s Conflict Minerals Report for the year ended December 31, 2016 is attached hereto as Exhibit 1.01 and is available at http://www.flir.com/aboutflir/Supply_Chain.

ITEM 1.02 Exhibit

The registrant’s Conflict Minerals Report for the year ended December 31, 2016 is attached hereto as Exhibit 1.01.

Section 2 - Exhibits

ITEM 2.01 Exhibits

Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.


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.
 

 
 
 
 
 
FLIR Systems, Inc.
 
 
BY:
 
/s/ Todd M. DuChene
 
Todd M. DuChene
Senior Vice President, General Counsel
and Secretary

Date: May 31, 2017

 

 

 EX-1.01 2 flir-conflictmineralsreport.htm EXHIBIT 1.01 Exhibit

Exhibit 1.01
Conflict Minerals Report of FLIR Systems, Inc.
for the Year Ending December 31, 2016
The following should be read in conjunction with the definitions contained in the Securities and Exchange Commission (“SEC”) instructions to Form SD and related rules.
This report for the year ended December 31, 2016 is presented to comply with Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934 (the “Exchange Act”). The Rule was adopted by the SEC to implement reporting and disclosure requirements related to “conflict minerals” as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The term “conflict minerals” is defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten. For the purposes of this report, tin, tungsten, tantalum and gold will collectively be referred to herein as the 3TGs.The Rule requires each SEC registrant to provide certain disclosures about conflict minerals which are necessary to the functionality or production of products manufactured by such registrant.
Description of Company
FLIR Systems, Inc. (“FLIR,” the “Company,” “we,” “us,” or “our”) is a world leader in developing technologies that enhance perception and awareness. We design, develop, market, and distribute solutions that detect people, objects and substances that may not be perceived by human senses and improve the way people interact with the world around them. We bring these innovative technologies—which include thermal imaging systems, visible-light imaging systems, locater systems, measurement and diagnostic systems, and advanced threat-detection solutions—into daily life.
Founded in 1978, FLIR is a pioneer in advanced sensors and integrated sensor systems that enable the gathering, measurement, and analysis of critical information through a wide variety of applications in commercial, industrial, government, and consumer markets worldwide. We offer the broadest range of infrared, also known as thermal, imaging solutions in the world, with products that range from consumer-use thermal camera smartphone accessories to highly advanced aircraft-mounted imaging systems for military and search and rescue applications, with products in between serving a multitude of markets, customers, and applications.

Products Overview
We offer a wide array of sensor products, including infrared imaging cameras and systems, detector cores, CBRNE threat detectors, test and measurement instruments, radars, maritime electronics, and related products and solutions. We have evolved our product suite over time, expanding our reach into markets that are adjacent to thermal imaging, with the intent of expanding the adoption and channel development for thermal imaging technology. Examples of this evolution include our entrance into the visible-image security and surveillance market, the maritime electronics market, and the traffic monitoring and signal control market. We intend to continue this evolution as we continue to lower the cost of advanced sensing products. As the cost to own thermal technology continues to decline, the application of these sensors is expanding beyond imaging to areas such as data acquisition where thermal sensors can provide important data that can be used for a wide variety of applications. For further information about our products, please see Item 1 of our Annual Report on Form 10-K for the year ending December 31, 2016.
We conducted an analysis of our products and found that 3TGs can be found in many of the products described above. Therefore, substantially all the products that we manufacture are subject to the reporting obligations of the Rule.
Due Diligence Process
Reasonable Country of Origin Inquiry
With respect to 3TGs necessary to the functionality or production of products manufactured by us, or contracted by us to be manufactured, and required to be reported on Form SD for 2016, we conducted in good faith a country of origin inquiry that we believe was reasonably designed to determine whether any of the 3TGs originated in the

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Democratic Republic of the Congo (the “DRC”) or an adjoining country (each a “Covered Country” and, collectively, the “Covered Countries”) or were from recycled or scrap sources.
First, we identified all component suppliers and analyzed the bill of materials to identify any 3TGs that may be contained in the components provided by these suppliers. To achieve greater control and transparency over our supply chain and help identify the risk that our products contain any 3TGss that may be financing or benefiting armed groups in any Covered Country, we utilized a reporting template, the Conflict Minerals Reporting Template version 4.10 or higher (“CMRT”), and data gathered by the Electronic Industry Citizenship Coalition (“EICC”) and the Global E-Sustainability Initiative (“GeSI”). We identified and compiled a list of our suppliers from whom we needed to request information about their sourcing of 3TGs, and we requested that such identified suppliers provide us with information regarding their supply chain using the CMRT.

To gain insight into the country of origin, chain of custody and Conflict Status of 3TGs in our products, we relied primarily on the data reported by suppliers via the CMRT and the data from the Conflict Free Smelter Assessment Program (“CFSP”) of the Extractives Work Group of the EICC and GeSI. As described by EICC/GeSI, CFSP is a voluntary program in which an independent third party evaluates smelter and refiner procurement activities and determines whether the smelter or refiner demonstrated that all the materials it processed originated from conflict-free sources. Pursuant to our Conflict Smelter Policy and our Supplier Code of Conduct, we require all production level suppliers to complete the EICC forms or provide us a signed letter stating that the Supplier did not use any conflict minerals in its products.
Based on the information we received from our suppliers (as described below), we have reason to believe that some 3TGs contained in our products may have come from recycled or scrap sources and that some 3TGs may have originated in Covered Countries.
To the extent we determined from our suppliers’ responses that the 3TGs originated (or may have originated) in the Covered Countries and may not have been from recycled or scrap sources, we exercised further due diligence as required by the Rule. In exercising due diligence, we were not able to conclusively determine whether the 3TGs that originated (or may have originated) in the Covered Countries directly or indirectly financed or benefitted armed groups.
Despite our good faith effort to determine the countries of origin and chain of custody of the 3TGs contained in our products, we have concluded that our products remain “DRC conflict undeterminable.” We have reached this conclusion because we have been unable to determine the countries of origin of much of the 3TGs used in our products and, for the 3TGs whose country of origin has become known to us, we have been unable to determine whether such 3TGs directly or indirectly financed or benefited armed groups in the Covered Countries.
Our ability to determine the origin and chain of custody of 3TGs, and whether they directly or indirectly finance or benefit armed groups in any Covered Country (the “Conflict Status”), is limited. Our supply chain for 3TGs is complex. In most cases, we are several steps removed from the mining and smelting or refining of 3TGs. Out of necessity, we depend on information from suppliers that may themselves purchase 3TGs from persons other than the miner, smelter or refiner of 3TGs.
Due to the breadth and complexity of our products and respective supply chain, it will take time for many of our suppliers to verify the origin of all the 3TGs they procure. By using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard CFSI/CFSP program and continuing our outreach efforts with suppliers, we hope to continue to enhance the transparency within our supply chain regarding 3TGs.

Design of Due Diligence Measures
During 2016, we followed our management systems and due diligence procedures for conflict minerals, including 3TGs, that we established in 2013 (our “CM Process”) with the intent to conform with 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, Second Edition, 2013 (“OECD Guidance”).

2


OECD Guidance Step 1 – Establish Strong Internal Management Systems
 
 
 
 
 
 
•
 
We have adopted a Conflict Minerals Policy and Supplier Code of Conduct, which is available on our web site at www.flir.com/aboutflir/Supply_Chain.

 
•
 
We have an internal team comprised of those employees who have responsibility for SEC reporting and compliance, and a system to notify the team of information that is relevant to supply-chain due diligence. This team is led by our legal department.

 
•
 
We use a third-party service provider to assist us with supply-chain outreach and CMRT collection as well as with due diligence activities related to the same.

 
•
 
This year, we put a strong emphasis on supplier education and training. To accomplish this, we utilized our third-party service provider’s Learning Management System, to provide all in-scope suppliers access to a conflict minerals training course. This training is tracked by our third-party service provider and evaluated based on completion. All suppliers were encouraged to complete this course.

Our employees may anonymously report suspected violations of our Conflict Minerals Policy and Supplier Code of Conduct using our hotline which is hosted by EthicsPoint, available 24 hours a day, seven days a week.

We have adopted a policy to retain relevant documentation for a period of five years. Through our third-party service provider we retain all conflict minerals related documents, including supplier responses to CMRTs.  All of this information and findings from this process are stored in a database that can be audited by internal or external parties.

OECD Guidance Step 2 – Identify and Assess Risk in the Supply Chain
 
 
•
 
We require all suppliers to complete the EICC forms and in addition, some suppliers provide us with a signed letter stating that the supplier did not use any conflict minerals in its products sold to FLIR.
 
 
•
 
We requested that our suppliers that provide in-scope products or parts complete a CMRT to collect information about the smelters of 3TG used in our products.
 
 
•
 
We analyzed the suppliers’ template responses for completeness and internal consistency and followed up with suppliers in an effort to resolve any discrepancies or incomplete answers that we identified.
 
 
•
 
We relied on representations from suppliers that we considered reasonable. Our third-party service-provider also has automatic validation to flag CMRTs that contain conflicting responses or missing information. If such a CMRT was submitted, the supplier received an automated email response indicating the issues with the CMRT it provided.


3


 
•
 
In some instances, we worked with suppliers to contact the manufacturer of products supplied to them. We considered warning signs or other circumstances that, in our view, indicated responses to the CMRT were unreliable or that the conflict minerals came from a Covered Country and were not from recycled or scrap sources.


Each facility that meets the CFSI definition of a smelter or refiner of a 3TG mineral is assigned a risk of high, medium or low based on three scoring criteria:
1.    Geographic proximity to the DRC and Covered Countries;
2.    Conflict-Free Smelter Program (CFSP) audit status;
3.    Known or plausible evidence of unethical or conflict sourcing.

Based on the above criteria the following facilities have been identified as being of highest concern to the supply chain:
•    Tony Goetz NV - CID002587
•    Kaloti Precious Metals - CID002563
•    Phoenix Metals - CID002507 
•    Universal Precious Metals Refining Zambia - CID002854
•    Sudan Gold Refinery - CID002567

When these facilities were reported on a CMRT by one of our suppliers, risk mitigation activities were initiated. Through our third-party service provider along with the FLIR site supplier chain organizations, supplier’s that included any of the above facilities were immediately contacted and requested to take their own risk mitigation actions, including , review of products sold to FLIR and advise in writing if minerals from any of these smelters were used in FLIR products and, if so, work towards removal of the high-risk smelter(s) from their supply chain.
 
In accordance with OECD Due Diligence Guidance, risk mitigation will depend on each supplier’s specific context. Suppliers are given clear performance objectives within reasonable timeframes with clear expectations to remediate the issue with focus on elimination of these risks from the supply chain.  

OECD Guidance Step 3 – Design and Implement a Strategy to Respond to Identified Risks
 
 
•
 
Supplier terms and conditions require, whenever possible, compliance with our Supplier Code of Conduct which requires suppliers to certify as to whether supplied products are or are not free of conflict minerals. Our standard Supplier Terms and Conditions includes language which states Suppliers are required to adhere to our Conflict Minerals Policy.

 
•
 
We notify our direct suppliers of conflict minerals and each third-party manufacturer of our products that contain conflict minerals of our Conflict Minerals Policy.
 
 
•
 
We are in the process of cross-referencing the smelter and refiner information provided by suppliers this year with the data made available by the Conflict Free Smelter Program (“CFSP”) concerning the country of origin of the conflict minerals processed by those facilities and their Conflict Status.


4


OECD Guidance Step 4 – Carry Out Independent Third-Party Audits of Supply Chain Due Diligence at Identified Points in the Supply Chain
 
 
•
 
We rely on the CFSP initiative described above to identify smelters or refiners who are compliant with their assessment protocols, in satisfaction of the OECD framework requirements. Any smelters or refiners that were reported by our suppliers on their CMRTs who were not part of the CFSP, were contacted directly by our third-party service provider to encourage them to participate in the CFSP.
 
 
 
 
OECD Guidance Step 5 – Report on Supply Chain Due Diligence
 
 
•
 
We publicly report the results of our due diligence by publishing a Conflict Minerals Report annually. Our reports are accessible on our website at http://www.flir.com/aboutflir/Supply_Chain.
Due Diligence Results
Survey Results
We received information from approximately 79.15% of our suppliers, including information on materials supplied directly to us and contained in products that we contracted to have manufactured by third parties. All final CMRT submissions were reviewed and validated to ensure no inaccuracies or inconsistencies were found. Submissions from suppliers that were advised of such inaccuracies or inconsistencies but did not submit a new CMRT were not considered valid.
Smelters and Refiners
A majority of the responses we received from our suppliers provided aggregate data for their global supplier list on entity company-wide basis. However, some of the responses we received were incomplete or stated that the supplier had no knowledge regarding the source of the 3TGs in their products supplied to FLIR because they had merely purchased such products from a source further down the supply chain. Some suppliers that responded were able to identify smelters or refiners used by sub tier suppliers in their supply chains but not at a component level. However, their responses indicated that their own supply chain due diligence was less than complete. A minority of our suppliers provided product level CMRTs but were unable to tie individual smelters or refiners to the specific components that were delivered to us and are contained in our end products. We are therefore unable to definitively (i) determine whether any of the 3TGs reported by our suppliers were contained in our end products or (ii) validate which of the smelters and refineries included in the Conflict Minerals Reporting Templates of our suppliers actually supplied 3TGs for specific components used in our end products. Due to this, our list of smelters or refiners may contain more facilities than those that processed the 3TGs contained in our products.
We are continuing our review of all responses to correlate, identify and resolve the inconsistencies and missing information related to each supplier’s responses. Our continuing efforts to determine the mine or location of origin of the 3TGs follow the steps outlined in the OECD Guidance described above.
Risk Mitigation and Future Due Diligence Measures
We have taken, or will take, the following steps since the period covered by this Report to mitigate the risk that our 3TGs financed or benefitted armed groups in the Covered Countries:
 
 
•
 
Increased the response rate of suppliers to our information requests by continuing to refine our data collection process.

5


 
•
 
Implemented a new conflict minerals procedure to clarify our processes.

 
•
 
Identify suppliers that do not submit CMRTs and/or are non-compliant with our Conflict Mineral Policy and Supplier Code of Conduct and take action to cause such suppliers to respond and comply with our stated policies. If such suppliers fail to remediate non-compliance with our Conflict Mineral Policy Statement and Supplier Code of Conduct, we may take corrective action, up to and including replacing supply sources with conflict-free suppliers.

 
•
 
Encourage suppliers to increase the participation rate of smelters and refiners in the CFSP.

 
•
 
Require new suppliers to commit to comply with our Conflict Minerals Policy and Supplier Code of Conduct before placing any orders with the supplier.
 
 
•
 
Improve our supply chain due diligence by increasing awareness internally and externally regarding our Conflict Minerals Policy.

We will also continue to engage with the EICC and other key industry groups as part of a wider industry collaboration to develop best practices for the global supply chain and address the ongoing issue of conflict minerals.
In accordance with the Rule, a copy of this Report will be posted on the Company’s website at http://www.flir.com/aboutflir/Supply_Chain.







6



Appendix A


Mineral
Smelter Name
Smelter Location
Gold
Abington Reldan Metals, LLC
UNITED STATES
Gold
Advanced Chemical Company
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração
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
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
AU Traders and Refiners
SOUTH AFRICA
Gold
AURA-II
UNITED STATES
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
Caridad
MEXICO
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Métaux S.A.
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
Chugai Mining
JAPAN
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
DODUCO GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Elemetal Refining, LLC
UNITED STATES
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CHINA
Gold
Geib Refining Corporation
UNITED STATES
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Gold
Guangdong Jinding Gold Limited
CHINA

7


Gold
Gujarat Gold Centre
INDIA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
Heimerle + Meule GmbH
GERMANY
Gold
Heraeus Ltd. Hong Kong
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
Hwasung CJ Co., Ltd.
KOREA, REPUBLIC OF
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
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
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES
Gold
KGHM Polska Miedź Spółka Akcyjna
POLAND
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
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
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
Materion
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
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
Gold
Metalúrgica Met-Mex Peñoles 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

8


Gold
Morris and Watson Gold Coast
AUSTRALIA
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
TURKEY
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ögussa Österreichische 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
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
PX Précinox S.A.
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
Remondis Argentia B.V.
NETHERLANDS
Gold
Republic Metals Corporation
UNITED STATES
Gold
Royal Canadian Mint
CANADA
Gold
SAAMP
FRANCE
Gold
Sabin Metal Corp.
UNITED STATES
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
SAXONIA Edelmetalle GmbH
GERMANY
Gold
Schone Edelmetaal B.V.
NETHERLANDS
Gold
SEMPSA Joyería Platería S.A.
SPAIN
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
Singway Technology Co., Ltd.
TAIWAN
Gold
So Accurate Group, Inc.
UNITED STATES
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN
Gold
Sudan Gold Refinery
SUDAN
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
SungEel HiTech
KOREA, REPUBLIC OF
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

9


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 Brasil Ltda.
BRAZIL
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
United Precious Metal Refining, Inc.
UNITED STATES
Gold
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
AUSTRALIA
Gold
WIELAND Edelmetalle GmbH
GERMANY
Gold
Yamamoto Precious Metal 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
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CHINA
Tantalum
D Block Metals, LLC
UNITED STATES
Tantalum
Duoluoshan
CHINA
Tantalum
Exotech Inc.
UNITED STATES
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
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck GmbH Goslar
GERMANY
Tantalum
H.C. Starck GmbH Laufenburg
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES
Tantalum
H.C. Starck Ltd.
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.
UNITED STATES
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
KEMET Blue Powder
UNITED STATES

10


Tantalum
King-Tan Tantalum Industry Ltd.
CHINA
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
Mineração Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining & Smelting
JAPAN
Tantalum
Molycorp Silmet A.S.
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
Plansee SE Liezen
AUSTRIA
Tantalum
Plansee SE Reutte
AUSTRIA
Tantalum
Power Resources Ltd.
MACEDONIA
Tantalum
QuantumClean
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.
BRAZIL
Tantalum
RFH Tantalum Smeltry Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemicals
JAPAN
Tantalum
Telex Metals
UNITED STATES
Tantalum
Tranzact, Inc.
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CHINA
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES
Tin
An Thai Minerals Co., Ltd.
VIET NAM
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tin
Cooperativa Metalurgica de Rondônia Ltda.
BRAZIL
Tin
CV Ayi Jaya
INDONESIA
Tin
CV Dua Sekawan
INDONESIA
Tin
CV Gita Pesona
INDONESIA
Tin
CV Serumpun Sebalai
INDONESIA
Tin
CV Tiga Sekawan
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
CV Venus Inti Perkasa
INDONESIA
Tin
Dowa
JAPAN
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
Elmet S.L.U.
SPAIN
Tin
EM Vinto
BOLIVIA
Tin
Estanho de Rondônia S.A.
BRAZIL
Tin
Fenix Metals
POLAND
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA

11


Tin
Gejiu Jinye Mineral Company
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
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Jiangxi Ketai Advanced Material 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
Tin
Metallo-Chimique N.V.
BELGIUM
Tin
Mineração Taboca S.A.
BRAZIL
Tin
Minsur
PERU
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
Modeltech Sdn Bhd
MALAYSIA
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CHINA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgical S.A.
BOLIVIA
Tin
Phoenix Metal Ltd.
RWANDA
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 Bangka Prima Tin
INDONESIA
Tin
PT Bangka Tin Industry
INDONESIA
Tin
PT Belitung Industri Sejahtera
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT Cipta Persada Mulia
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Eunindo Usaha Mandiri
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Justindo
INDONESIA
Tin
PT Karimun Mining
INDONESIA
Tin
PT Kijang Jaya Mandiri
INDONESIA
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
PT Mitra Stania Prima
INDONESIA
Tin
PT O.M. Indonesia
INDONESIA
Tin
PT Panca Mega Persada
INDONESIA

12


Tin
PT Prima Timah Utama
INDONESIA
Tin
PT Refined Bangka Tin
INDONESIA
Tin
PT Sariwiguna Binasentosa
INDONESIA
Tin
PT Stanindo Inti Perkasa
INDONESIA
Tin
PT Sukses Inti Makmur
INDONESIA
Tin
PT Sumber Jaya Indah
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
Tin
PT Tinindo Inter Nusa
INDONESIA
Tin
PT Tommy Utama
INDONESIA
Tin
PT Wahana Perkit Jaya
INDONESIA
Tin
Resind Indústria e Comércio Ltda.
BRAZIL
Tin
Rui Da Hung
TAIWAN
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
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 Mineração Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
ACL Metais Eireli
BRAZIL
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin 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
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
H.C. Starck GmbH
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co.KG
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
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 Dayu Longxintai Tungsten Co., Ltd.
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA

13


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 Xiushui Xianggan Nonferrous Metals Co., Ltd.
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
Kennametal Fallon
UNITED STATES
Tungsten
Kennametal Huntsville
UNITED STATES
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
Moliren Ltd
RUSSIAN FEDERATION
Tungsten
Niagara Refining LLC
UNITED STATES
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
AUSTRIA
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA






Appendix B


Countries of origin include:

Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, DRC,  Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland,  Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, and Zimbabwe.



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